For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 05-03-2015:00:06:17 Attachment No. C

C.1 Site Management & Control

Staff structure: • Facility Manager • Nominated Deputy Manager • Machine Drivers (2 No.) • General Operatives (2 No.) • Crane Driver (1 No.)

All facility employees have the requisite qualifications and experience to complete their assigned tasks.

C2. Environmental Management System

Greenore Port Ltd has developed elements of an environmental management system for the site, as required under Condition 2 of the current Waste Permit.

There are two waste handling procedures for site operations – copies of these are included separately in Attachment No. C.

Work is progressing on-site to develop the remaining elements of the site’s management system as required under Condition 2 of the Waste Permit.

C3. Hours of Operation

As the ship movement depends on the tide, the operational hours i.e. the times the bales are loaded onto the ships, are 24 hours a day 365 days a year. The waste acceptance hours are 08.00 to 18.00 Monday to Friday inclusive For inspection and purposes 08.00 only. to 14.00 on Saturday. Wastes are not Consent of copyright owner required for any other use. accepted at the facility on Sundays or Public Holidays.

C.4 Fit and Proper Person

Neither Greenore Port Ltd nor the company directors have been convicted under the Environmental Protection Agency Act 1992, as amended, the Waste Management Act 1996, as amended, the Local Government (Water Pollution) Acts 1997 and 1990, the Air Pollution Act 1987 and the Air Pollution Act 1987 (Environmental Specifications for Petrol and Diesel Fuels)(Amendment) Regulations 2004. A copy of the most recent audited accounts for Greenore Port Ltd is enclosed.

EPA Export 05-03-2015:00:06:17 DRAFT FINANCIAL STATEMENTS 3 September 2014

Greenore Port Limited

Directors' Report and

Financial Statements

for the year ended 31 December 2013

For inspection purposes only. Consent of copyright owner required for any other use.

84 Northumberland Road Duignan Carthy O'Neill Ballsbridge Chartered Accountants Dublin 4 Registered Auditors

EPA Export 05-03-2015:00:06:17 DRAFT FINANCIAL STATEMENTS 3 September 2014

Greenore Port Limited

Contents

Page

Contents 1

Company Information 2

Directors' Report 3 - 4

Independent Auditors' Report 5 - 6

Profit and Loss Account 7

Balance Sheet 8

Notes to the Financial Statements 9 - 22

For inspection purposes only. Consent of copyright owner required for any other use. Appendices 24

Page 1

EPA Export 05-03-2015:00:06:17 DRAFT FINANCIAL STATEMENTS 3 September 2014

Greenore Port Limited

Company Information

Directors E O'Reilly T King

Secretary V Price

Company Number 21631

Registered Office Greenore Co. Louth

Auditors Duignan Carthy O'Neill 84 Northumberland Road Ballsbridge Dublin 4

Business Address Greenore Co. Louth

Bankers Danske Bank Finance Centre

1For Airton inspection Close purposes only. Consent of copyright owner required for any other use. Dublin 24

Bank of Scotland (Ireland) Limited 72 - 74 Harcourt Street Dublin 2

Sankaty Advisors LLC 111 Huntington Avenue Boston, MA 02199

Solicitors Arthur Cox Arthur Cox Building Earlsfort Terrace Dublin 2

Page 2

EPA Export 05-03-2015:00:06:17 DRAFT FINANCIAL STATEMENTS 3 September 2014

Greenore Port Limited

Directors' Report for the year ended 31 December 2013

The directors present their report and the financial statements for the year ended 31 December 2013.

Principal Activity The company owns and operates the port at Greenore, Co. Louth. The directors have no plans to change the activities and operations of the company in the forseeable future.

Results And Dividends The results for the year are disclosed on page 7. The company did not pay a dividend (2012 : €Nil).

Research and Development The company did not engage in any research and development activity during the year.

Financial State of Affairs In the opinion of the directors, the state of affairs of the company is satisfactory and there is no material change since the balance sheet date.

The directors of Greenore Port Limited are aware of the statutory obligations in relation to providing a fair review of the company's development and performance. The directors are satisfied that the company faces no uncertainties or risks in the forseeable future other than the normal risks and uncertainties in the development and day to day operations of the company.

Directors and their Interests The directors and secretary of the company as at 31 December 2013, are listed on page 2.

The directors and secretary had no interests in the shares in, or debentures or loan stock of, the company or group companies. For inspection purposes only. Consent of copyright owner required for any other use. Political Donations During the year, the company made no political donations which are disclosable in accordance with the Electoral Act, 1997.

Post balance sheet events No material events affecting the company have occurred since the balance sheet date.

Books of Account The measures taken by the directors to ensure compliance with the requirements of Section 202, Companies Act, 2001, regarding proper books of account are the implementation of necessary policies and procedures for recording transactions, the employment of competent accounting personnel with appropriate expertise and the provision of adequate resources to the financial function. The books of account are maintained at Greenore, Co. Louth.

Page 3

EPA Export 05-03-2015:00:06:17 DRAFT FINANCIAL STATEMENTS 3 September 2014

Greenore Port Limited

Directors' Report for the year ended 31 December 2013

Directors' Responsibilities The directors are responsible for preparing the Annual Report and the financial statements in accordance with applicable Irish law and Generally Accepted Accounting Practice in Ireland including the accounting standards issued by the Accounting Standards Board and published by Chartered Accountants Ireland.

Irish company law requires the directors to prepare financial statements for each financial year which give a true and fair view of the state of the affairs of the company and of the profit or loss of the company for that year. In preparing these the directors are required to: - select suitable accounting policies and apply them consistently; - make judgements and estimates that are reasonable and prudent; - prepare the financial statements on the going concern basis unless it is inappropriate to presume that the company will continue in business.

The directors are responsible for keeping proper accounting records which disclose with reasonable accuracy at any time the financial position of the company and to enable them to ensure that the financial statements comply with the Companies Acts 1963 to 2013. They are also responsible for safeguarding the assets of the company and hence for taking reasonable steps for the prevention and detection of fraud and other irregularities.

Auditors The auditors, Duignan Carthy O'Neill, Chartered Accountants, have indicated their willingness to continue in office in accordance with the provisions of Section 160(2) of the Companies Act, 1963.

For inspection purposes only. Consent of copyright owner required for any other use.

On behalf of the Board

______Director

______Director

Date:

Page 4

EPA Export 05-03-2015:00:06:17 Independent Auditors' Report to the members of Greenore Port Limited

We have audited the financial statements of Greenore Port Limited for the year ended 31 December 2013 on pages 7 to 22, which comprise the Profit and Loss Account, the Balance Sheet and the related notes. These financial statements have been prepared under the accounting policies set out on page 9 to 10. The financial reporting framework that has been applied in their preparation is Irish law and accounting standards issued by the Financial Reporting Council and promulgated by Chartered Accountants Ireland (Generally Accepted Accounting Practice in Ireland).

This report is made solely to the company's members, as a body, in accordance with Section 193 of the Companies Act, 1990. Our audit work has been undertaken so that we might state to the company's members those matters we are required to state to them in an auditor's report and for no other purpose. To the fullest extent permitted by law, we do not accept or assume responsibility to anyone other than the company and the company's members as a body, for our audit work, for this report, or for the opinions we have formed.

Respective responsibilities of directors and auditors As explained more fully in the Directors' Responsibilities Statement on page 4 the directors are responsible for the preparation of financial statements giving a true and fair view. Our responsibility is to audit and express an opinion on the financial statements in accordance with Irish law and International Standards on Auditing (UK and Ireland). These standards require us to comply with the Auditing Practice Board's (APB's) Ethical Standards for Auditors.

Scope of the audit of the financial statements An audit involves obtaining evidence about the amounts and disclosures in the financial statements sufficient to give reasonable assurance that the financial statements are free from material misstatement, whether caused by fraud or error. This includes an assessment of: whether the accounting policies are appropriate to the company's circumstances and have been consistently applied and adequately disclosed; the reasonableness of significant accounting estimates made by the directors; and the overall presentation of the financial statements. In addition, we read all the financial and non-financial information in the directors report to identify material inconsistencies with the audited financial statements. If we become aware of any apparent material misstatements For inspection or purposes inconsistencies only. we consider the implications for our Consent of copyright owner required for any other use. report.

Opinion In our opinion the financial statements:

- give a true and fair view, in accordance with Generally Accepted Accounting Practice in Ireland, of the state of the company's affairs as at 31 December 2013 and of its profit for the year then ended: and

- have been properly prepared in accordance with the requirements of the Companies Acts, 1963 to 2013 and the European Communities (Company:Group Accounts) Regulations 1992.

Page 5

EPA Export 05-03-2015:00:06:17 Independent Auditors' Report to the members of Greenore Port Limited Continued...

Matters on which we are required to report by the Companies Acts 1963 to 2013 - We have obtained all the information and explanations which we consider necessary for the purposes of our audit.

- In our opinion, proper books of account have been kept by the company.

- The financial statements are in agreement with the books of account.

- In our opinion, the information given in the directors' report on pages 3 - 4 is consistent with the financial statements.

- The net assets of the company, as stated in the Balance Sheet on page 8, are more than half of the amount of its called up share capital and, in our opinion, on that basis there did not exist at 31 December 2013 a financial situation which under Section 40(1) of the Companies (Amendment) Act 1983 would require the convening of an extraordinary general meeting of the company.

Matters on which we are required to report by exception We have nothing to report in respect of the provisions in the Companies Acts 1963 to 2013 which require us to report to you if, in our opinion the disclosures of directors' remuneration and transactions specified by law are not made.

Timothy F. Carthy for and on behalf of 84 Northumberland Road Duignan Carthy O'Neill Dublin 4 Chartered Accountants Ireland Registered Auditors

Date: For inspection purposes only. Consent of copyright owner required for any other use.

Page 6

EPA Export 05-03-2015:00:06:17 DRAFT FINANCIAL STATEMENTS 3 September 2014

Greenore Port Limited

Profit and Loss Account for the year ended 31 December 2013

Continuing operations

2013 2012 Notes € € Turnover 2 2,070,525 1,979,552

Cost of sales )(1,181,775 )(1,232,265 Gross profit 888,750 747,287

Administrative expenses )(800,159 )(673,689 Operating profit 3 88,591 73,598

Rental Income 50,694 67,935 Interest payable and similar charges 4 )(12,604 )(94,940 Profit on ordinary activities before taxation 126,681 46,593

Tax charge on profit on ordinary activities 6 )(22,817 )(37,467 Profit for the year 103,864 9,126

There are no recognised gains or losses other than the profit for the above two financial years. For inspection purposes only. Consent of copyright owner required for any other use.

The financial statements were approved by the company's Board of Directors on ______and signed on its behalf by:

______Director

______Director

Page 7

EPA Export 05-03-2015:00:06:17 DRAFT FINANCIAL STATEMENTS 3 September 2014

Greenore Port Limited

Balance Sheet as at 31 December 2013

2013 2012 Notes € € € € Fixed Assets Tangible assets 7 10,551,237 21,082,569 Investments 8 136,168 136,168 10,687,405 21,218,737

Current Assets Debtors 9 90,873 88,826 Cash at bank and in hand 417,642 238,141 508,515 326,967

Creditors: (amounts falling due within one year) 10 )(973,960 )(8,604,026 Net Current Liabilities )(465,445 )(8,277,059 Total Assets Less Current Liabilities 10,221,960 12,941,678

Creditors: (amounts falling due after more than one year) 11 )(2,081,547 )(4,874,748

Provision for Liabilities and Charges 13 )(519,393 )(549,774 For inspection purposes only. Net Assets Consent of copyright owner required for any other7,621,020 use. 7,517,156

Capital and Reserves Called up share capital 15 672,961 672,961 Revaluation reserve 16 2,806,121 2,806,121 Profit and loss account 4,141,938 4,038,074 Equity Shareholders' Funds 17 7,621,020 7,517,156

The financial statements were approved by the company's Board of Directors on ______and signed on its behalf by:

______Director

______Director

Page 8

EPA Export 05-03-2015:00:06:17 DRAFT FINANCIAL STATEMENTS 3 September 2014

Greenore Port Limited

Notes to the Financial Statements for the year ended 31 December 2013

1. Accounting Policies

1.1. Basis of preparation The financial statements have been prepared in accordance with accounting standards generally accepted in Ireland and Irish statute comprising the Companies Acts, 1963 to 2013. Accounting Standards generally accepted in Ireland in preparing financial statements giving a true and fair view are those published by Chartered Accountants Ireland and issued by the Accounting Standards Board.

The company meets the size criteria for a small company set by the Companies (Amendment) Act 1986 and therefore, in accordance with FRS 1: Cash Flow Statements, it has not prepared a cash flow statement.

1.2. Turnover Turnover represents the total invoice value, excluding value added tax, of sales made during the year.

1.3. Tangible fixed assets and depreciation Tangible fixed assets are stated at cost or at valuation, less accumulated depreciation. No depreciation is provided on freehold land. The charge for depreciation is calculated to write down cost or valuation of other tangible fixed assets to their estimated residual values by equal annual instalments over their expected useful lives which are as follows:

Buildings and portworks 50 years Plant and Machinery 10 - 20 years For inspection purposes only. Consent of copyright owner required for any other use. 1.4. Leased assets Tangible fixed assets acquired under finance leases are included in the balance sheet at their equivalent capital value and are depreciated over the shorter of the lease term and their useful lives. The corresponding liabilities are recorded as a creditor and the interest element of the finance lease rentals is charged to the profit and loss account on an annuity basis.

1.5. Financial fixed assets Investments in subsidiary undertakings Investments in subsidiary undertakings are shown at cost less provisions for permanent diminuation in value. Income from financial assets is recognised in the profit and loss account in the period in which it is receivable.

Page 9

EPA Export 05-03-2015:00:06:17 DRAFT FINANCIAL STATEMENTS 3 September 2014

Greenore Port Limited

Notes to the Financial Statements for the year ended 31 December 2013

...... continued

1.6. Currencies The accounts have been presented in Euros (€). Transactions in foreign currencies are recorded at the rate ruling at the date of the transactions. The resulting monetary assets and liabilities are translated at the balance sheet rate and the exchange differences are dealt with in the profit and loss account.

1.7. Pensions Pension benefits for specific employees are met by payments to an independently administered defined contribution pension fund. Contributions are charged to the profit and loss account in the year in which they fall due.

1.8. Taxation The charge for taxation is based on the profit for the year. Deferred taxation is accounted for in respect of timing differences between profit as computed for taxation purposes and profit as stated in the financial statements.

1.9. Government Grants Capital government grants received are shown as deferred income and credited to the profit and loss account by instalments on a basis consistent with the depreciation policy of the relevant assets. Other grants are credited to the profit and loss account to offset the matching expenditure.

1.10. Consolidated accounts The company is a subsidiary of an EU parent and is therefore exempt from the requirement to For inspection purposes only. prepare consolidated financialConsent of statements copyright owner byrequired virtue for any other of use. Regulation 9 of the European Communities (Companies: Group Accounts) Regulations, 1992. Consequently, these financial statements deal with the results of the company as a single entity.

2. Turnover 2013 2012 Turnover is derived exclusively from the € € ownership and operation of the port at Greenore, Co. Louth 2,070,525 1,979,552

Page 10

EPA Export 05-03-2015:00:06:17 DRAFT FINANCIAL STATEMENTS 3 September 2014

Greenore Port Limited

Notes to the Financial Statements for the year ended 31 December 2013

...... continued

3. Operating profit 2013 2012 € € Operating profit is stated after charging: Depreciation of tangible assets 450,854 455,587 Government Grants Amortised )(37,044 )(37,044 Directors' fees 4,969 )(4,168 Auditors' remuneration - Audit 10,000 10,000 - Tax 1,225 1,225 - Other 1,000 1,000

4. Interest receivable and similar income 2013 2012 € €

Interest Receivable 2,202 1,086 Finance lease interest & charges )(643 )(432 Interest on bank overdraft and loans )(14,163 )(20,594 Interest on deferred purchase consideration - )(75,000 )(12,604 )(94,940

For inspection purposes only. Consent of copyright owner required for any other use.

Page 11

EPA Export 05-03-2015:00:06:17 DRAFT FINANCIAL STATEMENTS 3 September 2014

Greenore Port Limited

Notes to the Financial Statements for the year ended 31 December 2013

...... continued

5. Employees Number of employees The average monthly numbers of employees (including the directors) during the year were: 2013 2012 Number Number Management (including directors) 1 1 Administration 3 3 4 4

Employment costs 2013 2012 € €

Wages and salaries 181,599 177,287 Social welfare costs 13,458 18,336 Pension costs 15,419 15,756 210,476 211,379

For inspection purposes only. Consent of copyright owner required for any other use.

Page 12

EPA Export 05-03-2015:00:06:17 DRAFT FINANCIAL STATEMENTS 3 September 2014

Greenore Port Limited

Notes to the Financial Statements for the year ended 31 December 2013

...... continued

6. Taxation 2013 2012 € € Current year taxation Corporation Tax 52,567 25,791 Prior year adjustment 631 5,622 Deferred tax provision )(30,381 6,054 22,817 37,467

Factors affecting tax charge for the period 2013 2012 € €

Profit on ordinary activities before tax 126,681 46,593

Profit on ordinary activities multiplied by the rate of corporation tax of 12.5% (2012 - 12.5%) 15,835 5,824

Effects of: Fixed Asset Impairment 18,251 - Exempt Income - Grants )(4,631 )(4,631 Capital element of lease rentals )(250 54 Depreciation charges not allowable 19,821 19,683 Income charged at higher rate of tax 3,372 5,785 Other expenses not claimable For inspection purposes only. 169 125 Consent of copyright owner required for any other use. Loss Relief - )(1,049 52,567 25,791

Page 13

EPA Export 05-03-2015:00:06:17 DRAFT FINANCIAL STATEMENTS 3 September 2014

Greenore Port Limited

Notes to the Financial Statements for the year ended 31 December 2013

...... continued

7. Tangible assets

Buildings Plant Land & Portworks & Equipment Total € € € € Cost At 1 January 2013 2,949,435 21,669,838 5,460,919 30,080,192 Additions - 10,280 37,454 47,734 Disposals )(2,326,078 )(8,143,537 - (10,469,615) Re-analysis - 487,412 )(2,002 485,410 At 31 December 2013 623,357 14,023,993 5,496,371 20,143,721 Depreciation At 1 January 2013 - 5,381,776 3,615,846 8,997,622 Charge for year - 261,117 189,737 450,854 Disposals - )(487,412 - )(487,412 Impairment - 146,010 - 146,010 Re-analysis 487,412 )(2,002 485,410 At .31 December 2013 - 5,788,903 3,803,581 9,592,484

Net book Values

For inspection purposes only. At 31 December 2013Consent of copyright 623,357 owner required for 8,235,090 any other use. 1,692,790 10,551,237

At 31 December 2012 2,949,435 16,288,062 1,845,073 21,082,570

The portworks (excluding buildings and land) are included at directors' valuation. The revaluation which occurred on 5 May 1978 resulted in a revaluation surplus of €2,806,120 which has been credited to revaluation reserve. The aggregate depreciation determined on the historical cost of buildings and portworks at 31 December 2013 was €2,188,698 (2012: €2,132,576). Included in cost of plant and equipment are amounts of €2,770,746 (2012: €2,736,614) being fully depreciated assets still in use at 31 December 2013.

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EPA Export 05-03-2015:00:06:17 DRAFT FINANCIAL STATEMENTS 3 September 2014

Greenore Port Limited

Notes to the Financial Statements for the year ended 31 December 2013

...... continued

8. Financial Fixed Assets Subsidiary and other group undertakings

2013 2012 € € Cost At beginning of year 136,168 136,168 Investments during the year -- At end of year 136,168 136,168

None of the shares of the above subsidiary undertakings are listed on a recognised stock exchange. In the opinion of the directors, the shares in the company's subsidiary and other group undertakings are worth at least the amounts at which they are stated in the balance sheet. Details of group companies are set out in Note 19.

9. Debtors 2013 2012 € €

For inspection purposes only. Trade debtors Consent of copyright owner required for any other use. 43,938 44,129 Amount owed by group undertakings (see note 19) 10,377 337 VAT Repayable 1,691 7,942 Prepayments and accrued income 34,867 36,418 90,873 88,826

Page 15

EPA Export 05-03-2015:00:06:17 DRAFT FINANCIAL STATEMENTS 3 September 2014

Greenore Port Limited

Notes to the Financial Statements for the year ended 31 December 2013

...... continued

10. Creditors: amounts falling due 2013 2012 within one year € €

Bank loan 276,455 276,455 Deferred Purchase Consideration - 2,000,000 Net obligations under finance leases and hire purchase contracts 4,000 - Trade creditors 201,250 345,632 Corporation tax Payable/ (Repayable) 25,744 25,465 PAYE/ PRSI 5,766 4,818 Provision for asset write down - 5,482,203 Accruals and deferred income (see note 12) 460,745 469,453 973,960 8,604,026

11. Creditors: amounts falling due 2013 2012 after more than one year € €

Deferred Income (See Note 12) 1,361,132 1,398,176 Bank Loans 714,415 976,572 Deferred Purchase Consideration - 2,500,000 Net obligations under finance leases and hire purchase contracts 6,000 - For inspection purposes only. Consent of copyright owner required for any other use. 2,081,547 4,874,748

Page 16

EPA Export 05-03-2015:00:06:18 DRAFT FINANCIAL STATEMENTS 3 September 2014

Greenore Port Limited

Notes to the Financial Statements for the year ended 31 December 2013

...... continued

12. Government Grants Deferred

2013 2012 € €

At beginning of year 1,435,220 1,472,263 Amortised in year )(37,044 )(37,044 1,398,176 1,435,219 Included as accruals and deferred income under creditors:

Amounts falling due within one year (included note 10) 37,044 37,044 Amounts falling due after more than one year (included note 11) 1,361,132 1,398,176 1,398,176 1,435,220

Under an agreement between the company and the Department of the Marine and Natural Resources which is dated 21 May 2000, the company has a contingent liability to repay in whole or in part grants received if certain circumstances set out in the agreement occur before project completion.

13. Provisions for liabilities and charges For inspection purposes only. Consent of copyright owner required for any other use. 2013 2012 € € Deferred Tax At beginning of year 549,774 543,720 Released during year )(30,381 6,054 At end of year 519,393 549,774

The unprovided full potential liability to deferred tax at 31 December 2013 amounted to €Nil (2012: €Nil)

Page 17

EPA Export 05-03-2015:00:06:18 DRAFT FINANCIAL STATEMENTS 3 September 2014

Greenore Port Limited

Notes to the Financial Statements for the year ended 31 December 2013

...... continued

14. Bank loans, overdrafts, finance leases and other financing

Between Between Within one & two two & five After One Year Years Years five Years Total € € € € €

Bank Loans 276,455 552,910 161,505 - 990,870

Bank loans and overdrafts are secured by fixed and floating charges over the assets of the company.

15. Share capital 2013 2012 € € Authorised 1,000,000 Ordinary shares of €1.269738 each 1,269,738 1,269,738 4,000 Redeemable preference shares of €1.269738 each 5,079 5,079 1,274,817 1,274,817

Allotted, called up and fully paid equity

530,000 Ordinary shares of €1.269738 For inspection each purposes only. 672,961 672,961 Consent of copyright owner required for any other use.

16. Revaluation Reserve 2013 2012 € €

Surplus arising on revaluation of portworks on 5 May 1978 (Note 7) 2,806,121 2,806,121

Page 18

EPA Export 05-03-2015:00:06:18 DRAFT FINANCIAL STATEMENTS 3 September 2014

Greenore Port Limited

Notes to the Financial Statements for the year ended 31 December 2013

...... continued

17. Reconciliation of movements in shareholders' funds - equity 2013 2012 € €

Opening Shareholders' funds 7,517,156 7,508,030 Total Recognised gains for the year 103,864 9,126 Closing Shareholders' funds 7,621,020 7,517,156

18. Ultimate parent undertaking

The company's ultimate parent undertaking is Renore Limited, a company incorporated and operating in the Republic of Ireland. This company is exempt, due to its size, under Financial Reporting Standard No. 2 and the European Communities (Companies: Group Accounts) Regulations, 1992 from the requirement to prepare group accounts.

For inspection purposes only. Consent of copyright owner required for any other use.

Page 19

EPA Export 05-03-2015:00:06:18 DRAFT FINANCIAL STATEMENTS 3 September 2014

Greenore Port Limited

Notes to the Financial Statements for the year ended 31 December 2013

...... continued

19. Group Companies and Related party transactions

(a) Group Companies The company holds 100% of the ordinary share capital of the following companies: - Greenore Estates Limited, which owns and lets land at Greenore Co. Louth; - Carlingford Lough Shipping Agency Limited, which acts as a shipping agent for the port. - Greenore Logistics Limited, which carries on the business of logistics activities. The company holds 51% of the ordinary issued share capital of Greenore Stevedoring Limited, whose principal activity is the provision of stevedoring services. The registered office of all these companies is Greenore, Co. Louth.

(b) The profit and share capital and reserves of the group companies are as follows:

2013 2012 € € Greenore Estates Limited Loss after Tax )(1,343 )(1,500 Share Capital & Reserves 145,367 144,024 Carlingford Lough Shipping Agency Limited Profit/(Loss) after Tax 47,632 )(6,359 Share Capital & Reserves 578,187 530,555 For inspection purposes only. Greenore StevedoringConsent Limited of copyright owner required for any other use.

Loss after Tax )(551 )(243 Share Capital & Reserves )(16,303 )(15,752 Greenore Logistics Limited Profit after Tax 338 - Share Capital & Reserves - 338

(c) Related party transactions Turnover includes provision of harbour facilities amounting to €1,927,688 (2012: €1,856,234) to a subsidiary undertaking, Carlingford Lough Shipping Agency Limited. Included in cost of sales is an amount of €733,015 (2012: €832,080) for provision of stevedoring services by a subsidiary undertaking, Greenore Stevedoring Limited. Trade Creditors include an amount of €169,624 (2012: €273,226) owing to One 51 Plc, which owns 50% of Renore, the company's ultimate parent.

Page 20

EPA Export 05-03-2015:00:06:18 DRAFT FINANCIAL STATEMENTS 3 September 2014

Greenore Port Limited

Notes to the Financial Statements for the year ended 31 December 2013

...... continued

During the year, Greenore Port Limited re-charged the following expenses to other group companies at market rates - Insurance, Audit Fees, Light and Heat and other sundry expenses.

19. Group Companies and Related party transactions (continued)

Amounts due from/ (to) group undertakings comprise the following: 2013 2012 € €

Greenore Estates Limited )(1,343 1 Carlingford Lough Shipping Agency Limited )(25,976 - Greenore Stevedoring Limited 35,570 - Renore Limited 2,126 - Greenore Logistics Limited - )(338 10,377 )(337

20. Pension Commitments The company makes contributions on behalf of employees to a defined contribution pension scheme. The pension cost charge for the period amounted to €15,419 (2012 : €15,756) and there are no prepaid contributions at the balance sheet date.

For inspection purposes only. Consent of copyright owner required for any other use. 21. Capital commitments There were no capital commitments authorised or contracted for at the year end.

22. Security The bank loans and overdrafts are secured by a charge over the port of Greenore and adjoining lands and a charge over the land of Greenore Estates Limited and a debenture over the company's undertaking and assets.

23. Post Balance Sheet events No material events adversely affecting the finances of the company have occurred since the balance sheet date.

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EPA Export 05-03-2015:00:06:18 DRAFT FINANCIAL STATEMENTS 3 September 2014

Greenore Port Limited

Notes to the Financial Statements for the year ended 31 December 2013

...... continued

24. Approval of financial statements

The board of directors approved these financial statements on ______.

For inspection purposes only. Consent of copyright owner required for any other use.

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EPA Export 05-03-2015:00:06:18 DRAFT FINANCIAL STATEMENTS 3 September 2014

Greenore Port Limited

The following pages are for the members only and do not form part of the statutory financial statements

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 05-03-2015:00:06:18 DRAFT FINANCIAL STATEMENTS 3 September 2014

Greenore Port Limited

Appendix

2013 2012 € €

Cost of Sales Repairs & Maintenance to plant & cranes 167,023 100,997 Stevedoring 733,015 832,080 Depreciation - Plant & Machinery 187,644 192,925 Plant Hire 61 6,966 Other Port Costs 94,032 99,297 1,181,775 1,232,265 Administrative expenses

Salaries and commission 190,088 199,791 Staff pension costs 15,419 15,756 Directors' fees 4,969 )(4,168 Rates 65,816 86,222 Insurance 34,275 65,793 Employers Liablility Cost 8,072 19,504 Light and heat 31,074 22,328 Repairs 731 )(138 Advertising 90 285 Office Costs 9,421 6,472 Travel and Subsistence 2,668 3,050 Legal Fees 5,593 9,107 Audit, tax and accounting For inspection purposes only. 15,260 16,500 Consent of copyright owner required for any other use. Other Professional Fees 11,510 1,271 Bank charges 477 494 (Gain)/Loss on foreign exchange )(114 2 Sundry expenses 14,101 3,816 Subscriptions and Donations 18,533 1,986 Impairment of Fixed Assets 146,010 - Depreciation Quay Wall 106,681 106,681 Depreciation Office Equipment 2,093 2,195 Amortisation of Quay Wall Grant )(37,044 )(37,044 Depreciation Buildings 154,436 153,786 800,159 673,689

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EPA Export 05-03-2015:00:06:18 For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 05-03-2015:00:06:18 For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 05-03-2015:00:06:18 For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 05-03-2015:00:06:18 For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 05-03-2015:00:06:18 For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 05-03-2015:00:06:18 Attachment No. D.2 - Waste Types & Quantities

The individual EWC codes for the wastes accepted at the site are included in Table D.2 (i) at the back of the main IE Application form. The amount of each waste type accepted varies, but the total amount will not exceed 99,000 tonnes annually.

None of the wastes accepted are classified as animal by-products in accordance with Regulation 1069/2009.

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EPA Export 05-03-2015:00:06:18 Attachment No. D2.2 - Waste Acceptance Procedures

All wastes accepted at the facility originate at authorised waste management facilities.

Greenore Port Ltd weighs each truck as it enters and leaves the port area.

Only baled wastes are accepted at the facility. The facility is not be open to the general public and no waste processing is carried out. The bales are manufactured at authorised materials recovery facilities and meet the standards specified by the end destination recovery plants and the information submitted to the National TFS Office. The facility does not accept waste from contractors who do not have a contract with Greenore Port Ltd.

Copies of two waste handling procedures relating to site operations are included in Attachment No. C.

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EPA Export 05-03-2015:00:06:18 Attachment No. D 2.3 - Waste and Material Outputs from Waste Activities.

The installation is solely involved in the storage of baled wastes. There are no offices and no plant/vehicle maintenance is carried out within the storage area. The operation does not generate any waste, other than the contents of the oil interceptor on the surface water drainage system. This is routinely cleaned and emptied and the contents removed off-site for disposal/treatment at an appropriately authorised facility.

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EPA Export 05-03-2015:00:06:18

Attachment No. D 2.4 - Principles of Self-Sufficiency and Proximity

The current Waste Management Plan for the North East Region 2005-2010 encompasses areas of planning, regulation, collection, recycling, recovery and disposal of non-hazardous wastes generated within the region. It sets out the policy for an integrated approach to waste management in the context of a cross regional dimension.

In 2011, an evaluation of the current Plan in the context of the EU Waste Framework Directive concluded there was a need to prepare a new Plan to take account of the requirements of the Directive and the proposal to amend the existing waste management regions.

The draft Plan for the Midland-Eastern Waste Management Region was issued for consultation on the 18th November 2014 and the closing date for submission was the 30th January 2015.

Thermal recovery activities, where the principal use of the waste is as a fuel to generate energy, are part of the recovery tier of the Waste Hierarchy. These facilities typically accept waste from all parts of Ireland and operate on a national market basis. The draft Plan states that the Eastern Midlands Region contains five authorised active and pending thermal recovery plants, two waste to energy (WtE), and three cement kilns.

The cement kilns accept SRF and RDF, which are manufactured from municipal and construction sources, as well as other wastes such as meat and bone meal, chipped tyres and high calorific fuels. The draft Plan states that thermal treatment capacity is viewed by the local authorities as addressing national needs with respect to the recovery of residual municipal waste and other waste streams.

The draft Plan states that RDF/SRF is also exported from ports within the region to WtE facilities in Europe and while this assists For inspection Ireland purposes in only. meeting its recovery targets, a growing Consent of copyright owner required for any other use. dependence on the export market may lead to an overreliance on overseas markets to manage Ireland’s waste. This will have consequences for national policy ambitions to become self- sufficient in treating residual wastes.

The long term alternative to the export of residual wastes is for Ireland to become self- sufficient in terms of managing and treating the waste in indigenous thermal treatment facilities. The draft Plan supports self-sufficiency and the development of indigenous infrastructure for the thermal recovery of residual municipal wastes. To this end, it is a policy objective (A4) of the draft Plan to aim to improve regional and national self-sufficiency of waste management infrastructure for the reprocessing and recovery of particular waste streams, such as mixed municipal wastes, in accordance with the proximity principle.

Pending the introduction of adequate indigenous thermal treatment capacity for residual municipal waste, export remains crucial to Ireland meeting its waste recovery targets and complying with the Waste Management Hierarchy.

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EPA Export 05-03-2015:00:06:18 Attachment No. E.1 - Emissions to Atmoshpere

There are no point source emissions to atmosphere. The only potential fugitive emissions are dust, vehicle exhausts and odours.

As no waste processing is carried out, the only source of dusts are vehicle movements.

Vehicle exhausts contain a range of compounds that affect air quality, for example nitrous oxide, carbon monoxide, methane, carbon dioxide, benzene and particulates.

Odours are associated with both the types of wastes accepted and the time they are retained on site. Baled wastes can only be stored for a maximum of three weeks on-site, unless otherwise agreed, in accordance with Condition 5.22 of the Waste Permit.

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EPA Export 05-03-2015:00:06:18 For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 05-03-2015:00:06:18 Attachment No. E.2 - Emissions to Surface Water

The only emission to surface water from the installation is rainwater run-off from the paved area, which is discharged to Carlingford Lough estuary. This is weather dependent and periodic.

As there is the potential for the run-off to contain small amounts of hydrocarbons and suspended solids it is collected in a designated surface water drainage system which is directed to a silt trap and oil interceptor, as required by Condition 4.8 of the waste permit.

The location of the interceptor and the proposed monitoring point (SW 1) are shown on Drawing No. IBM0481-006 in Attachment No. B2. The monitoring location (SW 1) has yet to be approved by Louth County Council.

Schedule B3 of the Permit sets the following emission limit values for the outfall of the interceptor (SW 1) and prior to discharge to the river.

Parameter Limit Value pH 6 – 9 Mineral Oils 5 mg/l BOD 25 mg/l Suspended Solids 35 mg/l

The emission does not contain any substances listed in the Schedule of EPA (Industrial Emissions) (Licensing) Regulations 2013 S.I. No. 137 of 2013.

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EPA Export 05-03-2015:00:06:18 Attachment No. E.4 - Emissions to Ground

There are not and will not be any direct or indirect emissions to groundwater. All of the storage areas are paved with concrete. Hazardous substances are neither stored nor handled at the installation.

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EPA Export 05-03-2015:00:06:18 For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 05-03-2015:00:06:18 Attachment No. E.5 - Noise Emissions

The only source of noise emissions are the delivery vehicles and the mechanical grabs used to move the bales. Noise emissions occur during the waste acceptance periods and when the ships are being loaded. At other times the storage activity is not a source of noise.

Schedule B1 of the Waste Permit sets noise emission levels that must not be exceeded at one monitoring location (N1) specified in Schedule C1 of the Permit. These are as follows:

• 55 dBA Leq, LT during the hours 08.00 to 20.00

• 45 dBA Leq, LT during the hours 20.00 to 08.00

• There shall be no clearly audible tonal component, or impulsive component, in the noise emission from the development at any noise sensitive location.

The monitoring location has yet to be approved by Louth County Council. The proposed location of N1 is identified in Drawing No. IBM0481-006 in Attachment No. B2.

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EPA Export 05-03-2015:00:06:18 Table E6 - Tabular Data on Emission Points

Point Code Point Type Easting Northing Verified Emission Provide label ID’s 6E-digit GPS Irish 6N-digit GPS Irish Y = GPS used assigned in National Grid National Grid e.g. SO2, HCl, NH3 section F3 Reference Reference N = GPS not used

pH, BOD, SS, Mineral SW 1 Surface Water 322412 311047 No Oils

Co-ordinates provided in Irish National Grid

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EPA Export 05-03-2015:00:06:18 Attachment No. F.1 - Treatment, Abatement and Control Systems.

Atmosphere

The only potential emissions to air from the installation are: • dust associated with vehicle movement; • vehicle exhausts, and • odours.

To minimise the risk of dust generation, Greenore Port Ltd cleans the storage area regularly.

The diesel fuelled heavy goods vehicles that deliver the bales are typically fitted with Selective Catalytic Reduction (SCR) systems. A diesel fuel additive (AdBlue) is used in the SCR to reduce the nitrous oxide levels in the exhaust gases.

The wastes contained in the bales have been treated to remove the majority of the putrescible waste fraction, which is the primary source of odours. The bales are covered in multiple wraps of polyethylene sheeting, which effectively contains odours from any residual putrescible wastes.

Surface Water

The only emission to surface water from the facility is rainwater run-off from the storage area to Carlingford Lough estuary. This is collected and passed through a silt trap and oil interceptor as required by Condition 4.8 of the Waste Permit. The location of the interceptor is shown on Drawing No. IBM0481-007 Rev A in Attachment No. B.2.

Noise

The closest noise sensitive locations to the facility are private residences (N1) located on Euston Street that are approximately For 100m inspection to purposes the only. south of the storage area, as shown on Consent of copyright owner required for any other use. Drawing No. IBM0481-006 Rev A in Attachment No. B.2. Noise limit are specified in Schedule B1 of the Waste Permit.

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EPA Export 05-03-2015:00:06:18 Attachment No. F.2 - Emission Monitoring and Sampling Points

Locations

The current Waste Permit lists noise, dust and surface water monitoring points, but the locations have yet to be approved by Louth County Council. Proposed locations are shown in Drawing No. IBM0481-010 in Attachment No. B2.

Monitoring Methodologies

Noise The monitoring will be carried out in accordance with the Agency’s Guidance Note for Noise: Licence Applications, Surveys and Assessments in Relation to Scheduled Activities (NG4) (2012). The monitoring will be carried out annually or as required.

Dust The dust deposition monitoring will be conducted in accordance with VDI 2119 ‘Measurement of Dustfall, Determination of Dustfall using Bergerhoff Instrument (Standard Method)’, German Engineering Institute. The monitoring will be carried out bi-annually and at least one event will be between May and September.

Surface Water Grab samples will be collected at the outlet from the oil interceptor on a biannual basis.

Housekeeping Employees currently undertake daily site inspections to check on the condition of the bales and ensure any damaged bales are removed to the quarantine area prior to removal offsite.

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EPA Export 05-03-2015:00:06:18 Table F3 - Tabular Data on Monitoring & Sampling Points

Point Code Point Type Easting Northing Verified Pollutant 6E-digit GPS Provide label ID’s M=Monitoring 6N-digit GPS Y = GPS used Irish National e.g. SO , HCl, assigned in Irish National 2 Grid NH section F3 Grid Reference N = GPS not 3 S=Sampling Reference used pH, BOD, SW 1 M 322412 311047 N Suspended Solids, Mineral Oils N 1 M 322383 310886 N Noise D 1 M 322430 310976 N Dust D 2 M 322346 310924 N Dust

Co-ordinates are relative to Irish National Grid.

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EPA Export 05-03-2015:00:06:18 Attachment No. H.2 - Waste Prevention

The installation is used solely for the storage of baled wastes pending loading onto ships. The process does not generate waste, other than the contents of the oil-water interceptor on the surface water drainage system. As the interceptor is a necessary pollution mitigation measure, it is not practicable to prevent this waste from arising.

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EPA Export 05-03-2015:00:06:18 Attachment No. H.3 - Recovery and Disposal of Waste Generated at the Facility

The oil interceptor on the surface water drainage system is routinely cleaned and emptied and the contents removed off-site for disposal/treatment by a licensed contractor and brought to a licensed facility.

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EPA Export 05-03-2015:00:06:18 Attachment No. H.4 - Waste Hierarchy

As the installation is solely involved in the storage of waste, it does not generate wastes, other than the content of the oil interceptor, which will be sent off site for treatment in an authorised waste management facility. This is the only practical treatment option for the contents of the interceptor. All of the waste held at the installation is shipped to waste to energy recovery installations. There is no contact between the contents of the interceptor and the baled wastes.

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EPA Export 05-03-2015:00:06:18 Attachment No. I.1 - Assessment of Atmospheric Emissions

Existing Conditions

The EU Air Quality Framework Directive (96/62/EC) requires Member States to identify ‘Zones’ and ‘Agglomerations’ for air quality assessment purposes. In Ireland, four zones, A, B, C and D are defined in the Air Quality Standards (AQS) Regulations (S.I. No 180 of 2011). • Zone A – Dublin Conurbation • Zone B – Cork Conurbation • Zone C – Large Towns with a Population > 15,000 • Zone D – Remaining Area of Ireland

The facility is located in Zone D and the current Air Quality is Good according to the EPA’s website.

Statement on Main Polluting Substances

The installation is not a source of emissions of main polluting substances (as defined in the Schedule of EPA (Industrial Emissions) (Licensing) Regulations 2013, S.I. No. 137 of 2013) to the atmosphere.

Assessment of Impacts

The only potential emissions to air from the installation are dust associated with vehicle movement, vehicle exhausts and odours. The operation of the facility has no significant impact on air quality in the surrounding area.

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EPA Export 05-03-2015:00:06:18 Attachment No. I.2 - Assessment of Impacts on Receiving Surface Water

Existing Conditions

The site is located in the estuary of Carlingford Lough, whose main channel adjoins the quayside. Carlingford Lough is part of the Neagh Bann IRBD – a copy of the Neagh Bann IRBD Transitional and Coastal Waters Action Programme is in this Attachment.

Reports have been prepared on the ‘Status’ of each water body. Status means the condition of the water in a watercourse and is defined by its ecological and chemical status, whichever is worse. Water bodies are ranked in one of five classes, High, Good, Moderate, Poor and Bad. The WFD requires measures to ensure waters achieve at least ‘Good Status’ by 2015 and that their current status does not deteriorate. Where necessary, for example in heavily impacted or modified watercourses, extended deadlines (2021 and 2027) can be set for achieving the following objectives:-

• Prevent Deterioration • Restore Good Status • Reduce Chemical Pollution • Achieve Protected Areas Objectives

The objectives for particular watercourses are based on Pressure and Impact Assessments of human activity, including point and diffuse emissions, land use and morphological conditions on surface waters to identify those water bodies that are ‘At Risk’ of failing to meet the WFD objectives.

The Neagh Bann action programme states that Carlingford Lough’s overall status is “Moderate” with an objective to restore to “Good Status” by 2021. The Lough is also “At Risk” of not achieving “Good Status” – refer to the Full Report for Waterbody Carlingford Lough provided in this Attachment. A copy of the Carlingford Water Management Unit For inspection purposes only. Action Plan is also provided in thisConsent Attachment. of copyright owner required for any other use.

Statement on Main Polluting Substances

The emission to surface water does not contain any of the main polluting substances (as defined in the Schedule of EPA (Industrial Emissions) (Licensing) Regulations 2013, S.I. No. 137 of 2013).

Compliance with EC Environmental Objectives (Surface Waters) Regulations 2009, S.I. No. 272 of 2009.

The activity complies with the requirements of the EC Environmental Objectives (Surface Waters) Regulations 2009, S.I. No. 272 of 2009.

EPA Export 05-03-2015:00:06:18 Carlingford Water Management Unit Action Plan

Name Carlingford Water Management Unit Area 43 km2 River Basin Neagh Bann IRBD District

For inspection purposes only. Consent of copyright owner required for any other use. Main Counties Louth

2 SAC (Carlingford Shore & Carlingford Mtn.), 1 SPA (Carlingford Lough), 2 Protected drinking waters (Ryland River, Areas Carlingford), 1 Shellfish water (Carlingford)

100 Sectoral Total Phosphorus Source (This does not imply impact) 90

80

70

60

50

% 40

30

20

10

0 WWTP URBAN AGRICULT PEATLAND FORESTRY UNSEWERED UNSEWE_IND AQUACULTUR EPA ExportBACKGROUND 05-03-2015:00:06:18 Carlingford Water Management Unit Action Plan

STATUS/IMPACTS River data There are no Lakes within Overall status 2 waterbodies at good status and 2 at poor status. (Total of 4 river waterbodies). There are no lakes within the WMU. the WMU

Status elements There are no monitored waterbodies in this WMU as the waterbodies are Poor Good small draining directly into Carlingford Lough. Overall status based on 50% 50% extrapolated waterbodies

Possible Impacts - EPA No data from EPA Water Quality Reports Water Quality Reports

PRESSURES/RISKS SELECTED ACTION PROGRAMME NB All relevant basic measures, general supplementary measures and SEA mitigation measures apply Nutrient sources Approximately 65% of phosphorus load is from diffuse sources Point Sources WWTP measures are summarised in the Table below (predominantly from agriculture but also septic tanks, with less significant The Local Authority have indicated that storm water discharges are a problem contributing to the status amounts attributable to forestry). Almost 30% of the phosphorus load is classification of the WMU. Measures under the Water Pollution Acts in relation to storm water from point sources. discharges may be required. Point pressures 3 WWTPs -Carlingford WWTP discharges into marine waters downstream of Examine the terms of discharge authorisations to determine whether they require review for the purpose the WMU, Greenore WWTP and Omeath WWTP. One Local Authority of compliance with water body objectives including protected area objectives and environmental quality licenced (Section 4) discharge (leisure facility). No IPPC licences. standards.

Wastewater Treatment No water bodies at risk from WWTP or industrial discharges Diffuse Sources The Local Authority have indicated that agriculture and septic tanks are the main diffuse pressures. Plants (WWTP) and Particular measures will be required to address diffuse pollution pressures from agriculture such as the Industrial Discharges Good Agricultural Practices Regulations inspection and enforcement. Septic tanks - The are no at risk septic tanks to be prioritised for inspections.

Quarries, Mines & Landfills No water bodies at risk Other Protection of drinking waters and abstraction control will also be important basic measures required to ensure good water quality.

Agriculture 3 out of the 4 river waterbodies within the WMU are considered at risk from Future Developments Throughout the river basin management cycle future pressures and developments will need to be agriculture; (NB_06_1060, NB_06_507, NB_06_908) managed to ensure compliance with the objectives of the Water Framework Directive and the Programme of Measures will need to be developed to ensure issues associated with these new On-site systems There are 1004 septic tanks in this WMU, none have been assessed as a pressures are addressed. For inspection purposes only. risk to water quality. Consent of copyright owner required for any other use. No water bodies at risk from septic tanks Forestry No water bodies at risk from forestry WWTP Measures

Point Source County Priority Date WMU Dangerous substances No water bodies at risk from dangerous substances Discharge Measure (Investigation before Capital Works) Morphology No water bodies at risk from physical modifications Greenore Louth 2 Investigate the need for increase in capacity of treatment plant. 2012 Carlingford

Abstractions 1 waterbody at risk from abstractions; (NB_06_908) Omeath Louth 2 Investigate the need for increase in capacity of treatment plant. 2012 Carlingford Measure (Plants requiring the Implementation of Other N/A Point Source County Priority Recommendations of Pollution Reduction Plans for Date WMU Discharge Shellfish waters

OBJECTIVES Implementation of Recommendations of PRP for Shellfish Carlingford Louth 1 2010 Carlingford waters Good status Two river water bodies are currently at satisfactory quality and must be retained Implementation of Recommendations of PRP for Shellfish 2015 at good status. Greenore Louth 1 2010 Carlingford waters

Alternative Heavily Modified /Artificial Water bodies – none Implementation of Recommendations of PRP for Shellfish Omeath Louth 1 2010 Carlingford Objectives New Modifications – None. waters Extended Timelines – There are 2 extended timelines to 2021 proposed within Point Source Plants requiring increase in capacity or ensure capacity of County Priority Date WMU WMU for 2 river water bodies. Discharge treatment plant is not exceeded Carlingford Louth 2 Same measure as listed above 2010 Carlingford

EPA Export 05-03-2015:00:06:18 Carlingford Water Management Unit Action Plan

River Data

IE_NB_Carlingford Biological Elements Supporting Protected Areas Elements Date objective to be achieved to objective Date Monitored Y(Extrapolated N) Member State Code Conservation of Special Area Nutrient Sensitive Waters Sensitive Nutrient rsWtrPearlMussel FreshWater htbnhs(Diatoms) Phytobenthos arivrerts(Q) Macroinvertebrates Special Protection Area Special Protection Specific Polutants Donor Waterbody Ecological Status Ecological Physio-chemical Chemical Status Drinking Water Morphology Objective Fish

NB_06_1060 N NB_06_229 P Y GES 2021

NB_06_507 N NB_06_229 P Y GES 2021

NB_06_509 N NB_06_642 G Y GES 2009

NB_06_908 N NB_06_910 G Y Y GES 2009

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EPA Export 05-03-2015:00:06:18 Full Report for Waterbody Carlingford Lough

River Basin Management Plans (RBMPs) have been published for all River Basin Districts in Ireland in accordance with the requirements of the Water Framework Directive. The WaterMaps viewer is an integral part of the River Basin Management Plan and provides access to information at individual waterbody level and at Water Management Unit level for all the River Basin Districts in Ireland. For inspection purposes only. Consent of copyright owner required for any other use. The following report provides summary plan information about the selected waterbody (indicated by the pin in the map above) relating to its status, risks, objectives, and measures proposed to retain status where this is adequate, or improve it where necessary. Waterbodies can relate to surface waters (these include rivers, lakes, estuaries [transitional waters], and coastal waters), or to groundwaters. Other relevant information not included in this report can be viewed using the WaterMaps viewer, including areas listed in the Register of Protected Areas.

You will find brief notes at the bottom of some of the individual report sheets that will help you in interpreting the information presented. More detailed information can be obtained in relation to all aspects of the RBMPs at www.wfdireland.ie.

Date Reported to Europe:July 2010 Date Report Created 18/02/2015

EPA Export 05-03-2015:00:06:19 Summary Information:

Water Management Unit: N/A

WaterBody Category: Coastal Waterbody

WaterBody Name: Carlingford Lough

WaterBody Code: GBNIIE6NB030

Overall Status:

Overall Objective:

Overall Risk: 1a At Risk

Heavily Modified: No

Report data based upon final RBMP, 2009-2015.

The information provided above is a summary of the principal findings related to the selected waterbody. Further details and explanation of individual elements of the report are outlined in the following pages.

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Date Reported to Europe:July 2010 Date Report Created 18/02/2015

EPA Export 05-03-2015:00:06:19 Status Report Water Management Unit: N/A

WaterBody Category: Coastal Waterbody

WaterBody Name: Carlingford Lough

WaterBody Code: GBNIIE6NB030

Overall Status Result:

Heavily Modified: No

Status Element Description Result Status information DIN Dissolved Inorganic Nitrogen status N/A MRP Molybdate Reactive Phosphorus status N/A DO Dissolved oxygen as per cent saturation status N/A BOD Biochemical Oxygen Demand (5-days) status N/A PHY Macroalgae - phytobiomass status N/A OPP Macroalgae - opportunistic algae status N/A RSL Macroalgae - reduced species list status N/A ANG Angiosperms - Seagrass and Saltmarsh status N/A BIN Benthic Invertebrates status N/A FIS Fish status N/A HYD Hydrology status N/A

For inspection purposes only. MOR Morphology status Consent of copyright owner required for any other use. N/A

SP Specific Pollutant Status N/A PAS Overall protected area status N/A ES Ecological Status N/A CS Chemical Status N/A SWS Surface Water Status N/A EXT Extrapolated status N/A DON Donor water bodies N/A

Date Reported to Europe:July 2010 Date Report Created 18/02/2015

EPA Export 05-03-2015:00:06:19 n/a - not assessed

Status By ‘Status’ we mean the condition of the water in the waterbody. It is defined by its chemical status and its ecological status, whichever is worse. Waters are ranked in one of 5 status classes: High, Good, Moderate, Poor, Bad. However, not all waterbodies have been monitored, and in such cases the status of a similar nearby waterbody has been used (extrapolated) to assign status. If this has been done the first line of the status report shows the code of the waterbody used to extrapolate.

You can read more about status and how it is measured in our RBMP Document Library at www.wfdireland.ie (Directory 15 Status).

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Date Reported to Europe:July 2010 Date Report Created 18/02/2015

EPA Export 05-03-2015:00:06:19 Risk Report Water Management Unit: N/A WaterBody Category: Coastal Waterbody

WaterBody Name: Carlingford Lough

WaterBody Code: GBNIIE6NB030

Overall Risk Result: 1a At Risk

Heavily Modified: No

Risk Test Description Risk Marine Direct Impacts

MDI1 Dangerous Substances na N/A MDI2 OSPAR na N/A MDI3 UWWT Regs Designations na N/A MDIO Marine Direct Impacts Overall - Worst Case na N/A Morphological Risk Sources

CM1 Dredging na N/A CM2 Deposition na N/A CM3 Coastal Defences na N/A CM4a Built Structures - Port Tonnage na N/A CM4b Built Structures - Industrial/Urban Shoreline na N/A CM4c Built Structures - Industrial Intakes na N/A CM5 Intensive Landuse (Coastal Lagoons) na N/A For inspection purposes only. MOR Overall Morphological Risk - WorstConsent Case of copyright owner required for any other use. 2b Not At Risk

MOR Overall (MIMAS) Morphological Risk - Worst Case (2008) na N/A Overall Risk

CP Worst case of Point and Marine Direct Impacts Overall (2008) 1a At Risk RA Coastal Risk Overall - Worst case (2008) 1a At Risk Point Risk Sources

CP1 WWTPs (2008) 1a At Risk CP2 CSOs na N/A CP3 IPPCs (2008) 2b Not At Risk CP4 Section 4s (2008) 2b Not At Risk CP5 WTPs/Mines/Quarries/Landfills na N/A CPO Overall Risk from Point Sources - Worst Case (2008) na N/A

Date Reported to Europe:July 2010 Date Report Created 18/02/2015

EPA Export 05-03-2015:00:06:19 Risk By 'risk' we mean the risk that a waterbody will not achieve good ecological or good chemical status/potential at least by 2015. To examine risk the various pressures acting on the waterbody were identified along with any evidence of impact on water status. Depending on the extent of the pressure and its potential for impact, and the amount of information available, the risk to the water body was placed in one of four categories: 1a at risk; 1b probably at risk; 2a probably not at risk; 2b not at risk. Note that '2008' after the risk category means that the risk assessment was revised in 2008. All other risks were determined as part of an earlier risk assessment in 2005.

You can read more about risk assessment in our 'WFD Risk Assessment Update' document in the RBMP document library, and other documents at www.wfdireland.ie (Directory 31 Risk Assessments).

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Date Reported to Europe:July 2010 Date Report Created 18/02/2015

EPA Export 05-03-2015:00:06:19 Objectives Report

Water Management Unit: N/A

WaterBody Category: Coastal Waterbody

WaterBody Name: Carlingford Lough

WaterBody Code: GBNIIE6NB030

Overall Objective:

Heavily Modified: No

Objectives Description Result Extended timescale information E1 Extended timescales due to time requirements to upgrade WWTP discharges No Status E2 Extended timescales due to delayed recovery of chemical pollution and No Status chemical status failures E3 Extended timescales due to winter dissolved nitrogen exceedances No Status E4 Extended timescales due to time requirements for status recovery No Status E5 Extended timescales from Northern Ireland Environment Agency No Status E0V Overall extended timescale - combination of all extended timescales fields No Status Objectives information OB1 Prevent deterioration objective No Status OB2 Restore at least good status objective No Status OB3 Reduce chemical pollution objective No Status

OB4 Protected areas objective For inspection purposes only. No Status Consent of copyright owner required for any other use. OBO Overall objectives No Status

Extended timescales Extended timescales have been set for certain waters due to technical, economic, environmental or recovery constraints. Extended timescales are usually of one planning cycle (6 years, to 2021) but in some cases are two planning cycles (to 2027).

Objectives In general, we are required to ensure that our waters achieve at least good status/potential by 2015, and that their status does not deteriorate. Having identified the status of waters (this is given earlier in this report), the next stage is to set objectives for waters. Objectives consider waters that require protection from deterioration as well as waters that require restoration and the timescales needed for recovery. Four default objectives have been set initially:-

Prevent Deterioration Restore Good Status Reduce Chemical Pollution Achieve Protected Areas Objectives

These objectives have been refined based on the measures available to achieve them, the latter's likely effectiveness, and consideration of cost-effective combinations of measures. Where it is considered necessary extended deadlines have been set for achieving objectives in 2021 or 2027.

Date Reported to Europe:July 2010 Date Report Created 18/02/2015

EPA Export 05-03-2015:00:06:19 Measures Report Water Management Unit: N/A WaterBody Category: Coastal Waterbody

WaterBody Name: Carlingford Lough

WaterBody Code: GBNIIE6NB030 Heavily Modified: No

Measures Description Applicable BC Total number of basic measures which apply to this waterbody No BW Directive - Bathing Waters Directive No BIR Directive - Birds Directive No HAB Directive - Habitats Directive No MAE Directive - Major Accidents and Emergencies Directive No EIA Directive - Environmental Impact Assessment Directive No UWT Directive - Urban Waste Water Treatment Directive No PPP Directive - Plant Protection Products Directive No NIT Directive - Nitrates Directive No IPC Directive - Integrated Pollution Prevention Control Directive No POI Other Stipulated Measure - Control of point source discharges No DIF Other Stipulated Measure - Control of diffuse source discharges No PS Other Stipulated Measure - Control of priority substances No MOD Other Stipulated Measure - Controls on physical modifications to surface waters No OA Other Stipulated Measure - Controls on other activities impacting on water status No For inspection purposes only. AP Other Stipulated Measure - PreventionConsent of copyrightor reduction owner required of the for impact any other of use. accidental No

pollution incidents TP1 WSIP - Agglomerations with treatment plants requiring capital works No TP2 WSIP - Agglomerations with treatment plants requiring further investigation prior to No capital works TP3 WSIP - Agglomerations requiring the implementation of actions identified in No Shellfish PRPs TP4 WSIP - Agglomerations with treatment plants requiring improved operational No performance TP5 WSIP - Agglomerations requiring investigation of CSOs No TP6 WSIP - Agglomerations where exisitng treatment capacity is currently adequate but No predicted loadings would result in overloading OTS On-site waste water treatment systems No SHE Shellfish Pollution Reduction Plan No IPR IPPC licences requiring review No WPR Water Pollution Act licences requiring review No

Date Reported to Europe:July 2010 Date Report Created 18/02/2015

EPA Export 05-03-2015:00:06:19 HQW Protect high quality waters No

Measures Measures are necessary to ensure that we meet the objectives set out in the previous page of this report. Many measures are already provided for in national legislation and must be implemented. Other measures have been recently introduced or are under preparation. A range of additional potential measures are also being considered but require further development. Any agreed additional measures can be introduced through the update of Water Management Unit Action Plans during the implementation process.

You can read more about Basic Measures in 'River Basin Planning Guidance' and in other documents in our RBMP Document Library at www.wfdireland.ie.

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Date Reported to Europe:July 2010 Date Report Created 18/02/2015

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Neagh Bann IRBD

Transitional and Coastal Waters

Action

Programme

For inspection purposes only. Consent of copyright owner required for any other use.

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Name Neagh Bann RBD Transitional and Coastal Waters Action Plan Length of 177km, (Mainland), 4km (Islands) Coastline Main Counties Monaghan, Louth. 4 Bathing Water; Shelling Hill/Templetown, Port, Lurganboy, Clogherhead, Seapoint.

2 Shellfish Water; Dundalk Bay, Carlingford Protected 1 Nutrient Sensitive Water: Castletown Estuary. Areas 2 SPA; Carlingford Lough SPA, Dundalk Bay SPA.

2 SAC; Dundalk Bay, Clogher Head, Boyne Coast And Estuary, Carlingford Shore.

STATUS/IMPACTS Overall There are 9 Transitional Waterbodies within this RBD; all are moderate status. status There are 5 Coastal Waterbodies within this RBD; 3 moderate, 1 good and 2 unassigned.

Chemical Status fails for Inner Dundalk Bay

Status Moderate water bodies with monitoring data indicating the test determining below good elements status classification are as follows:

Newry Estuary: High Nitrogen levels Carlingford Lough: High Nitrogen levels Outer Dundalk Bay: Suction and hydraulic dredge for cockles, and some dredge of razors Inner Dundalk Bay: Shellfish dredging (covering 21km2) Castletown Estuary: Sensitive Area; UWWTD - Failing to meet objectives

Possible Nutrient input, WWTP, Shellfish dredging Impacts - For inspection purposes only. Consent of copyright owner required for any other use.

PRESSURES/RISKS

LAND Pressure Based Risk Assessment results (2008) identify the following waterbodies as at BASED risk from land based point source pressures: PRESSURES Transitional Risk Test Identified as "at risk" or "probably at risk" Fane Estuary Point Source - WWTPs Coastal Risk Test Identified as "at risk" or "probably at risk" Carlingford Lough Point Source - WWTPs

Pressure Based Risk Assessment results (2005) identifies the following waterbodies as at risk from land based diffuse pressures (nutrient input):

Transitional Risk Test Identified as "at risk" or "probably at risk" Outer Dundalk Bay Point Source - WWTPs Castletown Estuary Nutrient Inputs

Further detail on the land based pressures which affect marine waters in this RBD, such as WWTP discharges, septic tanks, and agriculture are detailed in the following Water Management Unit Action Plans:

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PRESSURES/RISKS (continued) Transitional/Coastal Water Body Relevant Water Management Unit Action Plan Fane Estuary Fane WMU Glyde Estuary Glyde WMU Ballymascanlan Estuary Castletown WMU Newry Estuary Carlingford WMU Carlingford Lagoons Carlingford WMU Shilties Lough Carlingford WMU Corstown Lagoon Dee WMU Portstewart Bay Lough Foyle WMU (NW) Louth Coast (HA 06) Dee WMU Mourne Coast Cooley Penninsula/Carlingford WMU Carlingford Lough Carlingford WMU Outer Dundalk Bay Cooley Penninsula/Glyde/Dee WMU Inner Dundalk Bay Castletown/Fane WMU Castletown Estuary Castletown/Fane WMU

Transitional and coastal water bodies where Shellfish designations are located will also include more detail in the relevant Pollution Prevention Programmes: http://www.environ.ie/en/Environment/Water/WaterQuality/ShellfishWaterDirective/Shellfis hWatersDraftCharacterisationReportsandPRPs/

MARINE PRESSURES Pressure Based Risk Assessment results (2008) identify the following waterbodies as at Morphology risk from morphological pressures:

Fane Estuary: Channelisation by OPW Glyde Estuary: Maintained as part of the OPW Glyde and Dee channel scheme Castletown Estuary: Coastal defences For inspection purposes only. There are 77 licensedConsent of copyright aquaculture owner required areas for any other in use.the NBRBD. The waterbodies with Aquaculture aquaculture areas protected under the Shellfish Directive are:

Carlingford Lough Newry Estuary Mourne Coast Outer Dundalk Bay Inner Dundalk Bay

Shellfish Production Figures (provided by Bord Iascaigh Mhara):

Shellfish Volume Year Value (€) Location (t) Carlingford Bottom Mussel 5160 2007 7,646,000 Lough

Carlingford Gigas Oyster 648 2007 1,164,300 Lough

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SELECTED ACTION PROGRAMME Bathing Waters Measures are required to preserve protect and improve the quality of bathing waters. Guidance is being prepared in the preparation of management plans to minimise risk to bathers and human health. Where water quality problems exist,

preventative and remedial action must be taken.

Measures are included in the Pollution Prevention programmes under the Shellfish Waters Quality of Shellfish Waters Regulations. DAFF licence shellfish growing areas under the under the Fisheries (Amendment) Act, 1997

Aquaculture: Aquaculture is regulated and licensed by the Department of Agriculture, Fisheries and Food; local authorities control discharge licenses for fin fish farms. The Department of the Environment, Heritage and Local Government makes shellfish pollution reduction programmes which provide general water quality protection. A multi-department Marine Coordination Group has recently been established to ensure ongoing co-ordination of marine management activities and application of Appropriate Assessment through strengthened regulation; and coordination of biodiversity issues at an EU level.

Water Pollution Acts, Local Authority Licensing of trade effluent to surface waters include discharges Water Services Act, to transitional and coastal waters IPPC and Foreshore Act IPPC licensed discharges under the integrated pollution prevention control directive and Environmental Protection Agency Acts

Foreshore Acts – development under the mean High Water Mark within transitional and coastal waters are subject to control under the Foreshore Acts.

Key provisions of the habitat regulations introduced under these directives allow Birds and Habitats For inspection purposes only. directive for the ConsentDEHLG of copyright to control owner required damaging for any other activities use. within and outside designated sites. All planned projects not necessary for the management of the Natura 2000 network will be subject to appropriate assessment under Article 6 of the habitats Directive

Urban Wastewater The Urban Waste Water Treatment Regulations (S.I No. 254 of 2001) deal with Treatment the collection, treatment and discharge of urban wastewater and wastewater from certain industrial sectors. Transitional and coastal waters receive direct discharges from Wastewater Treatment Plants and industry. Controls under these Regulations and the Environmental Objectives Regulations will provide the basis for deciding on appropriate treatment required to meet the objectives of the WFD. In addition Wastewater Discharge Authorisation Regulations (S.I. No. 684 of 2007) require Local Authorities to have authorisations from the EPA for WWTPs >500pe

Morphology Marine morphological impacts can impact ecological standards. Ireland’s existing planning and development controls and marine licensing systems (Controls on Physical Modifications) provide a general level of control for new development. The DEHLG is considering the introduction of new regulations to control physical modifications in our surface waters which may involve an authorisation system where low risk activities may simply be registered and higher risk works would be subject to more detailed assessment and more prescriptive licences.

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OBJECTIVES Protect/Restore 2015 2 water bodies Alternative Extended Deadlines – 11 water bodies (2021) Objectives 1 water body – objective not yet determined (Louth Coast)

New Modifications – none

HMWB – none

TRANSITIONAL

100%

High Status Good Status Moderate or Less Status COASTAL Status Unassigned

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20%

20%

60%

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Transitional and Coastal Status

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Glossary and Abbreviations Biodiversity: Word commonly used for biological diversity and defined as assemblage of living organisms from all habitats including terrestrial, marine and other aquatic ecosystems and the ecological complexes of which they are part.

BOD Biological Oxygen Demand

Coastal waters: That area of surface water on the landward side of a line, every point of which is at a distance of one nautical mile on the seaward side from the nearest point of the baseline from which the breadth of territorial waters is measured, extending where appropriate up to the outer limit of transitional waters.

DAFF: Department of Agriculture, Fisheries and Food.

DEHLG: Department of Environment, Heritage and Local Government.

DETE: Department of Enterprise, Trade and Employment.

Diffuse sources (of Non-point sources primarily associated with run-off and other discharges pollution): related to different land uses such as agriculture and forestry, from septic tanks associated with rural dwellings and from the land spreading of industrial, municipal and agricultural wastes.

DO Dissolved Oxygen

EC: European Commission

Ecological status: An expression of the structure and functioning of aquatic ecosystems associated with surface waters. Such waters are classified as being of good ecological status when they meet the requirements of the Water Framework Directive.

Ecology: The study of the relationships among organisms and between those organisms and their non-living environment.

EPA: Environmental Protection Agency. For inspection purposes only. Consent of copyright owner required for any other use. EU: European Union Good status: A collective term used to refer to the status achieved by a surface water body when both its ecological status and its chemical status are at least good or, for groundwater, when both its quantitative status and chemical status are at least good.

HMWB (Heavily A water body that has been changed substantially in character as a modified water body): result of physical alterations by human activity.

Inland surface waters: All standing or flowing water on the surface of the land (such as reservoirs, lakes, rivers) on the landward side of the baseline from which the breadth of territorial waters is measured.

Macroalgae Multicellular algae such as seaweeds and filamentous algae.

Mitigation measures: Measures to avoid, prevent, minimise, reduce or, as fully as possible, offset or compensate for any significant adverse effects on the environment, as a result of implementing a plan or programme.

On-site system: Septic tank or other system for treating wastewater from unsewered properties.

One of the elements used in classification of Ecological Status of transitional and coastal waters measured by spatial extent and biomass Opportunistic

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Macroalgae of macroalgae. While these algae are natural components of estuarine systems and play important roles in several estuarine processes, macroalgal blooms are of ecological concern because they can reduce the habitat quality.

Phytoplankton Solitary and colonial unicellular algae and cyanobacteria that live in the water column, at least for part of their lifecycle.

Phytoplankton Biomass One of the elements used in classification of Ecological Status of transitional and coastal waters measured by the total weight of phytoplankton, a free-floating flora, at a given time per unit area.

PRP Pollution reduction programme

Programme of Those actions, defined in detail, which are required to achieve the measures: environmental objectives of the Directive within a river basin district.

Protected area Water protected by European legislation including drinking waters, shellfish waters, bathing waters, urban wastewater nutrient sensitive areas or sites designated as Special areas of Conservation or Special Protected Areas

River Basin District Administrative area for coordinated water management, composed of (RBD) & International multiple river basins (or catchments), with cross-border basins (i.e. those River Basin District covering the territory of more than one Member State) assigned to an (IRBD): international RBD.

River basin The area of land from which all surface water run-off flows, through a sequence of streams, rivers and lakes into the sea at a single river mouth, estuary or delta.

SERBD South Eastern River Basin District

Special Area of Site designated according to the Habitats Directive (Council Directive Conservation (SAC): 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and flora).

Special Protection Area Area designated under the European Directive on the Conservation of (SPA): Wild Birds. For inspection purposes only. Consent of copyright owner required for any other use.

Statutory Instrument Any order, regulation, rule, scheme or bye-law made in exercise of a (SI): power conferred by statute.

Surface water Inland waters on the land surface (such as reservoirs, lakes, rivers, transitional waters, coastal waters) within a river basin.

Transitional waters Bodies of surface water in the vicinity of river mouths which are partly saline in character as a result of their vicinity to coastal waters, but which are substantially influenced by freshwater flows.

Water body A coherent sub-unit in the river basin (district) to which the environmental objectives of the directive must apply. Hence, the main purpose of identifying “water bodies” is to enable the status to be accurately described and compared to environmental objectives

Water Framework The Water Framework Directive is European legislation that promotes a Directive (WFD) new approach to water management through river basin planning. It covers inland surface waters, estuarine waters, coastal waters and groundwater.

WMU Water Management Unit - geographical sub unit of a river basin district

WWTP Waste Water Treatment Plant

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