Draft National Policy Framework on Alternative Fuels Infrastructure for Transport in Ireland
Natura Impact Statement
October 2016
NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport
TABLE OF CONTENTS
1 INTRODUCTION ...... 1
1.1 LEGISLATIVE CONTEXT FOR APPROPRIATE ASSESSMENT ...... 1
1.2 PURPOSE OF THE AA PROCESS ...... 2
1.3 OVERLAP WITH THE STRATEGIC ENVIRONMENTAL ASSESSMENT OF THE AFF ...... 2
1.4 CONSULTATION ...... 2
1.5 WORK COMPLETED TO DATE ...... 4 2 BACKGROUND AND OVERVIEW OF THE AFF ...... 5
2.1 ALTERNATIVE FUELS DIRECTIVE ...... 5
2.2 WHAT IS AN ALTERNATIVE FUEL ? ...... 5
2.3 REQUIREMENT FOR THE AFF ...... 6
2.4 VISION OF THE AFF ...... 7
2.5 APPROACH TO DEVELOPMENT OF THE AFF ...... 7
2.6 BARRIERS TO UPTAKE OF ALTERNATIVE FUELS ...... 8
2.7 ENERGY AND CLIMATE POLICY ...... 8
2.8 CONTENT OF THE AFF ...... 11 3 ASSESSMENT METHODOLOGY ...... 12
3.1 GUIDANCE DOCUMENTS ON AA ...... 12
3.2 GUIDING PRINCIPLES AND CASE LAW ...... 13
3.3 STAGES OF APPROPRIATE ASSESSMENT ...... 13
3.4 INFORMATION SOURCES CONSULTED ...... 14
3.5 IMPACT PREDICTION ...... 15 4 OVERVIEW OF THE RECEIVING ENVIRONMENT ...... 16
4.1 IDENTIFICATION OF EUROPEAN SITES ...... 16
4.2 CONSERVATION OBJECTIVES ...... 19
4.3 CONSERVATION STATUS OF EU PROTECTED HABITATS AND SPECIES ...... 20
4.4 EXISTING THREATS AND PRESSURES TO EU PROTECTED HABITATS AND SPECIES ...... 21
4.5 RELEVANT BIODIVERSITY POLICY ...... 22 5 STAGE 1 SCREENING FOR AA...... 23
5.1 POTENTIAL FOR LIKELY SIGNIFICANT EFFECTS ...... 23
5.2 SCREENING FOR APPROPRIATE ASSESSMENT CONCLUSION ...... 25 6 STAGE 2 APPROPRIATE ASSESSMENT ...... 26
6.1 INTRODUCTION ...... 26
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6.2 APPROACH TO ASSESSMENT ...... 26
6.3 IMPACT PREDICTION ...... 26
6.4 ASSESSMENT OF EFFECTS ...... 30
6.5 ASSESSMENT OF IN COMBINATION EFFECTS WITH OTHER PLANS OR PROJECTS ...... 52 7 MITIGATION MEASURES ...... 59
7.1 CONSTRUCTION , UPGRADE AND /OR OPERATION OF ALTERNATIVE FUELS RE-FUELLING INFRASTRUCTURE ... 59
7.2 LAND USE CHANGES AS A RESULT OF INDIRECTLY ENCOURAGING THE INCREASED USE OF ALTERNATIVE FUELS ...... 61
7.3 EMISSIONS TO AIR AS A RESULT OF INDIRECTLY ENCOURAGING THE INCREASED USE OF ALTERNATIVE FUELS 63 8 CONCLUSIONS ...... 65
8.1 NEXT STEPS ...... 65 9 REFERENCES ...... 66
APPENDICES
Appendix A Consultation Responses – AA Specific Appendix B Special Areas of Conservation (SACs) Republic of Ireland Appendix C Special Protection Areas (SPAs) Republic of Ireland Appendix D Special Areas of Conservation (SACs) Northern Ireland Appendix E Special Protection Areas (SPAs) Northern Ireland Appendix F Screening for Appropriate Assessment Appendix G EU Condition Assessment Appendix H Generic Threats and Pressures Considered Relevant to the AFF
LIST OF FIGURES
Figure 2.1 – Context of the AFF...... 11 Figure 4.1 - European Sites ...... 18
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LIST OF TABLES
Table 1.1 Statutory Consultees for SEA ...... 3 Table 1.2 Details of Consultation Responses with Relevance to AA Received by DTTAS ...... 3 Table 2.1 Alternative Fuels, Infrastructure and Feedstocks ...... 6 Table 2.2 Content of the AFF ...... 11 Table 4.1 European Sites within the ZoI of the AFF ...... 17 Table 5.1 Potential Likely Significant Effects – Electricity and Electric Vehicle Infrastructure ...... 23 Table 5.2 Potential Likely Significant Effects – Hydrogen and Hydrogen Fuel Infrastructure ...... 23 Table 5.3 Potential Likely Significant Effects – Biofuels and Associated Infrastructure ...... 24 Table 5.4 Potential Likely Significant Effects – Synthetic and Paraffinic Fuels and Infrastructure ...... 24 Table 5.5 Potential Likely Significant Effects – Natural gas Including Biomethane, in Gaseous Form (Compressed Natural Gas (CNG)) and in Liquefied Form (Liquefied Natural Gas (LNG)) and Associated Infrastructure ...... 24 Table 5.6 Potential Likely Significant Effects – Liquefied Petroleum Gas and Refuelling Infrastructure ...... 25 Table 6.1 Main Ecological Impacts Associated with the AFF ...... 28 Table 6.2 Electricity Measures by end 2017 ...... 30 Table 6.3 Electricity Measures to be implemented by end 2018 ...... 31 Table 6.4 Electricity Measures to be considered by end of 2018 ...... 32 Table 6.5 Electricity Measures by end of 2020 ...... 33 Table 6.6 Natural Gas (CNG & LNG) Measures to be implemented by end 2017 ...... 35 Table 6.7 Natural Gas (CNG & LNG) Measures to be considered by end 2018 ...... 36 Table 6.8 Hydrogen Policy Measures by end 2020 ...... 37 Table 6.9 LPG Future Policy Measures to be considered by end 2018 ...... 38 Table 6.10 Synthetic and Paraffinic Fuels Policy Measures ...... 39 Table 6.11 Policy Measures to Support Move to Low Emissions Vehicles ...... 39 Table 6.12 Air Emission Characteristics for Alternative Fuels ...... 44 Table 6.13 Primary Fuel Inputs for Electricity Generation 2014 and EEA Tier 1 Emission Factor ...... 46 Table 6.14 Habitats experiencing a decline in biodiversity as a result of air pollution (Adapted from NRA, 2011) ...... 48 Table 6.15 Examples of habitat changes as a result of nitrogen deposition for some European ecosystems (summary, adapted from Nordin, et al ., 2011)...... 51 Table 6.16 In-Combination Impacts with Other Plans and Strategies ...... 53 Table 6.17 In-Combination with Environmental Legislation and Policy ...... 58 Table 7.1 AA Mitigation ...... 59
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NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport
1 INTRODUCTION
The Department of Transport, Tourism and Sport (DTTAS) is currently preparing a National Policy Framework on Alternative Fuels Infrastructure for Transport (hereafter referred to as the AFF). This is in response to Council Directive 2014/94/EU on the deployment of alternatives fuels infrastructure which requires Member States to develop national policy frameworks for the market development of alternative fuels and related infrastructure.
The preparation of the Natura Impact Statement (NIS) complies with the requirements of Article 6 of the Council Directive 92/43/EEC of 21 May 1992 on the Conservation of Natural Habitats and of Wild Fauna and Flora (as amended) (hereafter referred to as the Habitats Directive). This is transposed in Ireland principally through the Planning and Development Act 2000 (as amended) and the European Communities (Birds and Natural Habitats) Regulations 2011 (as amended). The NIS has been prepared by RPS on behalf of the DTTAS (the Competent Authority).
The AFF is a national plan to ensure consistency across Europe on the development of alternative fuels infrastructure. Owing to this, the NIS is focussed at a national strategic level.
1.1 LEGISLATIVE CONTEXT FOR APPROPRIATE ASSESSMENT
The Habitats Directive provides legal protection for habitats and species of European importance. Articles 3 to 9 provide the legislative means to protect habitats and species of Community interest through the establishment and conservation of an EU-wide network of sites known as the Natura 2000 network. These are Special Areas of Conservation (SACs) designated under the Habitats Directive and Special Protection Areas (SPAs) designated under the Conservation of Wild Birds Directive (79/409/ECC) as codified by Directive 2009/147/EC (hereafter referred to as the Birds Directive).
Articles 6(3) and 6(4) of the Habitats Directive set out the decision-making tests for plans and projects likely to affect European Sites (Annex 1.1). Article 6(3) establishes the requirement for Appropriate Assessment (AA):
Any plan or project not directly connected with or necessary to the management of the [European] site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subjected to appropriate assessment of its implications for the site in view of the site’s conservation objectives. In light of the conclusions of the assessment of the implications for the site and subject to the provisions of paragraph 4, the competent national authorities shall agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the site concerned and, if appropriate, after having obtained the opinion of the general public.
Article 6(4) states:
If, in spite of a negative assessment of the implications for the [European] site and in the absence of alternative solutions, a plan or project must nevertheless be carried out for imperative reasons of overriding public interest, including those of a social or economic nature, Member States shall take all compensatory measures necessary to ensure that the overall
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coherence of Natura 2000 is protected. It shall inform the Commission of the compensatory measures adopted.
The Habitats Directive has been transposed into Irish law by the Planning and Development Act 2000 (as amended) and the European Communities (Birds and Natural Habitats) Regulations 2011 (as amended). In the context of the AFF, the governing legislation is principally Article 27 of the Birds and Natural Habitats Regulations which sets out the duties of public authorities (in this case the DTTAS) relating to nature conservation; and Article 42 which addresses AA. If screening for AA determines the likelihood for significant effects on a European Site(s), in view of its conservation objectives, then AA must be carried out for the Plan, including the compilation of a NIS to inform the decision making.
1.2 PURPOSE OF THE AA PROCESS
The overall purpose of the AA process is to ensure that the AFF does not result in any adverse effects on the integrity of any European Sites in view of its conservation objectives. This NIS has been prepared in support of the AA process having regard for the legislative requirements of EU and national law as outlined previously.
The responsibility for carrying out the AA lies with the DTTAS. The NIS will inform the AA determination made by the DTTAS at the time of adoption of the AFF, and the AA decision will be published alongside the adopted AFF.
1.3 OVERLAP WITH THE STRATEGIC ENVIRONMENTAL ASSESSMENT OF THE AFF
A Strategic Environmental Assessment (SEA) of the AFF is being carried out concurrently with the preparation of the NIS. The purpose of the SEA is to evaluate at an early stage, the range of environmental consequences that may occur as a result of implementing the AFF and to give interested parties an opportunity to comment upon the perceived or actual environmental impacts of the proposal. There is a degree of overlap between the requirements of the SEA and AA and in accordance with best practice, an integrated process of data sharing has been carried out, such as sharing of baseline data and mapping of European Sites, sharing of potential ecological effects of the AFF on European Sites and clarification on more technical aspects of the AFF. These processes together have informed and shaped the development of the AFF.
It is also noted that there are issues relevant to the Habitats Directive that are not strictly related to AA, including Article 10 and 12 of the directive. In these cases, the issues have been brought forward to the biodiversity, flora and fauna section of the SEA and have been addressed in that context as part of the wider environmental assessments informing the AFF.
1.4 CONSULTATION
From the outset, consultation is a mandatory requirement in the SEA process and responses often have specific guidance recognising the AA process. In line with the SEA Directive, specific environmental authorities (statutory consultees) were consulted in May 2016, see Table 1.1 . It is noted that a number of these departments have recently changed name and some responsibilities
MDR1224Rp005F01 2 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport have migrated between departments. Table 1.1 therefore also provides clarity on the name changes. The SEA legislation (S.I. 435 and S.I. 436 of 2004, as amended) has not been updated to reflect these recent departmental changes.
Table 1.1 Statutory Consultees for SEA
Statutory Consultees under National SEA Newly Named Departments Legislation Environmental Protection Agency (EPA) N/A Department of the Environment, Community and Department of the Housing, Planning, Community Local Government (DECLG) and Local Government (DHPCLG) Department of Arts, Heritage and the Gaeltacht Department of Arts, Heritage, Regional, Rural and (DAHG) Gaeltacht Affairs (DAHRRGA) Department of Communications, Energy and Natural Department of Communications, Climate Action Resources (DCENR) and the Environment (DCCAE) Department of Agriculture, Food and the Marine N/A (DAFM)
In recognition of the potential for transboundary effects with Northern Ireland, through potential changes relating to air quality, the Northern Ireland Department of Agriculture, Environment and Rural Affairs (DAERA) with responsibility for SEA in Northern Ireland, was also consulted. A number of responses were received during the SEA Scoping phase including the following that had direct bearing upon the AA process. Summary details of these are presented in Table 1.2 , while copies of these submissions are included for reference in Appendix A .
Table 1.2 Details of Consultation Responses with Relevance to AA Received by DTTAS
Consultee Date Summary of AA-specific issues raised Supplied a publication on forestry and biomass, and some DAFM 23 rd June 2016 background data on forestry biomass. DAERA (Northern Consideration of SACs and SPAs in Northern Ireland as part 21 st June 2016 Ireland) of the AA. Submission related specifically to SEA, however the broader EPA 4th July 2016 response was also useful in informing for the AA process.
In addition, an SEA scoping workshop was subsequently held in June 2016, with the AA team also in attendance. Representatives from all statutory consultees were invited to attend this workshop. EPA and the Department of Communications, Climate Action and the Environment (formerly the Department of Communications, Energy and Natural Resources) were represented on the day.
All responses received as part of the consultation, as noted in Table 1.1 , as well as comments received at the SEA Scoping workshop have been taken into account in the NIS.
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1.5 WORK COMPLETED TO DATE
Screening for AA of the AFF was compiled by RPS on behalf of the DTTAS in May 2016. It was submitted to the Development Applications Unit (DAU) of the DAHG (now the DAHRRGA) on 24 th May 2016, advising that the AFF was proceeding to AA and the production of an NIS (see Section 5 for a summary of the screening stage, while the full Screening for Appropriate Assessment report is included in Appendix F ).
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2 BACKGROUND AND OVERVIEW OF THE AFF
2.1 ALTERNATIVE FUELS DIRECTIVE
As identified, the requirement for a plan for Alternative Fuels is derived from Directive 2014/94/EU. The directive addresses a situation where more than 90% of the energy used in transport within Europe is derived from crude oil, most of which is imported. In 2011, 84% of Europe’s oil was imported, costing up to one billion euro per day 1. This supply depends, to a large degree, on politically unstable regions and, as such, raises security of supply concerns.
For Ireland, oil dependency levels were the fourth highest in the EU in 2013, at 49% of all energy use and the cost of all energy imports for the same year was €6.7 billion. Of this approximately €3.5 billion was spent on transportation where oil was the dominant fuel. In 2014, 97% of energy used in the transport sector in Ireland was from oil based products. This near total dependence on a single fuel source is unique to the transport sector.
The Commission has taken the view that a major obstacle to market uptake of alternative fuels was the slow establishment of supporting infrastructure, along with a lack of associated common technical standards across the EU. Therefore, Directive 2014/92/EC sets out common standards for future technical infrastructure specifications across Europe.
As well as specific targets for regional infrastructural coverage, the Directive also includes timelines for implementation. It relies on the Trans-European Transport Network (TEN-T) in order to determine where alternative fuel infrastructure should be provided. This TEN-T includes a network of core corridors (including road, rail, air and water transport) in the European Union and it envisages coordinated improvements to key routes. Within Ireland, the North Sea-Mediterranean Corridor stretches from Belfast to the Irish ports of Cork and Dublin encompassing a number of existing road corridors:, M1, M50, M7, M8, the Cork to Belfast railway line, Dublin and Cork Airport and the ports of Dublin, Cork and Shannon-Foynes.
In March 2010, the Commission established an Expert Group on Future Transport Fuels, with the objective of providing advice on specific actions aimed at the long term substitution of oil as a transport fuel. According to the report of the Expert Group 2, the following represents the main alternative fuels for propulsion in transport:
° Electricity/hydrogen, and biofuels (liquids) as the main options; ° Synthetic fuels as a technology bridge from fossil to biomass based fuels; ° Methane (natural gas and biomethane) as complementary fuel; and ° Liquefied Petroleum Gas (LPG) as supplement.
2.2 WHAT IS AN ALTERNATIVE FUEL?
For the purposes of the directive “ alternative fuels means fuels or power sources which serve, at least partly, as a substitute for fossil oil sources in the energy supply to transport and which have the
1 Clean Power for Transport – A European Alternative Fuel Strategy, COM(2013) 2 Report of the European Expert Group on Future Transport Fuels, January 2011
MDR1224Rp005F01 5 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport potential to contribute to its decarbonisation and enhance the environmental performance of the transport sector. They include, inter alia: electricity, hydrogen, biofuels as defined in point (i) of Article 2 of Directive 2009/28/EC, synthetic and paraffinic fuels, natural gas, including biomethane, in gaseous form (compressed natural gas (CNG)) and liquefied form (liquefied natural gas (LNG)), and liquefied petroleum gas (LPG)”.
It is important to note that, as stated in the directive, alternative fuels are fuels/ power sources which serve, at least partly, as a substitute for fossil oil sources in the energy supply to transport. They have the potential to contribute to environmental performance and decarbonisation of the transport sector. Table 2.1 provides a summary of the possible feedstocks and the existing and required infrastructure (both for processing and for distribution) for the six alternative fuels.
Table 2.1 Alternative Fuels, Infrastructure and Feedstocks
Alternative Fuel Infrastructure Feedstock − Fossil fuels − National Grid − Biomass Electricity − Network of city & town charging points − Wind − Network of fast-charge points on intercity routes − Solar − Hydroelectric − Processing facility to generate hydrogen from − Natural Gas feedstock Hydrogen − Water − Processing facility to convert electricity to − hydrogen Biomass − − Network of fuelling stations Coal − Pure plant oil − Liquid biofuel processing facilities − Used cooking oil Biofuels − Anaerobic digestion facilities − Animal By-products − Facility to upgrade biogas to biomethane − Cereal crops − Network of fuelling stations − Biomass − Natural Gas Synthetic & Paraffinic fuels − Processing facility to generate fuel from feedstock − Coal − Network of fuelling stations − Biomass − Plastic waste Natural Gas (LNG and CNG) − Network of fuelling stations − Natural gas
Liquid Petroleum Gas (LPG) − Natural Gas − Network of fuelling stations − Petroleum
2.3 REQUIREMENT FOR THE AFF
Directive 2014/92/EC seeks to ensure that member states develop a sustainable alternative fuels strategy, which would support the development of appropriate refuelling infrastructure and associated standards. The Directive requires Member States to develop national policy frameworks for the market development of alternative fuels and related infrastructure.
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The Department of Transport, Tourism and Sport (DTTAS) is currently preparing the AFF on behalf of the Minister in response to this requirement. As part of the preparation of the AFF, a working group has been established to oversee its development. The working group is comprised of expertise from within both the DTTAS and the divisions of Energy Security, Energy Regulation and Renewables.
The AFF contains defined targets and objectives for the deployment of alternative fuels infrastructure in order to support a range of fuels. In tandem with the development of a policy framework, the DTTAS are developing national regulations that will transpose Directive 2014/94/EU on ‘the deployment of alternatives fuels infrastructure’ into Irish law. The transposition of this Directive must be completed by Ireland and the other Member States by the 18 th November 2016.
2.4 VISION OF THE AFF
Ireland has expressed its intention, through national policy position, that it will transition to a low carbon economy by 2050. The 2015 White Paper on energy policy has outlined the same commitment for the energy sector whilst Smarter Travel (2009-2020) sets policy commitments for a low carbon transport sector. Reducing reliance on fossil fuels and switching to the use of alternatives will be an integral part of the transport sectors efforts to decarbonise and this will be reflected both in the AFF and in the forthcoming National (Climate) Mitigation Plan. The AFF represents a first step in communicating a longer term vision for transport to 2050. Whilst the National (Climate) Mitigation Plan will deal with a multi-faceted set of measures to decarbonise transport, the AFF will focus exclusively on reducing Ireland’s dependency on oil through the provision of infrastructure as well as through incentives to support the use of that infrastructure. Targets for infrastructure have been underpinned by assumptions on vehicle uptake, through the use of fleet modelling and investment capacity scenarios.
The overall ambition for the transport sector is to transition away from fossil fuels over the next two decades, moving predominantly to electricity for passenger cars, commuter rail and taxis by 2030. Natural gas along with some electrification will provide an interim solution for larger vehicles i.e. freight and buses. Biofuels will continue to play a role over this period. Post 2030, it is likely that hydrogen will continue to increase its penetration across the entire fleet spectrum with a correlated decline in the predominance of vehicles run solely on fossil fuels (as stated in Chapter 2 of the AFF). While it is not possible to predict with complete accuracy the exact nature of the technologies that will be deployed, Ireland’s ambition is for all new cars and vans sold in Ireland from 2030 to be zero emission (or zero emission capable). The freight and bus sectors will continue on a positive trajectory towards full penetration of Low Emission Vehicles.
2.5 APPROACH TO DEVELOPMENT OF THE AFF
The AFF has looked to European developments in order to contextualise any national strategy or framework, e.g. the EU wide consideration of the minimum coverage of refuelling structures for the main alternative fuels and how that will impact on a national strategy. The European alignment of policy and public/private funding and taxation in the areas of alternative fuel infrastructure has been considered in a national context.
The AFF has considered the following key aspects in its development:
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° Assessment of EU Member States policy on Alternative Fuels Infrastructure and therefore alignment of the AFF to enable national compliance with European and international best practice. ° Identification and listing of most feasible alternative fuels for Ireland and hence the identification of any potential or possible deficits in the necessary infrastructures to support these fuels in Ireland. ° Scoping of possible opportunities for national network companies within the requirements of the Alternative Fuels Infrastructure, and hence identification of the opportunities and barriers associated with the infrastructure for the delivery of alternative fuels on a national scale.
2.6 BARRIERS TO UPTAKE OF ALTERNATIVE FUELS
The DTTAS considers the development and use of alternative fuel is being held back by four main barriers:
° The high cost of vehicles, ° Limited choice in vehicles available to potential buyers; ° A low level of consumer acceptance of alternative fuels; and ° The lack of recharging and refuelling stations.
DTTAS see these barriers as being mutually dependent. Investors can be reluctant to build infrastructure where a market is in its infancy. In the absence of appropriate levels of infrastructure to support the uptake of alternative fuels, it is unlikely that enough vehicles will be sold to assert the required downward pressure on market price. This generates unwillingness by consumers to buy alternative fuelled vehicles as the price of vehicles remains prohibitive. This lack of demand has an impact, in turn, on the numbers of vehicles being introduced to the market (thereby prohibiting choice to the consumer). Through Directive 2014/94/EU, the Commission is aiming to resolve this cycle of dependence through the introduction of binding targets on Member States for a minimum level of infrastructure for clean fuels such as electricity and natural gas, along with common EU wide standards for the equipment needed.
2.7 ENERGY AND CLIMATE POLICY
2.7.1 Energy Policy
While Europe has a focus on security of supply, there is also the parallel drive to increase the share of renewable energy in the energy supply mix across Member States. The 2009 Renewables Energy Directive set mandatory targets arising from an overall European target of 20% for all energy to come from renewable energy sources by 2020 (different targets set for each Member State in order to achieve the overall 20%). In line with the Renewable Energy Directive, Ireland is required to achieve 16% of gross final energy consumption from renewable sources by 2020. In order to contribute to this goal, Ireland’s National Renewable Energy Action Plan proposes a renewable target for transport (known as the RES-T) of 10%. All Member States are required to achieve the same target in transport by 2020. Accordingly, the role for transport is very much prescribed. The Bioenergy Plan and the Renewable Electricity Policy and Development Framework which are both under development will contribute towards the goals outlined in the National Renewable Energy Action Plan.
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The primary mechanism for achieving the RES-T will be the Biofuel Obligation Scheme (BOS). The BOS was introduced with effect from 1 July 2010 and requires large suppliers of road transport fuels to include a certain percentage of biofuels across their fuel mix. The obligation rate rose to 6% in 2013 and a further increase to 8% from 1 January 2017 is anticipated. Electric vehicles (EVs) are not likely to impact on the RES-T, despite a Government target to achieve 50,000 EVs in the transport fleet by 2020. However, beyond 2020, the increased deployment of EVs will make a greater contribution towards future targets with a steady upward trend for penetration of renewable electricity in transport by 2030.
Ireland’s recent Energy White Paper 3 outlines that the transition to a Low Carbon Energy Future 2015-2030 is a complete energy policy update. It states that a framework is required to guide policy and actions that Ireland intends to take in the energy sector from now up to 2030. It aims to transition to a low carbon energy system that will ensure secure energy supplies of competitive and affordable energy. It also states that a low carbon future will involve a number of factors including “increasing the use of electricity and bioenergy to heat our homes and fuel our transport ”.
At an EU level and hence subsequently at Member State level, there is a European Strategy on clean and energy efficient vehicles that began in 2010. Subsequently, there has been the promotion of clean and energy efficient mobility at EU and national level. Collectively there have been over 40 actions in the areas of legislation, research, standard development, for both conventional engine
developments (e.g. CO 2 legislation, multi-fuel engines) as well as for ultra-low carbon electric vehicles and hydrogen fuels.
2.7.2 Climate Policy
In order to limit the increase in global temperature, the EU has set an objective of reducing greenhouse gas emissions by 80-95% by 2050 compared to 1990 in developed countries as a whole. To ensure that Ireland can effectively and equitably contribute to the EU objective as part of joint global mitigation efforts, and for the purposes of compliance with EU law, a low-carbon development strategy is being developed for Ireland to cover the period to 2050.
The extent of the challenge to reduce greenhouse gas emissions at a national level is well understood and reflected in both the National Policy Position on Climate Action and Low Carbon Development, which was published in April 2014, and the Climate Action and Low Carbon Development Act 2015.
The National Policy Position, which commits the non-Emission Trading Scheme (ETS) in Ireland to collectively reducing emissions by 80% by 2050, provides a high-level policy direction for the adoption and implementation by Government of plans to enable the State to move to a low carbon economy by 2050.
The transport sector, as the second largest emitter in the non-ETS, will have a significant role to play in meeting this policy objective. In order to respond to the climate challenge, changes in technology and travel behaviour will be required on a large scale throughout the transport system.
The Climate Action and Low Carbon Development Act 2015 contains provisions relating to the development and approval of successive National Mitigation Plans. The Act creates a statutory
3 The White Paper, Ireland’s Transition to a Low Carbon Energy Future DCENR (2015-2030)
MDR1224Rp005F01 9 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport obligation on a number of sectors, including transport, electricity generation, built environment and agriculture, to develop sectoral climate change mitigation measures for inclusion in these Plans.
2.7.3 Transport Policy
The EU’s White Paper on Transport committed to achieving the following key goals by 2050:
° No more conventionally-fuelled cars in cities; ° 40% use of sustainable low carbon fuels in aviation; at least 40% cut in shipping emissions; and ° A 60% cut in transport emissions by the middle of the century.
The associated roadmap to the White Paper places a particular emphasis on urban transport and the need to support a shift to cleaner cars and cleaner fuels. It sets a goal of achieving a 50% shift away from conventionally fuelled cars by 2030 with a view to phasing them out in cities by 2050. It also seeks to achieve a target of CO 2-free movement of goods in major urban centres by 2030.
At a national level, the DTTAS’s Smarter Travel policy to 2020 sets out clear goals to reduce reliance on fossil fuels and to reduce transport emissions. The policy gives clear signals that it will support alternative technologies as they develop and become commercially feasible. A commitment has been given to use alternative technologies in public vehicle fleets and to encourage the uptake of alternative fuels in the taxi and private bus/coach fleets.
Figure 2.1 provides an overview of the key plans/ policy and legislation of relevance to the AFF. Chapter 6 of this NIS discusses these plans, programmes and policies and their relationship with the AFF.
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Figure 2.1 – Context of the AFF
2.8 CONTENT OF THE AFF
This AFF sets targets to achieve an appropriate level of alternative fuels infrastructure for transport, which is relative to national policy and Irish market needs. Non-infrastructure based incentives to support the use of the infrastructure and the uptake of alternative fuels are also included within the AFF. The AFF is laid out in the following structure, as outlined in Table 2.2.
Table 2.2 Content of the AFF
Chapter No. Content Chapter 1 Foreward: A note from the Minister for Transport. Executive Summary: Summary details on the National Policy Framework Alternative Fuels Chapter 2 Infrastructure for Transport in Ireland Introduction: Outline of the reasons for developing the AFF and the relevant existing policies Chapter 3 that will influence or be influenced upon by the AFF Chapter 4 Strategic Environmental Assessment and Appropriate Assessment Chapter 5 Assessment of the Current Usage of Alternative Fuels in the Transport Sector Chapter 6 National Policy Forecasts and Alternative Fuel Options Chapter 7 Targets for Alternative Fuel Infrastructure Chapter 8 Measures Necessary to Ensure National Targets and Objectives are Reached Designation of Densely Populated Areas to be Equipped with Publicly Accessible Electric Chapter 9 Charging Points and CNG Refuelling Points Chapter 10 Summary of Implementation Plan – Timeline (to be populated post public consultation) Chapter 11 Review Provisions Chapter 12 Appendices
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3 ASSESSMENT METHODOLOGY
3.1 GUIDANCE DOCUMENTS ON AA
The AA requirements of Article 6 of the Habitats Directive follow a sequential approach as outlined in the following legislation, guidance documents and Departmental Circulars, namely:
European and National Legislation:
° Council Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora (also known as the ‘Habitats Directive’); ° Council Directive 2009/147/EC on the conservation of wild birds, codified version, (also known as the ‘Birds Directive’); ° European Communities (Birds and Natural Habitats) Regulations 2011 to 2015; and ° Planning and Development Act 2000 to 2014.
Guidance:
° Appropriate Assessment of Plans and Projects in Ireland: Guidance for Planning Authorities. DEHLG (2009, revised 10/02/10); ° Assessment of Plans and Projects Significantly Affecting Natura 2000 sites: Methodological Guidance on the Provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC. European Commission (2001). ° Communication from the Commission on the Precautionary Principle . European Commission (2000b) ° EC study on evaluating and improving permitting procedures related to Natura 2000 requirements under Article 6.3 of the Habitats Directive 92/43/EEC . European Commission (2013). ° Guidance Document on Article 6(4) of the ‘Habitats Directive’ 92/43/EEC. Clarification of the concepts of: Alternative Solutions, Imperative Reasons of Overriding Public Interest, Compensatory Measures, Overall Coherence, Opinion of the Commission . European Commission (2007). ° Managing Natura 2000 sites: the provisions of Article 6 of the ‘Habitats’ Directive 92/43/EEC 4. European Commission (2000a). ° Marine Natura Impacts Statements in Irish Special Areas of Conservation . A working Document. DAHG (2012).
Departmental/NPWS Circulars:
° Appropriate Assessment under Article 6 of the Habitats Directive: Guidance for Planning Authorities. Circular NPWS 1/10 and PSSP 2/10. ° Appropriate Assessment of Land Use Plans . Circular Letter SEA 1/08 & NPWS 1/08.
4 The Commission has notified its intent to revise this guidance and a draft revised document was published in April 2015. It would appear that this has not been finalised to date, and no revised guidance document is available on the Commissions official website as of September 2016.
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° Water Services Investment and Rural Water Programmes – Protection of Natural Heritage and National Monuments . Circular L8/08. ° Guidance on Compliance with Regulation 23 of the Habitats Directive. Circular Letter NPWS 2/07. ° Compliance Conditions in respect of Developments requiring (1) Environmental Impact Assessment (EIA); or (2) having potential impacts on Natura 2000 sites . Circular Letter PD 2/07 and NPWS 1/07.
3.2 GUIDING PRINCIPLES AND CASE LAW
Over time legal interpretation has been sought on the practical application of the legislation concerning AA as some terminology has been found to be unclear. European and National case law has clarified a number of issues and some aspects of the published guidance documents have been superseded by case law. Case law has been considered in the preparation of both the Screening and NIS of the AFF.
3.3 STAGES OF APPROPRIATE ASSESSMENT
The AA process progresses through four stages. If at any stage in the process it is determined that there will be no adverse effect on the integrity of a European Site in view of the sites conservation objectives, the process is effectively completed. The four stages are as follows:
° Stage 1 – Screening of the proposed plan or project for AA; ° Stage 2 – An AA of the proposed plan or project; ° Stage 3 – Assessment of alternative solutions; and ° Stage 4 – Imperative Reasons of Overriding Public Interest (IROPI)/ Derogation.
Stage 1: Screening for AA
The aim of screening is to assess firstly if the plan or project is directly connected with or necessary to the management of European Site(s); or in view of best scientific knowledge, if the plan or project, individually or in combination with other plans or projects, is likely to have a significant effect on a European site. This is done by examining the proposed plan or project and the conservation objectives of any European Sites that might potentially be affected. If screening determines that there is potential for significant effects or there is uncertainty regarding the significance of effects then it will be recommended that the plan is brought forward to the next stage of the AA process. Screening of the AFF was undertaken in May 2016 and it was determined that AA was required.
Stage 2: Appropriate Assessment
The aim of Stage 2 of the AA process is to identify any adverse impacts that the plan or project might have on the integrity of relevant European Sites. As part of the assessment, a key consideration is ‘in combination’ effects with other plans or projects. Where adverse impacts are identified, mitigation measures can be proposed that would avoid, reduce or remedy any such negative impacts and the plan or project should then be amended accordingly, thereby avoiding the need to progress to Stage
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3. As part of this stage an NIS is prepared to support decision making. This document is the NIS for the AFF.
Stage 3: Alternative Solutions
If it is not possible during Stage 2 of the AA process to conclude that there will be no adverse effects on site integrity, Stage 3 of the process must be undertaken which is to objectively assess whether alternative solutions exist by which the objectives of the plan or project can be achieved. Explicitly, this means alternative solutions that do not have adverse impacts on the integrity of a European Site. It should also be noted that EU guidance on this stage of the process states that, ‘other assessment criteria, such as economic criteria, cannot be seen as overruling ecological criteria’ (EC, 2001). In other words, if alternative solutions exist that do not have adverse impacts on European Sites; they should be adopted regardless of economic considerations. This stage of the AA process should result in the identification of the least damaging options for the plan or project.
Stage 4: Imperative Reasons of Overriding Public Interest (IROPI)
This stage of the AA process is undertaken when it has been determined that a plan or project will have adverse effects on the integrity of a European Site, but that no alternatives exist. At this stage of the AA process, it is the characteristics of the plan or project itself that will determine whether or not the competent authority can allow it to progress. This is the determination of ‘over-riding public interest’.
It is important to note that in the case of European Sites that include in their qualifying features ‘priority’ habitats or species, as defined in Annex I and II of the Directive, the demonstration of ‘over- riding public interest’ is not sufficient and it must be demonstrated that the plan or project is necessary for ‘human health or public safety considerations’. Where plans or projects meet these criteria, they can be allowed, provided adequate compensatory measures are proposed. Stage 4 of the process defines and describes these compensation measures.
3.4 INFORMATION SOURCES CONSULTED
The following general sources of information have been consulted for background environmental information. A detailed reference list can be found in Section 9 .
° Information provided by DTTAS on the AFF; ° Department of Environment, Community and Local Government – online land use mapping www.myplan.ie/en/index.html; ° GeoHive online mapping http://map.geohive.ie/mapviewer.html; ° Ordnance Survey of Ireland – Online mapping and Aerial photography www.osi.ie; ° National Parks and Wildlife Service – online European Site information www.npws.ie; ° Northern Ireland Environment Agency – online European Site information www.daera- ni.gov.uk; ° National Parks and Wildlife Service – Information on the status of EU protected habitats in Ireland (NPWS 2013a & 2013b); ° Ireland’s Article 12 submission to the EU Commission on the Status and Trends of Bird Species (2008-2012) ; ° Information on the conservation status of birds in Ireland (Colhoun & Cummins, 2013);
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° Environmental Protection Agency – EnVision maps www.epa.ie; ° Information on River Basin Districts - www.wfdireland.ie; ° Geological Survey of Ireland – Geology, soils and hydrogeology www.gsi.ie; ° Format for a Prioritised Action Framework (PAF) for Natura 2000 (DAHG, 2014) www.npws.ie/sites/default/files/general/PAF-IE-2014.pdf; and ° Actions for Biodiversity 2011-2016 : Irelands National Biodiversity Plan (DAHG, 2011).
3.5 IMPACT PREDICTION
The methodology for the assessment of impacts is derived from the Assessment of Plans and Projects Significantly Affecting Natura 2000 Sites (EC, 2001). When describing changes/activities and impacts on ecosystem structure and function, the types of impacts that are commonly presented include:
° Direct and indirect effects; ° Short and long-term effects; ° Construction, operational and decommissioning effects; and ° Isolated, interactive and cumulative effects.
A “source –pathway-receptor” approach has been applied for this assessment. The source relates to the policy measures outlined in the AFF which have the potential to adversely impact European Sites e.g. infrastructural developments or generation/combustion of alternative fuels. The pathways by which AFF policy measures can impact European Sites include changes in land use, habitat loss/fragmentation, emissions to air and hydrological connections. The receptor in this instance is the Natura 2000 network, potentially including those transboundary sites for which there is a pathway of connectivity as a result of the implementation of the AFF.
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4 OVERVIEW OF THE RECEIVING ENVIRONMENT
Ireland has obligations under EU law to protect and conserve biodiversity. This relates to habitats and species both within and outside designated sites. Nationally, Ireland has developed a Biodiversity Plan (DAHG, 2011) to address issues and halt the loss of biodiversity, in line with international commitments. The overall target for Ireland’s National Biodiversity Plan is that biodiversity loss and degradation are reduced by 2016 and progress is made towards substantial recovery by 2020 . This follows on from the European Commission EU Biodiversity Strategy to 2020 which has a headline target to halt the loss of biodiversity and ecosystem services by 2020, to restore ecosystems in so far as is feasible and to step up the EU contribution to averting global biodiversity loss . This implements EU commitments under the Convention on Biological Diversity (1992).
4.1 IDENTIFICATION OF EUROPEAN SITES
Current guidance on the zone of influence (ZoI) to be considered during the AA process states the following:
“A distance of 15km is currently recommended in the case of plans, and derives from UK guidance (Scott Wilson et al., 2006). For projects, the distance could be much less than 15km, and in some cases less than 100m, but this must be evaluated on a case-by-case basis with reference to the nature, size and location of the project, and the sensitivities of the ecological receptors, and the potential for in combination effects”.
The AFF does not detail geographic specificity for the implementation of the AFF measures, so it must be assumed that these measures could be implemented anywhere within the Republic of Ireland. The ZoI of the AFF is therefore considered to include all European Sites within the Republic of Ireland and considers transboundary impacts to SACs and SPAs within 15km of the national border.
It is acknowledged that qualifying interest (QIs)/special conservation interests (SCIs) of European Sites have different sensitivities and therefore a set distance of 15km may not be appropriate to assess the potential effects on all QIs/SCIs. For example QI fish species could be affected by changes to water quality at more than 15km distance, SCI bird species might be most significantly affected by disturbance within 1km of their habitat. Therefore whilst a reference distance of 15km has been used for diagrammatic purposes, the impact assessment considers the sensitivities to European Sites in light of their generic Conservation Objectives (COs) (which encompass the spirit of the site specific COs in the context of maintaining and restoring favourable conservation condition) and therefore sensitivities of European Sites outside of 15km are considered.
The Natura 2000 Network of sites is designated owing to its ecological importance in a European context. Sites within the Natura 2000 Network are referred to as European Sites and comprise SACs and SPAs. SACs are concerned with the protection of specific QIs and SCIs and the legal basis for their designation is the EU Habitats Directive. In the Republic of Ireland, 430 SACs have been designated covering 59 habitat types recognised in Annex I of the Directive, with 16 habitats designated as “priority” habitats owing to their ecological vulnerability. In addition, the same Directive, recognises 26 Annex II species. The habitats covered extend across the country and cover a range of ecological features from coastal to grassland to woodland. Priority habitats include Active Bogs, Turloughs and Fixed Dunes. Annex II species include Bats, Otter ( Lutra lutra ), Freshwater pearl
MDR1224Rp005F01 16 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport mussel ( Margaritifera margaritifera ) among others. Through the Birds Directive, SPAs designated for the protection of endangered species of wild birds including listed rare and vulnerable species, regularly occurring migratory species as well as wetland habitats that support such species. Currently there are 165 SPAs designated within the Republic of Ireland.
Table 4.1 provides a summary breakdown of the European Sites both in Ireland and those transboundary sites in Northern Ireland which are within 15km of the land boundary shared between Ireland and Northern Ireland and that have been considered in this NIS. Figure 4.1 shows the distribution of the SACs and SPAs listed in Table 4.1 . A full listing of the European Sites is included in Appendix B-E.
Table 4.1 European Sites within the ZoI of the AFF
Ireland* Northern Ireland 424 SAC’s + 6 offshore SAC’s considerably 26 SACs removed from the mainland 165 SPAs 5 SPAs *Data downloaded from www.npws.ie and correct as of September 2016.
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Figure 4.1 - European Sites
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4.2 CONSERVATION OBJECTIVES
Article 6(3) of the Habitats Directive states that:
Any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subject to appropriate assessment of its implications of the site in view of the site’s conservation objectives .
QIs/SCIs are annexed habitats and annexed species of community interest for which an SAC or SPA has been designated. The Conservation Objectives (COs) for European Sites are set out to ensure that the QIs/SCIs of that site are maintained or restored to a favourable conservation condition/conservation status. Maintenance of favourable conservation condition of habitats and species at a site level in turn contributes to maintaining or restoring favourable conservation status of habitats and species at a national level and ultimately at the Natura 2000 network level.
In Ireland ‘generic’ COs have been prepared for all European Sites, while ‘site specific’ COs have been prepared for a number of individual Sites to take account of the specific QIs/SCIs of that Site. Both the generic and site specific COs aim to define favourable conservation condition for habitats and species at the site level.
Generic COs which have been developed by NPWS encompass the spirit of site specific COs in the context of maintaining and restoring favourable conservation condition as follows:
For SACs: ° ‘To maintain or restore the favourable conservation condition of the Annex I habitats and/or Annex II species for which the SAC has been selected’.
For SPAs: ° ‘To maintain or restore the favourable conservation condition of the bird species listed as Special Conservation Interests for the SPA ’.
Favourable Conservation status of a habitat is achieved when: ° its natural range, and area it covers within that range, are stable or increasing, and ° the specific structure and functions which are necessary for its long term maintenance exist and are likely to continue to exist for the foreseeable future, and ° the conservation status of its typical species is “favourable”.
Favourable Conservation status of a species is achieved when: ° population dynamics data on the species concerned indicate that it is maintaining itself on a long term basis as a viable component of its natural habitats, and ° the natural range of the species is neither being reduced nor is likely to be reduced for the foreseeable future, and ° there is, and will probably continue to be, a sufficiently large habitat to maintain its populations on a long term basis.
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A full listing of the COs and QIs/SCIs that each European Site is designated for, as well as the attributes and targets to maintain or restore the QIs/SCIs to a favourable conservation condition are available from the NPWS website www.npws.ie .
4.3 CONSERVATION STATUS OF EU PROTECTED HABITATS AND SPECIES
In 2007 and again in 2013 the National Parks and Wildlife Service (NPWS) published a report detailing the conservation status in Ireland of habitats and species listed in the EU Habitats Directive (92/43/EEC), often referred to as the Article 17 Report 5. Under the Habitats Directive, each member state is obliged to undertake surveillance of the conservation status of the natural habitats and species in the Annexes and under Article 17, to report to the European Commission every six years on their status and on the implementation of the measures taken under the Directive. Appendix G sets out a summary of the conservation status of each habitat and species from both 2007 and 2013.
In the Article 17 Report for 2013, 9% of habitats were assessed as “ favourable” , 50% as “ inadequate ” and 41% as “ bad ”. Among the key findings were:
° Some of the marine habitats are considered to be improving, and to have better prospects, due in part to implementation of other EU environmental Directives. ° The status of raised bogs in Ireland is “Bad”; and the trend is for an ongoing decline as restoration is necessary to cause improvement, notwithstanding the cessation of cutting on SAC bogs. ° Blanket bog is also assessed as “Bad”; the report notes that, as one of the main impacts on this habitat is grazing, an improving trend might be expected due to the implementation of Commonage Framework Plans. However, this improvement appears to be offset and even exceeded by on-going deleterious effects such as peat cutting, erosion, drainage and burning. ° Although some of our woodlands are rated as “Bad” because they are patchy and fragmented, improvements have been noted due to afforestation and the planting of native species, removal of alien species and control of overgrazing. ° Losses of limestone pavement has been recorded outside the SAC network, however the BurrenLIFE and Burren Farming for Conservation Programme have significantly improved the quality of pavement and its associated habitats.
From the 2013 report, 52% of species were assessed as “ favourable ”, 20% as “ inadequate ”, 12% as “bad ” and 16% as “ unknown ” or considered to be vagrant species. Among the key findings are:
° Otter has also been assessed as “Favourable” with evidence of an expanding range. ° Salmon ( Salmo salar ) is showing signs of improvement and the Killarney shad ( Alosa killarnensis ) is assessed as “Favourable”, but some other fish remain at “Bad” status. ° Freshwater pearl mussel is “Bad” and declining.
Similarly, the requirements for reporting under Article 12 of the Birds Directive (2009/147/EC) are every 6 years. Irelands Article 12 submission to the EU Commission on the Status and trends of bird species (2008-2012)6 covers 196 species, which includes breeding, wintering and passage species.
5 The Status of EU Protected Habitats and Species in Ireland, NPWS 2007 (Vol 1-3) and 2013 (Vol 1 -3) 6 http://ec.europa.eu/environment/nature/knowledge/rep_birds/index_en.htm Accessed September 2016
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The report details that some species have had significant increases in population over the long term, including Raven ( Corvus corax ), Collard dove ( Streptopelia decaocto ), Buzzard ( Buteo buteo ) and Blackcap ( Sylvia atricapilla ). However, other species have undergone significant declines in their long-term breeding population trend: Corncrake ( Crex crex ) (85%), Curlew ( Numenius arquata ) (98%), Lapwing ( Vanellus vanellus ) (88%), and Redshank ( Tringa totanus ) (88%). The Hen harrier (Circus cyaneus ) shows a long-term population trend decrease of 27%. The results confirm that there is a need for measures to halt the declines noted above, most of which are due largely to changes in farming practices and intensity, and also the increase of activity in extensively farmed uplands through forestry and wind farm construction. Appendix G sets out a summary of the conservation status of each bird species from both 2007 and 2013.
4.4 EXISTING THREATS AND PRESSURES TO EU PROTECTED HABITATS AND SPECIES
Under Article 17 of the Habitats Directive, member states are obliged to identify threats and pressures to QIs/SCIs using a standard set of criteria. A threat is defined as an “Activity expected to have an impact on a species/habitat type in the future”, and a pressure is defined as an “Activity impacting a species/habitat type during the reporting cycle” 7.
Threats and pressures considered to be most relevantly linked either directly or indirectly to the AFF were extracted from the full list of threats and pressures 8. The headline categories considered relevant to the AFF are presented below, with a more detailed breakdown of the threats and pressures under each headline category presented in Appendix H.
° Agriculture; ° Forestry; ° Mining, quarrying and energy production; ° Transportation and service infrastructure; ° Urbanisation, residential and commercial development; ° Disturbance due to human activities; ° Pollution; ° Invasive and introduced species; ° Modification of natural conditions; and ° Climate change.
A general lack of environmental awareness, especially regarding ecosystem services has also been cited by the EPA in the latest State of the Environment Report 2012 as a pressure on national biodiversity. An updated State of the Environment Report is expected to be published later in 2016 as is an updated National Biodiversity Plan.
7 Reference Portal for reporting under the Article 17 of the Habitats Directive Explanatory Notes & Guidelines for the period 2007-2012 http://bd.eionet.europa.eu/activities/Reporting/Article_17/reference_portal 8 Accessed on the Reference Portal for reporting under the Article 17 of the Habitats Directive http://bd.eionet.europa.eu/activities/Reporting/Article_17/reference_portal
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4.5 RELEVANT BIODIVERSITY POLICY
Ireland's Prioritised Action Framework was published by DAHG in November 2014 and this was based upon the EU Biodiversity Strategy to 2020 (2011). It identified a range of actions needed to help improve the status of Ireland's habitats and species. The key priorities outlined in the framework are outlined below:
° Restoration of raised bogs; ° Better protection for blanket bogs and Ireland’s uplands generally; ° Better management of Ireland’s dunes and machair systems; ° Better protection for turloughs; ° Measures to protect Ireland’s remaining Freshwater pearl mussels; and ° New measures to protect birds in decline such as the Hen harrier, Corncrake and waders.
In addition there is a growing awareness and recognition of importance of ecosystem services supported at policy level. Target 2 of the Convention on Biological Diversity (CBD) Strategic Plan 2011-2020 requires that: By 2020, at the latest, biodiversity values have been integrated into national and local development and poverty reduction strategies and planning processes and are being incorporated into national accounting, as appropriate, and reporting systems. This is mirrored in both the EU Biodiversity Strategy to 2020 (Target 5) and Irelands National Actions for Biodiversity 2011-2016 (Target 3).
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5 STAGE 1 SCREENING FOR AA
In order to comply with the requirements of Article 6(3) of the EU Habitats Directive, the process of Screening for AA was undertaken at an early stage in the drafting of the AFF. The AA Screening assessed the potential for the AFF to result in likely significant effects on any European Sites within the Natura 2000 network, either alone or in combination with other plans and projects.
5.1 POTENTIAL FOR LIKELY SIGNIFICANT EFFECTS
The AA Screening was undertaken before the detailed policy measures were developed and therefore the potential likely significant effects, as presented in column three of Table 5.1 to Table 5.6 below, were inferred, particularly in relation to potential impacts to sensitive habitats e.g. those sensitive to air quality changes. The assessment was largely based on the range of alternative fuels to be considered as part of the AFF. As such, the AA Screening was undertaken in a strategic manner with cognisance of the precautionary principle.
The potential likely significant effects identified at the AA Screening stage in relation to each alternative fuel type being considered in the AFF have been extracted from the AA Screening document and are detailed in Table 5.1 to Table 5.6 .
Table 5.1 Potential Likely Significant Effects – Electricity and Electric Vehicle Infrastructure
Aspects of the AFF With Potential for Potential Significant Effects Significant Effects ° Provision of new infrastructure for electric vehicles e.g. domestic charge Loss or disturbance to habitats or species or points, public access city and town charge their supporting features through: points and inter-urban fast charging Electricity & ° Inappropriate siting of new infrastructure; points; Electric ° Construction of new infrastructure or Vehicle ° Upgrade of existing infrastructure to upgrade of existing infrastructure; provide additional capacity etc.; and Infrastructure ° Inappropriate management of facilities; ° Provision of infrastructure for Shore Side and Electricity (SSE). ° Impact to air quality.
Table 5.2 Potential Likely Significant Effects – Hydrogen and Hydrogen Fuel Infrastructure
Aspects of the AFF With Potential for Potential Significant Effects Significant Effects Loss or disturbance to habitats or species or their supporting features through: ° Provision of infrastructure for a hydrogen ° Inappropriate siting of new infrastructure; Hydrogen & refuelling network; ° Construction of new infrastructure; Hydrogen ° Use of hydrogen supplied fuel cells; and Refuelling ° Inappropriate management of fuel or ° Storage and transport of fuel. Network facilities;
° Impact to air quality; and ° Potential for spillage in transit.
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Table 5.3 Potential Likely Significant Effects – Biofuels and Associated Infrastructure
Aspects of the AFF With Potential for Potential Significant Effects Significant Effects Loss or disturbance to habitats or species or their supporting features through: ° Consumption of biomass/ biofuels; ° Generation of biomass/ biofuels; ° Provision of new infrastructure; ° Inappropriate siting of new infrastructure; Biofuels & ° Upgrade of existing infrastructure; ° Construction of new infrastructure or Associated upgrading of existing infrastructure; Infrastructure ° Storage and transport of fuel; and ° Conversion of fossil-fuel vehicles to dual- ° Inappropriate management of fuel or fuel engines. facilities; ° Impact to air quality; and ° Potential for spillage in transit.
Table 5.4 Potential Likely Significant Effects – Synthetic and Paraffinic Fuels and Infrastructure
Aspects of the AFF With Potential for Potential Significant Effects Significant Effects Loss or disturbance to habitats or species or their supporting features through: ° Provision of new infrastructure e.g. Plans ° Inappropriate siting of new infrastructure; by private entities to develop processing Synthetic & plants; ° Construction of new infrastructure or Paraffinic upgrading of existing infrastructure; Fuels & ° Upgrade of existing infrastructure; and ° Inappropriate management of fuel or Infrastructure ° Storage and transport of fuel. facilities;
° Impact to air quality; and ° Potential for spillage in transit.
Table 5.5 Potential Likely Significant Effects – Natural gas Including Biomethane, in Gaseous Form (Compressed Natural Gas (CNG)) and in Liquefied Form (Liquefied Natural Gas (LNG)) and Associated Infrastructure
Aspects of the AFF With Potential for Potential Significant Effects Significant Effects
° Provision of new fuelling infrastructure Loss or disturbance to habitats or species or including refuelling equipment and their supporting features through: bunkering (LNG); ° Inappropriate siting of new infrastructure; Natural Gas ° Supply of LNG by truck or via shuttle from LNG terminal (nearest in Wales) as there ° Construction of new infrastructure or Including upgrading of existing infrastructure; Biomethane is no LNG terminal in Ireland; (CNG & LNG) ° Development of new CNG Infrastructure ° Inappropriate management of fuel or facilities; & Associated ° Upgrading of existing infrastructure Infrastructure (CNG) e.g. Gas Networks Ireland ° Emissions from transport from nearest refuelling station in Cork and temporary LNG terminal and potential risk of spillage station in Dublin; and in transit; and Impact to air quality. ° Storage and transport of fuel. °
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Table 5.6 Potential Likely Significant Effects – Liquefied Petroleum Gas and Refuelling Infrastructure
Aspects of the AFF With Potential for Potential Significant Effects Significant Effects Loss or disturbance to habitats or species or their supporting features through: ° Provision of new fuelling infrastructure; Liquefied ° Inappropriate siting of new infrastructure; ° Upgrading of existing infrastructure; and Petroleum ° Construction of new infrastructure; Gas & ° Storage (pressure containers) and ° Inappropriate management of fuel or Refuelling transport of fuel. facilities; Infrastructure ° Impact to air quality; and ° Potential for spillage in transit.
5.2 SCREENING FOR APPROPRIATE ASSESSMENT CONCLUSION
On completion of the AA Screening, it was concluded that the potential for likely significant effects on European Sites could not be ruled out and the AFF would undergo AA. The DTTAS recorded their AA Screening determination accordingly. The AA Screening can be found in Appendix F .
The Screening for AA was submitted to the DAU of the DAHG (now the DAHRRGA) on 24 th May 2016, advising that the AFF was proceeding to AA.
The AA process then proceeded to the preparation of a NIS to inform the AA to be undertaken by DTTAS.
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6 STAGE 2 APPROPRIATE ASSESSMENT
6.1 INTRODUCTION
The assessment considers the impacts 9 that the AFF will have on the integrity of the European Sites, with respect to the conservation objectives of the sites and to their structure and function. EC guidance (MN2000) states that the integrity of a site involves its ecological functions and the decision as to whether it is adversely affected should focus on, and be limited to, the site’s conservation objectives.
Following on from the Screening for Appropriate Assessment, (see Section 5 ), this section considers further and sets out the elements of the AFF that have potential to give rise to likely significant effects on European Sites. The potential effects have been assessed in the absence of any mitigation measures, and taking account of the precautionary principle.
It is noted that the Habitats Directive promotes a hierarchy of avoidance, mitigation and compensatory measures. Through iterative discussion during the preparation of the AFF, avoidance of impacts as a result of implementing the AFF has therefore been to the forefront of discussions with the DTTAS.
The principle direct effect of the AFF relates to new or upgraded fuel delivery infrastructure e.g. provision of alternative fuel pumps at fuel stations, inclusion of shore-side electricity charging points etc. However, it is acknowledged that by providing the refuelling infrastructure this indirectly encourages the use of alternative fuels and as such the fuel source/feedstock, method of generation and resultant emissions must also be considered in its broadest sense in relation to likely significant effects on European Sites.
6.2 APPROACH TO ASSESSMENT
In line with the relevant guidance this stage of the Appropriate Assessment consists of three main steps:
° Impact Prediction - where the likely impacts of the AFF are examined. A source-pathway- receptor model has been used to assess potential for impact; ° Assessment of Effects - where the effects of the AFF are assessed as to whether they have any adverse effects on the integrity of European Sites as defined by conservation objectives; and ° Mitigation Measures - where mitigation measures are identified to ameliorate any adverse effects on the integrity of any European Site.
6.3 IMPACT PREDICTION
As noted in Chapter 3 , in considering the potential for impacts from implementation of the AFF, a “source –pathway-receptor” approach has been applied. The source relates to the policy measures outlined in the AFF which have the potential to adversely impact European Sites e.g. infrastructural developments or generation/combustion of alternative fuels. The pathways relates to how the AFF
9 Impacts considered include direct, indirect, short term, long term, temporary, permanent and cumulative.
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6.3.1 Context for Impact Prediction
The development and implementation of the AFF itself is considered to be largely positive in terms of its impacts on the environment as it will facilitate a shift from almost complete dependence on oil to a broader cleaner fuel base including opportunities for use of renewable energy fuel sources. This will indirectly contribute to targets in relation to GHG emissions, set to tackle climate change nationally and at an EU level. Climate change is one of the most significant future challenges for the protection of the Natura 2000 network across Europe as habitats and species distribution responds to the changes.
The primary objectives of the AFF are to: support the provision of alternative fuels refuelling infrastructure and incentives to support the use of that infrastructure. It is anticipated that the realisation of these objectives would in turn facilitate a modal shift from oil dependent fuel sources to alternative fuels and move the nation closer to a decarbonisation of our transport sector.
The development and implementation of the AFF is driven by European Directive and national policy. The AFF does not include explicit geographic context or project specific details of future activities/actions associated with the implementation of the AFF. Rather it provides predictions and assumptions on the alternative fuel targets that are to be achieved and which are supported through other existing plans/programmes. The strategic objectives and actions laid out in the AFF provide a framework for the development of other more specific plans or projects within the planning hierarchy. Therefore, at the strategic level, the main direct impact associated with the AFF is considered to be in relation to siting of alternative fuels infrastructure.
It is acknowledged that by providing the refuelling infrastructure and incentivisation envisaged through the AFF, this directly encourages the use of alternative fuels. Thus the fuel source/feedstock, method of generation and resultant emissions must also be considered in relation to indirect likely significant effects on European Sites. For example, an increase in electric vehicle (EV) usage will result in an increase in the demand for electricity. While the EVs themselves have no direct tailpipe emissions and would have no likely significant effect on European Sites, and in fact the shift away from petrol and diesel emissions would be expected to impact positively on some European Sites. However, dependent on the method of electricity generation there could be indirect effects on European Sites as a result of emissions to air where the source of the electricity is from peat/coal burning rather than renewable sources. Similarly, effects on European Sites via land use changes for renewable energy infrastructure/feedstock are also a potential indirect consequence of providing additional infrastructure and encouraging alternative fuels. There is a body of evidence at this stage in relation to impacts to sensitive species, such as hen harrier, from the provision of renewable wind infrastructure in sensitive habitat. Therefore, there is potential for direct and indirect impacts on the Natura 2000 Network arising from the future proposals of the AFF.
6.3.2 Impact Identification
A summary of the main potential ecological impacts that could arise from the implementation of the AFF are presented below and are used in the impact prediction.
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° Habitat loss, destruction, fragmentation or degradation : habitat loss or destruction is caused where there is complete removal of a habitat type, for example arising from the development of new infrastructure or a change of land use which alters the existing habitat. Habitat fragmentation results from the incremental loss of small patches of habitat within a larger landscape. Fragmentation can also result from impediments to the natural movements of species. This is relevant where important corridors for movement or migration are disrupted e.g. migration routes for lamprey species or Atlantic Salmon along river corridors are obstructed by hydropower infrastructure. Habitat degradation results in the diminishment of habitat quality and a loss of important habitat functions. It can arise from the introduction of invasive species, toxic contamination or physical alteration (e.g. arising from poor management during construction and subsequent operation of new infrastructure); ° Alterations to water quality and/or water movement : This is relevant where there could be an impact on the hydrological/hydrogeological connection to a European Site or on water quality. This could be via point source or diffuse pollution from infrastructural developments, changes to water quality via eutrophication/acidification as a result of emissions to air, or via infrastructural developments that alter surface or subsurface water flow. In terms of potential for alteration of water quality, the impact(s) may be in-situ or ex-situ (i.e. downstream and outside the immediate area) and can include the release of suspended solids, increased nutrient run-off from land such as biofuel crops/forestry, increased acidification/eutrophication as a result of emissions to air and siting of infrastructure. ° Alteration to air quality : The generation and combustion of alternative fuels may give rise to emissions to air. For larger industrial facilities this is regulated through strict licensing procedure with limits set for the protection of human health and the environment. This would be the case for generation plants such as Moneypoint. ° Disturbance to habitats/species : Disturbance to habitats/species within a European Site is likely to increase where there is an increase in activity or noise levels from developments within or adjacent to those sites. It is particularly important that known sensitive areas, such as those supporting breeding birds, otter, salmonids and others are taken into consideration during the investigation/feasibility or design stage of any infrastructure prior to approval. ° In-combination impacts : A series of individually modest impacts may ‘in combination’ produce a significant impact. The underlying intention of this in-combination provision is to take account of combined impacts, and these will often only occur over time. In that context, one must consider plans or projects which are completed; in preparation; or approved but uncompleted. Where there is a series of small, but potentially adverse impacts occurring within or adjacent to a European Site, consideration should be made as to their combined impacts.
6.3.3 Impact Prediction
In line with the methodology for impact prediction outlined in Section 3.4 , the main impacts that could arise from the various aspects of the AFF are summarised in Table 6.1 and discussed below. In- combination impacts are assessed separately in Section 6.5 .
Table 6.1 Main Ecological Impacts Associated with the AFF
Impact Source Impact Identification Impact Prediction Construction, upgrade and ° Habitat loss or destruction; ° Land use changes as a result of operation of alternative ° Habitat fragmentation or construction and operation of fuel ‘refuelling’ degradation; alternative fuel infrastructure. Direct infrastructure ° Alterations to water quality and permanent in nature.
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Impact Source Impact Identification Impact Prediction and/or water movement; ° Construction related impacts including ° Disturbance to changes to water quality, disturbance to habitats/species. habitats/species. Indirect and short term in nature. Land use changes as a ° Land use changes as a result of result of indirectly construction and operation of encouraging the increased alternative fuel generation facilities e.g. use of alternative fuels windfarms, hydropower, to meet increased demand on electricity. Indirect and permanent in nature. ° Landuse changes as a result of requirement for feedstock for alternative fuel e.g. biofuel crops/peat. Indirect and permanent in nature. ° Barriers to movement of species as a result of land use change e.g. hydropower creating barriers to ° Habitat loss or destruction; movement along river corridors. ° Habitat fragmentation or Indirect and long term in nature. degradation; ° Land use changes leading to resultant ° Alterations to water quality impacts on water quality e.g. and/or water movement; sedimentation and eutrophication as a ° Disturbance to result of run-off from sites cleared for habitats/species. windfarms or other electricity
generating facilities. Indirect and permanent in nature. ° Land use changes altering water movement or water retention e.g. construction of facilities altering groundwater movement to groundwater dependent habitats. Indirect and permanent in nature. ° Disturbance to habitats/species as a result of land use changes e.g. roosting/foraging grounds disturbed or altered. Indirect and long term in nature. Emissions to air from ° Combustion of fossil fuels to generate generation and electricity and resultant emissions to combustion of alternative air. Indirect and long term in nature. fuels a result of indirectly ° Generation of other alternative fuel and encouraging the increased associated emissions to air. Indirect and ° Habitat or degradation; use of alternative fuels long term in nature. ° Alteration to air quality; ° Combustion of alternative fuel and ° Disturbance to resultant tail pipe emissions to air. habitats/species. Indirect and long term in nature. ° Transportation of alternative fuel/feedstock leading to emissions to air dependent on the transport method used. Indirect and long term in nature.
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6.4 ASSESSMENT OF EFFECTS
Article 6 of the Habitats Directive states that:
Any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subject to appropriate assessment of its implications of the site in view of the site’s conservation objectives.
The impact prediction and assessment of potential effects on the Natura 2000 network from the AFF has considered the potential to impact on the achievement of the COs of the European Sites and is presented in the following sections.
6.4.1 Assessment of Policy Measures to Support Uptake of Electric Vehicles
Broadly speaking the AFF proposes to increase the uptake of EV through a combination of policy, research and incentivisation measures. The focus for this alternative fuel (electric vehicles) is not on additional infrastructure to any large degree with a small expansion of the current re-charging network sufficient to support 20,000 EVs by 2020. It is noted in the AFF that the number of re- charging points required to support 50,000 EVs would not differ significantly from that required to service 20,000 EVs. As such there is limited potential for direct effects on European Sites. The potential for effects stems from increased demand for electricity from both renewable and non- renewable sources, both of which have potential for significant effects on European Sites and associated species. It is however acknowledged that the existing and future load on the electricity grid is not the subject matter of the AFF .
Table 6.2 Electricity Measures by end 2017
Policy Measures Impact Assessment and Mitigation No direct potential likely significant effects to European Revise regulations, as required, in relation to Sites as this relates to governance and compliance with the technical specifications for normal and high- Directive. power recharging points and shore-side electricity supplies in line with the development Public authorities (the DTTAS and other) are also obliged to of new EU standards and/or any further changes comply with paragraph 27 of the Birds and Natural to Annex II of Directive 2014/94/EU. Habitats regulations 2011-2015 in relation to nature conservation. No direct potential likely significant effects to European The current Programme for Government Sites as this relates to information gathering that will includes a commitment to establish an EV inform future decision making. Taskforce to consider the range of measures and Although the establishment of a Taskforce is positive, options available to Government for the purpose there is potential for indirect effects. The Taskforce, in of accelerating the deployment of EVs. It is considering the range of measures and options available to expected that the work of the Task force will be accelerate the deployment of EVs, must consider the divided into three areas; potential indirect impacts of these on the Natura 2000 1. market growth stimuli, Network. Early consideration of the Natura 2000 Network would have positive effects on European Sites. See Section 2. charging infrastructure, and 6.4.2 ‘Construction, Upgrade and/or Operation of 3. legislation and planning. Alternative Fuels Re-fuelling Infrastructure’ for discussion and Chapter 7 which outlines mitigation. While the taskforce will also consider other No direct potential likely significant effects to European
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Policy Measures Impact Assessment and Mitigation carbon low carbon technologies and fuels, the Sites as this relates to incentivisation schemes. following reflects some of the market stimulus It is acknowledged that incentivisation schemes could lead options to be considered in respect of EVs: to potential indirect likely significant effects on European o Change to grant and VRT levels Sites through an increased demand for electricity and (methods, duration and cost); resultant environmental effects in terms of land use and emissions to air dependent on the method of electricity o Tolls (reduced charges and exemptions); generation used, albeit licensed and permitted in o Benefit in kind (BIK) relief; accordance with the appropriate planning and o Motor tax rates; environmental legislation and regulatory processes. o Public parking charges; See Section 6.4.2 ‘Construction, Upgrade and/or o Supports for leasing arrangements; Operation of Alternative Fuels Re-fuelling Infrastructure’ for discussion and Chapter 7 which outlines mitigation. o Supports for car sharing EVs; o Potential access to bus lanes; o Energy credits and Obligation Schemes; and o VAT on purchase of vehicle. Establish a Green Bus Fund, which would No direct potential likely significant effects to European support the uptake of electrically powered Sites as this relates to a monetary fund. buses, either hybrids or full electric.
Table 6.3 Electricity Measures to be implemented by end 2018
Policy Measures Impact Assessment and Mitigation No direct potential likely significant effects to European Sites as this relates to implementing measures recommended by the taskforce. Although the work of the Taskforce is positive, there is potential for indirect effects. The Taskforce, in considering Implement any measures recommended by the the range of measures and options available to accelerate LEV Taskforce and approved by government. the deployment of EVs, must consider the potential indirect impacts of these on the Natura 2000 Network. Early consideration of the Natura 2000 Network would have positive effects on European Sites. See Section 6.4.2 ‘Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure’ for discussion and Chapter 7 which outlines mitigation. Assess the need for an action package aimed at removing any administrative obstacles related to No potential likely significant effects to European Sites as the deployment of public and private recharging this relates to streamlining administrative procedures. points. In line with the White Paper on Energy Policy, establish a Government-backed scrappage No direct potential likely significant effects to European scheme for taxis aged 7 years or older where the Sites as this relates to a monetary scheme. car is being replaced by an EV. Consider contribution of building regulations for No direct potential likely significant effects to European supporting market uptake of EVs. Revised Sites as this relates to developing specific governance/ regulations would ideally provide for the setting procedures. of minimum requirements on the number of Public authorities (the DTTAS and other) are also obliged electric recharging points to be established at to comply with paragraph 27 of the Birds and Natural new residential or commercial developments Habitats regulations 2011-2015 in relation to nature
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Policy Measures Impact Assessment and Mitigation (where car parking is being provided). conservation.
Table 6.4 Electricity Measures to be considered by end of 2018
Policy Measures Impact Assessment and Mitigation In order to monitor and evaluate the operation of the charging points and to estimate the future load on the electricity grid, an assessment methodology and reporting system should be No direct potential likely significant effects to European established. Eirgrid are in the process of Sites. This relates to an information gathering exercise that developing modelling scenarios in this context, will inform future decision making. which will be informed by the ambition of this Draft AFF. Onshore and offshore interconnectivity should be considered in this regard. No direct potential likely significant effects to European Sites as this relates to input into information gathering that will help inform future decision making. Potential for indirect effects on European Sites if they are Participation in the development and research of not considered at the earliest possible stage. Early new technologies, trials, technical specifications consideration of the Natura 2000 Network in any and standards at EU and international level. research/studies would have positive effects on European Sites and, where possible, should be integrated into research proposals. See Section 6.4.2 ‘Construction, Upgrade and/or Operation of Alternative Fuels Re- fuelling Infrastructure’ for discussion research/studies and Chapter 7 which outlines mitigation. No direct potential likely significant effects to European Sites as this relates to developing specific governance/ Address the issue of misuse or ‘icing’ of charge procedures. point spaces through parking and/or road traffic Public authorities (the DTTAS and other) are also obliged regulations. to comply with paragraph 27 of the Birds and Natural Habitats regulations 2011-2015 in relation to nature conservation. No direct potential likely significant effects to European Sites as this relates to information gathering and feasibility studies that will inform future decision making. Potential for indirect effects on European Sites if they are Undertake a life cycle cost analysis of rolling out not considered at the earliest possible stage. Early Fixed Electrical Ground Power (FEGP) units at all consideration of the Natura 2000 Network in any airports not currently using electricity supply for research/studies would have positive effects on European stationary aircraft. Sites and, where possible, should be integrated into research proposals. See Section 6.4.2 ‘Construction, Upgrade and/or Operation of Alternative Fuels Re- fuelling Infrastructure’ for discussion research/studies and Chapter 7 which outlines mitigation Develop a feasibility study on shore-side No direct potential likely significant effects to European electricity supply for seagoing ships in TEN-T Sites as this measure in the first instance relates to ports (Dublin, Cork and Shannon-Foynes) taking information gathering and feasibility study that will inform into account demands, CBA and environmental future decision making. Potential for indirect potential effects and the level of financial support that likely significant effects on European Sites if they are not
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Policy Measures Impact Assessment and Mitigation may be required to make the delivery of the considered at the earliest possible stage. infrastructure feasible. Based on the results of the study, targets for shore side electricity It is acknowledged that there exists the potential for supply should be established, as required, with a potential direct and indirect likely significant effects on view to the deployment of any related European Sites as the measure suggests deploying infrastructure at these core TEN-T ports initially, infrastructure in three ports. Shannon-Foynes is located subject to the requirements of the relevant within two European Sites (Lower River Shannon SAC and environmental legislation, including Article 6 of River Shannon and River Fergus Estuaries SPA), with Dublin the Habitats Directive. and Cork ports and/or shipping lanes located adjacent to or adjoining a number of European Sites. Therefore, any future development of infrastructure at these ports has the potential for likely significant effects e.g. direct habitat loss or disturbance to QI/SCI species as well as in- combination/cumulative likely significant effects from other port activities. However, the measure explicitly highlights the requirement for Appropriate Assessment at development application level which would ensure protection of the European Sites.
See Section 6.4.2 ‘Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure’ for discussion in relation to the potential likely significant effects in relation to investigative and feasibility studies and Chapter 7 which outlines mitigation. No direct potential likely significant effects to European Sites as this relates to short term measures to stimulate demand. It is acknowledged that stimulation schemes could lead to The study on shore-side electricity supply should potential indirect likely significant effects on European also investigate the possibility for reducing the Sites through an increased demand for electricity and rate of electricity tax for shore-side electricity in resultant environmental effects in terms of land use and the short term to stimulate demand, If the emissions to air dependent on the method of electricity reduced rate was below the rate set by the generation used, albeit licensed and permitted in Energy Taxation Directive, authorisation would accordance with the appropriate planning and be required from the EU. environmental legislation and regulatory processes. See Section 6.4.2 ‘Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure’ for discussion and Chapter 7 which outlines mitigation.
Table 6.5 Electricity Measures by end of 2020
Policy Measures Impact Assessment and Mitigation No direct potential likely significant effects to European Sites as this relates to developing specific governance/ Develop, if required, regulatory measures to procedures. facilitate the deployment of home/private Public authorities (the DTTAS and other) are also obliged chargers. to comply with paragraph 27 of the Birds and Natural Habitats Regulations 2011-2015 in relation to nature conservation. Assess the implementation of regulations in No direct potential likely significant effects to European relation to user information associated with this Sites as this relates to developing governance/procedures
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Policy Measures Impact Assessment and Mitigation Directive 2014/94/EU. in relation to provision of information to the public. Assess and amend (if necessary) regulations and standards in order to ensure appropriate level of use of recharging infrastructure at apartment No direct potential likely significant effect to European blocks, parking lots, office and business Sites as this relates to review of governance to ensure locations, e.g.: Building Control Act, 1990 (3 of alternative fuel infrastructure is considered. 1190), Building Control Act, 2007, Building Control Regulations 1994-2014, Building Public authorities (the DTTAS and other) are also obliged Regulations 1994-2014, Road Traffic (Traffic and to comply with paragraph 27 of the Birds and Natural parking) Regulations, 1997 (S.I. No. 182/1997), Habitats Regulations 2011-2015 in relation to nature Road Traffic (Traffic And Parking) (Car Clubs And conservation. Electrically Powered Vehicles) Regulations 2014 (S.I. No. 325 of 2014). No direct potential likely significant effects to European Sites as this relates to consideration of utilisation of solar Consider the inclusion of any amended energy. regulations, a requirement for recharging points to incorporate, where feasible, renewable Public authorities (the DTTAS and other) are also obliged sources of energy i.e. solar photovoltaic panels. to comply with paragraph 27 of the Birds and Natural Habitats regulations 2011-2015 in relation to nature conservation. No direct potential likely significant effects to European Ensure development of new National Planning Sites as this relates to governance. Indirect positive Framework takes account of this draft AFF. impacts in the longer term as this will facilitate proper integration with other national plans. No direct potential likely significant effects to European Sites. This is a research and development measure that will inform future decision making. Continue to support and foster research on Early consideration of the Natura 2000 Network in any future technologies (e.g. wireless charging and research/studies would have positive effects on European battery swapping). Sites and, where possible, should be integrated into research proposals. See Section 6.4.2 ‘Construction, Upgrade and/or Operation of Alternative Fuels Re- fuelling Infrastructure’ for discussion research/studies and Chapter 7 which outlines mitigation. No direct potential likely significant effects to European Establish partnerships with public entities and Sites as this relates to forging partnerships with private companies in order to facilitate trials of information gatherers that will inform future decision EVs in public sector and public transport fleets. making.
6.4.1.1 Assessment of Policy Measures to Support Uptake of Natural Gas (CNG & LNG)
The primary constituent of CNG and LNG is methane and as it is a simple hydrocarbon the combustion of methane will generate combustion gases such as NO x, CO and CO 2. Particulates are not a major pollutant from methane as it readily and efficiently combusts with little or no particulate
residue. However as a fossil fuel, natural gas combustion generates CO 2 emissions unlike carbon free fuels. The suite of measures developed to support the uptake of natural gas as a fuel for transport include tax incentives to reduce the cost of running vehicles on natural gas and support the conversion to natural gas.
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Table 6.6 Natural Gas (CNG & LNG) Measures to be implemented by end 2017
Policy Measures Impact Assessment and Mitigation No direct potential likely significant effects to European Sites as this measure is focused on the development of small fast-fill stations on existing hardstanding areas. Potential for indirect potential likely significant effects on European Sites if appropriate construction measures are not applied at the earliest possible stage to the installation of the stations. Installation of 5 CNG publically accessible fast-fill Dublin Port is adjacent to European Sites and therefore stations at strategic locations including Dublin any future development of infrastructure at these ports Port. has the potential for likely significant effects e.g. disturbance to QI/SCI species. However, Screening for Appropriate Assessment at development application level which would ensure protection of the European Sites. See Section 6.4.2 ‘Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure’ for discussion in relation to the potential likely significant effects in relation to infrastructure and Chapter 7 which outlines mitigation. No direct potential likely significant effects to European Sites as this relates to completion of an investigative study and developing policy. Complete the assessment on biogas and Potential for indirect effects on European Sites if they are biomethane, which is currently being not considered at the earliest possible stage in undertaken by SEAI and develop appropriate investigative studies and also as a result of a requirement policy options to support the use of for re-fuelling infrastructure and emissions to air in biomethane, particularly in the public transport supporting the use of biomethane. and freight sectors. See Section 6.4.2 ‘Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure ’ and ‘Emissions to Air as a Result of Indirectly Encouraging the Increased Use of Alternative Fuels’ for discussion and Chapter 7 which outlines mitigation. Introduce a new ACA tax incentive for No direct potential likely significant effects to European companies with the aim of encouraging Sites as this relates to incentivisation schemes. investment in refuelling infrastructure and It is acknowledged that incentivisation schemes could lead equipment for natural gas. The ACA would to potential indirect effects on European Sites through an allow companies to write off 100% of the increased demand for natural gas and resultant purchase value of qualifying vehicles and environmental effects in terms of requirement for re- refuelling equipment, including CNG fuelling infrastructure and emissions to air. compression equipment, against their profit in See Section 6.4.2 ‘Construction, Upgrade and/or the year of purchase. It is anticipated that Operation of Alternative Fuels Re-fuelling Infrastructure ’ qualifying vehicles will need to demonstrate and ‘Emissions to Air as a Result of Indirectly Encouraging compliance with, at least, the Euro 6/VI emission the Increased Use of Alternative Fuels’ for discussion and standards. Chapter 7 which outlines mitigation. No direct potential likely significant effects to European Revise regulations, as required, in relation to Sites as this relates to developing specific governance/ technical specifications for refuelling points in procedures. line with the development of new EU standards Public authorities (the DTTAS and other) are also obliged and/or any further changes to Annex II of to comply with paragraph 27 of the Birds and Natural Directive 2014/94/EU. Habitats regulations 2011-2015 in relation to nature conservation under
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Policy Measures Impact Assessment and Mitigation Utilise the Green Bus Fund to support demonstration projects in public transport fleets. Only vehicles that demonstrate No direct potential likely significant effects to European compliance with the Euro 6/VI emission Sites as this relates to utilisation of funding for trials. standards will be supported through this fund.
Table 6.7 Natural Gas (CNG & LNG) Measures to be considered by end 2018
Policy Measures Impact Assessment and Mitigation No direct potential likely significant effects to European Sites as this relates to including biiomethane within the Biofuel Obligation Scheme. It is acknowledged that including biomethane could lead Include biomethane as a transport fuel in the to potential indirect likely significant effects on European Biofuel Obligation Scheme. Sites through resultant environmental effects in terms of emissions to air. See Section 6.4.2 ‘Emissions to Air as a Result of Indirectly Encouraging the Increased Use of Alternative Fuels’ for discussion and Chapter 7 which outlines mitigation. A low carbon vehicle fund to provide first mover No direct potential likely significant effects to European backing in commercial fleets. Sites as this is a monetary measure. No direct potential likely significant effects to European Sites as this relates to incentivisation schemes. It is acknowledged that incentivisation schemes could lead to potential indirect effects on European Sites through an increased demand for natural gas and resultant VRT and motor tax treatment to recognise low environmental effects in terms of requirement for re- emission HGVs. fuelling infrastructure and emissions to air. See Section 6.4.2 ‘Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure ’ and ‘Emissions to Air as a Result of Indirectly Encouraging the Increased Use of Alternative Fuels’ for discussion and Chapter 7 which outlines mitigation. No direct potential likely significant effects to European Funding for innovation within the Irish transport Sites as this is a monetary measure with no specific target sector. identified.
A Green Transport Certificate for goods No direct potential likely significant effects to European transported using low carbon technology. Sites as this relates to a certification process. No direct potential likely significant effects to European Sites as this relates to incentivisation schemes. Support measures to encourage captive fleets, It is acknowledged that incentivisation schemes could lead maintained by local authorities and public to potential indirect likely significant effects on European bodies, to move to CNG vehicles, if suitable, by Sites through an increased demand for natural gas and 2030. resultant environmental effects in terms of requirement for re-fuelling infrastructure and emissions to air. See Section 6.4.2 ‘Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure ’
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Policy Measures Impact Assessment and Mitigation and ‘Emissions to Air as a Result of Indirectly Encouraging the Increased Use of Alternative Fuels’ for discussion and Chapter 7 which outlines mitigation. No direct potential likely significant effects to European Sites as this relates to information gathering that will Market analysis will be undertaken in relation to inform future decision making. demand for LNG (and related refuelling Although market analysis in itself is not an issue, there infrastructure) along the TEN-T corridor, to exists a potential for indirect effects on European Sites include the motorway between Dublin and Cork from construction of re-fuelling infrastructure. and the associated ports of Dublin, Cork and See Section 6.4.2 ‘Construction, Upgrade and/or Shannon Foynes. Market analysis of demand for Operation of Alternative Fuels Re-fuelling Infrastructure’ LNG at TEN-T Comprehensive Ports should also for discussion in relation to the potential likely significant be included. effects in relation to construction of re-fuelling infrastructure, investigative and feasibility studies and Chapter 7 which outlines mitigation.
6.4.1.2 Assessment of Policy Measures to Support Uptake of Hydrogen
Hydrogen is harnessed for use in transport by fuel cell technology which utilises hydrogen to produce electricity without combustion. In the next few years, a number of major car manufacturers, are planning to start mass-production of fuel cell electric vehicles (FCEVs). While FCEVs produce zero tailpipe emissions, they have most in common with the traditional internal combustion engine in terms of range and refuelling. A tank of hydrogen could support distances of approximately 500km with refuelling times in the order of 3 to 5 minutes. The suite of measures developed to support uptake of hydrogen are principally related to preparatory work to facilitate future uptake.
Table 6.8 Hydrogen Policy Measures by end 2020
Policy Measures Impact Assessment and Mitigation No direct potential likely significant effects to European Facilitate trials on fuel-cell propelled vehicles. Sites. As such, this is a trial that will help inform future decision making. No direct potential likely significant effects to European Sites as this relates to information gathering and feasibility study that will inform future decision making. Potential for indirect potential likely significant effects on European Sites if they are not considered at the earliest possible stage. Assess the feasibility of establishing a hydrogen refuelling network based on technological See Section 6.4.2 ‘Construction, Upgrade and/or development and market uptake. Operation of Alternative Fuels Re-fuelling Infrastructure’ and ‘Emissions to Air as a Result of Indirectly Encouraging the Increased Use of Alternative Fuels’ for discussion in relation to the potential likely significant effects in relation to investigative and feasibility studies and construction of re-fuelling infrastructure and Chapter 7 which outlines mitigation. Consider incentives for uptake of hydrogen, No direct potential likely significant effects to European including accelerated capital allowances to Sites as this relates to incentivisation schemes. It is
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Policy Measures Impact Assessment and Mitigation support investment in refuelling infrastructure. acknowledged that incentivisation schemes could lead to potential indirect effects on European Sites through an increased demand for hydrogen and resultant environmental effects in terms of requirement for re- fuelling infrastructure and emissions to air. See Section 6.4.2 ‘Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure’ and ‘Emissions to Air as a Result of Indirectly Encouraging the Increased Use of Alternative Fuels’ for discussion in relation to the potential likely significant effects in relation to construction of re-fuelling infrastructure and Chapter 7 which outlines mitigation.
6.4.1.3 Assessment of Policy Measures to Support Uptake of LPG
Liquefied Petroleum Gas (LPG) is the most widely-used alternative automotive fuel in Europe, fuelling more than 6 million vehicles, mainly passenger cars and buses. LPG is also widely used as a clean fuel for indoor vehicles such as forklift trucks. Due to the flexibility of its supply chain, LPG can be used in remote areas and as a back-up energy for intermittent renewables such as photovoltaic, 10 solar-thermal, wind and small hydro. Tests have shown that LPG autogas produces 20% less in CO 2 emissions when compared with an equivalent petrol vehicle and can have up to a 10% advantage over an equivalent diesel. It is also cleaner than diesel from the perspective of particulates, sulphur
content and NO x. The suite of measures developed to support uptake of LPG are principally related to incentivising uptake in the commercial sector.
Table 6.9 LPG Future Policy Measures to be considered by end 2018
Policy Measures to be considered by end 2018 Impact Assessment and Mitigation No direct potential likely significant effects to European Sites as this relates to incentivisation schemes. It is acknowledged that incentivisation schemes could lead to potential indirect likely significant effects on European Secure commitment to maintain or reduce Sites through an increased demand for LPG and resultant excise duty rates for a prolonged period environmental effects in terms of requirement for re- (minimum 8 years), taking account of excise fuelling infrastructure and emissions to air. levels on other alternative fuels, providing certainty to the market for LPG. See Section 6.4.2 ‘Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure ’ and ‘Emissions to Air as a Result of Indirectly Encouraging the Increased Use of Alternative Fuels’ for discussion and Chapter 7 which outlines mitigation. Introduce Accelerated Capital Allowance (ACA) No direct potential likely significant effects to European tax incentive for companies with the aim of Sites as this relates to incentivisation schemes. encouraging investment in refuelling It is acknowledged that incentivisation schemes could lead infrastructure and equipment for LPG. The ACA to potential indirect likely significant effects on European would allow companies to write off 100% of the Sites through an increased demand for LPG and resultant purchase value of qualifying refuelling environmental effects in terms of requirement for re- equipment against their profit in the year of fuelling infrastructure and emissions to air.
10 European Liquid Petroleum Gas Association - http://www.primagas.cz/media/tinyManager/files/48.pdf
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Policy Measures to be considered by end 2018 Impact Assessment and Mitigation purchase. See Section 6.4.2 ‘Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure ’ and ‘Emissions to Air as a Result of Indirectly Encouraging the Increased Use of Alternative Fuels’ for discussion and Chapter 7 which outlines mitigation. No direct potential likely significant effects to European Examine Vehicle Registration Tax (VRT) rates on Sites as this relates to the examination of the current factory fitted LPG fuelled vehicles. baseline.
6.4.1.4 Assessment of Policy Measures to Support Uptake of Synthetic and Paraffinic Fuels
Synthetic and paraffinic fuels can contribute to the improvement of air quality and reduction in CO 2 emissions (depending on fuel type, composition and processing). These fuels do not need new infrastructure since they are blended (25-100%) to traditional fuels. Synthetic fuels can be made from different range of resources: natural gas, biomass, coal, plastic or hydrotreated vegetable oil (HVO). Paraffinic fuels are clean, high quality diesel fuels made from a wide variety of feedstocks, namely BTL (biomass to liquid), GTL (gas to liquid), and HVO (Hydrotreated Vegetable Oil). The measures proposed to support uptake of synthetic and paraffinic fuels are principally related to investigative work to facilitate future uptake.
Table 6.10 Synthetic and Paraffinic Fuels Policy Measures
Policy Measures Impact Assessment and Mitigation No direct potential likely significant effects to European Facilitate trials, as required, on synthetic fuels in Sites. As such, this is a trial that will help inform future public transport vehicles (bus and rail). decision making. Analyse need for financial incentive to support No direct potential likely significant effects to European greater use of synthetic and paraffinic fuels. Sites as this relates to information gathering.
6.4.1.5 Assessment of Other Measures Aimed at Accelerating the Move to Low Emissions Vehicles
A number of other measures are included to accelerate the move to low emission vehicles. These include changes to taxation as well as improved education and awareness of the benefits of alternative fuels and the geographic spread of supporting infrastructure.
Table 6.11 Policy Measures to Support Move to Low Emissions Vehicles
Policy Measures Impact Assessment and Mitigation Taxation Measures to be implemented by end of 2017 No direct potential likely significant effects to European Commitment made in Budget 2017 to retain the Sites as this relates to incentivisation. preferential VRT rates for EVs for a new period It is acknowledged that incentivisation could lead to of 5 years and for PHEVs for 2 years. potential indirect likely significant effects on European Sites through an increased demand for electricity and resultant environmental effects in terms of land use and
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Policy Measures Impact Assessment and Mitigation emissions to air dependent on the method of electricity generation used, albeit licensed and permitted in accordance with the appropriate planning and environmental legislation and regulatory processes. See Section 6.4.2 ‘Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure’ for discussion and Chapter 7 which outlines mitigation. Possible Taxation measures by end 2020 No direct potential likely significant effects to European Sites as this relates to incentivisation schemes. The taxation measures, which are to be considered, and could play a key role in It is acknowledged that incentivisation schemes could lead supporting the transition to a low carbon to potential indirect likely significant effects on European transport system include: Sites through an increased demand for alternative fuels and resultant environmental effects in terms of • Retention of a preferential VRT and motor requirement for re-fuelling infrastructure, indirect land tax regime for the lowest carbon vehicles. use changes for electricity generation facilities and feedstock and emissions to air. • Reviewing the VRT and motor tax regime for See Section 6.4.2 for discussion in relation to the potential light good vehicles (LGVs). likely significant effects in relation to construction of re- • Updating and implementing benefit-in-kind fuelling infrastructure and land use changes and emissions taxation for LEVs. to air, and Chapter 7 which outlines mitigation.
• Rebalancing of excise duty. It is also acknowledged that this measure could have indirect positive effects on European Sites by removing the • VAT rebate for petrol (including hybrids). preference for diesel usage due to the price differential, • Removal of Diesel Rebate Scheme. and hence reducing emissions to air from diesel and a shift towards petrol and alternative fuels, which would result in an overall net positive in terms of air quality. Possible Promotional Campaigns by end 2020 - Advertising Develop a media campaign that will reflect the benefits of alternative fuels (e.g. smoother drive, No direct potential likely significant effects to European low noise, positive image). Sites as this relates to provision of information.
Develop a media campaign that will provide No direct potential likely significant effects to European information on the vehicles/infrastructure Sites as this relates to provision of information. available.
Possible Promotional Campaigns by end 2020 - Information Review user-friendliness of existing online data on recharging infrastructure, such as the ecar No direct potential likely significant effects to European interactive mapping tool. Sites as this relates to provision of information.
Develop online tool for accessing information on No direct potential likely significant effects to European refuelling stations for CNG. Sites as this relates to provision of information. Develop a cost comparator that will provide the capability to examine the total cost of vehicle No direct potential likely significant effects to European ownership across a range of alternative fuels Sites as this relates to provision of information. (from 2020 onwards).
Develop a campaign targeted at dealerships. No direct potential likely significant effects to European Sites as this relates to provision of information. Awareness raising - targeted at fleet managers No direct potential likely significant effects to European
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Policy Measures Impact Assessment and Mitigation (private and public) e.g. workshops. Sites as this relates to provision of information. Regulation Keep abreast of international developments in regulation aimed at curbing emissions in national vehicle fleets, particularly any proposals No direct potential likely significant effects to European aimed at limiting the sale of vehicles which are Sites as this relates to provision of information. not zero emissions capable. Review any emerging regulations for application in Irish context.
6.4.2 Discussion of Key Issues Associated with the Implementation of the AFF
As discussed in Section 6.3.3 , there are three key issues associated with the implementation of the AFF. These are discussed under their relevant headings below.
Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure
Installation of refuelling infrastructure has the potential for likely significant effects on European Sites arising from the construction and operation of same. The main effects on European Sites associated with this would be:
° Direct habitat loss of European Sites if infrastructure was constructed within the Sites; ° Direct or indirect habitat fragmentation through loss of small patches of habitat within a larger European Site if infrastructure was sited within the Sites. This could also arise from loss of ecological corridors and connectivity, outside of European Sites but which support the functioning of the European Sites, such as loss of hedgerows, treelines or small wetlands through clearance of sites to construct alternative fuel infrastructure. ° Indirect disturbance to QI/SCI habitats and/or species of European Sites located in the vicinity during construction and operation of the infrastructure e.g. via noise or human disturbance. ° Impacts on water quality both ex-situ and in-situ arising from construction works, such as sedimentation and release of pollutants from contaminated land which could impact water dependent habitats and species. This is also relevant to operation of the alternative fuel infrastructure, for example surface water run-off posing a threat to water quality.
Electricity: Infrastructure for electric vehicles (EVs) is already established in Ireland, with the Electricity Supply Board (ESB) having rolled out ecars in 2010 including the supporting charging infrastructure. This was further expanded on in 2013 via a cross border project to expand the fast (rapid) charge network.
The AFF (Chapter 7, Table 7) illustrates the national targets for EV recharging points up to 2030. The increase in the number of recharging points required is relatively low overall due to the existing recharging network, with the exception of private recharging points. The AFF states that a large proportion of residents in Ireland have access to driveways and private car parking spaces capable of installing private chargers, thus reducing overall demand on the public charging network. As such, as this infrastructure would be located within existing developments (i.e. residential dwellings), there would be limited potential for likely significant effects on European Sites. However, as there is no
MDR1224Rp005F01 41 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport explicit geographic context outlined in the AFF there remains a potential (albeit slight) for likely significant effect on European Sites.
Shore-side electricity infrastructure is highlighted in the AFF in relation to TEN-T ports of Dublin, Cork and Shannon-Foynes. Shannon-Foynes is located within two European Sites (Lower River Shannon SAC and River Shannon and River Fergus Estuaries SPA), with Dublin and Cork ports and/or shipping lanes located adjacent to or adjoining a number of European Sites (including South Dublin Bay and River Tolka Estuary SPA, North Bull Island SPA, North Dublin Bay SAC, South Dublin Bay SAC, Cork Harbour SPA and Great Island Channel SAC). Therefore there is potential for likely significant effects on European Sites as a result of installing shore-side electricity infrastructure such as direct habitat loss or disturbance to QI/SCI species during construction/operation. Cumulative effects with existing port operations is also a potential for likely significant effects.
Natural Gas (CNG and LNG): It is anticipated that natural gas will form an interim solution as an alternative fuel for larger vehicles i.e. freight and buses. There is no LNG terminal in Ireland [although planning permission was granted previously for Shannon LNG in the Shannon Estuary] therefore LNG would have to be imported into Ireland via truck or shuttle carrier, with the nearest LNG terminal located in Milford Haven, UK. LNG is not used in heavy goods vehicles in Ireland. There are no LNG projects planned for TEN-T ports and LNG is not likely to form a large part of the fuel mix for road transport in Ireland going forward and as such no targets have been set in the AFF for numbers of LNG vehicles.
The target for numbers of CNG refuelling stations up to 2030 is outlined in Chapter 7, Table 8 of the AFF. The target for the numbers of CNG refuelling stations to be rolled out by 2030 is relatively low when considered on a national scale. This is to facilitate a ‘skeleton’ refuelling network across the country. As a separate project, GNI as part of a CER supported initiative, is to build three new CNG refuelling stations in 2016. The Alternative Fuels Infrastructure Directive requires a minimum number of CNG stations to be located in strategic urban and suburban locations, with a total of 70 fast fill stations to be deployed nationwide by 2025. As there is no explicit geographic context outlined in the AFF there is potential for direct and indirect likely significant effects on European Sites as a result of construction and operation of the re-fuelling infrastructure.
LPG: Table 2 in Chapter 5 of the AFF outlines that there are approximately 1,500 LPG vehicles circulating in the Republic of Ireland at present. However, LPG does not offer a long term solution in terms of emissions reductions and decarbonisation. Although the AFF supports LPG propelled vehicles, it does not require targets for LPG infrastructure to be set. As such there is no direct potential likely significant effect on European Sites as a result of construction/operation of LPG re- fuelling infrastructure.
Hydrogen: Hydrogen is not expected to deliver mass market uptake up to 2030 as refuelling infrastructure and vehicles remain prohibitively expensive when compared to the demand. Ireland is therefore not planning to establish a hydrogen refuelling network at present. Therefore, there is no direct potential likely significant effect on European Sites as a result of construction/operation of hydrogen re-fuelling infrastructure.
Biofuels: Biofuels are currently in use in Ireland through the Biofuel Obligation Scheme (BOS). The scheme places an obligation on all suppliers of mineral oil to ensure that a proportion of the motor fuels (petrol or diesel) that they place on the market in Ireland is sourced from renewable sources e.g. bioethanol or biodiesel. The Energy (Biofuel Obligation and Miscellaneous Provisions) Act 2010 gives effect to the BOS. The obligation has increased from an initial 4% (by volume) to 6% in 2013 and the National Oil Reserves Agency Act 2007 (Biofuel Obligation Rate) Order 2016 increased the
MDR1224Rp005F01 42 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport obligation to 8%, effective from 1 st January 2017. This will drive a continued increase in the biofuel obligation to reach 10% by 2020. As policy on biofuels is already addressed through the implementation of the Renewable Energy Directive and Fuel Quality Directive, with the BOS acting as the mechanism by which a progressive increase in usage will be facilitated, no targets are being set out in the AFF in relation to refuelling infrastructure for biofuels. Also, as these fuels are currently within the fuel mix and utilise the existing petrol/diesel refuelling infrastructure no targets have been set for refuelling infrastructure. Therefore, there is no potential likely significant effect on European Sites as a result of construction/operation of biofuel re-fuelling infrastructure.
Synthetic and Paraffinic Fuels: Although the use of these fuels is supported by the AFF, no infrastructure is required. It is most likely that the fuels will be blended into diesel supplies and, similar to that of biofuels, the existing petrol/diesel refuelling infrastructure will be utilised for refuelling. Therefore, there is no potential likely significant effect on European Sites as a result of construction/operation of re-fuelling infrastructure.
Land Use Changes as a Result of Indirectly Encouraging the Increased Use of Alternative Fuels
It is acknowledged that incentivisation schemes could lead to indirect likely significant effects on European Sites through an increased demand for alternative fuels. This could lead to an increased demand for electricity generation facilities or land required for alternative fuel feedstock and resultant effects on European Sites dependent on the alternative fuel concerned. This is particularly relevant in relation to electricity, biofuels and synthetic and paraffinic fuels 11 . As such these are the only alternative fuels considered in this section.
Electricity generation plants in Ireland are powered by a number of materials including peat, coal, oil, natural gas and biomass. Currently there are 4 main electricity generation stations that utilise solid fuels in Ireland. Three of these stations - Edenderry, Lough Ree (Lanesborough) and Shannonbridge – are peat-fired power plants. The fourth, at Moneypoint, is a coal-fired plant. The Edenderry Power Station in Offaly is owned by Bord na Móna and co-fires with a mixture of peat and biomass. Volumes have increased year-on-year with just over 1,000,000 tonnes of peat and biomass co-fired in 2015, of which 320,000 was biomass. The stations at Lough Ree and Shannonbridge are owned by ESB Group. Almost 890,000 tonnes were combusted at Lough Ree in 2015, which was a 9% increase on the previous year. More than 1.2 million tonnes of peat were combusted at Shannonbridge in 2015, which was an 8% increase on 2014. At Moneypoint, almost 1.9 million tonnes of coal was combusted in 2015, which was a 21% increase on 2014.
Extraction and production of these materials in itself can result in habitat loss/land use changes. In the case of peat extraction, this can directly impact on Annex I peatland habitat types, as defined by the Habitats Directive, both within and outside of European Sites. Biomass production can change land use and has the potential to result in a range of likely significant effects on European Sites such as habitat loss/fragmentation to grow crops and habitat deterioration as a result of water quality changes from run-off of fertilisers or sediment run-off into nearby watercourses impacting downstream European Sites.
Construction of electricity generation facilities can result in likely significant effects on European Sites through land use change, similar to those outlined under ‘Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure ’ previously in Section 6.4.2 . An increased demand on electricity resulting in a requirement for more electricity generation facilities to be
11 which can be produced from biomass
MDR1224Rp005F01 43 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport constructed across the country also has the potential for cumulative likely significant effects on European Sites. As Ireland transitions to decarbonising the electricity generation sector there will be an increased reliance on renewable electricity infrastructure.
Renewable electricity infrastructure, such as wind farms and hydro power facilities, can result in likely significant effects on European Sites through land use change, similar to those outlined in ‘Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure ’ previously in Section 6.4.2 . For example, many wind farm sites are located in upland areas of peatland/heathland, which can correspond to Annex I habitats types within and outside of European Sites, resulting in habitat loss. Construction and operation of these sites can also lead to habitat deterioration for example through machinery access, surface water run-off changes resulting in erosion or increased exposure of habitats as a result of vegetation disturbance. During operation, wind farms can have direct impacts on species including SPA birds through collision with turbines resulting in mortality and ex-situ effects by creating barriers to movement such as altering migratory routes of SPA birds to avoid wind farms (which in turn could result in decreased survival rates of the birds on migration due to increased expenditure of energy). There is a body of evidence in relation to impacts on sensitive species, such as hen harrier and some bat species from the provision of renewable wind infrastructure in sensitive habitats. Similarly other renewable electricity infrastructure such as hydro power and tidal power can result in direct impacts to European Sites through habitat loss as they may be located within rivers/estuaries designated as SACs or may result in direct mortality of QI species such as fish as a result of collision with infrastructure e.g. turbines, and can create barriers to movement hindering migration of species such as fish species or marine mammals. Therefore there is potential for indirect likely significant effects on European Sites as a result of the AFF.
Emissions to Air as a Result of Indirectly Encouraging the Increased Use of Alternative Fuels
In terms of increasing the use of alternative fuels one of the main indirect potential likely significant effects with regard to European Sites is the emissions to air. Each fuel type has varying emissions characteristics dependent on the method of generation of the fuel and also on combustion. A summary of the main characteristics of emissions to air from each alternative fuel type is presented in Table 6.12.
Table 6.12 Air Emission Characteristics for Alternative Fuels
Alternative Direct Emissions Indirect Emissions Comparison to Petrol/Diesel Fuel (from combustion) (from generation) Dependent on fuel type used in From power generation powergen sector. If renewable sector: sources used (e.g. wind, hyrdo), zero Fossil fuel burning to emissions. If peat, coal, gas etc. used Electricity 12 N/A generate electricity emits emission levels are similar but not
NO x, SO x, CO, CO 2 and proportional (i.e. net reduction in PM10. emissions). At 10% usage of EV's, net
reduction in CO 2. Production is energy Water vapour, warm Reduced PM, NO , SO , VOC's, Hydrogen intensive. A number of x x air, hydrogen gas. methods of generation can hydrocarbons, CO, CO 2, PAH's, etc. be used and emissions
12 Brady and O’Mahony, (2011).
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Alternative Direct Emissions Indirect Emissions Comparison to Petrol/Diesel Fuel (from combustion) (from generation) would vary accordingly. Production - land use Increased NOx emissions and change (decreased carbon acetaldehyde and formaldehyde (for sinks). Use/Transport - PM, VOC's, PAH's, NO , E85*). 79% reduction in carbon Biofuels 13 x imported biofuels and CO, hydrocarbons intensity. E10 has higher NO feedstock and transporting x emissions than E0 gasoline. Reduced biofuels internally (CO 2 benzene and PM emissions. emissions). Higher cetane number so lower emissions and free from sulphur. Reduced emissions of benzene and toluene. Lower NO , SO and Typical hydrocarbon From commercial x x Synthetic and decreased PM levels. CO emissions emissions (i.e. similar manufacture (i.e. energy 2 Parrafinic can be 40-90% lower than to petrol and diesel): production to power Fuels 14 petrol/diesel CO emissions. Road NO , CO, CO , SO , PM processing of feedstock). 2 x 2 2 studies showed 40% less PM, 20%
less NO x, up to 60% less HC (hydrocarbons) and up to 75% less CO (carbon monoxide). Extraction leakages - Natural Gas CNG has similar emissions to petrol, methane (CH ) leaks at (LNG and NO , CO , CO 4 but slightly lower PM. Compared to x 2 extraction points. CNG) 15 diesel lower NO and PM than diesel. Importation of fuel. x Higher CO compared to diesel* but lower NOx, and PM than diesel. Typical hydrocarbon Lower CO and NOx than petrol. Liquid combustion emissions Lower PM emissions. ( Note : LPG has Petroleum Gas (NOx, CO, CO , SO , Importation of fuel 2 2 higher GHG emissions than LNG and (LPG) 16 CH , N O etc) but less 4 2 CNG). (*contradictory study showed PM. 8% lower CO emissions compared to diesel).
Overall (Table 6.12) it can be seen that in comparison to petrol and diesel run vehicles, alternative fuel run vehicles would result in a net positive in terms of emissions to air. With reference to the targets of the AFF, the main issues in relation to emissions to air associated with each alternative fuel type are discussed below.
Electricity: EVs use electricity stored in a battery pack to power an electric motor. Therefore there are no direct tailpipe emissions to air from the EVs themselves, and hence no potential likely significant effects on European Sites from the use of EVs. On comparison with petrol/diesel fuelled vehicles, which accounts for the primary fuel source for vehicles in Ireland currently, EVs would be considered to have a positive impact on European Sites. This is mainly with reference to a reduction in combustion related gases (e.g. NO x, CO, CO 2) and PM.
13 Niven, (2005). 14 ASFE, (2016a & 2016b). 15 Cathles, L. M., (2012). 16 USEPA, 1995; Raslavičius, et. al. (2014).
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However, there exists a potential for indirect potential likely significant effects on European Sites dependent on the method of electricity generation used. Table 6.13 is taken from the SEAI “ Energy in Ireland 1990 - 2014 ” (SEAI, 2015) and outlines the primary energy inputs for fuel generation. Also listed in the table are selected Tier 1 emission factors from the European Environment Agency “EMEP/EEA air pollutant emission inventory guidebook – 2016” (Sector 1.A.1 Energy Industries). These emission factors are European aggregates but are used here as an illustration of the extent of emission of combustion gases associated with each fuel used for electricity generation.
Table 6.13 Primary Fuel Inputs for Electricity Generation 2014 and EEA Tier 1 Emission Factor
Total Primary NO x SO x PM 10 Fuel Energy Share 2014 (ktoe) (g/GJ) (g/GJ) (g/GJ) Peat (Brown Coal) 550 247 1,680 7.9 Coal (Hard Coal) 942 209 820 7.7 Natural Gas 1,973 89 0.281 0.89 Oil 60 142 495 25.2 Wind 442 0 0 0 Hydro 61 0 0 0 Other Renewables* 128 81 10.8 155 Electricity Imports 185 Not specified *Emission Factors listed for “Other Renewables” only relate to biomass. It is unknown what proportion of “Other Renewables” relates to biomass.
It can be seen from Table 6.13 that Ireland is currently reliant on fossil fuels for electricity generation with a small proportion of the generation arising from renewable sources; peat (13%), coal (22%), natural gas (45%), oil (1%), wind (10%), hydro (1%), other renewables (3%), electricity imports (4%). The emission factors outlined in the table above illustrate how each source of power compares in terms of emissions to air when combusted and shows that peat has the highest emissions to air followed by coal, oil and natural gas. Biomass has a mixed performance relative to the fossil fuels but emits more PM than any of these fuels.
As referenced above, there are four main electricity generation stations in Ireland that utilise solid fuels. Three of these stations - Edenderry, Lough Ree (Lanesborough) and Shannonbridge – are peat- fired power plants. The fourth, at Moneypoint, is a coal-fired plant. The Edenderry Power Station in Offaly is owned by Bord na Móna and co-fires with a mixture of peat and biomass. By using these sources of fuel to generate the electricity for EVs, there is a potential indirect negative impact on European Sites as a result of ongoing air emissions [albeit controlled by license requirements placed on these energy generators]. This potential for impact will continue in the short-medium term until the mix of fuel sources shifts away from fossil fuels toward renewable sources.
The source/production of the feedstock for power generation must also be considered. For example, biomass production in itself has the potential to result in a range of likely significant effects on European Sites such as habitat loss/fragmentation to grow crops and water quality changes as a result of run-off of fertilisers or sediment run-off into nearby watercourses impacting downstream European Sites. The method by which the biomass fuel is then transported to the electricity generation facility, and distance over which it must be transported can also have resultant likely significant effects on European Sites e.g. emissions to air. It is also widely accepted that peatlands
MDR1224Rp005F01 46 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport act as effective long term carbon sinks and therefore loss of peatlands sites can result in liberation of
CO 2 into the atmosphere.
In effect, although EVs represent a positive step in decarbonising transport, the source of the electricity generation to service an increased demand for electricity as a result of increased numbers of EVs in the national fleet has the potential for likely significant effects on European Sites.
Natural Gas (CNG and LNG): Combustion of natural gas can lead to emissions of CO, CO 2, NO x and PM, however, on comparison with the current diesel and petrol fleet there would be a resultant net positive in terms of reduction in emissions. The introduction of biogas, produced from anaerobic digestion or landfill gas, blended into CNG or on its own would also result in a net positive especially in terms of emissions to air. A biomethane and CNG blend can improve the emissions profile of the CNG.
LNG has to be imported to Ireland, with the nearest LNG facility being in the UK, therefore there are associated emissions from the transport of LNG via land or sea. LNG would be envisaged to potentially support maritime ports and heavy goods vehicles in the future. However, at present it is not an entirely feasible option and targets for LNG infrastructure are not being set as part of the AFF, therefore there will be no resultant indirect emissions.
Hydrogen: Production of hydrogen is an energy intensive process with a number of methods used in its production e.g. natural gas reforming which generates CO 2 and electrolysis of water. Therefore the extent of the emissions from the generation process is dependent on the method used, and the power source to source that generation process e.g. electricity generated by fossil fuel versus renewable sources.
There are no direct tail pipe emissions from hydrogen powered vehicles except water vapour and warm air. If there was a national fleet of hydrogen vehicles it could have the potential to emit amounts of water vapour large enough to affect local or regional distribution of water vapour. There could be potential to affect local or regional humidity levels which could lead to changes in temperate and precipitation patterns which in turn could have likely significant effects on QI/SCI habitats and species of European Sites. Pielke et al . (2003) urge that careful calculations be made to ensure we don't trade one problem for another in terms of diesel/petrol emissions to water vapour emission, but Keith and Farrell (2003) assert the effects of water vapour will be insignificant, since they are not emitted in the stratosphere. The AFF is not promoting hydrogen production plants or hydrogen as a fuel type up to 2030 so as such it is not a concern for the current plan. However, the AFF does support feasibility studies into establishing a hydrogen re-fuelling network. Therefore, there exists potential for likely significant effects on European Sites.
Biofuels: The AFF does not outline any policies/targets in relation to the uptake of biofuels. This has already been addressed through the implementation of the Renewable Energy Directive and the Fuel Quality Directive and is facilitated through the BOS. The Bioenergy Plan is currently in preparation and will also support this. Therefore, there is no potential for likely significant effects on European Sites as a result of the AFF in relation to biofuels.
LPG: The production and availability of LPG is increasingly becoming worldwide, and there are large storage facilities available in the UK and Europe. LPG is imported into Ireland for use, and distributed by tankers across Ireland, therefore there are associated emissions from the transport of LPG via land and sea. Combustion of LPG leads to emissions of combustion gases similar to that of
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petrol/diesel combustion such as CO, CO 2, NO x and to a lesser extent PM. The extent of emissions depends on the volatility of the LPG coupled with the efficiency of the engine. However, on comparison with the current diesel and petrol fleet there would be a resultant net positive in terms of reduction in emission.
Synthetic and Paraffinic Fuels: Synthetic and paraffinic fuel production and usage is in its infancy in Ireland. Synthetic fuel can be produced from a range of resources including natural gas, biomass, coal, plastic and hydrogenated vegetable oil. Paraffinic fuels are also made from a wide variety of feedstocks, namely biomass to liquid, gas to liquid and hydrogenated vegetable oil. Emissions as a result of generation and combustion of these fuels will greatly depend on the process applied and feedstock used. They are blended with petrol and diesel and therefore will emit similar combustion gases to that of petrol and diesel. However, they burn more efficiently, have a low sulphur content
and lack of aromatic content resulting in lower emissions of SO 2, NO x, CO 2 and PM compared to petrol and diesel. On comparison with the current diesel and petrol fleet there would be a resultant net positive in terms of reduction in emissions associated with these fuels.
A number of the potential likely significant effects on European Sites as a result of emissions to air by alternative fuels are discussed below. Studies focusing on the impact of alternative fuel emissions on habitats and species protected under the Habitats Directive are limited, especially in Ireland. A number of studies have been carried out in the UK and other European countries which have been consulted in place of Irish studies, owing to the fact that the countries share many common habitats as listed on the Habitats Directive, have similar annual environmental conditions and currently have and are expected to adopt similar alternative fuel usage in line with EU Directive 2014/94/EU on the deployment of alternative fuels infrastructure.
The key effects on European Sites associated with fuel combustion are; nitrogen/sulphur deposition leading to acidification and eutrophication of soils/water, deposition of particulate matter leading to
vegetation damage and increased atmospheric CO and CO 2 accelerating climate change.
A number of habitats have been studied for impacts on biodiversity resulting from air quality impacts and are summarised in Table 6.14.
Table 6.14 Habitats experiencing a decline in biodiversity as a result of air pollution (Adapted from NRA, 2011)
Links with Annex I habitat Habitat Impact on Biodiversity Cause occurring in Ireland Increased survival of harmful Homology with Nitrogen Temperate and boreal exotic pests and diseases and temperature woodlands deposition @ CL forests changes in ground vegetation (91A0, 91D0, 91E0 & 91J0) 10-20 kgN/ha/yr and mycorrhiza Possible homology with Nitrogen Artic, alpine and Decline in lichens, mosses and Alpine and Boreal heath deposition @ CL subalpine scrub evergreen shrubs* (4060) 5-15 kgN/ha/yr "U" Calluna dominated Decreased heather Nitrogen Wet heath ( Calluna wet heath (upland dominance, decline in lichens deposition @ CL dominated) (3160) moorland) and mosses 10-20 kgN/ha/yr Nitrogen "L" Erica tetralix Wet heath ( Erica tetralix Transition from heather to deposition @ CL dominated wet heath dominated) (3160) grasses (i.e. loss of species) 10-25 kgN/ha/yr
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Links with Annex I habitat Habitat Impact on Biodiversity Cause occurring in Ireland Nitrogen Transition from heather to Dry heaths Dry heath (4030) deposition @ CL grasses and decline in lichens 10-20 kgN/ha/yr Heath ( Juncus ) Nitrogen Species-rich Nardus Decrease in bryophytes and meadows and humic deposition @ CL upland grassland (6230) decreased diversity* (Nardus stricta ) swards 10-20 kgN/ha/yr Fixed dunes (grey dunes) (2130) Nitrogen Inland dune siliceous Increase in tall grasses and Dune slack (2190) deposition @ CL grasslands decrease in diversity* Dunes with creeping 20-30 kgN/ha/yr willow (2170) Embryonic shifting dunes Nitrogen Inland dune pioneer (2110) Decrease in lichens* deposition @ CL grasslands Marram dunes (white 10-20 kgN/ha/yr dunes) (2120) Nitrogen Molinia caerulea Decrease of bryophytes and Molinia meadows (6410) deposition @ CL meadows decreased diversity* 15-25 kgN/ha/yr Decrease of characteristic Nitrogen Alkaline fens (7230) Rich fens mosses and decrease in deposition @ CL Cladium fen (7210) diversity* 15-35 kgN/ha/yr * Expert Opinion
Atmospheric deposition of sulphur and nitrogen compounds causes acidification of soil and surface waters. It has also been found that particulate matter (PM) deposition can result in acidification of soils (Bhattacharjee, et al ., 1999). In 2010, 7% of land area in the EU-28 (28 EU Member States) exceeded acidification critical loads and this is projected to decrease to 4% by 2020 (EEA, 2015c). Deposition of sulphur and nitrogen compounds also causes eutrophication of freshwater and saltwater systems (EEA, 2015c).
A European workshop was conducted between the EU member states in 2009 to assess the impacts of nitrogen deposition on the Natura 2000 network of sites (Bell, 2013). The main findings/outcomes of the workshop were:
° Nitrogen deposition is a “ major threat to European biodiversity, including sensitive habitats listed under the Habitats Directive ”; ° The magnitude of the threat to European biodiversity is owning to the naturally occurring low nitrogen supply within many of the Annex I habitats. Therefore fertilisation by increased nitrogen deposition alters the nutrient balance and results in the loss of the most sensitive species and their replacement by invasive species; ° Nitrogen deposition results in a net loss of overall numbers of species; ° Exceedance of critical loads for nitrogen is widespread across Europe and there is strong evidence (field and experimental) of the associated impacts.
Nitrogen deposition, as a result of NO x emissions, causes many alterations to vegetation communities. It has been found that the number of species at risk within acidic and calcareous grasslands increased at nitrogen deposition rates greater than 5-10 kg N ha-1 yr -1 (JNCC, 2011). Increases of up to 50% in canopy height at N-deposition rates of 45-50 kg N ha -1 yr -1 (Stevens, et a l., 2010) and an increase in the occurrence and abundance of competitive species have also been
MDR1224Rp005F01 49 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport documented (JNCC, 2011). The JNCC (2011) also found that increased N-deposition on calcareous grasslands resulted in decreased species richness, forb and bryophyte cover and an increase in grass cover. This results in an overall decline in biodiversity.
The European Environment Agency (EEA) highlight that NO x emissions contribute to the acidification of soil, lakes and rivers, causing loss of animal and plant life and biodiversity (EEA, 2015a). Similarly the EEA (2014) identified one of the main pressures on grassland ecosystem biodiversity was airborne nitrogen, amongst other pressures such as habitat fragmentation, conversion of land for biofuel crop and afforestation. Airborne nitrogen was identified to encourage the establishment of competitive species, favour species poor communities (i.e. reduced diversity) and reduce the structural density of grasslands through acidification and eutrophication.
Nitrogen deposition is known to be affecting acidic and calcareous grasslands, heathlands and bogs (JNCC, 2011). Past studies (Maskell, et al., 2010; Stevens, 2004; Stevens, et al ., 2010) of acid grasslands experiencing increased N-deposition showed a clear decline in species richness. This decline has been attributed to a reduction in the cover and occurrence of forb species (Dupré, et al ., 2010; Maskell, et al ., 2010) as a result of increased nitrogen inputs. Unlike acidic (and calcareous) grasslands, heathland showed both negative and positive relationships of canopy height with increased N-deposition. Therefore, these changes in canopy height are more likely to be due to site- specific factors. However, there is still a trend of increased grass cover and decreased forbs, lichens, bryophytes and shrub cover (JNCC, 2011) in response to elevated nitrogen. For bog habitats, “no evidence of impact” on indices of ecological function at N-deposition rates below 10 kg N ha -1 yr -1 was found. At 10-15 kg N ha -1 yr -1 and 15-20 kg N ha -1 yr -1 there is also no evidence of an increase in the occurrence of competitive plants or an increase in productivity (JNCC, 2011). This is likely due to the differing ‘natural’ concentrations of nitrogen in each of these habitats.
Payne, et al., (2014) showed that heather moorlands are impacted by nitrogen deposition, with air pollution by sulphur and nitrogen being correlated with lower species richness. A statistically significant negative relationship between total species richness and cumulative nitrogen deposition in all surveys (P<0.05) was found. It was concluded that acidification, rather than eutrophication, was the dominant driver of species composition change (Caporn, et al . 2014). Another study focusing on the impacts of N-deposition on Calluna Moorlands and Scottish Montane habitats was carried out. With increasing nitrogen deposition the species richness of bryophytes declined strongly in the Calluna Moorland Survey (CMS) and showed an increase (together with cover) in the Scottish Montane Survey (SMont). It is possible that the inconsistency between the CMS and SMont results was due to different ranges, as well as differing cumulative doses of N-deposition; the strongest decline in species richness in the CMS occurred at the highest levels of N deposition (RoTAP, 2012).
Forests and woodlands have long been identified as a habitat likely to be impacted by nitrogen deposition. Forest decline occurs as a result of acidification of soil (Ulrich, et al ., 1979) due to interception of atmospheric pollutants (such as those emitted from biomass combustion). The EEA have stated that acid deposition of S and N compounds played a significant role as “predisposing or contributing factors leading to the observed decline in trees” (EEA, 2014). Forest damage and decline, resulting in effects to the diversity of the ecosystem, has also been attributed to PM deposition (Rai, 2016).
Nitrogen addition experiments have been carried out across Europe (Bobbink, et al. , 2010; Nordin, et al ., 2011) in grasslands, wetlands, (sub) Arctic and alpine vegetation. A clear “ negative-log relationship between exceedance of empirical nitrogen critical loads and plant species richness ” has been found (Bobbink, et al., 2010). Exceedance of critical N-deposition loads has been linked to
MDR1224Rp005F01 50 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport reduced plant species richness and this trend can be seen occurring across a broad range of European ecosystems (Nordin, et al., 2011, Hicks, et al., 2011). The impacts of nitrogen deposition on biodiversity across a number of European habitats (some of which have links to habitats listed under the Habitats Directive) has been summarised in Table 6.15 (taken from Nordin, et al. (2011)).
Table 6.15 Examples of habitat changes as a result of nitrogen deposition for some European ecosystems (summary, adapted from Nordin, et al ., 2011).
Habitat Effect Decreased abundance of bryophytes and lichens and increased growth of Artic and Alpine ecosystems graminoids. Major changes in ground vegetation species composition but no decline in total plant species richness (i.e. decline in bryophyte, lichen and dwarf-shrub Boreal forest species but increase in graminoids and herbs). When combined with deforestation, N-induced impacts will be magnified. Initial increase in plant biomass/cover but an overall decrease in plant Temperate forest species richness and species evenness resulting in a loss of biodiversity. Heathlands: dwarf-shrub growth is increased but bryophyte and lichen growth declines. When heathland is subject to management or increased Temperate heathlands and herbivory, dwarf-shrub dominance declines and is succeeded by grass grasslands species. Grasslands: species loss (particularly, rare species) occurs. This is particularly visible in acid grasslands (UK). Increase in invasive grasses and resulting decline in species richness due to Mediterranean vegetation loss of native vegetation species. Major shifts in lichen communities occur also.
Emissions of PM can have many detrimental effects on vegetation (Beckett, et al., 1998; Rai, 2016). Rai (2016) stated that PM may adversely affect biodiversity, in particular urban forests. Alterations to the physical structure of vegetation have been found to occur as a result of PM deposition; a significant source of damage to trees, by PM pollution, can be the abrasive action of the turbulent deposition of the PM (Das, et al ., 2012; Hirano, et al ., 1995; Kulshreshtha, et al. , 1994). Kulshreshtha, et al. , (1994) showed this to have increased callus tissue formation on leaf surfaces. The increased deposition of atmospheric PM has also been shown to result in the occlusion of stomata, thereby decreasing the efficiency of gaseous exchange (Beckett, et al ., 1998; Das, et al ., 2012; Hirano, et al ., 1995). The formation of a ‘crust’ on leaves and bark surfaces has also been observed due to PM deposition, with the crust disrupting physiological processes, such as bud break, pollination and light absorption/reflectance (Beckett, et al., 1998). Although fine PM deposition has been found to provide nutrients to vegetation, it also changes leaf surface properties, increases the duration of surface wetness and can result in modification of the habitat for epiphytic organisms, which may lead to increased risks from pathogens (Cape, 2008; Manning and Feder, 1980; Shkaraba and Perevedentseva, 1991). Therefore, PM can result in likely significant effects to habitats and species within European Sites.
Several pollutants associated with alternative fuels emissions have a high global warming potential (GWP), such as carbon dioxide and nitrous oxide, whereas others act as precursors to greenhouse gases (GHGs). One such example is carbon monoxide (CO). When in the atmosphere CO reacts with - hydroxyl radicals (OH ) to form carbon dioxide (CO 2), which has a much higher GWP than CO. Along with this increase in CO 2, concentrations of atmospheric methane also increase when CO concentrations are elevated. This is due to the decreased levels of hydroxyl radicals for the methane
MDR1224Rp005F01 51 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport to react with, which would typically remove methane from the atmosphere (i.e. the formation of
CO 2 leaves fewer OH molecules in the atmosphere for methane to react with, thereby increasing methane’s concentration) (ESSEA, 2010). Along with CO, NO x emissions contribute indirectly to global warming. When CO and NO x emissions are elevated in the atmosphere, the photochemical oxidation of CO produces tropospheric ozone (O 3). Ozone has an extremely high GWP and therefore contributes to global warming (California Institute of Technology, 2016). Global warming and climate change are recognised threats to biodiversity and hence to European Sites and habitats and species therein.
6.5 ASSESSMENT OF IN COMBINATION EFFECTS WITH OTHER PLANS OR PROJECTS
The assessment of in-combination effects with other plans or projects is a crucial and often difficult aspect of Article 6(3) assessment, particularly at the plan level. This step aims to consider the policy and framework within which the AFF is being developed and to identify at this early stage any possible in-combination effects of the proposed AFF with other plans and projects. In theory, there are many other plans / projects that interact with or have the potential to combine pressures and threats to European Sites, however, the in-combination assessment is a matter of applying a practical and realistic approach.
In line with MN2000 guidance, a stepwise approach has been taken to consideration of in- combination effects as follows:
° Identify plans / projects that might act in combination; ° Identify the types of impact that might occur; ° Define boundaries of the assessment; ° Identify pathways for impact; and ° Impact prediction and assessment.
While the AFF sits within a larger planning framework and it focuses on alternative fuels usage and direct tailpipe emissions, there are other plans/programmes that deal with the source of the alternative fuels. Therefore the AFF must take account of other plans/programmes and vice versa. The plans considered to hold potential for in-combination effects (positive and negative) are further explored in Table 6.16.
The focus of in-combination impact assessment is directed towards plans where the cumulative impacts have the potential to magnify the impact upon European Sites and their constituent features of interest. Table 6.17 presents a brief summary of the effects arising out of the cumulative impact of principal environmental protection legislation.
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Table 6.16 In-Combination Impacts with Other Plans and Strategies
Plan Key Types of Impacts Potential for In-combination Effects and Mitigation
National Planning Framework ° Habitat loss or destruction; The plan will succeed the National Spatial ° Habitat fragmentation or The plan will be subject to AA but is not yet completed. The potential for in- Strategy. It will provide a framework for degradation; combination effects are unclear as the plan is not sufficiently developed at this national planning and will focus on economic ° Alterations to water quality stage, however, would be expected to be in relation to requirement for development and investment in housing, water and/or water movement; infrastructure. However, it is a policy of the AFF to ensure the National Planning services, transport, communications, energy, ° Alteration to air quality; Framework takes account of the AFF. health and education infrastructure. ° Disturbance. ° Habitat loss or destruction; National Mitigation Plan ° Habitat fragmentation or The primary objective of this plan will be to degradation; This plan is undergoing its own AA but it is not yet completed. The potential for monitor implementation of current measures ° Alterations to water quality in-combination effects are unclear as the plan is not sufficiently developed at this to 2020 and identify additional measures in the and/or water movement; stage, however, the thrust of the plan is positive and would not be expected to longer term to reduce greenhouse gas ° Alteration to air quality; conflict with any aspects of the AFF but to positively influence it going forward. emissions and progress the overall national low carbon transition agenda to 2050. ° Disturbance.
National Renewable Electricity Policy and This plan is undergoing its own AA but it is not yet completed. A key issue to be Development Framework addressed will be the method of renewable electricity generation and associated The main objective of this plan will be to guide ° Habitat loss or destruction; ecological impacts. The potential for in-combination effects are unclear as the the development of renewable electricity ° Habitat fragmentation or plan is not sufficiently developed at this stage, however, would be expected to projects to ensure Ireland meets its future degradation; be in relation to electricity generation infrastructure. However, the main thrust of the plan is positive and would not be expected to conflict with any aspects of needs for renewable electricity in a sustainable ° Alterations to water quality the AFF but to positively influence it going forward. manner. and/or water movement; The plan will have to take account of the demands of the AFF. ° Alteration to air quality; ° Disturbance.
Bioenergy Plan ° Habitat loss or destruction; The plan is undergoing its own AA but it is not yet completed. The potential for This plan will underpin the development of the ° Habitat fragmentation or in-combination effects is expected to be in relation to habitat loss and the sector in the period up to 2020 and lay degradation; associated ecological impacts. This plan would not be expected to conflict with
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Plan Key Types of Impacts Potential for In-combination Effects and Mitigation foundations for its longer term growth and in ° Alterations to water quality any aspects of the AFF but to positively influence/inform it going forward. contributing to renewable energy targets. and/or water movement; ° Alteration to air quality; ° Disturbance. National Renewable Energy Action Plan This plan was not subject to AA, but some actions arising out of it have since (NREAP) ° Habitat loss or destruction; been subject to AA owing to judicial review. The NREAP is produced as a requirement of the ° Habitat fragmentation or The plan is positive in that its aims are to accelerate the uptake on renewable Renewable Energy Directive, and sets out degradation; energy, thereby reducing the dependence on fossil fuels and reducing Ireland’s “ national targets for the share of ° Alterations to water quality; greenhouse gas emissions. Potential for in-combination effects are in relation to energy from renewable sources consumed in ° Alteration to air quality; habitat loss and the associated ecological impacts. The AFF will contribute to transport, electricity and heating and cooling in ° Disturbance reaching the targets set in the NREAP and as such the plans are complementary. 2020 .” National Climate Change Adaptation Framework 2012 The measures and research as a result of the plan will place a responsibility on all ° Habitat loss or destruction; stakeholders to adapt to the severe impacts of predicted climate change. This The framework provides strategic focus to ° Habitat fragmentation or framework prioritises reducing knowledge gaps through an evidence base and to ensure adaptation measures are taken across degradation. develop tools to support the adaptation decision-making process. The AFF will different sectors and levels of government to contribute towards the plan and as such no significant in-combination effects are reduce Ireland's vulnerability to the negative envisaged. impacts of climate change. Grid25 Implementation Programme 2011- 2016 This Plan was subject to AA. There is potential for in-combination effects with the The Grid25 Implementation Programme (IP) is ° Habitat loss or destruction; AFF in terms of infrastructure requirements resulting in habitat loss, a practical strategic overview of how the early ° Habitat fragmentation or fragmentation and degradation and the associated ecological impacts. No stages of Grid25 are intended to be degradation; significant in-combination impacts are envisaged at plan level. Projects/plans implemented. The IP identifies the best current ° Disturbance. arising from the AFF are required to undergo AA which will ensure no in- understanding of those parts of the combination effects further down the planning hierarchy. transmission system that are envisaged as likely to be developed over the next five years. Forests, Products and People. Ireland’s Forest ° Habitat loss or destruction; As a high level policy document, the forestry policy did not undergo AA. Policy - A Renewed Vision ° Habitat fragmentation or Forestry and afforestation are a key element in satisfying the requirement for Strategic goal is to develop an internationally degradation; biomass for electricity generation. There is potential for in-combination effects competitive and sustainable forest sector that ° Water quality changes; with the AFF in terms of potential habitat loss, fragmentation and degradation
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Plan Key Types of Impacts Potential for In-combination Effects and Mitigation provides a full range of economic, ° Disturbance to species. and the associated ecological impacts particularly on sensitive species such as environmental and social benefits to society Freshwater Pearl Mussel and Hen Harrier. To address negative effects of forestry: and which accords with the Forest Europe ° DAFM are currently developing Catchment Forest Management Plans for eight definition of sustainable forest management. priority FPM catchments which will contribute to protection of this particular species. ° The Forest Service’s Appropriate Assessment procedures will continue to be applied at project level. ° Also compliance with the procedures outlined in the updated Forest Service Forestry Schemes Manual underpins this Forestry Strategy. See also mitigation under National Forestry Programme below. The Forestry Programme was subject to its own AA. The programme includes a number of policies for the protection of habitats and species under the Birds and Habitats Directives including: Forestry Programme 2014-2020 ° Identifying whether Annex I habitats, Annex I Birds or Annex II species are Provides Ireland’s proposals for 100% state aid present in consultation with NPWS and if required, surveys to be carried out funding for a new Forestry Programme for the before works begin, particularly at sensitive times of year (e.g. breeding period. The measures proposed are consistent season). with “Forests, products and people Ireland’s ° Habitat loss or destruction; ° Forest Management Plan for Priority Freshwater Pearl Mussel Catchments forest policy – a renewed vision”. ° Habitat fragmentation or (Forest Service) shall be adhered to once published. There is also a The Programme identifies the needs of the degradation; requirement for protection of Freshwater Pearl Mussel catchments through Forestry sector as: ° Alterations to water quality riparian planting and converting coniferous to native woodlands under the ° Increase forest cover and/or water movement; Native Woodland Conservation Scheme. ° Increase the production of forest biomass to ° Disturbance. ° Individual forestry proposals will be subject to assessment of their potential meet renewable energy targets impacts prior to consent or licence through the Forest Service Appropriate ° Support forest holders to actively manage Assessment Procedure. their plantations ° Provide buffers for afforestation adjacent to areas of wetland Annex I habitats or other water habitats such as blanket mire. ° Avoid afforestation on high value sites with a high sensitivity in terms of water quality. No significant in-combination impacts are predicted. Rural Development Plan 2014-2020 ° Overgrazing; The Rural Development Plan was subject to its own AA.
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Plan Key Types of Impacts Potential for In-combination Effects and Mitigation Provides a new suite of rural development ° Land use change or The plan aims to enhance sustainable management of natural resources. measures designed to enhance the intensification; Incentives are included to address significant effects on biodiversity, water competitiveness of the agri-food sector, ° Water pollution; management and preventing soil erosion. Mitigation in the plan requires that achieve more sustainable management of Appropriate Assessment is to be carried out for all individual building, tourism or ° Nitrogen deposition; natural resources and ensure a more balanced agricultural reclamation projects, stakeholder engagement and site based development of rural areas. Includes ° Disturbance to habitats / species; monitoring. With the required mitigation in the rural development plan, no provisions under GLAS; Green Low-Carbon significant in-combination impacts are predicted. Agri–Environment Scheme; Bio-Energy; nutrient management planning; “Carbon Navigator” software tool Foodwise 2025 was subject to its own AA. Foodwise 2025 ° Land use change or intensification Growth is to be achieved through sustainable intensification to maximise Foodwise 2025 strategy identifies significant ° Water pollution production efficiency whilst minimising the effects on the environment however growth opportunities across all subsectors of there is increased risk of nutrient discharge to receiving waters and in turn a ° Nitrogen deposition the Irish agri-food industry. Growth Projection potential risk to biodiversity and Europe Sites if not controlled. With the includes increasing the value added in the agri- ° Disturbance to habitats / species required mitigation in the Foodwise Plan no significant in-combination impacts food, fisheries and wood products sector by are predicted. 70% to in excess of €13 billion.
Green, Low-Carbon, Agri-environment Scheme (GLAS) The primary purpose of the scheme is to improve environmental quality. No risk Agri-environment funding scheme arising from of likely significant in-combination effects are foreseen owing to the overarching Rural Development Programme 2014-2020. aim of the scheme in protecting the environment. However, individual plans that ° Land use change Seeks to protect and enhance the rural are developed in respect of funding are not typically subject to Appropriate environment by preserving traditional hay ° Disturbance to habitats / species Assessment. An Activity Requiring Consent (ARC) system was proposed by NPWS meadows; low-input pastures; minimum for certain actions under the scheme. Actions outside of the GLAS plan must be tillage; application of agricultural production notified directly to NPWS. methods compatible with the protection of the environment. National Peatlands Strategy (NPS) and Raised ° Habitat loss or destruction; The Raised Bog SAC Management Plan was subject to its own AA. Bog SAC Management Plan ° Habitat fragmentation or The NPS will ensure protection of peatlands in terms of sustainable peat Establishes principles in relation to Irish degradation; extraction and land use utilisation e.g. wind farms or forestry. This plan would peatlands in order to guide Government policy. ° Alterations to water quality not be expected to conflict with any aspects of the AFF but to positively interact Aims to provide a framework for which all of and/or water movement. with it and outline a series of considerations in relation to peatlands. Therefore
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Plan Key Types of Impacts Potential for In-combination Effects and Mitigation the peatlands within the State can be managed there is no likely significant in-combination effects foreseen. responsibly in order to optimise their social, environmental and economic contribution. Aims to meet nature conservation obligations while having regard to national and local economic, social and cultural needs.
Regional Planning ° Habitat loss or destruction; The Regional Planning Guidelines were subject to Appropriate Assessment. The Guidelines ° Habitat fragmentation or likely in-combination effects would be expected to be in relation to requirement Policy Document which seeks to focus future degradation; for infrastructure and associated ecological impacts although no location specific growth patterns through a strategic planning ° Alterations to water quality information is presented. No likely significant in-combination effects foreseen framework as required under the National and/or water movement; due to the fact this plan will help inform where alternative fuel infrastructure Spatial Strategy. ° Disturbance to habitats/species may be required moving forward.
River Basin Management Plans ° Provision of new / upgraded These strategic plans will be subject to AA and will include a programme of infrastructure measures which will contribute to achieving objectives set at the local level. Plans to take an integrated approach to the ° Land use changes These measures will see an improvement of water quality and protection of protection, improvement and sustainable European Sites and the wider water dependant ecosystems. A strong focus in management of the water environment. The ° Changes to water quality or nd the second cycle of the RBMP will be on catchment management and EPA are responsible for delivery of the 2 cycle quantity [improvements] stakeholder engagement. Therefore no likely significant in-combination effects plans which are currently in prep. are envisaged. ° Habitat loss and disturbance from new / upgraded infrastructure; Water Services Strategic Plan ° Species disturbance; The overarching strategy was subject to Appropriate Assessment and highlighted the need for additional plan/project environmental assessments to be carried Overarching strategy for next 25 years in ° Changes to water quality or out at the tier 2 and tier 3 level. Therefore no likely significant in-combination relation to water services planning. quantity; effects are envisaged. ° Nutrient enrichment /eutrophication. National Water Resources Plan (in prep) Framework to deliver a sustainable water ° Increased abstractions leading to The plan will seek to develop sustainable water supplies but must consider supply on a catchment and water resource changes / pressure on existing particularly critical drought periods when assimilation capacity for diffuse runoff zone basis, meeting growth and demand hydrology / hydrogeological may be reduced. The potential for in-combination impacts are unclear as the requirements and be maintained through regimes. plan is not sufficiently developed at this stage. drought and critical periods.
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Table 6.17 In-Combination with Environmental Legislation and Policy
Legislation and Policy Potential for In-combination Impacts No risk of likely significant in-combination effects will result as the primary Water Framework Directive (2000/60/EC) purpose of the Directive is to improve environmental quality. The proper The primary purpose of this Directive and the various pieces of national legislation that have management of infrastructural development will contribute to achieving enacted through the implementation of River Basin Management Plans, is to achieve good the objectives of the WFD as developed through the RBMP. The second status for all water bodies, with no deterioration in water body status. cycle of the River Basin Management Plans are in preparation and are anticipated for completion in 2017. EU Groundwater Directive (2006/118/EC) No risk of likely significant in-combination effects will result as the primary This Directive establishes a regime, which sets groundwater quality standards and purpose of the Directive is to improve environmental quality. introduces measures to prevent or limit inputs of pollutants into groundwater. Nitrates Directive (91/676/EEC) No risk of likely significant in-combination effects will result as the primary This Directive has the objective of reducing water pollution caused or induced by nitrates purpose of the Directive is to improve environmental quality. from agricultural sources and preventing further pollution. The Integrated Pollution Prevention Control Directive (96/61/EC) Objective is to achieve a high level of protection of the environment through measures to No risk of likely significant in-combination effects will result as the primary prevent in the first instance or to reduce emissions to air, water and land from industrial purpose of the Directive is to improve environmental quality. sources. European Union Biodiversity Strategy to 2020 No risk of likely significant in-combination effects will result as the primary purpose of the Strategy is to halt the loss of habitat and species. Aims to halt or reverse biodiversity loss and speed up the EU's transition towards a resource Opportunities may exist in the implementation of the Plan to assist in efficient and green economy as per the Convention on Biological Diversity. achieving the objectives of the Strategy through reducing loss of habitat and /or disturbance to species that rely on them. Prioritised Action Framework for Natura 2000 (2014-2020) No risk of likely significant in-combination effects as this plan is entirely This plan identifies the range of actions needed to help improve the status of Ireland's positive in its actions. habitats and wildlife.
The Common Agriculture Policy Some likely significant impacts are addressed through the Rural Development Plan 2014-2020 through the requirement for Appropriate The Common Agriculture Policy through various iterations is the principal policy that drives Assessment and Monitoring and introducing several pieces of legislation agricultural management throughout the European Union. It recognises the economic and under the Good Agricultural Practice for Protection of Waters (Regulations rural importance of agriculture through a system subsidies and support programmes. 2014, S.I. 31/2014).
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7 MITIGATION MEASURES
To further improve actions contained within the AFF and to address potential negative effects identified in this NIS, mitigation measures have been included in the AFF through an iterative review process throughout the making of the plan and are outlined in Table 7.1.
The AFF is a strategic plan which relies to a significant degree on other policy, strategy and plan initiatives to achieve the targets for alternative fuel infrastructure. Many of these have already undergone AA or are undergoing AA with development of specific mitigation which are or will be implemented. The measures committed to in these other plans will be essential to ensuring that the targets of the AFF are met and that the AFF does not have an adverse effect on any European Sites.
Table 7.1 AA Mitigation
Reference Amendment Location in AFF Include the following European Site Protection Policy: Ensure that all plans and projects [as defined under Part 1 of the Birds and Natural Habitats Regulations 2011, as amended] arising from the AFF are subject to Screening for Appropriate Assessment and/or Proposed New Appropriate Assessment, whichever is deemed necessary, to ensure Chapter 4 Policy Measure 1 there are no likely significant effects on European Sites and/or no adverse effects to European Site integrity. The requirements of Article 6(3) and, where necessary, Article 6(4) of the Habitats Directive must be fully satisfied. Further detail is provided for in Section 7.1. Include the following European Site Protection Policy: All investigative and feasibility studies to be carried out in relation to Proposed New alternative fuels and alternative fuels infrastructure must include an Chapter 4 Policy Measure 2 environmental appraisal which considers the potential effects on the Natura 2000 Network. Further detail is provided for in Section 7.1. Include ‘ Siting Criteria’ text for the protection of European Sites from infrastructural development as a result of the AFF. Proposed text for inclusion is outlined in Section 7.1. Proposed New Chapter 9 Measure 3 Include the following Protection Policy: All infrastructural development arising from the implementation of the AFF must adhere to the ‘Siting Criteria’ included in Chapter 7 of the plan.
7.1 CONSTRUCTION, UPGRADE AND/OR OPERATION OF ALTERNATIVE FUELS RE-FUELLING INFRASTRUCTURE
Any alternative fuel re-fuelling infrastructural developments will be subject to the appropriate planning development controls in line with the relevant environmental legislation and regulatory processes, with Screening for Appropriate Assessment is required a minimum as a matter of compliance with legislation. Although investigative/feasibility studies would not be subject to planning development controls, the AFF has anticipated the need for these studies to consider
MDR1224Rp005F01 59 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport potential effects to European Sites at the earliest possible stage. Together with planning development controls, the protective policies committed to in Chapter 4 of the AFF (Proposed New Policy Measure 1 & 2 from Table 7.1 above) will ensure no likely significant effects to European Sites as they require all plans and projects [as defined under Part 1 of the Birds and Natural Habitats Regulations 2011, as amended] arising from the AFF are subject to Screening for Appropriate Assessment and/or Appropriate Assessment, whichever is deemed necessary, to ensure there are no likely significant effects on European Sites and/or no adverse effects to European Site integrity. The requirements of Article 6(3) and, where necessary, Article 6(4) of the Habitats Directive must be fully satisfied and that all investigative/feasibility studies to be carried out in relation to alternative fuels and alternative fuels infrastructure must include an environmental appraisal which considers the potential effects on the Natura 2000 Network. These protective policies have been incorporated into the AFF following iterative review of the emerging AFF by the AA team throughout the plan making process.
The commitment to protection of European Sites and the wider environment is further strengthened by the inclusion of Siting Criteria (see below) in relation to alternative fuels infrastructure in Chapter 9 of the AFF, and a protective policy within the AFF to ensure that all infrastructural development arising from the implementation of the AFF must adhere to the ‘Siting Criteria’ included in Chapter 9 of the plan . The siting criteria have been incorporated into the AFF following iterative review of the evolving plan by the SEA / AA team and will be applied as part of the site assessment process. The inclusion of siting criteria within the AFF will assist in the proper planning and development of future infrastructure and ensure the impact on European Sites and associated species can be minimised, managed and mitigated.
Siting Criteria
° Existing sites (where appropriate) and brownfield sites should be considered in the first instance for any infrastructural development or expansions. ° Avoid siting alternative fuel infrastructure immediately adjacent to or adjoining European Sites in order to limit the potential impacts and disturbance to habitats and species therein during construction and/or operation. Where this is unavoidable, all development proposals should be accompanied by an Appropriate Assessment Screening and/or Natura Impact Statement, whichever is deemed necessary, which should include, but not be limited to assessing construction related impacts (e.g. water quality), operational related impact (e.g. such as disturbance from noise and water quality) and ex-situ impacts (e.g. roosting/feeding grounds for SPA birds outside of the SPA). ° In the case of shore side electricity, which may be located within or immediately adjacent to an SAC/SPA, infrastructure should be located on existing built ground/structures where possible. This is to limit the potential impacts and disturbance to habitats and species during construction and/or operation. All shore side electricity infrastructure development proposals should be accompanied by an Appropriate Assessment Screening Report and/or Natura Impact Statement, whichever is deemed necessary, which should be informed by detailed ecological survey data related to the European Sites concerned. It should include, but not be limited to assessing construction/operational related impacts (e.g. habitat loss, water quality) and disturbance related impacts (e.g. noise impacts to birds or increased footfall of ships/people in a certain location). ° Avoid siting alternative fuel infrastructure in proposed Natural Heritage Areas (pNHAs), Natural Heritage Areas (NHAs), Statutory Nature Reserves, Refuges for Fauna and Annex I Habitats occurring outside of European Sites, but which provide a supporting role to European Sites. Where this is unavoidable, all development proposals should be accompanied
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by an Appropriate Assessment Screening Report and/or Natura Impact Statement, whichever is deemed necessary. ° In order to protect habitats which, by virtue of their linear and continuous structure (e.g. rivers and their banks, hedgerows) or their contribution as stepping stones (e.g. ponds or small woods), are essential for the migration, dispersal and genetic exchange of wild species, these features will be protected as far as possible from loss or disruption through good site layout and design. ° To protect river habitats and water quality (including physical habitat and hydrological processes/regimes), ensure that no alternative fuel facilities takes place within a minimum distance of 25 m measured from each bank of any river, stream or watercourse. ° To protect river habitats, species and water quality ensure that no infrastructure, including clearance and storage of materials, takes place within a minimum distance of 25m measured from each bank of any river, stream or watercourse. ° To protect water quality, where alternative fuel infrastructure is being developed at existing refuelling infrastructure, ensure that the appropriate tests for contaminated land are carried out and the appropriate mitigation measures are developed prior to the construction of alternative fuel infrastructure. ° To protect water quality, ensure Sustainable Drainage Systems (SuDS) is applied to any new facility and that site-specific solutions to surface water drainage systems are developed taking account of the alternative fuel type(s) being deployed on the site, and which meet the requirements of the Water Framework Directive and associated River Basin Management Plans. ° Avoid development of infrastructure in flood risk areas. Reference should be made to the Planning System and Flood Risk Management for Planning Authorities (DECLG/OPW 2009) and the National Flood Hazard Mapping (OPW) while referring to the relevant Flood Risk Management Plan (FRMP). ° Ensure sites for alternative fuel infrastructure are surveyed for the presence of invasive species (as listed in the Third Schedule of the Birds and Natural Habitats Regulations) prior to infrastructural development, and that strict protocols are applied to prevent the spread of invasive species. ° Avoid geologically unsuitable areas including karst where practicable, and areas susceptible to subsidence or landslides.
7.2 LAND USE CHANGES AS A RESULT OF INDIRECTLY ENCOURAGING THE INCREASED USE OF ALTERNATIVE FUELS
The focus of the AFF is on supporting alternative fuels re-fuelling infrastructure; however discussion on the potential land use changes from the requirement for increased generation of electricity, biofuels and synthetic or paraffinic fuels has been included as it is indirectly linked to the AFF.
In terms of guiding the development of electricity generation infrastructure across the nation, there are a number of policy documents that will set the framework for this. Directive 2009/28/EC on the promotion of the use of energy from renewable sources (the “RES” Directive) establishes a basis for the achievement of 20% renewable energy target by 2020. This legislation is driving the shift on electricity generation from fossil fuels to renewable sources with further targets set of 2030 and 2050 under the EU Climate and Energy Package. In this regard, there will be a predicted increase in the requirement for renewables electricity generation infrastructure with a focus on renewable sources of electricity moving forward. The Department of Housing, Planning, Community and Local
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Government is currently preparing the National Mitigation Plan (NMP) which will add further credence to this Directive, by outlining how Ireland will guide electricity generation to move towards decarbonisation of the sector (i.e. from renewable sources).
The Department of Housing, Planning, Community and Local Government (DHPCLG, formerly the DECLG) are preparing the National Planning Framework (NPF) which will provide a framework for national planning and which will address energy amongst other topics. The NPF will be subject to Appropriate Assessment. This will ensure that any potential likely significant effects on European Sites as a result of the NPF are identified.
The Department of Communications, Climate Action and Environment (formerly the DCENR) is preparing a Renewable Electricity Policy and Development Framework (REPDF) to guide the development of large scale renewable electricity projects on land. It will contribute towards meeting Ireland’s future energy/electricity needs, particularly up to 2030 and beyond. Amongst other policies, it will set out policy in respect of environmental considerations and will seek to broadly identify suitable areas where renewable electricity projects can be developed. The REPDF will itself be subject to Appropriate Assessment and will therefore have to assess the potential for impacts to QI/SCI habitats/species within the Natura 2000 Network in relation to identifying potential renewable energy areas across the State and potential for impacts in the context of the content of the REPDF. The usual planning development controls will remain unchanged, with Screening for Appropriate Assessment and/or Appropriate Assessment being required at a project level, as well as other environmental assessments such as SEA and EIA. Therefore, the REPDF will strategically ensure that renewable electricity generation is guided in a sustainable manner and that likely significant effects on European Sites are minimised.
For smaller renewable electricity projects, the majority of County Councils have produced and adopted wind energy strategies or renewable energy strategies. These add a further layer of protection to European Sites as, in general, these strategies outline the types of renewable energy that will be considered within the County and potential suitable areas for development. These will be updated as and when appropriate in accordance with proper planning, and will have to take into account the plans/policies relevant to renewable electricity such as the NMP, NPF and REPDF.
In relation to proposed electricity generation facilities in general; the usual planning development controls remain and all infrastructural developments will be subject to the appropriate planning development controls in line with relevant environmental legislation and regulatory processes, with Screening for Appropriate Assessment and/or Appropriate Assessment being required at a project level, as well as other environmental assessments such as SEA and EIA. This will ensure that the potential likely significant effects of any proposal are considered and ensure no adverse effects on the integrity of European Sites.
Peat is currently being used as a fuel source for electricity generation, with potential likely significant effects on European Sites if it is being extracted from SACs. The RES Directive will ensure a gradual move away from fossil fuels in the longer term, however in the interim there remains a potential impact. The National Peatland Strategy aims to provide a framework for which all of the peatlands within the State can be managed responsibly in order to optimise their social, environmental and economic contribution while meeting nature conservation obligations. It will ensure protection of peatlands in terms of sustainable peat extraction and land use utilisation e.g. wind farms or forestry. A review of commercial harvesting operations arising out of the objectives listed in the National Peatlands Strategy is currently underway and it is expected to be issued in late 2016. Separate to
MDR1224Rp005F01 62 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport this, Bord na Móna have made a commitment that no new peat harvesting sites will be acquired into the future.
Potential land use change as a result of an increase in the requirement for biofuel crops (being used to produce biofuels, synthetic or paraffinic fuels or as a feedstock for electricity generation facilities) will also be addressed through other policy. The Renewable Energy Directive 2009/28/EC has strict sustainability criteria attached to biofuels, transposed into Irish law in the European Union (Biofuel Sustainability Criteria) Regulations 2012 (S.I. 33 of 2012), which require that biofuels shall not be made from raw materials obtained from land with high biodiversity value or land with high carbon stock 17 . The Indirect Land Use Change (ILUC) Directive (EU) 2015/1513 amends the Renewable Energy Directive, in particular limiting the contribution from “food crops” to renewable energy targets to 7%. The implementation of this measure will ensure the extent of land use change for biofuels is limited, with an increased move towards ‘advanced’ biofuels which are derived from non food crops. The Bioenergy Plan sets out the vision for how the targets for biofuel crops will be met and is also heavily reliant on the Forestry Programme 2014-2020, both of which have been subject to AA and as such the potential likely significant effects on European Sites have been addressed through these plans.
All of these control measures will ensure the potential likely significant effects on European Sites are considered throughout the planning process, and ultimately that European Site integrity is not adversely affected as a result of an increased demand on electricity.
7.3 EMISSIONS TO AIR AS A RESULT OF INDIRECTLY ENCOURAGING THE INCREASED USE OF ALTERNATIVE FUELS
The focus of the AFF is on supporting alternative fuels infrastructure. However discussion on the potential emissions from the generation or combustion from alternative fuels has been included as it is indirectly linked to the AFF, with the emissions from the generation of electricity currently of particular importance. Although alternative fuels do give rise to emissions to air from generation or combustion, substitution of petrol and diesel with alternative fuels on the whole will result in a net positive in terms of emissions to air. As such any positive changes to air emissions will contribute positively towards maintaining or restoring favourable conservation condition if QI/SCI habitats and species.
In relation to electricity generation, generation facilities both existing and proposed, are subject to environmental licensing. Industrial Emissions Licensing (IEL) and Integrated Pollution Control (IPC) licensing is carried out by the EPA, with the requirement for an EPA licence typically being based on a range of conditions with which the operator must comply with in order to ensure no significant environmental impact, including requirements to limit and prevent emissions to air. All licence applications and licence reviews undergo Appropriate Assessment Screening as part of the consent procedure. If it is determined that Appropriate Assessment is required then an NIS can be requested by the EPA. As such, this licensing procedure will capture the potential for likely significant effects on European Sites and ensure no adverse effects to European Site integrity.
Although Ireland is currently reliant on fossil fuels for electricity generation, Directive 2009/28/EC on the promotion of the use of energy from renewable sources (the “RES” Directive) establishes a basis for the achievement of 20% renewable energy target by 2020. This legislation is driving the shift on
17 Energy Security in Ireland: A Statistical Overview (SEAI, 2016)
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The Department of Housing, Planning, Community and Local Government is currently preparing the National Mitigation Plan (NMP). The primary objective of this plan will be to bring a clear and strong focus to both challenges and the opportunities of transitioning to a low carbon future, monitor implementation of current measures to 2020 and identify additional measures in the longer term to reduce greenhouse gas emissions and progress the overall national low carbon transition agenda to 2050. The NMP will incorporate measures relating to electricity generation that will ensure the sector is guided towards reducing CO2 emissions and, by knock on effect, other emissions associated with the electricity generation sector as outlined previously.
The Department of Communications, Climate Action and Environment is preparing a Renewable Electricity Policy and Development Framework (REPDF) to guide the development of large scale renewable electricity projects on land. It will contribute towards meeting Ireland’s future energy/electricity needs, particularly up to 2030 and beyond and will be reviewed at five-yearly intervals . Amongst other policies, it will set out policy in respect of environmental considerations and will seek to broadly identify suitable areas where renewable electricity projects can be developed. The usual planning development controls will remain unchanged, with Screening for Appropriate Assessment being required. The REPDF will guide the transition from reliance on fossil fuel in electricity generation and ultimately will facilitate a net reduction in the emissions to air associated with these generation facilities. As such, the AFF is heavily reliant on the REPDF to ensure that the increased demand for electricity as a result of increased usage of EVs can be met by renewable sources of electricity in the longer term to ensure no impacts on European Sites. The DTTAS understands the importance of the REPDF in terms of fulfilling the overall vision of the AFF and in terms of obligations in relation to nature conservation and air quality/climate change. The AFF has included a commitment in Section 11 Review Provisions to undertake meetings twice a year with the DCCAE to ensure that there is coordination between the REPDF and the AFF on electricity supply from renewable sources and that the meetings focus on progress made on implementing the REPDF. This will help inform any subsequent reviews of the AFF.
As such, the RES Directive, NMP and REPDF will ensure that Ireland moves away from reliance on fossil fuels in the electricity generation sector which will, in the medium to longer term result in a net positive in terms of emissions to air. Any positive changes to air emissions will contribute positively towards maintaining or restoring favourable conservation condition if QI/SCI habitats and species.
It is acknowledged that there remain some knowledge gaps in terms of emission to air and the associated ecological effects as some alternative fuels are still in their infancy (e.g. hydrogen, synthetic and paraffinic fuels). As technology and research moves forward with these fuels, feasibility studies into the potential to roll out for use by the national fleet will have to be undertaken. The protective policy committed to in Chapter 4 of the AFF (Proposed New Policy Measure 2 from Table 7.1 above) will ensure that all investigative/feasibility studies to be carried out in relation to alternative fuels and alternative fuels infrastructure must include an environmental appraisal which considers the potential effects on the Natura 2000 Network . This protective policy has been incorporated into the AFF following iterative review of the emerging AFF by the AA team throughout the plan making process.
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8 CONCLUSIONS
DTTAS is aware of the importance of protection of European Sites and hence the AFF has been formulated with the intention of avoiding adverse effects on European Sites.
The AFF has been assessed in terms of the likely significant effects of the plan and where these would adversely affect the integrity of European Sites. The assessment identified that the majority of policy measures proposed did not give rise to direct effects on European Sites and that, in the main, the effects identified were indirect in nature.
The policy measures of the AFF have been influenced to avoid, as appropriate, policy measures that would have an adverse effect upon the integrity of a European Site(s). Any project arising out of policy measures of the AFF shall be required to conform to the mitigation measures contained within this NIS (as transposed into the AFF) and to the relevant regulatory provisions aimed at preventing pollution or other environmental effects likely to adversely affect the integrity of European Sites. In addition, all lower level projects arising from the implementation of the AFF will themselves be subject to Appropriate Assessment when details of location and design become known.
The conclusion of the NIS for the AFF is that there will be no adverse effects on the integrity of any European Sites.
8.1 NEXT STEPS
This NIS will go on public display together with the draft AFF and the accompanying SEA Environmental Report. Following this period of consultation, the DTTAS will consider all submissions prior to finalising the AFF. Where a submission on the AFF requires further assessment, it will be documented supplementary to the NIS. Thereafter and as part of this process, DTTAS, as the competent authority for the AFF, will undertake an Appropriate Assessment and document their determination. DTTAS will only adopt the AFF if it is satisfied that it will not adversely affect the integrity of any European Site either alone or in-combination with other plans and programmes and in view of the Sites conservation objectives.
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APPENDIX A
Consultation Responses – AA Specific
Drprr;mcnt of Agriculture, ~!= Food and the Marine —' An R.Uinn Talmhaiochta, Bia agus Mara
Denise Keoghan, National Policy Framework on Alternative Fuels Infrastructure for Transport, Climate Change Unit., Department of Transport, Tourism and Sport, Leeson Lane, Dublin 2. 23rd June 2016.
Re: Alternative Fuels Framework.
Dear Ms Keoghan,
I refer to your recent correspondence concerning the above.
The Department of Agriculture, Food and the Marine wish to make the following comments/observations:
In table 2.2 tallow is mentioned as possible feedstock, perhaps it should refer to animal by - products(ABP) and not just tallow — also relevant to table 4.4.
Pg. 24 potential data sources column —opposite climatic factors the ref to EPA 2012-2030 projections doc is out of date - there is a more recent one.
Page 27 —On the assessment criteria for SEA Objective, perhaps consideration should also be given to the extent that the AFF will safeguard sustainable food production.
I am enclosing a publication on forestry and biomass which may be useful(table 12 in particular). Biomass is rarely considered for use in transport, it is mostly used by timber processors themselves as a source of heat for drying timber. Forestry biomass is also used in combined heat and power installations in industry and it is also burned at Bord na Mona's co firing electricity generating station at Edenderry.
In 2013, 34% of the roundwood harvested in the Republic of Ireland was used for energy generation, mainly within the forest products sector. In 2013, the output of the forest-based biomass energy sector grew by 13.8% over 2012.
Demand for forestry biomass is expected to increase in the coming years in order to meet Ireland's renewable energy target of 16% by 2020. Current estimates suggest that demand for this material will increase 2-fold, from 1.6 million cubic metres (m) in 2011 to 3.3milllion m3 in 2020 and that a significant supply gap will emerge in the years to come. Without appropriate action, this supply gap will increase beyond 2020 as fossil fuel prices increase along with EU renewable energy targets.
Increased production of biomass is being addressed in the new Forestry Programme 2014- 2020. This new programme is committed to spending €482 million on establishing 44,000 hectares of new forests during the programme period. This includes a new forestry for fibre scheme which aims to facilitate the planting of 3,300 hectares of fast growing trees such as eucalyptus which has the capacity to produce up to 300m3 of material per hectare, clearfelled at year 15. This alone represents new production of almost 1million m3 of forestry biomass within a relatively short 15 year rotation.
Mobilising forestry biomass is also an important aim of the new programme. The forest roads scheme will provide €27million to build 700km of new roads allowing private forest growers to access their plantations and undertake first thinnings. The National Forest Inventory 2012 showed that almost 23% of the national forestry estate had reached thinning stage but had not been thinned. Thinning is essential in order to bring this material to market.
A thinning grant for broadleaf forests under the Woodland Improvement Scheme of €750 per hectare is also being provided to encourage forest owners to thin their broadleaf forests on time. This represents funding to thin a total of 6,000 hectares of broadleaf forests during the 6 year programme period, most of which will be sold as firewood. This growing market is worth €33million per annum.
The Department is also providing financial support for forest management plans which will allow forest owners to plan for thinning and road building activities. This will help improve the productivity of these forests and ensure that material is brought to market in a manner which will maximise the financial return for owners.
Yours sincerely
0 Liz McDonnell Environmental Co-ordination'Unit Climate Change and Bioenergy Division Department of Agriculture Food and the Marine Pavilion A Grattan Business Park Portlaoise Co. Laois R32 K857 057 8689915
Ms Denise Keoghan National Policy Framework on Alternative Fuels Infrastructure for Transport Climate Change Unit Department of Transport, Tourism and Sport Leeson Lane Dublin 2
4th July 2016 Our Ref: SCP160503.2
Re: National Policy Framework on Alternative Fuels Infrastructure for Transport
Dear Ms. Keoghan,
I refer to and acknowledge your electronic correspondence, dated 23rd June, in relation to the Strategic Environmental Assessment Scoping for the National Policy Framework on Alternative Fuels Infrastructure for Transport, referred to hereafter as the AFF.
In addition to our SEA Scoping submission issued on the 16/06/16, this submission consists of specific comments on the scoping report to take into account, as described in Attachment I
Further comments will be made upon receipt of the Draft AFF and SEA Environmental Report stage of the SEA process.
Should you have any queries or require further information in relation to the above please contact the undersigned. I would be grateful if an acknowledgement of receipt of this submission could be sent electronically to the following address: [email protected].
Yours Sincerely,
______Tadhg O’Mahony Senior Scientific Officer SEA Section Office of Evidence and Assessment Environmental Protection Agency Regional Inspectorate Inniscarra, County Cork
SCP160503.1 EPA SEA Scoping Submission AFF 04.07.2016 1
Attachment 1: Specific Additional Comments on the AFF SEA Scoping Report
Chapter 2 – Description of the Framework The AFF and associated SEA should consider including a graphic showing the relationship and hierarchy of the AFF in relation to other climate mitigation/adaptation-related plans/programmes/policies. This would assist in promoting how an integrated and consistent approach to achieve a reduction in greenhouse gas emissions is to be implemented in collaboration with other Plans/Programmes and Government Departments.
Table 2.2 Alternative Fuels, Infrastructure and Feedstocks We note the alternative fuel options, infrastructure requirements and feedstock related considerations described in this section. The Plans supporting the infrastructure and feedstock-related aspects should also be described in terms of their ability to fulfil and advance the uptake of non-oil based fuel sources in an environmentally sustainable manner. These aspects should also be described in the AFF.
In Section 2.3 – Content and Main Objectives of the Framework and Table 2.3 – Proposed Structure of the AFF, consideration should also be given to the energy and greenhouse gas emissions savings that will result from developing the AFF and the different alternative fuels that will be deployed. Where percentages are referred to, in terms of specific commitments or contributions to reducing greenhouse gas emissions or energy savings etc., the SEA Environmental Report should provide the associated empirical values (e.g. energy units (joules) or greenhouse gas emissions (CO2eq) etc.).
Chapter 4 – Other Relevant Plans and Programs We acknowledge the comprehensive list of relevant plans, programmes and policies described.
The AFF should consider what are the barriers to the uptake of alternative fuels infrastructure over the lifetime of the framework. Consideration should also be given to identifying the key relevant strategic plans/programmes/policies which could be supported (or may be required) in order to help overcome these barriers, in collaboration with relevant stakeholders.
In terms of climate change adaptation, the National Adaptation Framework, like the National Mitigation Plan, will form the basis for how Ireland will adapt to climate change. Large scale infrastructure related to the AFF, will have to take into account the possible effects of climate change over its lifetime.
There is merit in recognising that the AFF could influence spatial planning at a strategic level, by promoting that commitments are included in the National Planning Framework (NPF) and Regional Spatial Economic Strategies (RSES), (currently being prepared by the Department of the Environment, Community and Local Government) to support the need to provide for adequate and appropriate AFF-related infrastructure in spatial planning. Options to consider could include providing and prioritising Electric Vehicle (EV) parking / charging facilities at strategic / desirable locations within settlements, along road corridors etc.
In Table 4.2 European Plans, Programmes, Policy and Legislation, the Environmental Noise Directive might be an additional Directive to consider including.
Including an additional column in Table 4.4 - National Plans of Key Significance, summarising the key relevant aspects and relationship with these plans and the AFF would be useful.
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In relation to the scoping question posed in this Chapter “Based on the plans, policies and programmes outlined in Chapter 4 of this report, are there any other key relevant plans, policies or programmes that should be considered in the SEA Environmental Report?”
The relationship between electricity / energy grid infrastructure (onshore and offshore interconnectivity) and infrastructure required under the AFF, should be highlighted in the Scoping Report and the AFF.
In terms of potential implications on human health / quality of life aspects, the AFF may have potential for social impacts. The relationship and influence of the AFF on fuel poverty-related strategies such as the 2016 “Strategy to Combat Energy Poverty” (DCENR, 2016) may need to be considered.
Chapter 5 – Scope of the Strategic Environmental Assessment We note that the Alternative Fuels Directive sets out minimum alternative-fuels infrastructure targets to achieve for 2020, 2025 and 2030 for certain fuels. The AFF should consider including a commitment to formal reviews over its lifetime to coincide with these periods. This will allow reporting on how the AFF is progressing in achieving those targets and whether advances in technology / economic costs etc. need to be reflected and integrated into the AFF. It is also useful to consider linking such reviews to environmental monitoring and performance related aspects of the AFF.
While it is likely that minimum requirements to achieve the targets for implementation of the AFF are to be promoted, consideration should also be given to setting out a vision for achieving an increased take-up of non-oil based fuel transport infrastructure, beyond the minimum requirements.
The National Transition Objective and the Climate Action and Low Carbon Development Act set out an emissions reduction pathway to 2050. We note that the transport sector is currently working on a sectoral plan, to progress this aim, as part of the National Mitigation Plan (as mentioned in Section 4.3). The transport sector (climate change) mitigation-related plan will outline how transport related emissions of carbon dioxide will be reduced by eighty per cent by 2050. In this context, moving from oil-based to alternative fuels alone will not be sufficient. This transition must also result in less energy use and less greenhouse gas emissions. A coordinated and integrated effort to achieve a low to zero-carbon path for transport on in the longer term will also be needed and should be promoted in the AFF.
Where specific commitments relating to fuel alternatives are being progressed through other plans, such as the National Bioenergy Plan, it would be also useful to describe this aspect in Appendix B. The achievement of the aims of the AFF and other significant and relevant plans should be closely aligned to minimize potential for conflicting objectives. The implications for air quality should also be a key factor in assessing viability / suitability of particular fuel alternatives also.
The Plan should recognise the need to de-carbonise the electricity generation infrastructure (provide electricity from renewable energy sources) to support the preferred option for increased use of electric vehicles for private vehicular transport to be strengthened. The relevant aspects of high level related plans should where possible be considered and promoted in this regard. Targets and objectives should not only reflect an awareness of the major transition ahead for transport, it is also important to consider monitoring and evaluating energy and emissions savings delivered through AFF.
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The AFF should consider whether a need exists to identify potential regional or demographic constraints for particular alternative fuel infrastructure (e.g. rural / urban / suburban). Outside of the Greater Dublin Area area, integrated regional transport/public transport services are more limited. It would be useful, however, to consider the implications of these differences in identifying additional or replacement alternative fuels infrastructure.
We note in Section 5.4 – Key Environmental Considerations, the alternative fuels and related infrastructure to be considered in the AFF (Electricity, Hydrogen, Biofuels, Synthetic and paraffinic fuels, Natural Gas and Liquefied Petroleum Gas). We also note that targets will be set for CNG, LNG and EV fuel sources. These should also be captured in the selection and assessment of alternatives.
It would also be useful to describe the potential vulnerability of AFF infrastructure to climate change, in terms of flood risk, storm event, and drought conditions considerations.
In response to the scoping question “Do you agree with the potential significant effects that have been identified in Chapter 5 of this report? Should any be added or removed?” a number of additional considerations are included below: - Indirect impacts on human health could be broadened to consider visual amenity and quality of life related aspects.
- Is a high level of assessment of infrastructure requirements going to consider aspects such as flood risk / storm events / sea level rise aspects?
- The extent to which a high level assessment of infrastructure requirements may consider aspects such as flood risk, storm events and sea level rise considerations
Chapter 6 – Preliminary Baseline The EPA is currently preparing a new State of the Environment Report for 2016, which is due to publication in Q3 2016. The European Environment Agency, have also produced a State of the Environment Report for 2015. These reports would be useful as high level environmental baseline resources to consider and reference in the preparation of the Plan and SEA Environmental Report.
On the scoping question “Are there other significant information sources that should be considered?”, the EPA has launched www.catchments.ie for information on Water Framework Directive and River Basin catchment management considerations. The hydrometrics unit of the EPA has also launched Hydronet, for hydrogeological data which may be useful also to consider in terms of monitoring groundwater implications which may arise out of implementing the AFF.
Chapter 7 – Proposed Framework for Assessing Environmental Effects We note Table 7-1 – Draft SEA Alternatives for Discussion, which consider aspects such as strategic, modal, spatial and temporal aspects.
Alternatives should consider the various options for private vehicle, public transport and commercial freight transport options in terms of capturing their particular requirements for fuel source infrastructure alternatives.
The various alternative fuel options (or combination of options) for achieving the 2020, 2025 and 2030 Alternative Fuel Directive targets could be considered utilising a multi-criteria assessment approach. This approach could provide a clear rationale for determining which sources are most appropriate during short, medium and long term plan review periods. Where
SCP160503.1 EPA SEA Scoping Submission AFF 04.07.2016 4
particular fuel sources and related infrastructure are not viable currently, they may become increasingly viable as technology, economic cost, social acceptance improve. From an environmental perspective, ensuring aspects such as protection of European Sites (under the Habitats Directive) and Protected Areas (under the Water Framework Directive) need to be considered in assessing and selecting alternatives. Options which provide for a greater (and sustainable) level of decarbonisation should be prioritised.
It would be useful to review the current viability of the various alternative fuel options as described in Appendix B – Alternatives Fuels and their Status in Ireland at specific time periods over the lifetime of the Plan. The AFF should be capable of responding to the viability of particular options over its lifetime with advances in technology, while ensuring that environmental sensitivities are appropriately protected. It is also worth clarifying whether aspects such as transport-related infrastructure aspects such as import / export aspects of fuel types used, will be considered in the AFF.
In relation to the SEA Scoping Question in this chapter “Do you have any suggestions in relation to the overall approach to alternatives?” applying a multi-criteria assessment approach, taking into account aspects such as environmental, technical, social and economic may prove a useful method to identify alternatives and associated infrastructure which may be more or less viable over the lifetime of the AFF.
Section 7.2 – Identification of Objectives, Targets and Indicators The Draft SEA Environmental Objectives of the AFF and the National Mitigation Plan, currently being prepared should be aligned, where relevant.
In Table 7.2 – Draft SEA Environmental Objectives - For Objective 4, it may be useful to provide examples of water courses for clarity, as follows: “Protect the quality and management of water courses (including lakes, rivers and estuaries) and groundwater…”
- Objective 6 “Minimise emissions of greenhouse gasses”, should be reworded to include a reference to support the National Transition Objective (80% reduction in CO2 in transport by 2050). This would provide a clear and robust objective and highlight the urgency of developing and implementing a low carbon pathway to 2050.
- Objective 6 (second bullet point ) - While we note that flooding will be considered, the AFF should also consider other aspects such as extreme weather events, warmer temperatures impacts on alternative infrastructure etc.
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APPENDIX B Special Areas of Conservation (SACs) Republic of Ireland
SAC Site Code SAC Site Code Killyconny Bog (Cloghbally) SAC 000006 Great Island Channel SAC 001058 Lough Oughter & Associated Loughs Kilkieran Lake & Castlefreke Dunes 000007 001061 SAC SAC Ballyallia Lake SAC 000014 Myross Wood SAC 001070 Ballycullinan Lake SAC 000016 Ballyness Bay SAC 001090 Ballyogan Lough SAC 000019 Coolvoy Bog SAC 001107 Black Head-Poulsallagh Complex SAC 000020 Dunragh Loughs/Pettigo Plateau SAC 001125 Danes Hole, Poulnalecka SAC 000030 Gweedore Bay & Islands SAC 001141 Dromore Woods & Loughs SAC 000032 Kindrum Lough SAC 001151 Inagh River Estuary SAC 000036 Muckish Mountain SAC 001179 Pouladatig Cave SAC 000037 Sheephaven SAC 001190 Lough Gash Turlough SAC 000051 Termon Strand SAC 001195 Moneen Mountain SAC 000054 Keeper Hill SAC 001197 Moyree River System SAC 000057 Glenasmole Valley SAC 001209 Poulnagordon Cave (Quin) SAC 000064 Aughrusbeg Machair &Lake SAC 001228 Ballymacoda (Clonpriest & Pillmore) 000077 Courtmacsherry Estuary SAC 001230 SAC Glengarriff Harbour & Woodland SAC 000090 Carrownagappul Bog SAC 001242 Clonakilty Bay SAC 000091 Cregduff Lough SAC 001251 Caha Mountains SAC 000093 Dog's Bay SAC 001257 Lough Hyne Nature Reserve And Gortnandarragh Limestone Pavement 000097 001271 Environs SAC SAC Roaringwater Bay & Islands SAC 000101 Inisheer Island SAC 001275 Sheep's Head SAC 000102 Kiltiernan Turlough SAC 001285 St. Gobnet's Wood SAC 000106 Omey Island Machair SAC 001309 The Gearagh SAC 000108 Rusheenduff Lough SAC 001311 Three Castle Head To Mizen Head 000109 Ross Lake & Woods SAC 001312 SAC Aran Island (Donegal) Cliffs SAC 000111 Rosturra Wood SAC 001313 Ballintra SAC 000115 Termon Lough SAC 001321 Cloonee & Inchiquin Loughs, Uragh Ballyarr Wood SAC 000116 001342 Wood SAC Croaghonagh Bog SAC 000129 Mucksna Wood SAC 001371 Donegal Bay (Murvagh) SAC 000133 Ballynafagh Lake SAC 001387 Durnesh Lough SAC 000138 Rye Water Valley/Carton SAC 001398 Fawnboy Bog/Lough Nacung SAC 000140 Arroo Mountain SAC 001403 Gannivegil Bog SAC 000142 Glen Bog SAC 001430 Horn Head & Rinclevan SAC 000147 Glenstal Wood SAC 001432 Inishtrahull SAC 000154 Clogher Head SAC 001459 Lough Eske And Ardnamona Wood 000163 Clew Bay Complex SAC 001482 SAC Lough Nagreany Dunes SAC 000164 Doogort Machair/Lough Doo SAC 001497 Lough Nillan Bog (Carrickatlieve) SAC 000165 Erris Head SAC 001501 Magheradrumman Bog SAC 000168 Keel Machair/Menaun Cliffs SAC 001513 Lough Cahasy, Lough Baun & Roonah Meenaguse/Ardbane Bog SAC 000172 001529 Lough SAC Meentygrannagh Bog SAC 000173 Mocorha Lough SAC 001536 Curraghchase Woods SAC 000174 Castletownshend SAC 001547 Rathlin O'Birne Island SAC 000181 Urlaur Lakes SAC 001571 Sessiagh Lough SAC 000185 Castlesampson Esker SAC 001625
SAC Site Code SAC Site Code Annaghmore Lough (Roscommon) Slieve League SAC 000189 001626 SAC Slieve Tooey/Tormore 000190 Four Roads Turlough SAC 001637 Island/Loughros Beg Bay SAC Bricklieve Mountains & Keishcorran St. John's Point SAC 000191 001656 SAC Knockalongy & Knockachree Cliffs Tranarossan & Melmore Lough SAC 000194 001669 SAC West Of Ardara/Maas Road SAC 000197 Lough Arrow SAC 001673 Baldoyle Bay SAC 000199 Streedagh Point Dunes SAC 001680 Howth Head SAC 000202 Liskeenan Fen SAC 001683 Kilmuckridge-Tinnaberna Sandhills Lambay Island SAC 000204 001741 SAC Malahide Estuary SAC 000205 Kilpatrick Sandhills SAC 001742 North Dublin Bay SAC 000206 Holdenstown Bog SAC 001757 Rogerstown Estuary SAC 000208 Magherabeg Dunes SAC 001766 South Dublin Bay SAC 000210 Lough Carra/Mask Complex SAC 001774 Inishmaan Island SAC 000212 Pilgrim's Road Esker SAC 001776 Inishmore Island SAC 000213 Kilroosky Lough Cluster SAC 001786 White Lough, Ben Loughs & Lough River Shannon Callows SAC 000216 001810 Doo SAC Coolcam Turlough SAC 000218 Lough Forbes Complex SAC 001818 Barroughter Bog SAC 000231 Split Hills &Long Hill Esker SAC 001831 Caherglassaun Turlough SAC 000238 Philipston Marsh SAC 001847 Castletaylor Complex SAC 000242 Galmoy Fen SAC 001858 Cloonmoylan Bog SAC 000248 Derryclogher (Knockboy) Bog SAC 001873 Coole-Garryland Complex SAC 000252 Glanmore Bog SAC 001879 Croaghill Turlough SAC 000255 Meenaguse Scragh SAC 001880 Derrycrag Wood Nature Reserve SAC 000261 Maulagowna Bog SAC 001881 Galway Bay Complex SAC 000268 Mullaghanish Bog SAC 001890 Inishbofin & Inishshark SAC 000278 Unshin River SAC 001898 Kilsallagh Bog SAC 000285 Cloonakillina Lough SAC 001899 Kiltartan Cave (Coole) SAC 000286 Glendree Bog SAC 001912 Levally Lough SAC 000295 Sonnagh Bog SAC 001913 Lisnageeragh Bog & Ballinastack 000296 Glenade Lough SAC 001919 Turlough SAC Lough Corrib SAC 000297 Bellacorick Bog Complex SAC 001922 Lough Cutra SAC 000299 East Burren Complex SAC 001926 Lough Lurgeen Bog/Glenamaddy Mweelrea/Sheeffry/Erriff Complex 000301 001932 Turlough SAC SAC Lough Rea SAC 000304 Comeragh Mountains SAC 001952 Loughatorick South Bog SAC 000308 Croaghaun/Slievemore SAC 001955 Peterswell Turlough SAC 000318 Boyne Coast & Estuary SAC 001957 Pollnaknockaun Wood Nature Ballyhoorisky Point To Fanad Head 000319 001975 Reserve SAC SAC Rahasane Turlough SAC 000322 Lough Gill SAC 001976 Rosroe Bog SAC 000324 Tamur Bog SAC 001992 Shankill West Bog SAC 000326 Bellacragher Saltmarsh SAC 002005 Slyne Head Islands SAC 000328 Ox Mountains Bogs SAC 002006 Tully Mountain SAC 000330 Maumturk Mountains SAC 002008 Akeragh, Banna & Barrow Harbour 000332 Old Domestic Building (Keevagh) SAC 002010 SAC Ballinskelligs Bay &Inny Estuary SAC 000335 North Inishowen Coast SAC 002012
SAC Site Code SAC Site Code The Twelve Bens/Garraun Complex Castlemaine Harbour SAC 000343 002031 SAC Old Domestic Building, Dromore 000353 Boleybrack Mountain SAC 002032 Wood SAC Kilgarvan Ice House SAC 000364 Connemara Bog Complex SAC 002034 Killarney National Park, Macgillycuddy's Reeks & Caragh River 000365 Ballyhoura Mountains SAC 002036 Catchment SAC Lough Yganavan & Lough 000370 Carrigeenamronety Hill SAC 002037 Nambrackdarrig SAC Old Domestic Building, Curraglass Mount Brandon SAC 000375 002041 Wood SAC Cloghernagore Bog & Glenveagh Sheheree (Ardagh) Bog SAC 000382 002047 National Park SAC Tralee Bay & Magharees Peninsula, Ballynafagh Bog SAC 000391 002070 West To Cloghane SAC Pollardstown Fen SAC 000396 Slyne Head Peninsula SAC 002074 Red Bog, Kildare SAC 000397 Ballinafad SAC 002081 Hugginstown Fen SAC 000404 Newhall & Edenvale Complex SAC 002091 Old Domestic Building, Askive Wood The Loughans SAC 000407 002098 SAC Slieve Bloom Mountains SAC 000412 Corliskea/Trien/Cloonfelliv Bog SAC 002110 Lough Melvin SAC 000428 Kilkieran Bay & Islands SAC 002111 Barrigone SAC 000432 Ballyseedy Wood SAC 002112 Tory Hill SAC 000439 Lough Coy SAC 002117 Lough Ree SAC 000440 Barnahallia Lough SAC 002118 Fortwilliam Turlough SAC 000448 Lough Nageeron SAC 002119 Carlingford Mountain SAC 000453 Lough Bane & Lough Glass SAC 002120 Dundalk Bay SAC 000455 Lough Lene SAC 002121 Killala Bay/Moy Estuary SAC 000458 Wicklow Mountains SAC 002122 Ardkill Turlough SAC 000461 Ardmore Head SAC 002123 Balla Turlough SAC 000463 Bolingbrook Hill SAC 002124 Bellacorick Iron Flush SAC 000466 Anglesey Road SAC 002125 Mullet/Blacksod Bay Complex SAC 000470 Pollagoona Bog SAC 002126 Brackloon Woods SAC 000471 Murvey Machair SAC 002129 Broadhaven Bay SAC 000472 Tully Lough SAC 002130 Ballymaglancy Cave, Cong SAC 000474 Lough Nageage SAC 002135 Carrowkeel Turlough SAC 000475 Lower River Suir SAC 002137 Carrowmore Lake Complex SAC 000476 Mountmellick SAC 002141 Cloughmoyne SAC 000479 Newport River SAC 002144 Clyard Kettle-Holes SAC 000480 Lisduff Fen SAC 002147 Cross Lough (Killadoon) SAC 000484 Newgrove House SAC 002157 Corraun Plateau SAC 000485 Kenmare River SAC 002158 Doocastle Turlough SAC 000492 Mulroy Bay SAC 002159 Duvillaun Islands SAC 000495 Long Bank SAC 002161 Flughany Bog SAC 000497 River Barrow & River Nore SAC 002162 Glenamoy Bog Complex SAC 000500 Lough Golagh & Breesy Hill SAC 002164 Greaghans Turlough SAC 000503 Lower River Shannon SAC 002165 Kilglassan/Caheravoostia Turlough Blackwater River (Cork/Waterford) 000504 002170 Complex SAC SAC Inishkea Islands SAC 000507 Bandon River SAC 002171 Lackan Saltmarsh & Kilcummin Head 000516 Blasket Islands SAC 002172 SAC
SAC Site Code SAC Site Code Lough Gall Bog SAC 000522 Blackwater River (Kerry) SAC 002173 Shrule Turlough SAC 000525 Leannan River SAC 002176 Moore Hall (Lough Carra) SAC 000527 Lough Dahybaun SAC 002177 Oldhead Wood SAC 000532 Towerhill House SAC 002179 Owenduff/Nephin Complex SAC 000534 Gortacarnaun Wood SAC 002180 Skealoghan Turlough SAC 000541 Drummin Wood SAC 002181 Slieve Fyagh Bog SAC 000542 Slieve Mish Mountains SAC 002185 All Saints Bog & Esker SAC 000566 Drongawn Lough SAC 002187 Charleville Wood SAC 000571 Farranamanagh Lough SAC 002189 Clara Bog SAC 000572 Ireland's Eye SAC 002193 Ferbane Bog SAC 000575 Glenloughaun Esker SAC 002213 Fin Lough (Offaly) SAC 000576 Killeglan Grassland SAC 002214 Mongan Bog SAC 000580 Island Fen SAC 002236 Moyclare Bog SAC 000581 Lough Derg, North-East Shore SAC 002241 Raheenmore Bog SAC 000582 Clare Island Cliffs SAC 002243 Cuilcagh - Anierin Uplands SAC 000584 Ardrahan Grassland SAC 002244 Old Farm Buildings, Ballymacrogan Sharavogue Bog SAC 000585 002245 SAC Ballycullinan, Old Domestic Building Ballinturly Turlough SAC 000588 002246 SAC Bellanagare Bog SAC 000592 Toonagh Estate SAC 002247 Callow Bog SAC 000595 The Murrough Wetlands SAC 002249 Carrowbehy/Caher Bog SAC 000597 Carrowmore Dunes SAC 002250 Cloonchambers Bog SAC 000600 Thomastown Quarry SAC 002252 Derrinea Bog SAC 000604 Ballyprior Grassland SAC 002256 Lough Fingall Complex SAC 000606 Moanour Mountain SAC 002257 Errit Lough SAC 000607 Silvermines Mountains West SAC 002258 Lisduff Turlough SAC 000609 Tory Island Coast SAC 002259 Lough Croan Turlough SAC 000610 Magharee Islands SAC 002261 Valencia Harbour/Portmagee Lough Funshinagh SAC 000611 002262 Channel SAC Mullygollan Turlough SAC 000612 Kerry Head Shoal SAC 002263 Cloonshanville Bog SAC 000614 Kilkee Reefs SAC 002264 Ballysadare Bay SAC 000622 Kingstown Bay SAC 002265 Ben Bulben, Gleniff & Glenade 000623 Achill Head SAC 002268 Complex SAC Bunduff Lough &Machair/Trawalua/Mullaghmore 000625 Carnsore Point SAC 002269 SAC Cummeen Strand/Drumcliff Bay 000627 Wicklow Reef SAC 002274 (Sligo Bay) SAC Lough Hoe Bog SAC 000633 Askeaton Fen Complex SAC 002279 Lough Nabrickkeagh Bog SAC 000634 Dunbeacon Shingle SAC 002280 Templehouse And Cloonacleigha 000636 Reen Point Shingle SAC 002281 Loughs SAC Turloughmore (Sligo) SAC 000637 Rutland Island & Sound SAC 002283 Union Wood SAC 000638 Lough Swilly SAC 002287 Carrowbaun, Newhall And Ballylee Ballyduff/Clonfinane Bog SAC 000641 002293 Turloughs SAC Galtee Mountains SAC 000646 Cahermore Turlough SAC 002294 Kilcarren-Firville Bog SAC 000647 Ballinduff Turlough SAC 002295 Helvick Head SAC 000665 Williamstown Turloughs SAC 002296 Nier Valley Woodlands SAC 000668 River Moy SAC 002298
SAC Site Code SAC Site Code Tramore Dunes & Backstrand SAC 000671 River Boyne & River Blackwater SAC 002299 Garriskil Bog SAC 000679 River Finn SAC 002301 Lough Ennell SAC 000685 Dunmuckrum Turloughs SAC 002303 Lough Owel SAC 000688 Carlingford Shore SAC 002306 Scragh Bog SAC 000692 Slieve Bernagh Bog SAC 002312 Ballyteige Burrow SAC 000696 Ballymore Fen SAC 002313 Bannow Bay SAC 000697 Old Domestic Buildings, Rylane SAC 002314 Cahore Polders & Dunes SAC 000700 Glanlough Woods SAC 002315 Lady's Island Lake SAC 000704 Ratty River Cave SAC 002316 Saltee Islands SAC 000707 Cregg House Stables, Crusheen SAC 002317 Screen Hills SAC 000708 Knockanira House SAC 002318 Tacumshin Lake SAC 000709 Kilkishen House SAC 002319 Raven Point Nature Reserve SAC 000710 Kildun Souterrain SAC 002320 Ballyman Glen SAC 000713 Glendine Wood SAC 002324 Bray Head SAC 000714 Mouds Bog SAC 002331 Carriggower Bog SAC 000716 Coolrain Bog SAC 002332 Deputy's Pass Nature Reserve SAC 000717 Knockacoller Bog SAC 002333 Glen Of The Downs SAC 000719 Carn Park Bog SAC 002336 Knocksink Wood SAC 000725 Crosswood Bog SAC 002337 Buckroney-Brittas Dunes & Fen SAC 000729 Drumalough Bog SAC 002338 Vale Of Clara (Rathdrum Wood) SAC 000733 Ballynamona Bog & Corkip Lough SAC 002339 Hook Head SAC 000764 Moneybeg & Clareisland Bogs SAC 002340 Blackstairs Mountains SAC 000770 Ardagullion Bog SAC 002341 Slaney River Valley SAC 000781 Mount Hevey Bog SAC 002342 Cullahill Mountain SAC 000831 Tullaher Lough & Bog SAC 002343 Spahill & Clomantagh Hill SAC 000849 Brown Bog SAC 002346 Clonaslee Eskers & Derry Bog SAC 000859 Camderry Bog SAC 002347 Lisbigney Bog SAC 000869 Clooneen Bog SAC 002348 Ridge Road, SW Of Rapemills SAC 000919 Corbo Bog SAC 002349 The Long Derries, Edenderry SAC 000925 Curraghlehanagh Bog SAC 002350 Clare Glen SAC 000930 Moanveanlagh Bog SAC 002351 Kilduff, Devilsbit Mountain SAC 000934 Monivea Bog SAC 002352 Silvermine Mountains SAC 000939 Redwood Bog SAC 002353 Corratirrim SAC 000979 Tullaghanrock Bog SAC 002354 Ballyteige (Clare) SAC 000994 Ardgraigue Bog SAC 002356 Ballyvaughan Turlough SAC 000996 Blackwater Bank SAC 002953 Glenomra Wood SAC 001013 West Connacht Coast SAC 002998 Carrowmore Point To Spanish Point & 001021 Hemptons Turbot Bank SAC 002999 Islands SAC Barley Cove To Ballyrisode Point SAC 001040 Rockabill to Dalkey Island SAC 003000 Cleanderry Wood SAC 001043 Codling Fault Zone SAC 003015
Offshore SAC Site Code Offshore SAC Site Code Belgica Mound Province SAC 002327 North West Porcupine Bank SAC 002330 Hovland Mound Province SAC 002328 Porcupine Bank Canyon SAC 003001 South-West Porcupine Bank SAC 002329 South-East Rockall Bank SAC 003002
APPENDIX C Special Protection Areas (SPAs) Republic of Ireland
SPA Site Code SPA Site Code Saltee Islands SPA 004002 Pettigo Plateau Nature Reserve SPA 004099 Puffin Island SPA 004003 Inishtrahull SPA 004100 Inishkea Islands SPA 004004 Ballykenny-Fisherstown Bog SPA 004101 Cliffs of Moher SPA 004005 Garriskil Bog SPA 004102 North Bull Island SPA 004006 All Saints Bog SPA 004103 Skelligs SPA 004007 Bellanagare Bog SPA 004105 Blasket Islands SPA 004008 Coole-Garryland SPA 004107 Lady's Island Lake SPA 004009 Eirk Bog SPA 004108 Drumcliff Bay SPA 004013 The Gearagh SPA 004109 Rockabill SPA 004014 Lough Nillan Bog SPA 004110 Rogerstown Estuary SPA 004015 Duvillaun Islands SPA 004111 Baldoyle Bay SPA 004016 Howth Head Coast SPA 004113 Mongan Bog SPA 004017 Illaunonearaun SPA 004114 The Raven SPA 004019 Inishduff SPA 004115 Ballyteigue Burrow SPA 004020 Inishkeel SPA 004116 Old Head of Kinsale SPA 004021 Ireland's Eye SPA 004117 Ballycotton Bay SPA 004022 Keeragh Islands SPA 004118 Ballymacoda Bay SPA 004023 Loop Head SPA 004119 South Dublin Bay and River Tolka 004024 Rathlin O'Birne Island SPA 004120 Estuary SPA Broadmeadow/Swords Estuary SPA 004025 Roaninish SPA 004121 Dundalk Bay SPA 004026 Skerries Islands SPA 004122 Tramore Back Strand SPA 004027 Sovereign Islands SPA 004124 Blackwater Estuary SPA 004028 Magharee Islands SPA 004125 Castlemaine Harbour SPA 004029 Wicklow Head SPA 004127 Cork Harbour SPA 004030 Ballysadare Bay SPA 004129 Inner Galway Bay SPA 004031 Illancrone and Inishkeeragh SPA 004132 Dungarvan Harbour SPA 004032 Aughris Head SPA 004133 Bannow Bay SPA 004033 Lough Rea SPA 004134 Ardboline Island and Horse Island Trawbreaga Bay SPA 004034 004135 SPA Cummeen Strand SPA 004035 Clare Island SPA 004136 Killala Bay/Moy Estuary SPA 004036 Dovegrove Callows SPA 004137 Blacksod Bay/Broadhaven SPA 004037 Lough Croan Turlough SPA 004139 Killarney National Park SPA 004038 Four Roads Turlough SPA 004140 Derryveagh And Glendowan 004039 Cregganna Marsh SPA 004142 Mountains SPA Wicklow Mountains SPA 004040 Cahore Marshes SPA 004143 High Island, Inishshark and Davillaun Ballyallia Lough SPA 004041 004144 SPA Lough Corrib SPA 004042 Durnesh Lough SPA 004145 Lough Derravaragh SPA 004043 Malin Head SPA 004146 Lough Ennell SPA 004044 Fanad Head SPA 004148 Glen Lough SPA 004045 Falcarragh to Meenlaragh SPA 004149 Lough Iron SPA 004046 West Donegal Coast SPA 004150 Lough Owel SPA 004047 Donegal Bay SPA 004151 Lough Gara SPA 004048 Inishmore SPA 004152 Lough Oughter SPA 004049 Dingle Peninsula SPA 004153 Lough Arrow SPA 004050 Iveragh Peninsula SPA 004154 Lough Carra SPA 004051 Beara Peninsula SPA 004155
SPA Site Code SPA Site Code Carrowmore Lake SPA 004052 Sheep's Head to Toe Head SPA 004156 Lough Cutra SPA 004056 River Nanny Estuary and Shore SPA 004158 Slyne Head To Ardmore Point Islands Lough Derg (Donegal) SPA 004057 004159 SPA Lough Derg (Shannon) SPA 004058 Slieve Bloom Mountains SPA 004160 Stack's to Mullaghareirk Mountains, Lough Fern SPA 004060 West Limerick Hills and Mount Eagle 004161 SPA Mullaghanish to Musheramore Lough Kinale and Derragh Lough SPA 004061 004162 Mountains SPA Slievefelim to Silvermines Mountains Lough Mask SPA 004062 004165 SPA Poulaphouca Reservoir SPA 004063 Slieve Beagh SPA 004167 Lough Ree SPA 004064 Slieve Aughty Mountains SPA 004168 Lough Sheelin SPA 004065 Cruagh Island SPA 004170 The Bull and The Cow Rocks SPA 004066 Dalkey Islands SPA 004172 Inishmurray SPA 004068 Deenish Island and Scariff Island SPA 004175 Lambay Island SPA 004069 Bills Rocks SPA 004177 Stags of Broad Haven SPA 004072 Connemara Bog Complex SPA 004181 Tory Island SPA 004073 Mid-Clare Coast SPA 004182 Illanmaster SPA 004074 The Murrough SPA 004186 Lough Swilly SPA 004075 Sligo/Leitrim Uplands SPA 004187 Wexford Harbour and Slobs SPA 004076 Tralee Bay Complex SPA 004188 River Shannon and River Fergus 004077 Kerry Head SPA 004189 Estuaries SPA Carlingford Lough SPA 004078 Galley Head to Duneen Point SPA 004190 Boyne Estuary SPA 004080 Seven Heads SPA 004191 Clonakilty Bay SPA 004081 Helvick Head to Ballyquin SPA 004192 Greers Isle SPA 004082 Mid-Waterford Coast SPA 004193 Inishbofin, Inishdooey and Inishbeg 004083 Horn Head to Fanad Head SPA 004194 SPA Inishglora and Inishkeeragh SPA 004084 Cross Lough (Killadoon) SPA 004212 River Little Brosna Callows SPA 004086 Courtmacsherry Bay SPA 004219 Lough Foyle SPA 004087 Corofin Wetlands SPA 004220 Rahasane Turlough SPA 004089 Illaunnanoon SPA 004221 Sheskinmore Lough SPA 004090 Mullet Peninsula SPA 004227 Stabannan-Braganstown SPA 004091 Lough Conn and Lough Cullin SPA 004228 Tacumshin Lake SPA 004092 West Donegal Islands SPA 004230 Termoncarragh Lake and Annagh Inishbofin, Omey Island and Turbot 004093 004231 Machair SPA Island SPA River Boyne and River Blackwater Blackwater Callows SPA 004094 004232 SPA Kilcolman Bog SPA 004095 River Nore SPA 004233 Middle Shannon Callows SPA 004096 Ballintemple and Ballygilgan SPA 004234 River Suck Callows SPA 004097 Doogort Machair SPA 004235 Owenduff/Nephin Complex SPA 004098
APPENDIX D Special Areas of Conservation (SAC) Northern Ireland
There are a total of 77 SACs currently designated in Northern Ireland. There are five SACs within 15km of the territorial border which overlap with six SACs within the Republic of Ireland. They are indicated with ‘*’
Special Area of Conservation (SAC) Site Code Special Area of Conservation (SAC) Site Code Cuilcagh Mountain * UK0016603 Bann Estuary UK0030084 Pettigoe Plateau * UK0016607 Binevenagh UK0030089 Fairy Water Bogs UK0016611 Cladagh (Swanlinbar) River UK0030116 Magilligan UK0016613 Moneygal Bog UK0030211 Upper Lough Erne UK0016614 Moninea Bog UK0030212 Eastern Mournes UK0016615 Owenkillew River UK0030233 Monawilkin UK0016619 Rostrevor Wood UK0030268 Derryleckagh UK0016620 Slieve Gullion UK0030277 Magheraveely Marl Loughs * UK0016621 West Fermanagh Scarplands UK0030300 Slieve Beagh UK0016622 River Foyle and Tributaries * UK0030320 Largalinny UK0030045 River Roe and Tributaries UK0030360 Lough Melvin * UK0030047 River Faughan and Tributaries UK0030361 Fardrum and Roosky Turloughs UK0030068 Skerries and Causeway UK0030383
APPENDIX E Special Protection Areas (SPAs) Northern Ireland
There are a total of 16 SPAs currently designated in Northern Ireland (as of January 2016). Of those, five occur within 15km of territorial border with those marked as ‘*’ straddling the border and subject to separate SPA designation in the Republic of Ireland.
Special Protection Area (SPA) Site Code Lough Foyle UK9020031 Pettigoe Plateau UK9020051 Upper Lough Erne UK9020071 Slieve Beagh-Mullaghfad-Lisnaskea * UK9020091 Carlingford Lough UK9020161
APPENDIX F Screening for Appropriate Assessment
National Policy Framework on Alternative Fuels Infrastructure for Transport
Screening for Appropriate Assessment
May 2016 National Policy Framework on Alternative Fuels Infrastructure for Transport – Screening for Appropriate Assessment
TABLE OF CONTENTS
1 INTRODUCTION ...... 3
1.1 LEGISLATIVE CONTEXT FOR APPROPRIATE ASSESSMENT ...... 3
1.2 PURPOSE OF AA SCREENING ...... 4
1.3 OVERLAP WITH SEA OF THE AFF ...... 4
1.4 CONSULTATION ...... 5 2 OVERVIEW OF THE AFF ...... 6
2.1 WHY DEVELOP AN AFF? ...... 6
2.2 DESCRIPTION OF THE AFF ...... 6
2.3 POTENTIAL STRUCTURE OF THE AFF ...... 7 2.3.1 Limitations of the Plan...... 8 3 ASSESSMENT METHODOLOGY ...... 9
3.1 GUIDANCE DOCUMENTS ON APPROPRIATE ASSESSMENT ...... 9
3.2 GUIDING PRINCIPLES AND CASE LAW ...... 10
3.3 STAGES OF APPROPRIATE ASSESSMENT ...... 10
3.4 INFORMATION SOURCES CONSULTED ...... 11 4 SCREENING FOR APPROPRIATE ASSESSMENT ...... 12
4.1 DESCRIPTION OF THE PLAN ...... 12
4.2 IDENTIFICATION OF RELEVANT EUROPEAN SITES ...... 12
4.3 ASSESSMENT OF LIKELY EFFECTS ...... 14 4.3.1 Conservation Objectives ...... 16 4.3.2 In-Combination Effects ...... 17 5 CONCLUSION ...... 20 6 REFERENCES ...... 21
MDR1224RP0003F01 i National Policy Framework on Alternative Fuels Infrastructure for Transport – Screening for Appropriate Assessment
APPENDICES
Appendix A Special Areas of Conservation, Republic of Ireland
Appendix B Special Protection Areas, Republic of Ireland
Appendix C Special Areas of Conservation, Northern Ireland
Appendix D Special Protection Areas, Northern Ireland
LIST OF FIGURES
Figure 4.1 - National Distribution of European Sites Including Transboundary Sites ...... 13
LIST OF TABLES
Table 2.1 – Proposed Structure of the AFF ...... 7 Table 4.1 – Number of European Sites in Ireland and Northern Ireland ...... 12 Table 4.2 – Potential Likely Significant Effects – Electricity and Electric Vehicle Infrastructure ...... 14 Table 4.3 – Potential Likely Significant Effects – Hydrogen and Hydrogen Fuel Infrastructure ...... 14 Table 4.4 – Potential Likely Significant Effects – Biofuels and Associated Infrastructure ...... 15 Table 4.5 – Potential Likely Significant Effects – Synthetic and Paraffinic Fuels and Infrastructure .... 15 Table 4.6 – Potential Likely Significant Effects – Natural gas Including Biomethane, in Gaseous Form (Compressed Natural Gas (CNG)) and in Liquefied Form (Liquefied Natural Gas (LNG)) and Associated Infrastructure ...... 15 Table 4.7 – Potential Likely Significant Effects – Liquefied Petroleum Gas and Refuelling Infrastructure ...... 16 Table 4.8 – National Plans, Programmes and Policies ...... 17 Table 4.9 – National Plans of Key Significance ...... 19
MDR1224RP0003F01 ii National Policy Framework on Alternative Fuels Infrastructure for Transport – Screening for Appropriate Assessment
1 INTRODUCTION
The Department of Transport, Tourism and Sport (DTTAS) is currently preparing a National Policy Framework on Alternative Fuels Infrastructure for Transport, hereafter referred to as the Alternative Fuels Framework (AFF). This is in response to Council Directive 2014/94/EU on the deployment of alternatives fuels infrastructure which requires Member States to develop national policy frameworks for the market development of alternative fuels and related infrastructure.
The DTTAS is also tasked with the transposition of Directive 2014/94/EU which must be completed by the 18 th November 2016. Given the close relationship between transport and energy, the DTTAS is working closely with the Department of Communications, Climate Change and Natural Resources (DCCCNR) 1 in the delivery of the AFF.
This report comprises information in support of a screening for Appropriate Assessment (AA) of the AFF in line with the requirements of Article 6(3) of the EU Habitats Directive (Directive 92/43/EEC) on the Conservation of Natural Habitats and of Wild Fauna and Flora as transposed into Irish law through the European Communities (Birds and Natural Habitats) (Amendment) Regulations 2015.
Appropriate Assessment is a process for undertaking a comprehensive ecological impact assessment of a plan or project, examining its implications, on its own or in-combination with other plans and projects, on one or more European Sites in view of the sites’ conservation objectives, as referred to in Article 6(3) of the EU Habitats Directive.
1.1 LEGISLATIVE CONTEXT FOR APPROPRIATE ASSESSMENT
The Council Directive 92/43/EEC on the Conservation of Natural Habitats and of Wild Fauna and Flora, better known as the “Habitats Directive” provides legal protection for habitats and species of European importance. Articles 3 to 9 provide the legislative means to protect habitats and species of Community interest through the establishment and conservation of an EU-wide network of sites known as the Natura 2000 network. These are Special Areas of Conservation (SACs) designated under the Habitats Directive and Special Protection Areas (SPAs) designated under the Conservation of Wild Birds Directive (79/409/ECC) as codified by Directive 2009/147/EC.
Articles 6(3) and 6(4) of the Habitats Directive set out the decision-making tests for plans and projects likely to affect European Sites (Annex 1.1). Article 6(3) establishes the requirement for AA:
Any plan or project not directly connected with or necessary to the management of the [European] site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subjected to appropriate assessment of its implications for the site in view of the site’s conservation objectives. In light of the conclusions of the assessment of the implications for the site and subject to the provisions of paragraph 4, the competent national authorities shall agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the site concerned and, if appropriate, after having obtained the opinion of the general public.
1 Formerly the Department of Communications, Energy and Natural Resources
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Article 6(4) states:
If, in spite of a negative assessment of the implications for the [European] site and in the absence of alternative solutions, a plan or project must nevertheless be carried out for imperative reasons of overriding public interest, including those of a social or economic nature, Member States shall take all compensatory measures necessary to ensure that the overall coherence of Natura 2000 is protected. It shall inform the Commission of the compensatory measures adopted.
The Habitats Directive has been transposed into Irish law by the Planning and Development Act 2000 (as amended) and the European Communities (Birds and Natural Habitats) (Amendment) Regulations 2015. In the context of the AFF, the governing legislation is principally Article 27 of the Birds and Habitats Regulations which sets out the duties of public authorities (in this case the DTTAS) relating to nature conservation and Article 42 which addresses screening for AA and AA of implications for European Sites. If screening determines likelihood for significant effects on a European Site, then full AA must be carried out for the plan, including the compilation of a Natura Impact Statement (NIS) to inform the decision making.
1.2 PURPOSE OF AA SCREENING
The purpose of the screening for AA is to assess, in view of the best scientific knowledge and in view of the conservation objectives of the sites, if that plan or project, individually or in combination with other plans or projects is likely to have a significant effect on the site.
Screening is the process that addresses and records the reasoning and conclusions in relation to the first two tests of Article 6(3):
° Whether a plan or project is directly connected to or necessary for the management of the site, and ° Whether a plan or project, alone or in combination with other plans and projects, is likely to have significant effects on a European Site in view of its conservation objectives.
It is the responsibility of the public authority to carry out AA screening and record their AA screening determination.
1.3 OVERLAP WITH SEA OF THE AFF
An SEA is being carried out concurrently with the AA process. The purpose of the SEA is to evaluate at an early stage, the range of environmental consequences that may occur as a result of implementing the AFF and to give interested parties an opportunity to comment upon the perceived or actual environmental impacts of the proposal. There is a degree of overlap between the requirements of both the SEA and AA and in accordance with best practice, an integrated process of sharing gathered data, such as that potentially affecting the integrity (threats and sensitivities) of European Sites has been carried out. These processes together have informed and shaped the development of the AFF.
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It is also noted that there are issues relevant to the Habitats Directive that are not strictly related to AA. These include Article 10 and 12 of the directive. In these cases, the issues have been brought forward to the biodiversity, flora and fauna section of the SEA and have been addressed in that context as part of the wider environmental assessments informing the AFF.
1.4 CONSULTATION
From the outset, consultation is a mandatory requirement in the SEA process and responses often have specific guidance recognising the AA process. Statutory consultation will be undertaken in May 2016 in relation to SEA Scoping for the AFF.
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2 OVERVIEW OF THE AFF
2.1 WHY DEVELOP AN AFF?
Today more than 90% of the energy used in transport within Europe is derived from crude oil, of which 84% is imported (2011), costing up to one billion euro per day. Europe’s oil supply and, as a consequence, its mobility, depend to a large degree on politically unstable regions. This raises security of supply concerns 2. In Ireland, the cost of all energy imports in 2013 was €6.7 billion and, from this, approximately €3.5 billion was spent on transportation, with oil being the dominant fuel.
Ireland agreed under the Renewable Energy Directive (2009/28/EC) and the National Renewable Energy Action Plan that the 16% renewable energy source target for 2020 will be met by 10% from transport with the remainder coming from electricity (40%) and heat (12%). In addition, one of the primary goals of the Irish Government’s Smarter Travel policy (2009-2020) 3 is to improve security of energy supply by reducing dependency on imported fossil fuels. Ireland’s recent Energy White Paper 4 outlines the need for an effective transition to a Low Carbon Energy Future 2015-2030. It states that a framework is required to guide policy as well as the actions that Ireland intends to take in the energy sector from now up to 2030. It outlines that a low carbon energy system will help to secure competitive and affordable energy supplies. It also states that a low carbon future will involve a number of factors including “ increasing the use of electricity and bioenergy to heat our homes and fuel our transport ”.
To help reduce oil dependency in transport and the correlated harmful effects, the EU Commission undertook to develop a sustainable alternative fuels strategy, which would support the development of appropriate refuelling infrastructure and associated standards, Directive 2014/92/EC. This directive must be transposed into national legislation in all 28 Member States by 18 November 2016. In order to fulfil the requirements of the directive, Member States have the responsibility to draft and implement national policy frameworks on the deployment of alternative fuels infrastructure and the strategies must include national targets and objectives. As previously mentioned the DTTAS will deliver on the transposition of the directive and the development of a policy framework.
2.2 DESCRIPTION OF THE AFF
The National Policy Framework on Alternative Fuel Infrastructure for Ireland will support the provision of refuelling infrastructure for alternative fuels, common technical standards and appropriate consumer information.
The Commission has taken the view that a major obstacle to market uptake of alternative fuels was the slow establishment of supporting infrastructure, along with a lack of associated common technical standards across the EU. Therefore, Directive 2014/92/EC sets out common standards for future technical infrastructure specifications across Europe e.g. one type of electric vehicle connector, enabling cars from an EU country to be recharged in another EU country without the need for an expensive adapter. As part of the AFF, Member States are asked to include defined targets with respect to the alternative fuelled vehicle fleet and measures that can promote the use of the planned infrastructure.
2 Clean Power for Transport – A European Alternative Fuel Strategy, COM(2013) 3 Smarter Travel – A Sustainable Transport Future, A New Transport Policy for Ireland 2009-2020 4 White Paper, Ireland’s Transition to a Low Carbon Energy Future 2015-2030, DCENR
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2.3 POTENTIAL STRUCTURE OF THE AFF
The AFF may have a similar structure to that contained in Annex I of Directive 2014/92/EC which outlines that the “ report shall contain a description of the measures taken in a Member State in support of alternative fuels infrastructure build-up ” and shall include at least the following elements, as outlined in Table 2.1 .
Table 2.1 – Proposed Structure of the AFF
Content Requirements for AFF Legal measures Information on legal measures, which may consist of legislative, regulatory or administrative measures to support the build-up of alternative fuels infrastructure, such as building permits, parking lot permits, certification of the environmental performance of businesses and fuel stations concessions. Policy measures supporting the implementation of the national policy framework Information on those measures shall include the following elements: ° Direct incentives for the purchase of means of transport using alternative fuels or for building the infrastructure; ° Availability of tax incentives to promote means of transport using alternative fuels and the relevant infrastructure; ° Use of public procurement in support of alternative fuels, including joint procurement; ° Demand-side non-financial incentives, for example preferential access to restricted areas, parking policy and dedicated lanes; ° Consideration of the need for renewable jet fuel refuelling points in airports within the TEN-T Core Network; and ° Technical and administrative procedures and legislation with regard to the authorisation of alternative fuels supply, in order to facilitate the authorisation process. Deployment and manufacturing support Annual public budget allocated for alternative fuels infrastructure deployment, broken down by alternative fuel and by transport mode (road, rail, water and air). Annual public budget allocated to support manufacturing plants for alternative fuels technologies, broken down by alternative fuel and by transport mode. Consideration of any particular needs during the initial phase of the deployment of alternative fuels infrastructures. Research, technological development and demonstration (RTD&D) Annual public budget allocated to support alternative fuels RTD&D, broken down by fuel and by transport mode. Targets and objectives ° Estimation of the number of alternative fuel vehicles expected by 2020, 2025 and 2030. ° Level of achievement of the national objectives for the deployment of alternative fuels in the different transport modes (road, rail, water and air). ° Level of achievement of the national targets, year by year, for the deployment of alternative fuels infrastructure in the different transport modes. ° Information on the methodology applied to take account of the charging efficiency of high power recharging points. Alternative fuels infrastructure developments Changes in supply (additional infrastructure capacity) and demand (capacity actually used).
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2.3.1 Limitations of the Plan
Given the strategic nature of the plan, it may not explicitly address specific locations where development of infrastructure will be required. As such an assessment of the implications of the plan for European Sites, in view of their conservation objectives, must consider the generality of the plan and ensure it includes the necessary protections to ensure it does not adversely affect the integrity of any European Site.
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3 ASSESSMENT METHODOLOGY
3.1 GUIDANCE DOCUMENTS ON APPROPRIATE ASSESSMENT
The AA requirements of Article 6 of the Habitats Directive 92/43/EEC (European Communities 2001) follow a sequential approach as outlined in the following legislation and guidance documents/ Departmental Circulars, namely:
European and National Legislation:
° Council Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora (also known as the ‘Habitats Directive’); ° Council Directive 2009/147/EC on the conservation of wild birds, codified version, (also known as the ‘Birds Directive’); ° European Communities (Birds and Natural Habitats) (Amendment) Regulations 2015; and ° Planning and Development Act 2000-2014.
Guidance:
° DEHLG (2009) Appropriate Assessment of Plans and Projects in Ireland: Guidance for Local Authorities (revision 10/02/10); ° European Commission (2000) Managing Natura 2000 sites: the provisions of Article 6 of the ‘Habitats’ Directive 92/43/EEC 5; ° European Commission (2002) Assessment of Plans and Projects Significantly Affecting Natura 2000 sites: Methodological Guidance on the Provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC; ° European Commission (2007) Guidance Document on Article 6(4) of the ‘Habitats Directive’ 92/43/EEC. Clarification of the concepts of: Alternative Solutions, Imperative Reasons of Overriding Public Interest, Compensatory Measures, Overall Coherence, Opinion of the Commission; and ° DAHG (2012) Marine Natura Impacts Statements in Irish Special Areas of Conservation. A working Document.
Departmental/NPWS Circulars:
° Circular NPWS 1/10 & PSSP 2/10: Appropriate Assessment under Article 6 of the Habitats Directive: Guidance for Planning Authorities; ° Circular Letter SEA 1/08 & NPWS 1/08: Appropriate Assessment of Land Use Plans; ° Circular L8/08: Water Services Investment and Rural Water Programmes – Protection of Natural Heritage and National Monuments; ° Circular Letter NPWS 2/07: Guidance on Compliance with Regulation 23 of the Habitats Directive; and
5 The Commission has notified its intent to revise this guidance and a draft revised document was published in April 2015. It would appear that this has not been finalised to date, with no revised guidance document available on the Commissions website.
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° Circular Letter PD 2/07 and NPWS 1/07: Compliance Conditions in respect of Developments requiring (1) Environmental Impact Assessment (EIA); or (2) having potential impacts on Natura 2000 sites.
3.2 GUIDING PRINCIPLES AND CASE LAW
Over time legal interpretation has been sought on the practical application of the legislation concerning AA as some terminology has been found to be unclear. European and National case law has clarified a number of issues and some aspects of the published guidance documents have been superseded by case law. Case law has been considered in the preparation of the screening of the AFF.
3.3 STAGES OF APPROPRIATE ASSESSMENT
The AA process progresses through four stages. If at any stage in the process it is determined that there will be no adverse effect on the integrity of a European Site in view of the sites conservation objectives, the process is effectively completed. The four stages are as follows:
° Stage 1 – Screening of the proposed plan or project for AA; ° Stage 2 – An AA of the proposed plan or project; ° Stage 3 – Assessment of alternative solutions; and ° Stage 4 – Imperative Reasons of Overriding Public Interest (IROPI)/ Derogation.
Stage 1: Screening for AA
The aim of screening is to assess firstly if the plan or project is directly connected with or necessary to the management of European Site(s); or in view of best scientific knowledge, if the plan or project, individually or in combination with other plans or projects, is likely to have a significant effect on a European site. This is done by examining the proposed plan or project and the conservation objectives of any European Sites that might potentially be affected. If screening determines that there is potential for significant effects or there is uncertainty regarding the significance of effects then it will be recommended that the plan is brought forward to the next stage of the AA process.
Stage 2: Appropriate Assessment
The aim of Stage 2 of the AA process is to identify any adverse impacts that the plan or project might have on the integrity of relevant European Sites. As part of the assessment, a key consideration is ‘in combination’ effects with other plans or projects. Where adverse impacts are identified, mitigation measures can be proposed that would avoid, reduce or remedy any such negative impacts and the plan or project should then be amended accordingly, thereby avoiding the need to progress to Stage 3.
Stage 3: Alternative Solutions
If it is not possible during Stage 2 of the AA process to conclude that there will be no adverse effects on site integrity, Stage 3 of the process must be undertaken which is to objectively assess whether alternative solutions exist by which the objectives of the plan or project can be achieved. Explicitly,
MDR1224RP0003F01 10 National Policy Framework on Alternative Fuels Infrastructure for Transport – Screening for Appropriate Assessment this means alternative solutions that do not have adverse impacts on the integrity of a European Site. It should also be noted that EU guidance on this stage of the process states that, ‘other assessment criteria, such as economic criteria, cannot be seen as overruling ecological criteria’ (EC, 2002). In other words, if alternative solutions exist that do not have adverse impacts on European Sites; they should be adopted regardless of economic considerations. This stage of the AA process should result in the identification of the least damaging options for the plan or project.
Stage 4: Imperative Reasons of Overriding Public Interest (IROPI)
This stage of the AA process is undertaken when it has been determined that a plan or project will have adverse effects on the integrity of a European Site, but that no alternatives exist. At this stage of the AA process, it is the characteristics of the plan or project itself that will determine whether or not the competent authority can allow it to progress. This is the determination of ‘over-riding public interest’.
It is important to note that in the case of European Sites that include in their qualifying features ‘priority’ habitats or species, as defined in Annex I and II of the Directive, the demonstration of ‘over- riding public interest’ is not sufficient and it must be demonstrated that the plan or project is necessary for ‘human health or public safety considerations’. Where plans or projects meet these criteria, they can be allowed, provided adequate compensatory measures are proposed. Stage 4 of the process defines and describes these compensation measures.
3.4 INFORMATION SOURCES CONSULTED
The following sources of information have been consulted:
° Department of Housing, Planning and Local Government – online land use mapping www.myplan.ie/en/index.html; ° GeoHive online mapping http://map.geohive.ie/mapviewer.html; ° Ordnance Survey of Ireland – Online mapping and Aerial photography www.osi.ie; ° National Parks and Wildlife Service – online European Site information www.npws.ie; ° Northern Ireland Environment Agency – online European Site information https://www.doeni.gov.uk/; ° National Parks and Wildlife Service – Information on the status of EU protected habitats in Ireland (NPWS 2013a & 2013b); ° Environmental Protection Agency – Water Quality www.epa.ie; ° Information on www.wfdireland.ie; ° Geological Survey of Ireland – Geology, soils and Hydrogeology www.gsi.ie; ° Information on the conservation status of birds in Ireland (Colhoun & Cummins, 2013); and ° Directive 2014/94/EC on the deployment of alternative fuels infrastructure.
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4 SCREENING FOR APPROPRIATE ASSESSMENT
In line with best practice guidance the AA Screening involves the following:
1. Description of the plan; 2. Identification of relevant European Sites; 3. Assessment of likely significant effects; 4. Screening statement/determination with conclusions.
4.1 DESCRIPTION OF THE PLAN
An overview of the AFF, including background and context are provided in Chapter 2 of this document.
4.2 IDENTIFICATION OF RELEVANT EUROPEAN SITES
European Sites comprise (a) Special Areas of Conservation (SACs) that are designated under the Habitats Directive as requiring the conservation of important, rare or threatened habitats and species (other than birds) and (b) Special Protection Areas (SPAs), which are designated under the Birds Directive to conserve certain migratory or rare birds and their habitats. Collectively these sites form the Natura 2000 network. In accordance with DEHLG Guidance (2009), the AA also takes into account transboundary impacts where it is identified that the implementation of the plan has the potential to impact on European Sites in Northern Ireland.
The AFF is a national plan concerned with reducing oil dependency in transport and the correlated harmful effects through the development of a sustainable fuels strategy, therefore the zone of influence of the plan is considered to include all European Sites for Ireland and Northern Ireland. At this time, location specific information is not presented in the plan to allow for any European Site to be removed from consideration. Furthermore the AFF is not directly connected with or necessary to the management of any European Sites in Ireland or Northern Ireland. As such, all European Sites within Ireland and 15km of the border between Ireland and Northern Ireland will be considered in the first instance (Figure 4.1 and Table 4.1 ). An inventory of all European Sites including transboundary sites are listed in Appendices A-D.
Table 4.1 – Number of European Sites in Ireland and Northern Ireland
Ireland* Northern Ireland* ° 424 SACs 57 SACs ° 165 SPAs 16 SPAs *Data downloaded as of Mar 2016 (latest notification from NPWS).
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Figure 4.1 - National Distribution of European Sites Including Transboundary Sites
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4.3 ASSESSMENT OF LIKELY EFFECTS
The main objective of the AFF is to reduce oil dependency through the generation of infrastructure that will support the use of alternative (cleaner and greener) fuels in the transport sector in Ireland. The AFF will have to account for the protection of the environment and prevention of harmful effects on soil, vegetation, fauna and humans , providing a clear foundation for the protection of the environment including European Sites. However, notwithstanding this, the DTTAS recognises the broader environmental impacts of the AFF in terms of potential emissions to air and potential loss of greenfield sites through the development of infrastructure.
The potential threats from the AFF on European Sites cannot at this stage be confirmed based on the level of detail available, however they may be inferred particularly in relation to impacts to sensitive habitats e.g. those sensitive to air emissions. Table 4.2 -4.7 outline the potential likely significant effects associated with each alternative fuel type covered by the AFF.
Table 4.2 – Potential Likely Significant Effects – Electricity and Electric Vehicle Infrastructure
Aspects of the Plan With Potential for Potential Significant Effects Significant Effects ° Provision of new infrastructure for electric vehicles e.g. domestic Loss or disturbance to habitats or species or charge points, public access city and their supporting features through: town charge points and inter-urban ° Inappropriate siting of new Electricity & fast charging points; infrastructure; Electric ° Upgrade of existing infrastructure ° Construction of new infrastructure or Vehicle to provide additional capacity etc.; upgrade of existing infrastructure; Infrastructure and ° Inappropriate management of ° Provision of infrastructure for Shore facilities; and Side Electricity (SSE); ° Impact to air quality.
Table 4.3 – Potential Likely Significant Effects – Hydrogen and Hydrogen Fuel Infrastructure
Aspects of the Plan With Potential for Potential Significant Effects Significant Effects Loss or disturbance to habitats or species or their supporting features through: ° Provision of infrastructure for a ° Inappropriate siting of new hydrogen refuelling network; Hydrogen & infrastructure; Hydrogen ° Use of hydrogen supplied fuel cells; ° Construction of new infrastructure; Refuelling and ° Inappropriate management of fuel or Network ° Storage and transport of fuel. facilities;
° Impact to air quality; and ° Potential for spillage in transit.
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Table 4.4 – Potential Likely Significant Effects – Biofuels and Associated Infrastructure
Aspects of the Plan With Potential for Potential Significant Effects Significant Effects Loss or disturbance to habitats or species or their supporting features through: ° Generation of biomass/ biofuels; ° Consumption of biomass/ biofuels; ° Inappropriate siting of new ° Provision of new infrastructure; Biofuels & infrastructure; ° Upgrade of existing infrastructure; Associated ° Construction of new infrastructure or Infrastructure ° Storage and transport of fuel; and upgrading of existing infrastructure; ° Conversion of fossil-fuel vehicles to ° Inappropriate management of fuel or dual-fuel engines. facilities; ° Impact to air quality; and ° Potential for spillage in transit.
Table 4.5 – Potential Likely Significant Effects – Synthetic and Paraffinic Fuels and Infrastructure
Aspects of the Plan With Potential for Potential Significant Effects Significant Effects Loss or disturbance to habitats or species or their supporting features through: ° Provision of new infrastructure e.g. ° Inappropriate siting of new Plans by private entities to develop infrastructure; Synthetic & processing plants; Paraffinic ° Construction of new infrastructure or ° Upgrade of existing infrastructure; upgrading of existing infrastructure; Fuels & and Infrastructure ° Inappropriate management of fuel or ° Storage and transport of fuel. facilities;
° Impact to air quality; and ° Potential for spillage in transit.
Table 4.6 – Potential Likely Significant Effects – Natural gas Including Biomethane, in Gaseous Form (Compressed Natural Gas (CNG)) and in Liquefied Form (Liquefied Natural Gas (LNG)) and Associated Infrastructure
Aspects of the Plan With Potential for Potential Significant Effects Significant Effects
° Provision of new fuelling Loss or disturbance to habitats or species or infrastructure including refuelling their supporting features through: Natural Gas equipment and bunkering (LNG); ° Inappropriate siting of new Including ° Supply of LNG by truck or via infrastructure; Biomethane shuttle from LNG terminal (nearest (CNG & LNG) ° Construction of new infrastructure or in Wales) as there is no LNG & Associated upgrading of existing infrastructure; terminal in Ireland; Infrastructure ° Inappropriate management of fuel or ° Development of new CNG facilities; Infrastructure ° Emissions from transport from
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Aspects of the Plan With Potential for Potential Significant Effects Significant Effects ° Upgrading of existing infrastructure nearest LNG terminal and potential (CNG) e.g. Gas Networks Ireland risk of spillage in transit; and refuelling station in Cork and ° Impact to air quality. temporary station in Dublin; and ° Storage and transport of fuel;.
Table 4.7 – Potential Likely Significant Effects – Liquefied Petroleum Gas and Refuelling Infrastructure
Aspects of the Plan With Potential for Potential Significant Effects Significant Effects Loss or disturbance to habitats or species or ° Provision of new fuelling their supporting features through: Liquefied infrastructure; ° Inappropriate siting of new Petroleum ° Upgrading of existing infrastructure; Gas & infrastructure; and ° Construction of new infrastructure; Refuelling ° Storage (pressure containers) and ° Inappropriate management of fuel or Infrastructure transport of fuel. facilities; ° Impact to air quality; and ° Potential for spillage in transit.
The risk of a potential likely significant effect does not necessarily mean that it will occur. In the absence of finalised controls or mitigation measures at this preliminary stage of the preparation of the AFF as well as the remaining unknowns in relation to the potential effect on air quality, the potential loss of greenfield sites through infrastructural development, and the production of fuel e.g. rapeseed monocultures, it is considered that there is a likelihood of significant effects occurring on one or more European Sites.
4.3.1 Conservation Objectives
The overall aim of the Habitats Directive is to maintain or restore the favourable conservation status of habitats and species of community interest (the qualifying interest habitats and species for which a site has been designated).
Site specific conservation objectives aim to define favourable conservation condition for these habitats or species at the site level. Maintenance of favourable conservation condition of habitats and species at a site level in turn contributes to maintaining or restoring favourable conservation status of habitats and species at a national level and ultimately at the Natura 2000 Network level.
Given the number of European Sites that could potentially be impacted by the implementation of AFF (Table 4.1 and Appendix A - D), it is not practical to list the Conservation Objectives of each site in the screening report. Rather the generic Conservation Objectives which have been developed by NPWS (as part of the Department of Regional Development, Rural Affairs, Arts and the Gaeltacht),
MDR1224RP0003F01 16 National Policy Framework on Alternative Fuels Infrastructure for Transport – Screening for Appropriate Assessment and encompass the spirit of site specific Conservation Objectives in the context of maintain and restore are presented:
° To maintain at favourable conservation status Annex I habitats and Annex II species for which the SAC or SPA has been selected; ° To maintain the extent of species richness and diversity of the entire SAC and for SPAs; and ° To maintain the bird species of special conservation interest for which the SPA has been listed at favourable conservation status.
In undertaking this screening of the AFF, consideration has been given to the potential to impact on the achievement of Conservation Objectives at this more general level in the first instance.
4.3.2 In-Combination Effects
It is a requirement of Article 6(3) of the Habitats Directive that the in-combination effects with other plans or projects are considered. Consideration has been given, at this draft stage of the AFF, to other relevant plans on a similarly strategic level that have clear potential to have a cumulative impact upon European Sites.
Given the level of detail currently available for the AFF and that potential likely significant effects cannot currently be ruled out as a result of implementation of the plan, it is considered that the AFF has the potential to result in in-combination effects with other plans. Some of the plans considered are listed in Table 4.8.
Table 4.8 – National Plans, Programmes and Policies
National Plans, Programmes and Policies National Clean Air Strategy (DECLG) (in preparation) National Planning Framework (DECLG) (in preparation) Regional Spatial and Economic Strategies (Regional Assembly) (in preparation) Renewable Electricity Policy and Development Framework (DECENR) (in preparation) National Bioenergy Plan (DCENR) (in preparation) National Mitigation Plan (for Climate Change) (DECLG) (in preparation) National River Basin Management Plan (2017) (this 2nd cycle of plans is under preparation) Catchment Flood Risk Assessment and Management Plans (CFRAMs) (in preparation) Irelands Regional Waste Management Plans 2015-2021 (2015) Draft National Raised Bog Special Area of Conservation (SAC) Management Plan (still to be adopted) Transport Strategy for the Greater Dublin Area 2016 – 2035 (NTA) The White Paper 'Ireland's Transition to a Low Carbon Energy Future 2015-2030' (DCENR, 2015) National Landscape Strategy for Ireland 2015-2025 (DAHG, 2015) National Energy Efficiency Action Plan (DCENR 2014) Ireland - Rural Development Programme 2014-2020 (DAFM, 2015) Forestry Programme 2014-2020 Ireland (DAFM, 2015) Food Wise 2025 (DAFM, 2015) (replacing Food Harvest 2020) Green Paper on Energy Policy in Ireland (DCENR, 2014)
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National Plans, Programmes and Policies National Peatland Strategy (Draft) (DAHG, 2014) Offshore Renewable Energy Development Plan (DCENR, 2014) Review of Raised Bog Natural Heritage Area Network (NPWS, 2014) National Hazardous Waste Management Plan 2014-2020 (EPA, 2014) Raised Bog SAC Management Plan (Draft) (DAHG, 2014) National Policy Position on Climate Action and Low-Carbon Development (2014) Forest Policy Review: Forests, Products and People - Ireland's Forest Policy-Renewed Vision (DAFM, 2014) Ireland’s Nitrates Action Programme (DAFM, 2014) Offshore Renewable Energy Development Plan (DCENR, 2014) Delivering Resource Efficiency: Northern Ireland Waste Management Strategy (DOE, 2013) Integrated Implementation Plan 2013-2018 for the Greater Dublin Area (NTA) Our Sustainable Future: A Framework for Sustainable Development for Ireland (DECLG, 2012) National Climate Change Adaptation Framework (DECLG, 2012) A Resource Opportunity: Waste Management Policy in Ireland (DECLG, 2012) Strategy for Renewable Energy 2012-2020 Grid25 Implementation Programme 2011-2016 (EirGrid, 2012) Actions for Biodiversity 2011-2016, Ireland’s National Biodiversity Plan (DAHG, 2011) National Renewable Energy Action Plan (NREAP) (DCENR, 2010) Bioenergy Roadmap (SEAI, 2010) River Basin Management Plans (2009-2015) Smarter Travel ‘A New Transport Policy for Ireland’ 2009-2020 The Planning System and Flood Risk Management Guidelines for Planning Authorities (OPW, 2009) National Climate Change Strategy 2007 – 2012 (DEHLG, 2007) National Development Plan from 2007-2013 Agri-vision 2015 Action Plan (DAFM, 2006) The National Strategy on Biodegradable Waste (DEHLG, 2006) National Heritage Plan (DAHG, 2002) National Spatial Strategy 2002-2020 (DECLG, 2002) (to be updated by the National Planning Framework) A Platform for Change: An Integrated Transportation Strategy for the Greater Dublin Area 2000 to 2016 (DTO, 2001) Renewable Energy Feed-In Tariff (REFIT) Schemes 1, 2 and 3 NPWS Conservation Plans and/or Conservation Objectives for SAC and SPAs
Whilst Table 4.8 has outlined a number of plans/ programmes which would be expected to influence, or be influenced by the AFF, there are three key plans that have direct national influence on the AFF and correspondingly the policies within AFF may influence them. These plans of national significance to the AFF include;
° National Bioenergy Plan; ° National Renewable Electricity Policy and Development Framework; and ° National Mitigation Plan.
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Table 4.9 provides an overview of the main objectives relevant to each of the plans, their timelines, the key environmental issues and the key linkages between the plans.
Table 4.9 – National Plans of Key Significance
National Renewable National Bioenergy Plan Electricity Policy and National Mitigation Plan Development Framework Department DCCCNR [formerly DCENR] DCCCNR [formerly DCENR] DoECLG 6 To optimise the Bioenergy resources opportunities for producing contributing to economic electricity from renewable Transition to a low carbon, development and sustainable energy sources in projects of climate resilient and Plan Vision/ growth, generating jobs for significant scale on land, to environmentally sustainable Objective citizens supported by serve both the All Island economy by the end of coherent policy, planning and Single Electricity Market and 2050. regulation, and managed in an any future EU regional integrated manner. market. - Biomass/ biofuel feedstock - Wind Energy (offshore & (wood/ grass/ rapeseed/ Relevant onshore) soyabean/ waste etc) - Transport Sectors/ - Hydropower Sources/ - Anaerobic digestion (biogas) - Agriculture - Solar Energy Feedstock/ -Wood boilers/ stoves - Electricity Generation Technologies/ (electricity & heat) - Aerothermal/ Geothermal/ Hydrothermal - Built Environment Outputs - Waste to Energy facilities - Bioenergy - Production of Bioethanol Reduction in carbon dioxide emissions of at least 80% (compared to 1990 levels) Contribute to 16% of gross Contribute to 16% of gross by 2050 across the final consumption from final consumption from electricity generation, built renewable sources by 2020. renewable sources by 2020. environment and transport sectors; and in parallel, an Targets This will be met through: This will be met through: 40% from electricity 40% from electricity approach to carbon neutrality in the agriculture 12% from heat 12% from heat and land-use sector, 10% from transport 10% from transport including forestry, which does not compromise capacity for sustainable food production. - Air Quality/Climate Change - Air Quality/Climate Change - Air Quality/Climate Change - - Landscape - Landscape Landuse Key SEA - Landuse - Landuse Issues - Biodiversity (afforestation/ - Population - Population land use change/ air quality) - Biodiversity - Biodiversity Draft Plan Q2/Q3 2016 Draft Plan Q2/Q3 2016 Draft Plan Q3 2016 Timescale Adopted Plan Q4 2016 Adopted Plan Q4 2016 Adopted Plan Q2 2017
6 Still to be established whether this Plan is under the Department of Communications, Climate Change and Natural Resources or the Department of Housing, Planning and Local Government
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5 CONCLUSION
The information described herein relates to the AFF. Given the strategic nature of the plan, the current stage of preparation of the plan and in light of a number of uncertainties relating to the implementation of the plan going forward, it is considered that there is potential for likely significant effects on one or more European Sites, in view of the sites conservation objectives.
For that reason, and in applying the precautionary principle, the AA process in relation to the draft AFF must proceed to Appropriate Assessment and the preparation of a Natura Impact Statement (NIS) to fully inform the Appropriate Assessment is to be undertaken by the DTTAS.
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6 REFERENCES
Council of the European Communities (1992) Council Directive of 21 May 1992 on the Conservation of Natural Habitats and of Wild Fauna and Flora (92/43/EEC). OJL 206/35, 1992
DoEHLG (2010). Appropriate Assessment of Plans and Projects in Ireland – Guidance for Planning Authorities (Department of Environment, Heritage and Local Government, Rev. Feb 2010).
DEHLG (2010a) Appropriate Assessment of Plans and Projects in Ireland. Guidance for Planning Authorities. Department of the Environment, Heritage and Local Government, Dublin.
DEHLG (2010b) Department of the Environment, Heritage and Local Government Circular NPW1/10 and PSSP 2/10 on Appropriate Assessment under Article 6 of the Habitats Directive – Guidance for Planning Authorities. Department of the Environment, Heritage and Local Government, Dublin.
Environmental Protection Agency (2011). EPA ENVision Service (online environmental information portal). http://gis.epa.ie/Envision
European Commission (2007). Guidance Document on Article 6(4) of the Habitats Directive 92/43/EEC. Clarification of the Concepts of Alternative Solutions, Imperative Reasons of Overriding Public Interest, Compensatory Measures, Overall Coherence . Opinion of the European Commission.
European Commission (2000a). Managing Natura 2000 Sites: the provisions of Article 6 of the ‘Habitats’ Directive 92/43/EEC. Office for Official Publications of the European Communities, Luxembourg.
European Commission (2000b) Communication from the Commission on the Precautionary Principle. Office for Official Publications of the European Communities, Luxembourg.
European Commission (2001). Assessment of Plans and Projects significantly affecting Natura 2000 sites: Methodological guidance on the provisions of Article 6(3) and 6(4) of the Habitats Directive 92/43/EEC (European Commission Environment Directorate-General)
European Parliament and European Council (2009). Directive 2009/147/EC of 30 th November 2009 on the Conservation of Wild Birds (2009/147/EC). Official Journal L20/7, 2010.
EU Habitats Directive (92/43/EEC)
NPWS (2010). Circular NPW 1/10 & PSSP 2/10 Appropriate Assessment under Article 6 of the Habitats Directive: Guidance for Planning Authorities. (Department of Environment, Heritage and Local Government, 2010).
MDR1224RP0003F01 21
APPENDIX A
Special Areas of Conservation, Republic of Ireland
Special Area of Conservation (SAC) Site Code Special Area of Conservation (SAC) Site Code Killyconny Bog (Cloghbally) SAC 000006 Great Island Channel SAC 001058 Lough Oughter & Associated Loughs Kilkieran Lake & Castlefreke Dunes 000007 001061 SAC SAC Ballyallia Lake SAC 000014 Myross Wood SAC 001070 Ballycullinan Lake SAC 000016 Ballyness Bay SAC 001090 Ballyogan Lough SAC 000019 Coolvoy Bog SAC 001107 Black Head-Poulsallagh Complex SAC 000020 Dunragh Loughs/Pettigo Plateau SAC 001125 Danes Hole, Poulnalecka SAC 000030 Gweedore Bay & Islands SAC 001141 Dromore Woods & Loughs SAC 000032 Kindrum Lough SAC 001151 Inagh River Estuary SAC 000036 Muckish Mountain SAC 001179 Pouladatig Cave SAC 000037 Sheephaven SAC 001190 Lough Gash Turlough SAC 000051 Termon Strand SAC 001195 Moneen Mountain SAC 000054 Keeper Hill SAC 001197 Moyree River System SAC 000057 Glenasmole Valley SAC 001209 Poulnagordon Cave (Quin) SAC 000064 Aughrusbeg Machair &Lake SAC 001228 Ballymacoda (Clonpriest & Pillmore) 000077 Courtmacsherry Estuary SAC 001230 SAC Glengarriff Harbour & Woodland SAC 000090 Carrownagappul Bog SAC 001242 Clonakilty Bay SAC 000091 Cregduff Lough SAC 001251 Caha Mountains SAC 000093 Dog's Bay SAC 001257 Lough Hyne Nature Reserve And Gortnandarragh Limestone Pavement 000097 001271 Environs SAC SAC Roaringwater Bay & Islands SAC 000101 Inisheer Island SAC 001275 Sheep's Head SAC 000102 Kiltiernan Turlough SAC 001285 St. Gobnet's Wood SAC 000106 Omey Island Machair SAC 001309 The Gearagh SAC 000108 Rusheenduff Lough SAC 001311 Three Castle Head To Mizen Head 000109 Ross Lake & Woods SAC 001312 SAC Aran Island (Donegal) Cliffs SAC 000111 Rosturra Wood SAC 001313 Ballintra SAC 000115 Termon Lough SAC 001321 Cloonee & Inchiquin Loughs, Uragh Ballyarr Wood SAC 000116 001342 Wood SAC Croaghonagh Bog SAC 000129 Mucksna Wood SAC 001371 Donegal Bay (Murvagh) SAC 000133 Ballynafagh Lake SAC 001387 Durnesh Lough SAC 000138 Rye Water Valley/Carton SAC 001398 Fawnboy Bog/Lough Nacung SAC 000140 Arroo Mountain SAC 001403 Gannivegil Bog SAC 000142 Glen Bog SAC 001430 Horn Head & Rinclevan SAC 000147 Glenstal Wood SAC 001432 Inishtrahull SAC 000154 Clogher Head SAC 001459 Lough Eske And Ardnamona Wood 000163 Clew Bay Complex SAC 001482 SAC Lough Nagreany Dunes SAC 000164 Doogort Machair/Lough Doo SAC 001497 Lough Nillan Bog (Carrickatlieve) SAC 000165 Erris Head SAC 001501 Magheradrumman Bog SAC 000168 Keel Machair/Menaun Cliffs SAC 001513 Lough Cahasy, Lough Baun & Roonah Meenaguse/Ardbane Bog SAC 000172 001529 Lough SAC Meentygrannagh Bog SAC 000173 Mocorha Lough SAC 001536 Curraghchase Woods SAC 000174 Castletownshend SAC 001547 Rathlin O'Birne Island SAC 000181 Urlaur Lakes SAC 001571 Sessiagh Lough SAC 000185 Castlesampson Esker SAC 001625 Annaghmore Lough (Roscommon) Slieve League SAC 000189 001626 SAC Slieve Tooey/Tormore 000190 Four Roads Turlough SAC 001637
Special Area of Conservation (SAC) Site Code Special Area of Conservation (SAC) Site Code Island/Loughros Beg Bay SAC Bricklieve Mountains & Keishcorran St. John's Point SAC 000191 001656 SAC Knockalongy & Knockachree Cliffs Tranarossan & Melmore Lough SAC 000194 001669 SAC West Of Ardara/Maas Road SAC 000197 Lough Arrow SAC 001673 Baldoyle Bay SAC 000199 Streedagh Point Dunes SAC 001680 Howth Head SAC 000202 Liskeenan Fen SAC 001683 Kilmuckridge-Tinnaberna Sandhills Lambay Island SAC 000204 001741 SAC Malahide Estuary SAC 000205 Kilpatrick Sandhills SAC 001742 North Dublin Bay SAC 000206 Holdenstown Bog SAC 001757 Rogerstown Estuary SAC 000208 Magherabeg Dunes SAC 001766 South Dublin Bay SAC 000210 Lough Carra/Mask Complex SAC 001774 Inishmaan Island SAC 000212 Pilgrim's Road Esker SAC 001776 Inishmore Island SAC 000213 Kilroosky Lough Cluster SAC 001786 White Lough, Ben Loughs & Lough River Shannon Callows SAC 000216 001810 Doo SAC Coolcam Turlough SAC 000218 Lough Forbes Complex SAC 001818 Barroughter Bog SAC 000231 Split Hills &Long Hill Esker SAC 001831 Caherglassaun Turlough SAC 000238 Philipston Marsh SAC 001847 Castletaylor Complex SAC 000242 Galmoy Fen SAC 001858 Cloonmoylan Bog SAC 000248 Derryclogher (Knockboy) Bog SAC 001873 Coole-Garryland Complex SAC 000252 Glanmore Bog SAC 001879 Croaghill Turlough SAC 000255 Meenaguse Scragh SAC 001880 Derrycrag Wood Nature Reserve SAC 000261 Maulagowna Bog SAC 001881 Galway Bay Complex SAC 000268 Mullaghanish Bog SAC 001890 Inishbofin & Inishshark SAC 000278 Unshin River SAC 001898 Kilsallagh Bog SAC 000285 Cloonakillina Lough SAC 001899 Kiltartan Cave (Coole) SAC 000286 Glendree Bog SAC 001912 Levally Lough SAC 000295 Sonnagh Bog SAC 001913 Lisnageeragh Bog & Ballinastack 000296 Glenade Lough SAC 001919 Turlough SAC Lough Corrib SAC 000297 Bellacorick Bog Complex SAC 001922 Lough Cutra SAC 000299 East Burren Complex SAC 001926 Lough Lurgeen Bog/Glenamaddy Mweelrea/Sheeffry/Erriff Complex 000301 001932 Turlough SAC SAC Lough Rea SAC 000304 Comeragh Mountains SAC 001952 Loughatorick South Bog SAC 000308 Croaghaun/Slievemore SAC 001955 Peterswell Turlough SAC 000318 Boyne Coast & Estuary SAC 001957 Pollnaknockaun Wood Nature Ballyhoorisky Point To Fanad Head 000319 001975 Reserve SAC SAC Rahasane Turlough SAC 000322 Lough Gill SAC 001976 Rosroe Bog SAC 000324 Tamur Bog SAC 001992 Shankill West Bog SAC 000326 Bellacragher Saltmarsh SAC 002005 Slyne Head Islands SAC 000328 Ox Mountains Bogs SAC 002006 Tully Mountain SAC 000330 Maumturk Mountains SAC 002008 Akeragh, Banna & Barrow Harbour 000332 Old Domestic Building (Keevagh) SAC 002010 SAC Ballinskelligs Bay &Inny Estuary SAC 000335 North Inishowen Coast SAC 002012 The Twelve Bens/Garraun Complex Castlemaine Harbour SAC 000343 002031 SAC Old Domestic Building, Dromore 000353 Boleybrack Mountain SAC 002032
Special Area of Conservation (SAC) Site Code Special Area of Conservation (SAC) Site Code Wood SAC Kilgarvan Ice House SAC 000364 Connemara Bog Complex SAC 002034 Killarney National Park, Macgillycuddy's Reeks & Caragh River 000365 Ballyhoura Mountains SAC 002036 Catchment SAC Lough Yganavan & Lough 000370 Carrigeenamronety Hill SAC 002037 Nambrackdarrig SAC Old Domestic Building, Curraglass Mount Brandon SAC 000375 002041 Wood SAC Cloghernagore Bog & Glenveagh Sheheree (Ardagh) Bog SAC 000382 002047 National Park SAC Tralee Bay & Magharees Peninsula, Ballynafagh Bog SAC 000391 002070 West To Cloghane SAC Pollardstown Fen SAC 000396 Slyne Head Peninsula SAC 002074 Red Bog, Kildare SAC 000397 Ballinafad SAC 002081 Hugginstown Fen SAC 000404 Newhall & Edenvale Complex SAC 002091 Old Domestic Building, Askive Wood The Loughans SAC 000407 002098 SAC Slieve Bloom Mountains SAC 000412 Corliskea/Trien/Cloonfelliv Bog SAC 002110 Lough Melvin SAC 000428 Kilkieran Bay & Islands SAC 002111 Barrigone SAC 000432 Ballyseedy Wood SAC 002112 Tory Hill SAC 000439 Lough Coy SAC 002117 Lough Ree SAC 000440 Barnahallia Lough SAC 002118 Fortwilliam Turlough SAC 000448 Lough Nageeron SAC 002119 Carlingford Mountain SAC 000453 Lough Bane & Lough Glass SAC 002120 Dundalk Bay SAC 000455 Lough Lene SAC 002121 Killala Bay/Moy Estuary SAC 000458 Wicklow Mountains SAC 002122 Ardkill Turlough SAC 000461 Ardmore Head SAC 002123 Balla Turlough SAC 000463 Bolingbrook Hill SAC 002124 Bellacorick Iron Flush SAC 000466 Anglesey Road SAC 002125 Mullet/Blacksod Bay Complex SAC 000470 Pollagoona Bog SAC 002126 Brackloon Woods SAC 000471 Murvey Machair SAC 002129 Broadhaven Bay SAC 000472 Tully Lough SAC 002130 Ballymaglancy Cave, Cong SAC 000474 Lough Nageage SAC 002135 Carrowkeel Turlough SAC 000475 Lower River Suir SAC 002137 Carrowmore Lake Complex SAC 000476 Mountmellick SAC 002141 Cloughmoyne SAC 000479 Newport River SAC 002144 Clyard Kettle-Holes SAC 000480 Lisduff Fen SAC 002147 Cross Lough (Killadoon) SAC 000484 Newgrove House SAC 002157 Corraun Plateau SAC 000485 Kenmare River SAC 002158 Doocastle Turlough SAC 000492 Mulroy Bay SAC 002159 Duvillaun Islands SAC 000495 Long Bank SAC 002161 Flughany Bog SAC 000497 River Barrow & River Nore SAC 002162 Glenamoy Bog Complex SAC 000500 Lough Golagh & Breesy Hill SAC 002164 Greaghans Turlough SAC 000503 Lower River Shannon SAC 002165 Kilglassan/Caheravoostia Turlough Blackwater River (Cork/Waterford) 000504 002170 Complex SAC SAC Inishkea Islands SAC 000507 Bandon River SAC 002171 Lackan Saltmarsh & Kilcummin Head 000516 Blasket Islands SAC 002172 SAC Lough Gall Bog SAC 000522 Blackwater River (Kerry) SAC 002173 Shrule Turlough SAC 000525 Leannan River SAC 002176 Moore Hall (Lough Carra) SAC 000527 Lough Dahybaun SAC 002177
Special Area of Conservation (SAC) Site Code Special Area of Conservation (SAC) Site Code Oldhead Wood SAC 000532 Towerhill House SAC 002179 Owenduff/Nephin Complex SAC 000534 Gortacarnaun Wood SAC 002180 Skealoghan Turlough SAC 000541 Drummin Wood SAC 002181 Slieve Fyagh Bog SAC 000542 Slieve Mish Mountains SAC 002185 All Saints Bog & Esker SAC 000566 Drongawn Lough SAC 002187 Charleville Wood SAC 000571 Farranamanagh Lough SAC 002189 Clara Bog SAC 000572 Ireland's Eye SAC 002193 Ferbane Bog SAC 000575 Glenloughaun Esker SAC 002213 Fin Lough (Offaly) SAC 000576 Killeglan Grassland SAC 002214 Mongan Bog SAC 000580 Island Fen SAC 002236 Moyclare Bog SAC 000581 Lough Derg, North-East Shore SAC 002241 Raheenmore Bog SAC 000582 Clare Island Cliffs SAC 002243 Cuilcagh - Anierin Uplands SAC 000584 Ardrahan Grassland SAC 002244 Old Farm Buildings, Ballymacrogan Sharavogue Bog SAC 000585 002245 SAC Ballycullinan, Old Domestic Building Ballinturly Turlough SAC 000588 002246 SAC Bellanagare Bog SAC 000592 Toonagh Estate SAC 002247 Callow Bog SAC 000595 The Murrough Wetlands SAC 002249 Carrowbehy/Caher Bog SAC 000597 Carrowmore Dunes SAC 002250 Cloonchambers Bog SAC 000600 Thomastown Quarry SAC 002252 Derrinea Bog SAC 000604 Ballyprior Grassland SAC 002256 Lough Fingall Complex SAC 000606 Moanour Mountain SAC 002257 Errit Lough SAC 000607 Silvermines Mountains West SAC 002258 Lisduff Turlough SAC 000609 Tory Island Coast SAC 002259 Lough Croan Turlough SAC 000610 Magharee Islands SAC 002261 Valencia Harbour/Portmagee Lough Funshinagh SAC 000611 002262 Channel SAC Mullygollan Turlough SAC 000612 Kerry Head Shoal SAC 002263 Cloonshanville Bog SAC 000614 Kilkee Reefs SAC 002264 Ballysadare Bay SAC 000622 Kingstown Bay SAC 002265 Ben Bulben, Gleniff & Glenade 000623 Achill Head SAC 002268 Complex SAC Bunduff Lough &Machair/Trawalua/Mullaghmore 000625 Carnsore Point SAC 002269 SAC Cummeen Strand/Drumcliff Bay 000627 Wicklow Reef SAC 002274 (Sligo Bay) SAC Lough Hoe Bog SAC 000633 Askeaton Fen Complex SAC 002279 Lough Nabrickkeagh Bog SAC 000634 Dunbeacon Shingle SAC 002280 Templehouse And Cloonacleigha 000636 Reen Point Shingle SAC 002281 Loughs SAC Turloughmore (Sligo) SAC 000637 Rutland Island & Sound SAC 002283 Union Wood SAC 000638 Lough Swilly SAC 002287 Carrowbaun, Newhall And Ballylee Ballyduff/Clonfinane Bog SAC 000641 002293 Turloughs SAC Galtee Mountains SAC 000646 Cahermore Turlough SAC 002294 Kilcarren-Firville Bog SAC 000647 Ballinduff Turlough SAC 002295 Helvick Head SAC 000665 Williamstown Turloughs SAC 002296 Nier Valley Woodlands SAC 000668 River Moy SAC 002298 Tramore Dunes & Backstrand SAC 000671 River Boyne & River Blackwater SAC 002299 Garriskil Bog SAC 000679 River Finn SAC 002301 Lough Ennell SAC 000685 Dunmuckrum Turloughs SAC 002303
Special Area of Conservation (SAC) Site Code Special Area of Conservation (SAC) Site Code Lough Owel SAC 000688 Carlingford Shore SAC 002306 Scragh Bog SAC 000692 Slieve Bernagh Bog SAC 002312 Ballyteige Burrow SAC 000696 Ballymore Fen SAC 002313 Bannow Bay SAC 000697 Old Domestic Buildings, Rylane SAC 002314 Cahore Polders & Dunes SAC 000700 Glanlough Woods SAC 002315 Lady's Island Lake SAC 000704 Ratty River Cave SAC 002316 Saltee Islands SAC 000707 Cregg House Stables, Crusheen SAC 002317 Screen Hills SAC 000708 Knockanira House SAC 002318 Tacumshin Lake SAC 000709 Kilkishen House SAC 002319 Raven Point Nature Reserve SAC 000710 Kildun Souterrain SAC 002320 Ballyman Glen SAC 000713 Glendine Wood SAC 002324 Bray Head SAC 000714 Mouds Bog SAC 002331 Carriggower Bog SAC 000716 Coolrain Bog SAC 002332 Deputy's Pass Nature Reserve SAC 000717 Knockacoller Bog SAC 002333 Glen Of The Downs SAC 000719 Carn Park Bog SAC 002336 Knocksink Wood SAC 000725 Crosswood Bog SAC 002337 Buckroney-Brittas Dunes & Fen SAC 000729 Drumalough Bog SAC 002338 Vale Of Clara (Rathdrum Wood) SAC 000733 Ballynamona Bog & Corkip Lough SAC 002339 Hook Head SAC 000764 Moneybeg & Clareisland Bogs SAC 002340 Blackstairs Mountains SAC 000770 Ardagullion Bog SAC 002341 Slaney River Valley SAC 000781 Mount Hevey Bog SAC 002342 Cullahill Mountain SAC 000831 Tullaher Lough & Bog SAC 002343 Spahill & Clomantagh Hill SAC 000849 Brown Bog SAC 002346 Clonaslee Eskers & Derry Bog SAC 000859 Camderry Bog SAC 002347 Lisbigney Bog SAC 000869 Clooneen Bog SAC 002348 Ridge Road, SW Of Rapemills SAC 000919 Corbo Bog SAC 002349 The Long Derries, Edenderry SAC 000925 Curraghlehanagh Bog SAC 002350 Clare Glen SAC 000930 Moanveanlagh Bog SAC 002351 Kilduff, Devilsbit Mountain SAC 000934 Monivea Bog SAC 002352 Silvermine Mountains SAC 000939 Redwood Bog SAC 002353 Corratirrim SAC 000979 Tullaghanrock Bog SAC 002354 Ballyteige (Clare) SAC 000994 Ardgraigue Bog SAC 002356 Ballyvaughan Turlough SAC 000996 Blackwater Bank SAC 002953 Glenomra Wood SAC 001013 West Connacht Coast SAC 002998 Carrowmore Point To Spanish Point & 001021 Hemptons Turbot Bank SAC 002999 Islands SAC Barley Cove To Ballyrisode Point SAC 001040 Rockabill to Dalkey Island SAC 003000 Cleanderry Wood SAC 001043 Codling Fault Zone SAC 003015
APPENDIX B Special Protection Areas, Republic of Ireland
Special Protection Area (SPA) Site Code Special Protection Area (SPA) Site Code Saltee Islands SPA 004002 Pettigo Plateau Nature Reserve SPA 004099 Puffin Island SPA 004003 Inishtrahull SPA 004100 Inishkea Islands SPA 004004 Ballykenny-Fisherstown Bog SPA 004101 Cliffs of Moher SPA 004005 Garriskil Bog SPA 004102 North Bull Island SPA 004006 All Saints Bog SPA 004103 Skelligs SPA 004007 Bellanagare Bog SPA 004105 Blasket Islands SPA 004008 Coole-Garryland SPA 004107 Lady's Island Lake SPA 004009 Eirk Bog SPA 004108 Drumcliff Bay SPA 004013 The Gearagh SPA 004109 Rockabill SPA 004014 Lough Nillan Bog SPA 004110 Rogerstown Estuary SPA 004015 Duvillaun Islands SPA 004111 Baldoyle Bay SPA 004016 Howth Head Coast SPA 004113 Mongan Bog SPA 004017 Illaunonearaun SPA 004114 The Raven SPA 004019 Inishduff SPA 004115 Ballyteigue Burrow SPA 004020 Inishkeel SPA 004116 Old Head of Kinsale SPA 004021 Ireland's Eye SPA 004117 Ballycotton Bay SPA 004022 Keeragh Islands SPA 004118 Ballymacoda Bay SPA 004023 Loop Head SPA 004119 South Dublin Bay and River Tolka 004024 Rathlin O'Birne Island SPA 004120 Estuary SPA Broadmeadow/Swords Estuary SPA 004025 Roaninish SPA 004121 Dundalk Bay SPA 004026 Skerries Islands SPA 004122 Tramore Back Strand SPA 004027 Sovereign Islands SPA 004124 Blackwater Estuary SPA 004028 Magharee Islands SPA 004125 Castlemaine Harbour SPA 004029 Wicklow Head SPA 004127 Cork Harbour SPA 004030 Ballysadare Bay SPA 004129 Inner Galway Bay SPA 004031 Illancrone and Inishkeeragh SPA 004132 Dungarvan Harbour SPA 004032 Aughris Head SPA 004133 Bannow Bay SPA 004033 Lough Rea SPA 004134 Ardboline Island and Horse Island Trawbreaga Bay SPA 004034 004135 SPA Cummeen Strand SPA 004035 Clare Island SPA 004136 Killala Bay/Moy Estuary SPA 004036 Dovegrove Callows SPA 004137 Blacksod Bay/Broadhaven SPA 004037 Lough Croan Turlough SPA 004139 Killarney National Park SPA 004038 Four Roads Turlough SPA 004140 Derryveagh And Glendowan 004039 Cregganna Marsh SPA 004142 Mountains SPA Wicklow Mountains SPA 004040 Cahore Marshes SPA 004143 High Island, Inishshark and Davillaun Ballyallia Lough SPA 004041 004144 SPA Lough Corrib SPA 004042 Durnesh Lough SPA 004145 Lough Derravaragh SPA 004043 Malin Head SPA 004146 Lough Ennell SPA 004044 Fanad Head SPA 004148 Glen Lough SPA 004045 Falcarragh to Meenlaragh SPA 004149 Lough Iron SPA 004046 West Donegal Coast SPA 004150 Lough Owel SPA 004047 Donegal Bay SPA 004151 Lough Gara SPA 004048 Inishmore SPA 004152 Lough Oughter SPA 004049 Dingle Peninsula SPA 004153 Lough Arrow SPA 004050 Iveragh Peninsula SPA 004154 Lough Carra SPA 004051 Beara Peninsula SPA 004155 Carrowmore Lake SPA 004052 Sheep's Head to Toe Head SPA 004156 Lough Cutra SPA 004056 River Nanny Estuary and Shore SPA 004158
Special Protection Area (SPA) Site Code Special Protection Area (SPA) Site Code Slyne Head To Ardmore Point Islands Lough Derg (Donegal) SPA 004057 004159 SPA Lough Derg (Shannon) SPA 004058 Slieve Bloom Mountains SPA 004160 Stack's to Mullaghareirk Mountains, Lough Fern SPA 004060 West Limerick Hills and Mount Eagle 004161 SPA Mullaghanish to Musheramore Lough Kinale and Derragh Lough SPA 004061 004162 Mountains SPA Slievefelim to Silvermines Mountains Lough Mask SPA 004062 004165 SPA Poulaphouca Reservoir SPA 004063 Slieve Beagh SPA 004167 Lough Ree SPA 004064 Slieve Aughty Mountains SPA 004168 Lough Sheelin SPA 004065 Cruagh Island SPA 004170 The Bull and The Cow Rocks SPA 004066 Dalkey Islands SPA 004172 Inishmurray SPA 004068 Deenish Island and Scariff Island SPA 004175 Lambay Island SPA 004069 Bills Rocks SPA 004177 Stags of Broad Haven SPA 004072 Connemara Bog Complex SPA 004181 Tory Island SPA 004073 Mid-Clare Coast SPA 004182 Illanmaster SPA 004074 The Murrough SPA 004186 Lough Swilly SPA 004075 Sligo/Leitrim Uplands SPA 004187 Wexford Harbour and Slobs SPA 004076 Tralee Bay Complex SPA 004188 River Shannon and River Fergus 004077 Kerry Head SPA 004189 Estuaries SPA Carlingford Lough SPA 004078 Galley Head to Duneen Point SPA 004190 Boyne Estuary SPA 004080 Seven Heads SPA 004191 Clonakilty Bay SPA 004081 Helvick Head to Ballyquin SPA 004192 Greers Isle SPA 004082 Mid-Waterford Coast SPA 004193 Inishbofin, Inishdooey and Inishbeg 004083 Horn Head to Fanad Head SPA 004194 SPA Inishglora and Inishkeeragh SPA 004084 Cross Lough (Killadoon) SPA 004212 River Little Brosna Callows SPA 004086 Courtmacsherry Bay SPA 004219 Lough Foyle SPA 004087 Corofin Wetlands SPA 004220 Rahasane Turlough SPA 004089 Illaunnanoon SPA 004221 Sheskinmore Lough SPA 004090 Mullet Peninsula SPA 004227 Stabannan-Braganstown SPA 004091 Lough Conn and Lough Cullin SPA 004228 Tacumshin Lake SPA 004092 West Donegal Islands SPA 004230 Termoncarragh Lake and Annagh Inishbofin, Omey Island and Turbot 004093 004231 Machair SPA Island SPA River Boyne and River Blackwater Blackwater Callows SPA 004094 004232 SPA Kilcolman Bog SPA 004095 River Nore SPA 004233 Middle Shannon Callows SPA 004096 Ballintemple and Ballygilgan SPA 004234 River Suck Callows SPA 004097 Doogort Machair SPA 004235 Owenduff/Nephin Complex SPA 004098
APPENDIX C Special Areas of Conservation, Northern Ireland
Special Area of Conservation (SAC) Site Code Special Area of Conservation (SAC) Site Code Ballynahone Bog UK0016599 Main Valley Bogs UK0030199 Cuilcagh Mountain UK0016603 Moneygal Bog UK0030211 Garron Plateau UK0016606 Moninea Bog UK0030212 Pettigoe Plateau UK0016607 Montiaghs Moss UK0030214 Teal Lough UK0016608 North Antrim Coast UK0030224 Black Bog UK0016609 Owenkillew River UK0030233 Garry Bog UK0016610 Peatlands Park UK0030236 Fairy Water Bogs UK0016611 Rea’s Wood and Farr’s Bay UK0030244 Murlough UK0016612 Rostrevor Wood UK0030268 Magilligan UK0016613 Slieve Gullion UK0030277 Upper Lough Erne UK0016614 Turmennan UK0030291 Eastern Mournes UK0016615 Upper Ballinderry River UK0030296 Strangford Lough UK0016618 West Fermanagh Scarplands UK0030300 Monawilkin UK0016619 Wolf Island Bog UK0030303 Derryleckagh UK0016620 Aughnadarragh Lough UK0030318 Magheraveely Marl Loughs UK0016621 Ballykilbeg UK0030319 Slieve Beagh UK0016622 River Foyle and Tributaries UK0030320 Largalinny UK0030045 Cranny Bogs UK0030321 Lough Melvin UK0030047 Curran Bog UK0030322 Rathlin Island UK0030055 Dead Island Bog UK0030323 Fardrum and Roosky Turloughs UK0030068 Deroran Bog UK0030324 Banagher Glen UK0030083 Tully Bog UK0030326 Bann Estuary UK0030084 Tonnagh Beg Bog UK0030352 Binevenagh UK0030089 River Roe and Tributaries UK0030360 Breen Wood UK0030097 River Faughan and Tributaries UK0030361 Carn-Glenshane Pass UK0030110 Red Bay UK0030365 Cladagh (Swanlinbar) River UK0030116 Skerries and Causeway UK0030383 Hollymount UK0030169 The Maidens UK0030384 Lecale Fens UK0030180
APPENDIX D Special Protection Areas, Northern Ireland
Special Protection Area (SPA) Site Code Rathlin Island UK9020011 Sheep Island UK9020021 Lough Foyle UK9020031 Pettigoe Plateau UK9020051 Upper Lough Erne UK9020071 Lough Neagh and Lough Beg UK9020091 Belfast Lough UK9020101 Strangford Lough UK9020111 Carlingford Lough UK9020161 Larne Lough UK9020042 Killough Bay UK9020221 Outer Ards UK9020271 Belfast Lough Open Water UK9020290 Copeland Islands UK9020291 Antrim Hills UK9020301 Slieve Beagh-Mullaghfad-Lisnaskea UK9020302
APPENDIX G EU Condition Assessment
Conservation Habitat Name* Code Conservation Status 2013 (and Trend) Status 2007 Favourable. Sandbanks 1110 Inadequate Improvement owing to decline in pressures. Unfavourable-Inadequate. Estuary 1130 Inadequate Trend is likely improvement in habitat condition in the future. Mudflats and Sandflats no Unfavourable-Inadequate. covered by seawater at low 1140 Inadequate Trend is likely improvement in habitat condition in tide the future. Unfavourable-Bad. Lagoons * 1150 Bad No change since previous assessment period. Unfavourable-Inadequate. Large Shallow Inlets and Bays 1160 Inadequate Although inadequate, trend is considered to be improvement. Unfavourable-Bad. Reefs 1170 Inadequate Declining as there is no indication that current pressures will reduce in the future. Unfavourable-Inadequate. Annual vegetation of drift lines 1210 Inadequate Declining owing to loss of area and impairment of structure & functions. Perennial vegetation of drift Unfavourable-Inadequate. Trend is stable (e.g. no 1220 Inadequate lines change) Unfavourable-Inadequate. Vegetated seacliffs of the 1230 Inadequate Trend is estimated as stable though potential Atlantic and Baltic coasts impacts of climate change may pose a more serious threat. Unfavourable-Inadequate. Salicornia and other annuals 1310 Inadequate colonising mud and sand Trend is estimated as declining owing to on-going spread of common cordgrass. No Assessment given owing to the non-native nature Spartina Swards (Spartinion) 1320 Bad (in Ireland) of this habitat. Unfavourable-Inadequate. Atlantic salt meadows (Glauco- 1330 Inadequate Puccinellietalia maritimae) Trend is stable though grazing levels may impact habitat condition. Unfavourable-Inadequate. Mediterranean salt meadows 1410 Inadequate (Juncetalia maritimi) Trend is stable though grazing levels may impact habitat condition. Unfavourable-Bad. Halophlilous Scrub 1420 Bad Trend is declining owing to habitat vulnerability and losses. Unfavourable-Inadequate. Embryonic shifting dunes 2110 Inadequate Trend is Stable (negligible national loss of Area). Shifting dunes along the Unfavourable-Inadequate. shoreline with Ammophila 2120 Bad Trend is stable (no real change, owing to differing arenaria (“white dunes”) assessment methodology). Fixed coastal dunes with Unfavourable-Bad. herbaceous vegetation (grey 2130 Bad Trend is stable (no change in recreational pressures dunes) * and grazing levels including undergrazing). Unfavourable-Inadequate. Decalcified Empetrum Dunes * 2140 Bad Trend is slight improvement related to change in interpretation criteria.
Conservation Habitat Name* Code Conservation Status 2013 (and Trend) Status 2007 Unfavourable-Inadequate. Decalcified dune Heath * 2150 Bad Trend is slight improvement related to change in interpretation criteria. Unfavourable-Inadequate. Dunes with Creeping Willow 2170 Inadequate Trend is stable due to no apparent overall change in management pressures. Unfavourable-Inadequate. Humid dune slacks 2190 Bad Declining in view of the ongoing pressures and threats. Unfavourable-Bad. Machair * 21A0 Bad Trend is stable (negligible national loss of Area and habitat compromise due to management regimes). Unfavourable-Bad. Oligotrophic soft water Lakes 3110 Bad Trend is declining owing to eutrophication. Soft water lakes with base-rich Unfavourable-Inadequate. 3130 Bad influences Change to improved ecological analysis. Unfavourable-Bad. Hard water lakes 3140 Bad Trend is declining owing to continued pollution events. Unfavourable-Inadequate. Natural eutrophic lakes 3150 Bad Trend is stable, with change in status due to improved ecological analysis. Unfavourable-Inadequate. Dystrophic lakes 3160 Bad Trend is declining but change of assessment due to better ecological understanding of the distribution and ecological requirements of this habitat. Unfavourable-Inadequate. Turloughs * 3180 Inadequate Trend is stable but threats still remain. Unfavourable-Inadequate. Floating river vegetation 3260 Bad Trend is declining but change of assessment due to better ecological understanding of the distribution and ecological requirements of this habitat. Favourable Chenopdium rubri 3270 Favourable Trend is considered stable but further work required to improve understanding. Unfavourable-Bad. Wet Heath 4010 Bad Trend is stable owing to stocking reductions compensating for habitat loss. Unfavourable-Bad. European dry heaths 4030 Inadequate Trend is declining owing to differing assessment methodology and greater information. Inadequate (on hindsight the Unfavourable-Bad. Alpine and subalpine heath 4060 assessment Trend is improving owing to improvements in should have been management. bad) Unfavourable-Inadequate. Juniper scrub 5130 Inadequate Trend is stable owing to no apparent change in circumstances or condition. Unfavourable-Inadequate. Calaminarian grassland 6130 Inadequate Trend is stable and better understanding should feed
Conservation Habitat Name* Code Conservation Status 2013 (and Trend) Status 2007 into improved management regimes. Unfavourable-Bad. Orchid-rich calcareous 6210 Bad grassland * Trend is stable but no change in pressures in near future. Unfavourable-Bad. Species-rich Nardus upland 6230 Bad grassland * Trend is declining owing to losses from non- compatible land uses. Unfavourable-Bad. Molinia Meadows 6410 Bad Trend is declining owing to abandonment of management scrub encroachment. Inadequate (on hindsight the Unfavourable-Bad. Hydrophillous tall herb 6430 assessment Trend is declining despite its marginal extent owing should have been to reclamation. bad) Unfavourable-Bad. Lowland Hay meadows 6510 Bad Trend is stable owing to no overall change in extent of management. Unfavourable-Bad. Raised Bog (active) * 7110 Bad Trend is declining owing to ongoing extraction and drying out. Limited trials of drain blocking are showing signs of success. Unfavourable-Bad. Inadequate Degraded Raised Bog 7120 Trend is declining owing to loss of extent and habitat
degradation. Unfavourable-Bad. Blanket Bog (active) * 7130 Bad Trend is declining owing to loss of extent and habitat degradation. Unfavourable-Bad. Transition Mires 7140 Bad Trend is unconfirmed owing to lack of nationwide scientific data. Unfavourable-Inadequate. Rhynchosprion Depressions 7150 Favourable Trend is declining owing to habitat changes and species loss. Unfavourable-Bad. Cladium Fen * 7210 Bad Trend is unconfirmed owing to lack of nationwide scientific data. Unfavourable-Inadequate. Petrifying Springs * 7220 Bad Trend is stable but pressures and poor management regimes remain. Unfavourable-Bad. Alkaline Fen 7230 Bad Trend is unconfirmed owing to lack of nationwide scientific data. Unfavourable-Inadequate. Siliceous Scree 8110 Inadequate Trend is improving owing to implementation of commonage framework plans. Unfavourable-Inadequate. Eutric Scree 8120 Inadequate Trend is stable with no change. Unfavourable-Inadequate. Calcareous rocky slopes 8210 Inadequate Trend is stable although grazing levels can impair quality.
Conservation Habitat Name* Code Conservation Status 2013 (and Trend) Status 2007 Unfavourable-Inadequate. Siliceous rocky slopes 8220 Inadequate Trend is stable although grazing, recreation and spread of invasive species continue. Unfavourable-Inadequate. Limestone Pavement * 8240 Inadequate Trend is stable owing to management measures to control losses. Favourable. Caves 8310 Favourable Additional research required to understand structure and subterranean climatic conditions. Favourable. Sea Caves 8330 Favourable Trend is stable as no significant pressures. Unfavourable-Bad. Old Oak Woodlands 91A0 Bad Trend is improving due in part to considerable management effort to rehabilitate habitat. Favourable. Bog Woodland * 91D0 Inadequate Trend is improving owing to better understanding of, and subsequent increase in extent. Unfavourable-Bad. Residual Alluvial Forests * 91E0 Bad Trend is improving owing to level of rehabilitation to date. Unfavourable-Bad. Taxus baccata woods* 91J0 Bad Trend is improving to increase area and curtail threatening impacts. Submarine structures made by 1180 N/A Natura 2000 dataform suggests Good leaking gases * Indicates priority habitat under the Habitats Directive
Conservation Species Code Conservation Status 2013 (and Trend) Status 2007 Killarney Fern Favourable. 1421 Favourable (Trichomanes speciosum) Trend is stable with no significant impact. Marsh Saxifrage Favourable. 1528 Favourable (Saxifaga granulata) Trend is stable with no significant impact. Unfavourable-Inadequate. Slender Naiad (Najas flexilis) 1833 Inadequate Trend is stable but eutrophication remains an issue. Slender Green Feather Moss Favourable. 1393 Favourable (Hamatocaulis vernicosus) Trend is stable with no significant impact. Petalwort Favourable. 1395 Favourable (Petalophyllum ralfsii) Trend is stable with no significant impact. Unfavourable-Inadequate. Maërl Trend is improving due to genuine 1376 Inadequate improvement. Fishing and aquaculture related (Lithothamnion corralloides) activities are not considered to be a threat to these species in the future.
Unfavourable-Inadequate. Maërl Trend is improving due to genuine 1377 Inadequate improvement. Fishing and aquaculture related (Phymatolithon calcareum) activities are not considered to be a threat to these species in the future. Favourable. White cushion moss 1400 Inadequate No genuine change but it is widespread, occurs (Leucobryum glaucum) in many habitat types and is not under pressure or threat directly. Unfavourable-Inadequate. No change in trend. Condition of habitats Sphagnum genus 1409 Inadequate considered to be poor due to peat extraction, drainage, eutrophication and ecologically unsuitable grazing. Unfavourable-Inadequate. No change in trend. Condition of habitats Lycopodium group 1413 Inadequate considered to be poor due to peat extraction, drainage, eutrophication and ecologically unsuitable grazing. Unfavourable-Inadequate. No change in trend. Condition of habitats Cladonia subgenus cladina 1378 Inadequate considered to be poor due to peat extraction, drainage, eutrophication and ecologically unsuitable grazing. Unfavourable-Inadequate. Geyers whorl snail 1013 Inadequate Genuine decline in trend with losses not fully (Vertigo geyeri) understood. Sites for species fragile and easily damaged. Unfavourable-Inadequate. Narrow-mouthed whorl snail 1014 Inadequate (Vertigo angustoir) Genuine decline in trend due to changes in grazing and wetland drainage. Unfavourable-Inadequate. Desmoulins Whorl Snail Decline in trend. Genuine losses of population 1016 Bad in the last assessment period through (Vertigo moulinsiana) succession and drying out of wetlands have not been recovered. Favourable. Kerry Slug 1024 Favourable Trend stable. No evidence of decline, habitats (Geomacalus maculosus) remain in good condition. Unfavourable-Bad. Freshwater Pearl Mussel 1029 Bad Decline in trend. Wide variety of sources of (Margaritifera margaritifera) sediment and nutrients entering mussel rivers. Direct impacts from in-stream works. Unfavourable-Bad. Irish Freshwater Pearl Mussel Decline in trend. Despite significant 1990 Bad (Margaritifera durrovensis) conservation efforts it is unlikely that the habitat will be restored before the extinction of the wild population.
Unfavourable-Inadequate. White-Clawed Crayfish 1092 Inadequate (Austropotambius pallipes) Trend is stable. Threat from disease introduction is severe and unlikely to disappear. Unfavourable-Inadequate. Marsh Fritillary Inadequate Decline in trend. Appropriate measures need to (Euphydryas aurinia) be taken to reduce pressures. Unfavourable-Bad. Sea Lamprey 1095 Inadequate Trend is stable. Decline in status due to (Petromyzon marinus) improved knowledge. Low number of juveniles due to barriers to migration. Favourable. River Lamprey 1099 Favourable No change. Extensive areas of suitable habitat (Lampetra fluviatilis) and no significant pressures. Favourable. Brook Lamprey 1096 Favourable No change. Extensive areas of suitable habitat (Lampetra planeri) and no significant pressures. Favourable. Killarney Shad 5046 Favourable No change. Species maintaining robust (Alosa fallax killarnensis) population and habitat favourable. Unfavourable-Bad. Twaite Shad 1103 Bad Trend stable, approach refined. Concerns about (Alosa fallax fallax) habitat quality at spawning sites and hybridisation with Allis Shad. Unfavourable-Bad. No change in trend. Pressures identified Pollan 5076 Bad include depletion of oxygen through (Coregonus autumnalis) enrichment, introduced species competing for food and the presence of Zebra mussels and Asian clams. Unfavourable-Inadequate. Atlantic Salmon 1106 Bad Trend stable, no genuine change. This is due to (Salmo salar) threats to habitat quality and low populations compared to previous years. Unfavourable-Bad. Natterjack Toad 1202 Bad Trend improved due to investment in pond (Bufo calamita) creation increasing available habitat. Favourable. Common Frog 1213 Inadequate No trend change but improved status due to (Rana temporaria) better understanding of how frogs use the Irish landscape. Unknown. Leatherback Turtle 1223 Inadequate Full assessment not possible due to significant (Dermochelys coriacea) difficulties associated with studying the species. Favourable. Lesser Horseshoe Bat 1303 Favourable Trend is stable. Significant proportion of (Rhinolophus hipposideros) summer and winter roosts protected within SACs. Increased population.
Favourable. Common Pipistrelle 1309 Favourable Trend is stable. Population stable, possibly (Pipistrellus pipistrellus) increasing. Soprano Pipistrelle Favourable. 5009 Favourable (Pipistrellus pygmaeus) Trend is stable. Population increasing. Nathusius’ Pipistrelle Unknown. 1317 Favourable (Pipistrelle nathusii) Unknown due to uncertain data. Favourable. Natterer’s Bat 1322 Favourable Trend is stable. Area of suitable habitat (Myotis nattereri) increasing. Daubenton’s Bat Favourable. 1314 Favourable (Myotis daubentonii) Trend is stable. Stable populations. Favourable. Whiskered Bat 1330 Favourable Trend is stable. Area of suitable habitat (Myotis mystacinus) increasing. Brown Long-Eared Bat Favourable. 1326 Favourable (Plecotus auritus) Trend is stable. Population increasing. Leisler’s Bat Favourable. 1331 Favourable (Nyctalus leisleri) Trend is stable. Population increasing. Favourable. Mountain Hare 1334 Inadequate Change due to improved knowledge. Hare is (Lepus timidus) widespread with broad habitat niche. Favourable. Otter 1355 Inadequate Trend improved. Previous concerns about (Lutra lutra) population decline have been allayed. Pine Marten Favourable. 1357 Favourable (Martes martes) Trend is stable. Ample habitat available. Grey Seal Favourable 1364 Favourable (Halichoerus grypous) Trend is stable (owing to improved knowledge). Common Seal Favourable 1365 Favourable (Phoca vitulina vitulina) Trend is stable (owing to improved knowledge). Humpback Whale Unknown. 1345 Unknown (Megaptera novaeangliae) No change. Bottle-Nosed Dolphin Favourable. 1349 Favourable (Tursiops truncatus) Trend is stable. Improved knowledge. Common Dolphin Favourable. 1350 Favourable (Delphinus delphis) Trend is stable. Improved knowledge. Harbour porpoise Favourable 1351 Favourable (Phocoena phocoena) Trend is stable. Killer Whale Unknown. 2027 Unknown (Orcinus orca) No change. Favourable. Long-Finned Pilot Whale 2029 Unknown No trend. Improved status due to improved (Globicephala melas) knowledge. Risso’s Dolphin Unknown. 2030 Unknown (Grampus griseus) No change.
White-Sided Dolphin Favourable. 2031 Favourable (Lagenorhynchus acutus) Trend is stable. Favourable. White-Beaked Dolphin 2032 Unknown No trend. Improved status due to improved (Lagenorhynchus albirostris) knowledge. Favourable. Striped Dolphin 2034 Unknown No trend. Improved status due to improved (Stenella coeruleoalba) knowledge. Cuvier’s Beaked Whale Unknown. 2035 Unknown (Ziphius cavirostris) No change. Sowerby’s Beaked Whale Unknown. 2038 Unknown (Mesoplodon bidens) No change. Minke Whale Favourable. 2618 Favourable (Balaenoptera acutorostrata) Trend is stable. Fin Whale Favourable. 2621 Favourable (Balaenoptera physalus) Trend is stable. Blue Whale Unknown. 5020 Unknown (Balaenoptera musculus) No change. Sperm Whale Unknown. 5031 Unknown (Physeter catodon) No change. Northern Bottlenose Whale Unknown. 5033 Unknown (Hyperoodon ampullatus) No change. Sei Whale Unknown. 2619 Unknown (Balaenoptera borealis) No change. Vagrants (Species which have previously been recorded but are not assessed owing to infrequent nature of records) Northern Right Whale Unknown. 1348 Unknown (Eubalaena glacialis) Vagrant. False Killer Whale Unknown. 2028 Unknown (Pseudorca crassidens) Vagrant. True’s Beaked Whale Unknown. 2037 Unknown (Mesoplodon mirus) Vagrant. Pygmy Sperm Whale Unknown. 2622 Unknown (Kogia breviceps) Vagrant. Beluga/White Whale Unknown. 5029 Unknown (Delphinapterus leucas) Vagrant. Gervais’ Beaked Whale Unknown. 5034 Unknown (Mesoplodon europaeus) Vagrant. Allis Shad Unknown. 1102 Unknown (Alosa alosa) Vagrant. Brandt’s Unknown. 1320 Unknown (Myotis brandtii) Vagrant.
Bird Species Code Status BoCCI2 2007-2013* Status BoCCI3 2014-2019*
Red-throated Diver (Gavia A001 Amber (breeding) Amber (breeding) stellata) Great Northern Diver (Gavia A003 Green (wintering) Amber (wintering) immer) Little Grebe (Tachybaptus Amber A004 Amber (breeding/wintering) ruficollis) (breeding/wintering) Great Crested Grebe Amber A005 Amber (breeding/wintering) (Podiceps cirstatus) (breeding/wintering) Fulmar (Fulmarus glacialis) A009 Green (breeding) Green (breeding) Manx Shearwater (Puffinus A013 Amber (breeding) Amber (breeding) puffinus) Storm Petrel (Hydrobates A014 Amber (breeding) Amber (breeding) pelagicus) Leach’s Storm-petrel A015 Amber (breeding) Red (breeding) (Oceanodroma leucorhoa) Gannet (Morus bassanus) A016 Amber (breeding) Amber (breeding) Cormorant (Phalacrocorax Amber A017 Amber (breeding/wintering) carbo) (breeding/wintering) Shag (Phalacrocorax A018 Amber (breeding) Amber (breeding) aristotelis) Green Grey heron (Ardea cinerea) A028 Green (breeding/wintering) (breeding/wintering) Bewick’s Swan (Cygnus A037 Red (wintering) Red (wintering) columbianus bewickii) Whooper Swan (Cygnus A038 Amber (wintering) Amber (wintering) cygnus) Greylag Goose (Anser anser) A043 Amber (wintering) Amber (wintering) Barnacle Goose (Branta A045 Amber (wintering) Amber (wintering) leucopsis) Light-bellied Brent Goose A046 Amber (wintering) Amber (wintering) (Branta bernicola hrota) Amber Shelduck (Tadorna tadorna) A048 Amber (breeding/wintering) (breeding/wintering) Wigeon (Anas penelope) A050 Amber (wintering) Red (wintering) Amber Gadwall (Anas strepera) A051 Amber (breeding/wintering) (breeding/wintering) Amber Teal (Anas crecca) A052 Amber (breeding/wintering) (breeding/wintering) Mallard (Anas A053 Green (wintering) Green (wintering) pyatyrhynchos) Pintail (Anas acuta) A054 Red (wintering) Red (wintering) Shoveler (Anas clypeata) A056 Red (wintering) Red (wintering) Pochard (Aythya farina) A059 Amber (wintering) Red (wintering) Tufted Duck (Aythta A061 Amber (wintering) Red (wintering) fuligula) Scaup (Aythya marila) A062 Amber (wintering) Amber (wintering)
Amber Eider (Somateria mollissima) A063 Amber (breeding/wintering) (breeding/wintering) Common Scoter (Melanitta A065 Red (breeding) Red (breeding) nigra) Goldeneye (Bucephala A067 Amber (wintering) Red (wintering) clangula) Red-breasted Merganser Green A069 Green (breeding/wintering) (Mergus serrator) (breeding/wintering) Hen Harrier (Circus cyaneus) A082 Amber (breeding) Amber (breeding) Merlin (Falco columbarius) A098 Amber (breeding) Amber (breeding) Peregrine (Falco peregrinus) A103 Green (breeding) Green (breeding) Corncrake (Crex crex) A122 Red (breeding) Red (breeding) Amber Coot (Fulica atra) A125 Amber (breeding/wintering) (breeding/wintering) Oystercatcher (Haematopus Amber A130 Amber (breeding/wintering) ostralegus) (breeding/wintering) Ringed Plover (Charadrius A137 Amber (wintering) Green (wintering) hiaticula) Golden Plover (Pluvialis A140 Red (breeding/wintering) Red (breeding/wintering) apricaria) Grey Plover (Pluvialis A141 Amber(wintering) Amber (wintering) squatarola) Lapwing (Vanellus vanellus) A142 Red (breeding/wintering) Red (breeding/wintering) Knot (Calidris canutus) A143 Red (wintering) Amber (wintering) Sanderling (Calidris alba) A144 Green (wintering) Green (wintering) Purple Sandpiper (Calidris A148 Green (wintering) Green (wintering) maritima) Dunlin (Calidris alpina) A149 Amber (breeding/wintering) Red (breeding/wintering) Black-tailed Godwit (Limosa A156 Amber (wintering) Amber (wintering) limosa) Bar-tailed Godwit (Limosa A157 Amber (wintering) Amber (wintering) lapponica) Curlew (Numenius arquata) A160 Red (breeding/wintering) Red (breeding/wintering) Redshank (Tringa totanus) A162 Red (breeding/wintering Red (breeding/wintering) Greenshank (Tringa A164 Amber (wintering) Green (wintering) nebularia) (Ruddy) Turnstone (Arenaria A169 Green (wintering) Green (wintering) interpres) Black Headed Gull (Chroicocephalus A179 Red (breeding) Red (breeding) ridibundus) Common Gull (Larus canus) A182 Amber (breeding) Amber (breeding) Lesser Black-backed Gull A183 Amber (breeding) Amber (breeding) (Larus fuscus) Herring Gull (Larus A184 Red (breeding) Red (breeding) argentatus) Kittiwake (Rissa tridactyla) A188 Amber (breeding) Amber (breeding)
Sandwich Tern (Sterna A191 Amber (breeding) Amber (breeding) sandvicensis) Roseate Tern (Sterna A192 Amber (breeding) Amber (breeding) dougallii) Common Tern (Sterna A193 Amber (breeding) Amber (breeding) hirundo) Arctic Tern (Sterna A194 Amber (breeding) Amber (breeding) paradisaea) Guillemot (Uria aalge) A199 Amber (breeding) Amber (breeding) Razorbill (Alca torda) A200 Amber (breeding) Amber (breeding) Puffin (Fratercula arctica) A204 Amber (breeding) Amber (breeding) Kingfisher (Alcedo atthis) A229 Amber (breeding) Amber (breeding) Chough (Pyrrhocorax A346 Amber (breeding) Amber (breeding) pyrrhocorax) Greenland White-fronted Goose (Anser albifrons A395 Amber (wintering) Amber (wintering) flavirostric) Wetland & Waterbirds A999 ------*Taken from Birds of Conservation Concern Reports; BOCCI2: Lynas et. Al. (2007), BOCCI3: Colhoun and Cummins (2013).
Reference has also been made to Irelands (Birds Directive) Article 12 submission to the EU Commission on the Status and trends of birds species (2008-2012)18.
18 http://ec.europa.eu/environment/nature/knowledge/rep_birds/index_en.htm
APPENDIX H GENERIC THREATS AND PRESSURES CONSIDERED RELEVANT TO THE AFF
Code Description A Agriculture A01 Agricultural cultivation A02 Modification of cultivation practices A02.01 agricultural intensification A02.02 crop change A02.03 grassland removal for arable land A06 Crops of annuals & perennials (non-timber) A06.02 perennial non-timber crops A06.02.01 intensive perennial non-timber crops/intensification A06.02.02 non-intensive perennial non-timber crops A06.03 biofuel-production A07 Use of 'pesticides' in agriculture A08 Fertilisation in agriculture A09 Irrigation in agriculture A10 Restructuring agricultural parcels A11 Other agriculture activities B Forestry B01 Afforestation B01.01 forest planting on open ground (native trees) B01.02 artificial planting on open ground (non-native trees) B02 Forest and plantation management & use B02.01 forest replanting B02.01.01 forest replanting (native trees) B02.01.02 forest replanting (non native trees) B02.02 forestry clearance B02.03 removal of forest undergrowth B02.04 removal of dead and dying trees non- intensive timber production (leaving dead wood/ old B02.05 trees untouched) B02.06 thinning of tree layer B03 Forest exploitation B04 Use of 'pesticides' (forestry) B05 Use of fertilizers (forestry) B06 Grazing in forests & woodland B07 Other forestry activities C Mining, quarrying & energy production C01 Mining and quarrying C01.03 Peat extraction C01.03.01 hand cutting of peat C01.03.02 mechanical removal of peat C01.06 Geotechnical survey C01.07 Mining and extraction activities not referred to above C02 Oil and gas exploitation C02.01 exploration drilling C02.02 production drilling
Code Description C02.03 jack-up drilling rig C02.04 semi-submersible rig C02.05 drill ship C03 Production of renewable energy (abiotic) C03.01 geothermal power production C03.02 solar energy production C03.03 wind energy production C03.04 tidal energy production D Transportation & service infrastructure D02 Utility and service lines/pipelines D02.01 electricity and phone lines D02.01.01 suspended electricity and phone lines D02.01.02 underground/submerged electricity and phone lines D02.02 pipe lines D02.09 other forms of energy transport D06 Other transportation & service infrastructure E Urbanisation, residential & commercial development E01 Urbanisation and human habitation E02 Industrial or commercial areas E03 Discharges (household/industrial) E03.02 disposal of industrial waste E03.03 disposal of inert materials E03.04 Other discharges E04 Scattered structures and buildings E05 Storage of materials E06 Other urban/industrial developments E06.01 demolishment of buildings & human structures E06.02 reconstruction, renovation of buildings G Disturbances due to human activities G05 Other human intrusions and disturbances shallow surface abrasion/ mechanical damage to seabed G05.02 surface G05.03 penetration/ disturbance below surface of the seabed G05.11 death or injury by collision H Pollution H01 Pollution to surface waters H01.01 pollution to surface waters by industrial plants diffuse pollution to surface waters due to agricultural and H01.05 forestry activities diffuse pollution to surface waters due to transport and H01.06 infrastructure without connection to canalization/sweepers H02 Pollution to groundwater groundwater pollution by leakages from contaminated H02.01 sites
Code Description groundwater pollution by leakages from waste disposal H02.02 sites groundwater pollution associated with oil industry H02.03 infrastructure H02.04 groundwater pollution by mine water discharges groundwater pollution by discharge to ground such as H02.05 disposal of contaminated water to soakaways diffuse groundwater pollution due to agricultural and H02.06 forestry activities H03 Pollution to marine waters H03.01 oil spills in the sea H03.02.01 non-synthetic compound contamination H03.02.02 synthetic compound contamination H03.02.04 introduction of other substances (e.g. liquid, gas) H04 Air pollution, air-borne pollutants H04.01 Acid rain H04.02 Nitrogen-input H04.03 other air pollution H05 Soil pollution and solid waste (excl. discharges) H06 Excess energy (noise, light, heating, electromagnetic) H06.01 Noise nuisance, noise pollution H06.01.01 point source or irregular noise pollution H06.01.02 diffuse or permanent noise pollution H06.02 Light pollution H06.03 Thermal heating of water bodies H06.04 Electromagnetic changes H06.05 Seismic exploration, explosions H07 Other forms of pollution I Invasive and introduced species J Modification of natural conditions J02 Changes in water bodies conditions J02.01.04 recultivation of mining areas J02.02 Removal of sediments (mud...) J02.02.01 dredging/ removal of limnic sediments J02.02.02 estuarine and coastal dredging J02.03 Canalisation & water deviation J02.03.01 large scale water deviation J02.03.02 canalisation J02.05 Modification of hydrographic functioning, general J02.05.01 modification of water flow (tidal & marine currents) J02.05.02 modifying structures of inland water courses J02.05.03 mofification of standing water bodies J02.05.04 reservoirs J02.05.05 small hydropower projects, weirs J02.05.06 wave exposure changes
Code Description J02.06 Water abstractions from surface waters J02.06.01 surface water abstractions for agriculture surface water abstractions for the production of electricity J02.06.04 (cooling) J02.06.06 surface water abstractions by hydro-energy surface water abstractions by quarries/ open cast (coal) J02.06.07 sites J02.07 Water abstractions from groundwater J02.07.01 groundwater abstractions for agriculture J02.07.03 groundwater abstractions by industry J02.07.04 groundwater abstractions by quarries/open cast (coal)sites Raising the groundwater table /artificial recharge of J02.08 goundwater J02.08.01 discharges to groundwater for artificial recharge purposes J02.08.03 mine water rebound J02.08.04 other major groundwater recharge Siltation rate changes, dumping, depositing of dredged J02.11 deposits J02.11.01 Dumping, depositing of dredged deposits J02.11.02 Other siltation rate changes J02.15 Other human induced changes in hydraulic conditions J03 Other changes to ecosystems J03.01 reduction or loss of specific habitat features J03.01.01 reduction of prey availability (inluding carcasses) J03.02 anthropogenic reduction of habitat connectivity J03.02.01 reduction in migration/ migration barriers J03.02.02 reduction in dispersal J03.02.03 reduction in genetic exchange J03.03 reduction, lack or prevention of erosion J03.04 applied (industrial) destructive research M Climate change M01 Abiotic changes (climate change) M01.01 temperature changes (e.g. rise of temperature & extremes) M01.02 droughts and less precipitations M01.03 flooding and rising precipitations M01.04 pH-changes M01.05 water flow changes (limnic, tidal and oceanic) M01.06 wave exposure changes M01.07 sea-level changes M02 Biotic changes (climate change) M02.01 habitat shifting and alteration M02.02 desynchronisation of processes M02.03 decline or extinction of species M02.04 migration of species (natural newcomers)