SECTION F – EXISTING ENVIRONMENT & IMAPCT OF THE DISCHARGE(S)

Attachment F1: Assessment of Impact on Receiving Surface or Ground Water

− Attachment F.1: Natura Impact Statement

− Table F.1(i)(a): Upstream Ambient Monitoring Data – Regular Emissions

− Table F.1(i)(b): Downstream Ambient Monitoring Data – Regular Emissions

− Table F.1(ii)(a): Upstream Ambient Monitoring Data – Dangerous Emissions

− Table F.1(ii)(b): Downstream Ambient Monitoring Data – Dangerous Emissions Irish Water Report

Natura Impact Statement as part of the Eyrecourt Waste Water COA application Contents

Introduction 3 Legislative Context 3

Methodology 5 Guidance Followed 5 Stages Involved in the Appropriate Assessment Process 6 Field Walkover Surveys 6 Consultation 6

Stage 1: Screening 7

Stage 2: Appropriate Assessment 8 Description of the Project 8 Description of the Receiving Environment and Monitoring Results 9 Waste Assimilative Capacity 10 Field Walkover Survey 11 Description of the Natura 2000 Sites Affected 12 Callows SAC 12 Description of the Conservation Interests of the SAC 14 Annex I Habitats 14 Annex II Species 15 Conservation Objectives of the River Shannon Callows SAC 16 Middle Shannon Callows SPA 16 Description of the Conservation Interests of the SPA 17 Table 7.0 Qualifying SPA Features along surveyed stretch 20 Conservation Objectives of the Middle Shannon Callows SPA 20 Impact Prediction 20 Impacts on Water Quality 20 Impacts on Annex I Habitats 22 Impacts on Annex II Species 22 Impacts on designated features of the SPA 23 Mitigation Measures 24 Stage 2 Appropriate Assessment Conclusion Statement 25

References 26

2 | Irish Water Natura Impact Statement - Eyrecourt Introduction

This Natura Impact Statement provides an Appropriate Assessment (AA) of the existing Waste Water Treatment Plant (WwTP), located at Eyrecourt, , for the purposes of the Waste Water Discharge (Authorisation) Regulations, 2007 (S.I. No. 684 of 2007), as amended. It assesses whether the on-going operation of the plant, alone or in combination with other plans and projects, is likely to have significant effects on a European Site(s) in view of best scientific knowledge and the conservation objectives of the site(s). European Sites are those identified as sites of European Community importance designated as Special Areas of Conservation under the Habitats Directive or as Special Protection Areas under the Birds Directive.

This report follows the guidance for AA published by the Environmental Protection Agency’s (EPA) ‘Note on Appropriate Assessments for the purposes of the Waste Water Discharge (Authorisation) Regulations, 2007 (S.I. No. 684 of 2007)’ (EPA, 2009); and takes account of the Department of the Environment, Heritage and Local Government’s guidelines ‘Appropriate Assessment of Plans and Projects in Ireland. Guidance for Planning Authorities’ (DoEHLG, 2009) and Circular L8/08 ‘Water Services Investment and Rural Water Programmes – Protection of Natural Heritage and National Monuments’ (DoEHLG, 2008).

This report was completed by Tobins Consulting Engineers on behalf of Irish Water.

Legislative Context The Council Directive 92/43/EEC on the Conservation of Natural Habitats and of Wild Fauna and Flora, better known as “The Habitats Directive”, provides legal protection for habitats and species of European importance. Articles 3 to 9 provide the legislative means to protect habitats and species of Community interest through the establishment and conservation of an EU-wide network of sites known as Natura 2000. These are Special Areas of Conservation (SACs) designated under the Habitats Directive and Special Protection Areas (SPAs) designated under the Conservation of Wild Birds Directive (79/409/ECC) as codified by Directive 2009/147/EC.

Articles 6(3) and 6(4) of the Habitats Directive set out the decision-making tests for plans and projects likely to affect Natura 2000 sites (Annex 1.1). Article 6(3) establishes the requirement for Appropriate Assessment (AA):

Any plan or project not directly connected with or necessary to the management of the [Natura 2000] site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subjected to appropriate assessment of its implications for the site in view of the site’s conservation objectives. In light of the conclusions of the assessment of the implications for the site and subject to the provisions of paragraph 4, the competent national authorities shall agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the site concerned and, if appropriate, after having obtained the opinion of the general public.

3 | Irish Water Natura Impact Statement - Eyrecourt Article 6(4) states:

If, in spite of a negative assessment of the implications for the [Natura 2000] site and in the absence of alternative solutions, a plan or project must nevertheless be carried out for imperative reasons of overriding public interest, including those of a social or economic nature, Member States shall take all compensatory measures necessary to ensure that the overall coherence of Natura 2000 is protected. It shall inform the Commission of the compensatory measures adopted.

4 | Irish Water Natura Impact Statement - Eyrecourt Methodology

Guidance Followed Both EU and national guidance exists in relation to Member States fulfilling their requirements under the EU Habitats Directive, with particular reference to Article 6(3) and 6(4) of that Directive. The methodology followed in relation to this AA has had regard to 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).

 Appropriate Assessment of Plans and Projects in Ireland: Guidance for Planning Authorities. Department of Environment, Heritage and Local Government, (DoEHLG, 2010).

 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).

 Communication from the Commission on the Precautionary Principle. Office for Official Publications of the European Communities, Luxembourg, (EC, 2000a).

 Managing Natura 2000 Sites: the provisions of Article 6 of the ‘Habitats’ Directive 92/43/EEC, Office for Official Publications of the European Communities, Luxembourg, (EC, 2000b).

 Assessment of plans and projects significantly affecting Natura 2000 sites: Methodological guidance on the provisions of Articles 6(3) and (4) of the Habitats Directive 92/43/EEC. Office for Official Publications of the European Communities, Brussels (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).

5 | Irish Water Natura Impact Statement - Eyrecourt

Stages Involved in the Appropriate Assessment Process

Stage 1: Screening / Test of Significance This process identifies whether the WwTP discharge is 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 for each European Site(s) of not significant, significant, potentially significant, or uncertain effects. The latter three determinations will cause that site to be brought forward to Stage 2.

Stage 2: Appropriate Assessment This stage considers the impact of the WwTP discharge 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.

Field Walkover Surveys Field walkover surveys were undertaken on June 18th 2014 to identify the potential for qualifying species and habitats in the surrounding environs of the WwTP discharge.

Consultation The EPA, as the competent authority, will seek NPWS advice as may be required in reaching their decision on a WwTP discharge. The NPWS can only communicate with the applicant (i.e. Irish Water) on request from the competent authority, when the formal application process to the competent authority has already commenced.

Inland Fisheries Ireland (Shannon Area) identified that the Eyrecourt stream is likely to support coarse fisheries and has the potential to support trout fisheries (though the latter could not be

6 | Irish Water Natura Impact Statement - Eyrecourt

confirmed). They noted that any future upgrade plans should consider incorporating a constructed wetland in addition to standard tertiary nutrient treatment and effluent should be passed through the ICW together with stormwater overflows. They highlighted the opportunity to include some measures to redevelop the stream when the plant is upgraded.

Stage 1: Screening

Screening for Appropriate Assessment was undertaken by the Environmental Protection Agency for the former licence application who determined that an Appropriate Assessment of the existing discharge from the Eyrecourt WwTP is required due to the potential adverse impact on the qualifying interests of River Shannon Callows SAC and Middle Shannon Callows SPA. This determination was based on the following:

 Eyrecourt WwTP discharges into the Eyrecourt stream which enters the designated sites ca. 3km to the south-east and joins the River Shannon ca. 4km to the south-east; and  The limited dilution available in the receiving waters for the normal waste water discharge.

Therefore, applying the Precautionary Principle and in accordance with Article 6(3) of the Habitats Directive, for the purposes of the CoA application the current WwTP discharge at Eyrecourt will be brought forward for a Stage 2 Appropriate Assessment.

7 | Irish Water Natura Impact Statement - Eyrecourt Stage 2: Appropriate Assessment

The River Shannon Callows SAC and Middle Shannon Callows SPA, which have been determined as requiring AA, are described and all the potential impacts resulting from the Eyrecourt WwTP discharge are discussed in relation to the conservation objectives of these designated sites.

Description of the Project The Eyrecourt agglomeration is located in east County Galway. The Eyrecourt treatment works are located in pasture land, approximately 600m south-east of Eyrecourt town, adjacent to the Eyrecourt Stream.

The existing WWTP consists of a manually raked inlet coarse bar screen, followed by primary settlement. The sludge is removed from the settlement tank and is then transferred to the adjacent sludge drying beds for drying/thickening, prior to transport off site for treatment/disposal. The current p.e. for the agglomeration (2017) is 304, while the future (2023) pe is 318. The existing Eyrecourt WwTP has a design capacity of 325p.e. Based on a loading of 225l/pp/day the dry weather flow for the discharge is calculated at 0.00083m3/sec. The 95 percentile flow for the receiving Eyrecourt stream, as obtained from the EPA letter dated 30/04/2013 is 0.007m3/sec.

There is a storm overflow chamber that incorporates a two sided overflow weir, situated between the screen and the settlement tank. The chamber accommodates excess flows and allows them to overflow and discharge directly to the Eyrecourt Stream, without primary settlement. The primary settlement tank has a capacity of 34m3. Treated effluent from the primary settlement tank combines with the storm water overflow and is discharged by gravity via a 300mm diameter outfall into the nearby Eyrecourt Stream.

Both the storm water overflow and the treated effluent are discharged from the same outflow to the Eyrecourt Stream, a tributary of the River Shannon, at coordinates 191813E and 216227N. The confluence of the Eyrecourt Stream and the River Shannon is situated 4km downstream, to the east of the discharge point. The effluent discharge point is located approximately 3km upstream of the River Shannon Callows SAC (000216) the Middle Shannon Callows SPA (004096).

Effluent data together with the standards required for the discharge are presented in Table 1.0.

Table 1.0: Eyrecourt WwTP Monitoring Data (mg/l)

Parameter Effluent (mean Effluent Standards values 2010-2014)

BOD 140.21 25 COD 312.90 125 SS 76.27 35

8 | Irish Water Natura Impact Statement - Eyrecourt

The effluent discharge does not meet the Urban Wastewater Treatment regulations (2001) (S.I. No. 254/2001) for all parameters measured based on monitoring data from 2010 to 2014, though it is noted these ELV’s do not apply to WwTPs <500p.e.. Monitoring results exceed standards on over 75% of monitoring occasions.

Description of the Receiving Environment and Monitoring Results

The WwTP discharges to the Eyrecourt stream. Monitoring data (latest available from 2010- 2011) from both upstream and downstream of the discharge locations demonstrates that the water quality within the Eyrecourt stream downstream of the WwTP is not in compliance with Schedule 5 of the European Communities Environmental Objectives (Surface Water) Regulations 2009 (S.I. No. 272 of 2009). Concentrations upstream of the WwTP are within regulation limits.

Table 2.0: Monitoring Data both Upstream and Downstream of WwTP Discharge (Mean Concentrations based on monitoring data from Feb 2010 to Jul 2011)

Parameter EQS* Upstream Downstream

BOD ≤2.6 1 6 Ammonia (as NH3 – N) ≤0.14 0.05 1.23 Orthophosphate ≤0.075 0.048 0.28 *European Communities Environmental Objectives (Surface Waters) Regulations 2009, S.I. No. 272 of 2009 (95%ile standards presented).

The EPA currently monitor two sites on the Eyrecourt stream for biological water quality. Both current monitoring sites are downstream of the WwTP (Bridge NNE of Fearmore Code 0100, and Bridge upstream of Shannon River confluence Code 0200). Both of these sites achieved a Q3 rating in 2014. Therefore, the objective under the Water Framework Directive (2000/60/EC) is to increase its ‘poor status’ to at least a ‘good’ status. The main channel of the Shannon into which the Eyrecourt stream discharges has ‘Good’ water status and achieved a Q4 rating in 2014 just downstream of the confluence at Incherky Quay. A historical Q sampling site upstream of Eyrecourt was last sampled in 2003 when it achieved Q3 rating.

During the field survey in 2014 a TOBINs ecologist sampled the river at two locations:  170m upstream of the WwTP at the road crossing  1.5km downstream of the discharge at Lismore Bridge (EPA Station 0100)

The upstream sample attained a Q3 rating being dominated by moderately pollution tolerant Group C taxa such as Gammarus duebeni, the snail Potamopyrgus antipodarum and dipteran larvae. Group B cased caddis and Group D Asellus aquaticus were also frequent.

Anoxic sediments and sewage fungus associated with the discharge were present in the vicinity of the outfall. Downstream of the WwTP at Lismore Bridge deposition on the rocks was still noticeable. Diversity was low and the sample here was dominated by Gammarus duebeni with occasional Baetis rhodani and riffle beetles. As these were all Group C taxa the site warranted a Q3 rating.

9 | Irish Water Natura Impact Statement - Eyrecourt

Waste Assimilative Capacity Table 3.0 summaries the assimilative capacity calculations which are based on the current loading of 318p.e., 95%ile river flow (0.007m3/sec) and water quality standards in the European Communities Environmental Objectives (Surface Water) Regulations, 2009 (S.I. No. 272 of 2009). Assimilative capacity calculations use both actual background concentrations and the ‘notionally clean river’ approach.

Table 3.0: Assimilative capacity calculations at estimated loadings of 318 p.e. for actual background concentrations and for a notionally clean river.

Parameter Background Predicted EQS* (mg/l) (mg/l) downstream quality (mg/l)

BOD Actual Background 1 15.44 ≤2.6 Notionally Clean 0.260 14.77 Ammonia Actual Background 0.05 2.99 ≤0.14 Notionally Clean 0.008 2.96 Orthophosphate Actual Background 0.048 0.613 ≤0.075 Notionally Clean 0.005 0.575 *European Communities Environmental Objectives (Surface Waters) Regulations 2009, S.I. No. 272 of 2009 (95%ile standards presented).

Using both the actual background concentrations and the notional clean river concentrations demonstrates that the Eyrecourt steam has no capacity to assimilate the WwTP discharge.

Eyrecourt WwTP discharges to the Eyrecourt stream, a tributary of the River Shannon. To determine the possible impacts on the River Shannon Callows SAC and Middle Shannon Callows SPA, the assimilative capacity of the main channel of the River Shannon was calculated using the effluent monitoring data, flow data and ‘notionally clean’ surface water concentrations (Table 4.0). There is no flow data available for the Shannon on the EPA Hydrotool website. An indicative flow was taken from the WWDL Application for WwTP (DC141-01) which gave a figure of 22,204,800m3/day 50-percentile flow for the Shannon at Banagher Bridge.

Table 4.0: River Shannon assimilative capacity calculations at estimated loadings of 318 p.e. using notionally clean background river concentrations.

Parameter Background Predicted EQS* (mg/l) (mg/l) downstream quality (mg/l)

BOD Notionally Clean 0.260 0.260 ≤2.6 Ammonia Notionally Clean 0.008 0.008 ≤0.14 Orthophosphate Notionally Clean 0.005 0.005 ≤0.075

As seen in Table 4.0 above the River Shannon has the assimilative capacity for the Eyrecourt WwTP discharge for all parameters based on the ‘notionally clean river’ approach.

10 | Irish Water Natura Impact Statement - Eyrecourt

It is noted that the assessment is based on limited data, particularly with regard to Ammonia and Orthophosphate effluent monitoring data for which there is no data from 2012 onwards. It is also noted that there is no upstream and downstream monitoring data available after June 2011. There is also no water monitoring data available for the River Shannon in the vicinity of the confluence with the Eyrecourt stream.

In summary, the Eyrecourt stream does not have the capacity to assimilate the WwTP discharge. In terms of impact on the River Shannon, while the river has the capacity to assimilate the Eyrecourt discharge based on the ‘notionally clean river’ approach, actual background concentrations are not available and considering the precautionary principle the potential for negative impacts on the water quality of the River Shannon cannot be ruled out.

Field Walkover Survey The Eyrecourt stream was examined upstream and downstream of the discharge location to determine the impact on water quality and to examine the streams potential to support species and habitats associated with the SAC.

Upstream of the discharge the channel is 1.5-2m wide and partially shaded. The watercourse is a moderately flowing riffle/pool complex with a cobble/gravel substrate and some silt in depositing areas along slower flowing edges and near the bridge. Instream vegetation comprised of watercress (Rorippa nasturtium-aquaticum) in the shallow edges. Bank side vegetation included crack willow (Salix fragilis), bramble (Rubus fruticosus agg), marsh valerian (Valeriana sitchensis), remote sedge (Carex remota) and nettle (Urtica dioica).

In the vicinity of the discharge the watercourse is heavily shaded with a bankside comprising beech (Fagus sylvatica), hawthorn (Crategus monogyna), privet (Lingustrum sp), bramble (Rumex fruticosus agg), hazel (Crategus monogyna), cleaver (Gallium aparine), dock (Rumex obtusifolius), holly (Ilex aquifolium), dog rose (Rosa canina), hard fern (Blechnum spicant). Banks are high ca. 2m and the stream is slow flowing and shallow ca 20-40cm. The substrate was almost entirely anoxic mud deposits arising from the WwTP discharge. Sewage fungus was abundant.

Further downstream at Lismore Bridge the stream has recovered somewhat as it has passed through farmland. The stream is mostly unshaded as bridge works in the recent past have involved replanting/removing of vegetation and diverting the channel along a wall for a short distance. Bankside vegetation includes dock (Rumex obtusifolius), hard rush (Juncus inflexus), ivy (Hedera helix), willow (Salix cinerea), alder (Alnus incana), smooth meadowgrass (Poa pratensis), daisy (Bellis perennis), hawthorn (Crategus monogyna) and dog rose (Rosa canina). Instream vegetation included watercress and algae on rocks. The subsrate is a mix of rocks, cobbles and gravels, and the flow type is relatively fast flowing sections of riffle and glide. A muddy brown deposit on rocks was still apparent.

No Annex I habitats were noted in the sections of the Eyrecourt stream examined. No signs of Annex II species were noted. The habitat may be suitable for the following species:  Otter (Lutra lutra) [1355].

11 | Irish Water Natura Impact Statement - Eyrecourt

No protected bird species were recorded.

IFI identified that the Eyrecourt stream has potential for trout but they could not confirm its presence. No salmonids were observed through out the upstream or downstream sections during the survey. The physical characteristics of the river would indicate it has potential for salmonids (e.g. riffle and pool complexes, stone and gravel substrate).

Otter is widespread in the River Shannon Callows SAC. While its distribution does not include the10K square M91, the area is within its range. No otter signs (e.g. spraints, feeding remains, paths/slides) were recorded upstream or downstream of the discharge location.

Description of the Natura 2000 Sites Affected

River Shannon Callows SAC

The River Shannon Callows is a long and diverse site which consists of seasonally flooded, semi-natural, lowland wet grassland, along and beside the river between the towns of and Portumna. It is approximately 50 km long and averages about 0.75 km wide (reaching 1.5 km wide in places). Along much of its length the site is bordered by raised bogs (many, but not all, of which are subject to large-scale harvesting), esker ridges and limestone-bedrock hills. The soils grade from silty-alluvial to peat. This site has a common boundary, and is closely associated, with two other sites with similar habitats, River Suck Callows and Little Brosna Callows.

The River Shannon Callows is mainly composed of lowland wet grassland. Different plant communities occur, depending on elevation, and therefore flooding patterns. Two habitats listed on Annex I of the E.U. Habitats Directive are well-represented within the site – Molinia meadows and lowland hay meadows. The former is characterised by the presence of the Meadow Thistle (Cirsium dissectum) and Purple Moor-grass (Molinia caerulea), while typical species in the latter include Meadow Fescue (Festuca pratensis), Rough Meadow-grass (Poa trivialis), Downy Oat- grass (Avenula pubescens), Common Knapweed (Centaurea nigra), Ribwort Plantain (Plantago lanceolata) and Common Sorrel (Rumex acetosa). In places these two habitats grade into one another.

Low-lying areas of the callows with more prolonged flooding are characterised by Floating Sweet-grass (Glyceria fluitans), Marsh Foxtail (Alopecurus geniculatus) and wetland herbs such as Yellow-cress (Rorippa spp.), Water Forget-me-not (Myosotis scorpioides) and Common Spike-rush (Eleocharis palustris). Most of the callows consist of a plant community characterised by Creeping Bent (Agrostis stolonifera), Brown Sedge (Carex disticha), Common Sedge (Carex nigra), and herbs such as Marsh-marigold (Caltha palustris) and Marsh Bedstraw (Galium palustre), while the more elevated and peaty areas are characterised by low-growing sedges, particularly Yellow Sedge (Carex flava agg.) and Star Sedge (Carex echinata). All these communities are very diverse in their total number of plant species, and include the scarce species Meadow-rue (Thalictrum flavum), Summer Snowflake (Leucojum aestivum) and Marsh Stitchwort (Stellaria palustris).

12 | Irish Water Natura Impact Statement - Eyrecourt A further two Annex I habitats, both listed with priority status, have a minor though important presence within the site. Alluvial forest occurs on a series of alluvial islands just below the ESB weir near Meelick. Several of the islands are dominated by well-grown woodland consisting mainly of Ash (Fraxinus excelsior) and Willows (Salix spp.). The islands are prone to regular flooding from the river.

At Clorhane, an area of limestone pavement represents the only known example in Co. Offaly. It is predominantly colonised by mature Hazel (Corylus avellana) woodland, with areas of open limestone and calcareous grassland interspersed. The open limestone pavement comprises bare or moss -covered rock, or rock with a very thin calcareous soil cover supporting a short grassy turf. The most notable plant in the grassy area is a substantial population of Green-winged Orchid (Orchis morio), which occurs with such species as Sweet Vernal-grass (Anthoxanthum odoratum), Quaking-grass (Briza media), sedges (Carex caryophyllea, C. flacca), Common Bird’s-foot-trefoil (Lotus corniculatus), Common Knapweed (Centaurea nigra), and Ribwort Plantain (Plantago lanceolata). Ferns associated with the cracks in the pavement include Asplenium trichomanes, A. ruta-muraria, A. adiantum-nigrum and Polypodium australe. Bryophytes include Grimmia apocarpa and Orthotrichum cf. anomalum. Anthills are common within the open grassland. The Hazel wood is well-developed and has herbaceous species such as Primrose (Primula vulgaris), Common Dog-violet (Viola riviniana), Wood-sorrel (Oxalis acetosella) and Herb-Robert (Geranium robertianum). The wood is noted for its luxuriant growth of epiphytic mosses and liverworts, with such species as Neckera crispa and Hylocomium brevirostre. Yew (Taxus baccata) occurs in one area.

Other habitats of smaller area but also of importance within the site are lowland dry grassland, drainage ditches, freshwater marshes and reedbeds. The dry grassland areas, especially where they exist within hay meadows, are species-rich, and of two main types: calcareous grassland on glacial material, and dry grassland on levees of river alluvium. The former can contain many orchid species, Cowslip (Primula veris), abundant Adder's-tongue (Ophioglossum vulgatum) and Spring-sedge (Carex caryophyllea), and both contain an unusually wide variety of grasses, including False Oat-grass (Arrhenatherum elatius), Yellow Oat-grass (Trisetum flavescens), Meadow Foxtail (Alopecurus pratense), and Meadow Brome (Bromus commutatus). In places Summer Snowflake also occurs.

Good quality habitats on the edge of the callows included in the site are wet broadleaved semi- natural woodland dominated by both Downy Birch (Betula pubescens) and Alder (Alnus glutinosa), and dry broadleaved woodland dominated by Hazel. There are also areas of raised bog, fen on old cut-away bog with Black Bog-rush (Schoenus nigricans), and a 'petrifying stream' with associated species-rich calcareous flush which supports Yellow Sedge (Carex lepidocarpa), Blunt-flowered Rush (Juncus subnodulosus) and Stoneworts (Chara spp.).

Two species which are legally protected under the Flora (Protection) Order, 1999, occur in the site - Opposite-leaved Pondweed (Groenlandia densa) in drainage ditches, and Meadow Barley (Hordeum secalinum) on dry alluvial grassland. This is one of only two known inland sites for Meadow Barley in Ireland. The Red Data Book plant Green-winged Orchid is known from dry calcareous grasslands within the site, while the site also supports a healthy population of Marsh Pea (Lathyrus palustris).

13 | Irish Water Natura Impact Statement - Eyrecourt

This site holds a population of Otter, a species listed on Annex II of the E.U. Habitats Directive, while the Irish Hare, which is listed in the Irish Red Data Book, is a common sight on the callows. The Shannon Callows are used for summer dry-stock grazing (mostly cattle, with some sheep and a few horses), and permanent hay meadow. About 30 ha is a nature reserve owned by voluntary conservation bodies. The River Shannon is used increasingly for recreational purposes with coarse angling and boating accounting for much of the visitor numbers. Intermittent and scattered damage to the habitats has occurred due to over-deepening of drains and peat silt deposition, water-skiing, ploughing and neglect of hay meadow (or reversion to pasture). However, none of these damaging activities can yet be said to be having a serious impact. Threats to the quality of the site may come from the siting of boating marinas in areas away from centres of population, fertilising of botanically-rich fields, the use of herbicides, reversion of hay meadow to pasture, neglect of pasture and hay meadow, disturbance of birds by boaters, anglers, birdwatchers and the general tourist. The maintenance of generally high water levels in winter and spring benefits all aspects of the flora and fauna, but in this regard, summer flooding is a threat to breeding birds, and may cause neglect of farming.

The Shannon Callows has by far the largest area of lowland semi-natural grassland and associated aquatic habitats in Ireland, and one in which there is least disturbance of natural wetland processes. Botanically, it is extremely diverse with two legally protected species of plants and many scarce species. Excellent examples of two habitats listed on Annex I of the E.U. Habitats Directive occur within the site – Molinia meadows and lowland hay meadows with good examples of a further two Annex habitats (both with priority status). In winter the site is internationally important for numbers and species of waterfowl. In spring it feeds large numbers of birds on migration, and in summer it holds very large numbers of breeding waders, rare breeding birds and the endangered Corncrake, as well as a very wide variety of more common grassland and wetland birds. The presence of Otter, an Annex II species, adds further importance to the site.

Description of the Conservation Interests of the SAC Annex I Habitats

The site is a Special Area of Conservation (SAC) selected for the following habitats and/or species listed on Annex I / II of the E.U. Habitats Directive (* = priority; numbers in brackets are Natura 2000 codes): [6410] Molinia Meadows (Conservation status: bad, declining) [6510] Lowland Hay Meadows (Conservation status: bad, stable) [8240] Limestone Pavement* (Conservation status: inadequate, stable) [91E0] Alluvial Forests* (Conservation status: bad, improving)

Molinia meadows, lowland hay meadows and limestone pavement are terrestrial habitats with little or no potential to be impacted. These habitats are not found in the 10K square M91 which includes the Eyrecourt stream and the nearest part of the SAC. It can be concluded therefore that there is no potential for the WwTP to impact on these habitats.

14 | Irish Water Natura Impact Statement - Eyrecourt Alluvial forests are found in areas subject to flooding along watercourses and water bodies where species tolerant of periodic water logging such as alder Alnus glutinosa, ash Fraxinus excelsior and willow Salix sp. are found. These are water dependant habitats and the problem of pollution finding its way into watercourses is a greater risk than in drier woodland. Key pressures to this habitat noted by NPWS (2013) were invasive species and problematic native species. Less critical issues include dumping, grazing, thinning, water abstraction, recreational use and long-term flooding. NPWS (2013) also note that nitrate pollution is an additional possibility when overgrazing occurs and also from effluent run-off. Alluvial woodland is not noted as occurring in the 10K square M91 which includes the Eyrecourt stream and the closest part of the SAC, nor is it evident from aerial photography. It does however occur further downstream in 10K square M80. It is considered that the Eyrecourt discharge is not impacting significantly on the River Shannon downstream as the water quality of the Shannon main channel immediately downstream its confluence with the Eyrecourt stream (Incherky quay) is currently classified by the EPA to be of Good Status, Q4. This indicates that length of the channel to the Shannon (4km) and the dilution afforded by the stream would counteract the pollution effect so as to have little if any effect on the vegetation communities.

Annex II Species The River Shannon Callows SAC is selected for the following Annex II species:

 [1355] Otter (Lutra lutra)

Otter (1355)

Otter is widespread in the River Shannon Callows SAC. While its distribution does not include the10K square M91, the area is within its range. Habitat along the Eyrecourt stream downstream of the discharge location has the potential to support otter, though no signs of otter presence (spraints, slides, paths, couches) were noted during the field survey. While the physical channel of the river is suitable in terms of providing safe refuges, poor water quality is likely to affect fish stocks on which this species feeds and may account for the lack of records.

The overall assessment of the conservation status of otter is 'Favourable' (NPWS, 2013b).

Table 5.0: Qualifying SAC Habitats along Surveyed Stretch

Site Qualifying Habitats Present

River Molinia meadows Upstream No Shannon Downstream No Callows SAC Lowland hay meadows Upstream No Downstream No Limestone pavement Upstream No Downstream No Alluvial forests Upstream No Downstream No

15 | Irish Water Natura Impact Statement - Eyrecourt

Table 6.0: Qualifying SAC Species along Surveyed Stretch

Site Qualifying Observed or signs of species Suitable Habitat Present Species presence

River Otter Upstream No Upstream Yes Shannon Downstream No Downstream Yes Callows SAC

Conservation Objectives of the River Shannon Callows 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.

The generic conservation objective for the River Shannon Callows SAC is to maintain or restore the favourable conservation conditions of the Annex I habitats and Annex II species for which the SAC has been selected. No specific conservation objectives have been published for this SAC. Reference was made to the detailed conservation objectives available for the Lower River Shannon SAC (002165) and the River Barrow and River Nore SAC (2162).

Middle Shannon Callows SPA The SPA covers the same area as the River Shannon Callows SAC which have been described in terms of habitats and species above. The Middle Shannon Callows qualifies as a site of International Importance for wintering waterfowl both on the total numbers regularly exceeding 20,000 birds (for example 27,581 in winter 1998/99) and for the Whooper Swan population (287 – average peak count 1995/96-1999/00). Whooper Swan is listed on Annex I of the EU Birds Directive. Five further species occur in numbers of national importance (all figures are average peaks for winters 1995/96-1999/00) - Mute Swan 349, Wigeon 2,972, Golden Plover (listed on Annex I of the EU Birds Directive) 4,254, Lapwing 11,578 and Black-tailed Godwit 388. For some of these species, peak counts in the period have been considerably higher than the averages, such as 1,096 Black-tailed Godwits and 23,839 Lapwings. The importance of the site for species like Blacktailed Godwit and Whimbrel may have been underestimated if count coverage missed the brief spring peaks for these species.

16 | Irish Water Natura Impact Statement - Eyrecourt

A wide range of other species occur in numbers of regional or local importance, including Bewick’s Swan (listed on Annex I of the EU Birds Directive) 7, Teal 77, Tufted Duck 33, Dunlin 369, Curlew 129, Redshank 31 and Black-headed Gull 1,061. Small numbers of Greenland Whitefronted Goose (listed on Annex I of the EU Birds Directive) use the Shannon Callows (average 21, peak 55) and these are generally associated with larger flocks which occur on the adjacent Little Brosna Callows and River Suck Callows. The callow grasslands provide optimum feeding grounds for these various species of waterfowl, while many of the birds also roost or rest within the site.

The site is also of national importance for breeding waterfowl. The total population of breeding waders (Lapwing, Redshank, Snipe and Curlew) on the Shannon and Little Brosna Callows in 1987 was one of three major concentrations in Ireland and Britain. Since then, however, numbers of at least Lapwing and Redshank have shown serious declines. For example, at a monitoring site at the callows at Shannon Harbour, numbers of Lapwing fell from 29 to 10 pairs and Redshank from 26 to 10 pairs between 1987 and 1994. Black-tailed Godwit, a very rare breeding species in Ireland, nests or attempts to nest in small numbers each year within the site. A further scarce breeding species, Shoveler, also nests in small numbers each year (an estimated 12 pairs in 1987).

The Shannon Callows continues to hold approximately 40% of the Irish population of Corncrake, a species of global conservation concern that is also listed on Annex I of the EU Birds Directive. Between 1997 and 2001, the average number of calling birds was 60, with a peak of 69. BirdWatch Ireland, in association with Dúchas and the RSPB, operate a grant scheme to encourage farming practices that favour the Corncrake and this has probably been responsible for the stabilisation of numbers in recent years. A related scarce species, the Quail, is also known to breed within the callow grasslands.

A good variety of other bird species are attracted to this site. Birds of prey, including scarce species such as Merlin (listed on Annex I of the EU Birds Directive) and wintering Hen Harrier (listed on Annex I of the EU Birds Directive), are regularly reported hunting over the callows. A range of passerine species associated with grassland and swamp vegetation breed, including Sedge Warbler, Grasshopper Warbler, Skylark and Reed Bunting. Kingfisher (listed on Annex I of the EU Birds Directive is also regularly seen within the site. Whinchat, an uncommon breeding species, occur in small numbers. The wintering waterfowl within the Shannon Callows are difficult to monitor due to the size and inaccessibility of large parts of the site. In each winter there is usually one complete aerial census, as well as partial land-based counts. The population of Corncrake within the site is monitored each year and research is carried out on various aspects of the species’ ecology. The breeding waders are also surveyed at intervals. About 30 ha of the callows is a nature reserve owned by voluntary conservation bodies.

Description of the Conservation Interests of the SPA

The SPA is designated for seven bird species at the wetlands that support them:  Whooper swan (Cygnus cygnus);  Wigeon (Anas penelope);  Corncrake (Crex crex);  Golden Plover (Pluvialis apricaria);

17 | Irish Water Natura Impact Statement - Eyrecourt

 Lapwing (Vanellus vanellus);  Black-tailed godwit (Limosa limosa); and  Black-headed gull (Chroicocephalus ridibundus).

The species listed above are wintering populations with the exception of Corncrake which refers to the breeding population. In addition ‘Wetlands’ is also listed as a special conservation interest. The Shannon Callows is one of the largest sites counted during I-Webs and ground based coverage is limited (Crowe, 2005).

Population information (where available), requirements and sensitivities of these species are considered in more details below with information taken from Crowe (2005), NPWS (2011) and the referenced swan and geese census reports.

Whooper swans are primarily herbivorous, feeding on aquatic plants, grasses and agricultural plants such as grain and vegetables. The most recent published swan census (Hall et al, 2012) indicated that just over 50% of the habitat usage records for Whooper Swans were for dry improved pasture with 37.5% seen on arable land. The count in the Shannon region for this species in 2010 was 364 down 16% from 2005. Nationally the most important sites for Whooper swan are Lough Foyle and Upper Lough Erne. They are an amber-listed species of conservation concern (Colhoun & Cummins, 2013).

Greenland white-fronted geese historically wintered on bogland, callowland and rough grassland where they fed by uprooting cyperacean species in particular Eriphorum angustifolium. In the latter half of the 20th century they have increasing used grassland habitats and have shown good flexibility in adapting to new food sources including agricultural stubbles and fodder beet. The decline in the global population continues and is mainly attributed to climate-related changes and increased competition for nest sites with the expanding population of breeding Canada geese. It is an amber-listed species of conservation concern (Colhoun & Cummins, 2013). The most significant population of these geese in Ireland is found in the Wexford slobs. The latest geese autumn/spring counts for the middle and lower river Shannon region were 196/196 (River Suck) and 200/176 (Little Brosna) for 2012/2013. The previous years counts were 136/205 and 202/167 respectively (Fox et al, 2013).

The lapwing wintering population moves in from continental Europe and northern and western Britain (NPWS, 2011). They are traditionally ‘inland’ waders principally using lowland farmland and freshwater wetlands (e.g. turloughs and callows). They are opportunistic and mobile birds and will readily exploit temporary food sources such as newly-ploughed fields where they feed on a variety of soil and surface-living invertebrates such as small arthropods and earthworms. They are a red-listed species of conservation concern (Colhoun & Cummins, 2013).

Golden Plovers that winter in Ireland are thought to be mostly the Icelandic-breeding subspecies. In winter they primarily feed within agricultural grassland and arable land. They eat a wide range of soil and surface-living invertebrate species including beetles and earthworms, but also on plant material such as berries, seeds and grasses. They are a red-listed species of conservation concern (Colhoun & Cummins, 2013).

18 | Irish Water Natura Impact Statement - Eyrecourt

Wigeon are common and widespread throughout Ireland in the winter where they occur on the coast and in inland wetlands, lakes and rivers. When inland they graze on algae and also regularly feed on grasslands and cereal crops. They are an amber-listed species of conservation concern (Colhoun & Cummins, 2013).

Black-tailed godwit are a winter visitor from Iceland. They are amber-listed in Ireland as they winter at less than ten sites. They feed on a range of invertebrates and away from coastal habitats they are known to feed on rough pasture where they consume crane fly larvae and amphipods, and have also been recorded feeding on grain in stubble fields. They are an amber- listed species of conservation concern (Colhoun & Cummins, 2013).

Corncrakes are a summer visitor which nest on the ground in tall vegetation in hay meadows. They are red-listed due to severe declines in breeding population caused by more intensive agricultural practices concern (Colhoun & Cummins, 2013). They eat mostly terrestrial invertebrates with some plant material.

Black-headed gulls arrive in significant numbers from the continent in winter, with small number breeding in western Ireland in the summer. This species is red-listed due to its rapidly declining and localised breeding populations (Colhoun & Cummins, 2013). It feeds on insects especially in arable fields.

Wetlands are also listed as a feature of the SPA. Eutrophication has the potential to alter wetland habitats as certain wetland species would be sensitive to changes in water quality. Influxes in nutrients can result in a shift in species composition toward more tolerant competitive species and a loss of rarer species which typically require lower nutrient inputs. Floristic diversity generally decreases and sensitive invertebrate species may be lost. Some aquatic plants and algae may increase in biomass. Sensitive wetland habitats were not noted along the Eyrecourt stream and more sensitive wetlands within the designated site are located a significant distance downstream. Furthermore most of the species listed as features of the SPA feed terrestrially in agricultural fields adjacent to the river Shannon 3-4km to the south of the WwTP where they have little potential of being impacted by the discharge. There is significant dilution capacity for the Eyrecourt stream in the River Shannon and water quality on the main channel of the Shannon is ‘Good’. However whooper swan and wigeon are mobile species and may feed on aquatic plants associated with the Eyrecourt stream, therefore a slight negative impact to these species cannot be ruled out, particularly in combination with other catchment pressures.

19 | Irish Water Natura Impact Statement - Eyrecourt Table 7.0 Qualifying SPA Features along surveyed stretch

Site Qualifying Observed or signs of species Suitable Habitat Present Species presence

Middle Whooper Swan Upstream No Upstream No Shannon Downstream No Downstream Yes Callows SPA Wigeon Upstream No Upstream No Downstream No Downstream Yes Corncrake Upstream No Upstream No Downstream No Downstream Yes Golden Plover Upstream No Upstream No Downstream No Downstream Yes Lapwing Upstream No Upstream No Downstream No Downstream Yes Black-tailed Upstream No Upstream No Godwit Downstream No Downstream Yes Black-headed Upstream No Upstream No Gull Downstream No Downstream Yes Wetlands Upstream No Downstream Yes

Conservation Objectives of the Middle Shannon Callows SPA Detailed conservation objectives are not yet available for Middle Shannon Callows SPA. However reference was made to those for Wexford Slobs SPA which include the following targets for many of the wintering bird species:  To maintain the long term population trend stable or increasing.  There should be no significant decrease in the numbers of range of areas used by waterbird species other than that occurring from natural patterns of variation.

Impact Prediction

Impacts on Water Quality The integrity and favourable conservation status of the conservation interests of the River Shannon Callows SAC and Middle Shannon Callows SPA have the potential to be indirectly impacted through deterioration in the quality of the Eyrecourt stream a result of eutrophication from the WwTP. The main causes are likely to be elevated levels of nutrients such as BOD, Ammonia and Orthophosphate.

The Eyrecourt Stream has limited assimilative capacity, particularly with regard to BOD, Ammonia and Orthophosphate. It is noted that the stream achieves only a Q3 value upstream of the discharge indicating moderate pollution prior to receiving the WwTP discharge. Effluent monitoring results indicate that levels of nutrients in the effluent regularly exceed standards. Examination of the invertebrate fauna immediately downstream of the discharge revealed the presence of Chironomus larvae, a highly pollution-tolerant species associated with serious

20 | Irish Water Natura Impact Statement - Eyrecourt sewage pollution. Biological water quality monitored by the EPA in the Eyrecourt stream also indicates unsatisfactory water quality downstream of the WwTP.

At present the River Shannon appears to have sufficient dilution capacity to assimilate the Eyrecourt stream without resulting in a drop in water quality, however given the poor state of the discharge at Eyrecourt the risk of negative impacts to water quality in the SAC and SPA cannot be ruled out.

Cumulative impacts in the catchment possibly pose the greatest risk to the conservation objectives. The poor quality discharge from Eyrecourt WwTP has the potential to combine with other sources of nutrient pollution in the catchment and result in significant combined effects on the integrity of the SAC and SPA. While there are no other point-source discharges into the Eyrecourt stream, other channels in the catchment are at risk from a number of different factors.

The Management Unit Action Plan 2009-2015 for the Water Management Unit (WMU) which includes the Eyrecourt stream (IE_SH_25_3524) highlights that the waterbody is of Poor status and is ‘At Risk’ (ShRBD, 2010). WwTPs are highlighted as the most significant risk for this waterbody. Fourteen of the WwTPs within the WMU are considered at risk. In addition the catchment is considered to be at risk from 6 industries. Diffuse pollution is also a major issue for the WMU with agriculture and unsewered properties accounting for over 80% of total phosphorus.

Other impacts which are likely to act cumulatively and impact on the SAC result from the following:

 Chemical fertiliser application to agricultural lands (the main fertilisers in use supply nitrogen, phosphorus, potassium and sulphur);  Agricultural practices such as ploughing leads to greater mineralisation and nitrification, and in the case of old grassland, it can result in an increase in the release of nitrogen over a number of years (OECD, 1986);  Artificial drainage increases nitrate leaching and reduce the morphological qualities of watercourses, thereby reducing the quality of habitat for flora and fauna;  Endocrine disruptors in domestic sewage, including the main active component in the oral contraceptive pill, can interfere with the endocrine system of plants and animals which controls a wide range of processes including metabolism, growth and reproduction. Effects include a high degree of intersexuality downstream of sewage works (Routledge et al. 1998);  Forestry may alter water quality indirectly through increased evaporation losses and hence an increase in solute concentrations;  On-site wastewater treatment systems, poorly performing septic tank units and other small effluent systems can be significant sources of nutrients to rivers;  Water abstraction from rivers can cause low flows, which can be directly damaging due to reducing flows and assimilation capacity;  Point pressures including Section 4 licenced facilities and IPPC licensed facilities (6 industries in WMU); and  Quarries.

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The Eyrecourt stream in combination with other catchment pressures has the potential to impact on the water quality of the SAC/SPA. Mitigation measures to improve water quality are detailed below.

Impacts on Annex I Habitats

Impacts to habitats are not considered likely as they are either terrestrial in nature or located a significant distance from the WwTP.

Table 8.0: Qualifying Habitats Potentially Impacted by WwTP Discharge

Qualifying Potential Brief Explanation Mitigation Habitats Impacts required

Molinia No Terrestrial habitat located a significant distance from the No Meadows WwTP (in Tipperary) therefore no potential for adverse effects and no changes to the conservation status of this habitat. Lowland hay No Terrestrial habitat not noted in the vicinity of the WwTP No meadows therefore no potential for adverse effects and no changes to the conservation status of this habitat. Limestone No Terrestrial habitat not noted in the vicinity of the WwTP No pavements therefore no potential for adverse effects and no changes to the conservation status of this habitat. Alluvial forests No Little potential for adverse impacts to this habitat located No downstream along the River Shannon where water quality is ‘Good’.

Impacts on Annex II Species

Otter (1355)

Reduced water quality and ecological status downstream of the discharge of the Eyrecourt WwTP could be potentially having indirect effects on otters; as a result of reduced food supply i.e. reduced macroinvertebrate and fisheries production. The otter is dependent on fish stocks, which are ultimately dependent on water quality. However, there is no indication that the ongoing operation of this plant is having an adverse effect on otters within the River Shannon Callows SAC as a whole.

There are no specific targets for otter currently listed for the River Shannon Callows SAC, however, specific targets listed in the River Barrow and Nore SAC detailed conservation objectives include no significant decline in the distribution and extent of habitats, no decline in couch sites or holts, no decline in fish biomass and no increase in barriers to connectivity. Given the wide range of otters territories there is potential for a negative impact to this species due to poor water quality.

22 | Irish Water Natura Impact Statement - Eyrecourt Table 9.0: Qualifying Species Potentially Impacted by WwTP Discharge

Qualifying Potential Brief Explanation Mitigation Species Impact Required

Otter Yes Reduced water quality and ecological status Yes downstream of the discharge of the Eyrecourt WwTP could be potentially having indirect effects on otters as a result of reduced food supply.

Impacts on designated features of the SPA The Natura 2000 Data form for the SPA notes that the principal threat to the ornithological interests is agricultural improvement including drainage attempts to reduce winter flooding and agricultural intensification which may also be affecting numbers of breeding waders. Wildfowling is also an issue causing disturbance to species.

Most of the birds listed are adaptable and utilise agricultural grasslands in the floodplain of the River Shannon and are unlikely to use the Eyrecourt stream or be impacted by poor water quality. Exceptions are whooper swan and wigeon which may graze on aquatic plants and algae. Whooper swan numbers in the Shannon have declined in recent years although there is no indication that this is due to eutrophication and may be down to natural population variations. Wigeon are common and widespread in Ireland, Crowe (2005) notes a decline in numbers of this species in the Shannon Callows, however it is also noted that numbers are prone to extreme fluctuations.

Moderate eutrophication may cause a shift in species composition and an increase in biomass of these food sources which is not likely to impact negatively on whooper swan or wigeon. In addition the River Shannon maintains good water quality status at the confluence with the Eyrecourt stream which would indicate that no impacts are occurring. However there is a very slight risk of toxic effects if the WwTP was to become seriously overloaded and following the precautionary principle mitigation measures are proposed below.

Table 10.0: Qualifying Features of SPA Potentially Impacted by WwTP Discharge

Qualifying Potential Brief Explanation Mitigation Habitats Impacts required

Whooper Yes Species that may graze on aquatic plants and algae and Yes Swan therefore a slight chance that the WwTP could result in negative impacts. Wigeon Yes Species that may graze on aquatic plants and algae and Yes therefore a slight chance that the WwTP could result in negative impacts. Corncrake No Species feeding predominately in terrestrial habitats No (breeding) with little or no potential to be impacted by the WwTP discharge.

23 | Irish Water Natura Impact Statement - Eyrecourt

Golden Plover No Species feeding predominately in terrestrial habitats No with little or no potential to be impacted by the WwTP discharge. Lapwing No Species feeding predominately in terrestrial habitats No with little or no potential to be impacted by the WwTP discharge. Black-tailed No Species feeding predominately in terrestrial habitats No Godwit with little or no potential to be impacted by the WwTP discharge. Black-headed No Species feeding predominately in terrestrial habitats No Gull with little or no potential to be impacted by the WwTP discharge. No Sensitive wetland habitats associated with the No Wetlands designated site are located a significant distance downstream and do not have the potential to be impacted

Mitigation Measures

While the current WwTP is technically operating within its treatment capacity of 325 p.e. poor effluent quality and limited assimilative capacity in the Eyrecourt stream highlight the need for optimisation of processes within the current plant to prevent impacts to the integrity of the SAC and SPA.

To comply with the measures in the Lough Derg Water Management Unit Action Plan, the Eyrecourt WwTP requires implementation of the following:

 Increase capacity of treatment plant.  Provide tertiary treatment or relocate outfall.  Provide nutrient removal or relocate outfall.

Mitigation Measures recommended for the ongoing operation of the new plant are as follows:

 Implementation of an appropriate performance management system for the plant;  Optimisation of the current waste water treatment process and investigate further measures to reduce the levels of BOD, Ammonia and Orthophosphate currently being discharged from the plant  Ensure that the capacity of the WwTP is not exceeded; and  Monitoring upstream and downstream (incl. biological water quality monitoring) once prior to the upgrade works to provide the baseline and once after the works to show improvement to the receiving watercourse.

24 | Irish Water Natura Impact Statement - Eyrecourt

Stage 2 Appropriate Assessment Conclusion Statement The current Appropriate Assessment has been prepared following the EPA (2009) ‘Note on Appropriate Assessments for the purposes of the Waste Water Discharge (Authorisation) Regulations, 2007 (S.I. No. 684 of 2007)’. The Department of the Environment, Heritage and Local Government guidance ‘Appropriate Assessment of Plans and Projects in Ireland. Guidance for Planning Authorities’ (DoEHLG, 2009a) has also been taken into account. The current assessment for the Waste Water Discharge Licence Application investigates the potential adverse effects on the aquatic qualifying interests of the Natura 2000 network arising from the plant discharge, in combination with other plans / projects affecting the aquatic environment. The assessment considers whether the discharge, alone or in combination with other projects or plans, will have adverse effects on the integrity of a Natura 2000 site, and includes any mitigation measures necessary to avoid, reduce or offset negative effects.

When the above mitigation measures are implemented in full, it is envisaged that there will be no significant adverse effects on the integrity of the River Shannon Callows SAC and Middle Shannon Callows SPA in view of these site’s conservation objectives and that the conservation status of the Annex I habitats, Annex II species, or protected bird species will not be compromised by WwTP discharge either directly, indirectly or cumulatively.

It is therefore concluded that the Eyrecourt WwTP discharge, alone or in-combination with other plans and / or projects will not give rise to significant effects on the integrity of River Shannon Callows SAC and Middle Shannon Callows SPA, as long as the mitigation measures as listed above are implemented in full. Stage 2 concludes the Appropriate Assessment process of the Eyrecourt Waste Water Discharge Licence Application.

25 | Irish Water Natura Impact Statement - Eyrecourt

References Colhoun, K & Cummins, S.(2013) Birds of Conservation Concern in Ireland 2014-2019. Irish Birds 9: 523-544.

Crowe (2005) Irelands Wetlands and Their Waterbirds: Status and Distribution. Birdwatch Ireland.

DoEHLG (2008). Circular L8/08 Water Services Investment and Rural Water Programmes – Protection of Natural Heritage and National Monuments. Department of the Environment, Heritage and Local Government.

DoEHLG (2009). ‘Appropriate Assessment of Plans and Projects in Ireland. Guidance for Planning Authorities’. Department of the Environment, Heritage and Local Government.

Environment Agency (2000). Aquatic Eutrophication in England & Wales: A Management Strategy. Environment Agency, Bristol.

European Commission (2000a). Communication from the Commission on the Precautionary Principle., Office for Official Publications of the European Communities, Luxembourg.

European Commission (2000b). Managing Natura 2000 Sites: the provisions of Article 6 of the ‘Habitats’ Directive 92/43/EEC, Office for Official Publications of the European Communities, Luxembourg.

European Commission (2001). Assessment of plans and projects significantly affecting Natura 2000 sites: Methodological guidance on the provisions of Articles 6(3) and (4) of the Habitats Directive 92/43/EEC. Office for Official Publications of the European Communities, Brussels.

European Commission (2006). Nature and biodiversity cases: Ruling of the European Court of Justice. Office for Official Publications of the European Communities, Luxembourg.

European Commission (2007). Guidance document on Article 6(4) of the 'Habitats Directive' 92/43/EEC – Clarification of the concepts of: alternative solutions, imperative reasons of overriding public interest, compensatory measures, overall coherence, opinion of the commission.

European Commission (2013). Interpretation Manual of European Union Habitats. Version EUR 28. DG Environment.

European Communities Environmental Objectives (Surface Waters) Regulations 2009. S.I. 272 of 2009.

European Communities (Birds and Natural Habitats) Regulations 2011. S.I. 477 of 2011.

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EPA (2009) Waste Water Discharge Licensing Appropriate Assessment Guidance Notes. Notes on Appropriate Assessments for the purposes of the Waste Water Discharge (Authorisation) Regulations, 2007 (S.I. No. 684 of 2007) Environmental Protection Agency, Co. Wexford.

Fox, T; Francis, I, Norriss, D & A. Walsh. (2013) Report of the 2012/2013 International Census of Greenland White-fronted Geese. Greenland White-fronted Goose Study. Final Report – November 2013.

Hall,C; Glanville, J.R.; Boland, H; Einarsson, O; McElwaine, G; Holt, C.A; Spray, C.J. and Rees, E. (2012) Population size and breeding success of Iceland Whooper Swans Cygnys Cygnus: results of the 2010 international census. Wildfowl 62: 73-96.

Mainstone, C.P., Parr, W. & Day, M. (2000). Phosphorus and River Ecology – tackling sewage inputs. English Nature/Environment Agency, Peterborough.

Maitland & Campbell. (1992). Freshwater Fishes of the British Isles. Harper Collins Publishers. Somerset, UK.

NPWS (2008). The Status of EU Protected Habitats and Species in Ireland. National Parks and Wildlife Service, Department of the Environment, Heritage and Local Government, Dublin.

NPWS (2011). Wexford Harbour and Slobs SPA (004076) and the Raven SPA (004019): Conservation Objectives Supporting Document[Version 1]. Unpublished Report.

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

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

OECD (1986) Water pollution by fertilisers and pesticides. Organisation for Economic Cooperation and Development, Paris, 144 pp.

Routledge, E.J., D. Sheahan, C. Desbrow, G. Brighty, M. Waldock, and J.P. Sumpter (1998). Identification of estrogenic chemicals in sewage treatment effluent, 2. In vivo responses in trout and roach, Environment, Science and Technology, 32: 1559-65.

ShRBD (2010) District - River Basin Management Plan – Lough Derg Water Management Unit: http://www.wfdireland.ie/docs/1_River%20Basin%20Management%20Plans%202009%20- %202015/ShIRBD%20RBMP%202010/Water%20Management%20Unit%20Action%20Plans/Lo ugh%20Derg%20WMU.pdf

27 | Irish Water Natura Impact Statement - Eyrecourt

28 | Irish Water Natura Impact Statement - Eyrecourt Parameter Results(mg/l) Sampling Method Limit of Quantitation Analysis Method/Technique 16/04/2009 Date Date Date pH 7.8 Grab 2 pH Probe Temperature 11.2 Grab 5 Temperature Probe Electrical Conductivity (@25oC) 758 Grab 5 Conductivity Meter Suspended Solids 2 Grab 2 Gravimetric Ammonia (as N) 0.024 Grab 0.005 Konelab-Salicylate Biochemical Oxygen Demand <1 Grab 2 5 day test based on 510B Chemical Oxygen Demand 21 Grab 10 Reacter Digestion Dissolved Oxygen 10.5 Grab 1 Oxygen Probe Hardness (as CaCo3) 378.1 Grab 20 Konelab based on 2340C Total Nitrogen (as N) 2.8 Grab 0.1 Persulphate Digestion Method Nitrite (as N) 0.012 Grab 0.005 Konelab based on 4500 - NO2 Nitrate (as N) 1.868 Grab 0.1 Konelab based on 4500 - NO3 Total Phosphorus (as P) 0.032 Grab 0.01 Acid Digestion & Konelab Orthophosphate (as P) - unfiltered 0.03 Grab 0.01 Konelab based on 4500-P Sulphate (SO4) 20.64 Grab 5 Konelab based on blue book Phenols (sum) Note : (ug/l) <5 Grab 5 GC/MS Parameter Results(mg/l) Sampling Method Limit of Quantitation Analysis Method/Technique 17/04/2009 Date Date Date pH 7.8 Grab 2 pH Probe Temperature 11.1 Grab 5 Temperature Probe Electrical Conductivity (@25oC) 764 Grab 5 Conductivity Meter Suspended Solids 4 Grab 2 Gravimetric Ammonia (as N) 0.353 Grab 0.005 Konelab-Salicylate Biochemical Oxygen Demand 5 Grab 2 5 day test based on 510B Chemical Oxygen Demand 10 Grab 10 Reacter Digestion Dissolved Oxygen 10.1 Grab 1 Oxygen Probe Hardness (as CaCo3) 391.5 Grab 20 Konelab based on 2340C

Total Nitrogen (as N) 3.13 Grab 0.1 Persulphate Digestion Method

Nitrite (as N) 0.014 Grab 0.005 Konelab based on 4500 - NO2

Nitrate (as N) 1.776 Grab 0.1 Konelab based on 4500 - NO3 Total Phosphorus (as P) 0.137 Grab 0.01 Acid Digestion & Konelab Orthophosphate (as P) - unfiltered 0.07 Grab 0.01 Konelab based on 4500-P Konelab based on blue book Sulphate (SO4) 20.57 Grab 5 method E 2nd edition Phenols (sum) Note : (ug/l) <5 Grab 5 GC/MS Parameter Results(μg/l) Sampling Method Limit of Quantitation Analysis Method/Technique 16/04/2009 Date Date Date Atrazine <0.02 Grab 0.04 GC Dichloromethane <1 Grab 1 GCMS Simazine <0.02 Grab 0.04 GC Toluene 1.6 Grab 1 GCMS Tributyltin <0.02 Grab 0.02 GCMS Xylenes <1 Grab 1 GCMS Arsenic <0.05 Grab 0.5 ICP-MS Chromium <0.05 Grab 0.5 ICP-MS Copper 2 Grab 1 ICP-MS Cyanide <10 Grab 10 Colorimetric Fluoride 0.2 Grab 0.1 IC Lead <0.05 Grab 0.5 ICP-MS Nickel <0.05 Grab 0.5 ICP-MS Zinc 5 Grab 5 ICP-MS Boron <10 Grab 10 ICP-MS Cadmium <0.5 Grab 0.5 ICP-MS Mercury <0.05 Grab 0.05 ICP-MS Selenium <0.5 Grab 0.5 ICP-MS Barium 20 Grab 0.5 ICP-MS Parameter Results(μg/l) Sampling Method Limit of Quantitation Analysis Method/Technique 17/04/2009 Date Date Date Atrazine <0.02 Grab 0.04 GC Dichloromethane <1 Grab 1 GCMS Simazine <0.02 Grab 0.04 GC Toluene 1 Grab 1 GCMS Tributyltin 0.02 Grab 0.02 GCMS Xylenes 1 Grab 1 GCMS Arsenic 0.5 Grab 0.5 ICP-MS Chromium 0.5 Grab 0.5 ICP-MS Copper 1 Grab 1 ICP-MS Cyanide 10 Grab 10 Colorimetric Fluoride 0.1 Grab 0.1 IC Lead 0.5 Grab 0.5 ICP-MS Nickel 0.5 Grab 0.5 ICP-MS Zinc 5 Grab 5 ICP-MS Boron 10 Grab 10 ICP-MS Cadmium 0.5 Grab 0.5 ICP-MS Mercury 0.05 Grab 0.05 ICP-MS Selenium 0.5 Grab 0.5 ICP-MS Barium 0.5 Grab 0.5 ICP-MS