Ecological Impact Assessment (EcIA) for a proposed Strategic Housing Development at Belmayne P4, adjacent Churchwell Road and Churchwell Crescent, Belmayne, Dublin 13.
26th April 2021
Prepared by: Bryan Deegan (MCIEEM) of Altemar Ltd. On behalf of: Balgriffin Park Limited.
Altemar Ltd., 50 Templecarrig Upper, Delgany, Co. Wicklow. 00-353-1-2010713. [email protected] Directors: Bryan Deegan and Sara Corcoran Company No.427560 VAT No. 9649832U www.altemar.ie Document Control Sheet Client Balgriffin Park Limited Project Ecological Impact Assessment (EcIA) for a proposed Strategic Housing Development at Belmayne P4, adjacent Churchwell Road and Churchwell Crescent, Belmayne, Dublin 13. Report Ecological Impact Assessment Date 26th April 2021 Project No: Document Reference: Version Author Reviewed Date Draft 01 Bryan Deegan Jack Doyle 22nd April 2021 Draft 02 Bryan Deegan Jack Doyle 26th April 2021
Table of Contents Introduction ...... 4 Background ...... 4 Study Objectives ...... 4 Altemar Ltd...... 4 Project Description ...... 5 Drainage ...... 5 Ecological Assessment Methodology ...... 17 Desk Study ...... 17 Field Survey ...... 17 Consultation ...... 17 Spatial Scope and Zone of Influence ...... 17 Ecological Evaluation Criteria ...... 18 Impact Assessment Significance Criteria ...... 18 Results ...... 19 Proximity to Designated Conservation Sites ...... 19 Habitats and Species...... 26 4 Analysis of the Potential Impacts ...... 36 Introduction ...... 36 Direct Impacts ...... 36 Construction ...... 36 Operational Phase ...... 36 Indirect Impacts ...... 37 Avoidance and Remedial Measures ...... 37 Mitigation by Avoidance ...... 37 Storage/Use of Materials, Plant & Equipment ...... 37 Surface Water Protection During Construction (downstream impacts) ...... 38 Air & Dust ...... 38 Mitigation For Birds ...... 39 Mitigation for Mammals/Amphibians ...... 39 Mitigation for Flora ...... 39 Mitigation for Bats ...... 39 Cumulative Impacts ...... 40 Residual Impacts and Conclusion ...... 43 References ...... 44 Appendix 1 – Bat Fauna Survey ...... 46
Introduction Background Ecological Impact Assessment (EcIA) has been defined as ‘the process of identifying, quantifying and evaluating the potential impacts of defined actions on ecosystems or their components’ (Treweek, 1999). “The purpose of EcIA is to provide decision-makers with clear and concise information about the likely ecological effects associated with a project and their significance both directly and in a wider context. Protecting and enhancing biodiversity and landscapes and maintaining natural processes depends upon input from ecologists and other specialists at all stages in the decision-making and planning process; from the early design of a project through implementation to its decommissioning” (IEEM, 2010).
The following EcIA has been prepared by Altemar Ltd. at the request of Balgriffin Park Limited. The project relates to a proposed Strategic Housing Development at Belmayne P4, adjacent Churchwell Road and Churchwell Crescent, Belmayne, Dublin 13. Study Objectives The objectives of this EcIA are to:
1. Outline the project and any alternatives assessed; 2. Undertake a baseline ecological feature, resource and function assessment of the site and zone of influence; 3. Assess and define significance of the direct, indirect and cumulative ecological impacts of the project during its construction, lifetime and decommissioning stages; 4. Refine, where necessary, the project and propose mitigation measures to remove or reduce impacts through sustainable design and ecological planning; and 5. Suggest monitoring measures to follow up the implementation and success of mitigation measures and ecological outcomes.
The following guidelines have been used in preparation of this EcIA: • Guidelines on the information to be contained in Environmental Impact Statements (EPA, 2002); • Advice Notes on current practice in the preparation of EIS’s (EPA, 2003); • Institute of Ecology and Environmental Management Guidelines for EIA (IEEM, 2005).
A separate Appropriate Assessment Screening, in accordance with the requirements of Article 6(3) of the EU Habitats Directive, has been produced by Altemar to identify potential impacts of the development on Natura 2000 sites, Annex species or Annex habitats. In summary, there is no possibility of significant effects on any European Sites, features of interest or site-specific conservation objectives.
Altemar Ltd. Since its inception in 2001, Altemar has been delivering ecological and environmental services to a broad range of clients. Operational areas include: residential; infrastructural; renewable; oil & gas; private industry; Local Authorities; EC projects; and, State/semi-State Departments. Bryan Deegan, the managing director of Altemar, is an Environmental Scientist and Marine Biologist with 26 years’ experience working in Irish terrestrial and aquatic environments, providing services to the State, Semi-State and industry. He is currently contracted to Inland Fisheries Ireland as the sole “External Expert” to environmentally assess internal and external projects. He is also chair of an internal IFI working group on environmental assessment. Bryan Deegan (MCIEEM) holds a MSc in Environmental Science, BSc (Hons.) in Applied Marine Biology, NCEA National Diploma in Applied Aquatic Science and a NCEA National Certificate in Science (Aquaculture). Bryan Deegan carried out all elements of this Ecological Impact Assessment (EcIA).
4 Project Description Ballgriffin Park Limited intend to apply to An Bord Pleanála for permission for a strategic housing development at this site at Belmayne P4, adjacent Churchwell Road and Churchwell Crescent, Belmayne, Dublin 13. The development will consist of 260 no. apartment units within an urban block (with 6 cores) ranging in height up to 7 storeys. The unit mix will comprise of 108 no. 1-beds, 135 no. 2-beds, and 17 no. 3-beds (10 no. duplexes and 7 no. apartments), all with associated private balconies/terraces to the north/south/east/west elevations. The development will also include c.314 m2 of residential amenity facilities, c.2,945 m2 of communal open space at podium level, 199 no. car parking spaces (180 no. at undercroft level and 19 no. at surface level), and 400 no. cycle parking spaces (384 no. at undercroft level and 16 no. at surface level). Vehicular access to the undercroft parking area will be provided from Churchwell Crescent. All other site services and works to enable the development of the site will also be provided including bins, ESB substation and switchroom, plant areas, boundary treatments and landscaping. Drainage The following drainage strategy for the proposed project is outlined in the Infrastructure Design Report issued by DBFL Consulting Engineers.
Surface Water Drainage
In terms of existing services and utilities, the report outlines the following:
‘There are existing surface water sewers in close vicinity to the subject site. Existing 300mm surface water pipes are located along the western boundary. There is also an existing 375mm pipe along the eastern boundary in Churchwell Crescent. This sewer connects to the existing 600mm diameter surface water sewer in Churchwell Drive. The existing 600mm diameter pipe continues parallel to Parkside Boulevard and outfalls to the existing attenuation system. The outfall from the above attenuation system traverses to the north and discharge to the Mayne River.’
The surface water drainage strategy for the proposed development is as follows:
‘Roof Level:
As the first part of the treatment train, the SuDS features have been designed to prioritise interception and reduction of flow rates. The features that will be incorporated into the design are:
• Green roof – this will be an extensive type green roof with 80mm minimum construction depth. All necessary safety requirements will be designed and constructed to ensure safe maintenance can occur. The green roof will provide interception and reduction of flow rates at the beginning of the treatment train, providing source control for a large area of the development. Drawing 200004-DBFL-RD-SP-DR-C-1002shows the extents of the green roof. 70% of the roof area is proposed to be green roof. After surface water has passed through the Green Roof and blue podium, this will pass through to the surface water drainage network to the attenuation system. • Planters will also be installed on the roof terraces locally to reduce run off and allowing an element of interception to occur. • The hardstanding of roof terraces will drain to the underlying free draining aggregate and drainage board allowing the surface water to slowly percolate through the build-up before being discharged to the existing attenuation system to the north adjacent to Belmayne playground. • Impermeable roof areas will be sloped towards the green roof where possible to infiltrate water runoff through the green roof build up before draining to the attenuation system.
Podium Level (1st Floor):
• The proposed podiums of the development will predominantly be green landscaping which will act as a SuDs feature. Paved areas are provided for pedestrian access. Generally these paved areas will drain to the green landscaping and where not possible will drain to slot drains which outfall to the free draining aggregate and drainage board below. Refer to DBFL drawing 200004-DBFL-RD-SP-DR-C-1002 for extents. The green landscaped areas will constitute what is similar to an intensive green roof build-up, allowing surface water
5 run-off to slowly percolate through the vegetation, planters and build-up medium reducing the flows through the drainage network and also allowing vegetation to intercept run-off creating a reduction in run- off volumes before discharging to the drainage board below. • Paved areas will generally drain to the green areas or to slot drains which outfall to the free draining aggregate and drainage board below allowing a reduction in flows within the drainage network. • Once the rainwater has filtered through the various build-up mediums and drainage board, run-off will drain to gullies located at the structural slab level and then conveyed to the below ground system surface water drainage system.’
‘Ground Floor:
• The remaining areas surrounding the block and podiums will be green landscaped areas with no positive drainage to the surface water network.
The above source control SuDS measures being included within the design have been co-ordinated into the landscape design to ensure the surface water strategy is integral to the Landscape design. This has reduced the sites reliance on the existing attenuation system. Although due to the design storm event, and the need to incorporate climate change within the design a certain volume is still required within an attenuation tank to satisfied design requirements.
Runoff from the subject site will be attenuated in the existing attenuation system located500m north-east from the subject site. The existing attenuation system situated in open space was designed for Zone A and attenuates runoff from Catchment A and Catchment B, the subject site is located within Catchment B. Please refer to Appendix B for overall catchment attenuation strategy. The existing attenuation tank volume is4450m3and sized for the 1 in 100 year storm event plus climate change.
SuDS elements as described previously have decreased the reliance on attenuation system and using a co-ordinated multi element SuDS network to service the site.
The incorporation of the above SUDS elements will provide a sustainable manner in which to disperse surface water from the site and provide treatment of run-off and subsequent improvement of discharge quality.
Attenuation
Attenuation volumes have been calculated based on an allowable outflow runoff rate of2l/s/ha as required by Dublin City Council which equates to 2.44l/s for the site based on a catchment area of 1.31ha.’
‘The impermeable areas contributing to the attenuation volume have the following reduction factors applied:
Roof Level:
• Green roofs, the proposed build-up will be a mix of intensive and extensive type with 80mm minimum construction depth. The soil build-up will primarily absorb some of the initial run-off and once saturated will reduce the flow of run-off through the green roof medium. Therefore, a reduction of volume and flow rate will occur due to the presence of the green roof. Also, the green roof plant life will absorb a percentage of the run-off, further reducing volume that will drain to the surface water network. Therefore a 30% reduction factor has been applied. • Flat impermeable roof and roads, a 5% reduction of the surface area is applied to take account of run-off not collected and stored within the micro and macrotexture of the surfacing (various sources recommend different reduction coefficients e.g., IS EN752 recommends Runoff Coefficient (C for the Rational Method) of 0.9 to 1.0 for impermeable areas and steeply sloping roofs. For flatroofs it recommends 0.5 to 1.0 depending on area).
Podium Level & Ground Floor:
• Green areas over podium, a reduction factor of 30% has been applied. The deep soil build-up, vegetation and planting will primarily absorb a substantial amount of the initial run-off and once saturated will reduce the flow of run-off through the green roof medium.
6 • Paved Areas on podium and terraces will generally drain to the green areas or to slot drains which outfall to the free draining aggregate and drainage board below allowing a reduction in flows within the drainage network. Rainfall will ‘wet’ the initial surface of the paving allowing water to be stored in the micro and macrotexture of the surfacing and will be lost to evapotranspiration, as the run-off drains through the drainage board it will also ‘wet’ giving another volume reduction due to evapotranspiration and natural storage within the SuDS feature. A reduction in velocity will also occur as the aggregate used will slow the run-off at source, changing the input hydrograph which will ultimately reduce the peak inflow for attenuation calculations. A reduction factor of 5% has been applied for these reasons.
Providing an attenuation system within the subject site is not required as existing surface water drainage / attenuation / flood protection infrastructure has been constructed within the overall Belmayne Lands under parent permissions 0354/02 and 4315/03. These works include, entire floodplain works along the entire main Mayne River between Malahide Road and Hole in Wall Road, surface water drainage systems within the developed lands to the west of Belmayne Avenue and surface water attenuation provisions for the lands west of Belmayne Avenue in the form of a 4,450m3 attenuation tank mobilised by a ‘smart’ discharge manhole arrangement. All works completed to date have been agreed with and inspected by Dublin City Council Drainage Division as part of the normal compliance procedures. Existing attenuation tank provides attenuation volume for the subject site. Attenuation volume was calculated for the 100-year storm event using Micro Drainage source control software. Calculations show approx 500 m3 of storage volume is required for the subject site which can be accommodated in the existing attenuation system. We can confirm there is sufficient volume in the existing attenuation system to the northeast as the attenuation here was sized to cater for all of Catchment A and B, please refer to Overall Catchment Surface Water / Attenuation Strategy Drawing in Appendix B. We can confirm the attenuation system cater for the 100 year storm with a 20% allowance for climate change. A hydrobrake has been provided at surface water manhole S1 restricting outflow to 53.1 l/s.’
‘Surface Water Outfall
The runoff from the subject site will be attenuated in existing attenuation tank and then discharged to the Mayne River via the existing outfall.
To mitigate the risk of flood waters entering the attenuation system a “smart manhole” is proposed with a weir at the inlet to the tank to ensure that flood waters cannot enter the attenuation system and a positive head is maintained upstream of the hydrobrake.
Hydrobrake flow controllers are compatible for both free discharge and submerged outlet scenarios. Where the risk of a submerged outlet occurs hydrobrakes are fitted with a vent pipe which ensures that air is continuously available in the core of the vortex controller. Maintaining available air at this point ensures that the vortex motion within the hydrobrake is not inhibited by a submerged outlet condition. Therefore, it is proposed to install a vortex vent pipe.’
Foul Drainage
In terms of existing services and utilities, the report outlines the following:
‘There are existing foul water sewers in close proximity to the subject site on Churchwell Crescent to the east of the subject site. Another 225mm foul pipe runs along Churchwell Road to the north of the subject site.’ Further: ‘This ultimately discharges to the North Fringe Sewer. The North Fringe Sewer was constructed under the alignment of Parkside Boulevard in 2002.’
The foul drainage strategy for the proposed development is as follows:
‘The proposed foul drainage layout for the development will discharge from the under-croft to the existing 225mm diameter foul sewer on Churchwell Crescent to the east of the subject site. Incidental car park drainage will be collected in the under-croft before discharging to the foul sewer network as required by GDSDS.’
Flood Risk Assessment
The Flood Risk Assessment concluded that” the development meets the requirements of The FRA Guidelines and that the proposed development is appropriate to this flood zoning and a justification test is not required.”
7 Figure 1. Site outline and location on satellite imagery (ESRI) 8 Figure 2. Outline of Proposed Site 9 Figure 3. Proposed Site Location Map 10
Figure 4. Proposed Site Plan 11
Figure 5. Overall Landscape Masterplan
12
Figure 6. Proposed Site Sections 13 Figure 7. Proposed Foul and Surface Water Drainage Plan 14 Figure 8. Existing Attenuation Services. From Appendix B of DBFL’s Infrastructure Design Report, red rectangle reflects indicative site location. Please refer to architect’s drawing for an accurate red line boundary. 15 Existing attenuation structures and petrochemical interceptors designed to mitigate against downstream effects.
‘Class 1 full retention interceptor unit. Final specifications as per requirements of Dublin City Council’
Figure 9. Existing Attenuation Services at the River Mayne 16 Ecological Assessment Methodology Desk Study A desk study was undertaken to gather and assess ecological data prior to undertaking fieldwork elements. Sources of datasets and information included:
• The National Parks and Wildlife Service • National Biological Data Centre • Satellite, aerial and 6” map imagery • Bing Maps (ArcGIS)
A provisional desk-based assessment of the potential species and habitats of conservation importance was carried in April 2021. Altemar assessed the project, the proposed construction methodology and the operation of the proposed development. It was determined that the proposed development had the potential to impact beyond the site outline and into the surrounding environment through dust and surface water emissions, in the absence of mitigation measures. Field Survey A field survey was carried out by Altemar Ltd. on the 8th April 2021, following completion of the desk-based assessment. A site visit was carried out by Bryan Deegan in relation to flora, fauna and included a bat emergent survey. The survey was carried out in mild dry conditions and covered all the lands within the site outline and the land immediately outside the site. The bat survey also included the lands outside the proposed development site. The purpose of the field survey was to identify habitat types according to the Fossitt (2000) habitat classification and map their extent. In addition, more detailed information on the species composition and structure of habitats, conservation value and other data were gathered.
Survey Limitations
The field survey was carried out in April 2021. This is within the period for full species assessments of the flora, mammals in addition to bat surveys. Weather conditions were mild (10oC) and dry and allowed a bat detector survey to take place. April is also a good time to observe terrestrial mammal activity. It should be noted that good coverage of the site was possible. Consultation A request for data in relation to species of conservation interest was submitted to the National Parks and Wildlife Service (NPWS). Data of rare and threatened species were provided by NPWS within 5km of the proposed development and the information from these data is included in the EcIA. The National Biological Data Centre records were consulted for species of conservation significance. Spatial Scope and Zone of Influence IEEM (2006) defined the zone of influence as ‘the areas/resources that may be affected by the biophysical changes caused by activities associated with a project’. In order to define the extent of the study area for ecological assessment, all elements of the project were assessed and reviewed in order to identify the spatial scale at which ecological features could be impacted. Due to the self-contained nature and limited temporal/ geographical scale of the project, in addition to compliance requirements in relation to SUDS and on site discharges, significant impacts on biodiversity, would not extend beyond site outline, with the exception of mammal and avian activity where the proposed site may form part of a larger range. However, the project would involve excavations and construction, which may impact beyond the site through noise, dust and light impacts. Standard construction phase controls will need to be implemented to limit the potential impact of the proposed development into the surrounding environment. Zone of Influence (ZoI) is the ‘effect area’ over which changes could give rise to potentially significant impacts. The potential ZOI of the construction phase of the project was deemed to be within the site outline, nearby sensitive receptors located proximate to the site, such surrounding roads and unpaved areas and downstream of the surface water sewer connection. However, the ZOI of the operation of the proposed development would be the immediate area of the proposed development site.
17 Ecological Evaluation Criteria The ecological significance of the potential zone of influence was determined using the site evaluation scheme provided by the National Roads Authority Ecological Assessment Guidelines (Table 1) and impact matrix (Table 2). Table 1. Site Evaluation Scheme (NRA, 2006)
Rating Qualifying Criteria A Internationally important Sites designated (or qualifying for designation) as SAC* or SPA* under the EU Habitats or Birds Directives. Undesignated sites containing good examples of Annex I priority habitats under the EU Habitats Directive. Major salmon river fisheries. B Nationally important Sites or waters designated or proposed as an NHA* or statutory Nature Reserves. Undesignated sites containing good examples of Annex I habitats (EU Habitats Directive). Undesignated sites containing significant numbers of resident or regularly occurring populations of Annex II species under the EU Habitats Directive or Annex I species under the EU Birds Directive or species protected under the Wildlife (Amendment) Act 2000. Water bodies with major amenity fishery value. C High value, locally important (Regional, County & River Basin District) Sites containing semi‐natural habitat types with high biodiversity in a local context and a high degree of naturalness, or significant populations of locally rare species. Small water bodies with known salmonid populations or with good potential salmonid habitat. Sites containing any resident or regularly occurring populations of Annex II species under the EU Habitats Directive or Annex I species under the EU Birds Directive. D Moderate value, locally important (Regional, County & River Basin District) Sites containing some semi‐natural habitat or locally important for wildlife. Small water bodies with some coarse fisheries value or some potential salmonid habitat. Any water body with unpolluted water (Q‐value rating 4‐5). E Low value, locally important (Regional, County & River Basin District) Artificial or highly modified habitats with low species diversity and low wildlife value. Water bodies with no current fisheries value and no significant potential fisheries value.
Impact Assessment Significance Criteria As outlined in IEEM (2010) ‘assessment of impacts should be undertaken in relation to the baseline conditions within the zone of influence of the proposed development’. Impacts during site preparation, construction and occupation upon ecological receptors were quantified and characterised based on IEEM impact characterisation (IEEM, 2010) (Table 2) Following an evaluation of ecological receptors, the potential impact (positive, neutral or adverse) of the project on the ecological receptors was carried out based on the criteria in an impact significance matrix (based on NRA, 2009) (Table 3).
Table 2. Characterisation of the impacts
Direction of impact Whether the impact benefits (beneficial or positive) or detracts (adverse or negative) from net biodiversity value of the receptor; Magnitude level of severity of influence on the receptor; fragmentation and isolation of habitats; disturbance to species from noise, light or other visual stimuli Extent Area affected and percent of total area of the receptor; direct loss of wildlife habitats Complexity direct or indirect effect Reversibility reversible or irreversible Timing/ Frequency constant or intermittent and impact on critical life stages Duration measured time interval for the activity and predicted duration of the impact on receptor Confidence certain/near certain, probably, unlikely or extremely unlikely
18 Table 3. Impact matrix
Impact level Site Category A sites B sites C Sites D sites E Sites Internationally Nationally High value, Moderate Low value, important important Locally value, locally important locally important important Severe Any permanent Permanent adverse impacts impacts on a large part of a site Major Temporary Permanent Permanent adverse impacts on a impacts on a impacts on a large part of a small part of a large part of a site site site Moderate Temporary Temporary Permanent Permanent adverse impacts on a impacts on a impacts on a impacts on a small part of a large part of a small part of a large part of a site site site site Minor Temporary Temporary Permanent Permanent adverse impacts on a impacts on a impacts on a impacts on a small part of a large part of a small part of a large part of a site site site site Negligible No impacts No impacts No impacts No impacts Permanent impacts on a small part of a site Minor Permanent Permanent beneficial beneficial beneficial impacts on a impacts on a small part of a large part of a site site Moderate Permanent Permanent beneficial beneficial beneficial impacts on a impacts on a small part of a large part of a site site Major Permanent Permanent beneficial beneficial beneficial impacts on a impacts on a small part of a large part of a site site
Results Proximity to Designated Conservation Sites Designated conservation sites (National and international) within 15km of the proposed development are seen in Figures 10 to 12. It should be noted that the proposed development site is not within a designated conservation area.
The closest Natura 2000 sites are the Baldoyle Bay SAC and the Baldoyle Bay SPA, located 2.1 km and 2.5 km respectively from the subject site (Figures 10 and 11). The nearest national conservation site is the Baldoyle Bay pNHA, located 2.1 km from the site, and the Sluice River Marsh pNHA, located 2.4 km from the site (Figure 12). Baldoyle Bay is also Ramsar site. Details of Natura 2000 sites are seen in Table 4, while details on national conservation sites are in Table 5.
An AA screening accompanies this application. Following the implementation of mitigation measures, it was demonstrated, on the basis of the scientific information available, which was considered adequate to make the
19 conclusion, that the project alone or in combination with other plans or projects will not have an adverse effect on the integrity of Natura 2000 sites in view of their conservation objectives. Details of international conservation sites within 15km and national conservation sites within 15km of the proposed development are seen in Tables 4 and 5. All Natura 2000 sites beyond 15km do not have a direct hydrological pathway. Several Natura 2000 sites beyond 15 km are located beside or within the marine environment. Due to the distance and dilution and mixing in the marine environment, no significant effects would be seen on Natura 2000 sites beyond 15km.
Table 4. Distances to NATURA 2000 sites within 15km of the subject site
Site Code NATURA 2000 Site Distance Special Areas of Conservation IE0000199 Baldoyle Bay SAC 2.1 km IE0000206 North Dublin Bay SAC 2.8 km IE0000205 Malahide Estuary SAC 4.6 km IE0000202 Howth Head SAC 6.2 km IE0003000 Rockabill to Dalkey Island SAC 6.9 km IE0000210 South Dublin Bay SAC 6.9 km IE0002193 Ireland’s Eye SAC 7 km IE0000208 Rogerstown Estuary SAC 10.2 km IE0000204 Lambay Island SAC 13.1 km Special Protection Areas E0004016 Baldoyle Bay SPA 2.5 km IE0004006 North Bull Island SPA 2.5 km IE0004025 Malahide Estuary SPA 5.2 km IE0004117 Ireland’s Eye SPA 6.6 km IE0004024 South Dublin Bay and River Tolka Estuary SPA 6.9 km IE0004113 Howth Head Coast SPA 7.9 km IE0004015 Rogerstown Estuary SPA 10.4 km IE0004069 Lambay Island SPA 13 km IE0004172 Dalkey Island SPA 14.7 km Table 5. Distances to National conservation sites within 15km of the subject site
Conservation Site Name Conservation Type Distance Baldoyle Bay pNHA 2.1 km Sluice River Marsh pNHA 2.4 km North Dublin Bay pNHA 2.8 km Feltrim Hill pNHA 3.2 km Santry Demesne pNHA 4.2 km Malahide Estuary pNHA 4.6 km Howth Head pNHA 5.5 km Dolphins, Dublin Docks pNHA 6.8 km Ireland’s Eye pNHA 6.8 km South Dublin Bay pNHA 6.9 km Royal Canal pNHA 6.9 km Grand Canal pNHA 7.5 km Portraine Shore pNHA 9 km Rogerstown Estuary pNHA 10.2 km Booterstown Marsh pNHA 10.2 km Dalkey Coastal Zone and Killiney Hill pNHA 12.6 km Liffey Valley pNHA 12.8 km Lambay Island pNHA 13.1 km
20 Figure 10. Special Areas of Conservation located within 15km of the proposed development
21 Figure 11. Special Protection Area located within 15km of the proposed development
22
Figure 12. pNHAs within 15 km of the proposed development
23
Figure 13. Watercourses within 1 km of the proposed development 24
Figure 14. Waterbodies and pNHAs within 5 km of the development 25 Habitats and Species A site assessment was carried out on the 8th April 2021. Habitats within the proposed site were classified according to Fossitt (2000) (Figure 12) based on the 8th April 2021 field survey.
Figure 15. Fossitt (2000) Map (See the Habitat descriptions below for an explanation of the Fossitt Codes) 26 BL3- Buildings and artificial surfaces) No buildings are present within the site outline. Roads, paths and carparking areas consisting of tarmac are present on site and make up approximately 20% of the site. No flora or fauna of conservation importance were noted in these areas.
Plate 1. Picture of road bordering the eastern portion of the site.
ED3 Recolonising Bare Ground As can be seen from figure 15 the vast majority of the proposed development site consists of an area of Recolonising Bare Ground. Based upon an examination of historic satellite imagery (Google Historic Imagery and Geohive ) significant works and full site clearance was observed until July 2013. Since 2013 the activity appears to have been localised on the eastern portion of while vegetation is recolonising spoil heaps in the centre and the west of the site. This site is being recolonised by opportunistic species such as nettle (Urtica dioica), rape (Brassica napus), dandelion (Taraxacum spp.), red valerian (Centranthus ruber), bramble (Rubus fruticosus agg.), colt’s foot (Tussilago farfara), pampas grass (Cortaderia selloana), wild teasel (Dipsacus fullonum), creeping buttercup (Ranunculus repens), hedge bindweed (Calystegia sepium), clover (Trifolium spp.), cow parsley (Anthriscus sylvestris), daisy (Bellis perennis), plantains (Plantago spp.), thistles (Cirsium arvense & C. vulgare), docks (Rumex spp.), cat’s-ear (Hypochaeris radicata), pineappleweed (Matricaria discoidea), butterfly-bush (Buddleja spp.`), rushes (Juncus sp), wild carrot (Daucus carota), lesser trefoil (Trifolium dubium), ragwort (Senecio sp.), rosebay willowherb (Chamaenerion angustifolium) and field forget-me-not (Myosotis arvensis). Of note, approximately 2m2 of three-cornered garlic/leek (Allium triquetrum) was noted in the central area of the site. This is a medium impact species listed on the third Schedule of regulation 49 & 50 in the European Communities (Birds and Natural Habitats) Regulations 2011. An invasive species management plan for the three-cornered garlic/leek (Allium triquetrum) accompanies this submission.
27
Plate 2. ED3-Recolonising bare Ground
Plate 3. ED3-Recolonising bare Ground
WL1- Hedgerow The northern portion of the main development site is bordered by a tall Griselinia hedge and a narrow strip of grassland. Herbicide use is evident in this area.
28
Plate .4. Griselinia hedge and narrow grassland area to the north of the site.
Evaluation of Habitats The proposed development site is primarily recolonising bare ground with a Griselinia hedge to the north. No habitats of conservation significance were noted within the site outline.
Plant Species The plant species encountered at the various locations on site are detailed above. No rare or plant species of conservation value were noted during the field assessment. Records of rare and threatened species from NBDC and NPWS were examined. No rare or threatened plant species were recorded within the proposed development site.
Invasive Plant species Approximately 2m2 of three-cornered garlic/leek (Allium triquetrum) was noted in the central area of the site. This is a medium impact species listed on the third Schedule of regulation 49 & 50 in the European Communities (Birds and Natural Habitats) Regulations 2011. An invasive species management plan for the three-cornered garlic/leek (Allium triquetrum) accompanies this submission. No other invasive plant species that could hinder removal of soil from the site during groundworks, such as Japanese knotweed, giant rhubarb, Himalayan balsam or giant hogweed were noted on site.
Fauna Records of rare and threatened species from NBDC and NPWS were examined. No rare or threatened faunal species were recorded within the proposed site.
Bats A bat survey was carried out and the results of the survey are seen in Appendix I. There were no seasonal or climatic constraints as survey was undertaken within the active bat season in good weather conditions with daytime temperatures of 10°C after dark. Winds were very light and there was no rainfall. There are no trees or buildings on site that could form a bat roost. A detector survey was carried out with a Echo Meter Touch Pro bat detector. Foraging activity was not noted on site.
Amphibians/Reptiles The common frog (Rana temporaria) was not observed on site. There are no features within the site boundary that could be important to frogs.
29 Terrestrial Mammals No mammal activity was noted on site.
Birds The bird species noted on site are seen in Table 6. The site is primarily recolonising bare ground and would not be seen as a habitat that would be used by wintering birds.
Table 6: Bird Species noted in the vicinity of the proposed development.
Common Name Scientific Name Pied wagtail Motacilla alba yarrellii Wren Troglodytes troglodytes Robin Erithacus rubecula Blackbird Turdus merula Blue tit Parus caeruleus Magpie Pica pica Mistle Thrush. Turdus viscivorus Wood Pidgeon Columba palumbus
Assessment of Biodiversity Records
The National Biodiversity Data Centre’s online viewer was consulted in order to determine the extent of biodiversity and/or species of interest in the area. First, an assessment of the site-specific area was carried out by generating a report based on the site outline, however it recorded no species of interest in the site area. Following this a 2 km2 grid, reference number O24A, based on the Ordnance Survey Ireland (OSI) Irish Grid classification system was assessed. Table 7 provides a list of all species recorded in the species reports generated for this grid that possess a specific designation, such as Invasive Species or Protected Species. These include marine and coastal species.
Table 6. Table of species, NBDC
Date of Species Name Designation Record 14/05/2001 Arctic Tern (Sterna paradisaea) Protected Species: Wildlife Acts || Protected Species: EU Birds Directive || Protected Species: EU Birds Directive >> Annex I Bird Species || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 31/12/2011 Barn Swallow (Hirundo rustica) Protected Species: Wildlife Acts || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 04/01/2003 Bar-tailed Godwit (Limosa Protected Species: Wildlife Acts || Protected Species: EU Birds lapponica) Directive || Protected Species: EU Birds Directive >> Annex I Bird Species || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 04/01/2003 Black Guillemot (Cepphus grylle) Protected Species: Wildlife Acts || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 31/12/2011 Black-headed Gull (Larus Protected Species: Wildlife Acts || Threatened Species: Birds of ridibundus) Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Red List 03/01/2003 Black-legged Kittiwake (Rissa Protected Species: Wildlife Acts || Threatened Species: OSPAR tridactyla) Convention || Threatened Species: Birds of Conservation Concern
30 || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 04/01/2003 Black-tailed Godwit (Limosa Protected Species: Wildlife Acts || Threatened Species: Birds of limosa) Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 31/12/2011 Brent Goose (Branta bernicla) Protected Species: Wildlife Acts || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 31/12/2011 Common Coot (Fulica atra) Protected Species: Wildlife Acts || Protected Species: EU Birds Directive || Protected Species: EU Birds Directive >> Annex II, Section I Bird Species || Protected Species: EU Birds Directive >> Annex III, Section II Bird Species || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 04/01/2003 Common Goldeneye (Bucephala Protected Species: Wildlife Acts || Protected Species: EU Birds clangula) Directive || Protected Species: EU Birds Directive >> Annex II, Section II Bird Species || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 04/01/2003 Common Greenshank (Tringa Protected Species: Wildlife Acts || Threatened Species: Birds of nebularia) Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 03/01/2003 Common Guillemot (Uria aalge) Protected Species: Wildlife Acts || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List Common Kestrel (Falco Protected Species: Wildlife Acts || Threatened Species: Birds of 31/12/2011 tinnunculus) Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 31/12/2011 Common Linnet (Carduelis Protected Species: Wildlife Acts || Threatened Species: Birds of cannabina) Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 31/07/1991 Common Pheasant (Phasianus Protected Species: Wildlife Acts || Protected Species: EU Birds colchicus) Directive || Protected Species: EU Birds Directive >> Annex II, Section I Bird Species || Protected Species: EU Birds Directive >> Annex III, Section I Bird Species 04/01/2003 Common Pochard (Aythya Protected Species: Wildlife Acts || Protected Species: EU Birds ferina) Directive || Protected Species: EU Birds Directive >> Annex II, Section I Bird Species || Protected Species: EU Birds Directive >> Annex III, Section II Bird Species || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 03/01/2003 Common Redshank (Tringa Protected Species: Wildlife Acts || Threatened Species: Birds of totanus) Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Red List 04/01/2003 Common Scoter (Melanitta Protected Species: Wildlife Acts || Protected Species: EU Birds nigra) Directive || Protected Species: EU Birds Directive >> Annex II, Section II Bird Species || Protected Species: EU Birds Directive >> Annex III, Section III Bird Species || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Red List 04/01/2003 Common Shelduck (Tadorna Protected Species: Wildlife Acts || Threatened Species: Birds of tadorna) Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 31 04/01/2003 Common Snipe (Gallinago Protected Species: Wildlife Acts || Protected Species: EU Birds gallinago) Directive || Protected Species: EU Birds Directive >> Annex II, Section I Bird Species || Protected Species: EU Birds Directive >> Annex III, Section III Bird Species || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 31/12/2011 Common Starling (Sturnus Protected Species: Wildlife Acts || Threatened Species: Birds of vulgaris) Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 31/07/1991 Common Swift (Apus apus) Protected Species: Wildlife Acts || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 31/12/2011 Common Wood Pigeon Protected Species: Wildlife Acts || Protected Species: EU Birds (Columba palumbus) Directive || Protected Species: EU Birds Directive >> Annex II, Section I Bird Species || Protected Species: EU Birds Directive >> Annex III, Section I Bird Species 04/01/2003 Dunlin (Calidris alpina) Protected Species: Wildlife Acts || Protected Species: EU Birds Directive || Protected Species: EU Birds Directive >> Annex I Bird Species || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 03/01/2003 Eurasian Curlew (Numenius Protected Species: Wildlife Acts || Protected Species: EU Birds arquata) Directive || Protected Species: EU Birds Directive >> Annex II, Section II Bird Species || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Red List 31/12/2011 Eurasian Oystercatcher Protected Species: Wildlife Acts || Threatened Species: Birds of (Haematopus ostralegus) Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 04/01/2003 Eurasian Teal (Anas crecca) Protected Species: Wildlife Acts || Protected Species: EU Birds Directive || Protected Species: EU Birds Directive >> Annex II, Section I Bird Species || Protected Species: EU Birds Directive >> Annex III, Section II Bird Species || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 04/01/2003 Eurasian Wigeon (Anas Protected Species: Wildlife Acts || Protected Species: EU Birds penelope) Directive || Protected Species: EU Birds Directive >> Annex II, Section I Bird Species || Protected Species: EU Birds Directive >> Annex III, Section II Bird Species || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 04/01/2003 European Golden Plover Protected Species: Wildlife Acts || Protected Species: EU Birds (Pluvialis apricaria) Directive || Protected Species: EU Birds Directive >> Annex I Bird Species || Protected Species: EU Birds Directive >> Annex II, Section II Bird Species || Protected Species: EU Birds Directive >> Annex III, Section III Bird Species || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Red List 04/01/2003 European Shag (Phalacrocorax Protected Species: Wildlife Acts || Threatened Species: Birds of aristotelis) Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 03/01/2003 Great Black-backed Gull (Larus Protected Species: Wildlife Acts || Threatened Species: Birds of marinus) Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List
32 04/01/2003 Great Cormorant (Phalacrocorax Protected Species: Wildlife Acts || Threatened Species: Birds of carbo) Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 04/01/2003 Great Crested Grebe (Podiceps Protected Species: Wildlife Acts || Threatened Species: Birds of cristatus) Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 04/01/2003 Great Northern Diver (Gavia Protected Species: Wildlife Acts || Protected Species: EU Birds immer) Directive || Protected Species: EU Birds Directive >> Annex I Bird Species 04/01/2003 Grey Plover (Pluvialis Protected Species: Wildlife Acts || Threatened Species: Birds of squatarola) Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 31/12/2011 Herring Gull (Larus argentatus) Protected Species: Wildlife Acts || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Red List 31/07/1991 House Martin (Delichon Protected Species: Wildlife Acts || Threatened Species: Birds of urbicum) Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 31/12/2011 House Sparrow (Passer Protected Species: Wildlife Acts || Threatened Species: Birds of domesticus) Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 31/12/2011 Lesser Black-backed Gull (Larus Protected Species: Wildlife Acts || Threatened Species: Birds of fuscus) Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List Little Egret (Egretta garzetta) Protected Species: Wildlife Acts || Protected Species: EU Birds 04/01/2003 Directive || Protected Species: EU Birds Directive >> Annex I Bird Species 04/01/2003 Little Grebe (Tachybaptus Protected Species: Wildlife Acts || Threatened Species: Birds of ruficollis) Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 31/12/2011 Mallard (Anas platyrhynchos) Protected Species: Wildlife Acts || Protected Species: EU Birds Directive || Protected Species: EU Birds Directive >> Annex II, Section I Bird Species || Protected Species: EU Birds Directive >> Annex III, Section I Bird Species 04/01/2003 Mediterranean Gull (Larus Protected Species: Wildlife Acts || Protected Species: EU Birds melanocephalus) Directive || Protected Species: EU Birds Directive >> Annex I Bird Species || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 04/01/2003 Merlin (Falco columbarius) Protected Species: Wildlife Acts || Protected Species: EU Birds Directive || Protected Species: EU Birds Directive >> Annex I Bird Species || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 31/12/2011 Mew Gull (Larus canus) Protected Species: Wildlife Acts || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 31/12/2011 Mute Swan (Cygnus olor) Protected Species: Wildlife Acts || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 03/01/2003 Northern Lapwing (Vanellus Protected Species: Wildlife Acts || Protected Species: EU Birds vanellus) Directive || Protected Species: EU Birds Directive >> Annex II, Section II Bird Species || Threatened Species: Birds of
33 Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Red List 04/01/2003 Northern Pintail (Anas acuta) Protected Species: Wildlife Acts || Protected Species: EU Birds Directive || Protected Species: EU Birds Directive >> Annex II, Section I Bird Species || Protected Species: EU Birds Directive >> Annex III, Section II Bird Species || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Red List 01/01/2003 Northern Shoveler (Anas Protected Species: Wildlife Acts || Protected Species: EU Birds clypeata) Directive || Protected Species: EU Birds Directive >> Annex II, Section I Bird Species || Protected Species: EU Birds Directive >> Annex III, Section III Bird Species || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Red List 03/01/2003 Razorbill (Alca torda) Protected Species: Wildlife Acts || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 06/01/2001 Red Knot (Calidris canutus) Protected Species: Wildlife Acts || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Red List
03/01/2003 Red-breasted Merganser Protected Species: Wildlife Acts || Protected Species: EU Birds (Mergus serrator) Directive || Protected Species: EU Birds Directive >> Annex II, Section II Bird Species 04/01/2003 Red-throated Diver (Gavia Protected Species: Wildlife Acts || Protected Species: EU Birds stellata) Directive || Protected Species: EU Birds Directive >> Annex I Bird Species || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 04/01/2003 Ringed Plover (Charadrius Protected Species: Wildlife Acts || Threatened Species: Birds of hiaticula) Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 31/12/2011 Sand Martin (Riparia riparia) Protected Species: Wildlife Acts || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 04/01/2003 Sky Lark (Alauda arvensis) Protected Species: Wildlife Acts || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 31/07/1991 Spotted Flycatcher (Muscicapa Protected Species: Wildlife Acts || Threatened Species: Birds of striata) Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 06/01/2001 Stock Pigeon (Columba oenas) Protected Species: Wildlife Acts || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 04/01/2003 Tufted Duck (Aythya fuligula) Protected Species: Wildlife Acts || Protected Species: EU Birds Directive || Protected Species: EU Birds Directive >> Annex II, Section I Bird Species || Protected Species: EU Birds Directive >> Annex III, Section II Bird Species || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 04/01/2003 Water Rail (Rallus aquaticus) Protected Species: Wildlife Acts || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List 04/01/2003 Whooper Swan (Cygnus cygnus) Protected Species: Wildlife Acts || Protected Species: EU Birds Directive || Protected Species: EU Birds Directive >> Annex I Bird 34 Species || Threatened Species: Birds of Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Amber List
08/08/2017 Yellowhammer (Emberiza Protected Species: Wildlife Acts || Threatened Species: Birds of citrinella) Conservation Concern || Threatened Species: Birds of Conservation Concern >> Birds of Conservation Concern - Red List
08/05/2017 Butterfly-bush (Buddleja davidii) Invasive Species: Invasive Species || Invasive Species: Invasive Species >> Medium Impact Invasive Species
28/05/2019 Giant Hogweed (Heracleum Invasive Species: Invasive Species || Invasive Species: Invasive mantegazzianum) Species >> High Impact Invasive Species || Invasive Species: Invasive Species >> Regulation S.I. 477 (Ireland) 22/02/1992 European Rabbit (Oryctolagus Invasive Species: Invasive Species || Invasive Species: Invasive cuniculus) Species >> Medium Impact Invasive Species 20/09/2005 Soprano Pipistrelle (Pipistrellus Protected Species: EU Habitats Directive || Protected Species: EU pygmaeus) Habitats Directive >> Annex IV || Protected Species: Wildlife Acts
Figure 16. Species survey grid reference O24A, NBDC
An assessment of files received from the NPWS (Code No. 2020_185) which contain records of rare and protected species and grid references for sightings of these species was carried out as part of this EcIA for the proposed development at Belmayne. There are no recorded sightings within the site itself, however the following table (Table 8) provides a summary of the species identified, the year of identification/sample, survey name and data ID of sightings locations in the areas surrounding the proposed development. Of note however, is that the area has undergone significant development in recent years.
Table 7. Species survey, NPWS
Data ID. Species Survey Name Sample Year 12525 Common Lizard (Zootoca vivipara) AFF Mammals, Reptiles, Amphibians 1908 Distribution Atlas 1978 21561 Grey Heron (Ardea cinerea) Otter – National Otter Survey 2010 – 2010 2011 2128 Hairy Violet (Viola hirta) Portmarnock - O24 1989 2020 Borrer’s Saltmarsh-Grass Baldoyle – O24 1993 (Puccinelia fasciculata) 1902 Meadow Barley (Hordeum Portmarnock – O24 1991 secalinum)
35 4 Analysis of the Potential Impacts Introduction The proposed development will involve the removal of the existing terrestrial habitats on removal of left over construction detritus. Direct Impacts Construction The development of the site is likely to have direct negative impacts upon the existing habitats, fauna and flora. Direct negative effects will be manifested in terms of the removal of the site’s internal habitats. The removal of these habitats will result in a loss of species of low biodiversity importance. The area is not deemed to be an important foraging area for terrestrial mammals or birds of conservation importance.
Designated Sites
Given that there are extensive attenuation structures and a petrochemical interceptor already existing within the drainage network designed to prevent downstream impacts, the surface water drainage strategy will have a negligible impact on the conservation sites located in the marine environment. However, compliance with Water Pollution Acts will be required. The indirect pathway of surface or foul wastewater will not result in a significant effect on the designated conservation sites.
Construction Impact: Neutral, localised; Permanent.
Terrestrial Habitats and Species
Construction will result in the complete removal of existing terrestrial habitats on site. There are no species or habitats of conservation importance on site.
Construction Impact: Neutral, localised; Permanent.
Bat Fauna
Construction impacts could result in artificial lighting within the proposed development area. No roosts are present on site and foraging was not noted.
Construction Impact: Neutral, localised. Operational Phase The proposed development site is located within a developed environment, 2.1 km away from the nearest site of conservational interest. There is no direct hydrological or ecological corridor from the proposed site to any Natura 2000 or pNHA conservation site. Construction on this site will create localised light and noise disturbance. However, given that the closest site of conservational interest is 2.1 km away, any light or noise disturbance impacts would be considered negligible at this distance across a developed environment. Existing operational phase controls are be in place to comply with the Water Pollution Acts.
Designated Sites
Given that there are extensive attenuation structures and a petrochemical interceptor already existing within the drainage network designed to prevent downstream impacts, the surface water drainage strategy will have a negligible impact on the conservation sites located in the marine environment. The indirect pathway of surface or foul wastewater will not result in a significant effect on the designated conservation sites.
Operational Impact: Neutral, localised; Permanent.
Terrestrial Habitats and Species
As the landscaping elements improve with maturity it would be expected that the biodiversity value of the site to birds and flora would also increase. Landscaping will be important to overall impact of the operational phase.
Operational Impact: Neutral, localised; Permanent.
36 Bat Fauna
Operational impacts of the development may also arise from the placement and design of artificial lighting within the proposed development. Due to the current levels of light spill from adjacent public road lighting and the proposed lighting plan, it is expected that lighting associated with the proposed development will not significantly impact the local bat population. Once developed the buildings on site would be clearly visible to bats if they were to enter the site. See Appendix I for further details
Operational Impact: Neutral, localised; Permanent. Indirect Impacts Appropriate measures should be taken to prevent the movement of silt laden surface water run-off and dust into adjacent habitats. Standard measures need to be in pace including a wheelwash and roads weeping to ensure silt does not enter the drainage network from construction access roads. Avoidance and Remedial Measures Mitigation by Avoidance Direct negative impacts upon the existing vegetation within the site are not regarded as being significant due to the absence of species of conservation importance and as a result do not require mitigation. Storage/Use of Materials, Plant & Equipment • Materials, plant and equipment shall be stored in the proposed site compound location; • Plant and equipment will be parked in areas remote from any sensitive locations, including drains, at the end of the working day; • Hazardous liquid materials or materials with potential to generate runoff shall be stored in areas remote from any sensitive locations, including drains; • All hazardous liquid materials shall be stored in a bunded area and spill containment measures will be in place; • All oils, fuels and other hazardous liquid materials shall be clearly labelled and stored in an upright position in an enclosed bunded area within the proposed development site compound. The capacity of the bunded area shall conform with EPA Guidelines – hold 110% of the contents or 110% of the largest container whichever is greater; • Fuel may be stored in the designated bunded area or in fuel bowsers located in the proposed compound location. Fuel bowsers shall be double skinned and equipped with certificates of conformity or integrity tested, • in good condition and have no signs of leaks or spillages; • Smaller quantities of fuel may be carried/stored in clearly labelled metal jerry cans. Green for diesel and red for petrol and mixes. The Jeri cans shall be in good condition and have secure lockable lids. The Jeri cans shall be stored in a drip tray when not in use. They will not be stored within 50m1 of drains; • Drip trays will be turned upside down if not in use to prevent the collection of rainwater; • Waters collected in drip trays must be assessed prior to discharge. If classified as contaminated, they shall be disposed by a permitted waste contractor in accordance with current waste management legal and regulatory requirements; • Plant and equipment to be used during works, will be in good working order, fit for purpose, regularly serviced/maintained and have no evidence of leaks or drips; • No plant used shall cause a public nuisance due to fumes, noise, and leakage or by causing an obstruction; • Re-fuelling of machinery, plant or equipment will be carried out in the site compound as per the appointed Construction Contractor re-fuelling controls; • The appointed Construction Contractor EERP will be implemented in the event of a material spillage;
1 Standard Operation Procedures for TII are to ensure that “Oil storage tank(s) and the associated filling area and distribution pipe work should be at least 10m distant from surface watercourses (rivers, lakes, streams, field drains) and 50m from wells or boreholes. As a precaution 50m has been selected in this instance. https://www.tii.ie/tii- library/environment/construction-guidelines/Guidelines-for-the-Crossing-of-Watercourses-during-the-Construction-of- National-Road-Schemes.pdf 37 Surface Water Protection During Construction (downstream impacts) No watercourses are present on site. However, appropriate monitoring of groundwater levels during site works will be undertaken. As there is an indirect hydrological connection from the proposed works to the Mayne River via the existing attenuation on site, a series of standard control measures will implemented in relation to drainage from the site during construction. This commences with site clearance right through to the completion of the project. These measures are not necessary to prevent significant effects on Natura 2000 sites but are to ensure compliance with Water Pollution Acts.
Sufficient onsite cleaning of vehicles prior to leaving the site and on nearby roads, will be carried out, particularly during groundworks.
The Site Manager will be responsible for the pollution prevention programme and will ensure that at least daily checks are carried out to ensure compliance. A record of these checks will be maintained.
The site compound will include a dedicated bund for the storage of dangerous substances including fuels, oils etc. Refuelling of vehicles/machinery will only be carried out within the bunded area. The site compound will clearly display emergency contact details for Fingal County Council in the event of a pollution incident or environmental emergency. Adequate spill kits will be available in the event of a spill of oil or other hazardous substance.
Dewatering of excavations may be necessary. Appropriate monitoring of groundwater levels during site works will be undertaken. Standard construction phase filtering of surface water for suspended solids will be carried out. Trenched double silt fencing shall be put in place along sensitive boundaries. The silt fencing will act as a temporary sediment control device to protect surrounding areas from sediment and potential site water runoff. The fencing will be inspected twice daily based on site and weather conditions for any signs of contamination or excessive silt deposits.
Concrete trucks, cement mixers or drums/bins are only permitted to wash out in designated wash out area greater than 50m from sensitive receptors.
Spill containment equipment shall be available for use in the event of an emergency. The spill containment equipment shall be replenished if used and shall be checked on a scheduled basis.
All site personnel will be trained in the importance of good environmental practices including reporting to the site manager when pollution, or the potential for pollution, is suspected. All persons working on-site will receive work specific induction in relation to surface water management and run off controls. Daily environmental toolbox talks / briefing sessions will be conducted to outline the relevant environmental control measures and to identify any environment risk areas/works. Air & Dust Dust may enter the surface water network. Measures will be carried out reduce dust emissions to a level that avoids the possibility of adverse effects on the Mayne River. The main activities that may give rise to dust emissions during construction include the following: • Excavation of material; • Materials handling and storage; • Movement of vehicles (particularly HGV’s) and mobile plant. • Contaminated surface runoff
The following measures will be in place • Trucks leaving the site with excavated material will be covered so as to avoid dust emissions along the haulage routes. • A double layer of silt fencing would be placed at the lowest perimeter of the site and prevent silt laden runoff exiting the site. • Speed limits on site (15kmh) to reduce dust generation and mobilisation.
Site Management • Regular inspections of the site and boundary should be carried out to monitor dust, records and notes on these inspections should be logged.
38 • Record all dust and air quality complaints, identify cause(s), take appropriate measures to reduce emissions in a timely manner, and record the measures taken. • Make the complaints log available to the local authority when asked. • Record any exceptional incidents that cause dust and/or air emissions, either on- or offsite, and the action taken to resolve the situation in the log book.
Monitoring • Undertake daily on-site and off-site inspection, where receptors are nearby, to monitor dust, record inspection results, and make the log available to the local authority when asked. This should include regular dust soiling checks of surfaces within 100 m of site boundary, integrity of the silt control measures, with cleaning and / or repair to be provided if necessary. Preparing and Maintaining the Site • Plan site layout so that machinery and dust causing activities are located away from receptors, as far as is possible. • Fully enclose specific operations where there is a high potential for dust production and the site is active for an extensive period. • Avoid site runoff of water or mud. • Keep site fencing, barriers and scaffolding clean using wet methods. • Remove materials that have a potential to produce dust from site as soon as possible, unless being re-used on site. If they are being re-used on-site cover as described below. • Cover, seed or fence stockpiles to prevent wind whipping. • Hard surface roads will be swept to remove mud and aggregate materials from their surface while any un- surfaced roads will be restricted to essential site traffic. • Any road that has the potential to give rise to fugitive dust will be regularly watered, as appropriate, during dry and/or windy conditions.
Waste Management • Avoid bonfires and burning of waste materials.
Measures Specific to Earthworks • Re-vegetate earthworks and exposed areas/soil stockpiles to stabilise surfaces as soon as practicable. • Only remove the cover in small areas during work and not all at once. • During dry and windy periods, and when there is a likelihood of dust nuisance, a bowser will operate to ensure moisture content is high enough to increase the stability of the soil and thus suppress dust.
Mitigation For Birds Relevant guidelines and legislation (Section 40 of the Wildlife Acts, 1976 to 2012) in relation to the removal of trees and timing of nesting birds will be followed e.g. trees or shrubs will not be removed during the nesting season (1st March to 31st August).
Mitigation for Mammals/Amphibians No specific mitigation is required.
Mitigation for Flora An invasive species management plan has been prepared and should be followed prior to construction activities commencing on site. Mitigation for Bats No mitigation is required in relation to bat species.
39 Cumulative Impacts The following is a list of planning application(s) as identified on the Department of Housing, Local Government and Heritage’s ‘National Planning Application Database’ portal (Table 3)2:
Table 8. Planning application details and reference numbers of sites proximate to the proposed development
Ref. No. Address Proposal
2600/20 Junction of The development will consist of the construction of a part three storey, Main Street part two storey post primary school in Belmayne - Roll Number 68346T - and Belmayne including PE Hall, 4 classroom Special Education Needs Unit and all Avenue, ancillary site works. The main wings of the building will create a frontage Belmayne, on both Main Street and Belmayne Avenue. The design also includes staff Clongriffin, car parking (36 spaces), bicycle parking (300 spaces), delivery access, drop Dublin 13 off areas (3 spaces), pedestrian access, and bicycle lane. Vehicular access will be from Belmayne Avenue. The project includes the construction of six (6) external ball courts, landscaping, ESB substation and all associated site works and connections to public services. 3894/19 Lands at Planning permission is sought for development at lands at Clongriffin, Clongriffin, Dublin 13, on plots known as 3, 13 and 15, located to the south of Park Dublin 13 on Street, east of Friars' Street and north of main Street (plot 3), to the north plots known as of Market Street, south of Dargan Street, east of Lake Street and west of 3, 13 and 15, Clongriffin Road (plot 13), to the north of Main Street, south of Market located to the Street, west of Station Square and east of Market Lane (plot 15); all of south of Park which are located to the north of Main Street, Clongriffin, Dublin 13. The Street, east of development will consist of the construction of a mixed-use development Friars' Street (within 3 no blocks, i.e. Blocks 3, 13 and 15) comprising of 420 no. and north of apartment units (127 no. one beds, 273 no. two beds and 20 no. three Main Street beds) of which 233 no. units are residential and 187 no. units are 'build to (plot 3) to the rent' with ancillary residential amenity facilities; 14 no. retail units, 1 no. 8 north of screen cinema, 4 no. cafes/restaurants and 10 no. floors of commercial Market Street, office suites, all of which will be provided as follows: - Block 3 containing a south of total of 141 no. residential apartments comprising 31 no. 1 beds, 104 no. Dargam Sreet, 2 beds and 6 no. 3 beds, all apartments with private balconies/terraces to east of Lake north, south, east and west elevations, in 3 no. buildings ranging from 5 to Street and 6 storeys in height, with ancillary residential amenity facilities, 2 no. retail west of units at ground floor level with 5 no. floors of commercial office suites at Clongriffin first to fifth floor level, 1 no. ESB substation at ground floor level, all surrounding 1 no. landscaped podium garden with play equipment, off street car parking totalling 80 no. spaces accessed via new vehicular access on Park Street, 43 no. on-street car parking spaces (10 no. spaces on Park Street, 13 no. spaces on Friars' Street, 10 no. spaces on Main Street/Lake Street and 10 no. spaces on proposed Park Lane), 200 no. bicycle parking spaces at ground floor level and associated elevational signage to all retail/commercial units; - Block 13 containing a total of 187 no. residential build to rent apartments comprising 58 no. 1 beds, 115 no. 2 beds and 14 no. 3 beds, all apartments with private balconies/terraces to north, south, east and west elevations, in 3 no. buildings ranging from 5-7 storeys in height, with ancillary residential amenity facilities as follows: games room, gym, conference room, amenity room, laundry, bulk store and guest suites; 6 no. retail units and 1 no. cafe/restaurant all at ground floor level, 5 no. floors of commercial office suites at first to fifth floor level, 1 no. landscaped roof deck at fifth floor level to serve offices, 1 no. ESB substation at ground floor level, surrounding 1 no. landscaped podium garden with play equipment, off street car parking totalling 97 no. spaces accessed via new vehicular access on Lake Street, 26 no. on-street car parking spacess (8 no. spaces on Dargan Street, 11 no. spaces on
2 https://housinggovie.maps.arcgis.com/apps/webappviewer/index.html?id=9cf2a09799d74d8e9316a3d3a4d3a8de 40 Clongriffin Road and 7 no. spaces on Lake Street); 234 no. bicycle parking spaces (20 no. on street and 214 no. at ground floor level) and associated elevational signage to all retail/commercial units; - Block 15 containing a total of 92 no. residential apartments comprising 38 no. 1 beds and 54 no. 2 beds, all apartments with private balconies/terraces to north, south, east and west elevations, in 2 no. buildings ranging from 3 to 6 storeys in height, with ancillary residential amenity facilities; 1 no. 8 screen cinema, 5 no. retail units and 3 no. cafes/restaurants at ground floor level, 1 no. retail unit split over ground and first floor level, 1 no. ESB substation at ground floor level, surrounding 1 no. landscaped podium garden, off street car parking totalling 50 no. spaces accessed via new vehicular access on Market Lane, 32 no. on-street car parking spaces (23 no. spaces on Market Lane and 9 no. spaces on Main Street); 201 no. bicycle parking spaces (20 no. street and 181 no. at ground floor level) and associated elevational signage to all retail/commercial units. The proposed development provides for a total of 328 no. car parking spaces and 635 no. bicycle spaces all across surface and undercroft levels. Planning permission is also sought for landscaping, roads, footpaths, boundary treatments and all associated engineering and site works necessary to facilitate the development. An Environmental Impact Assessment Report has been prepared in respect of the proposed development. F16A/0412 The Coast, 550 no. residential units (379 no. apartments and 171 no. houses) and a Baldoyle, village centre comprising C.1,585sq. m. of commercial floor space laid out Dublin 13 in 13 no. blocks (Blocks A1, A2, A3, B1, B2, B3, B4, C1, C2, C3, C4, C5 and D1) ranging in height from two storeys to six storeys as follows:
Blocks A1, A2 and A3 will consist of 3 no. six storey buildings (c. 30.05m OD to roof level with an overall height of c. 33.90 OD to include lift overrun) comprising 195 no. residential units (5 no. 1-bed apartment, 162 no. 2-bed apartments, and 28 no. 3-bed apartments) at first to fifth floor level, c.1,585 sq.m. of commercial floor area at ground floor level comprising a convenience outlet (c. 493sq.m.), cafe (c. 200sq.m.), 4 no. retail units (c. 88sq.m., 99sq.m., 99 sq.m. and 90sq.m.), a crèche (c. 516sq.m.) with outdoor play area (c. 183sq.m.) and shared car park also at ground floor level with two associated communal courtyard areas at first floor level above a podium.
Block B1 will consist of a four storey building over basement car park (c. 21.6m OD to roof level with an overall height of c. 25m OD to include lift overrun) comprising 82 no. residential units (3 no. 1-bed apartments, 75 no. 2-bed apartments, and 4 no. 3-bed apartments); Blocks B1 and B2 include a shared central communal courtyard area over a shared basement car park and a community room (c. 78sq.m.) in the entrance pavilion to the basement.
Block B2 will consist of 3 no. three storey terraces over basement car park comprising 24 no. residential units (12 no. own door 2-bed apartments and 12 no. own door 2-bed duplex apartments).
Block B3 will consist of 1 no. two storey terrace and 3 no. three storey terraces comprising 32 no. residential units (11 no. 3-bed terraced houses and 21 no. 4-bed terraced houses).
Block B4 will consist of 2 no. two storey terraces and 1 no. three storey terrace comprising 25 no. residential units (16 no. 3-bed terraced houses and 9 no. 4-bed terraced houses).
41 Block C1 will consist of 3 no. three storey terraces comprising 32 no. residential units (16 no. 2-bed own door apartments and 16 no. 2-bed own door duplex apartments).
Block C2 will consist of 1 no. two storey terrace and 2 no. three storey terraces comprising 35 no. residential units (9 no. 2-bed own door apartments, 9 no. 2-bed own door duplex apartments, 10 no. 3-bed terraced houses and 7 no. 4-bed terraced houses.
Block C3 will consist of 1 no. two storey terrace and 2 no. three storey terraces comprising 29 no. residential units (11 no. 3-bed houses and 18 no. 4-bed houses).
Block C4 will consist of 2 no. two storey terraces and 2 no. three storey terraces comprising 47 no. residential units (5 no. 1-bed own door apartments, 2 no. 2-bed own door apartments, 5 no. 2-bed own door duplex apartments, 2 no. 3-bed own door duplex apartments, 24 no. 3-bed terraced houses and 9 no. 4-bed terraced houses).
Block C5 will consist of 2 no. two storey terraces and 2 no. three storey terraces comprising 37 no. residential units (5 no. 1-bed own door apartments, 2 no. 2-bed own door apartments, 5 no. 2-bed own door duplex apartments, 2 no. 3-bed own door duplex apartments, 14 no. 3-bed terraced houses, and 9 no. 4-bed terraced houses).
Block D1 will consist of 12 no. two storey 3-bed semi-detached houses.
All apartments and duplex apartments have private terraces or balconies and private communal amenity areas. The proposed development will also include 896 no. residential (including visitor) car parking spaces, 62 no. commercial car parking spaces, 551 no. residential bicycle spaces and 13 no. commercial bicycle spaces; pedestrian, vehicular and bicycle access will be via the existing Longfield Road and Red Arches Road and the proposed internal road network comprising Stapolin Avenue, Ireland's Eye Avenue and smaller access roads; construction access will be via existing haul road from the Coast Road; landscaping works including Stapolin Square (c. 0.4ha) which will provide access to Clongriffin Train Station via a series of terraces, steps and slopes, a range of public open spaces including pocket parks and amenity spaces, the largest of which will be Stapolin Haggard (c. 1.57ha); public lighting; a wetland area (c. 0.4ha.) for water quality treatment associated with the proposed development; all associated ancillary facilities including 8 no. ESB substations, switch rooms, refuse storage, water storage tanks and plant; and all associated site development works including the removal of existing roads and infrastructure where required and demolition of existing temporary lift and stair enclosure and associated infrastructure to Clongriffin Train Station. The subject site of C 15.89ha comprised Growth Area 1 of the Baldoyle-Stapolin Local Area Plan 2013-2019. This application is accompanied by an Environmental Impact Statement (E.I.S.)
Application 2600/20 is accompanied by an Appropriate Assessment Screening issued by Moore Group – Environmental Services on behalf of the Department of Education and Skills. The report concludes that:
1) ‘The proposed Project is not directly connected with, or necessary to the conservation management of the European sites considered in this assessment; 2) The proposed Project is unlikely to indirectly significantly affect the Qualifying interests or Conservation Objectives of the European sites considered in this assessment;
42 3) The proposed Project, alone or in combination with other projects, is not likely to have significant effects on the European sites considered in this assessment in view of their conservation objectives; 4) It is possible to conclude that there would be no significant effects, no potentially significant effects and no certain effects if the proposed Project were to proceed.’
Application 3894/19 is accompanied by an Appropriate Assessment Screening report issued by Openfield Ecological Services for Gerard Gannon Properties. This report concludes that: ‘This proposed development is not located within or directly adjacent to any SAC or SPA but pathways do exist to a number of these areas. An assessment of the aspects of this project has shown that significant negative effects are not likely to occur to these areas either alone or in combination with other plans and projects.’
Based on a review of the planning application viewer there are no developments of significance proposed in proximity of the proposed development. Given this, it is considered that in combination effects with other existing and proposed developments in proximity to the application area would be unlikely, neutral, not significant and localised. It is concluded that no significant effects on conservation sites will be seen as a result of the proposed development alone or combination with other projects.
No significant cumulative impacts are likely in relation to the proposed development. Residual Impacts and Conclusion Based on the successful implementation of the construction phase controls and proposed works to be carried out in accordance with this EcIA and landscape plan, it is likely that there will be no significant ecological impact arising from construction and the day-to-day operation of the proposed development. Existing pollution controls are in place downstream from the proposed works. Natura 2000 sites and localised pNHA conservation sites will not be significantly impacted by the proposed development.
Standard construction phase control measures have been outlined to ensure that the proposed project complies with Water Pollution Acts. It is essential that these measures are complied with, to ensure that the proposed development does not have localised environmental impacts.
No significant ecological impacts would be likely outside the immediate vicinity of the proposed development. Impacts in the vicinity of the housing development, would be considerable due to the removal of the majority existing habitats. But, due to the fact that the site is poor in species diversity and no species of conservation importance were found these impacts would be limited, localised and reversible depending on the planting regime.
No significant environmental impacts are likely in relation to the construction or operation of the proposed development.
43 References The following references were used in the preparation of this AA screening report.
1. Brickell C. (1998) The Horticultural Society’s Encyclopaedia of Garden Plants. The Royal Horticultural Society. Curtis T.G.F. & McGough H.N. (1988) The Irish Red Data Book. 1. Vascular Plants. 2. Dempsey E. (2002) The Complete Guide to Ireland’s Birds. 2nd Ed. Gill and Macmillan. European Communities (Natural Habitats) Regulations, 1997 (S.I. No. 94 of 1997). Fossitt J.A. (2000 ) A Guide to Habitats in Irela nd. The Heritage Council. Fitter R., Fitter A. & Blamey M. (1974) The Wild Flowers of Britain and Northern Europe. 3. Dempsey E and O'Clery M. (2005). Pocket Guide to the Common Birds of Ireland. Gill and Macmillan, Dublin. 4. Dublin Naturalists' Field Club (1998). Flora of County Dublin. Dublin. 5. EPA (2017). Draft Guidelines on the information to be contained in Environmental Impact Assessment Reports (EIAR) 6. Fossitt JA (2000). A Guide to Habitats in Ireland. The Heritage Council. Hayden T and Harrington R (2000). Exploring Irish Mammals. Duchas, the Heritage Service. 7. Hayden T. & Harrington R. (2001) Exploring Irish Mammals, Dúchas The Heritage Service. Hume R. (1998) The Guide to Birds of Britain and Europe. Macm illan. 8. Joint Nature Conservancy Council (1993) Phase I Habitat Survey Techniques. JNCC. National Parks and Wildlife Service (Dept. of the Environment, Heritage and Local Government) Designated Site Information. 9. Marnell F, Kingston N. & Looney D. (2010). Ireland Red List NO.3: Terrestrial Mammals. National Parks and Wildlife Service, Department of the Environment, Heritage and Local Government, Dublin, Ireland. 10. National Roads Authority (2005), Guidelines for the Treatments of Badgers Prior to the Construction of National Road Schemes. National Roads Authority, Dublin 11. National Biodiversity Data Centre (2012), Online Map Viewer Datasets. http://maps.biodiversityireland.ie 12. National Parks and Wildlife Service online resource www.npws.ie 13. National Roads Authority (2008), Ecological Surveying Techniques for Protected Flora & Fauna during the Planning of National Road Schemes. Dublin: National Roads Authority. 14. Phillips R. (1977) Wild Flowers of Britain. Macmillan. Phillips R. (1978) Trees in Britain, Europe and North America. Macmillan. Phillips R. (1980 Grasses, Ferns, Mosses & Lichens of Great Britain and Ireland. 15. Scannell M.J.P & Synnott D.M. (1987) Census catalogue of the flora of Ireland. (2nd Ed.). Stationery Office, Dublin. 16. Smal. C. (1995), The badger and habitat survey of Ireland ; Summary report / report. Dublin: Stationery Office, 17. Webb D.A., Parnell J. and Doogue D. (1996) An Irish Flora. Dundalgan Press, Dundalk. 18. Whilde A. (1993) Irish Red Data Book 2: Vertebrates. HMSO, Belfast. Wildlife (Amendment) Act, 2000 (S.I. No. 38 of 2000). 19. Curtis, T.G.F. and McGough, H.N. (1988) The Irish Red Data Book 1. Vascular Plants. The Stationery Office, Dublin. Doogue, D., Nash, D., Parnell, J., Reynolds, S. and Wyse Jackson, P. (1998) Flora of County 20. Department of Environment Heritage and Local Government Circular NPW 1/10 and PSSP 2/10 on Appropriate Assessment under Article 6 of the Habitats Directive – Guidance for Planning Authorities March 2010. 21. Appropriate Assessment of Plans and Projects in Ireland: Guidance for Planning Authorities, Department of the Environment, Heritage and Local Government 2009; http://www.npws.ie/publications/archive/NPWS_2009_AA_Guidance.pdf 22. Managing NATURA 2000 Sites: the provisions of Article 6 of the Habitats Directive 92/43/EEC, European Commission 2000; http://ec.europa.eu/environment/nature/Natura2000/management/docs/art6/provision_of_art6 _en.pdf 23. 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;
44 http://ec.europa.eu/environment/nature/Natura2000management/docs/art6/Natura_2000_asse ss_en.pdf 24. Guidance document on Article 6(4) of the 'Habitats Directive' 92/43/EEC – Clarification of the concepts of: alternative solutions, imperative reasons of overriding public interest, compensatory measures, overall coherence, opinion of the commission; http://ec.europa.eu/environment/nature/Natura2000/management/docs/art6/guidance_art6_4_ en.pdf 25. Guidance document on the implementation of the birds and habitats directive in estuaries and coastal zones with particular attention to port development and dredging; http://ec.europa.eu/environment/nature/Natura2000/management/docs/guidance_doc.pdf 26. The Status of EU Protected Habitats and Species in Ireland. http://www.npws.ie/publications/euconservationstatus/NPWS_2007_Conservation_Status_Repor t.pdf 27. NPWS (2012) Conservation Objectives: Baldoyle Bay SAC 000199. Version 1.0. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht. 28. NPWS (2013) Conservation Objectives: North Dublin Bay SAC 000206. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht. 29. NPWS (2013) Conservation Objectives: Malahide Estuary SAC 000205. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht. 30. NPWS (2016) Conservation Objectives: Howth Head SAC 000202. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage, Regional, Rural and Gaeltacht Affairs. 31. NPWS (2013) Conservation Objectives: Rockabill to Dalkey Island SAC 003000. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht. 32. NPWS (2013) Conservation Objectives: South Dublin Bay SAC 000210. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht. 33. NPWS (2017) Conservation Objectives: Ireland's Eye SAC 002193. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage, Regional, Rural and Gaeltacht Affairs. 34. NPWS (2013) Conservation Objectives: Rogerstown Estuary SAC 000208. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht. 35. NPWS (2013) Conservation Objectives: Lambay Island SAC 000204. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht. 36. NPWS (2013) Conservation Objectives: Baldoyle Bay SPA 004016. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht. 37. NPWS (201ϱ) Conservation Objectives: North Bull Island SPA 004006. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht. 38. NPWS (2013) Conservation Objectives: Malahide Estuary SPA 004025. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht. 39. NPWS (2021) Conservation objectives for Ireland's Eye SPA [004117]. Generic Version 8.0. Department of Housing, Local Government and Heritage. 40. NPWS (201ϱ) Conservation Objectives: South Dublin Bay and River Tolka Estuary SPA 004024. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht. 41. NPWS (2021) Conservation objectives for Howth Head Coast SPA [004113]. Generic Version 8.0. Department of Housing, Local Government and Heritage. 42. NPWS (2013) Conservation Objectives: Rogerstown Estuary SPA 004015. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht. 43. NPWS (2021) Conservation objectives for Lambay Island SPA [004069]. Generic Version 8.0. Department of Housing, Local Government and Heritage. 44. NPWS (2021) Conservation objectives for Dalkey Islands SPA [004172]. Generic Version 8.0. Department of Housing, Local Government and Heritage.
45 Appendix 1 – Bat Fauna Survey
Bat Fauna Survey for a proposed strategic housing development at Belmayne P4, adjacent Churchwell Road and Churchwell Crescent, Belmayne, Dublin 13.
22nd April 2021
Prepared by: Bryan Deegan (MCIEEM) of Altemar Ltd. On behalf of: Balgriffin Park Limited.
Altemar Ltd., 50 Templecarrig Upper, Delgany, Co. Wicklow. 00-353-1-2010713. [email protected] Directors: Bryan Deegan and Sara Corcoran Company No.427560 VAT No. 9649832U www.altemar.ie
46
SUMMARY
Structure: None. Proposed residential development on previously cleared site.
Location: Belmayne P4, adjacent Churchwell Road and Churchwell Crescent, Belmayne, Dublin 13.
Bat species present: None Roosting. No foraging within the proposed site.
Proposed work: Development of previously cleared site.
Impact on bats: None
Survey by: Bryan Deegan MCIEEM
Survey date: 8th April 2021
47 Receiving Environment
Background Ballgriffin Park Limited intend to apply to An Bord Pleanála for permission for a strategic housing development at this site at Belmayne P4, adjacent Churchwell Road and Churchwell Crescent, Belmayne, Dublin 13. The development will consist of 260 no. apartment units within an urban block (with 6 cores) ranging in height up to 7 storeys. The unit mix will comprise of 108 no. 1-beds, 135 no. 2-beds, and 17 no. 3-beds (10 no. duplexes and 7 no. apartments), all with associated private balconies/terraces to the north/south/east/west elevations. The development will also include c.314 m2 of residential amenity facilities, c.2,945 m2 of communal open space at podium level, 199 no. car parking spaces (180 no. at undercroft level and 19 no. at surface level), and 400 no. cycle parking spaces (384 no. at undercroft level and 16 no. at surface level). Vehicular access to the undercroft parking area will be provided from Churchwell Crescent. All other site services and works to enable the development of the site will also be provided including bins, ESB substation and switchroom, plant areas, boundary treatments and landscaping. Survey constraints The detector survey was undertaken during the active bat season. Weather conditions were good with temperatures of 10°C after sunset. Winds were light and there was no rainfall.
Bat assessment findings Review of local bat records The review of existing bat records (sourced from Bat Conservation Ireland’s National Bat Records Database) within a 2km of the study area reveals that one of the nine known Irish species have been observed locally (Table 1). Based on NBDC/NPWS records, bats have not been seen on site.
Table 1: Status of bat species within a 2km grid which incorporates the study location
Common Name Title of Dataset Date Soprano Pipistrelle (Pipistrellus pygmaeus) National Bat Database of Ireland 20/09/2005
Structure /Roost survey No buildings or structures of roosting potential were present on site. In relation to bat roosting potential, the site comprised of one previously cleared plot with a hedgerow to the north . No trees of bat roosting potential were noted. Detector survey There were no seasonal or climatic constraints as survey was undertaken within the active bat season in good weather conditions with temperatures of 10°C after dark. Winds were very light and there was no rainfall. An Echo Meter Touch 2 Pro was used to detect bat activity. No bats were detected on site.
48 Figure 1. Site outline.
49 Potential impacts of proposed redevelopment on bats No buildings are noted on site. No onsite trees were observed. No bat activity was noted. The site has no features that would act as potential roosting areas. The proposed development will involve the construction of dwellings on site with additional light spill in the area which may reduce the foraging potential of the site. However, no foraging was noted.
Mitigation measures No mitigation in relation to bat fauna is required.
Predicted and residual impact of the proposal There is no evidence of a current or past bat roost on site and no bat activity was noted, therefore no significant negative impacts on these animals are expected to result from the proposed redevelopment. The buildings proposed would be clearly visible to bat species in an existing larger development area and would be clearly visible to bat species.
References Convention on the Conservation of European Wildlife and Natural Habitats (Bern Convention) 1982
Convention on the Conservation of Migratory Species of Wild Animals (Bonn Convention) 1979
EC Directive on The Conservation of Natural habitats and of Wild Fauna and Flora (Habitats Directive) 1992
European Communities (Birds and Natural Habitats) Regulations 2011 Government of Ireland, Dublin
Kelleher, C. and Marnell, F. 2007 Bat Mitigation Guidelines for Ireland – Irish Wildlife Manuals No. 25. National Parks and Wildlife Service, Department of the Environment, Heritage and Local Government, Dublin
Marnell, F., Kingston, N. and Looney, D. 2009 Ireland Red List No. 3: Terrestrial Mammals. National Parks and Wildlife Service, Department of the Environment, Heritage and Local Government, Dublin
Wildlife Act 1976 and Wildlife Amendment Acts 2000 and 2010. Government of Ireland.
50 Legal status and conservation issues – bats All Irish bat species are protected under the Wildlife Act (1976) and Wildlife Amendment Acts (2000 and 2010). Also, the EC Directive on The Conservation of Natural habitats and of Wild Fauna and Flora (Habitats Directive 1992), seeks to protect rare species, including bats, and their habitats and requires that appropriate monitoring of populations be undertaken. All Irish bats are listed in Annex IV of the Habitats Directive and the lesser horseshoe bat Rhinolophus hipposideros is further listed under Annex II. Across Europe, they are further protected under the Convention on the Conservation of European Wildlife and Natural Habitats (Bern Convention 1982), which, in relation to bats, exists to conserve all species and their habitats. The Convention on the Conservation of Migratory Species of Wild Animals (Bonn Convention 1979, enacted 1983) was instigated to protect migrant species across all European boundaries. The Irish government has ratified both these conventions.
All Irish bats are listed in Annex IV of the Habitats Directive and the lesser horseshoe bat is further listed under Annex II. The current status and legal protection of the known bat species occurring in Ireland is given in the following table.
Common and scientific name Wildlife Act 1976 & Wildlife Irish Red List Habitats Bern & Bonn (Amendment) Acts 2000/2010 status Directive Conventions Common pipistrelle Yes Least Concern Annex IV Appendix II Pipistrellus pipistrellus Soprano pipistrelle Yes Least Concern Annex IV Appendix II P. pygmaeus Nathusius pipistrelle Yes Not referenced Annex IV Appendix II P. nathusii Leisler’s bat Yes Near Annex IV Appendix II Nyctalus leisleri Threatened Brown long-eared bat Yes Least Concern Annex IV Appendix II Plecotus auritus Lesser horseshoe bat Yes Least Concern Annex II Appendix II Rhinolophus hipposideros Annex IV Daubenton’s bat Myotis Yes Least Concern Annex IV Appendix II daubentonii Natterer’s bat Yes Least Concern Annex IV Appendix II M. nattereri Whiskered bat Yes Least Concern Annex IV Appendix II M. mystacinus Brandt’s bat Yes Data Deficient Annex IV Appendix II M. brandtii
Also, under existing legislation, the destruction, alteration or evacuation of a known bat roost is a notifiable action, and a derogation licence has to be obtained from the National Parks and Wildlife Service before works can commence.
It should also be noted that any works interfering with bats and especially their roosts, including for instance, the installation of lighting in the vicinity of the latter, may only be carried out under a licence to derogate from Regulation 23 of the Habitats Regulations 1997, (which transposed the EU Habitats Directive into Irish law) issued by NPWS. The details with regards to appropriate assessments, the strict parameters within which derogation licences may be issued and the procedures by which and the order in relation to the planning and development regulations such licences should be obtained, are set out in Circular Letter NPWS 2/07 "Guidance on Compliance with Regulation 23 of the Habitats Regulations 1997 - strict protection of certain species/applications for derogation licences" issued on behalf of the Minister of the Environment, Heritage and Local Government on the 16th of May 2007.
Furthermore, on 21st September 2011, the Irish Government published the European Communities (Birds and Natural Habitats) Regulations 2011 which include the protection of the Irish bat fauna and further outline derogation licensing requirements re: European Protected Species.
51