Ecological Impact Assessment Report

ECOLOGICAL IMPACT

ASSESSMENT REPORT

FOR RESIDENTIAL DEVELOPMENT

AT LANDS at NEWTOWNPARK AVENUE, BLACKROCK, CO. DUBLIN

December 2020

ON BEHALF OF

Prepared by Enviroguide Consulting Dublin Kerry www.enviroguide.ie 3D Core C, Block 71, The Plaza, 19 Henry Street [email protected] Park West, Dublin 12 Kenmare, Co. Kerry +353 1 565 4730 Enviroguide Consulting Residential Development Ecological Impact Assessment Newtownpark Avenue, Blackrock, Co. Dublin.

DOCUMENT CONTROL SHEET

Client Glenveagh Homes Ltd

Project Title Residential Development at Newtownpark Avenue, Blackrock, Co. Dublin.

Document Title Ecological Impact Assessment Report

Revision Status Author(s) Reviewed Approved Issue Date

Internal Liam Gaffney Jim Dowdall 1.0 - - Draft Project Ecologist Director

Liam Gaffney Jim Dowdall 2.0 Draft - 09/04/2020 Project Ecologist Director

Final Liam Gaffney Jim Dowdall Jim Dowdall 3.0 24/09/2020 Draft Project Ecologist Director Director

Final Liam Gaffney 4.0 Draft - - 13/10/2020 Project Ecologist V.2

Liam Gaffney Jim Dowdall Jim Dowdall 5.0 Final 20/10/2020 Project Ecologist Director Director

Final Liam Gaffney Jim Dowdall Jim Dowdall 6.0 09/12/2020 V.2 Project Ecologist Director Director

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TABLE OF CONTENTS

TABLE OF CONTENTS ...... 2 LIST OF TABLES ...... 3 LIST OF FIGURES ...... 4 1 INTRODUCTION ...... 1

1.1 QUALITY ASSURANCE AND COMPETENCE ...... 1 2 RELEVANT LEGISLATION ...... 2

2.1 NATIONAL LEGISLATION...... 2 2.1.1 Wildlife Act 1976 and amendments ...... 2 2.1.2 EU Habitats Directive 1992 and EC (Birds and Natural Habitats) Regulations 2011 ...... 2 2.1.3 Flora (Protection) Order, 1999 ...... 3 2.2 INTERNATIONAL LEGISLATION ...... 3 2.2.1 EU Birds Directive ...... 3 2.2.2 EU Habitats Directive ...... 3 2.2.3 Bern and Bonn Convention ...... 3 2.2.4 Ramsar Convention ...... 3 3 METHODOLOGY ...... 4

3.1 SCOPE OF ASSESSMENT ...... 4 3.2 DESK STUDY ...... 4 3.3 FIELD SURVEYS ...... 5 3.3.1 Habitat Surveys ...... 5 3.3.2 Invasive Species Surveys ...... 5 3.3.3 Bat Surveys...... 5 3.3.4 Bird Surveys ...... 5 3.3.5 Mammal Surveys ...... 6 3.3.6 Other Fauna ...... 6 3.4 CONSULTATION ...... 6 3.5 ASSESSMENT ...... 6 3.6 LIMITATIONS ...... 7 4 BASELINE ECOLOGICAL CONDITIONS ...... 8

4.1 SITE OVERVIEW ...... 8 4.1.1 Geology, Hydrogeology and Hydrology ...... 8 4.2 DESIGNATED SITES ...... 8 4.3 HABITATS ...... 14 4.3.1 Buildings and Artificial Surfaces (BL3)...... 14 4.3.2 Dry Meadows and Grassy Verges (GS2) [unmanaged] ...... 14 4.3.3 Recolonising Bare Ground (BL1)...... 14 4.3.4 Scrub (WS1) ...... 14 4.3.5 Mixed Broadleaved Woodland (WD1) ...... 15 4.3.6 Hedgerows (WL1)...... 15 4.3.7 Treelines (WL2) ...... 15 4.3.8 Habitat Evaluation ...... 15 4.4 SPECIES AND SPECIES GROUPS ...... 18 4.4.1 Flora ...... 18

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4.4.2 Mammals (excl. bats) ...... 20 4.4.3 Bats ...... 22 4.4.4 Birds ...... 24 4.4.5 Fish ...... 25 4.4.6 Amphibians ...... 26 4.4.7 Invertebrates ...... 26 4.4.8 Other species and species groups ...... 26 4.4.9 Fauna Evaluation ...... 27 5 DESCRIPTION OF THE PROPOSED DEVELOPMENT ...... 28 6 POTENTIAL IMPACTS OF THE PROPOSED DEVELOPMENT ...... 30

6.1 IMPACTS ON DESIGNATED SITES ...... 30 6.2 IMPACTS ON HABITATS AND FLORA ...... 31 6.2.1 Mixed Broadleaved Woodland (WD1) ...... 32 6.2.2 Treelines (WL2) ...... 32 6.2.3 Impact of Japanese Knotweed remediation works...... 32 6.3 IMPACTS ON MAMMALS ...... 34 6.4 IMPACTS ON BATS ...... 35 6.5 IMPACTS ON BIRDS ...... 35 6.6 IMPACTS ON OTHER TAXA ...... 36 6.7 DO NOTHING IMPACT ...... 36 6.8 CUMULATIVE IMPACTS ...... 36 7 MITIGATION AND ENHANCEMENT MEASURES ...... 39

7.1 DESIGNATED SITES ...... 39 7.2 HABITATS ...... 39 7.2.1 Invasive species spread ...... 39 7.3 FAUNA ...... 39 7.3.1 Mammals ...... 41 7.4 BATS ...... 42 7.4.1 Construction Phase ...... 42 7.4.2 Operational Phase ...... 43 7.5 BIRDS ...... 45 8 RESIDUAL IMPACTS ...... 46 9 CONCLUSION ...... 51 10 REFERENCES ...... 52

LIST OF TABLES

TABLE 1. DESIGNATED SITES OF CONSERVATION IMPORTANCE LOCATED WITHIN 15KM OF THE SITE OF THE PROPOSED DEVELOPMENT...... 8 TABLE 2. EVALUATION OF HABITATS RECORDED WITHIN THE SITE OF THE PROPOSED DEVELOPMENT...... 15 TABLE 3. RECORDS OF RARE OR PROTECTED FLORA FOR THE SURROUNDING 10KM (O22), 2KM (O22E AND O22J) AND 1KM (O2128 AND O2228) GRID SQUARES FROM THE NBDC...... 18

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TABLE 4. RECORDS OF INVASIVE SPECIES OF FLOWERING PLANT FOR THE SURROUNDING 10KM O22), 2KM (O22J & O22E) AND 1KM (O2128 & O2228) GRID SQUARES FROM THE NBDC...... 19 TABLE 5. RECORDS OF TERRESTRIAL MAMMALS FOR THE SURROUNDING 10KM (O22), 2KM (O22J & O22E) AND 1KM (O2128 & O2228) GRID SQUARES FROM THE NBDC...... 20 TABLE 6. RECORDS OF BATS FOR THE SURROUNDING 10KM (O22), 2KM (O22J & O22E) AND 1KM (O2128 & O2228) GRID SQUARES FROM THE NBDC...... 22 TABLE 7. BIRD SPECIES RECORDED WITHIN THE PROJECT SITE DURING SITE BREEDING BIRD SURVEYS AND THEIR ASSOCIATED BREEDING STATUS CODES...... 24 TABLE 8. EVALUATION OF FAUNA RECORDED WITHIN THE SURROUNDING AREA...... 27 TABLE 9. SUMMARY OF POTENTIAL IMPACTS ON KER(S), MITIGATION PROPOSED AND RESIDUAL IMPACTS...... 47

LIST OF FIGURES

FIGURE 1. DESIGNATED SITES WITHIN 15KM OF THE PROPOSED DEVELOPMENT...... 13 FIGURE 2. HABITAT MAP OF SITE OF THE PROPOSED DEVELOPMENT AND VICINITY...... 17 FIGURE 3. ARCHITECT DRAWING OF PROPOSED SITE LAYOUT, ADAPTED FROM DRAWING NO: 950677 CMB P 0003 PROPOSED SITE PLAN (HENRY J LYONS, 20TH OCTOBER, 2020)...... 29 FIGURE 4. EXTENT OF JAPANESE KNOTWEED AT THE SITE OF THE PROPOSED DEVELOPMENT IN 2017 (ADAPTED FROM: INVAS BIOSECURITY, 2017)...... 34 FIGURE 5. INTERNAL LIGHTING GUIDANCE DIAGRAM ADAPTED FROM ILP (2018)...... 44

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1 INTRODUCTION

Enviroguide Consulting was commissioned by Glenveagh Homes Ltd. to undertake an Ecological Impact Assessment for a proposed Residential Development at Newtownpark Avenue, Blackrock, Co. Dublin.

This Ecological Impact Assessment (EcIA) assesses the potential effects of the proposed residential development in Blackrock, Co. Dublin on habitats and species; particularly those protected by national and international legislation or considered to be of particular nature conservation importance. This report will describe the ecology of the Site of the Proposed Development, with emphasis on habitats, flora and fauna, and will assesses the potential impacts of the construction and operational phases of the Proposed Development on these ecological receptors. The report follows Guidelines for Ecological Impact Assessment in the UK and Ireland, by the Chartered Institute of Ecology and Environmental Management (CIEEM, 2018).

1.1 Quality assurance and competence Synergy Environmental Ltd., T/A Enviroguide Consulting, is a wholly Irish Owned multi-disci- plinary consultancy specialising in the areas of Environment, Waste Management and Plan- ning. Our directors and consultants have scientific, engineering, or legal qualifications and have a wealth of experience working within the Environmental Consultancy sectors, having undergone extensive training and continued professional development All surveying and re- porting have been carried out by qualified and experienced ecologists and environmental consultants

Liam Gaffney has a M.Sc. Hons. (Wildlife Conservation and Management) from University College Dublin, and a wealth of experience in desktop research, literature scoping-review, and report writing; as well as practical field experience (Habitat surveys, Wintering bird surveys, large mammals, fresh water macro-invertebrates etc.).

Eric Dempsey is an Environmental Consultant and Ornithologist who has worked on a wide range of conservation, research and ecological monitoring projects across Ireland. Eric is the author of the best-selling books, The Complete Field Guide to Ireland’s Birds and Finding Birds in Ireland and is experienced in coordinating and undertaking surveys along with being highly proficient in report writing and data management. Eric is very experienced with all survey methodology and has inputted in various Environmental Impact Assessment Reports, Envi- ronmental Assessments and Appropriate Assessments. Jim Dowdall, Director Enviroguide Consulting, has an MSc in Chemistry and LLM in Environ- mental and Natural Resources Law. He is an experienced ornithologist having over 40 years’ experience with particular interest in population dynamics and bird identification. He has published extensively in both National and International Ornithological Journals the most recent being in the Auk, describing the discovery of a new species of storm petrel to science by a team of Irish and American ornithologists of which he was part. Jim has served on the Irish Rare Birds Committee, the Cape Clear Bird Observatory Council and three terms as a board member of Birdwatch Ireland the most recent ending in June 2019.

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2 RELEVANT LEGISLATION

An Ecological Impact Assessment (EcIA) is a process of identifying, quantifying, and evaluat- ing potential effects of development-related, or other actions, on habitats, species and eco- systems (CIEEM, 2016). The Proposed Development at Newtownpark Avenue, Blackrock, Co. Dublin, is sub-threshold for an Environmental Impact Assessment (EIA) under the Planning and Development Regulations 2001 – 2018.

When an EcIA is undertaken as part of an EIA process it is subject to the EIA Regulations (under the EU Planning and Development [Environmental Impact Assessment] Regulations 2001-2018). An EcIA is not a statutory requirement, however it is a best practise evaluation process. This EcIA has been undertaken to support and assess the Proposed Development planning application and assess the potential impact that the Proposed Development may have on the ecology of the site and its environs. Where potential for a risk to the environment is identified, mitigation measures are proposed on the basis that by deploying these mitigation measures the risk is eliminated or reduced to an insignificant level. This EcIA is provided to assist An Bord Pleanala with its decision making in respect of the Proposed Development.

2.1 National Legislation

2.1.1 Wildlife Act 1976 and amendments The Wildlife Act 1976 was enacted in order to provide protection to birds, animals, and plants in Ireland and to control activities which may have an adverse impact on the conservation of wildlife. In regard to the listed species, it is an offence to disturb, injure or damage their breeding or resting place wherever these occur without an appropriate licence from National Parks and Wildlife Service (NPWS). This list includes all birds along with their nests and eggs. Intentional destruction of an active nest from the building stage up until the chicks have fledged is an offence. This includes the cutting of hedgerows from the 1st of Match to the 31st of Au- gust. The act also provides a mechanism to give statutory protection to Natural Heritage Are- as (NHAs). The Wildlife Amendment Act 2000 widened the scope of the Act to include most species, including the majority of fish and aquatic invertebrate species which were excluded from the 1976 Act.

2.1.2 EU Habitats Directive 1992 and EC (Birds and Natural Habitats) Regulations 2011 The EU Directive on the Conservation of Natural Habitats and of Wild Fauna and Flora ( the Habitats Directive 1992) provides protection to particular species and habitats throughout Europe. The Habitats Directive has been transposed into Irish law through the EC (Birds and Natural Habitats) Regulations 2011.

Annex IV of the EU Habitats Directive provides protection to a number of listed species, wherever they occur. Under Regulation 23 of the Habitat Directive any person who, in regards to the listed species; “Deliberately captures or kills any specimen of these species in the wild, Deliberately disturbs these species particularly during the period of breeding, rearing, hibernation and migration, Deliberately takes or destroys the eggs from the wild, or Damages or destroys a breeding site or resting place of such an animal shall be guilty of an offence.”

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2.1.3 Flora (Protection) Order, 1999 The Flora (Protection) Order grants protection to 86 species of plant in Ireland (56 vascular plants, 14 mosses, 4 liverworts and 2 stoneworts). This Act makes it illegal for anyone to up- root, cut or damage any of the listed plant species and it also forbids anyone from altering, interfering, or damaging their habitats. This protection is not confined to within designated conservation sites and applies wherever the plants are found.

2.2 International Legislation

2.2.1 EU Birds Directive The Birds Directive constitutes a level of general protection for all wild birds throughout the European Union. Annex I of the Birds Directive includes a total of 194 bird species that are considered rare, vulnerable to habitat changes or in danger of extinction within the European Union. Article 4 establishes that there should be a sustainable management of hunting of listed species, and that any large scale non-selective killing of birds must be outlawed. The Directive requires the designation of Special Protection Areas (SPAs) for listed and rare species, regularly occurring migratory species and for wetlands which attract large numbers of birds. There are 25 Annex I species that regularly occur in Ireland and a total of 153 Special Protection Areas have been designated.

2.2.2 EU Habitats Directive The Habitats Directive aims to protect some 220 habitats and approx. 1000 species throughout Europe. The habitats and species are listed in the Directives annexes where Annex I covers habitats and Annex II, IV and V cover species. There are 59 Annex I habitats in Ireland and 33 Annex IV species which require strict protection wherever they occur. The Directive requires the designation of Special Areas of Conservation for areas of habitat deemed to be of European interest. The SACs together with the SPAs from the Birds Directive from a network of protected sites called Natura 2000.

2.2.3 Bern and Bonn Convention The Convention on the Conservation of European Wildlife and Natural Habitats (Bern Convention 1982) was enacted to conserve all species and their habitats. The Convention on the Conservation of Migratory Species of Wild Animals (Bonn Convention 1979, enacted 1983) was introduced in order to give protection to migratory species across borders in Europe.

2.2.4 Ramsar Convention The Ramsar Convention on Wetlands is an intergovernmental treaty signed in Ramsar, Iran, in 1971. The treaty is a commitment for national action and international cooperation for the conservation of wetlands and their resources. In Ireland there are currently 45 Ramsar sites which cover a total area of 66,994ha

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3 METHODOLOGY

This section details the steps and methodology employed to undertake an ecological impact assessment of the Proposed Development.

3.1 Scope of assessment The specific objectives of the study were to:

- Undertake baseline ecological surveys and evaluate the nature conservation importance of the Site of the Proposed Development; - Identify and assess the direct, indirect, and cumulative ecological implications or impacts of the Proposed Development during its lifetime; and - Where possible, propose mitigation measures to remove or reduce those impacts at the appropriate stage of the development.

3.2 Desk study A desktop study was carried out to collate and review available information, datasets and documentation sources pertaining to the site’s natural environment. The desk study, completed April 2020, relied on the following sources:

- Information on species records1 and distributions, obtained from the National Biodi- versity Data Centre (NBDC) at www.biodiversityireland.ie/maps - Information on waterbodies, catchment areas and hydrological connections obtained from the Environmental Protection Agency (EPA) at www.epa.ie/gis - Information on bedrock, groundwater, aquifers and their statuses, obtained from Ge- ological Survey Ireland (GSI) at www.gsi.ie ; - Information on the network designated conservation sites, site boundaries, qualifying interests and conservation objectives, obtained from the National Parks and Wildlife Service (NPWS) at www.npws.ie ; - Satellite imagery and mapping obtained from various sources and dates including Google, Digital Globe, Bing and Ordinance Survey Ireland; - Information on the existence of permitted development, or developments awaiting decision, in the vicinity of the Proposed Development from Dún Laoghaire-Rathdown County Council, available at www.dlrcocouncil.maps.arcgis.com ; - Information on the extent, nature, and location of the Proposed Development, provided by the applicant and/or their design team; - Information on the construction methods to be followed as part of the Proposed De- velopment, taken from the Construction Environmental Management Plan submitted with this application; - The current conservation status of birds in Ireland taken from Colhoun & Cummins (2013); and

A comprehensive list of all the specific documents and information sources consulted in the completion of this report is provided in Section 10, References.

1 The Site of the Proposed Development lies within the 10km grid square O22, the 2km grid square O22H and the 1km grid square O2324. Records from the last 30 years from available datasets are given in the relevant sections of this report.

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3.3 Field Surveys

3.3.1 Habitat Surveys Habitat surveys of the Site of the Proposed Development were conducted by Enviroguide on the 7th April 2020 and 25th May 2020. Habitats were categorised according to the Heritage Council’s ‘A Guide to Habitats in Ireland’ (Fossitt, 2000) to level 3. The habitat mapping exercise had regard to the ‘Best Practice Guidance for Habitat Survey and Mapping’ (Smith et al., 2010) published by the Heritage Council. Habitats within the surrounding area of the Proposed Development were classified based on views from the site and satellite imagery where necessary (Google Earth, Digital Globe and OSI).

3.3.2 Invasive Species Surveys Invasive species surveys were carried out in conjunction with the habitat surveys on the 7th April 2020 and 25th May 2020. Information on a known Japanese Knotweed infestation at the Site of the Proposed Development was also provided by the applicant (Invas Biosecurity, 2017; Invasive Plant Solutions, 2019).

3.3.3 Bat Surveys A bat survey was carried out by Professional Ecologist Seán Meehan ACIEEM on 6th Septem- ber 2019.

3.3.3.1 Roost Inspection Surveys Roost inspection surveys were carried out in relation to the Proposed Development on 6th September 2019 by Professional Ecologist Seán Meehan.

Survey methodology followed the best-practice techniques outlined in the Bat Conservation Trusts “Bat Surveys for Professional Ecologists” (3rd edition, 2016) guidelines.

Mature trees located within the Site of the Proposed Development were inspected from ground-level for their suitability to support roosting bats.

3.3.3.2 Activity Surveys A post-sunset activity survey was carried out by Professional Ecologist Seán Meehan in relation to the Proposed Development on 6th September 2019.

Survey methodology followed the best-practice techniques outlined in the Bat Conservation Trusts “Bat Surveys for Professional Ecologists” (3rd edition, 2016) guidelines. The post-sunset (dusk) activity survey commenced at 19.33, approximately 30 minutes before sunset, and lasted until 22.03, approximately 2 hours after sunset. An A+EM3 bat detector was used to detect any bat activity within the development site and immediate area. A set transect was walked by an ecologist and the details of all records (peak frequency, species, time, location) were recorded on field sheets and 1:250 field maps.

3.3.4 Bird Surveys

3.3.4.1 Breeding Bird Survey A breeding bird survey was undertaken at the Site of the Proposed Development on 7th April 2020 and 25th May 2020. The survey methodology followed the British Trust for Ornithology’s

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(BTO) Common Bird Census (CBS) technique (Bibby et al, 1992). Surveys commenced approximately 1.5 – 2 hours after sunrise and lasted for approximately 2 hours.

A pre-determined transect was walked during both surveys. All bird species encountered were recorded on field sheets, along with the corresponding breeding evidence code.

3.3.4.2 Winter Bird Surveys Winter Bird surveys for waterfowl and shorebirds listed as SCI species for the Natura 2000 Sites located within the precautionary Zone of Influence of the Proposed Development were undertaken on the following dates in 2020:

- November 19th, - November 23rd, - November 27th, - November 31st - December 7th, - December 11th.

Surveys were carried out over 6 hours starting either at Dawn or finishing at Dusk. These timings were alternated to cover the full day. No waterbird species or other SCI species was recorded during these surveys.

3.3.5 Mammal Surveys Mammal surveys of the site were carried out in conjunction with the other field surveys. The site was searched for tracks and signs of mammals. The habitat types recorded throughout the survey area were used to assist in identifying the fauna considered likely to utilise the area. During this survey, the site was searched for tracks and signs of mammals as per Bang and Dahlstrom. (2001).

3.3.6 Other Fauna During the course of all surveys at the Site of the Proposed Development, other species of fauna were noted, and these are included in the report where applicable.

3.4 Consultation The following were consulted in relation to the Proposed Development:

- Dún Laoghaire-Rathdown County Council: Consultation and meetings were held with DLRCC on March 20th, 2020.

3.5 Assessment The value of the ecological resources, i.e. the habitats and species present or potentially present, was determined using the ecological evaluation guidance given in the National Roads Authority’s Ecological Assessment Guidelines (NRA, 2009), presented in Appendix I. This evaluation scheme, with values ranging from locally important to internationally important, seeks to provide value ratings for habitats and species present that are considered ecological receptors of impacts that may ensue from a proposal. Any habitats or species evaluated as

December 2020 Page 6 Enviroguide Consulting Residential Development Ecological Impact Assessment Newtownpark Avenue, Blackrock, Co. Dublin. being of Local Importance (higher value), or greater, are selected as Key Ecological Receptors (KERs) and are assessed further.

The assessment of the potential effect or impact of the Proposed Development on the identified KERs was carried out with regard to the criteria outlined in the draft EPA Guidelines (EPA, 2017), presented in Appendix II. These guidelines set out a number of parameters such as quality, magnitude, extent, and duration that should be considered when determining which elements of the Proposed Development could constitute impact or sources of impacts.

3.6 Limitations An extensive search of available datasets for records of rare and protected species within proximity of the Proposed Development has been undertaken as part of this assessment. However, the records from these datasets do not constitute a complete species list. The absence of species from these datasets does not necessarily confirm an absence of species in the area.

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4 BASELINE ECOLOGICAL CONDITIONS

4.1 Site Overview The subject site is located along Newtownpark Avenue, Blackrock Do Dublin. The site is situated in a primarily residential area and measures ca.1.29ha. There are two main areas; a smaller section which is heavily wooded is located along Newtownpark Avenue and forms the access point for the site while a larger section runs parallel with the road but located at the rear of Cluain Mhuire Centre. This larger rear area comprises wooded and open areas. The site is bordered to the west by the Daughters of Charity residence and gardens. A Primary school is located directly south, while a row of detached residential properties is located to the north. The rear of the residential properties abuts the northern section of the site.

4.1.1 Geology, Hydrogeology and Hydrology The subject site is located within the townland of Rockfield Co. Dublin. Rockfield and the surrounding area are located within the Kilcullen groundwater body. The overall status of this waterbody is recorded as Good (EPA, 2020).

The groundwater rock units underlying the area are classified as Dinantian Upper Impure Limestones and the sub-soil at the Site of the Proposed Development is classified as Till derived from limestones (GSI, 2020) and Made Ground (GSI, 2020). The Site of the Proposed Development area is located on a Poor Aquifer - Bedrock which is generally unproductive except for local zones (PI), with groundwater vulnerability in the area listed as High (GSI, 2020).

The Site of the Proposed Development is located within the River Dodder_SC_010 sub-catchment and in the Brewery Stream_010 (IE_EA_09B130400) sub-basin. The nearest water- course to Site of the Proposed Development, as mapped by the EPA, is the Monkstown Stream (EPA Code: 09M02) located ca.280m to the east of Site of the Proposed Development rising Deansgrange ca. 1km southeast. The Monkstown stream is culverted and flows in an easterly direction entering Dublin Bay via culvert at Salthill

4.2 Designated Sites Table 1 below presents details of the key ecological features of designated sites within 15km2 of the Proposed Development.

TABLE 1. DESIGNATED SITES OF CONSERVATION IMPORTANCE LOCATED WITHIN 15KM OF THE SITE OF THE PROPOSED DEVELOPMENT.

Site Distance Site Name Qualifying Interests Code to Site

Special Areas of Conservation (SAC)

- [1140] Tidal Mudflats and Sandflats 000210 South Dublin Bay SAC 0.79km - [1210] Annual vegetation of drift lines

2 This distance was chosen as standard practice to ensure all potential Natura 2000 sites were identified.

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- [1310] Salicornia and other annuals colonising mud and sand - [2110] Embryonic shifting dunes

Rockbill to Dalkey Is- - [1170] Reefs 003000 5.42km land SAC - [1351] Harbour Porpoise (Phocoena phocoena)

- [1140] Tidal Mudflats and Sandflats - [1210] Annual Vegetation of Drift Lines - [1310] Salicornia Mud - [1330] Atlantic Salt Meadows - [1410] Mediterranean Salt Meadows 000206 North Dublin Bay SAC 6.02km - [2110] Embryonic Shifting Dunes - [2120] Marram Dunes (White Dunes) - [2130] Fixed Dunes (Grey Dunes)* - [2190] Humid Dune Slacks - [1395] Petalwort (Petalophyllum ralfsii)

- [3110] Oligotrophic Waters containing very few miner- als - [3160] Dystrophic Lakes - [4010] Wet Heath - [4030] Dry Heath - [4060] Alpine and Subalpine Heaths Wicklow Mountains - [6130] Calaminarian Grassland 002122 9.77km SAC - [6230] Species-rich Nardus Grassland* - [7130] Blanket Bogs (Active)* - [8110] Siliceous Scree - [8210] Calcareous Rocky Slopes - [8220] Siliceous Rocky Slopes - [91A0] Old Oak Woodlands - [1355] Otter (Lutra lutra)

- [7220] Petrifying Springs* 000725 Knocksink Wood SAC 9.54km - [91E0] Alluvial Forests*

- [7220] Petrifying Springs* 000713 Ballyman Glen SAC 9.7km - [7230] Alkaline Fens

- [1230] Vegetated Sea Cliffs 000202 Howth Head SAC 10.8km - [4030] Dry Heath

- [1140] Tidal Mudflats and Sandflats - [1310] Salicornia Mud 000199 Baldoyle Bay SAC 11.4km - [1330] Atlantic Salt Meadows - [1410] Mediterranean Salt Meadows

- [1230] Vegetated Sea Cliffs 000714 Bray Head SAC 12.3km - [4030] Dry Heath

- [6210] Orchid-rich Calcareous Grassland* 001209 Glenasmole Valley SAC - [6410] Molinia Meadows 13.7km - [7220] Petrifying Springs*

- [1220] Perennial Vegetation of Stony Banks 002193 Ireland’s Eye SAC 13.8km - [1230] Vegetated Sea Cliffs

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Special Protection Areas (SPA)

- [A046] Light-bellied Brent Goose (Branta bernicla hrota) [wintering] - [A130] Oystercatcher (Haematopus ostralegus) [wintering] - [A137] Ringed Plover (Charadrius hiaticula) [wintering] - [A141] Grey Plover (Pluvialis squatarola) [wintering] - [A143] Knot (Calidris canutus) [wintering] - [A144] Sanderling (Calidris alba) [wintering] South Dublin Bay and - [A149] Dunlin (Calidris alpina) [wintering] 004024 River Tolka Estuary - [A157] Bar-tailed Godwit (Limosa lapponica) [wintering] 0.75km SPA - [A162] Redshank (Tringa totanus) [wintering] - [A179] Black-headed Gull (Chroicocephalus ridibun- dus) [wintering] - [A192] Roseate Tern (Sterna dougallii) [passage] - [A193] Common Tern (Sterna hirundo) [breeding] [passage] - [A194] Arctic Tern (Sterna paradisaea) [breeding [passage] - [A999] Wetland and Waterbirds

- [A192] Roseate Tern (Sterna dougallii) [breeding [passage] - [A193] Common Tern (Sterna hirundo) [breeding [pas- 004172 Dalkey Islands SPA 5.61km sage] - [A194] Arctic Tern (Sterna paradisaea) [breeding [passage]

- [A046] Light-bellied Brent Goose (Branta bernicla hrota) [wintering] - [A048] Shelduck (Tadorna tadorna) [wintering] - [A052] Teal (Anas crecca) [wintering] - [A054] Pintail (Anas acuta) [wintering] - [A056] Shoveler (Anas clypeata) [wintering] - [A130] Oystercatcher (Haematopus ostralegus) [wintering] - [A140] Golden Plover (Pluvialis apricaria) [wintering] - [A141] Grey Plover (Pluvialis squatarola) [wintering] 004006 North Bull Island SPA - [A143] Knot (Calidris canutus) [wintering] 5.9km - [A144] Sanderling (Calidris alba) [wintering] - [A149] Dunlin (Calidris alpina) [wintering] - [A156] Black-tailed Godwit (Limosa limosa) [wintering] - [A157] Bar-tailed Godwit (Limosa lapponica) [wintering] - [A160] Curlew (Numenius arquata) [wintering] - [A162] Redshank (Tringa totanus) [wintering] - [A169] Turnstone (Arenaria interpres) [wintering] - [A179] Black-headed Gull (Chroicocephalus ridibun- dus) [wintering] - [A999] Wetland and Waterbirds

Wicklow Mountains - [A098] Merlin (Falco columbarius) [breeding] 004040 10.4km SPA - [A103] Peregrine (Falco peregrinus) [breeding]

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004113 Howth Head Coast SPA - [A188] Kittiwake (Rissa tridactyla) [breeding] 10.9km

- [A046] Light-bellied Brent Goose (Branta bernicla hrota) [wintering] - [A048] Shelduck (Tadorna tadorna) [wintering] - [A137] Ringed Plover (Charadrius hiaticula) [wintering] 004016 Baldoyle Bay SPA 11.7km - [A140] Golden Plover (Pluvialis apricaria) [wintering] - [A141] Grey Plover (Pluvialis squatarola) [wintering] - [A157] Bar-tailed Godwit (Limosa lapponica) [wintering] - [A999] Wetland and Waterbirds

- [A017] Cormorant (Phalacrocorax carbo) [wintering] [Breeding] - [A184] Herring Gull (Larus argentatus) [Breeding] 004117 Ireland’s Eye SPA 13.6km - [A188] Kittiwake (Rissa tridactyla) [Breeding] - [A199] Guillemot (Uria aalge) [Breeding] - [A200] Razorbill (Alca torda) [Breeding]

Natural Heritage Areas (NHA)

There are no NHAs within 15km of the Proposed Development.

Proposed Natural Heritage Areas (pNHA)

000210 South Dublin Bay 0.67km

001205 Booterstown Marsh 2.35km

Dalkey Coastal Zone 001206 2.73km And Killiney Hill

001753 Fitzsimon’s Wood 4.74km

000201 Dolphins, Dublin Docks 5.47km

001207 Dingle Glen 5.68km There are no formal qualifying interests listed for proposed 001211 Loughlinstown Woods Natura Heritage Areas (pNHA). A general site synopsis is 5.69km available for most sites on the NPWS website.

000206 North Dublin Bay 5.81km

002104 Grand Canal 6.61km

002103 Royal Canal 7.52km

001202 Ballybetagh Bog 7.78km

000725 Knocksink Wood 9.24km

000713 Ballyman Glen 9.43km

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000202 Howth Head 9.48km

000991 Dodder Valley 10.54km

001768 Powerscourt Woodland 11.16km

000199 Baldoyle Bay 11.46km

001754 Dargle River Valley 11.73km

000714 Bray Head 11.98km

000178 Santry Demesne 12.55km

001769 Great Sugar Loaf 12.78km

001755 Glencree Valley 13.32km

001209 Glenasmole Valley 13.55km

000128 Liffey Valley 13.7km

000203 Ireland’s Eye 13.78km

001763 Sluice River Marsh 14.15km

000724 Kilmacanoge Marsh 14.19km

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FIGURE 1. DESIGNATED SITES WITHIN 15KM OF THE PROPOSED DEVELOPMENT.

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4.3 Habitats The habitats within the Site of the Proposed Development are coded and categorised to level 3 according to Fossitt (2000). The following habitats were identified within the Site of the Pro- posed Development boundary:

- Buildings and Artificial Surfaces (BL3); - Dry Meadows and Grassy Verges (GS2); - Recolonising Bare Ground (BL1); - Scrub (WS1); - Mixed Broadleaved Woodland (WD1); - Hedgerows (WL1); - Treelines (WL2);

4.3.1 Buildings and Artificial Surfaces (BL3) A section of this habitat type is present in the south of the Site in the form of a section of Newtownpark Avenue (Dún Laoghaire- Rathdown County Council lands), included within the scope of works due to proposed drainage and traffic works.

4.3.2 Dry Meadows and Grassy Verges (GS2) [unmanaged] This habitat is found in areas throughout the Site of the Proposed Development in an unmanaged state. This habitat coincides with areas of Japanese Knotweed (Fallopia japonica) (JKW) infestation. With little management apart from limited glyphosphate application to the Japa- nese Knotweed, this habitat type is undergoing succession to bramble (Rubus fructicosus) - rich scrub, which covers most other areas of the Site of the Proposed Development. Species recorded include: Yorkshire fog (Holcus lanatus), cock’s foot (Dactylis glomerata), perennial ryegrass (Lolium perenne), nettle (Urtica dioica), cleavers (Galium aparine), bramble (Rubus fructicosus), tree mallow (Lavatera arborea), Alexanders (Smyrnium olusatrum) and Common Hogweed (Heracleum sphondylium). Three cornered garlic (Allium triquetrum) was also recorded, predominantly in the south and south-east of the Site, in sections of woodland.

4.3.3 Recolonising Bare Ground (BL1) This habitat covers the northernmost section of The Site of the Proposed Development, where vegetation has been cleared. Species recorded include dandelion (Taraxacum vulgaria), daisy (Bellis perennis), broad-leaved dock (Rumex obtusifolius), creeping thistle (Cirsium arvense), ivy (Hedera hibernica), ribwort plantain (Plantago lanceolata) and herb Robert (Geranium robertianum).

4.3.4 Scrub (WS1) The areas of scrub within the Site of the Proposed Development are predominately located in the central/northern section; and along the south and south-eastern boundaries, amongst the areas of woodland. The dominant species in this habitat was bramble (Rubus fructicosus), forming a thick impenetrable layer in some sections. Other species recorded included: cleavers (Galium aparine), elder (Sambucus nigra), dandelion (Taraxacum vulgaria), broad-leaved dock (Rumex obtusifolius), nettle (Urtica dioica), tree mallow (Lavatera arborea) and common hogweed (Heracleum sphondylium).

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4.3.5 Mixed Broadleaved Woodland (WD1) There is a section of this habitat in the south-eastern portion of the Site of the Proposed De- velopment, joining up with a prominent treeline to the north which runs along the Site’s eastern boundary behind the Cluaim Mhuire Family Center. The most abundant tree species found here are sycamore (Acer pseudoplatanus), beech (Fagus sylvatica), ash (Fraxinus excelsior) and dense areas of willow (Salix sp.) woodland. Ground flora is primarily composed of ivy (Hedera hibernica), three cornered garlic (Allium triquetrum), common hogweed (Heracleum sphondylium) and Alexanders (Smyrnium olusatrum).

4.3.6 Hedgerows (WL1) This habitat borders the majority of the western and southern boundaries of the Site of the Proposed Development, in addition to areas in the north of the site; between sections of treeline. This habitat type is not well developed due to the man-made walls that form the main boundaries of the Site. As such it is made up of large growths of ivy (Hedera hibernica), bramble (Rubus fructicosus), and elder (Sambucus nigra); overlapping the walls and appearing as large clumps along the boundaries.

4.3.7 Treelines (WL2) There is a prominent treeline of evergreen trees along the western boundary of the Site of the Proposed Development comprised of cypress species as well as a fir species (Abies sp. A second treeline is present along the eastern boundary of the Site, along the wall behind the Family center. This treeline is formed by a mix of ash (Fraxinus excelsior), sycamore (Acer pseudoplatanus), beech (Fagus sylvatica) and an individual large pine tree, possibly Austrian pine (Pinus nigra).

4.3.8 Habitat Evaluation Habitats have been evaluated below in Table 2 for their conservation importance, based on the NRA evaluation scheme (NRA, 2009b). Those selected as key ecological receptors are those which are evaluated to be of at least local importance (higher value). The impacts of the Proposed Development on these receptors are assessed below in section 6.2. The summary in Table 2 below indicates the evaluation rating assigned to each habitat. The rationale behind these evaluations is also provided.

TABLE 2. EVALUATION OF HABITATS RECORDED WITHIN THE SITE OF THE PROPOSED DEVELOP- MENT.

Key Ecological Species Evaluation Rationale Receptor (KER)

Buildings and Artifi- No Conservation Section of road, no ecological value. No cial Surfaces (BL3) Value

Unmanaged grassland undergoing succes- Dry Meadows and Local importance sion to scrub. Largely taken up by sections No Grassy Verges (GS2) (lower value) of Japanese Knotweed under treatment. Not of conservation value.

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Recolonising Bare Local importance Highly modified and not of conservation No Ground (BL1) (lower value) value.

Largely made up of sprawling sections of Local importance bramble. May provide some shelter/forage Scrub (WS1) No (lower value) for local fauna, but not considered of conservation value.

In the context of the Site and its urban sur- Mixed Broadleaved Local importance roundings this wooded area provides roost- Yes Woodland (WD1) (Higher value) ing/foraging/nesting habitat for a variety of faunal species.

Small sections of undeveloped hedgerow Local importance Hedgerows (WL1) made up predominantly of ivy clumps along No (Lower value) boundary walls. Low conservation value.

Although some sections composed of non- native species, the treeline particularly Local importance along the eastern boundary wall, behind Treelines (WL2) Yes (Higher value) the Family centre, likely provides roosting/foraging/nesting habitat for a variety of faunal species.

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FIGURE 2. HABITAT MAP OF SITE OF THE PROPOSED DEVELOPMENT AND VICINITY.

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4.4 Species and Species Groups

4.4.1 Flora

4.4.1.1 Rare and Protected Flora The Site of the Proposed Development is located within the Ordnance Survey National Grid 10km Square O22. Species records from the National Biodiversity Data Centre (NBDC) online database for the 10km square O22 were studied for the presence of rare or protected flora species. In addition, a search of the two-kilometre (O22E and O22J) and 1km (O2128 and O2228) grid squares encompassing the Site of the Proposed Development on the online database was completed, and these records also added. Table 3 presents details of the rare and protected flora species found within the 10km, 2km and 1km squares pertaining to the Site of the Proposed Development.

TABLE 3. RECORDS OF RARE OR PROTECTED FLORA FOR THE SURROUNDING 10KM (O22), 2KM (O22E AND O22J) AND 1KM (O2128 AND O2228) GRID SQUARES FROM THE NBDC.

Species Date of last Name Database Designation Group record

Lesser Copperwort Flora Protection (Cephaloziella massa- Moss 13/04/2008 Bryophytes of Ireland Order; Vulnerable longi)

Lead-moss Flora Protection Moss 13/04/2008 Bryophytes of Ireland (Ditrichum plumbicola) Order; Endangered

Round-leaved Crane's- Flowering Online Atlas of Vascular Threatened Spe- bill 21/04/2019 plant Plants 2012-2020 cies: Endangered (Geranium rotundifolium)

Threatened Spe- Corncockle Flowering Online Atlas of Vascular 01/05/2019 cies: Regionally (Agrostemma githago) plant Plants 2012-2020 Extinct

Threatened Spe- Cornflower (Centaurea Flowering Online Atlas of Vascular 01/05/2019 cies: Regionally cyanus) plant Plants 2012-2020 Extinct

4.4.1.2 Invasive Species There are records for 21 species of flora considered to be invasive within the 10km (O22), 2km (O22J and O22E) and 1km (O2128 and O2228) grid squares within which the Site of the Proposed Development is located. Details of these records are listed in Table 4 below.

Japanese Knotweed was recorded during Site surveys and is known to be established in several locations at the Site. For additional detail see assessment report on Japanese Knotweed present at the Site by Invasive Plant Solutions (IVP 2019) appended in Appendix V.

Three-cornered Garlic was also recorded in several clumps in the south of the Site, with a number of Sycamore trees also present.

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TABLE 4. RECORDS OF INVASIVE SPECIES OF FLOWERING PLANT FOR THE SURROUNDING 10KM O22), 2KM (O22J & O22E) AND 1KM (O2128 & O2228) GRID SQUARES FROM THE NBDC.

Grid Date of last Species Source Designations square record

American Skunk-cab- Species Data from - Medium Impact Invasive bage O22 07/04/2005 the National Vege- Species (Lysichiton americanus) tation Database - Regulation S.I. 477 O22 01/12/2018 Online Atlas of Vas- Butterfly-bush O22E 28/08/2019 - Medium Impact Invasive cular Plants 2012- (Buddleja davidii) 022J 19/03/2017 Species 2020 O2128 22/05/2017

- High Impact Invasive Spe- Canadian Waterweed River Biologists' Da- O22 07/07/2009 cies (Elodea canadensis) tabase (EPA) - Regulation S.I. 477 Online Atlas of Vas- Cherry Laurel - High Impact Invasive Spe- O22 24/05/2016 cular Plants 2012- (Prunus laurocerasus) cies 2020

Common Broomrape BSBI tetrad data for - Medium Impact Invasive O22 31/12/2010 (Orobanche minor) Ireland Species

Giant Hogweed Online Atlas of Vas- - High Impact Invasive Spe- (Heracleum mantegazzi- O22 27/06/2018 cular Plants 2012- cies anum) 2020 - Regulation S.I. 477 Himalayan Honey- Online Atlas of Vas- - Medium Impact Invasive suckle O22 21/10/2018 cular Plants 2012- Species (Leycesteria formosa) 2020

- Medium Impact Invasive Himalayan Knotweed National Invasive O22 25/11/2017 Species (Persicaria wallichii) Species Database - Regulation S.I. 477

- High Impact Invasive Spe- Hottentot-fig National Invasive O22 24/07/2017 cies (Carpobrotus edulis) Species Database - Regulation S.I. 477

- High Impact Invasive Spe- Indian Balsam National Invasive O22 31/07/2009 cies (Impatiens glandulifera) Species Database - Regulation S.I. 477 O22 19/07/2018 Online Atlas of Vas- - High Impact Invasive Spe- Japanese Knotweed O22E 28/04/2011 cular Plants 2012- cies (Fallopia japonica) O22J 25/05/2019 2020 - Regulation S.I. 477 O2228 25/05/2019

Least Duckweed National Invasive - Medium Impact Invasive O22 11/10/2015 (Lemna minuta) Species Database Species

New Zealand Pigmy - High Impact Invasive Spe- National Invasive weed O22 26/09/2014 cies Species Database (Crassula helmsii) - Regulation S.I. 477

- High Impact Invasive Spe- Nuttall's Waterweed O22 31/12/2007 National Invasive cies (Elodea nuttallii) Species Database - Regulation S.I. 477 Online Atlas of Vas- Russian-vine - Medium Impact Invasive O22 20/04/2018 cular Plants 2012- (Fallopia baldschuanica) Species 2020

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Online Atlas of Vas- - Medium Impact Invasive Sea-buckthorn O22 10/05/2018 cular Plants 2012- Species (Hippophae rhamnoides) 2020 - Regulation S.I. 477 Online Atlas of Vas- Sycamore 01/12/2018 - Medium Impact Invasive O22 cular Plants 2012- (Acer pseudoplatanus) Species 2020

O22 10/05/2018 Online Atlas of Vas- - Medium Impact Invasive Three-cornered Garlic O22E 04/04/2017 cular Plants 2012- Species (Allium triquetrum) O2128 04/04/2017 2020 - Regulation S.I. 477 Online Atlas of Vas- Traveller's-joy O22 01/12/2018 - Medium Impact Invasive cular Plants 2012- (Clematis vitalba) O22J 19/03/2017 Species 2020

Turkey Oak Irish Vascular Plant - Medium Impact Invasive O22 27/08/2006 (Quercus cerris) Data - Paul Green Species

Wall Cotoneaster BSBI tetrad data for - Medium Impact Invasive (Cotoneaster horizon- O22 31/12/2010 Ireland Species talis)

4.4.2 Mammals (excl. bats) Records for terrestrial mammals were retrieved from the NBDC online database. Table 5 below lists these species, their date of last record and summarises their protected status. This information is collected differently by the different bodies involved but when detailed collec- tively presents a more complete overall picture of the potential for impact on mammals by the Proposed Development.

TABLE 5. RECORDS OF TERRESTRIAL MAMMALS FOR THE SURROUNDING 10KM (O22), 2KM (O22J & O22E) AND 1KM (O2128 & O2228) GRID SQUARES FROM THE NBDC.

Grid Date of last Species Source Designation square record

NATIVE

Mammals of Ireland Badger O22 18/08/2017 2016-2025; - Wildlife (Amendment) Act 2000 (Meles meles) Roadkill Survey - Bern Convention Appendix III

O22 17/08/2017 Mammals of Ireland Hedgehog O22E 09/05/2018 2016-2025; - Wildlife (Amendment) Act 2000 (Erinaceus euro- O22J 01/09/2013 Mammals in Ireland - Bern Convention Appendix III paeus) O2228 01/09/2013 2010-2015

Irish (mountain) Hare Atlas of Mammals in O22 24/06/2012 - Bern Convention Appendix III (Lepus timidus hiber- Ireland 2010-2015 nicus)

Irish Stoat Mammals of Ireland - Wildlife (Amendment) Act 2000 (Mustela erminea O22 26/08/2017 2016-2025 - Bern Convention Appendix III subsp. hibernica)

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Mammals of Ireland - EU Habitats Directive – Annex Otter O22 28/10/2016 2016-2025; Atlas of II & IV (Lutra lutra) O22J 30/08/2015 Mammals in Ireland - Wildlife (Amendment) Act 2000 2010-2015 - Bern Convention Appendix III

Pygmy Shrew Mammals of Ireland O22 07/07/2017 - Wildlife (Amendment) Act 2000 (Sorex minutus) 2016-2025 Red Deer Atlas of Mammals in O22 16/07/2015 - Wildlife (Amendment) Act 2000 (Cervus elaphus) Ireland 2010-2015 O22 16/01/2018 Mammals of Ireland O22E Red Fox 09/05/2018 2016-2025; Atlas of O22J - n/a (Vulpes vulpes) 21/02/2016 Mammals in Ireland O2128 07/12/2012 2010-2015 O2228 24/02/2015

Mammals of Ireland Red Squirrel O22 19/11/2017 2016-2025 - Wildlife (Amendment) Act 2000 (Sciurus vulgaris)

Mammals of Ireland Wood Mouse O22 19/08/2017 2016-2025; Atlas of (Apodemus sylvati- O22J 20/07/2015 - n/a Mammals in Ireland cus) O2228 20/07/2015 2010-2015;

NON-NATIVE

Mammals of Ireland O22 22/06/2017 Brown Rat 2016-2025; Atlas of - High Impact Invasive Species O22J 27/10/2014 (Rattus norvegicus) Mammals in Ireland - Regulation S.I. 477 (Ireland) O2228 27/10/2014 2010-2015

Mammals of Ireland O22 10/01/2018 2016-2025; Atlas of Eastern Grey Squir- O22E 22/10/2016 Mammals in Ireland rel - High Impact Invasive Species O22J 27/08/2015 2010-2015; Mam- (Sciurus caro- - Regulation S.I. 477 (Ireland) O2128 22/10/2016 mals of Ireland 2016- linensis) O2228 31/12/2012 2025; Irish Squirrel Survey 2012

European Rabbit Mammals of Ireland - Medium Impact Invasive Spe- (Oryctolagus cunicu- O22 02/07/2017 2016-2025 cies lus)

Feral Goat Mammals of Ireland - Medium Impact Invasive Spe- O22 26/12/2017 (Capra hircus) 2016-2025 cies

Mammals of Ireland O22 21/05/2016 House Mouse 2016-2025; Atlas of O22J 19/07/2015 - High Impact Invasive Species (Mus musculus) Mammals in Ireland O2228 19/07/2015 2010-2015

Raccoon National Invasive O22 24/08/2014 - High Impact Invasive Species (Procyon lotor) Species Database

Sika Deer Deer of Ireland Data- - High Impact Invasive Species O22 31/12/2008 (Cervus nippon) base - Regulation S.I. 477 (Ireland)

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No active badger setts or signs of badger presence (e.g. snuffle holes, latrines, tracks etc.) were recorded during field surveys. However, a burrow was recorded during the site survey within the wooded area in the south-east of the Site. Although seemingly overgrown and in disuse, it may be an old badger sett and it is possible that badger utilise the Site of the Pro- posed Development occasionally. There is also potential habitat for hedgehog, stoat and pygmy shew within the area of mixed broadleaved woodland, scrub and hedgerows present within the site.

The red squirrel populations in Dún Laoghaire-Rathdown are now confined to two remaining areas: a small population in Killiney Hill Park and a larger population in coniferous plantations in the Dublin Mountains (Lawton et al., 2015). It is therefore considered that red squirrel are unlikely to occur within the Site of the Proposed Development. Similarly, the closest red deer population (the majority of which are hybrids) is associated with the Dublin/Wicklow Mountains and this species is therefore not considered further in this report.

There were no watercourses or waterbodies recorded during site surveys and as such, it is not expected that otter would utilise the Site due to the lack of any suitable habitat for this species within the general surrounds of the Site of the Proposed Development, and the residential/built-up nature of the lands surrounding the Site itself.

Fox was not recorded directly during site surveys although this species is widespread in the locality and may be present. While no rabbits were observed during surveys, it is considered possible that they may be present in the area, as could brown rat and house mouse. However, none of the species listed in this paragraph are of current conservation concern and are therefore not considered further in this assessment.

4.4.3 Bats Six species of bat have been recorded within the 1km, 2km and 10km grid squares which encompass the Site of the Proposed Development. These species records are listed in Table 6.

TABLE 6. RECORDS OF BATS FOR THE SURROUNDING 10KM (O22), 2KM (O22J & O22E) AND 1KM (O2128 & O2228) GRID SQUARES FROM THE NBDC.

Grid Date of last Species Source Designation square record

Brown Long-eared - EU Habitats Directive - Annex O22 05/09/2012 National Bat Data- Bat IV base of Ireland (Plecotus auritus) - Wildlife (Amendment) Act 2000

- EU Habitats Directive - Annex Daubenton's Bat O22 17/09/2005 National Bat Data- IV (Myotis daubentonii) base of Ireland - Wildlife (Amendment) Act 2000

O22 05/09/2012 - EU Habitats Directive - Annex Leisler’s Bat National Bat Data- O22E 01/07/2004 IV (Nyctalus leisleri) base of Ireland O22J 01/06/2004 - Wildlife (Amendment) Act 2000

- EU Habitats Directive - Annex Natterer's Bat O22 16/07/2007 National Bat Data- IV (Myotis nattereri) base of Ireland - Wildlife (Amendment) Act 2000

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Common Pipistrelle 05/09/2012 - EU Habitats Directive - Annex O22 National Bat Data- (Pipistrellus pipistrel- 01/07/2004 IV O22E base of Ireland lus sensu lato) - Wildlife (Amendment) Act 2000

Soprano Pipistrelle - EU Habitats Directive - Annex O22 05/09/2012 National Bat Data- (Pipistrellus pyg- IV O22E 01/07/2004 base of Ireland maeus) - Wildlife (Amendment) Act 2000

4.4.3.1 Roost Inspection Surveys Trees on site were examined for features that may be of possible use by bats for roosting. Such features include cracked and damaged limbs and branches, rot holes, lifting bark and natural cavities.

Several mature trees of note were recorded as having bat roost potential. A large mature, ivy- covered Sycamore located in a northern section of the Site; a very large mature Aspen containing split limbs, lifting bark and dying sections of wood, located in the same area; a large mature conifer species along the Site’s western boundary-wall, with a damaged/split trunk; and a mature Sycamore and Beech tree located along the boundary wall behind Cluain Mhuire Family centre, that were not entirely visible but may have potential roost features.

Table 2 from the Bat Survey Report is reproduced below detailing the trees with bat potential and adding in the numbers assigned to these trees in the Arborists Report:

Tree Species Location ITM Features Sycamore 721913,728638 Mature, notably large stature, ivy covered. Unable to view entire tree. T63 Aspen 721915,728622 Mature, girth of 7 metres at chest height, split limbs, dying sections, lifting bark, Unable to view entire tree. T64 (Poplar) Conifer Species 721885,728583 Damaged trunk with split. T82 (Douglas Fir) Beech 721937,728601 Mature tree. Unable to view entire tree. Possible features. T69 Sycamore 721931,728591 Mature tree. Unable to view entire tree. Possible features. T70

4.4.3.2 Activity Surveys A total of three species were recorded within the Site of the Proposed Development during the Bat survey carried out on the 6th September 2019; Common Pipistrelle, Soprano Pipistrelle and a brief fly-by by a Leisler’s Bat. Approximately 14 passes were recorded during the 2.5- hour long survey period. Illumination from the buildings and grounds to the east of the site was notable and possibly decreases the level of bat activity along the eastern boundary of the site.

Weather conditions during the survey were optimal, with dry, calm, and mild weather throughout the survey period. Temperatures ranged from +16°C at the commencement of the survey to +14°C on completion.1

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4.4.3.3 Emergence No bats were observed emerging from the aforementioned roost potential trees however this does not negate the requirement for future examinations prior to the commencement of any works.

4.4.4 Birds

4.4.4.1 Breeding Birds Results from the breeding bird survey carried out at the Site of the Proposed Development on 7th April 2020 and 25th May 2020 are shown in Table 7 below. A total of 27 species were identified within the Site of the Proposed Development with 6 species identified as ‘confirmed breeding’ and a further 17 species identified as ‘probable breeders’, based on activity observed during the two surveys.

TABLE 7. BIRD SPECIES RECORDED WITHIN THE PROJECT SITE DURING SITE BREEDING BIRD SUR- VEYS AND THEIR ASSOCIATED BREEDING STATUS CODES.

Breeding BoCCI3 Species EU Designation Evidence Breeding Status Status Code4

Blackbird Green N/A FY Confirmed breeding

Robin Amber N/A S Probable breeder

Song Thrush Green N/A S Probable breeder

Hooded Crow Green N/A ON Confirmed breeding

Bullfinch Green N/A S Probable breeder

Woodpigeon Green N/A ON Confirmed breeding

Blackcap Green N/A S Probable breeder

Blue Tit Green N/A FL Confirmed breeding

Chaffinch Green N/A S Probable breeder

Goldfinch Green N/A S Probable breeder

Great Tit Green N/A S Probable breeder

Wren Green N/A S Probable breeder

Magpie Green N/A FL Confirmed breeder

Dunnock Green N/A S Probable breeder

Starling Amber N/A S Probable breeder

Willow Warbler Green N/A S Probable breeder

3 Birds of Conservation Concern in Ireland 2014-2019 (Calhoun, K. and Cummins, S., 2012). 4 British Trust for Ornithology (BTO) Breeding Evidence Code. See Appendix III.

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Chiffchaff Green N/A S Probable breeder

Jackdaw Green N/A FY Confirmed breeder

Goldcrest Amber N/A S Probable breeder

Long tailed Tit Green N/A S Probable breeder

Coal Tit Green N/A S Probable breeder

Collared Dove Green N/A P Probable breeder

Mistle Thrush Amber N/A S Probable breeder

In addition, the following species were recorded on or flying over the site that were not considered to be breeding or associating with the site: Swallow, Swift and House Martin. These species are aerial feeders and can travel some distance from their breeding sites to feed. Rook was recorded on the site in May 2020 but there is no evidence to suggest breeding. (Rooks breed in large colonies known as Rookeries).

4.4.4.2 Winter Bird Survey Results Surveys of potential usage of the Site lands by wintering waterfowl and shore bird species, such as those listed as SCI species for nearby Natura 2000 SPA Sites, were carried out over 6 days in November and December 2020.

Over the course of the 36 hours of surveys, covering both dawn and dusk, no evidence of usage by any of the species in question was recorded; with the only shore bird species recorded in proximity to the Site being the occasional Gull, Larus sp. flying overhead. All bird activity recorded at the Site comprised the common hedgerow species as listed above in Table 7.

It is noted the usage of the Site by SCI species is deemed highly unlikely, due to the inherent unsuitability of the habitats present at the Site for these species and their specific needs. The lands at the Site of the Proposed Development consist of a mosaic of high-sward rank grassland, dense bramble scrub and woodland; none of which provide suitable ex-situ nesting, roosting, foraging habitat for the waterfowl and shorebirds in question.

4.4.5 Fish

4.4.5.1 Atlantic Salmon (Salmo salar) & Trout (Salmo trutta)

There are two species of salmonid associated with freshwater habitats in Ireland, namely At- lantic salmon (Salmo salar) and brown trout (Salmo trutta). The Atlantic salmon is listed as an Annex II species under the Habitat Directive. There are no records for either of these species within the relevant 10km (O22), 2km (O22J & O22E) and 1km (O2128 & O2228) grid squares.

There are no waterbodies within the Site of the Proposed Development, or within the immediate vicinity, and therefore no hydrological links with any waterbodies that might support these species. As such they are not considered further in this report.

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4.4.5.2 Lamprey (Lampetra sp. & Petromyzon marinus) All three lamprey species recorded in Ireland are listed on Annex II of the EU Habitats Di- rective. Lamprey larval burrows are characteristically found at eddies or backwaters, on the inside of bends or behind obstructions, where current velocity is below that of the main stream and where organic material tends to accumulate (Kelly & King, 2001). There are no records for any species of lamprey within either the 10km grid square O22, 2km grid squares O22J & O22E or 1km grid squares O2128 & O2228.

4.4.5.3 European eel (Anguilla anguilla) European eel is a red listed species5 and are currently considered to be one of the most threatened fish species in Ireland (King et al. 2011). There are no records for European eel within either the 10km grid square O22, 2km grid squares O22J & O22E or 1km grid squares O2128 & O2228.

4.4.6 Amphibians Common Frog (Rana temporaria) have been recorded in the 10km grid square O22, the 2km square O22J and the 1km square O2228.

The absence of any waterbodies, ditches or ponds at the Site of the Proposed Development suggesting a lack of amphibian breeding habitat would indicate that the presence of this species or any other amphibian at the Site is unlikely. As such this group will not be assessed further in this report.

4.4.7 Invertebrates There are no records of white-clawed crayfish within any of the grid squares encompassing the Site of the Proposed Development.

There are no records of Marsh Fritillary butterfly (Euphydryas aurinia) within the last 30 years for the 10km grid square O22 and no individuals of this species or it’s associated food plant; devil’s bit scabious (Succisa pratensis), were recorded during the field surveys.

4.4.8 Other species and species groups No records of common lizard exist within the 10km square O22 and there is little habitat of value for common lizard (Lacerta vivipara) within the Site of the Proposed Development.

5 The status of a species is designated by the relevant authorities as red amber or green. Red list species range from vulnerable to extinct, amber list species with unfavourable conservation status or declining population and green list species are those which are not currently of conservation concern.

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4.4.9 Fauna Evaluation Fauna that have the potential to utilise areas within the immediate area of the Proposed De- velopment, or for which records exist in the wider area, have been evaluated below in Table 8 for their conservation importance. This evaluation follows the Guidelines for Assessment of Ecological Impacts of National Road Schemes (NRA, 2009b). The rationale behind these evaluations is also provided.

TABLE 8. EVALUATION OF FAUNA RECORDED WITHIN THE SURROUNDING AREA.

Key Ecological Species Evaluation Rationale Receptor (KER)

No active setts or tracks were identified National during surveys, however a disused animal Badger Yes Importance burrow was recorded and may have been a badger sett previously.

Suitable habitat within Site of the Proposed National Hedgehog Development and species likely to utilise Yes Importance surrounding area.

National No suitable habitat present within develop- Irish (mountain) Hare No Importance ment site.

National No suitable habitat present within develop- Irish Stoat No Importance ment site.

International No suitable habitat present within develop- Otter No Importance ment site.

National Potential habitat within the Site of the Pro- Pygmy Shrew Yes Importance posed Development.

National Not considered likely to utilise areas within Red Deer No Importance the Site of the Proposed Development.

Site of the Proposed Development is not National Red Squirrel located within the two areas of remaining No Importance populations in south Dublin.

3 species of bat recorded within Site of the International Bat assemblage Proposed Development. Roost potential in Yes Importance some mature trees.

One amber listed species recoded at de- Bird assemblage National velopment site (Robin) as a probable Yes (Amber listed) Importance breeder.

Bird assemblage County Numerous species recorded likely breeding Yes (Green listed) Importance within Site of the Proposed Development.

No potential habitat within the Site of the International Common Frog Proposed Development.or links to potential No Importance aquatic habitat.

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5 DESCRIPTION OF THE PROPOSED DEVELOPMENT

The development will consist of the demolition of the existing c. 26sqm single storey shed on site and construction of a residential development comprising 140 no. residential apartments and duplex units across 5 no. 2 to 5 storey buildings (with a basement under Blocks C + D), an ancillary single storey concierge/reception building, 97 no. car-parking spaces, 226 no. cycle spaces, a single storey ESB substation, hard and soft landscaped areas, public lighting, attenuation, service connections, bin stores, a new pedestrian crossing on Newtownpark Av- enue and all ancillary site development works, all on the 1.46ha site.

The development will consist of the demolition of the existing c. 26sqm single storey shed on site and construction of a residential development comprising;

• 140 no. apartment and duplex units across 5 no. 2-5 storey buildings (Blocks C&D over basement) comprising 1 studio apartment, 59 no. 1 bedroom apartments, 71 no. 2 bedroom apartments and 9 no. 3 bedroom apartments (along with a ‘linked’ single storey amenity building) as follows:

• Block A (4 storeys) comprises 32 no. apartments [balconies on all elevations] consisting of 17 no. 1 bedroom, and 15 no. 2 bedroom apartments;

• Block B (5 storeys) comprises 40 no. apartments [balconies on all elevations] consisting of 21 no. 1 bedroom and 19 no. 2 bedroom apartments;

• Block C (4 - 5 storeys over basement) comprises 31 no. apartments [balconies on all elevations] consisting of 1 no. studio apartment, 8 no. 1 bedroom, 17 no. 2 bedroom and 5 no. 3 bedroom apartments;

• Block D (4 storeys over basement) comprises 28 no. apartments [balconies on all elevations] consisting of 9 no. 1 bedroom, 15 no. 2 bedroom and 4 no. 3 bedroom apartments;

• Block E (2 - 3 storeys) comprises 9 no. duplex units [balconies on north and south elevations] consisting of 4 no. 1 bedroom units and 5 no. 2 bedroom units;

• Communal Amenity Space (889sqm) and public open space (1,680sqm) totalling 2,569sqm is provided throughout the site including internal amenity space/concierge area totalling 175sqm within a single story ‘linked’ building between Blocks A and B;

• Vehicular access to the development will be from the upgraded existing access from Newtownpark Avenue and will extend throughout the site linking to the basement car parking level (as well as provision of a future potential links to lands to the west and to Cluain Mhuire);

• Provision of 97 no. car parking spaces (29 no. surface car parking and 68 no. basement car parking); 226 no. cycle parking spaces (56 no. surface cycle parking space and 170 no. basement car parking) and 6 no. motorcycle spaces;

• Provision of a single storey ESB substation, hard and soft landscaped areas, public lighting, attenuation, service connections, bin stores, and a new pedestrian crossing on Newtownpark Avenue and all ancillary site development works.

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FIGURE 3. ARCHITECT DRAWING OF PROPOSED SITE LAYOUT, ADAPTED FROM DRAWING NO: 950677 CMB P 0003 PROPOSED SITE PLAN (HENRY J LYONS, 20TH OCTOBER, 2020).

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6 POTENTIAL IMPACTS OF THE PROPOSED DEVELOPMENT

6.1 Impacts on Designated Sites The closest Natura 2000 site to the Site of the Proposed Development is the South Dublin Bay and River Tolka Estuary SPA, ca. 0.75km to the north. The Appropriate Assessment Screen- ing Report containing information for the purposes of Stage 1 Screening for AA is presented in a separate document with this application, the conclusions of which are presented below.

“In conclusion, upon the examination, analysis and evaluation of the relevant information including, in particular, the nature of the Proposed Development and the likelihood of significant effects on any Natura 2000 site, in addition to considering possible in-combination effects, and applying the precautionary principles, it is concluded by the authors of this report that, on the basis of objective information; the possibility may be excluded that the Proposed Development will have a significant effect on any of the Natura 2000 sites listed below:

• South Dublin Bay SAC [000210] • North Dublin Bay SAC [000206] • Rockabill to Dalkey Island SAC [003000] • Wicklow Mountains SAC [002122] • Howth Head SAC [000202] • Knocksink Wood SAC [000725] • Glenasmole Valley SAC [001209] • Baldoyle Bay SAC [000199] • Ballyman Glen SAC [000713] • Ireland’s Eye SAC [002193] • Bray Head SAC [000714] • South Dublin Bay and River Tolka Estuary SPA [004024] • North Bull Island SPA [004006] • Dalkey Islands SPA [004172] • Wicklow Mountains SPA [004040] • Baldoyle Bay SPA [004016] • Howth Head Coast SPA [004113] • Ireland’s Eye SPA [004117]” Thus, it can be concluded on the basis of the results of Stage 1 of the Appropriate Assessment process that there is no requirement to proceed to Stage 2 of said process; and the preparation of a Natura Impact Statement (NIS) is not required.

There are no Natural Heritage Areas (NHAs) within 15km of the Proposed Development. The closest proposed NHA is South Dublin Bay pNHA, located ca. 0.67km to the north.

Although there are no direct hydrological connections between the Proposed Development and both the above pNHA, or any other pNHA, a potential indirect hydrological impact pathway has been identified via the surface water sewer on Newtownpark Avenue that will service the Site. Stormwater is proposed to be discharged to the existing surface water sewer on New- town-park Avenue, which discharges to the Irish Sea at West Pier in Dún Laoghaire Harbour.

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A Hydrological and Hydrogeological Qualitative Risk Assessment was carried out by AWN Consulting (contained in a separate report as part of this application) to assess the potential for any likely significant impacts on receiving waters within protected areas, during both the construction and operational phase of the Proposed Development.

Regarding the potential impact pathway via contaminated surface water run-off during the construction and operation of the Proposed Development, the risk assessment states:

“There is no direct open-water pathway between the site and Dublin Bay. However, should any silt-laden stormwater from construction manage to enter the public stormwater sewer i.e., without on-site mitigation, the suspended solids will naturally settle within the surface water drainage system or naturally settle at the point of discharge (Dublin Bay). Standard mitigation e.g., the use of a silt buster or similar to allow settlement of any silt laden stormwater during construction will be incorporated into the construction plan design to minimise any impacts on stormwater drains. However, in the event of a worst-case hydrocarbon leak of 1000L, there is a low potential (if unmitigated at the site) for hydrocarbon concentrations slightly in excess of background water quality (statutory concentrations as outlined in S.I. No. 272 of 2009 and S.I. No. 77 of 2019 amendment) by at the stormwater outfall to the bay. Given the short distance from the site to the discharge point to the Dublin Bay (West Pier, c. 950 m from the site) and based on this loading, the impact would be local and temporary due to dilution within the drainage pipes and bay. Overall, there would be no perceptible risk to water requirements for the Natura sites in Dublin Bay based on loading, mixing levels and high level of dilution in Dublin bay.”

“During operation, the potential for sediment runoff is low based on the SUDs design measures. In addition, the potential for hydrocarbon discharge is quite minimal based on an individual vehicle (70 litres) leak being the only source for hydrocarbon release. The drainage design also incorporates a petrol interceptor system and significant attenuation prior to discharge to the public sewer. However, even if the operation of the proposed SuDS, interceptor and attenuation systems are excluded from consideration, there is no likely exceedance of water quality objectives as outlined in S.I. No. 272 of 2009 and S.I. No. 77 of 2019b) in the worst-case scenarios described ...”

As such, it is deemed that there is no potential for significant impacts within South Dublin Bay pNHA, or any other pNHA, due to the absence of any direct impact pathways, hydrological or other, linking these protected sites and the Proposed Development.

6.2 Impacts on Habitats and Flora The Proposed Development will result in the loss of the majority of habitats currently present within the Site of the Proposed Development. This includes the following habitat types

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Two of the above habitats are considered of high conservation value Mixed Broadleaved Woodland (WD1) and Treelines (WL2).

6.2.1 Mixed Broadleaved Woodland (WD1) The Proposed Development as it stands will involve the removal of the majority of the section of this habitat at the Site to make way for the apartment blocks to be located in the center/eastern section and south-eastern section of the Site. It is noted that the majority of these trees are classed as category C trees by the arboriculturist and considered to be either trees of “low quality with an estimated life expectancy of at least 10 years, or young trees with a stem di- ameter below 150mm”. In addition a number of the trees to be removed in this section of woodland are classed as category U trees and are described as “Those in such a condition that they cannot realistically be retained as living trees in the context of the current land use for longer than 10 years”.

It is considered that the loss of these trees, although it will represent a loss of some potential roosting/foraging/nesting habitat for a variety of mammal, insect and bird species, is not considered to be of high conservation concern due to their poor quality. However, there are also a number of category B trees included in the proposed works that will be removed. These are described as “Trees of moderate quality with an estimated life expectancy of at least 20 years”, and their loss would be of greater significance due to their inherent quality. The loss of this habitat type associated with the Proposed Development is considered to be a negative, moderate, permanent impact.

6.2.2 Treelines (WL2) The Proposed Development will involve the loss of trees from the conifer treeline along the western Site boundary as it stands. These trees for proposed removal are comprised of one Category B Conifer (T81) and one category U conifer (T82). Further north along the western boundary there are three category B trees (T63, T57 and T58 sycamores) and one Category C tree (T64 poplar). Within the treeline that runs along the eastern Site boundary, behind the Family centre, one category A tree is to be removed and a number of smaller younger category C trees. Again, the loss of these trees will represent some loss in potential habitat to a variety of mammal, insect, and bird species. The loss of this habitat type associated with the Proposed Development is considered to be a negative, moderate, permanent impact.

6.2.3 Impact of Japanese Knotweed remediation works. It is also noted however, that the above areas of woodland and treeline are within close proximity to the two main areas of Japanese Knotweed (JKW) infestation at the Site of the Pro- posed Development. A previous survey and assessment of JKW infestation at the Site in 2017 (Invas Biosecurity, 2017) concluded that there were 2 main areas of infestation named “JK1” in the central section of the Site, and “JK2” in the south-eastern portion of the Site, see Figure 4 below. The infestations were subsequently treated in-situ with herbicide and fenced off with signage.

A further assessment carried out in 2019 by Invasive Plant Solutions concluded that the extent of the infestation had not changed significantly since the 2017 assessment was carried out and that, on consideration of a range of potential management/treatment strategies for JKW at the Site, the only suitable and practical remediation strategy in the context of the Proposed

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Development; was the excavation and removal off-site of all JKW plant matter and infected soils.

There are several remediation options available for controlling JKW. These are, however, impacted by the nature and constraints presented by a project or site. In this instance, the management options for JKW are restricted because of the urban nature of the site and the intention to complete the development over the short term.

Treatment with herbicides is generally not considered viable for a project such as this because this treatment method requires the application of herbicide to the full area of infestation, with annual or bi-annual applications carried out over a minimum of three to four years, with a further minimum two years of monitoring to validate its eradication. Since development works are intended to proceed as soon as practicable, there is not enough time available to follow this course of treatment safely and effectively. Therefore, the excavation and removal of all Japanese Knotweed material (vegetation, roots and soil containing root material) from all areas involving construction is recommended.

However, it is proposed that soft landscaping be implemented where possible, for example within the rooting areas of T73 and T74, which would involve removing most of the vegetation above ground and implementing a programme of injection with herbicide. This would mean isolating this area for a period of time (up to 5 years until there was no further evidence of Japanese Knotweed. We would also suggest that a programme of removal (in as far as possible) be implemented within the rooting area of the large cedar (T78) followed by the installation of a root barrier membrane. Horizontal root barrier membranes are applied where most of the infested soil does not have to be disturbed to facilitate the proposed development or construction works, by virtue of the infested soil being located within the construction footprint, but principally below formation level. In such circumstances only the uppermost level of infested soil, located above formation level, is removed. The rest of the infested soil is then overlain with a root barrier membrane system which will contain it and prevent the rhizome from regenerating.

In conclusion, herbicide treatment is not suitable for this development as development works are intended to proceed as soon as practicable. However, subject to the results of an intrusive investigation that will determine the extent and depth of the Japanese Knotweed rhizome network, it may be possible to implement a soft landscaping approach as described above and it is recommended that this approach be taken where possible while at the same time avoiding the risk of residual Knotweed containing material remaining near structures.

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FIGURE 4. EXTENT OF JAPANESE KNOTWEED AT THE SITE OF THE PROPOSED DEVELOPMENT IN 2017 (ADAPTED FROM: INVAS BIOSECURITY, 2017).

It is also noted that associated with the proposed JKW remediation works is the risk of a potential spread of this invasive species to other locations via the vehicles and personnel on- site during these works. The receiving waste facility environment is also at risk if the JKW is not processed and disposed of in accordance with best practise guidelines and relevant invasive species legislation. Therefore, in the absence of any mitigation measures there is the potential for negative, long-term, significant impacts should JKW be spread outside of the Site of the Proposed Development and become established.

6.3 Impacts on Mammals No mammals of conservation concern were recorded within the Site of the Proposed Devel- opment although a variety of species may utilise the Site.

The Proposed Development could have a potential negative, permanent, significant impact at a local level on some woodland species, if they are present, such as Badger, Hedgehog and Pygmy Shrew, in the absence of mitigation/compensatory measures, through the removal of scrub and woodland habitat at the Proposed Development.

Noise and dust generated during the Construction Phase has the potential to cause negative, short-term, slight impacts in the form of disturbance to mammals at a local level. Hedgehog are known to inhabit residential areas (BHPS, 2019) however and so likely inhabit/ frequent the site of the Proposed Development. Increased human presence during both the Construc- tion and Operational Phases, in addition to increased lighting at the site, also have the potential to cause negative, permanent, slight disturbance to mammals in the locality.

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Small mammal species in particular Hedgehog, have the potential to become entangled in construction materials such as netting and plastic sheeting, as well as other waste materials, causing entrapment and injury or death. This constitutes a negative, short-term, significant risk at a local level associated with the Construction Phase of the Proposed Development.

6.4 Impacts on Bats The mature trees within the Site of the Proposed Development were examined for the presence of roosting bats. No evidence of bat presence was recorded, and no bats were seen emerging from any of these trees during surveys. However, as outlined in the Bat Assessment Report pertaining to the Proposed Development, several mature trees were identified to have bat roost potential and three of these namely T63, T64 and T82 are proposed for removal. As such there is the potential for negative, permanent, significant impacts on bats at a local level through removal of potential roosting sites associated with the Proposed Development. It should be noted that the other trees identified as having bat potential; trees numbered T69 and T70, are proposed to be retained.

The Proposed Development will result in the loss of some commuting and foraging habitat for locally occurring bats in the form of the replacement of areas of linear vegetation across the Site with buildings and hardstanding; and the removal of scrub and meadow habitats. In- creased human presence and lighting during both the Construction and Operational phases of the Proposed Development could also potentially pose a barrier to bats commuting and foraging along vegetation and treelines in the vicinity of the Site.

Thus, it is considered that the Proposed Development has the potential to have a negative, permanent, significant impact on foraging/commuting bats at a local level in the absence of mitigation/compensatory measures; through the loss of foraging/commuting habitat; as well as a negative, permanent, moderate local impact through the increased lighting associated with both Construction and Operational Phases of the development.

6.5 Impacts on Birds The Proposed Development will result in the loss nesting and foraging habitat for a range of bird species. The results of a preliminary bird survey carried out as part of this assessment identified a total of 23 species that could potentially be breeding at the Site.

There will be a reduction in vegetative habitats at the Site, including wooded areas, treelines and scrub; within which birds may nest, forage or roost; associated with Proposed Develop- ment. The increased noise and dust levels associated with the Construction Phase of the Proposed Development also has the potential to cause disturbance to local bird populations. Increased human presence during both the construction and operational phases, at the Site is not considered to pose a significant impact due to the residential surroundings of the Site and its proximity to Newtown Park Avenue.

Therefore, the potential impacts of the Proposed Development on local bird assemblages, in the absence of mitigation/compensatory measures, are considered to be:

- a negative permanent significant impact at a local level as a result of habitat loss; and - a negative short-term slight impact at a local level as a result of construction related noise and dust disturbance.

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6.6 Impacts on Other Taxa There are no other species of conservation concern that are considered to be at risk of significant impacts as a result of the Proposed Development.

6.7 Do Nothing Impact If the Proposed Development were not to go ahead, the succession of the unmanaged grassland areas within the site to scrub would continue. The current Japanese Knotweed infestation would remain at similar levels to the current situation but would likely continue to spread across the Site.

6.8 Cumulative Impacts The following permitted, or in-progress, developments within the vicinity of the Proposed De- velopment were reviewed and considered for possible in-combination effects with the Pro- posed Development:

ABP-303804-19:A planning permission for a strategic housing development at this site of circa 4.56 hectares at St. Teresa’s House/Centre (a protected structure) and St. Teresa’s Lodge (a protected structure) Temple Hill, Monkstown, Blackrock, County Dublin by Oval Target Ltd.The site area also includes existing gates to the north of the site (a protected structure); a portion of the public roadway at St. Vincent’s Park; a portion of lands at Car- mond; and a portion of lands at The Alzheimer’s Society of Ireland, all located at Temple Hill, Monkstown, Blackrock, County Dublin. The development will consist of a new residential scheme of 294 residential units (ranging from one to eight storeys overall in height) in a combination of new apartment buildings; the subdivision, conversion and re-use of St. Teresa’s House; and the dismantling and relocation of St. Teresa’s Lodge within the site development area. The demolition (total circa 2,787 square metres gross floor area) of all later ancillary buildings and extensions (buildings vary from one to three storeys) associated with St. Teresa’s House and St. Teresa’s Lodge is also proposed. This includes a single storey return on lands at The Alzheimer’s Society of Ireland adjoining Building 1 on the subject site.

ABP-306949-20 Application for permission under section 4 of the Planning and Develop- ment (Housing) and Residential Tenancies Act 2016, in accordance with plans and par- ticulars, lodged with An Bord Pleanála on the 20th day of March 2020 by Lulani Dalguise care of John Spain Associates, 39 Fitzwilliam Place, Dublin 2.The proposed development will consist of a residential development on the lands at Dalguise House (protected structure Register of Protected Structures number 870). The proposed development will comprise of 300 number dwelling units, including the conversion of ‘Dalguise House’ into two dwellings and a creche, eight new apartment blocks of 276 number units, ranging in height from five to nine storeys and 22 number houses, (including the converted stable yard and refurbishment of an existing gate lodge), within a site area of circa 3.66 hectares, with a gross floor area of 30,587 square metres. D20A/0222: Application lodged 13th March 2020. Location – At a site of 0.81ha, “Ard na Glaise”, Stillorgan Park, (R825) Co Dublin. Permission is sought for the development will consist of the demolition of 1 No. (1 and 2 storey) residential unit. ''Árd na Glaise'' (c 400sq Gross

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Floor Area (GFA)) and the construction of a residential development comprising 63 No. residential (53 No. apartments and duplex units and 10 No. houses) consisting of: Apartment Block A1 (4 storey block, c. 1,436 sqm GFA) comprising: 2 No. studio units (c. 37.5 sqm GFA each); 7 No. 1 bed units (ranging in size from c. 48.1 sqm GFA to 53.5 sqm GFA); 9 No. 2 bed units (ranging in size from c. 77.1 sqm GFA to 85.4 sqm GFA ); Block A1 comprises balconies on southern, northern and western elevations; and sedum roof at roof level. Apartment Block B1 (3 and 5 storey block c. 2,260 sqm GFA) comprising: 1 No. studio unit (c. 42 sqm GFA each); 10 No. 1 bed units, (ranging in size from c. 48.2 sqm GFA to 50.6 sqm GFA); 15 No. 2 bed units, (ranging in size from c. 74.1 sqm GFA to 81.6 sqm GFA); 1 No. 3 bed unit (c. 98.1sqm GFA). Block B1 comprises balconies on southern, northern and western elevations; a roof terrace at 3rd floor level and sedum roof at roof level. 2 No. Duplex Blocks D1 (3 storey blocks), comprising c.805 sqm GFA (for both blocks) and providing the following units within both blocks: 4 No. 2 bed units (c. 82 sqm GFA each); 4 No. 3 bed duplex units (ranging in size from c. 113.6sqm GFA to 114.8sqm GFA); 10 No. 2 storey semi-detached / terraced 3 bed houses (ranging in size from c. 116.0sqm GFA to 128.0 sqm GFA). The development will also consist of: a revised vehicular access to the development from Stillorgan Park (R825); a separate pedestrian access to the development from Stillorgan Park (R825); a gated pedestrian access to Coppinger Glade at the south-eastern side of the development; the provision of 44 No. surface level car parking spaces, 2 No. motorcycle spaces; 82 No. bicycle parking spaces; 1 No. bicycle shelter to the west of revised vehicular access off Stillorgan Park (R825); 1 No. ESB distribution kiosk to the east of proposed vehicular access from Stillorgan Park (R825); ancillary bin storage structures; and all associated landscaping and boundary treatment works, the provision of public and private open space areas comprising hard and soft landscaping, site services (foul and surface water drainage and water supply); and all other associated site excavation, infrastructural and site development works above and below ground.

D19A/0947: Planning granted on 07-Feb-2020 –An application for development at Ferry Ter- minal Building and adjacent lands, St. Michael's Pier, Harbour Road, Dun Laoghaire, Co. Dub- lin seeking Permission for: 1. The removal / deletion of condition number 2 of the Grant of Planning Permission Register Reference Number D18A/0078, Final Grant Number, P/2128/18, approval date 6th September 2018. 2. Redesign of the Ground Floor entrance foyer internal area by the deletion of the ground floor Restaurant and food vending café elements of the above described approved development and its substitution by a ''food court'' element. An Appropriate assessment screening was carried out and Having regard to the nature and scale of the proposed development, which comprises modifications to a permitted development in a fully serviced urban location, it is considered that there is no real likelihood of significant effects on the environment arising from the proposed development. This application is under Appeal at present.

D19A/0378: Planning Permission granted 14-Oct-2019. Location - Former Richmond Chesh- ire Home, Richmond Park, Monkstown, Co Dublin. Permission for revisions to a residential development previously permitted under Reg. Ref. D17A/0590 / ABP-301533-18. The proposed development will consist of the following revisions to the permitted scheme; minor revisions to the siting and footprint of the 2 no. permitted apartment blocks; reconfiguration of the internal permitted floor layouts of both blocks resulting in a total of 72 no. residential units in these 2 no. apartment blocks (1 no. four storey block consisting of 17 no. one beds and 23 no. two beds ([Block A]; 1 no. four storey block consisting of 17 no. one beds and 15 no two beds [block B]) (this is in lieu of a total of 56 no. residential units permitted under Reg. Ref.

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D17A/0590 / ABP-301533-18), elevational changes to accommodate this reconfiguration; revisions to the permitted basement to now provide 79 car parking spaces, 7 motorcycle spaces and 64 bicycle spaces and all associated site works necessary to facilitate the development. An appropriate assessment screening report was submitted as part of the application and the Local Authority determined the development to be retained would not significantly impact upon a Natura 2000 site. This application is currently under Appeal at present.

D19A/0772: Permission was granted on 2nd December 2019 by Dun Laoghaire-Rathdown County Council for the construction of a new two-storey extension integrated to the existing school building at the main entrance incorporating a new Classroom and Accessible Toilet at ground floor level and 4No. Resource Rooms, Principal's Office and Meeting Room at first floor level together with other ancillary alterations at both levels. The existing prefabricated building and link at the western end to the main building will be demolished and removed. This primary school development is situated on lands directly south of the Site of the Proposed Development.

In addition, the following Policies and Plans were reviewed and considered for possible in- combination effects with the proposed development.

- Dublin City Biodiversity Action Plan 2015 ‐ 2020 - Dun Laoghaire-Rathdown Biodiversity Plan (2009-2013) – Currently under review - Dún Laoghaire‐Rathdown County Council County Development Plan 2016 ‐ 2022 - South Dublin County Council Development Plan 2016 ‐ 2022

On examination of the above it is considered that there are no means for the Proposed De- velopment to act in-combination with any plans or projects that would cause any likely significant effects to nearby ecological sensitivities.

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7 MITIGATION AND ENHANCEMENT MEASURES

7.1 Designated Sites

Due to the lack of hydrological connections from the Proposed Development to any designated sites within a 15km radius of the Site, and the distances between the Site of the Proposed Development and any of the listed designated sites, it is deemed that there is no possibility for potential significant impacts on water quality at these sites, and/or any other adverse impact, as a result of the Proposed Development. Therefore, no mitigation is recommended.

7.2 Habitats To offset the loss of a considerable proportion of all vegetative habitats at the Site of the Pro- posed Development it is recommended that planting of native trees and hedgerow species be incorporated into the Project Design where possible. In addition, every effort should be made in consultation with the project arboriculturist, to retain as many trees of ‘high value’ as is possible in the final landscape design. These measures will go some way to offsetting the loss of habitat to associated faunal species associated with the Proposed Development.

7.2.1 Invasive species spread To ensure that no further nuisances or off-site impacts occur as a result of the remediation of Japanese Knotweed and any other invasive species present at the Site of the Proposed De- velopment; an Invasive Species Management Plan has been compiled and is appended to this document. This report details the suite of best-practise measures that will be strictly followed when removing, handling, storing, transporting, and disposing of invasive species plant matter.

7.3 Fauna Reduction of Noise Impacts

Included in the CEMP (Byrne Environmental 2020) are a number of measures as set out in BS 5228-1: A1:2014 Code of practice for noise and vibration control on construction and open sites – Part 1: Noise that will be put in place during the Construction Phase of the Proposed Development. These will ensure that the level of noise caused by the proposed works will be controlled/reduced where possible so as to minimise the potential disturbance impact on local fauna species.

These measures will include but are not limited to:

• Selection of plant with low inherent potential for generating noise.

• Siting of plant as far away from sensitive receptors as permitted by site constraints.

• Avoid unnecessary revving of engines and switch off plant items when not required.

• Keep plant machinery and vehicles adequately maintained and serviced.

• Proper balancing of plant items with rotating parts.

• Keep internal routes well maintained and avoid steep gradients.

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• Minimise drop heights for materials or ensure a resilient material underlies.

• Use of alternative reversing alarm systems on plant machinery.

• Where noise becomes a source of resonating body panels and cover plates, additional stiffening ribs or materials should be safely applied where appropriate.

• Limiting the hours during which site activities likely to create high levels of noise are permitted.

• Appointing a site representative responsible for matters relating to noise.

• Monitoring typical levels of noise during critical periods and at sensitive locations.

These measures will ensure that any noise disturbance to nesting birds or any other fauna species in the vicinity of the Site of the Proposed Development will be reduced to a minimum.

Reduction of Dust related impacts

The following general dust control measures will be employed for the duration of the Construc- tion Phase of the Proposed Development, and will ensure no significant dust related impacts occur to nearby sensitive receptors including local faunal species:

• In situations where the source of dust is within 25m of sensitive receptors (i.e. the nearby school and church) the erection of screens (permeable or semi-permeable fences) will be erected.

• Haulage vehicles transporting gravel and other similar materials to site will be covered by a tarpaulin or similar.

• Access and exit of vehicles will be restricted to certain access/exit points.

• Vehicle speed restrictions of 20km/hr will be in place.

• Bowsers will be available during periods of dry weather throughout the construction period.

• During dry and windy periods, and when there is a likelihood of dust nuisance, a bow- ser will operate to ensure moisture content is high enough to increase the stability of the soil and thus suppress dust

• Stockpiles will be stored in sheltered areas of the Site and covered, and watered regularly or as needed if exposed during dry weather.

• Gravel should be used at site exit points to remove caked-on dirt from tyres and tracks.

• Equipment should be washed at the end of each work day.

• Hard surfaced roads will be wet-swept to remove any deposited materials.

• Unsurfaced roads will be restricted to essential site traffic only.

• If practicable wheel-washing facilities should be located at all exits from the construction site

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• Dust production as a result of site activity will be minimized by regular cleaning of the site access roads using vacuum road sweepers and washers. Access roads should be cleaned at least 0.5 km on either side of the approach roads to the access points.

• Public roads outside the site shall be regularly inspected for cleanliness, as a minimum daily, and cleaned as necessary. A road sweeper will be made available to ensure that public roads are kept free of debris.

• The frequency of cleaning will be determined by the Site Agent and is weather and activity dependent.

• The height of stockpiles will be kept to a minimum and slopes should be gentle to avoid windblown soil dust.

• The following will be damped down during dry weather:

- Unpaved areas subject to traffic and wind;

- Stockpiles;

- Areas where there will be loading and unloading of dust-generating materials, and

- Borrow-pits.

7.3.1 Mammals

7.3.1.1 Hedgehog and Pygmy shrew During the Construction Phase of the Proposed Development hedgehogs in particular have the potential to be significantly impacted through the loss of suitable hibernation and nest sites in the form of piles of dead wood, vegetation and leaves on site. This can be mitigated through the careful removal of dead wood/leaves to another part of the site where they will not be affected. Woody debris from the proposed clearance of vegetative areas on site can also be left in this out-of-the way location as compensatory hedgehog habitat during the Construction Phase. Hedgehog also frequent long grass for foraging and daytime nesting sites so caution when strimming/ mowing these areas of the site is advised. Work likely to cause disturbance during hibernation – for example removal of hibernation habitats such as log piles and dense scrub ideally should not take place during November to March.

Hedgehogs have the potential to be significantly impacted locally by the Proposed Develop- ment through the permanent loss of suitable woodland and scrub habitat across the Site. This impact can be mitigated through the retention, replanting and incorporation of some small areas of unmanaged native hedgerow/scrub/meadow in some areas of the Site, encouraging habitat connectivity throughout the Site. The Site margins along the boundaries of the Site have potential for this type of semi-natural wildlife strip and would go some way towards offsetting the loss of habitat associated with the Proposed Development, while also providing habitat for pollinator species such as bee.

As best-practise all construction-related rubbish on site e.g. plastic sheeting, netting etc. should be kept in a designated area on site and kept off ground level so as to prevent hedgehogs from entrapment and death. The above measures will also act to mitigate potential negative impacts on other small mammal species potentially found on site e.g. Pygmy Shrew.

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7.3.1.2 Badger There was no evidence of active Badger setts during the Site survey, although a potential disused sett that appeared abandoned for some time was recorded in the south of the Site. However, badgers create new setts regularly and existing setts may change in terms of breeding status or level of use by badgers. Therefore, in order to ensure that there are no significant changes to the extent of badger territory identified in the original site survey; and the associated mitigation measures recommended in this report, a pre-construction survey should be undertaken prior to the commencement of any works.

It is possible that badger may utilise the Site. Therefore, should a Badger sett be found prior to the commencement of the proposed works, the following provisions should apply (NRA Guidance document, Accessed: January 2020):

• Badger sett tunnel systems can extend up to c. 20m from sett entrances. Therefore, no heavy machinery should be used within 30m of badger setts (unless carried out under licence); lighter machinery (generally wheeled vehicles) should not be used within 20m of a sett entrance; light work, such as digging by hand or scrub clearance should not take place within 10m of sett entrances.

• During the breeding season (December to June inclusive), none of the above works should be undertaken within 50m of active setts nor blasting or pile driving within 150m of active setts.

• Following consultation with the NPWS and badger experts, works closer to active setts may take place during the breeding season provided appropriate mitigation measures are in place, e.g. sett screening, restricted working hours, etc. In order to comply with these constraints:

• All affected badger setts should be clearly marked, and the extent of bounds prohibited for vehicles clearly marked by fencing and signage. Bunting is an option on a temporary basis. Hazard tape is inadequate as it is prone to deterioration and damage by wind or cattle etc.

• All contractors/operators on site should be made fully aware of the procedures pertaining to each sett on site.

• Construction activities within the vicinity of affected setts may commence once these setts have been evacuated and destroyed under licence from the NPWS. Where affected setts do not require destruction, construction works may commence once recommended alternative mitigation measures to address the badger issues have been complied with.

In almost all circumstances, works close to badger setts may only be conducted under the supervision of a qualified expert under licence from the NPWS

7.4 Bats

7.4.1 Construction Phase Prior to the commencement of any works, it is recommended that a roost inspection survey and emergence surveys are carried out at the appropriate time of year, by a qualified ecologist

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The three trees listed above requiring felling will be examined beforehand (there should be no more than 24 hours between examination and felling). Examination will require access to the tree’s higher sections through the use of tree climbers, preferably with bat surveying of trees experience, or / and a cherry picker to enable an ecologist to examine higher located features with an endoscopic camera. The Poplar (T64) in particular is considered to have a high bat roost potential and should be retained as part of the landscape plans for the site if possible. An ecologist should be consulted prior to any site clearance works to ensure that these trees are examined prior to felling (if required) or cordoned off from works to ensure their retention and protection. . If bats are present, the relevant works will have to cease, and an application made to the National Parks and Wildlife Service for a derogation licence.

Any felling of mature trees with bat roost potential within the Site should be done during the autumn months where possible. The branches should then be left in-situ for at least 24 hours in order to allow for the movement of bats and other wildlife from the tree prior to mulching or removal. As compensation for any loss of potential roost habitat, 3 x 2F Schwegler bat boxes (or more) shall be attached to suitable trees within the immediate area. Boxes must be unlit and away from dense scrub that may block access for bats. Boxes must be at a height of no less than 3 metres.

7.4.2 Operational Phase Increased Lighting

It is recommended that the impact of increased lighting of the site as a result of the Proposed Development be mitigated through the incorporation of bat-friendly lighting measures into the project design and associated lighting plan.

This should ensure that the spill of light skywards, or onto certain areas of bat habitat i.e. hedgerows, treelines; and areas of trees in general where lit pedestrian walkways/cycle tracks and internal roadways are proposed to run, be reduced if not avoided completely.

Night-time lighting across the Site of the Proposed Development should be kept to a minimum during both the Construction and Operational Phases of the Proposed Development (once satisfying health & safety requirements), through the reduction of light spill from the building interior via windows/entrances, and the reduction of spill/glare from outdoor lighting in place on the building exterior and throughout the Site.

Incorporation of the appropriate luminaire specifications as advised by a lighting professional can have a considerable input in mitigating the potential impact of night-time lighting on local bats.

Measures including the following should be considered when choosing luminaires (ILP, 2018):

- Use of luminaires lacking UV elements when manufactured. Metal halide, fluorescent sources should be avoided.

- LED luminaires should be used where possible due to their sharp cut-off, lower intensity, good colour rendition and dimming capability.

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- A warm white spectrum (ideally <2700Kelvin) should be adopted to reduce blue light component.

- Luminaires should feature peak wavelengths higher than 550nm to avoid the component of light most disturbing to bats (Stone, 2012).

- Internal luminaires can be recessed where installed in proximity to windows to reduce glare and light spill (See Figure 5 below).

- The use of specialist bollard or low-level downward directional luminaires to retain darkness above can be considered. However, this often comes at a cost of unaccepta- ble glare, poor illumination efficiency, a high upward light component and poor facial recognition, and their use should only be as directed by the lighting professional.

- Column heights should be carefully considered to minimise light spill.

- Only luminaires with an upward light ratio of 0% and with good optical control should be used – See ILP Guidance for the Reduction of Obtrusive Light.

- Luminaires should always be mounted on the horizontal, i.e. no upward tilt.

- Any external security lighting should be set on motion-sensors and short (1min) timers.

- As a last resort, accessories such as baffles, hoods or louvres can be used to reduce light spill and direct it only to where it is needed.

FIGURE 5. INTERNAL LIGHTING GUIDANCE DIAGRAM ADAPTED FROM ILP (2018).

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The Lighting Plan for the site will use a mixture of lighting columns between 5 and 6 metres high and the following columns, as per the drawing, P5, P6, P7, P11, P14, P15, P17, P18, P19, P20, P21 and P22 should be fitted with hoods or black louvres and sensor activated to avoid prolonged illumination of treelines and landscaped areas which are not required to be used by residents during darkness. No lights will have UV components and should have a colour temperature of warm white (830). During construction, temporary lighting should also be positioned appropriately to avoid light overspill and trigger sensor lighting deployed where possible

Retention of foraging habitat

It is also recommended that where possible areas of treeline and woodland be retained as part of the Project Design to compensate for the loss of habitat that will result from the Pro- posed Development. As with the compensatory measures for birds; additional complimentary planting should be carried out where possible to create new linear vegetative habitats, increasing habitat connectivity across the Site. The incorporation of the above as natural habitat features into the project design would benefit bats and other local wildlife considerably and act to offset the habitat loss that will occur as a result of the Proposed Development while also adding to the landscape diversity of the site for future students and locals alike.

7.5 Birds No species of conservation concern were found to be nesting on-site during the bird surveys carried out on 7th April 2020 and 25th May 2020.

Protection of breeding birds

Any clearance of vegetation should be done outside the main breeding season, which runs from 1st March to 31st August, in compliance with the Wildlife Act 2000. Should any vegetation removal be required during this period, this vegetation should be checked for birds and if any nests are noted during this evaluation prior to removal, a derogation shall be required from NPWS. This would note the section of habitat that is a nest site, the precise location within the hedgerow / trees, the species of bird present; and also elaborate the means by which the birds would be protected prior to nest removal. If eggs have been laid, the nest should be protected until the young have fledged after which time the nest could be destroyed (under licence from NPWS only). This may also require further compensatory measures including nesting sites for birds if practicable.

Retention and re-instating of foraging habitat

It is also recommended that where possible areas of treeline and woodland be retained as part of the Proposed Development to compensate for the loss of habitat that will result from the Proposed Development. Additional complimentary planting should be carried out where possible to create new habitats for local bird species and increase habitat connectivity across the Site of the Proposed Development.

As compensation for the loss of nesting habitat to local birds, 4 bird boxes of suitable character (suitable for small bird species) will be installed in appropriate locations across the Site. Boxes should be attached to walls, fences, or trees 3-5m above the ground, facing between north and south-east to avoid extreme weather conditions.

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8 RESIDUAL IMPACTS

Residual impacts are impacts that remain once mitigation has been implemented or impacts that cannot be mitigated. Table 9 below provides a summary of the impact assessment for the identified Key Ecological Resources (KERs) and details the nature of the impacts identified, mitigation proposed and the classification of any residual impacts.

Standard Construction Phase control measures have been outlined to ensure that the Pro- posed Development does not impact on any species or habitats of conservation importance or designated sites. It is essential that these measures are complied with, in order to ensure that the Proposed Development complies with National conservation legislation. Provided all such measures are implemented in full and remain effective throughout the lifetime of the Proposed Development, no significant negative residual impacts on the local ecology or on any designated nature conservation sites, are expected from the Proposed Works.

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TABLE 9. SUMMARY OF POTENTIAL IMPACTS ON KER(S), MITIGATION PROPOSED AND RESIDUAL IMPACTS.

Impact Without Mitigation Key Level Proposed Mitigation/ Miti- Residual Ecological of Signifi- Potential Impact Magnitude gating Factors Impact Resource cance Quality Duration Significance / Extent

Designated Sites

No impacts to any designated sites will occur as a result of the Proposed Development and therefore no mitigation measures are recommended.

Habitats and Flora

- Where possible implement a soft landscaping plan which would involve Mixed Broad- removing most of the vegetation above ground and leaved Wood- implementing a pro- land (WD1) gramme of injection with herbicide and isolating the area until there was Local no further evidence of Loss of significant sections of Significant Negative; Importance Japanese Knotweed. these habitats as a result of Pro- Negative proportion Permanent Moderate short term; (Higher posed Development. of habitat - Majority of trees to be re- slight. Level) moved classed as category C i.e. young and/or poor quality. Treelines (WL2) - Extensive native tree planting to be included as part of Project Design as well as retention of good quality trees as much as is possible.

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Potential spread of this high im- - An invasive species man- Invasive Local pact invasive species to other lo- agement plan has been Plant species Importance cations as a result of the pro- produced detailing best- Negative n/a Long-term Significant practise measures to be Negligible. e.g. Japanese (Higher posed remediation and removal followed across all as- Knotweed Level) of infested areas at the Site of the pects of the remediation Proposed Development. process.

Mammals

Loss of potential habitat as a re- - Compensatory habitat to sult of Proposed Development. be provided as part of the Significant Project design in the form Permanent Negative; of unmanaged Hedgerow/ Perma- meadow areas where nent; mod- possible around the boundary margins of the erate. Disturbance from noise, dust, Short-term Site. lighting and increased human Slight

Mammals presence during Construction - Construction related Negligible. (Badger, Phase. noise & dust control/mini- National Pygmy Shrew Negative n/a misation measures to be importance Permanent and Hedge- Moderate included in CEMP. Negative; hog) Disturbance from noise, lighting Perma- and increased human presence - Retention of as much existing vegetation as pos- nent; Mod- during Operational Phase. sible as part of the Pro- erate.

ject design.

Possible small mammal mortality Short-term - Best practise construc- Negligible due to construction site hazards Significant tion waste storage/han- (Plastic sheeting etc.). dling measures to be included in CEMP.

- Extensive native tree Negative; Loss and/or damage to sections Negative Permanent Significant planting to be included as Short- Bat National of potential roosting, foraging part of Project Design as term; assemblage Importance and commuting habitat. well as retention of good Slight.

quality trees as much as

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Disturbance/removal of foraging Negative n/a is possible. Creation of routes/habitat due to increased Permanent Moderate treelines/hedgerows lighting as a result of the Pro- along site boundaries. Negligible. posed Development. - Provision of 3x Bat boxes in appropriate locations to Negligible. offset any loss of potential roost habitat.

Negative Short-term Slight - Construction related Disturbance from noise and in- noise/dust control/minimi- creased human presence during sation measures to be in- Construction Phase. cluded in CEMP.

- Reduction/limitation of

night-lighting during Con-

struction Phase as much as possible.

- Incorporation of Bat friendly lighting measures, as laid out in section 7.4 of this report, into the final Project De- sign.

Birds

- Extensive native tree Loss of nesting/foraging habitat Permanent Significant planting to be included as Bird Negative County as a result of the Proposed De- part of Project Design as Negligible. assemblage n/a Importance velopment. Short term Slight well as retention of good (Green-listed) quality trees as much as is possible. Creation of

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Disturbance due to noise, dust treelines/hedgerows and increased human presence along site boundaries. during Construction Phase - Retention of as much existing vegetation as possible as part of the Project design.

- Installation of 4 bird boxes Bird across the Site in suitable National assemblage locations. Importance (Amber-listed) - Construction related noise/dust control/minimi- sation measures to be included in CEMP.

- No removal of vegetation to be carried out during nesting season unless essential.

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9 CONCLUSION

It is considered that, provided the appropriate measures proposed are carried out in full, there will not be any significant negative impact to any valued habitats, designated sites or individual or group of species as a result of the subject development.

Based on the successful implementation of the measures and proposed works to be carried out in accordance with the accompanying CEMP and landscape plan, is likely that there will be no significant ecological impact arising from construction and the day to day operation of the Proposed Development. However, the incorporation of significant native tree and hedgerow planting, and unmanaged semi-natural meadow areas specifically for native biodiversity; within the landscaping proposals, along with additional measures where possible to enhance biodiversity, are recommended, and would be of considerable benefit to the long-term biodiversity value of the Site and its surrounding area.

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Institution of Lighting Professionals (ILP). (2018). Guidance Note 08/18: Bats and artificial lighting in the UK. Bats and the Built Environment series. [ONLINE] Available at: https://www.theilp.org.uk/documents/guidance-note-8-bats-and-artificial-lighting/ [Accessed April 2020].

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King, J.L., Marnell, F., Kingston, N., Rosell, R., Boylan, P., Caffrey, J.M., FitzPatrick, Ú., Gargan, P.G., Kelly, F.L., O’Grady, M.F., Poole, R., Roche, W.K. and Cassidy, D. (2011). Ireland Red List No. 5: Amphibians, Reptiles and Freshwater Fish. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht, Dublin, Ireland

Kingston, N. (2005). Proposed Red Data List for Vascular Plants. A Consultation Document from the National Parks and Wildlife Service, Department of Environment, Heritage and Local Government.

Kelly, F.L., and King, J.J. (2001) A review of the ecology and distribution of three lamprey species, Lampetra fluviatilis (L.), Lampetra planeri (Bloch) and Petromyzon marinus (L.): A context for conservation and biodiversity considerations in Ireland. Biology and Environment: Proceedings of the Royal Irish Academy 101B(3), 165-185.

Lawton, C., Flaherty, M., Goldstein, E.A, Sheehy, E. and Carey, M. (2015) Irish Squirrel Survey 2012. Irish Wildlife Manuals, No. 89. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht, Ireland.

McAney, K. (2008). A Conservation Plan for Irish Vesper Bats. Irish Wildlife Manual No.20. National Parks and Wildlife Service, Department of the Environment, Heritage and Local Government.

Murnane, E., Heap, A., and Swain, A., (2006). Control of water pollution from linear construction projects. Technical guidance. CIRIA C648. Published by CIRIA, UK.

Natura Environmental Consultants (2015). Ecological Assessment – Beech Park Development, Old Bray Road, Cabinteely, Co. Dublin. Planning ref. number: D15A/0385.

NBDC, (2020). National Biodiversity Data Centre online mapping [ONLINE] Available at: http://maps.biodiversityireland.ie/Map.aspx. [Accessed April 2020].

NPWS, (2013a). The Status of EU Protected Habitats and Species in Ireland. Habitats Assessments Volume 2, Version 1.0. Unpublished Report, National Parks & Wildlife Services. Department of Arts, Heritage and the Gaeltacht, Dublin, Ireland.

NPWS, (2013b). The Status of EU Protected Habitats and Species in Ireland. Species Assessments Volume 3, Version 1.0. Unpublished Report, National Parks & Wildlife Services. Department of Arts, Heritage and the Gaeltacht, Dublin, Ireland.

NPWS, (2020). National Parks and Wildlife Service website [ONLINE] Available at: http://www.npws.ie/en/ [Accessed April 2020].

NRA (2006) Guidelines for the Treatment of Bats during the Construction of National Road Schemes. National Roads Authority (now Transport Infrastructure Ireland), Dublin.

NRA (2009a). Environmental Assessment and Construction Guidelines. National Roads Authority (now Transport Infrastructure Ireland), Dublin.

NRA (2009b). Guidelines for Assessment of Ecological Impacts of National Road Schemes. National Roads Authority (now Transport Infrastructure Ireland), Dublin.

Lundy M.G., Aughney T., Montgomery W.I., Roche N. (2011) Landscape conservation for Irish bats & species specific roosting characteristics. Bat Conservation Ireland.

Preston, C. D., Pearman, D. A., and T.D. Dines (2002). New Atlas of the British and Irish Flora. Oxford University Press.

Smith, G.F., O’Donoghue, P, O’Hora K., and Delaney, E. (2010). Best Practice Guidance for Habitat Survey and Mapping. Published by the Heritage Council.

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Stone, E.L., Jones, G., Harris, S. (2012). Conserving energy at a cost to biodiversity? Impacts of LED lighting on bats. Glob. Change Biol. 18, 2458–2465.

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Appendix I – Value of Ecological Resources

The criteria outlined in the table below, taken from the Guidelines for Assessment of Ecological Impacts of National Road Schemes published by the NRA, were used for assigning value to designated sites, habitats and species within the Site of the Proposed Development and surrounding area.

TABLE A. DESCRIPTION OF VALUES FOR ECOLOGICAL RESOURCES BASED ON GEOGRAPHIC HIERARCHY OF IMPORTANCE (NRA, 2009B).

Importance Criteria

- ‘European Site’ including Special Area of Conservation (SAC), Site of Community Im- portance (SCI), Special Protection Area (SPA) or proposed Special Area of Conserva- tion. - Proposed Special Protection Area (pSPA). - Site that fulfils the criteria for designation as a ‘European Site’ (see Annex III of the Habitats Directive, as amended). - Features essential to maintaining the coherence of the Natura 2000 Network - Site containing ‘best examples’ of the habitat types listed in Annex I of the Habitats Di- rective. - Resident or regularly occurring populations (assessed to be important at the national level) of the following: o Species of bird, listed in Annex I and/or referred to in Article 4(2) of the Birds Directive; and/or International o Species of animal and plants listed in Annex II and/or IV of the Habitats Di- Importance rective - Ramsar Site (Convention on Wetlands of International Importance Especially Water- fowl Habitat 1971). - World Heritage Site (Convention for the Protection of World Cultural & Natural Herit- age, 1972). - Biosphere Reserve (UNESCO Man & The Biosphere Programme) - Site hosting significant species populations under the Bonn Convention (Convention on the Conservation of Migratory Species of Wild Animals, 1979). - Site hosting significant populations under the Berne Convention (Convention on the Conservation of European Wildlife and Natural Habitats, 1979). - Biogenetic Reserve under the Council of Europe. - European Diploma Site under the Council of Europe. - Salmonid water designated pursuant to the European Communities (Quality of Salm- onid Waters) Regulations, 1988, (S.I. No. 293 of 1988). - Site designated or proposed as a Natural Heritage Area (NHA). - Statutory Nature Reserve. - Refuge for Fauna and Flora protected under the Wildlife Acts. - National Park. - Undesignated site fulfilling the criteria for designation as a Natural Heritage Area National Im- (NHA); Statutory Nature Reserve; Refuge for Fauna and Flora protected under the portance Wildlife Act; and/or a National Park. - Resident or regularly occurring populations (assessed to be important at the national level) of the following: o Species protected under the Wildlife Acts; and/or o Species listed on the relevant Red Data list. o Site containing ‘viable areas’ of the habitat types listed in Annex I of the Habi- tats Directive County Im- - Area of Special Amenity. portance - Area subject to a Tree Preservation Order. - Area of High Amenity, or equivalent, designated under the County Development Plan.

- Resident or regularly occurring populations (assessed to be important at the County level) of the following: o Species of bird, listed in Annex I and/or referred to in Article 4(2) of the Birds Directive; o Species of animal and plants listed in Annex II and/or IV of the Habitats Di- rective; o Species protected under the Wildlife Acts; and/or o Species listed on the relevant Red Data list. o Site containing area or areas of the habitat types listed in Annex I of the Habi- tats Directive that do not fulfil the criteria for valuation as of International or National importance. - County important populations of species; or viable areas of semi-natural habitats; or natural heritage features identified in the National or Local BAP; if this has been prepared. - Sites containing semi-natural habitat types with high biodiversity in a county context and a high degree of naturalness, or populations of species that are uncommon within the county. - Sites containing habitats and species that are rare or are undergoing a decline in quality or extent at a national level. - Locally important populations of priority species or habitats or natural heritage features identified in the Local BAP, if this has been prepared; - Resident or regularly occurring populations (assessed to be important at the Local level) of the following: o Species of bird, listed in Annex I and/or referred to in Article 4(2) of the Birds Directive; Local Im- o Species of animal and plants listed in Annex II and/or IV of the Habitats Di- portance rective; (higher value) o Species protected under the Wildlife Acts; and/or o o Species listed on the relevant Red Data list. o Sites containing semi-natural habitat types with high biodiversity in a local context and a high degree of naturalness, or populations of species that are uncommon in the locality; - Sites or features containing common or lower value habitats, including naturalised species that are nevertheless essential in maintaining links and ecological corridors between features of higher ecological value. Local Im- - Sites containing small areas of semi-natural habitat that are of some local importance portance for wildlife; (lower value) - Sites or features containing non-native species that is of some importance in maintaining habitat links.

Appendix II – EPA Impact Assessment Criteria

Criteria used to Define Quality of Effects

In line with the draft EPA Guidelines (EPA, 2017), the following terms are defined when quantifying the quality of effects. See TABLE, below.

TABLE B. DEFINITION OF QUALITY OF EFFECTS.

Quality Definition

A change which improves the quality of the environment (for example, by Positive Effects increasing species diversity; or the improving reproductive capacity of an ecosystem, or by removing nuisances or improving amenities).

No effects or effects that are imperceptible, within normal bounds of varia- Neutral Effects tion or within the margin of forecasting error

A change which reduces the quality of the environment (for example, less- Negative / adverse Effects ening species diversity or diminishing the reproductive capacity of an ecosystem; or damaging health or property or by causing nuisance).

Criteria used to Define Significance of Effects

In line with the draft EPA Guidelines (EPA, 2017), the following terms are defined when quantifying significance of impacts. See TABLE, below.

TABLE C. DEFINITION OF SIGNIFICANCE OF EFFECTS.

Significance of Effects Definition

Imperceptible An effect capable of measurement but without significant consequences.

An effect which causes noticeable changes in the character of the environ- Not significant ment but without significant consequences.

An effect which causes noticeable changes in the character of the environ- Slight Effects ment without affecting its sensitivities.

An effect that alters the character of the environment in a manner that is Moderate Effects consistent with existing and emerging baseline trends.

An effect which, by its character, magnitude, duration or intensity alters a Significant Effects sensitive aspect of the environment

An effect which, by its character, magnitude, duration or intensity signifi- Very Significant cantly alters most of a sensitive aspect of the environment.

Profound Effects An effect which obliterates sensitive characteristics

Criteria Used to Define Duration of Effects

In line with the draft EPA Guidelines (EPA, 2017), the following terms are defined when quantifying duration and frequency of effects. See TABLE, below.

TABLE D. DEFINITION OF DURATION OF EFFECTS.

Quality Definition

Momentary Effects Effects lasting from seconds to minutes

Brief Effects Effects lasting less than a day

Temporary Effects Effects lasting less than a year

Short-term Effects Effects lasting one to seven years.

Medium-term Effects Effects lasting seven to fifteen years.

Long-term Effects Effects lasting fifteen to sixty years

Permanent Effects Effects lasting over sixty years

Reversible Effects Effects that can be undone, for example through remediation or restoration

Appendix III – Breeding Bird Status Codes (British Trust for Ornithology)

Breeding Status Codes

Non-breeding F Flying over M Species observed but suspected to be still on Migration U Species observed but suspected to be sUmmering non-breeder

Possible breeder H Species observed in breeding season in suitable nesting Habitat S Singing male present (or breeding calls heard) in breeding season in suitable breeding habitat

Probable breeding P Pair observed in suitable nesting habitat in breeding season T Permanent Territory presumed through registration of territorial behaviour (song etc.) on at least two different days a week or more part at the same place or many individuals on one day D Courtship and Display (judged to be in or near potential breeding habitat; be cautious with wildfowl) N Visiting probable Nest site A Agitated behaviour or anxiety calls from adults, suggesting probable presence of nest or young nearby I Brood patch on adult examined in the hand, suggesting Incubation B Nest Building or excavating nest-hole

Confirmed breeding DD Distraction-Display or injury feigning UN Used Nest or eggshells found (occupied or laid within period of survey) FL Recently FLedged young (nidicolous species) or downy young (nidifugous species). Careful consideration should be given to the likely provenance of any fledged juvenile capable of significant geographical movement. Evidence of dependency on adults (e.g. feeding) is helpful. Be cautious, even if the record comes from suitable habitat. ON Adults entering or leaving nest-site in circumstances indicating Occupied Nest (including high nests or nest holes, the contents of which cannot be seen) or adults seen incubating FF Adult carrying Fecal sac or Food for young NE Nest containing Eggs NY Nest with Young seen or heard

Appendix IV – Enviroguide Invasive Species Management Plan

INVASIVE SPECIES MANAGEMENT PLAN

FOR

RESIDENTIAL DEVELOPMENT

LANDS at NEWTOWNPARK AVENUE, BLACKROCK, CO. DUBLIN

October 2020

ON BEHALF OF

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Enviroguide Consulting Residential Development Ecological Impact Assessment Newtownpark Avenue, Blackrock, Co. Dublin.

DOCUMENT CONTROL SHEET

Client Glenveagh Homes Ltd

Project Title Residential Development at Newtownpark Avenue, Blackrock, Co. Dublin.

Document Title Invasive Species Management Plan

Revision Status Author(s) Reviewed Approved Issue Date

Internal Siobhán Atkinson Jim Dowdall 1.0 - - Draft Ecologist Director

Siobhán Atkinson Jim Dowdall 2.0 Draft - 09/04/2020 Ecologist Director

Siobhán Atkinson Liam Gaffney Jim Dowdall 3.0 Final 25/09/2020 Ecologist Ecologist Director

Final Siobhán Atkinson Liam Gaffney Jim Dowdall 4.0 20/10/2020 V2 Ecologist Ecologist Director

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Enviroguide Consulting Residential Development Ecological Impact Assessment Newtownpark Avenue, Blackrock, Co. Dublin.

Table of Contents 1 Introduction ...... 1

1.1 Japanese Knotweed...... 1 1.2 Project Description ...... 2 1.3 Objectives of Plan ...... 3 2 Site Location ...... 4

2.1 Japanese Knotweed in 2017 & 2019 ...... 4 3 Legislative Context – extracted from Invasive Plant Solutions 2019 Report ...... 6

4 Code of Practice Guidelines – extracted from Invasive Plant Solutions 2019 report ...... 7

5 Management of Japanese Knotweed at Site of the Proposed Development ...... 8

5.1 Prevention of further spread of Japanese knotweed ...... 9 5.2 Excavation ...... 9 5.3 Temporary Stockpiling of Japanese Knotweed ...... 10 5.4 Transportation of materials across site ...... 10 5.5 Cleaning of Equipment ...... 11 5.6 Japanese Knotweed on Adjacent Sites...... 11 6 Additional invasive alien species of note on site ...... 11

6.1 Three-cornered garlic Allium triquetrum ...... 11 6.1.1 Introduction ...... 11

6.1.2 Management ...... 12

7 References ...... 12

List of Figures Figure 1. Key identification features of Japanese Knotweed. Image is extracted from the Non Native Species Secretariat Identification Sheet for Japanese Knotweed...... 2 Figure 2. Seasonal variation in the appearance of Japanese Knotweed. Image is extracted from the Non Native Species Secretariat Identification Sheet for Japanese Knotweed...... 2 Figure 3. Extent of Japanese Knotweed on site in 2017. (source: Invasive Plant Solutions) ...... 4 Figure 4. Japanese Knotweed infestation at JK 1 (a & b) and JK 2 (c & d). Photographs taken on the 7th of April 2020...... 6 Figure 5. Images of three-cornered garlic recorded on site. Image taken 7th April 2020...... 12

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Enviroguide Consulting Residential Development Ecological Impact Assessment Newtownpark Avenue, Blackrock, Co. Dublin.

Japanese Knotweed Fallopia japonica Management Plan

1 Introduction

1.1 Japanese Knotweed Japanese knotweed is a non-native invasive perennial species in Ireland. Since it was introduced as an ornamental plant in the 19th Century from Japan it has spread across the UK and Ireland. It is rhizomatous (produces underground stems) with distinctive branched hollow, bamboolike canes that can grow to over 3m in height. Red/purple shoots appear early in spring but as the canes grow, the leaves unfurl and the plant turns green. The mature canes are hollow and have a characteristic pattern of purple speckles. Flowering occurs in late summer/autumn and consists of creamy white flowers. The underground rhizomes are thick and woody with a knotty appearance and when broken reveal a bright orange-coloured centre. During the winter the leaves die back and reveal orange/brown woody erect stems. Only female Japanese knotweed plants have been recorded to date in Ireland and although seeds are produced, they are hybrids and rarely survive. The principal means of spread is through the deliberate or accidental movement of rhizome fragments or cut stems.

Japanese knotweed has the potential to out compete native plants and invade habitats, particularly along watercourses, transport routes and infested waste areas. Japanese knotweed forms tall thickets that exclude all other vegetation, shading the area below. Native plants can rarely compete with this invasive species and local plant biodiversity is reduced. Japanese knotweed can also seriously damage buildings, hard surfaces and infrastructure. Once established underneath or around the built environment, it can be particularly hard to control, growing through concrete and tarmac and other hardstandings. When Japanese knotweed colonises riverbanks, it can damage flood defence structures and reduce the capacity of channels to carry flood water.

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Enviroguide Consulting Residential Development Ecological Impact Assessment Newtownpark Avenue, Blackrock, Co. Dublin.

Figure 1. Key identification features of Japanese Knotweed. Image is extracted from the Non Native Species Secretariat Identification Sheet for Japanese Knotweed.

Figure 2. Seasonal variation in the appearance of Japanese Knotweed. Image is extracted from the Non Native Species Secretariat Identification Sheet for Japanese Knotweed.

1.2 Project Description The development will consist of the demolition of the existing c. 26sqm single storey shed on site and construction of a residential development comprising 140 no. residential apartments and duplex units across 5 no. 2 to 5 storey buildings (with a basement under Blocks C + D), an ancillary single storey concierge/reception building, 97 no. car-parking spaces, 226 no. cycle spaces, a single storey ESB substation, hard and soft landscaped areas, public lighting, attenuation, service connections, bin

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Enviroguide Consulting Residential Development Ecological Impact Assessment Newtownpark Avenue, Blackrock, Co. Dublin. stores, a new pedestrian crossing on Newtownpark Avenue and all ancillary site development works, all on the 1.46ha site. The development will consist of the demolition of the existing c. 26sqm single storey shed on site and construction of a residential development comprising;  140 no. apartment and duplex units across 5 no. 2-5 storey buildings (Blocks C&D over basement) comprising 1 studio apartment, 59 no. 1 bedroom apartments, 71 no. 2 bedroom apartments and 9 no. 3 bedroom apartments (along with a ‘linked’ single storey amenity building) as follows:

 Block A (4 storeys) comprises 32 no. apartments [balconies on all elevations] consisting of 17 no. 1 bedroom, and 15 no. 2 bedroom apartments;

 Block B (5 storeys) comprises 40 no. apartments [balconies on all elevations] consisting of 21 no. 1 bedroom and 19 no. 2 bedroom apartments;  Block C (4 - 5 storeys over basement) comprises 31 no. apartments [balconies on all elevations] consisting of 1 no. studio apartment, 8 no. 1 bedroom, 17 no. 2 bedroom and 5 no. 3 bedroom apartments;

 Block D (4 storeys over basement) comprises 28 no. apartments [balconies on all elevations] consisting of 9 no. 1 bedroom, 15 no. 2 bedroom and 4 no. 3 bedroom apartments;  Block E (2 - 3 storeys) comprises 9 no. duplex units [balconies on north and south elevations] consisting of 4 no. 1 bedroom units and 5 no. 2 bedroom units;

 Communal Amenity Space (889sqm) and public open space (1,680sqm) totalling 2,569sqm is provided throughout the site including internal amenity space/concierge area totalling 175sqm within a single story ‘linked’ building between Blocks A and B;

 Vehicular access to the development will be from the upgraded existing access from Newtownpark Avenue and will extend throughout the site linking to the basement car parking level (as well as provision of a future potential links to lands to the west and to Cluain Mhuire);

 Provision of 97 no. car parking spaces (29 no. surface car parking and 68 no. basement car parking); 226 no. cycle parking spaces (56 no. surface cycle parking space and 170 no. basement car parking) and 6 no. motorcycle spaces;

 Provision of a single storey ESB substation, hard and soft landscaped areas, public lighting, attenuation, service connections, bin stores, and a new pedestrian crossing on Newtownpark Avenue and all ancillary site development works.

1.3 Objectives of Plan The objectives of this invasive species management plan are to:  Describe the Japanese Knotweed infestation at the site based on Invasive Plant Solutions 2019 report  Provide code of practice guidelines and legislative context  Address how to undertake any construction activity within a Japanese knotweed site  Requirements for disposal of any contaminated material from within a Japanese Knotweed site.

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Enviroguide Consulting Residential Development Ecological Impact Assessment Newtownpark Avenue, Blackrock, Co. Dublin.

2 Site Location

2.1 Japanese Knotweed in 2017 & 2019 Invas Biosecurity carried out both mapping and treatment of Japanese Knotweed with a glyphosate- based herbicide in 2017. As part of the mapping exercise the actual extent as well as the potential/likely extent of further infestation (due to the more extensive underground rhizome network, which can extend up to 7m beyond the above ground plants) were mapped (Figure 3). Two main stands of Japanese Knotweed were identified in 2017, namely JK 1 and JK 2. It is estimated that stands JK 1 and JK 2 measure approx. 1200 sq.m. and 1000 sq.m. respectively, with the potential for a further approx. 700 sq.m. per stand of infested soils stretching beyond the above ground survey limits.

Figure 3. Extent of Japanese Knotweed on site in 2017. (source: Invasive Plant Solutions)

Invasive Plant Solutions carried out a walk-through survey of the subject lands, and the zones of Japanese Knotweed infestation on the 12th September 2019. The purpose of this inspection was to compare the current health, condition, and extent of the Japanese Knotweed stands, and how they have changed since the Invas Biosecurity 2017 report.

The main observations are as follows:

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Enviroguide Consulting Residential Development Ecological Impact Assessment Newtownpark Avenue, Blackrock, Co. Dublin.

 The western limit of the infested zone shows the presence of both dead and new juvenile growth of Japanese Knotweed, which is located both along, and beyond, the western site boundary line  There is some new juvenile growth of Japanese Knotweed within the ivy ground cover, adjacent to the wooded area running along the eastern limit of the Japanese Knotweed infested zone  Although the level of plant growth is now limited, the extent of the infested zone could not be considered as having changed significantly since the 2017 site survey

Stand JK 2  The perimeter of the Japanese Knotweed infested zone has been partially demarcated using timber posts, warning tape and signage.  Within the infested zone there has been regrowth of Japanese Knotweed, comprising a mix of healthy mature, healthy juvenile, distressed, and bonsai growth, which is spread across the site  There is some growth of healthy juvenile Japanese Knotweed beyond the demarcation fence running along the northern limits of the infested zone, which may also be beyond the site boundary line  Mature growth of Japanese Knotweed is concentrated in the eastern and south eastern sectors of the infested zone  Healthy Japanese Knotweed has spread from the south eastern sector of the site and is presenting in the adjoining ESB sub-station, as well as on the outside of the boundary wall, adjacent to the public footpath.  There is healthy Japanese Knotweed straddling the southern boundary, between the site and the adjoining Guardian Angels National School. The Japanese Knotweed appears to be colonising the linear compost heap that runs along the eastern end of the northern school boundary  Although the level of plant growth is now limited, the extent of the infested zone could not be considered as having changed significantly since the 2017 site survey

Taking into consideration the absence of specific details on how the site has been managed between the known herbicide treatment in 2017 and the 2019 inspection, the main conclusions that can be drawn on the Japanese Knotweed infestation at the site from Invasive Plant Solutions 2019 report are as follows:  The two Japanese Knotweed sites identified in 2017 (JK 1 and JK 2) were healthy and dense, suggesting that they were very well established by that time  JK 1 and JK 2 are still generating viable Japanese Knotweed growth, with the distribution of this growth across the extent of each site  The presence of mature and healthy Japanese Knotweed growth, particularly at JK 2, indicates equivalent healthy plant rhizomes  Japanese Knotweed growth straddles / crosses site boundaries at both JK 1 and JK 2

Thus, it is highly probable that the extent of both infested sites, and associated potential zones of further infestation, remain the same as those surveyed in 2017. The visual inspection walkover survey carried out by Enviroguide Consulting in May 2020 would support this. It must also be concluded that

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Enviroguide Consulting Residential Development Ecological Impact Assessment Newtownpark Avenue, Blackrock, Co. Dublin. the rhizome network across those areas, although subject to historic herbicide treatment, should be deemed to be viable over its full extent. The depth, and horizontal position, of this viable rhizome material cannot be determined by visible inspection and can only be established following a comprehensive test trenching programme. Notwithstanding this, it is probable that there will be a proportion of locations across the sites where the plant and rhizome material may have been eradicated or alternatively, could have entered a temporary state of dormancy. Note that while these conclusions have a high probability of being correct, further investigation and information are required before being considered definitive.

Figure 4. Japanese Knotweed infestation at JK 1 (a & b) and JK 2 (c & d). Photographs taken on the 7th of April 2020.

3 Legislative Context – extracted from Invasive Plant Solutions 2019 Report Japanese Knotweed Fallopia Japonica, and its hybrids, are listed as Invasive Alien Plant Species in Part 1 of the Third Schedule of the European Communities (Birds and Natural Habitats) Regulations 2011 (SI 477 of 2011, as amended). In addition, soils and other material containing Japanese Knotweed, and its hybrids, are classified in Part 3 of the Third Schedule as vector materials and are subject to the same strict legal controls. Failure to comply with the legal requirements set down can result in either civil or criminal prosecution, or both, with very severe penalties accruing. Convicted parties under the Act can be fined up to €500,000.00, jailed for up to 3 years, or both. Extracts from the relevant sections of the regulations are reproduced below.

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Enviroguide Consulting Residential Development Ecological Impact Assessment Newtownpark Avenue, Blackrock, Co. Dublin.

49(2) Save in accordance with a licence granted [by the Department of Arts, Heritage and the Gaeltacht], any person who plants, disperses, allows or causes to disperse, spreads or otherwise causes to grow in any place [a restricted non-native plant], shall be guilty of an offence.

49(3) … it shall be a defence to a charge of committing an offence under paragraph (1) or (2) to prove that the accused took all reasonable steps and exercised all due diligence to avoid committing the offence.

50(1) Save in accordance with a licence, a person shall be guilty of an offence if he or she […] offers or exposes for sale, transportation, distribution, introduction or release—

(a) [any restricted non-native animal or plant species],

(b) anything from which an animal or plant referred to in subparagraph (a) can be reproduced or propagated, or

(c) a vector material listed in the Third Schedule, [which includes] soil or spoil taken from places infested with Japanese Knotweed (Fallopia japonica)

4 Code of Practice Guidelines – extracted from Invasive Plant Solutions 2019 report

In order to help specifiers, consultants and contractors to select the most appropriate treatment option, some excerpts from the Knotweed Code of Practice 1 are reproduced below. The code of practice was developed by experts in the control of knotweed and is based on the successes and failures of hundreds of knotweed management plans in the United Kingdom. As such, it represents good guidance on the different treatment and remediation options, and the process to be followed to arrive at the most appropriate solution. Although the Code of Practice is targeted at Japanese Knotweed in particular, it is equally applicable to the control of its hybrids and other Knotweeds.

“Unless an area of ….. knotweed is likely to have a direct impact on the development, you should control it in its original location with herbicide over a suitable period of time, usually two - five years.

You should only consider excavating ….. knotweed as a last resort, and if so you should keep the amount of knotweed excavated to a minimum.

Soil containing ….. knotweed material may be buried on the site where it is produced, to ensure that you completely kill it. In this case, you must bury material at least 5m deep.

Where local conditions mean you cannot use burial as an option, it may be possible to create a ….. knotweed bund.

The purpose of the bund is to move the ….. knotweed to an area of the site that is not used. This ‘buys time’ for treatment that would not be possible where the ….. knotweed was originally located.

In some situations where burial is the preferred disposal method but it is not possible to bury ….. knotweed to 5m, it may be completely encapsulated into a root barrier membrane cell

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Enviroguide Consulting Residential Development Ecological Impact Assessment Newtownpark Avenue, Blackrock, Co. Dublin.

Sometimes, due to shortage of time and location, landfill is the only reliable option, but it should be treated as a last resort. Landfill is very expensive for the development industry, and needs haulage, which increases the risk of ….. knotweed spreading

When you transport soil infested with ….. knotweed to landfill, it is essential to carry out strict hygiene measures.

If you do not follow these standards, this may lead to ….. knotweed spreading.

It should be concluded from the above that any presence of Japanese Knotweed is a matter of serious concern. Its capacity to spread rapidly and seriously impair our native habitat, as well as being subject to strict statutory control, and formally classified as a controlled waste, means that its remediation requires close and careful management.

5 Management of Japanese Knotweed at Site of the Proposed Development

The Invasive Plant Solutions 2019 report highlighted the management options for Japanese Knotweed at the Site of the Proposed Development and their suitability. Based on the review of all the remediation options and taking into consideration the intention to comprehensively develop the site in the short term, it was concluded by Invasive Plant Solutions that the bio-secure removal, and offsite disposal, of Japanese Knotweed infested soils at both JK 1 and JK 2, offered the most practical and appropriate remediation solution.

Horizontal root barrier membranes are applied where most of the infested soil does not have to be disturbed to facilitate the proposed development or construction works, by virtue of the infested soil being located within the construction footprint, but principally below formation level. In such circumstances only the uppermost level of infested soil, located above formation level, is removed. The rest of the infested soil is then overlain with a root barrier membrane system which will contain it and prevent the rhizome from regenerating.

This approach will require a further assessment of the extent of the infestation and the depth, and horizontal position, of this viable rhizome in order to define the areas suitable for this ‘soft landscaping’ approach.

The off-site disposal of Japanese Knotweed infested soil is generally only considered as a last resort, when none of the other treatment options available are deemed to be feasible. The Japanese Knotweed must be disposed of it at a suitably licensed or permitted disposal facility. Any transport of contaminated soil on a national road will require a licence from the NPWS. Landfill operators dealing with material contaminated with Japanese knotweed must ensure that they are licensed/permitted to receive it and that they have enough capacity to handle the material.

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Enviroguide Consulting Residential Development Ecological Impact Assessment Newtownpark Avenue, Blackrock, Co. Dublin.

Facilities that are currently licenced to accept Japanese Knotweed vegetation and soil for incineration are:  Dublin Waste to Energy Facility Pigeon House Road, Poolbeg Peninsula, Dublin 4, Dublin. Licence Number W0231-01  Indaver Ireland Ltd Carranstown, Duleek, Meath, Meath. Licence Number W0167-03

Facilities that are currently licenced to accept Japanese Knotweed infested soil for deep burial are1:  Ballynagran Landfill Limited Ballynagran, Coolbeg and Kilcandra, Wicklow. Licence Number W0165-02  Corranure Landfill Co. Cavan Lismagratty & Corranure Townlands, Cootehill Road, Cavan, Cavan. Licence Number W0077-04

The following details the procedures for preventing further spread of Japanese Knotweed, excavating Japanese Knotweed, transporting materials associated with the plant across the site and temporary stockpiling of Japanese Knotweed (if necessary).

5.1 Prevention of further spread of Japanese knotweed It is essential that good site hygiene practices are employed to reduce the risk of contaminating other areas of the site with Japanese Knotweed. The following measures should be employed: 1. Japanese Knotweed infested areas should be clearly marked with tape and signage. As a general rule, the area of infestation is considered 7m horizontally from the nearest growth of Japanese Knotweed that can be seen. 2. All contractors should be made aware of the Japanese Knotweed infestation. 3. Vehicles with caterpillar tracks should not be used in the infested areas. 4. Vehicles exiting infested areas should either be confined to haulage routes protected by root barrier membranes, or be pressure washed in a designated wash-down area. 5. Vehicles used to transport infested soils must be thoroughly pressure-washed in a designated wash-down area before being used for other work. 6. The material left after the vehicles have been pressure washed must be contained, collected and disposed of along with the other Japanese knotweed material. 7. All activities concerning the infestation should be adequately supervised.

5.2 Excavation 1. The Ecologist / SHEQ Advisor will identify the exact area to be excavated on the ground using marking spray. The depth of the excavation will be determined by the depth of the roots of the Japanese Knotweed plant. It is vital to carefully identify rhizomes during the excavation process. The surface stalks and all knotweed vegetation will be excavated. All soil materials containing rhizomes and root structures will also be excavated. The removal of the roots will be deemed to be completed at the discretion of the environmental specialist. 2. The excavated material will be placed in a site dumper. The drop height from the excavator bucket to the dumper will be kept to a minimum to ensure that the contaminated soil is placed directly into the dumper and to prevent small particles of soil falling over the edges of the dumper.

1 Subject to available voidspace and compliance with their acceptance conditions.

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3. Work will be arranged to ensure that the loaded bucket slews across infested ground, hardstanding or geotextile sheet when loading. All spillage will be thoroughly cleaned before completion. 4. The dumpers will be filled to 80% capacity in order to avoid any risk of material spillage. 5. Plant used for transportation of the contaminated material will be supervised/inspected to ensure effective containment during transportation. Dumper trucks will not be allowed within the exclusion zone. Where the excavator enters the exclusion zone, wheel wash measures are to be used before it leaves the exclusion zone and wash materials added to the stockpiled materials.

5.3 Temporary Stockpiling of Japanese Knotweed In some instances, it may be necessary to stockpile the Japanese Knotweed for a short duration on site. In such circumstances the material will be excavated as outlined above and loaded into a site dumper and transported to a temporary stockpile site. 1. This stockpile site should be approved by the Environmental Specialist. It should not be subject to flooding. 2. A robust geotextile barrier, such as Terram 1000, will be laid out on the ground of the temporary receptor site. Excavated soil and plant materials will be placed on top of this barrier. Once all the excavated material has been stockpiled, the stockpile may be covered with the geotextile barrier until it can be removed off site. It is essential that this cover is thoroughly secured to prevent it from being blown off or damaged. Alternatively, work should be arranging so that stockpiling for loading is within infested area, or on hardstanding that can be completely cleaned on completion (e.g. tarmac). 3. An exclusion zone i.e. consisting of orange netlon supported on timber posts will be set up around the perimeter of the temporary stockpile to prevent unauthorised access to this area. 4. Margins of area should be level or bunded to prevent erosion of infested material (eg in runoff). 5. A sign will be erected to warn site personnel of the environmentally sensitive area.

The contaminated material will only be stored in the temporary stockpile as a short-term measure.

5.4 Transportation of materials across site 1. Designated haul routes will be used for the movement of plant and materials through the site. The haul route will have appropriate signage advising the site speed limit. The foreman is responsible for ensuring these measures are put in place and maintained throughout the works. 2. All vehicle drivers will use the designated route for transportation to the receptor site. 3. Vehicles may be covered to ensure that no materials fall over the edges of the tipper body. 4. All drivers will proceed to drive carefully to this area along the designated haul road abiding by the site speed limit. 5. Tipping of contaminated materials should only occur in the receptor pit and should be carried out so as not to drive over any contaminated soils. The tipping location should ensure that material does not fall back under the wheels once tipped, i.e. such as from a ramp. 6. Any transport of contaminated soil on a national road will require a licence from NPWS.

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5.5 Cleaning of Equipment 1. Following the tipping of contaminated materials into the receptor site, the environmental specialist will inspect the wheels of the vehicles and should he deem it necessary, a power washer will be used to clean the wheels of the lorry prior to the vehicle exiting the receptor area. 2. The excavator digging bucket will also be inspected and should he deem it necessary, a power washer will be used to clean the excavator into the dumper or receptor pit. 3. A wash stand will be used to clean plant if required at the donor site or receptor site. Dispose of cleanings as infested material.

5.6 Japanese Knotweed on Adjacent Sites It is particularly important to consider Japanese knotweed in the wider environment around a particular site. If Japanese knotweed is growing on an adjacent site then no matter how good on-site Japanese knotweed control is, it may recolonise recently cleared sites. Thus, an understanding of the wider context is necessary to determine if eradication or control efforts are likely to be successful. In some situations, treatment of all Japanese knotweed on site might not be appropriate due to the likelihood of re-colonisation, but infested areas within a construction footprint must be dealt with appropriately. Given that the Japanese Knotweed growth straddles / crosses site boundaries at both the JK 1 and JK 2, it is essential that a treatment plan for Japanese Knotweed in these areas is agreed upon with the owners of these lands.

6 Additional invasive alien species of note on site

6.1 Three-cornered garlic Allium triquetrum

6.1.1 Introduction The three-cornered garlic is a spring-flowering, bulbous, perennial herb. Native to the west and central Mediterranean, the species is now widely distributed in the south and south east of Ireland. It typically invades or naturalises within hedgerows, parks, footpaths, roadsides, waste areas, disturbed/cultivated sites, orchards, open woodlands, forests, moist pastures and riparian areas. It spreads vegetatively in clumps, while seeds are spread by ants. Humans play a major role in the spread of three-cornered garlic through garden discards and the seed is also transported in the air turbulence created by vehicles along road corridors. Human assisted dispersal plays a greater role in the long distance spread of the species relative to natural dispersal. Transportation of bulbils and/or seeds on grass-cutting equipment is likely to spread the plant rapidly following introduction into semi-natural garden areas.

The overall potential impact of this species is considered moderate (O’Rourke and O’Flynn, 2014). There are no known social or economic impacts to-date. It is thought that if any economic costs where to be incurred, they are likely to only be associated with management of the species within the agricultural sector. The three-cornered garlic may pose a threat to biodiversity where the plant forms early season dense monocultural masses, particularly at protected sites.

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Figure 5. Images of three-cornered garlic recorded on site. Image taken 7th April 2020.

6.1.2 Management This species can be removed via chemical and mechanical means. Careful mechanical removal of bulbs followed by appropriate off-site disposal will reduce the infestation but is unlikely to destroy the seed bank. Mechanical removal may need to be repeated over a number of years to exhaust the seed bank. Herbicide application may be successful at reducing the spread of the plant. Applications of herbicide should be made in spring before flowering. However, similar to mechanical removal, multiple applications may be required due to the persistence of bulbs and of the soil seed bank (Invasive Weed Solutions, 2020).

7 References Environment Agency. 2006. Managing Japanese Knotweed on Developed Sites.

Invasive Weed Solutions. 2020. Three Cornered Garlic Removal & Control. Available at: https://www.invasiveweedsolutions.co.uk/invasive-weeds/non-native/three-cornered-garlic/. [accessed: 08/04/2020].

Non-Native Species Secretariat. Japanese Knotweed Identification Sheet. Available at: http://www.nonnativespecies.org/index.cfm?sectionid=47 [accessed: 08/04/2020].

O’Rourke, E. and O’Flynn, C. 2014. Risk Assessment of Allium triquetrum. Available at: http://nonnativespecies.ie/wp-content/uploads/2014/03/Allium-triquetrum-Three-cornered- Leek1.pdf [accessed: 08/04/2020].

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Appendix V – Previous Japanese Knotweed Assessment Reports (Invasive Plant Solu- tions (2019); with INVAS Biosecurity Report (2017) appended within)

______

REVIEW OF ON-SITE JAPANESE KNOTWEED & ASSOCIATED REMEDIATION COSTS ______

PROPOSED DEVELOPMENT SITE at CLUAIN MHUIRE NEWTOWNPARK AVENUE BLACKROCK CO. DUBLIN for GLENVEAGH HOMES

OCTOBER 2019 ASSESSMENT OF JAPANESE KNOTWEED & REMEDIATION COSTS

DOCUMENT DETAILS

______

CLIENT : GLENVEAGH HOMES

PROJECT TITLE : PROPOSED DEVELOPMENT SITE CLUAIN MHUIRE, NEWTOWNPARK AVENUE, BLACKROCK, CO. DUBLIN

DOCUMENT TITLE : REVIEW OF ON-SITE JAPANESE KNOTWEED

& ASSOCIATED REMEDIATION COSTS

JOB NUMBER : SD-O3-19

PREPARED BY : MR. KYRAN COLGAN

DOCUMENT FILE NAME STATUS REVISION ISSUE DATE AUTHOR CHECKED

SD-03-19/RSJK/00 DRAFT 00 04 OCTOBER 2019 MR. KYRAN COLGAN K.J.C.

SD-03-18/RSJK/01

INVASIVE PLANT SOLUTIONS - The Stationhouse, Station Road, Dundrum, Co. Tipperary, E34 EK83 T : 086–2621443 / 062–71589 W : www.knotweed.ie E : [email protected]

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Table of Contents

1 Introduction………………………………………………………………………………………………………………………………..……..3 1.1. Background to the Review……………………………………………………………………………………………………………..3 1.2. Review Methodology…………………………..…………………………………………………………………………….…………..3

2 Japanese Knotweed on Development Sites…………………………………………………………………………..…………... 4 2.1. General description of Japanese Knotweed………...……………………………………………………….………….…....4 2.2. Legislative Context…………………………………………………………………..…………….……………………………………..4

2.3. Code of Practice Guidelines…………………….………………………………….…………….………….…………..….……….5

3 Assessment of Japanese Knotweed on the Site…………………………………………………………………….…….……...6 3.1. Site Conditions in 2017…………….…………………………………………………………………………………….….….………6 3.2. Site Conditions in 2019…………………………………………….…………………………………………………….…….……….7 3.3. Site Photographs in 2019…………………………..………………………………………………………………….…..…………..8 3.4. Conclusions…………………………………………………………………..……………………………..……………….……….….…16

4 Overview of Remediation Costs……………….……………………………………………………….…………….………….…….17 4.1. Remediation Options…………………….………………….…………………………………………………………..………..……18 4.2. Remediation Selection…………………………………………………………………………………………………………………..20 4.3. Budget Remediation Costs…………………………………….……………………………………………………………………….21

Appendices

Appendix 1 : Invas Biosecurity report : September 2017..……..………………………………….……….……….….…...22

Appendix 2 : N.N.S.S. : Japanese Knotweed I.D. Sheet………………………………………………………………….…...... 30

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1 INTRODUCTION

1.1 BACKGROUND TO THIS REVIEW

Invasive Plant Solutions were retained by Glenveagh Homes to conduct an assessment of the current status and condition of Japanese Knotweed on a proposed development site located at Cluain Mhuire, Newtownpark Avenue, Blackrock, County Dublin and, based on that assessment, provide guidance on the probable remediation costs associated with managing the Japanese Knotweed infestations.

The review derives from the fact that Glenveagh Homes are currently in the process of acquiring the subject lands from the Health Service Executive. As part of the due diligence process associated with the acquisition, the vendor provided the purchaser with a report, prepared by Invas Biosecurity in September 2017, setting out the extent of Japanese Knotweed present on site at that time, as well as the treatment carried out by them. No other documents were supplied to the purchaser, and there has been no confirmation of further treatment since the date of the Invas Biosecurity report.

The location and extent of the site is shown at Figure 1 below.

Figure 1 : Location of proposed development site (Source: Bing Maps)

1.2 REVIEW METHODOLOGY

The only supporting documentation available to us upon which to conduct this review is the 2017 Invas Biosecurity report referred to above, and attached at Appendix 1. Therefore the review will be based solely on the information provided therein, considered and interpreted in the context of the current prevailing site conditions, as observed during a site inspection carried out on the 12th. September 2019. Further observations in relation to site remediation costs are based on accepted remediation methodologies and prevailing market costs.

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2 JAPANESE KNOTWEED ON DEVELOPMENT SITES

As some of the parties reading this review may not have a full understanding of Japanese Knotweed we feel it important to provide some general information, to assist in understanding the plant, its threats and risks, and the legal context within which it exists, particularly where Japanese Knotweed is present on development sites. The NNSS data sheet for Japanese Knotweed is included at Appendix 2 of this report.

2.1 GENERAL DESCRIPTION OF JAPANESE KNOTWEED

Japanese Knotweed is an herbaceous perennial plant that can grow to heights of 2-4m. In summer it produces dense bushes of purplish bamboo-like stems with large, shield shaped, triangular leaves. In winter the herbaceous material dies back, leaving only its dead canes. It has robust creeping rhizomes (roots) that can spread up to 7m horizontally from the parent plant. Rhizomes can extend vertically underground to a depth of 3m, and up to over 6m in ground which has been subject to disturbance or placement of imported material.

In its native Japan it usually grows in harsh rocky habitats, including cliffs faces and active volcanoes. It was introduced to Europe in the 19th Century as an ornamental plant, favoured for its adaptability and rapid growth. However, due to its excessive growth and persistence it quickly gained a reputation as a nuisance plant. In the latter part of the 20th century it was spread throughout the UK and Ireland, primarily by cutting, dumping, movement of soils, and in construction and demolition wastes. It is now widespread in Ireland.

Japanese Knotweed is spread primarily by fragmentation and dispersal of its rhizomes (roots) or stems. Its flowers cannot yet produce viable seed, as only female Japanese Knotweed plants have been recorded to date in Ireland. Fragments of the plant will set root and grow to form new plants, allowing the plant to spread quickly in areas that are frequently disturbed, notably in quarries, building sites and hedges that are cut using flails. New plants can grow from rhizome (root) fragments weighing as little as 0.7g, and buried material can occasionally regrow from depths of up to 6m. If buried in a location from which it cannot regrow, plant material can remain dormant for many years.

As a result of its highly-invasive characteristics and vigorous growth, Japanese Knotweed is recognised as a significant constraint on construction sites. It can easily be spread by the movement of earth, gravel or rocks, and by snagging on construction vehicles, machinery, equipment, tools, materials and workwear. Viable rhizome and plant fragments can also force their way to the surface through weak surfaces such as tarmac and permeable paving, as well as through joints between building materials and via control / expansion joints in concrete surfaces.

2.2 LEGISLATIVE CONTEXT

Japanese Knotweed Fallopia Japonica, and its hybrids, are listed as Invasive Alien Plant Species in Part 1 of the Third Schedule of the European Communities (Birds and Natural Habitats) Regulations 2011 (SI 477 of 2011, as amended). In addition, soils and other material containing Japanese Knotweed, and its hybrids, are classified in Part 3 of the Third Schedule as vector materials and are subject to the same strict legal controls. Failure to comply with the legal requirements set down can result in either civil or criminal prosecution, or both, with very severe penalties accruing. Convicted parties under the Act can be fined up to €500,000.00, jailed for up to 3 years, or both.

Extracts from the relevant sections of the regulations are reproduced below.

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50(1) Save in accordance with a licence, a person shall be guilty of an offence if he or she […] offers or exposes for sale, transportation, distribution, introduction or release— (a) [any restricted non-native animal or plant species], (b) anything from which an animal or plant referred to in subparagraph (a) can be reproduced or propagated, or (c) a vector material listed in the Third Schedule, [which includes] soil or spoil taken from places infested with Japanese Knotweed (Fallopia japonica)

2.3 CODE OF PRACTICE GUIDELINES

In order to help specifiers, consultants and contractors to select the most appropriate treatment option, some excerpts from the Knotweed Code of Practice1 are reproduced below. The code of practice was developed by experts in the control of knotweed, and is based on the successes and failures of hundreds of knotweed management plans in the United Kingdom. As such, it represents good guidance on the different treatment and remediation options, and the process to be followed to arrive at the most appropriate solution. Although the Code of Practice is targeted at Japanese Knotweed in particular, it is equally applicable to the control of its hybrids and other Knotweeds

 “Unless an area of ….. knotweed is likely to have a direct impact on the development, you should control it in its original location with herbicide over a suitable period of time, usually two - five years.  You should only consider excavating ….. knotweed as a last resort, and if so you should keep the amount of knotweed excavated to a minimum.  Soil containing ….. knotweed material may be buried on the site where it is produced, to ensure that you completely kill it. In this case, you must bury material at least 5m deep.  Where local conditions mean you cannot use burial as an option, it may be possible to create a ….. knotweed bund. The purpose of the bund is to move the ….. knotweed to an area of the site that is not used. This ‘buys time’ for treatment that would not be possible where the ….. knotweed was originally located.  In some situations where burial is the preferred disposal method but it is not possible to bury ….. knotweed to 5 m, it may be completely encapsulated into a root barrier membrane cell  Sometimes, due to shortage of time and location, landfill is the only reliable option, but it should be treated as a last resort. Landfill is very expensive for the development industry, and needs haulage, which increases the risk of ….. knotweed spreading  When you transport soil infested with ….. knotweed to landfill, it is essential to carry out strict hygiene measures. If you do not follow these standards, this may lead to ….. knotweed spreading.

1 UK Environment Agency (2013) The Knotweed Code of Practice: Managing Japanese Knotweed on development sites. Version 3. Published by the UK Environment Agency, Bristol. Available online at https://www.gov.uk/government/publications/japanese-knotweed-managing-on-development-sites (now withdrawn)

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3 ASSESSMENT OF JAPANESE KNOTWEED ON THE SITE

3.1 JAPANESE KNOTWEED IN 2017

To understand the health, condition, and extent of Japanese Knotweed present on site in 2017 we have to rely in the information presented in the Invas Biosecurity report prepared at that time. As part of that report they carried out mapping of the Japanese Knotweed present, including the possible / likely extent of further infestation as a result of the more extensive underground rhizome network, which can extend up to 7m beyond the above ground plants. The map reproduced at Figure 2 below has been extracted from the Invas Biosecurity report, with the sole modifications being the addition of a colour key code and the assigning of reference numbers to the two Japanese Knotweed stands identified, namely JK 1 and JK 2.

Figure 2 : Extent of Japanese Knotweed on site in 2017 (Source: Invas Biosecurity)

By reference to the Invas Biosecurity report the main points of interest / concern would be as follows :

 At the time of the survey, the two Japanese Knotweed stands were growing healthily in disused open ground, with the stands being both dense and extensive, suggesting that they were both very well established  The mapping within the report indicates that stands JK 1 and JK 2 measure approx. 1200 sq.m. and 1000 sq.m. respectively, with the potential for a further approx. 700 sq.m. per stand of infested soils stretching beyond the above ground survey limits (See Figure 2 above). This is in contradiction to Table 2.1 of the report, which assigns an area to the stands of 200 - 500 sq.m. and 100 - 200sq.m. respectively (See Page 3 at Appendix 1)  The western edge of the above ground Japanese Knotweed stand JK 1, as well as the majority of the associated underground rhizome zone of infestation, straddles the western boundary of the land holding  The northern, eastern, and southern edges of the above ground Japanese Knotweed stand JK 2, as well as the majority of the associated underground rhizome zone of infestation, straddle the boundaries of the land holding  The Japanese Knotweed stands were treated in September 2017 using a foliar spray application of herbicide  The report recommends annual follow up site surveys and herbicide treatments, as well as the formation of exclusion zones with appropriate signage

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3.2 JAPANESE KNOTWEED IN 2019

Invasive Plant Solutions carried out a walk-through survey of the subject lands, and particularly the zones of Japanese Knotweed infestation, on the 12th. September 2019. The purpose of this inspection was to compare the current health, condition, and extent of the Japanese Knotweed stands, and how they have changed since the Invas Biodiversity 2017 report. The main observations are as follows :

Stand JK 1  The perimeter of the Japanese Knotweed infested zone has been partially demarcated using timber posts, warning tape and signage  Within the infested zone there has been regrowth of Japanese Knotweed, comprising a mix of healthy juvenile, distressed, and bonsai growth, which is thinly spread across the site  The western limit of the infested zone shows the presence of both dead and new juvenile growth of Japanese Knotweed, which is located both along, and beyond, the western site boundary line  There is some new juvenile growth of Japanese Knotweed within the ivy ground cover, adjacent to the wooded area running along the eastern limit of the Japanese Knotweed infested zone  Although the level of plant growth is now limited, the extent of the infested zone could not be considered as having changed significantly since the 2017 site survey

Stand JK 2  The perimeter of the Japanese Knotweed infested zone has been partially demarcated using timber posts, warning tape and signage.  Within the infested zone there has been regrowth of Japanese Knotweed, comprising a mix of healthy mature, healthy juvenile, distressed, and bonsai growth, which is spread across the site  There is some growth of healthy juvenile Japanese Knotweed beyond the demarcation fence running along the northern limits of the infested zone, which may also be beyond the site boundary line  Mature growth of Japanese Knotweed is concentrated in the eastern and south eastern sectors of the infested zone, with many of the plant stems currently in flower  Healthy Japanese Knotweed has spread from the south eastern sector of the site and is presenting in the adjoining ESB sub-station, as well as on the outside of the boundary wall, adjacent to the public footpath.  There is healthy Japanese Knotweed straddling the southern boundary, between the site and the adjoining Guardian Angels National School. The Japanese Knotweed appears to be colonising the linear compost heap that runs along the eastern end of the northern school boundary  Although the level of plant growth is now limited, the extent of the infested zone could not be considered as having changed significantly since the 2017 site survey

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3.3 SITE PHOTOGRAPHS OF JAPANESE KNOTWEED IN 2019

JK 1 - GENERAL VIEW OF INFESTED ZONE

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JK 1 – TYPICAL GROWTH WITHIN INFESTED ZONE

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JK 1 – GROWTH ALONG / BEYOND WESTERN SITE BOUNDARY

JK 1 – GROWTH WITHIN GROUND COVER IN EASTERN SECTOR OF INFESTED ZONE

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JK 2 - GENERAL VIEW OF INFESTED ZONE

JK 2 – TYPICAL GROWTH WITHIN INFESTED ZONE

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JK 2 – TYPICAL GROWTH WITHIN INFESTED ZONE

JK 2 – DEMARCATION FENCING ALONG NORTHERN BOUNDARY OF INFESTED ZONE

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JK 2 – JAPANESE KNOTWEED GROWTH ALONG NORTHERN BOUNDARY OF INFESTED ZONE

JK 2 – MATURE JAPANESE GROWTH IN EASTERN SECTOR OF INFESTED ZONE

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JK 2 – JUVENILE JAPANESE KNOTWEED GROWING THROUGH SOUTHERN BOUNDARY FENCE

JK 2 – MATURE JAPANESE GROWTH WITHIN THE E.S.B. SUB-STATION AT THE SOUTH EASTERN CORNER OF THE SITE

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JK 2 – MATURE JAPANESE GROWTH WITHIN THE E.S.B. SUB-STATION AT THE SOUTH EASTERN CORNER OF THE SITE

JK 2 – MATURE JAPANESE GROWTH BETWEEN THE EASTERN SITE BOUNDARY WALL AND THE PUBLIC FOOTPATH

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3.4 CONCLUSIONS In the absence of specific details on how the site has been managed between the known herbicide treatment in 2017 and the 2019 inspection it is difficult to be fully certain on the interpretation of the information presented and gathered. However certain conclusions can be drawn, which have a high probability of being correct, but which would require further investigation and information before being considered definitive. With this in mind, we have drawn the following conclusions :

 The two Japanese Knotweed sites identified in 2017 were healthy and dense, suggesting that they were very well established by that time  The two sites are still generating viable Japanese Knotweed growth, with the distribution of this growth across the extent of each site  The presence of mature and healthy Japanese Knotweed growth, particularly at JK 2, indicates equivalent healthy plant rhizomes  Japanese Knotweed growth straddles / crosses site boundaries at both JK 1 and JK 2

It must therefore be concluded that the extent of both infested sites, and associated potential zones of further infestation, remain the same as those surveyed in 2017. It must also be concluded that the rhizome network across those areas, although subject to historic herbicide treatment, should be deemed to be viable over its full extent. The depth, and horizontal position, of this viable rhizome material cannot be determined by visible inspection and can only be established following a comprehensive test trenching programme. Notwithstanding this, it is probable that there will be a proportion of locations across the sites where the plant and rhizome material may have been eradicated or alternatively, could have entered a temporary state of dormancy.

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4 OVERVIEW OF REMEDIATION COSTS The selection of available management options outlined in Section 4.1, follows the flow chart contained in the Knotweed Code of Practice, published by The Environment Agency in the UK, and reproduced at Figure 3 below. It provides details of the range of options available for the treatment of Japanese Knotweed in a relative hierarchy, with the optimum treatment solution being determined by the nature of the constraints presented by each particular development or site.

Based on the urban nature of this site, and the intention for its comprehensive development in the short term, including an extensive basement footprint, then the Japanese Knotweed remediation solutions available become significantly reduced, with the most likely outcome being the off-site disposal of all Japanese Knotweed infested soils.

Figure 3 : Flowchart for establishing preferred treatment option for the Cluain Mhuire site (Source: UK Environment Agency)

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4.1 JAPANESE KNOTWEED MANAGEMENT OPTIONS

4.1.1 Option 1 – Avoidance Japanese Knotweed has been identified within the proposed works area on the site, at the locations illustrated in Section 2 above. Typically a minimum horizontal distance of 7m from the outer limits of the above ground Japanese Knotweed plants is required to ensure that the plant and rhizomes are not disturbed.

Given the size of the site, the likely nature and scope of the development, and the footprint of buildings and roads, it is not possible for the development works to safely avoid the Japanese Knotweed stands. Conclusion – Not suitable for this site

4.1.2 Option 2 –Treatment with Herbicides The use of an in-situ multi annual herbicide treatment programme is a very effective, and bio-secure method of controlling Japanese Knotweed and other I.A.P.S. plants. For Japanese Knotweed in particular this treatment method requires the application of herbicide to the full area of infestation, with annual or bi-annual applications carried out over a minimum of three to four years, with a further minimum two years of monitoring to validate its eradication. No works within a zone of 7m around the infestations should proceed until full eradication is achieved.

It is intended that development works will proceed as soon as practicable. Therefore there is not sufficient time available to safely complete a multi-annual Japanese Knotweed treatment programme. Conclusion – Not suitable for this site

4.1.3 Option 3 - Combined Treatment Combined treatment involves herbicide control carried out in conjunction with digging the infested ground. The aim of the treatment is to break up the rhizome, which stimulates leaf production and therefore make the plant more vulnerable to herbicide treatment. Digging can be conducted during the winter, if care is taken no to compact wet soil. Fresh regrowth then can be treated during the spring and summer. This method reduces the amount of time required to chemically treat Knotweed but it must still be carried out for at least 18 months to be effective, and preferably be followed by a further two year monitoring period, to validate eradication.

As above, this method is deemed unsuitable as there is not sufficient time available to safely complete a Japanese Knotweed treatment programme. Conclusion – Not suitable for this site

4.1.4 Option 4 - Soil Screening and Sieving At sites where conditions allow, it can be possible to use mobile plant to sieve and screen soil. This allows the majority of the knotweed rhizome to be separated out, and disposed of by incineration or deep burial at landfill. If the screened soil is free from Japanese Knotweed rhizome it is suitable for reuse, and can be utilised on site. However the reuse of screened soil presents its own bio-security risks, as the screening process involves multiple soil handlings. A single fragment of only 0.7g of rhizome can regenerate into fresh Japanese Knotweed growth, and it has also been demonstrated that Japanese Knotweed rhizome can remain dormant, but viable, for up to 20 years. Therefore the careful handling, placement, management and monitoring of screened soil material is essential if this methodology is to be used successfully, and even then there is a risk that viable rhizome could be moved to other locations within the site. In this instance this would most likely be within the development footprint.

This option has been discounted given that there are significant risks of viable rhizome material remaining within screened soil, which could be moved to other areas of the site, posing a long term bio-security risk which is incompatible with the development. Conclusion – Not suitable for this site

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4.1.5 Option 5 - Horizontal Root Barrier Membrane This option seeks to minimise the amount of handling of Japanese Knotweed infested soils. It applies to situations where the majority of infested soil does not have to be disturbed to facilitate the proposed development or construction works, by virtue of the infested soil being located within the construction footprint, but principally below formation level. In such circumstances only the uppermost level of infested soil, located above formation level, is removed. The rest of the infested soil is then overlain with a proprietary root barrier membrane system which will contain it and prevent the rhizome from regenerating. The excavated soil must then be remediated using one of the approved methods, including the options of using and on-site cell or bund, and off-site disposal

Based on the likely design proposals, the infested soils at JK 1 and JK 2 will be located partially or wholly within the footprint of any proposed development, as well as immediately adjacent to existing site boundaries. It is anticipated that the construction works would have to be carried out in these locations will include extensive soil disturbance and ground reduction, significant excavation for basements, buildings and underground services, as well as extensive replacement and / or upgrading of site boundary structures. These works would exceed the depth of Japanese Knotweed rhizome material present. Therefore all infested soil material would need to be removed. Conclusion – Not suitable for this site

4.1.6 Option 6 – Burial Method This option involves the deep burial of Japanese Knotweed infested soil, and other I.A.P.S. plant material, on-site, to a depth of five metres or greater, measured from finished ground level to the top of the buried infested soil. It is advisable to apply non-persistent herbicide to the growing plants, at least once, in advance of excavation to prevent the potential regrowth of infested material prior to burial. The treated material should be left a sufficient amount of time to allow the herbicide to take effect on the plant prior to excavation and burial. Following placement, the top of the infested soil should be capped with a proprietary root barrier membrane system.

This option has been discounted due to the engineering demands posed by the nature of the excavation required to achieve the necessary depths of 7 – 10m, particularly when considered in conjunction with the likely locations for such burial being typically below the footprint of the buildings / basements. Conclusion – Not suitable for this site

4.1.7 Option 7 – Temporary Bund Method Where on-site burial is not an option, it can be possible to create a temporary Japanese Knotweed containment bund. A bund is a shallow structure designed to safely contain Japanese Knotweed contaminated soil while it undergoes herbicide treatment. Typically infested soil is evenly placed in the bund to a depth of 0.5m, which results in the bund having a significant footprint, unless. The bund can either be raised, on top of the ground, or placed within an excavation to make the surface flush with the surrounding area. The purpose of the bund is to move the knotweed to an area of the site that is not in use, and where it can be treated over an extended period of time, from 18 months - 2 years. After the successful completion of the Japanese Knotweed treatment the bund can be dismantled and removed. However the continuing management of the treated soil, as noted in Section 4.2.4 above, will still be required.

This method is deemed unsuitable as the site will be developed comprehensively, as a single integrated phase, with no suitable quarantine area available in which to place a large soil containment bund. Conclusion – Not suitable for this site

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4.1.8 Option 8 – Below Ground Sealed Containment Cell This option involves the construction of an underground containment cell, sized to permanently store all infested soil. The cell is formed using a proprietary root barrier membrane system which securely holds the soil. The cell must then be covered by a minimum of 2m of soil or inert material, which protects the integrity of the root barrier membrane from plant roots and burrowing animals.

Careful consideration must be given to the siting of any containment cell, to ensure that it is positioned in a location which is stable, which will not be at risk of disturbance from future development, and where long term soil subsidence is deemed acceptable. Such a cell should also be located as close as possible to the original infestations, reducing the distance that viable rhizome material needs to be transported, thus minimising bio-security risks. As a cell becomes a permanent feature on a site, its location needs to be mapped, shown on all drawings, and included on the legal maps pertaining to the property.

In advance of detailed design proposals, it may be considered theoretically feasible to utilise this solution to remediate the Japanese Knotweed infested soils. However, although there may be green areas provided within any development, such locations are likely to be either on top of a basement footprint or very close to large scale structures. Engineering, and site management, constraints would be very significant if construction works had to avoid these locations across the full development programme.

In addition, the volume of infested soils which would need to be placed in such underground cells will probably be very significant. In such a case it is unlikely that the soils could be accommodated in a single cell, and would require the provision of a series of smaller cells across the development site.

This option could be considered in more detail but will likely be discounted due to the sheer volume of soil to be managed, work constraints posed by the siting of the cells, and the legal burden that would remain on the property. Conclusion – Theoretically feasible but most likely to be discounted

4.1.9 Option 9 – Off-site Disposal The off-site disposal of Japanese Knotweed infested soil is generally only considered when none of the other treatment options available are deemed to be feasible. Although there are some bio-security challenges to the off- site disposal option, these are no greater than those associated with any of the alternative solutions which involve the handling and movement of infested soils. However, the off-site disposal option typically works out to be the most expensive solution, as waste handling charges and levies, and specialist transport costs, can add significantly to the overall remediation costs.

However these disadvantages are balanced out by the obvious advantage of ensuring that a site is fully remediated, with all infested soils removed, and with the property being relieved of what would be a continuing legal burden on it. This is of particular benefit where institutional investors are party to the development and where the property, either in part or in whole, may be subject to sale in the future. In addition, if the remediation of the Japanese Knotweed infested soils is carried out in advance of the commencement of the main construction package, then the site can be handed over to the building contractor in a remediated state, with no impediments or restrictions, and enabling construction works to proceed unhindered. Conclusion – Suitable for this site

4.2 REMEDIATION SELECTION

Based on the review of all the remediation options, as listed above, and taking into consideration the intention to comprehensively develop the site in the short term, it is our initial conclusion that the bio-secure removal, and off- site disposal, of Japanese Knotweed infested soils, offers the most practical and appropriate remediation solution.

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4.3 BUDGET REMEDIATION COSTS

04 OCTOBER 2019

The Stationhouse, Station Road, Dundrum, Co. Tipperary, E34 EK83

Telephone : 086 – 2621443 / 062 - 71589 Website : www.knotweed.ie Email : [email protected]

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REVIEW OF ON-SITE JAPANESE KNOTWEED & ASSOCIATED REMEDIATION COSTS

PROPOSED DEVELOPMENT SITE at CLUAIN MHUIRE NEWTOWNPARK AVENUE BLACKROCK CO. DUBLIN

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APPENDIX 1

INVAS BIOSECURITY REPORT – SEPTEMBER 2017

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24 | P a g e Cluain Mhuire Site, Blackrock ASSESSMENT OF JAPANESE KNOTWEED & REMEDIATION COSTS

25 | P a g e Cluain Mhuire Site, Blackrock ASSESSMENT OF JAPANESE KNOTWEED & REMEDIATION COSTS

26 | P a g e Cluain Mhuire Site, Blackrock ASSESSMENT OF JAPANESE KNOTWEED & REMEDIATION COSTS

27 | P a g e Cluain Mhuire Site, Blackrock ASSESSMENT OF JAPANESE KNOTWEED & REMEDIATION COSTS

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REVIEW OF ON-SITE JAPANESE KNOTWEED & ASSOCIATED REMEDIATION COSTS

PROPOSED DEVELOPMENT SITE at CLUAIN MHUIRE NEWTOWNPARK AVENUE BLACKROCK CO. DUBLIN

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APPENDIX 2

N.N.S.S. – JAPANESE KNOTWEED I.D. SHEET

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Appendix VI – Seán Meehan Bat Report

Bat survey at Cluain Mhuire site, Blackrock, Co. Dublin

For: Glenveagh Homes Ltd September 2019

By: Seán Meehan ACIEEM, Ecologist [email protected]

Bat survey of lands at Cluain Mhuire Newtownpark Avenue, Blackrock, Co. Dublin September 2019 Glenveagh Homes Ltd.

1. Introduction

Ecologist Seán Meehan carried out a bat survey of the site at the request of Glenveagh Homes Ltd. on the evening of September 6th, 2019. Seán holds a NPWS bat survey licence (DER / BAT 2019-6). The Cluain Mhuire site is located along Newtownpark Avenue, Blackrock, Co. Dublin and occupies an area of approximately 1.29 hectares, Figure 1. The site is located in a primarily residential area with green spaces and treelines to the west. The site can be divided into two connected sections; a smaller section, heavily wooded that has frontage along Newtownpark Avenue and a larger section, located to the rear of Cluain Mhuire Centre. This larger rear section has wooded areas but also cleared open sections. The site contains pockets of woodland with a mixture of ornamental and native trees such as sycamore Acer pseudoplatanus, beech Fagus sylvatica, ash Fraxinus excelsior and dense areas of willow Salix sp. woodland. Due to lack of management, many areas within the site are covered in a layer of bramble and bindweed, making access across sections of the site challenging. A number of mature trees are found on the site with one in particular, an aspen Populus sp., having an impressive girth and structure. Eradication measures for stands of Japanese knotweed Fallopia japonica are ongoing in both sections of the site.

Figure 1. Layout of the study site, showing proposed development

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Bat survey of lands at Cluain Mhuire Newtownpark Avenue, Blackrock, Co. Dublin September 2019 Glenveagh Homes Ltd.

2. Bats and legislation All bat species are protected by law in Ireland at a national and European level. Nationally, the Wildlife Act 1976 (amended 2000) makes it an offence to wilfully interfere with, or destroy, the resting or breeding place for bats. All species of Irish bats are listed under Schedule 5 of the Wildlife Act (1976) making it an offence to: • Intentionally kill, injure, or take a bat • Possess or control any live or dead specimen or anything derived from a bat • Wilfully interfere with any structure or place used for breeding or resting by a bat • Wilfully interfere with a bat while it is occupying a structure or place which it uses for that purpose

The EU ‘Habitats’ Directive (92/43/EC; transposed into Irish law by S.I. No. 94 of 1997) provides legal protection for bats and their roosts at a European Union level. In addition, the Irish government are signatories of the 1979 Bonn ‘Convention on the Conservation of Migratory Species of Wild Animals’ and the 1982 Convention on the ‘Conservation of European Wildlife and Natural Habitats’. Ireland must also fulfil commitments under the 1991 ‘Eurobats Agreement’ for the conservation of bats in Europe. Under the EU Habitats Directive, lesser horseshoe bats are listed as an Annex II species (afforded special protection). All other Irish bat species are listed in Annex IV (general protection) of this directive.

Under existing legislation, the destruction, alteration or evacuation of a known bat roost, NPWS (National Parks and Wildlife Service) must be notified and a derogation licence approved and obtained.

3. Desk study The site straddles the boundary between tetrads O22E and O22J. A tetrad is an area of 2km². A search of the National Biodiversity Datacentre’s database1 returned the following records for bats in tetrads O22E, O22J and two other adjacent tetrads, O22D and O22I. Table 1 lists the tetrads and bat species recorded from within them.

Table 1. NBDC bat records per relevant tetrad Tetrad Common name Scientific name O22E Common pipistrelle, Leisler’s bat Pipistrellus pipistrellus, Nyctalus leisleri O22J Leisler’s bat Nyctalus leisleri O22D Soprano pipistrelle, common Pipistrellus pygmaeus, Pipistrellus pipistrelle, Leisler’s bat pipistrellus, Nyctalus leisleri O22J Common pipistrelle, Leisler’s bat Pipistrellus pipistrellus, Nyctalus leisleri

These three species, common pipistrelle, soprano pipistrelle and Leisler’s bat are amongst the most commonly occurring species in Ireland and have adapted to living in suburban and urban areas where suitable habitats such as gardens and parkland are available. The Bat Conservation Ireland bat habitat

1 https://maps.biodiversityireland.ie/Map Accessed on September 4th, 2019

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Bat survey of lands at Cluain Mhuire Newtownpark Avenue, Blackrock, Co. Dublin September 2019 Glenveagh Homes Ltd. suitability index2 for tetrads O22E and O22J range from 13.000001 to 28.111099, indicating a landscape with a moderate habitat suitability for bats.

4. Survey methodology Trees on site were examined for features that may be of possible use by bats for roosting. Such features include cracked and damaged limbs and branches, rot holes, lifting bark and natural cavities. A dusk (evening) bat survey of the site commenced at 19.33, thirty minutes before sunset and continued until 22.03. Weather conditions during the survey were optimal, with dry, calm and mild weather throughout the survey period. Temperatures ranged from +16°C at the commencement of the survey to +14°C by completion. A +EM3 bat detector and Garmin etrek 10 GPS device were used

5. Results Table 2 lists trees that have noteworthy features for potential bat roosts. Locations are in ITM.

Table 2. Trees (with tag numbers) within the site with features / potential features possibly of use by bats Tree species and tag Location (ITM) Features number Sycamore – T63 721913, 728638 Mature, notably large stature, ivy covered. Unable to view entire tree. TO BE FELLED. Poplar – T64 721915, 728622 Mature, girth of 7 metres at chest height, split limbs, dying sections, lifting bark. Unable to view entire tree. TO BE FELLED. Douglas fir – T82 721885, 728583 Damaged trunk with split. TO BE FELLED. Beech – T69 721937, 728601 Mature tree. Unable to view entire tree. Possible features. TO BE RETAINED Sycamore – T70 721931, 728591 Mature tree. Unable to view entire tree. Possible features. TO BE RETAINED

Bat activity on the site during the 2.5 hours long survey comprised three species: soprano pipistrelle, common pipistrelle and a brief flyby of a Leisler’s bat. Approximately fourteen bat passes were detected during the survey. Illumination from the buildings and grounds to the west of the site is notable and possibly decreases the level of bat activity along the western boundary of the site. No bats were observed emerging from the flagged trees however this does not negate the requirement for future examinations of the trees listed in Table 2.

2 Lundy, M.G., Aughney, T., Montgomery, W.I., & Roche, N. (2011) Landscape conservation for Irish bats and specific roosting characteristics. Bat Conservation Ireland.

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Bat survey of lands at Cluain Mhuire Newtownpark Avenue, Blackrock, Co. Dublin September 2019 Glenveagh Homes Ltd.

5. Mitigation The three trees listed in Table 2 requiring felling will be examined beforehand (there should be no more than 24 hours between examination and felling). Examination will require access to the tree’s higher sections through the use of tree climbers, preferably with bat surveying of trees experience, or / and a cherry picker to enable an ecologist to examine higher located features with an endoscopic camera. The Poplar (T64) in particular is considered to have a high bat roost potential and should be retained as part of the landscape plans for the site if possible. An ecologist should be consulted prior to any site clearance works to ensure that these trees are examined prior to felling (if required) or cordoned off from works to ensure their retention and protection. A line of ash and sycamore trees runs along the boundary wall separating the front section of the site from the rear section. Although the bat roost potential for these trees is considered low, these trees should be felled softly or in sections, under the supervision of an ecologist, and left on the ground for at least 24 hours prior to being cut up / mulched. If bats are confirmed roosting, then no felling works on that tree can proceed until a mitigation plan is submitted to and approved by NPWS and a derogation licence obtained.

Many species of bats and other mammals are sensitive to lighting and will avoid areas which are illuminated3. Bats are amongst the most sensitive receptors in relation to light pollution originating from the site. It is important that the lighting plan for the site ensures that lighting is wildlife sensitive and minimises illumination of areas that are used by bats for potential roosting, foraging and commuting. The Lighting Plan for the site4 will use a mixture of lighting columns between 5 and 6 metres high and the following columns, as per the drawing, P5, P6, P7, P11, P14, P15, P17, P18, P19, P20, P21 and P22 should be fitted with hoods or black louvres and sensor activated to avoid prolonged illumination of treelines and landscaped areas which are not required to be used by residents during darkness. No lights will have UV components and should have a colour temperature of warm white (830). During construction, temporary lighting should also be positioned appropriately to avoid light overspill and trigger sensor lighting deployed where possible.

Landscaping design should prioritise the use of native tree and wildflower species to attract insects which provide food for bats. These landscaping measures will not only benefit bats, but also biodiversity in general, such as pollinators. The installation of bat boxes on suitably located trees will provide additional bat roost potential for the local bat population.

There is one small structure, serving as a shed, on the site (beside the front Cluain Mhuire carpark). External checks revealed no obvious signs of bat roosts and the likelihood of bats using this shed are considered low, however an internal check should be carried out by a suitably qualified ecologist prior to its demolition.

3 Kelleher, C. & Marnell, F. (2006). Bat Mitigation Guidelines for Ireland. Irish Wildlife Manuals, No. 25. National Parks and Wildlife Service, Department of the Environment, Heritage and Local Government, Dublin, Ireland 4 Cluain Mhuire Lighting Plan, Sabre Electrical Services Ltd. Drawing SE 13120. 17th September 2020

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Bat survey of lands at Cluain Mhuire Newtownpark Avenue, Blackrock, Co. Dublin September 2019 Glenveagh Homes Ltd.

6. Conclusion Bat activity on site consisted of three species, with a Leisler’s bat being detected once. There are a number of trees, that if being felled, will require examination using facilities provided, such as a cherry picker, to enable the ecologist to reach the higher parts of these trees. No roosts were confirmed on the site.

7. References

Collins, J. (ed.) (2016). Bat Surveys for Professional ecologists: Good Practice Guidelines (3rd ed.). The Bat Conservation Trust, London

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.

Wildlife Act 1976 and Wildlife [Amendment] Act 2000. Government of Ireland.

8. Plates

Plate 1. View of part of the rear section of the site with extensive bramble growth and woodland

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Bat survey of lands at Cluain Mhuire Newtownpark Avenue, Blackrock, Co. Dublin September 2019 Glenveagh Homes Ltd.

Plate 2. View of part of the mature Poplar (T64). Multiple potential bat roost features occur on this tree.

Plate 3. Douglas fir (T82) adjacent to the western boundary wall of the site with damaged trunk, offering potential bat roosting features.

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Bat survey of lands at Cluain Mhuire Newtownpark Avenue, Blackrock, Co. Dublin September 2019 Glenveagh Homes Ltd.

Plate 4. Previously cleared area of the site, to the rear of residential properties.

Plate 5. Central area of the rear section of the site. The burned vegetation is Japanese knotweed infestation which is being treated.

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