Irish Water Report
Natura Impact Statement to inform the Appropriate Assessment of the Proposed Sewerage Scheme at Omeath, Co. Louth
Contents
Introduction 4
Legislative Context 4
Source-Pathway-Receptor Model 5
Guidance Followed 6
Stages Involved in the Appropriate Assessment Process 7
Methodology 8
Desktop Study 8
Field Ecological Surveys 8
Consultation 8
Screening 9
Introduction 9
Description of Project 9
Project Background 9
Construction Methodology 10
Description of the Existing Environment 14
Wastewater Treatment Plant Location 14
Outfall Pipe 15
Water Quality in Carlingford Lough 16
Identification of Relevant Natura 2000 Sites 17
Potential Adverse Effects on the Natura 2000 Sites 23
Overview of potential impacts of the new sewerage scheme 23
Potential direct impacts 24
Potential indirect impacts 24
2 | Irish Water NIS – Omeath Sewerage Scheme
Possible Cumulative Impacts with other Plans and Projects in the Area 25
Screening Assessment 25
Screening Conclusions 30
Stage 2: Appropriate Assessment 31
Description of the Natura 2000 Site Potentially Affected 31
Description of the Qualifying Interests of the SAC 31
Conservation Objectives of the Carlingford Shore SAC 32
Annual Vegetation of Drift Lines 33
Perennial Vegetation of Stony Banks 33
Impact Prediction 34
Direct Adverse Effects 34
Indirect Adverse Effects 35
In-Combination / Cumulative Effects 35
Mitigation Measures 36
Mitigation by Avoidance 36
Construction Phase Mitigation 36
Marine Mammals, Otters , Annex IV species and other protected fauna 37
Biosecurity 37
Monitoring 38
Conclusion Statement for Appropriate Assessment 38
Plates 39
3 | Irish Water NIS – Omeath Sewerage Scheme
Introduction This report comprises an Appropriate Assessment Screening and Natura Impact Statement (NIS) for the proposed sewerage scheme at Omeath, Co. Louth. The purpose of this report is to inform the Appropriate Assessment process which is carried out by the appropriate planning authority.
An Appropriate Assessment is a requirement 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”). The overall aim of the Habitats Directive is to maintain or restore the “Favourable Conservation Status” of habitats and species of European Community Interest. These habitats and species are listed in the Habitats and Birds Directives (Council Directive 2009/147/EC on the conservation of wild birds) with Special Areas of Conservation and Special Protection Areas designated to afford protection to the most vulnerable of them. These two designations are collectively known as European Sites. European and national legislation places a collective obligation on Ireland and its citizens to maintain habitats and species in the Natura 2000 network at favourable conservation condition. The Government and its agencies are responsible for the implementation and enforcement of regulations (in particular Part XAB of the Planning and Development (Amendment) Act 2010 and the European Communities (Birds and Natural Habitats) Regulations, 2011 (S.I. 477) (often referred to as the Habitats Regulations) to ensure the ecological integrity of these sites. Appropriate Assessment (AA) is an assessment of whether a plan or project, alone and in combination with other plans or projects, could have significant effects on a European site in view of the site’s conservation objectives.
The project design to date has been an iterative approach which has sought to, as far as possible; avoid impacts to European Sites. This report considers the proposed design and determines whether there is the potential for direct, indirect and in-combination effects; or if there were uncertainty regarding potential effects. Given the “precautionary principle” requirements of Appropriate Assessment, mitigation measures are prescribed in order to avoid or further reduce the significane of potential impacts; or possible uncertainty regarding potential impacts.
Screening for Appropriate Assessment implemented for the project determined that the development required Stage 2 of the Appropriate Assessment process to be undertaken. This report therefore takes the forms of a Natura Impact Statement (NIS) as required by the Birds and Natural Habitats Regulations (2011). The NIS has been prepared by an experienced and appropriately qualified TOBIN ecologist.
Legislative Context The Appropriate Assessment process (AA) is an assessment of the potential for adverse or negative effects of a plan or project, in combination with other plans or projects, on the conservation objectives of a European Site. These sites consist of Special Areas of Conservation (SACs) and Special Protection Areas (SPAs) and provide for the protection and long-term survival of Europe’s most valuable and threatened species and habitats.
Council Directive 92/43/EEC of 21 May 1992 on the Conservation of Natural Habitats and of Wild Fauna and Flora - ‘The Habitats Directive’, has been transposed into Irish law by The European Community (Natural Habitats) Regulations 2011 (S.I. No. 477). The Birds Directive, Directive 2009/147/EC of the European Parliament and of the Council, seeks to protect birds of special
4 | Irish Water NIS – Omeath Sewerage Scheme
importance by the designation of Special Protection Areas (SPAs) whereas the Habitats Directive does the same for habitats and other species groups with Special Areas of Conservation (SACs). The requirement of AA is outlined in Article 6(3) and 6(4) of the EU Habitats Directive. Article 6(3) of the Habitats Directive requires 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 for the site in view of the site's conservation objectives. In the 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.”
Furthermore, Article 6(4) of the Habitats Directive requires that:
“If, in spite of a negative assessment of the implications for the 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, the Member State 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.”
If, in spite of a negative assessment of the implications for the site and in the absence of alternative solutions, a plan or project may nevertheless be carried out for “Imperative Reasons Of Overriding Public Interest”, including those of a social or economic nature, the Member State shall take all compensatory measures necessary to ensure that the overall coherence of Natura 2000 network is protected. It shall inform the Commission of the compensatory measures adopted. Where the site concerned hosts a priority natural habitat type and/or a priority species, the only considerations which may be raised are those relating to human health or public safety, to beneficial consequences of primary importance for the environment or, further to an opinion from the Commission, to other imperative reasons of overriding public interest.
Appropriate Assessment should be based on best scientific knowledge and Planning Authorities should ensure that scientific data (ecological and hydrological expertise) is utilised. This report details a Natura Impact Statement to inform the AA process which is finalised by the statutory authority.
Source-Pathway-Receptor Model Ecological impact assessment of potential indirect impacts on European Sites is conducted utilising a standard ‘Source-Pathway-Receptor’ model, where, in order for an indirect impact to be established all three elements of this mechanism must be in place. The absence or removal of one of the elements of the mechanism is sufficient to conclude that a potential effect is not of any relevance or significance. This report determines if direct, indirect and cumulative adverse effects will arise from the proposed development. Source(s) – e.g. pollutant run-off from proposed works. Pathway(s) – e.g. groundwater connecting to nearby qualifying wetland habitats. Receptor(s) – Qualifying aquatic habitats and species of European sites.
5 | Irish Water NIS – Omeath Sewerage Scheme
Guidance Followed This report has been carried out using the following guidance: Note on Appropriate Assessments for the purposes of the Waste Water Discharge (Authorisation) Regulations, 2007 (S.I. No. 684 of 2007). Environmental Protection Agency, (EPA, 2009). Circular L8/08 – Water Services Investment and Rural Water Programmes – Protection of Natural Heritage and National Monuments. Department of Environment, Heritage and Local Government, (DoEHLG, 2008). Appropriate Assessment of Plans and Projects in Ireland - Guidance for Planning Authorities. (Department of Environment, Heritage and Local Government, 2010). 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 (EC 2000); 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, Office for Official Publications of the European Communities, Luxembourg (EC 2001); 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. Office for Official Publications of the European Communities, Luxembourg (EC 2007). Nature and biodiversity cases: Ruling of the European Court of Justice. Office for Official Publications of the European Communities, Luxembourg (EC, 2006). Marine Natura Impact Statements in Irish Special Areas of Conservation: A working document, National Parks and Wildlife Service, Dublin (NPWS, 2012). European Communities (Birds and Natural Habitats) Regulations, 2011 (S.I. No.477 of 2011). Interpretation Manual of European Union Habitats. Version EUR 28. European Commission (EC, 2013).
In addition, a detailed online review of published scientific literature and ‘grey’ literature was conducted. This included a detailed review of the National Parks and Wildlife Website including mapping and available reports for relevant sites and in particular sensitive qualifying interests described and their conservation objectives. The EPA Envision Map-viewer (www.epa.ie) and available reports were also reviewed.
Definitions of conservation status, integrity and significance used in this assessment are defined in accordance with ‘Managing Natura 2000 sites: The provisions of Article 6 of the 'Habitats' Directive 92/43/EEC’ (EC, 2000). The conservation status of a natural habitat is defined as the sum of the influences acting on a natural habitat and its typical species that may affect its long-term natural distribution, structure and functions as well as the long-term survival of its typical species; The conservation status of a species is defined as the sum of the influences acting on the species concerned that may affect the long-term distribution and abundance of its population;
6 | Irish Water NIS – Omeath Sewerage Scheme
The integrity of a European Site is defined as the coherence of the site’s ecological structure and function, across its whole area, or the habitats, complex of habitats and/or populations of species for which the site is or will be classified; Significant effect should be determined in relation to the specific features and environmental conditions of the protected site concerned by the plan or project, taking particular account of the site’s conservation objectives.
Stages Involved in the Appropriate Assessment Process
Stage 1: Screening / Test of Significance This process identifies whether the proposed WwTP and associated works are directly connected to or necessary for the management of a European Site(s); and identifies whether the discharge is likely to have significant impacts upon a European Site(s) either alone or in combination with other projects or plans.
The output from this stage is a determination as to whether the potential for adverse effects on each European Site(s) would be: not significant; significant; potentially significant; or uncertain. The latter three determinations will require an Appropriate Assessment of the site at Stage 2 (i.e. NIS).
Stage 2: Appropriate Assessment This stage considers the impact of the WwTP and associated works on the integrity of a European Site(s), either alone or in combination with other projects or plans, with respect to (1) the site’s conservation objectives; and (2) the site’s structure and function and its overall integrity. Additionally, where there are adverse impacts, an assessment of the potential mitigation of those impacts
The output from this stage is a Natura Impact Statement (NIS). This document must include sufficient information for the EPA to carry out the appropriate assessment. If the assessment is negative, i.e. adverse effects on the integrity of a site cannot be excluded, then the process must consider alternatives (Stage 3) or proceed to Stage 4.
Stage 3: Assessment of Alternatives This process examines alternative ways of achieving the objectives of the project or plan that avoid adverse impacts on the integrity of the European Site. This assessment may be carried out concurrently with Stage 2 in order to find the most appropriate solution. If no alternatives exist or all alternatives would result in negative impacts to the integrity of the European sites then the process either moves to Stage 4 or the project is abandoned.
Stage 4: Assessment Where Adverse Impacts Remain An assessment of compensatory measures where, in the light of an assessment of Imperative Reasons of Overriding Public Interest (IROPI), it is deemed that the project or plan should proceed.
7 | Irish Water NIS – Omeath Sewerage Scheme
Methodology
Desktop Study The ecological desktop study completed for the proposed development comprised the following elements: Identification of European Sites (including Northern Ireland) with potential connection/pathways to the proposed development. Review of the NPWS/JNCC site synopses and conservation objectives for relevant European Sites1,2 Review of available literature and web data. This included a detailed review of the National Parks and Wildlife Website including mapping and available reports3 for relevant sites and in particular sensitive qualifying interests described and their conservation objectives.
Field Ecological Surveys A ecological site survey was carried out on the 21st August 2015 to identify protected habitats/species within the potential zone of influence of the proposed sewerage scheme. A follow up ecological survey was carried out in March 11th 2016. Habitat surveys and mapping were carried out in accordance with best practice guidelines (Smith et at. 2011).
Consultation Consultation with the Northern Ireland Environment Agency (NIEA) was undertaken to aquire the archival water quality data for the catchment area from the Water Framework Directive Sampling Programme. Consultation with the NPWS in relation to the proposed sewerage scheme was also undertaken in the form of a pre-planning enquiry. Following a meeting with NPWS, observations and recommendations were received from the Department of Arts Heritage and the Gaeltacht Developments Application Unit (DAU) in March 2016.
1 http://www.npws.ie/protectedsites/ 2 http://jncc.defra.gov.uk/pdf/SPA/UK9020161.pdf 3 http://www.npws.ie/mapsanddata/
8 | Irish Water NIS – Omeath Sewerage Scheme
Screening
Introduction This stage of the process identifies any likely significant effects upon European sites from a project or plan, either alone or in combination with other projects or plans. A series of questions are asked during the Screening Stage of the AA process in order to determine:
Whether a plan or project can be excluded from AA requirements because it is directly connected with or necessary to the management of a European site; and Whether the project or plan will have a potentially significant effect on a European site, either alone or in combination with other projects or plans, in view of the site’s conservation objectives or if residual uncertainty exists regarding potential impacts.
If the effects are deemed to be significant, potentially significant, or uncertain, or if the screening process becomes overly complicated, then the process must proceed to Stage 2 (AA). Screening should be undertaken without the inclusion of mitigation, unless potential impacts clearly can be avoided through sensitive design and associated design-stage proposals or through the modification or redesign of the plan or project.
This report comprises a Screening Assessment of the proposed development in which potential impacts to European Sites are identified and assessed. Standard and best practice construction methods have been integrated into the project design proposal and are therefore considered as an integral part of the proposed development.
Description of Project
Project Background The village of Omeath is located on the southern shore of Carlingford Lough approximately 12km northeast of Dundalk and 1km southwest of Warrenpoint. Carlingford shore is designated as a Special Area of Conservation (SAC) and Carlingford Lough is a proposed National Heritage Area and designated as a Shellfish water (designated under the European Communities (Quality of Shellfish Waters) Regulations, S.I. 268 of 2006).
There is currently no wastewater treatment facility in Omeath, with all wastewater generated in the town being discharged untreated via an outfall to Carlingford Lough at Flat Rock. Carlingford Lough also receives discharges from a number of agglomerations, including Warrenpoint, Rostrevor, Carlingford, Greenore and from Newry via the Newry Canal. The proposed Wastewater Treatment Plant at Omeath will be constructed on a phased basis as follows: Phase 1 with a design capacity of 1,000p.e. Phase 2 expansion to a design capacity of 2,000p.e. Phase 3 any future expansion beyond the design horizon of 2035.
The Phase 1 design capacity allows for a reasonable level of expansion above existing off-peak and peak season loadings. Following commissioning of the proposed plant at Omeath the standards for a treated effluent a will be as follows: Biological Oxygen Demand (5 day) 25mg/l Chemical Oxygen Demand 125mg/l
9 | Irish Water NIS – Omeath Sewerage Scheme
Suspended Solids 35mg/l Phosphate 2mg/l Faecal coliform 3 log reduction for Shellfish Waters E-coli 3 log reduction for Bathing Waters4
The projected future hydraulic and biological loads to be treated are as follows: Biological Load: o Off-peak Season 1,460p.e. o Peak Season 2,000p.e.
Hydraulic Load: o Off-peak Season DWF 300m³/d o Peak Season DWF 393m³/d o Multiples of DWF for Treatment 3
Construction Methodology Preliminary details of the construction of the proposed development are as follows;
The proposed location of the Wastewater Treatment Works (WwTW) is north of Cluain na Mara housing development on the R173 in the northern outskirts of the village. The proposed plant consists of a Phase 1 design capacity of 1000 PE, which would be constructed in a modular fashion to allow expansion to the long term project capacity of 2000PE. The WwTW will comprise of an inlet works, screening, aeration and settlement tanks, odour control and ancillary mechanical plant. The tanks are likely to be prefabricated below ground tanks constructed on concrete foundations. The WwTW site will have a control building, access road, security fencing, landscaping and ancillary services such as power, telecoms and water. Central pumping station located in the south of the village on Shore Road, to deliver wastewater to the proposed WwTW. The central pumping station would contain storage to prevent overflows to frequencies recommended for designated Bathing Areas. The pumping station will be an insitu constructed structure consisting of reinforced concrete, block work and other standard construction materials. The pumping station site will have an access road, security fencing, landscaping and ancillary services such as power, telecoms and water. Construction of 700m of rising main from the pumping station to the wastewater treatment plant. The rising main is expected to be a relatively small diameter pipe (e.g. 150mm diameter) and will be constructed in an open trench in the existing road carriageway. Construction of approximately 1,750m of foul sewers connecting to the pumping station and to the existing outfall. The foul sewers will be gravity pipelines of 225, 300, 375 and 400mm diameter and will be constructed in an open trench in the existing road carriageway. Rehabilitation of the existing outfall and extension beyond the low water mark. It is envisaged that the rehabilitation would be carried out by no dig techniques, such as cured in place liners, to minimise the impact of this work. It is envisaged that the
4 This reduction aims to achieve compliance for Bathing Waters
10 | Irish Water NIS – Omeath Sewerage Scheme
extension of the outfall will require the excavation of a trench, placement of the extended outfall pipe and diffusers and backfilling of the trench. It is likely the trench would need support during the construction process due to the tidal nature of the area, and this may consist of sheet piles or trench boxes, depending on the ground conditions encountered.
The location of the proposed WwTP site and pumping station are presented in Figure 1 and 2 respectively.
11 | Irish Water NIS – Omeath Sewerage Scheme
Figure 1. Location and layout of the proposed WwTP, Omeath, Co. Louth.
12 | Irish Water NIS – Omeath Sewerage Scheme
Figure 2. Location and layout of the proposed pumping station, Omeath, Co. Louth.
13 | Irish Water NIS – Omeath Sewerage Scheme
Description of the Existing Environment
Wastewater Treatment Plant Location The site for the proposed WwTP is located within wet grassland (GS4) and wet willow woodland (WN6) between the R173 and Carlingford Lough shore on the northern approach to Omeath Village. The development site is located outside of, but in close proximity to the Carlingford Lough SAC. A large stone wall (BL1) separates this site from the Newry Road (R173), mature beech Fagus sylvatica and sycamore Acer pseudoplatanus occur along this boundary. Willow Salix spp., holly Ilex aquifolium, brambles Rubus fruticosus and young ash Fraxinus excelsior were recorded from within the development site.
Invasive, non-native flora occur within the site, with Rhododendron ponticum occurring within the wet woodland. To the south of the development site, outside of the proposed works area, a stand of Japanese knotweed Fallopia japonica, was recorded.
There was some evidence of improved agricultural grassland (GA1) within the development site; however, it was found to be unmanaged and rank at the time of surveying. The herb layer consists of Nettle Urtica dioicia, Ragwort Senecio jacobaea, Hogweed Heracleum sphondylium, cocksfoot Dactylis glomerata, Broad-leaved dock Rumex obtusifolius, Creeping buttercup Ranunculus repens, Ribwort plantain Plantago lanceolata, Daisy Bellis perennis, Clover Trifolium repens, and Dandelion Taraxacum officinale. The site was previously grazed by horses with some poaching evident. A small area of wet grassland (GS4) is located around a drinking barrel with soft rush Juncus efffusus evident. There were no Annex I habitats recorded within the site, and the existing habitat is considered to be of local ecological importance (lower value).
No signs of protected mammals were recorded during the site visit. The mature beech Fagus sylvatica and sycamore Acer pseudoplatanus located along the western boundary wall by the R173 are covered in Ivy Hedera helix and have a potential for bat roost activity. There was evidence of fox activity throughout the site. Avifauna recorded from the site comprised common passerine species. Two herons Ardea cinerea and two ravens Corvus corax were recorded flying over adjacent lands.
Pumping Station The proposed pumping station site located within a field of improved grassland, which has been unmanaged, aligning with dry meadow habitat (GS2). This site is located outside of the Carlingford Lough SAC adjacent to Shore Road in the south of the village. The southern boundary of the site comprises a block wall (BL1) from the neighbouring property and the remainder of the site was characterised as being semi-improved with false oat-grass Arrhenatherum elatius and Cocks-foot Dactylis glomerata. The broadleaved herb component consisted of Ragwort Senecio spp., Hogweed Heracleum sphondylium, Broad leaved dock Rumex obtusifolius, Nettle Urtica dioica, Dead nettle Lamium spp. and Common knapweed Centaurea nigra. No protected species were found during this survey, and it was deemed that the habitats within the area are of local ecological value (lower importance). No signs of protected fauna, including mammal or bird species, were recorded from the pumping station site or its vicinity.
14 | Irish Water NIS – Omeath Sewerage Scheme
Outfall Pipe The existing outfall pipe is located approximately 300m to the south of the pier in Omeath. It is buried below the intertidal sediments and runs seaward for a distance of approximately 300m to Flat Rock where it discharges above the low tide mark. The intertidal section of the pipe alignment crosses the Carlingford Lough SAC; however, the existing discharge point, which is to be utilised by the proposed upgrade, is located to the east and seaward of the SAC boundary. A habitat map utilising the habitat classification codes from Fossitt (2000) is provided in Figure 1 along with the known locations of annual vegetation of driftlines and perennial vegetation of stony banks.
Shore Road is protected from the tide by means of a low wall and extensive rock armouring which follows along the upper shore along the seaward side of the sea wall. The adjacent foreshore area is predominantly intertidal, below mean high water level, with just a small section of supratidal sand adjacent to the pier area. Evidence of intertidal and coastal vegetation occurring on the stone walls and rock armour adjacent to the road are identified as comprising the following habitat communities:
Intertidal rock/mud/sandflats – A mosaic of rock and sediment occurs in the intertidal zone south of Omeath pier. Mussel beds are abundant and the sediment deposited around the rocky areas includes abundant broken shells. Seaweeds include serrated wrack Fucus serratus, sea lettuce Ulva latuca and laver Porphyra spp. in the lower tidal section and egg wrack Ascophyllum nodosum and bladder wrack Fucus vesiculosus in the mid-high shore area.
Driftline vegetation - The small area of driftline vegetation located adjacent to the existing pier, to the north of the proposed discharge pipe alignment includes spear- leaved orache Atriplex prostrata, sea beet Beta vulgaris subsp. maritima, sand couch Elytrigia juncea, knotweed Polygonum aviculare, annual meadow grass Poa annua, petty spurge Euphorbia peplus and sea sandwort Hockenya peploides.
Rock wall vegetation – species recorded from the boulder rock-armour placed along the seawall include: common scurvygrass Cochlearia officinalis, spear-leaved orache Atriplex prostrata, sea beet Beta vulgaris subsp. maritima, sea mayweed Matricaria maritima, spear thistle Cirsium vulgare, coltsfoot Tussilago farfara, red fescue Festuca rubra, yarrow Achillea millefolium, sow thistle Sonchus arvensis and American willowherb Epilobium ciliatum.
Boulder vegetation - Vegetation transitions from coastal vegetation amongst the boulders to a dry grassland verge on the road-side. More coastal species on this foreshore include sea beet Beta vulgaris subsp. maritima, spear-leaved orache Atriplex prostrata, sea mayweed Matricaria maritima, sea radish Raphanus raphanistrum subsp. maritimum, sea aster Aster tripolium. Along the road verge the following species were recorded: carrot Daucus carota, cleavers Galium aparine, common mallow Malva sylvestris, creeping bent Agrostis stolonifera, red fescue Festuca rubra, dovesfoot cranesbill, Geranium molle, silverweed Potentilla anserina, ribwort plantain Plantago lanceolata, hogweed Heracleum sphondylium, ox-eye daisy Leucanthemum vulgare, square-stemmed St John’s wort Hypericum tetrapterum, ragwort Senecio jacobea, corn sow thistle Sonchus arvensis and lesser trefoil Trifolium dubium.
15 | Irish Water NIS – Omeath Sewerage Scheme
No signs of protected mammals were noted in the area. There were, however several wintering birds. These birds included Herring gull Larus argentatus, Lesser Black-backed gull Larus fuscus, Great Black-backed gull Larus marinus, Oystercatcher Haematopus ostralegus, Black- headed gull Larus ridibundus, Curlew Numenius arquata, Turnstone Arenaria interpres, Redshank Tringa tetanus, Heron Ardea cinerea and Light-bellied brent geese Branta bernicla hrota.
Rising Main and Foul Sewers The new rising main and foul sewers line will be installed along a 1 km stretch of the existing carriageway on Shore Road, adjacent to Carlingford Shore SAC This area is highly urbanised and considered to be of low ecological value.
Water Quality in Carlingford Lough Carlingford Lough is situated in the Neagh Bann International River Basin District, which is a cross-border river basin district. 2,000 km2 is in the Republic of Ireland and 6,000 km2 is in Northern Ireland (Neagh Bann IRBD, 2010). The contributing catchment is almost 299.9 km2 in area, the majority of which lies in Northern Ireland. Land cover in the catchment is a mix of forest, rough grazing and improved grazing, with small areas of arable land. The principal freshwater input to the lough is the Newry River; other rivers on the northern side of the Lough include the Moygannon, the Rostrevor, the White Water, the Ballincurry and the Ghann.
Carlingford Lough (waterbody code GBNIIE6NB030), is a coastal waterbody categorised as ‘Moderate’ WFD status and is considered to be ‘At risk of not achieving Good status’5. It is designated as a shellfish water under S.I. No. 268 of 2006 European Communities (Quality of Shellfish Waters) Regulations.
The Marine Institute carries out ongoing shellfish monitoring for biotoxins at three locations in Carlingford Lough, the closest located ca. 3km east of the WwTP. In 2014-2015 levels were below required levels and the fisheries remained opened 6. The inner part of Carlingford Lough is a ‘Class B’ bivalve mollusc production area for Mussels (indicating E.coli levels <4600 and requiring treatment of shellfish harvested) while the outer area is a Class A area for Mussels Oysters and Razor Clams from September to February or April (depending on location) indicating E.coli levels <2307, reverting to Class B at other times of year. The latest available coastal water monitoring data for Carlingford Lough, presented in Table 1 was obtained from the NIEA. This data shows the Bi-annual water quality assessments for 5 sites within the catchment area, with Site CL1 being the closest to the existing outfall pipe location.
The Eurpoean Community Environmental Objectives (Surface Water) Regulations (SI 2002 of 2009) set out standards for Dissolved Inorganic Nitrogen (DIN) in Coastal Water Bodies. A coastal water body is deemed to have good nutrient status if DIN is ≤ 0.25 mg/l and to have achieved high status if DIN is ≤ 0.17 mg/l. The average of the 5 DIN results (0.483 mg/l) for samples taken at CL1, closest to proposed outfall, indicate that during the period 2013/14 that good status was not attained.
5 http://gis.epa.ie/Envision 6 http://www.marine.ie/Home/site-area/data-services/interactive-maps/latest-shellfish-safety-data 7 http://www.sfpa.ie/SeafoodSafety/Shellfish/ClassifiedAreas.aspx
16 | Irish Water NIS – Omeath Sewerage Scheme
Table 1. Water Quality data for the catchment area as deemed by the Environmental Protection Agency through the Water Framework Directive sampling. Site Date Salinity DO Ammonia Total Oxidised Dissolved Inorganic Nitrogen Nitrogen mg/l umol mg/l umol N/l mg/l umol N/l mg/l N/l CL1 19/11/13 31.9 8.36 6.83 0.096 19.3 0.270 26.13 0.366 18/12/13 36 9.24 10.3 0.129 25.7 0.360 36 0.504 16/01/14 32.7 8.48 5.9 0.119 47.6 0.666 53.5 0.749 04/12/14 33.66 8.56 4.4 0.120 22.1 0.309 26.5 0.371 19/02/15 30.82 10.84 3.57 0.152 26.8 0.375 30.37 0.425 CL2 19/11/13 33 7.93 2.46 0.034 10.6 0.148 13.06 0.183
18/12/13 14.95 9.24 3.05 0.043 11.9 0.167 14.95 0.209 16/01/14 33.1 8.11 2.65 0.037 23.6 0.330 26.25 0.368 04/12/14 33.41 8.69 1.36 0.019 14.2 0.199 15.56 0.218 19/02/15 32.73 10.76 2.35 0.033 18.4 0.258 20.75 0.291
CL3 19/11/13 33.5 8.2 1.85 0.026 9.04 0.127 10.89 0.152 18/12/13 12.37 9.47 1.47 0.021 10.9 0.153 12.37 0.173 16/01/14 33.1 8.21 1.07 0.015 16.3 0.228 17.37 0.243 04/12/14 32.55 8.72 0.57 0.008 12.3 0.172 12.87 0.180 19/02/15 33.04 10.42 1.02 0.014 13.8 0.193 14.82 0.207
CL4 19/11/13 33.8 8.51 1.22 0.017 7.72 0.108 8.94 0.125 16/01/14 33.6 8.14 0.68 0.010 14.2 0.199 14.88 0.208 04/12/14 31.7 8.12 0.59 0.008 12.1 0.169 12.69 0.178 19/02/15 34.1 10.81 0.61 0.009 12.4 0.174 13.01 0.182 NR2 19/11/13 29.7 8.16 6.1 0.085 17.88 0.250 23.98 0.336
18/12/13 35.4 8.72 10.2 0.143 25.2 0.353 35.4 0.496 16/01/14 29.4 8.71 7.05 0.099 57 0.780 64.05 0.897 04/12/14 30.78 8.44 5.21 0.073 27 0.378 32.21 0.451 19/02/15 29.85 10.72 5.2 0.073 30.5 0.427 35.7 0.500
Identification of Relevant Natura 2000 Sites This section of the screening process describes the Natura 2000 sites within a 15km radius of the Omeath sewerage scheme location. A 15km buffer zone has been chosen as a precautionary measure, to ensure that all potentially affected Natura 2000 sites are included in the screening process, which is in line with Appropriate Assessment of Plans and Projects in Ireland – Guidance for Planning Authorities produced by the Department of the Environment, Heritage and Local Government.
The SACs and SPAs occurring within 15km of the Omeath WWSS are presented in Table 2 and Table 3, respectively. The qualifying interests and conservation opbjectives for each of the identified Natura 2000 Sites are also provided. The location of these sites in relation to the study area are presented in Figure 2.
17 | Irish Water NIS – Omeath Sewerage Scheme
Figure 1. Habitat map of the proposed study area, focussed on the proposed development sites and existing discharge pipe alignment.
18 | Irish Water NIS – Omeath Sewerage Scheme
Figure 2. European Sites within 15km of Study Area.
19 | Irish Water NIS – Omeath Sewerage Scheme
Figure 3. The extent of the Carlingford Shore SAC within the study area of the Omeath WwTP works.
20 | Irish Water NIS – Omeath Sewerage Scheme
Table 2. SACs located within 15km of the Omeath Sewerage Scheme Site Code Site Name and Qualifying Interests Conservation Objectives distance 002306 Carlingford Shore Annual Vegetation of Driftlines [1210] Achieving Favourable Conservation Status for Annex 1 Coastal Habitats SAC Perennial Vegetation of Stony Banks [1220] Conservation Objectives supporting document – Coastal habitats May 2013. (Contiguous) http://www.npws.ie/sites/default/files/publications/pdf/002306_Carlingford%20Sho re%20SAC%20Coastal%20Supporting%20Doc_V1%20.pdf 000453 Carlingford Alpine and Boreal heaths [4060] To maintain or restore the favourable conservation condition of the Annex I Mountain SAC Siliceous scree of the montane to snow levels (Androsacetalia habitat(s) and/or the Annex II species for which the N2000 site has been selected: 2 km alpinae and Galeopsietalia ladani) [8110] This is a generic conservation objective, available online at: Calcareous rocky slopes with chasmophytic vegetation [8210] http://www.npws.ie/sites/default/files/protected- Siliceous rocky slopes with chasmophytic vegetation [8220] sites/conservation_objectives/CO000453.pdf UK0030268 Rostrevor Wood Old sessile oak woods with Ilex and Blechnum in the British Isles SAC 4.5 km [91A0] UK0016620 Derryleckagh SAC Transition mires and quaking bogs [7140] To maintain or restore the favourable conservation condition of the Annex I 7.5 km Old sessile oakm woods with Ilex and Blechnum in the British Isles habitats listed. based on a detailed list of attributes and targets [91A0] https://www.daera-ni.gov.uk/sites/default/files/publications/doe/land-information- derryleckagh-conservation-objectives-2015.pdf 000455 Dundalk Bay SAC Estuaries [1130] To maintain or restore the favourable conservation condition of the Annex I 10.5 km Mudflats and sandflats not covered by seawater at low tide [1140] habitats listed. based on a detailed list of attributes and targets Perennial vegetation of stony banks [1220] http://www.npws.ie/sites/default/files/protected- Salicornia and other annuals colonising mud and sand [1310] sites/conservation_objectives/CO000455.pdf Atlantic salt meadows (Glauco-Puccinellietalia maritimae) [1330] Mediterranean salt meadows (Juncetalia maritimi) [1410] UK0016615 Eastern Mournes Northern Atlantic wet heaths with Erica tetralix [4010] Maintain (or where appropriate restore to favourable ) status of each feature. SAC European dry heaths[4030 ] https://www.daera-ni.gov.uk/sites/default/files/publications/doe/land-information- 15km Alpine and Boreal heaths[4060] eastern-mournes-conservation-objectives-2015.pdf Siliceous alpine and boreal grasslands [6150] Blanket bogs (*if active bog) * Priority feature [7130] Siliceous scree of the montane to snow levels (Androsacetalia alpinae and Galeopsietalia ladani)[8110] Siliceous rocky slopes with chasmophytic vegetation [8220] UK0030277 Slieve Gullion European dry heaths[4030 ] Maintain (or where appropriate restore to favourable ) status each feature. SAC https://www.daerani.gov.uk/sites/default/files/publications/doe/land-information- 10km slieve-gullion-conservation-objectives-2015.pdf
21 | Irish Water NIS – Omeath Sewerage Scheme
Table 3 SPAs located within 15km of the Omeath Sewerage Scheme Site Code Site Name Qualifying Features – Annex I Species Conservation Objectives 004080 Carlingford Light-bellied Brent Goose (Branta bernicla hrota) [A046] To maintain the favourable conservation condition of Light-bellied Brent Goose in based on Lough SPA Wetlands and Waterbirds [A999] following attributes; Population trend and distribution 6 km To maintain the favourable conservation condition of the wetland habitat in Carlingford Lough SPA as a resource for the regularly-occurring migratory waterbirds that utilise it. http://www.npws.ie/sites/default/files/protected-sites/conservation_objectives/CO004078.pdf 004026 Dundalk Bay Great Crested Grebe (Podiceps cristatus) [A005] To maintain or restore the favourable conservation condition of each listed waterbird species. SPA Greylag Goose (Anser anser) [A043] based on a detailed list of attributes and targets 9 km Light-bellied Brent Goose (Branta bernicla hrota) [A046] http://www.npws.ie/sites/default/files/protected-sites/conservation_objectives/CO000455.pdf Shelduck (Tadorna tadorna) [A048] Teal (Anas crecca) [A052] Mallard (Anas platyrhynchos) [A053] Pintail (Anas acuta) [A054] Common Scoter (Melanitta nigra) [A065] Red-breasted Merganser (Mergus serrator) [A069] Oystercatcher (Haematopus ostralegus) [A130] Ringed Plover (Charadrius hiaticula) [A137] Golden Plover (Pluvialis apricaria) [A140] Grey Plover (Pluvialis squatarola) [A141] Lapwing (Vanellus vanellus) [A142] Knot (Calidris canutus) [A143] Dunlin (Calidris alpina) [A149] Black-tailed Godwit (Limosa limosa) [A156] Bar-tailed Godwit (Limosa lapponica) [A157] Curlew (Numenius arquata) [A160] Redshank (Tringa totanus) [A162] Black-headed Gull (Chroicocephalus ridibundus) [A179] Common Gull (Larus canus) [A182] Herring Gull (Larus argentatus) [A184] Wetland and Waterbirds [A999] UK9020161 Carlingford Light-bellied Brent Goose (Branta bernicla hrota) To maintain or restore the favourable conservation condition of listed waterbirds , associated Lough SPA Common Tern (Sterna hirundo) wetland habitats. based on a detailed list of attributes and targets 5.5 km Sandwich Tern (Sterna sandvicenis) https://www.daera-ni.gov.uk/sites/default/files/publications/doe/carlingford-lough-SPA- conservation-objectives-2015.pdf
22 | Irish Water NIS – Omeath Sewerage Scheme
Potential Adverse Effects on the Natura 2000 Sites This section documents the final stage of the screening process. It is vital that an assessment of potential source-pathway-receptor links is undertaken to assess potential impact links between the receptor (European Sites) and source (proposed development) to establish the risk of any likely significant effects. It used the information collected on the sensitivity of the Qualifying Interests of each European Site and describes any likely significant effects from the construction, operation and decommissioning stages of the proposed development. This assumes the absence of mitigation measures with the exception of those incorporated in the design stage as good practice such as avoidance.
A standard source-pathway-receptor conceptual model was used to identify ‘relevant’ European sites (i.e. those which could be potentially affected). This conceptual model is a standard tool in environmental assessment. In order for an effect to occur, all three elements of this mechanism must be in place. The absence or removal of one of the elements of the mechanism means there is no likelihood for the effect to occur. In the context of the proposed works, the model comprises: Source(s) – e.g. sediment run-off from proposed works Pathway(s) – e.g. hydrological connection to a European site Receptor(s) – Qualifying habitats and species of European sites.
Potential impacts and their significance, if any, of a proposed development in this area on the European sites listed above are considered below where a source-pathway-receptor relationship has been identified. Impacts are considered in light of the conservation objectives of the Annex I habitats and Annex II species, or Annex I bird species, for which the site is designated.
Of the 9 sites listed in Table 2 and 3, the following four sites are considered further – Carlingford Shore SAC, Carlingford Lough SPA and Dundalk Bay SAC and SPA. There is no potential source-pathway-receptor connection between the proposed development site and the other 5 designated sites. These terrestrial sites are significantly removed from the development site and not connected via surface or groundwater in any way.
Overview of potential impacts of the new sewerage scheme Elements of the proposed works that may give rise to impacts and that will be considered for potential effects to European sites are as follows: Construction of a new WwTP and pump station on lands outside of, but close to, Carlingford Shore SAC; and Repair and extension of the existing outfall including access routes to the works location.
The rising mains and foul sewers of the proposed scheme will be installed within the existing road ways and will not have any impact on the SAC. Similarly the construction of the new pumping station is on a low value terrestrial habitat outside the SAC, will not have any direct or indirect impact on the SAC.
The potential impacts presented by the new WwTP and outfall repair / extention are related to the construction stage of the project. Once operational, the new sewerage scheme is expected to have a positive impact in terms of reduction in the levels of nutrients and pathogens being discharged into Carlingford Lough.
23 | Irish Water NIS – Omeath Sewerage Scheme
Potential direct impacts Some elements of the proposed works, including the laying of sewer and rising mains along Shore Road and repairs to the existing outfall pipe, are within Carlingford Shore SAC. Works at the outfall are 8m seaward of the SAC boundary. The qualifying habitats are associated with the coastal part of the SAC above the high tide mark but construction plant accessing the foreshore during the outfall extension works represent a potential direct impact on the SACs qualifying features (Annual Vegetation of Driftlines and Perennial Vegetation of Stony Banks). There is no risk to these habitats from the construction of the WwTP or pumping station,sewer/rising mains or directly from the extension of the outfall.
Potential indirect impacts The proposed works at the outfall are over 4km from Carlingford Lough SPA (Irish Site) at the nearest point. The qualifying species are winter migrants and if works are being carried out in the summer months (May to August) there is no potential for disturbance to these species.The impact on the general wetlands and waterbirds listed, regardless of the timing of the works, will be insignificant. No cranes will be used for the installation of the outfall extension on the foreshore which could cause risk of collision on bird migration flight paths. The impact on birds from the SPA which could potentially use the foreshore or marine area at the location will be insignificant due to the temporary nature of the works and the relatively small corridor of activity on the foreshore (approximately 300m in length).The shoreline along the length of the outfall pipeline comprises of mixed shoreline and littoral rock habitats which are not generally suitable for brent geese. Despite this, a brent goose was recorded on the intertidal area during the most recent survey in March 2016.
Carlingford Lough SPA as designated by Northern Ireland, is on the opposite side of the Lough approximately 4.6 km away. It is designated for internationally important numbers of Light bellied brent geese (winter migrants), Common terns and Sandwich terns (summer breeders). Any minor amount of sediment generated by the construction of the outfall extension is not expected to impact the qualifying species of either of the SPAs, given the distance involved and the natural association of coastal waterbird species with sediment-rich environments.
Waterbirds rely to some extent on nutrient inputs which may sustain communities of benthic prey and macroalgae. However high nutrient conditions can also result in a loss of foraging habitat e.g. epiphytic algae smothering seagrass beds (NPWS, 2013). The upgrade will result in an improvement in nutrient levels in the discharge, however diffuse sources of nutrients, particularly from agriculture, will continue to flow into the lough. While there may be localised shifts (outside of the SPA) in bird foraging due to food availability in the vicinity of the outfall, the upgrade is not likely to significantly affect the distribution or abundance of the waterbird population of the SPA alone or cumulatively with other future WwTP upgrades in the catchment.
The coastal/estuarine habitats of Dundalk Bay SAC, and the waterbird population of Dundalk Bay SPA they support, are located at a distance of approximately 25km from the proposed works via the potential pathway of Carlingford Lough/Irish Sea. Given the distance and taking account of the scale and limited extent of the proposed works, there is no possibility of any significant effect to these habitats, or of disturbance effects to waterbird species.
24 | Irish Water NIS – Omeath Sewerage Scheme
Although Carlingford Lough has not been designated at a Special Area of Conservation for marine mammals they are afforded protection by national (Wildlife Acts) and international legislation. All ceteceans (dolphins, whales and porpoises) occurring in European waters are included in Annex IV of the EU Habitats Directive and require strict protection measures to be put in place. Bottlenose dolphins, harbour porpoises, grey seal and commons seals are listed as Annex II species which requires the establishment of Special Areas of Conservation to protect their habitats.
Taking account of the scale of the proposed works, and the limited extent and duration within the intertidal zone, it is evaluation that there is limited potential to cause disturbance to marine mammals due to noise and vibration from plant movement on the intertidal area during the construction of the extension to the outfall pipeline.
It is also assumed that the Eurasian Otter (Lutra lutra), listed on Annex II and IV of the Habitats Directive will be present along the section of foreshore being assessed as part of these works. Otters follow tracks above the highwater line. which they mark with spraints at prominent features. The movement of plant and machinery across the shoreline to access the outfall pipe extension works during the low tide window potentially has the potential to cause disturbance short term indirect disturbance, however, there would be no interaction between the works and otters foraging or commuting, as the works will be undertaken during daylight hours above the tide.
Possible Cumulative Impacts with other Plans and Projects in the Area As part of Stage 1 Screening, in addition to the proposed sewerage scheme, other relevant projects and plans in the relevant region must also be considered. This step aims to identify at this early stage any possible significant effects on the Natura 2000 Sites from the proposed sewerage scheme in-combination or cumulative with other plans and projects. Existing plans and projects which have been examined include:
Draft Louth County Development Plan 2015-2021; Carlingford Water Management Unit Action Plan; Draft Louth Biodiversity Action Plan 2015 – 2020; and Existing Omeath sewerage scheme.
The above plans have been assessed in accordance with Article 6(3) of the Habitats Directive and Part XAB of the Planning and Development Act, 2000, and are not envisaged to result in significant effects on the integrity of the Natura 2000 network.
Screening Assessment A summary of the likely significant impact of the Omeath WWSS on the qualifying interests and conservation objectives of the identified Natura 2000 sites within the zone of influence are presented in Table 4 and Table 5.
25 | Irish Water NIS – Omeath Sewerage Scheme
Table 4. Potential Significant Impacts on SAC sites from the Omeath Sewerage Scheme European Qualifying Interest Description of potential impacts from the proposed Potential for Potential for Site development significant adverse significant Project effects? adverse in- combination effects? Carlingford Annual Vegetation of Driftlines The SAC boundary is directly adjacent (8m west ) to the Potential No pathways for Shore SAC extension works proposed at the outfall location. This pathways for potential significant qualifiying feature is a coastal habitat and could potentially adverse effects due adverse effects directly impacted by construction plant when accessing the to proximity to works foreshore. They generally occur above the high water mark but any polluting matter accidently released during the outfall extention works could potentially be deposited on this Perennial Vegetation of Stony Banks The SAC boundary is directly adjacent (8m west ) to the Potential No pathways for extension works proposed at the outfall location. This pathways for potential significant qualifiying feature is a coastal habitat and could potentially adverse effects due adverse effects directly impacted by contsruction plant when accessing the to proximity to works foreshore. Carlingford Alpine and Boreal heaths [4060] There is no pathway for effects which would have the No pathways for No pathways for Mountain Siliceous scree of the montane to snow levels (Androsacetalia potential for significant adverse impacts on these habitats potential significant potential significant SAC alpinae and Galeopsietalia ladani) [8110] arising from the proposed development, taking account of adverse effects adverse effects Calcareous rocky slopes with chasmophytic vegetation [8210] the separation distance and the character of the proposed Siliceous rocky slopes with chasmophytic vegetation [8220] development. Rostrevor Old sessile oak woods with Ilex and Blechnum in the British There is no pathway for effects which would have the No pathways for No pathways for Wood SAC Isles [91A0] potential for significant adverse impacts on these habitats potential significant potential significant arising from the proposed development, taking account of adverse effects adverse effects the separation distance and the character of the proposed development. Derryleckagh Transition mires and quaking bogs [7140] There is no pathway for effects which would have the No pathways for No pathways for SAC Old sessile oakm woods with Ilex and Blechnum in the British potential for significant adverse impacts on these habitats potential significant potential significant Isles [91A0] arising from the proposed development, taking account of adverse effects adverse effects the separation distance and the character of the proposed development. Dundalk Bay Estuaries [1130] There is no pathway for effects which would have the No pathways for No pathways for SAC Mudflats and sandflats not covered by seawater at low tide potential for significant adverse impacts on these habitats potential significant potential significant 10.5 km [1140] arising from the proposed development, taking account of adverse effects adverse effects
26 | Irish Water NIS – Omeath Sewerage Scheme
Perennial vegetation of stony banks [1220] the separation distance and the character of the proposed Salicornia and other annuals colonising mud and sand [1310] development. Atlantic salt meadows (Glauco-Puccinellietalia maritimae) [1330] Mediterranean salt meadows (Juncetalia maritimi) [1410] Eastern Northern Atlantic wet heaths with Erica tetralix [4010] There is no pathway for effects which would have the No pathways for No pathways for Mournes European dry heaths [4030] potential for significant adverse impacts on these habitats potential significant potential significant SAC Alpine and Boreal heaths [4060] arising from the proposed development, taking account of adverse effects adverse effects Siliceous alpine and boreal grasslands [6150] the separation distance and the character of the proposed Blanket bogs (* if active bog) * Priority feature [7130] development. Siliceous scree of the montane to snow levels (Androsacetalia alpinae and Galeopsietalia ladani) [ 8110] Siliceous rocky slopes with chasmophytic vegetation [8220] Slieve European dry heaths[4030] There is no pathway for effects which would have the No pathways for No pathways for Gullion SAC potential for significant adverse impacts on these habitats potential significant potential significant arising from the proposed development, taking account of adverse effects adverse effects the separation distance and the character of the proposed development.
27 | Irish Water NIS – Omeath Sewerage Scheme
Table 5. Potential Significant Impacts on SPA sites from the Omeath Sewerage Scheme Site Name Qualifying Features – Annex I Species Description of potential impacts from the proposed Potential for Potential for development significant adverse significant adverse in- Project effects? combination effects? Carlingford Light-bellied Brent Goose (Branta bernicla hrota) This SPA site is hydrologically connected to this SPA. However, Pathway present, No pathways for Lough SPA Wetlands and Waterbirds [A999] given the distance involved (6 km) it is considered that there is but significant potential significant no potential for suspended solids, pollutants (hydrocarbons.) and adverse effect not adverse effects other water quality impacts to give rise to significant adverse considered likely. effects. The temporary nature and the limited areal extent of the works on the foreshore means that any of the listed species using the foreshore will not be significantly adversely impacted. There are no significant adverse effects identified with regard to the wetlands and invertebrate communities that support the SPA bird populations. Dundalk Bay Great Crested Grebe (Podiceps cristatus); Greylag This SPA site is hydrologically connected to the foreshore Pathway present, No pathways for SPA Goose (Anser anser); Light-bellied Brent Goose element of the proposed development. However, given the but significant potential significant (Branta bernicla hrota); Shelduck (Tadorna distance involved (9 km) it is considered that there is no potential adverse effect not adverse effects tadorna); Teal (Anas crecca; Mallard (Anas for suspended solids, pollutants (hydrocarbons.) and other water considered likely. platyrhynchos); Pintail (Anas acuta); Common quality impacts to give rise to significant adverse effects. The Scoter (Melanitta nigra; Red-breasted Merganser temporary nature and the limited areal extent of the works on the (Mergus serrator); Oystercatcher (Haematopus foreshore means that any of the listed species using the ostralegus); Ringed Plover (Charadrius hiaticula); foreshore will not be significantly adversely impacted. There are Golden Plover (Pluvialis apricaria; Grey Plover no significant adverse effects identified with regard to the (Pluvialis squatarola); Lapwing (Vanellus wetlands and invertebrate communities that support the SPA vanellus); Knot (Calidris canutus); Dunlin (Calidris bird populations. alpina); Black-tailed Godwit (Limosa limosa); Bar- tailed Godwit (Limosa lapponica); Curlew (Numenius arquata); Redshank (Tringa totanus); Black-headed Gull (Chroicocephalus ridibundus); Common Gull (Larus canus); Herring Gull (Larus argentatus); Wetland and Waterbirds Carlingford Light-bellied Brent Goose (Branta bernicla hrota); This SPA site is hydrologically connected to the foreshore Pathway present, No pathways for Lough SPA Common Tern (Sterna hirundo); Sandwich Tern element of the proposed development. However, given the but significant potential significant (UK) (Sterna sandvicenis) distance involved (5.5 km) it is considered that there is no adverse effect not adverse effects potential for suspended solids, pollutants (hydrocarbons.) and considered likely. other water quality impacts to give rise to significant adverse
28 | Irish Water NIS – Omeath Sewerage Scheme
Site Name Qualifying Features – Annex I Species Description of potential impacts from the proposed Potential for Potential for development significant adverse significant adverse in- Project effects? combination effects? effects. The temporary nature and the limited areal extent of the works on the foreshore means that any of the listed species using the foreshore will not be significantly adversely impacted. There are no significant adverse effects identified with regard to the wetlands and invertebrate communities that support the SPA bird populations.
29 | Irish Water NIS – Omeath Sewerage Scheme
Screening Conclusions From the current screening assessment, taking account of supporting documentation, the potential for significant cumulative impacts affecting Carlingford Shore SAC arising from the construction of the Omeath Sewerage Scheme cannot be excluded. From the examination of the information available it is considered that the construction works have the potential to result in significant impacts to the Natura 2000 network, specifically in relation to direct impacts affecting the conservation interests of Carlingford Shore SAC.
Through an assessment of the pathways for effects and an evaluation of the project, taking account of the processes involved and the distance of separation between other Natura 2000 designations in the wider study area, it has been evaluated that there are no likely significant adverse effects on the qualifying interests of any other designated European Site.
On the basis of the findings of this Screening for Appropriate Assessment, it is concluded that the proposed Omeath Sewerage Scheme: (i) is not directly connected with or necessary to the management of a Natura 2000 site; and (ii) it cannot be exclude that the potential remains (i.e. uncertainty) for significant adverse effects on a Natura 2000 site, Carlingford Shore SAC.
Therefore, applying the Precautionary Principle and in accordance with Article 6(3) of the Habitats Directive, an Appropriate Assesment is required for the Omeath Sewerage Scheme, as part of a Natura Impact Statement.
30 | Irish Water NIS – Omeath Sewerage Scheme
Stage 2: Appropriate Assessment
This stage of the AA process, often referred to as Stage 2, assesses potential impacts of the proposed development on the integrity of designated Natura 2000 sites, with respect to their conservation objectives i.e. structure and function. Where required, mitigation measures are applied in order to avoid or minimise the risk. The AA Screening identified designated sites within the wider study area and concluded that the potential for significant adverse effects was limited to Carlingford Shore SAC.
Description of the Natura 2000 Site Potentially Affected
The Carlingford Shore SAC site comprises the entire southern shoreline of Carlingford Lough from Warrenpoint to west of Cooley Point. While the principal conservation interests lie in the perennial vegetation of stony banks and the annual vegetation of drift lines, the site also has intertidal sand and mudflats, patches of saltmarsh, some areas of dry grassland, and an area of mixed deciduous woodland.
The distribution of the known stony and drift line habitats, extend more or less continuously from Greenore to west of Cooley Point. They occur as a strip of varying width, from only a few metres in places, to up to about 50 m. One of the best developed areas is south of Ballagan Point. The perennial vegetation of the upper beach of these stony banks is widely ranging, well developed and often stable.8 The perennial vegetation of the stony banks is often interspersed with annual drift line vegetation occupying accumulations of drift material and gravels rich in nitrogenous organic matter. The mapping of these habitats presented in the NPWS conservation objectives and supporting documentation (NPWS 2013) do not identify the occurrence of either of these habitats within the footprint or in close proximity to the proposed Omeath WWSS development.
A relatively extensive expanse of intertidal flats (more sand than mud) occur, particularly between Greenore Point and Carlingford Harbour. The flats in this area are broken by outcropping reefs and some shingle deposits and saltmarsh on the drier higher rocks.
Description of the Qualifying Interests of the SAC Carlingford Shore SAC supports two Annex I habitats:
[1210] Annual vegetation of Drift Lines [1220] Perennial Vegetation of Stony Banks
Detailed conservation objectives have been developed for this site (NPWS, 20139) and the documentation available includes mapping and/or information for each Annex I habitat.
The stony and driftline habitats are identified as occurring from Greenore to west of Cooley Point (the eastern-most coastal areas of the peninsula) ca. 9km east of Omeath. In the vicinity of Omeath a small area of driftline vegetation occurs 215m south of the proposed WwTP site. This
8 NPWS (2013) Carlingford Lough SAC (Site code 2306) Conservation objectives supporting documents – coastal habitats. Version 1 May 2013. 9 NPWS (2013) Conservation Objectives Series - Carlingford Shore SAC 002306. Version 1. 15 Jul 2013.
31 | Irish Water NIS – Omeath Sewerage Scheme
vegetation occurs on sand and shingle which has formed a bank on the leeward (east) side of the existing pier at Omeath. This sparse vegetation community conforms loosely to the Annex I habitat ‘Annual Vegetation of Drift Lines’ with the presence of spear-leaved orache Atriplex prostrata, petty spurge Euphorbia peplis and and knotgrass Polygonum aviculare (as listed in the Annex I habitat description in the EU Habitats Interpretation Manual).
The foreshore parallel to the seawall and Shore Road has been fortified with large boulder to as part of a tidal rock armouring. A number of plant species identified as occurring within the Annex I habitat type ‘Perennial Vegetation of Stony Banks’ were recorded from this bouldered area of the upper shore. As this area comprises artificially placed boulder rock armour and does not correspond to stony banks, the flora recorded from this location are not evaluated as corresponding to the Annex I habitat requirements along the Shore Road, within the study area of the Omeath WWSS.
Aside from the triangular area of sand by the pier, the high tide mark reaches the coastal build habitats (stone wall and boulders to roadway). There is no coastal vegetation around the lower intertidal zone of Flat Rock (or Black Rock) where the outfall extenision works are proposed. The area of foreshore where the outfall pipe extends comprises intertidal littoral rock and mixed sediment shores which is extensively covered by seaweeds. These consist of serrated wrack Fucus serratus, Egg wrack seaweed Ascophylum nodosum, bladderwrack Fucus vesiculosus and sea lettuce Ulva latuca. Dense mussel Mytilus edulis beds were in the lowtide zone, along with cockles Cerastoderma edules and common periwinkles Littorina littorea.
Conservation Objectives of the Carlingford Shore SAC 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 importance of a site designated under the Habitats Directive is defined by its qualifying features or interests. Qualifying interests for any Natura 2000 site are listed on a pro forma, called the Natura 2000 standard data form, which forms the basis of the rationale behind designation, and informs the Conservation Management Plan for targeted management and monitoring of key species and habitats.
Favourable conservation status of a habitat is achieved when: Its natural range, and area it covers within that range, are stable or increasing; The specific structure and functions which are necessary for its long-term maintenance exist and are likely to continue to exist for the foreseeable future; and The conservation status of its typical species is favourable.
The favourable conservation status of a species is achieved when: Population dynamics data on the species concerned indicate that it is maintaining itself on a long-term basis as a viable component of its natural habitats; The natural range of the species is neither being reduced nor is likely to be reduced for the foreseeable future; and
32 | Irish Water NIS – Omeath Sewerage Scheme
There is, and will probably continue to be, a sufficiently large habitat to maintain its populations on a long-term basis.
The generic conservation objective set out for this SAC are to maintain or restore the favourable conservation condition of the Annex I habitats for which the SAC has been selected: [1210] Annual vegetation of Drift Lines [1220] Perennial Vegetation of Stony Banks (conservation status: Inadequate, Stable)
Detailed conservation objectives, as per the NPWS (2013) documentation are as follows:
Annual Vegetation of Drift Lines Attribute: Habitat Area; o Target: The permanent habitat area is stable or increasing subject to natural processes, including erosion and succession. Attribute: Habitat Distribution; o Target: No decline, or change in habitat distribution, subject to natural processes. Attribute: Physical structure – functionality and sediment supply; o Target: Maintain the natural circulation of sediment and organic matter, without any physical obstructions; Attribute: Vegetation structure - zonation; o Target: Maintain the range of coastal habitats including transitional zones, subject to natural processes including erosion and succession. Attribute: Vegetation composition – typical species and sub-communities; o Target: Maintain the presence of species-poor communities with typical species: sea rocket (Cakile maritime), sea sandwort (Hockenya peploides), prickly saltwort (Salsola kali) and orache (Atriplex spp.). Attribute: Vegetation composition – negative indicator species; o Target: Negative Indicator species (including non-natives) to represent less than 5% cover.
Perennial Vegetation of Stony Banks Attribute: Habitat Area; o Target: Area stable or increasing, subject to natural processes, including erosion and succession. Attribute: Habitat Distribution; o Target: No decline, or change in habitat distribution, subject to natural processes. Attribute: Physical structure – functionality and sediment supply; o Target: Maintain the natural circulation of sediment and organic matter, without any physical obstructions; Attribute: Vegetation structure - zonation; o Target: Maintain the range of coastal habitats including transitional zones, subject to natural processes including erosion and succession. Attribute: Vegetation composition – typical species and sub-communities; o Target: Maintain the typical vegetated shingle flora including the range of sub- communities within the different zones.
33 | Irish Water NIS – Omeath Sewerage Scheme
Attribute: Vegetation composition – negative indicator species; o Target: Negative Indicator species (including non-natives) to represent less than 5% cover.
Impact Characteristics and Evaluation
Potential impacts arising from the proposed development, alone or in combination with other plans or project, are evaluated with respect to the Qualifying Interests of the Carlingford Shore SAC. The ecological impact assessment of potential impacts on European Sites is conducted utilising a standard Source-Receptor-Pathway model; where, all three elements of this mechanism must be in place to establish an impact arising. In addition, in line with the Appropriate Assessment process (EC, 2001; DOEHLG, 2010) mitigation has been discussed and applied to each potential impact in order to ensure that the proposed development, individually or in combination with other plans or projects, will not have a significant effect on, or adversely affect the integrity of any European Site. The following parameters are described when characterising ecological impacts: Direct and Indirect Impacts - An impact can be caused either as a direct or as an indirect consequence of a proposed development. Magnitude - Magnitude measures the size of an impact, which is described as high, medium, low, very low or negligible. Extent - The area over which the impact occurs – this should be predicted in a quantified manner.
Duration - The time for which the effect is expected to last prior to recovery or replacement of the resource or feature: Temporary: Up to 1 Year; Short Term: The effects would take 1-7 years to be mitigated; Medium Term: The effects would take 7-15 years to be mitigated; Long Term: The effects would take 15-60 years to be mitigated; Permanent: The effects would take 60+ years to be mitigated.
Likelihood: Certain/Near Certain: >95% chance of occurring as predicted; Probable: 50-95% chance as occurring as predicted; Unlikely: 5-50% chance as occurring as predicted; Extremely Unlikely: <5% chance as occurring as predicted.
Impact Prediction
Direct Adverse Effects Construction As noted in the screening section there is a potential risk to the qualifying habitats ‘Annual Vegetation of Driftlines and perennial vegetation of stony banks’ if the outfall works site on the foreshore was to be accessed through this area of habitat. The habitat is quite fragile and small in extent and machinery access could lead to partial loss of vegetation. This habitat would be present in the summer months when construction works are proposed and mitigation by avoidance is proposed below.
34 | Irish Water NIS – Omeath Sewerage Scheme
The presence of a number of the species listed in the Conservation Objectives supporting document for Carlingford Shore SAC suggests that ‘Perennial Vegetation of Stony Banks’ is present at the southern end of Shore Road in Omeath. The low coastal wall ends at this point and has been identified as a potential access point to the foreshore for machinery.
Operation The WwTP treatment standards and discharge via the existing pipe outfall will lead to a localised improvement in water quality particularly with respect to pathogens and phosphorus. Effects of water quality improvement on the qualifying features of Carlingford Shore SAC will be imperceptible with reference to the upper tidal qualifying habitats for which this SAC is designated. There are therefore no direct adverse impacts on the qualifying interests of this Natura 2000 site. In terms of overall water quality, the proposed upgrade to the Omeath WWSS are evaluated as being positive, with beneficial effects in terms of bacteriological and nutrient inputs to Carlingford Lough.
Indirect Adverse Effects Construction There is also a more general risk to water quality if best practice construction pollution control measures are not adhered to. As works at the outfall will take place during low tides, any pollutants could be transferred back to intertidal habitats on a rising tide. However, even in the absence of these measures, the risk of any pollutant reaching the supra-tidal coastal qualifying habitat is considered very low. General best practice pollution control and biosecurity measures are listed below and will be a mandatory requirement for any construction contractors. In particular it is noted that there can be no storage of fuels, machinery or materials within the SAC.
Operation The operation of the proposed Omeath WWSS will not have any potential for indirect adverse effects on the upper shoreline of Carlingford Lough within the Carlingford Lough SAC, precluding the potential for interaction or impacts on the Annex I habitats for which this site is designated.
In-Combination / Cumulative Effects Construction There are no construction phase impacts arising during the development of the Omeath WWSS which would have the potential to interact cumulatively with existing pressures and impacts affecting the Annex I habitats on the upper shore of Carlingford Lough SAC.
Operation Catchment pressures identified in the Carlingford Water Managment Unit Action Plan (NBIRBD, 2010) include three WwTP’s (Omeath, Greenore and Carlingford) and one Section 4 licensed discharge. Approximately 65% of the phosphorus load is from diffuse sources (predominately agriculture) with the rest identified as arising from point sources, including WwTP’s. There are high Nitrogen levels in Carlingford Lough and the main source of Dissolved Inorganic Nitrogen (DIN) inputs to Carlingford Lough is due to riverine inputs, representing approximately 88% of inputs. Wastewater Treatment Plants are evaluated as contributing a negligible < 0.2% to DIN loadings to Carlingford Lough (Tobin, 2012). DIN removal would therefore not be necessary at Omeath. On this basis, the proposed Omeath WWSS will result in a localised improvement in
35 | Irish Water NIS – Omeath Sewerage Scheme
water quality and an overall beneficial impact on water quality, despite this, the scale and extent of such effects in Carlingford Lough are evaluated as being imperceptible, when compared with the loadings attributable to other catchment pressures.
Table 6.0 Potential Impacts and Significance of Effects on the Qualifying Interests of the Carlingford Shoreline SAC. Impacts affecting other Annex II and IV species not listed as qualifying interests are also evaluated for clarity.
Qualifying Summary Potential Impact Significance of Potential Impacts Without Interests Description Mitigation Annual Direct damage to these habitats by The magnitude of impact caused by machinery Vegetation of construction plant and personnel accessing foreshore through this habitat would be Driftline accessing the foreshore. high (habitat loss). Magnitude of the impact caused Vegetation by personnel trampling on this habitat would be Indirect damage due to despostion of medium with a full recovery possible. The extent of Perennial polluting matter accidently released the damage (width of tracked excavator) would be vegetation of during outfall extension works. locally significant but insignificant in terms of the area stony banks of the entire SAC .
Depostion of pollutants from accidental release would be low due to dilution effects and temporary in nature Otters Physical disturbance due to presence Magnitude would be low as the works will proceed of personnel and machinery on the during the low tide allowing ample area of foreshore foreshore. for individual otter to avoid contact. There will be no physical barriers to impede otter access along the shoreline Seals Physical disturbance due to presence Significance of impact on seals is low due to the of personnel and machinery on the distance to the nearest haul out location (6km). Works foreshore. are temporary in nature and excavation will take place in soft sediment removing requirement for rock breaking. Cetaceans Potential noise impact during Works are temporary in nature and excavations will installation of the outfall extention . take place in soft sediment removing requirement for rock breaking which is detremintal to cetaceans .
Mitigation Measures Mitigation by Avoidance Potential direct impacts affecting the Qualifying Interests of Carlingford Shore SAC (Annual Vegetation of Driftlines and Perennial Vegetation of Stony Banks ) have been identified. These habitats identified in Figure 1 will be avoided by construction workers and machinery while accessing the foreshore. A ramp consisting of timber access mats will be used by machinery and personnel accessing the foreshore to avoid damage to any Perennial Vegetation of Stony Banks which occurs along the shoreline near the proposed pump station.
Construction Phase Mitigation
Proper site management during construction must be carried out to ensure that all necessary measures are taken to prevent run-off/pollutants from entering the intertidal or subtidal zones of Carlingford Lough. The following standard practice pollution control measures will be incorporated into a Construction Management Plan (CMP) for the project once developed, which the contractor will be obliged to follow to remove any risk of a pollution incident: Method Statements shall be submitted in full to Lough County Council/Irish Water for review and approval two weeks prior to the commencement of the works on site.
36 | Irish Water NIS – Omeath Sewerage Scheme
The Contractor shall prevent their operation polluting the Lough by implementing strict controls regarding sediment generation and other pollutants associated with the works, including the provision of attenuation measures, silt traps or geotextile curtains to reduce and intercept sediment release into the water. The Contractor shall ensure that all fuel or lubricating oils stored in bulk on the site are located as far as reasonably possible from any Lough and outside of Carlingford Shore SAC, and that such stores are covered and surrounded with an effective bund capable of holding the full contents of the store, and shall be kept locked when not in use. The Contractor will inspect machinery for leaks on a regular basis. The Contractor will ensure that stockpiling of excessive volumes of loose soil material/debris onsite is avoided, and surplus material is removed from the site as soon as work is completed. Any stockpile areas will be kept away from the Lough and outside of Carlingford Shore SAC and covered with a waterproof cover. The Contractor will ensure that any excavated/waste material is used/disposed of responsibly. Its disposal should not lead to the loss or damage of any natural or semi- natural habitats elsewhere. This material should not be placed close to any local watercourse or waterbody as it may result in an increase in the sediment load of that watercourse. No machinery or apparatus including plant, tools, offices, sheds, surplus materials, rubbish and temporary erections will be stored or located within the SAC. The temporary construction base will be located outside of Carlingford Shore SAC.
Marine Mammals, Otters , Annex IV species and other protected fauna If works at the outfall location require drilling or rock breaking and this will not be undertaken in the dry during low tide, it will be necessary to employ a Marine Mammal Observer to follow the lastest NPWS Guidance to manage the manage the risk to marine mammals from man-made sound sources in Irish Waters (NPWS 2014)10. Machinery will access the foreshore at a suitable location (potentially near to the pumping station site) and track perpendicular to the upper shore in order to limit the potential risk of accidental contact with otters. Although no evidence of protected species were recorded to inform the current assessment, it remains likely that an extended period will expire between authorisation of the proposed works and the commencement of construction activity. Therefore if over six months expire, it will be necessary to conduct additional detailed surveys of the proposed WwTP, pumping station and pipeline works corridor to identify the presence of otter holts, bat roosting sites and badgers setts. If impacts on the habitats, resting or breeding places of these species are unavoidable, licences maybe required under the Wildiife Act or deregations under the Habitat Regulations. The results of these surveys will be submitted to the National Parks and Wildlife Services as part of the licence applications.
Biosecurity
Due to the presence of Japanese knotweed occurring in close proximity to the proposed WwTP site, it is proposed that the development site be clearly defined and if necessary this stand be
10 http://www.npws.ie/sites/default/files/general/Underwater%20sound%20guidance_Jan%202014.pdf
37 | Irish Water NIS – Omeath Sewerage Scheme
excluded with a 10m buffer zone, to ensure no machinery or construction activities associated with the proposed development enter or move material, soil or spoil from this area. If access or works within this contaminated ground are required, it will be necessary to engage a suitably qualified ecologist to develop a Method Statement outlining how the contractor will manage and prevent its spread to neighbouring sites and the SAC. The statement will describe the most appropriate treatment option based on the specific site, the control measures required to prevent its spread during construction and a chemical treatment programme to eradicate the plant. The Contractor shall also adhere to the requirements of Inland Fisheries Ireland (2010) Biosecurity Protocol for Field Survey Work with respect to the protocols developed for the control of the spread of alien species to the aquatic environment.
Monitoring As the proposed works are to be undertaken within the intertidal environment, within the Carlingford Lough SAC, it will be necessary to engage a suitably qualified ecologist to monitor the Contractor’s full and complete implementation and compliance with the required mitigation and the details featured in the Contractor’s Construction Environmental Management Plan to be delivered to Irish Water in advance of works commencing. The Contractor may engage their own representative ecologist, however, it will be necessary for the proponent to have an independently appointed consultant ecologist to report directly on compliance.
Conclusion Statement for Appropriate Assessment
The proposed Omeath WWSS includes the WwTP, pumping station and associated sewerage scheme works. These have been evaluated with regard to the designated Natura 2000 sites within the wider study area. Potential impacts affecting the Qualifying Interests of the Carlingford Shore SAC, Carlingford Lough SPA, Dundalk Bay SAC and Dundalk SPA have been evaluated. Specific assessment has been undertaken with reference to the Annex I habitats listed as qualifying interests of the Carlingford Lough SAC, i.e. annual vegetation of driftlines and perennial vegetation of stony banks. Furthermore water quality impacts and potential disturbance to waterbirds, marine mammals and otters have been addressed. With the successful implementation of mitigation and monitoring measures described above, the proposed development, either alone or in-combination with other plans or projects will not result in significant adverse effects to the integrity of any European Sites, in view of their conservation objectives.
Potential impacts to the listed habitats will be mitigated through avoidance by construction vehicles and personnel while potential impacts during outfall line extension will be avoided implementation of the mitigation measures and good site management. The potential impacts during the operational phase will be managed via monitoring of the treated effluent quality. The mitigation measures set out in the current assessment, in addition to commitments will be incorporated into a Construction Environmental Management Plan. It is therefore concluded that the proposed development will not, beyond reasonable scientific doubt, adversely affect the integrity of any European Site (Natura 2000 site); whether directly, indirectly or cumulatively.
38 | Irish Water NIS – Omeath Sewerage Scheme
Plates
Plate 1. View of Shore Road, with vegetated road verge and vegetation growing on rock armour above the storm high water mark.
Plate 2. Annex I ‘Perennial vegetation of driftlines' occurring on sand and shingle to the south of the existing pier.
39 | Irish Water NIS – Omeath Sewerage Scheme
Plate 3. View of the proposed pumping station site, 2015.
Plage 4. View of the proposed pumping station site, 2016.
40 | Irish Water NIS – Omeath Sewerage Scheme
Plate 5. Immature alder, ash and sycamore, with significant bramble understory within the proposed WwTP development site, 2016.
41 | Irish Water NIS – Omeath Sewerage Scheme