Natura lmpact Statement

Site lnvestigations for Training Wall,

Belview Port, Co.

MAI.ONE O'REGAN

2B Richview Office Park, St. Catherine's House, 4, McDopagh Terrace, Clonskeagh, Catherine Street, Woodquay, Dublin L4. Waterford. Galway.

Tel: +353 01 2602655 Tel: +353 5L 876855 Tel: +353 91 53L069 NSAI Ccrllllcd Fax: +353 0I2602660 Fax:+353 51876828 Fax :+353 91 531084 e-mail: [email protected] e-mail : [email protected] e-mail: [email protected] Form ES - 04

2B Richview Office Pa¡k Glonskeagh, Dublin l4 fsl¡ +353- 1- 260 26 55 Fax: +353-1-2602660 /$)ì Fmall: [email protected] MALONE O'REGAN ENVIRONMENTAL SERVICES LTD

Title: Natura lmpact Statement, Site Investigat¡ons for River Training Wall

Job Number: E0848

Prepared By: Michelle Purcell S¡g

Checked By: Siobhan Maher Sign

Approved By: Siobhan Maher Sign

Revision Record lssue Date Description Remark Prepared Ghecked Approved No. 01 15t08t11 NlS, Site lnvestigations Finaf MP SM SM for River Traininq Wall N atu ra I m pa ct Statem ent August 2011 Site lnvestigations for River Training Wall Po¡t of Waterford Company Belview Port, Co. Waterford

Port of Waterford Gompany, Belview Port, Co. Waterford

Natura lmpact Statement

TABLE OF CONTENTS

1.0 Introduction ..... 2 1.1 Appropriate Assessment - Regulatory Context .2 1.2 Methodology ...... 2 2.0 Description of the Project...... 4 3.0 ldentification of Natura 2000 Sites. 5 3.1 Characteristics of the Designated Sites...... 5 4.0 Description and Assessment of Likely lmpacts...... I 4.1 Potential lmpacts on Annex I Habitats.... .9 4.2 Potential lmpacts on Annex ll Species

4.3 I n-Combination Effects 5.0 Mitigation Measures.. 5.1 Noise from Drilling Works 5.2 Release of Contaminants during Drilling 6.0 Residual lmpacts and Gonclusions...... 6.1 Annex I Habitats 6.2 Annex ll Species... 7.0 References

List of Figures Figure 1 Location of Proposed Project

List of Tables

Table 1 Qualifying Habitats for the Lower Suir SAC Table2 Annex ll of Directive 92l43lEEC (the Habitats Directive) listed for the Lower Suir SAC Table 3 Annexed Habitats present within the Natura site but which are not listed on the Natura 20OO Standard Data Form or on the Conservation Objectives for the Site Table 4 Qualifying habitats for the & Nore SAC Table 5 Annex ll of Directive 92l43lEEC (the Habitats Directive) Table 6 Recommended Criteria for Avoiding lnjuries to Fish from Pile Driving Operations Table 7 lnterim Criteria for lnjury Agreement in Principle

Appendices Appendix A Drawing No's. W10050-1 and W10050-2

Malone O'Regan Natura lmpact Statement August 201 I Site lnvestigations for River Training Wall Po¡t of Waterford Company Belview Pott, Co. Wateñord 1.0 lntroduction This Natura lmpact Statement (NlS) has been prepared by Malone O'Regan Environmental Services for the Port of Waterford Company in order to determine the likelihood and significance of impacts on sites with European conservation designations (i.e. Natura 2000 sites) arising from the proposed Site lnvestigations for the River Training Wall at Belview Port.

The purpose of this assessment is to determine, the appropriateness or otherwise, of the proposed project in the context of the conservation status of such sites. By taking the ecological impact assessment in a step by step manner in relation to the habitats and species of such sites, together with their conservation objectives, this report seeks to inform the screening process required as the first stage of the process pursuant to Article 6.3 of the EU Habitats Directive and also to provide full and detailed information as required for the second, that of Appropriate Assessment. This report is entitled a 'Natura lmpact Statement' but it also comprises the 'Screening Statement' as required under the first stage of the process.

1.1 Appropriate Assessment - Regulatory Gontext The Council Directive 92l43lEEC on the Conservation of Natural Habitats and of Wild Flora and Fauna better known as "The Habitats Directive" provides the framework for 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 (20091147|EEC) (better known as "The Birds Directive")

Article 6(3) and 6(a) of the Habitats Directive set out the decision-making tests for plans and projects likely to affect Natura2000 sites (Annex 1.1). Article 6(3) establishes the requirement for Natura lmpact Assessment (formerly referred to as Appropriate Assessment):

"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 and projects, shall be subjected to appropriate assessmenf of its implications for the site in view of fhe sife s conseruation objectives. ln light of the concluslons of fhe assessment of the implication 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 asceftained that it will not adversely affect the integrity of the site concerned and, if appropriate, after having obtained the opinion of the general public"

The regulatory context is set out in the recently published document 'Appropriate Assessment of Plans and Projects in lreland. Guidance for Planning Authorities' (Department of Environment, Heritage and Local Government December 2009, revised February 201 0, www.npws.ie).

1.2 Methodology This report has been undertaken in accordance with the European Commission Methodological Guidance on the provision of Article 6(3) and 6(a) of the 'Habitats' Directive 92l43lEEC (EC 2001) and the European Commission Guidance 'Managing

Malone O'Regan 2 Natura lmpact Statement August 2011 Site lnvestigations for River Training Wall Port of Watertord Company Belview Co. Waterford

Natura 2000 Sites'. The Guidance for Planning Authorities issued by the Department of Environment, Heritage and Local Government is also adhered to.

ln complying with the obligations under Article 6(3) and following the above Guidelines, the approach to Stage I Screening is as follows:

. Description of the Project; . ldentification of Natura 2000 sites potentially affected; . ldentification and description of individual and cumulative impacts likely to result from the Project; and . Assessment of the significance of the impacts identified above on the integrity of sites. Exclusion of sites where it can be objectively concluded that there will be no significant effects.

Requirements under Stage ll include a discussion of the predicted impacts, identification of appropriate mitigation measures and a concluding statement. This is included in Sections 4.0, 5.0 and 6.0 of this NlS.

Malone O'Regan 3 N atu ra I m pact State m ent August 2011 Site lnvestigations for River Training Wall Port of Watertord Company Belview Port, Co. Wateñord 2.0 Description of the Project The Port of Waterford Company (POWC) propose to carry out site investigations in relation to the construction of a River Training Wall at Belview Port, Co. Waterford. The investigation works will take place within the at the proposed location of the River Training Wall. The proposed location is just upstream of the confluence of the River Suir with the River Barrow/Nore.

The site is bounded to the north and west by the Waterford to Rosslare Railway line, to the east by the River Barrow/Nore and to the south by the River Suir. The River Training wall will be located in the River Suir at a maximum distance of approximately 300m from the bank of the river.

The purpose of the site investigations is to establish the ground conditions on the site where it is proposed to construct a River Training Wall. The proposed investigation will consist of the drilling of '15 dynamic probes, I boreholes and 4 coreholes and associated sampling and testing. The drilling work will be undertaken using shell and auger, rotary core and dynamic probe equipment which will be placed on a barge. The investigations will also comprise a geophysical survey which will be undertaken to provide a profile of the underlying rock on the site. The geophysical survey will extend over the full area of the base of the proposed River Training Wall. All drilling works will be through the river into underlying soils and rock. Access to the site will be from Belview Port.

At this juncture the investigation works are scheduled to commence on the'12th September and finish on 28th October 201 1.

The location of the proposed project is shown on Figure 1 and also on Drawing W10050 - I in Appendix A. The locations of boreholes, coreholes and dynamic probes are illustrated on Drawing W10050-2, also included in Appendix A.

Malone O'Regan 4 N atu ra I m pact State m ent August 2011 Site lnvestigations for River Training Wall Port of Wateñord Company Belview Port, Co. Waterford

3.0 ldentification of Natura 2000 Sites ln accordance with the European Commission Methodological Guidance (EC2001), a list of Natura 2O0O Sites that can be potentially affected by the proposed project has been complied. Adopting the precautionary principle in identifying these sites, it has been decided to include all SACs and SPA sites within a 1Okm radius of the location of the proposed site investigation works.

The proposed site investigation works occur within the following Natura 2000 Sites:

a Lower River Suir SAC (code: 02137); and

a River Barrow & SAC (code 02162)

3.1 Characteristics of the Designated Sites

3.1.1 Lower Suir SAC (site code: 0021371 This is an extensive site, which covers over 100km of main river channel from just south of on the upstream end to the Barrow-Suir confluence at the downstream end where the river is tidal and brackish. The SAC is noted for several riparian wetland habitats as well as a wide range of Annex ll species (Table 1 and 2 below).

Table I Habitats for the Lower Suir SAC Qualifvins Habitats (* denotes Prioritv Habitat) Code Atlantic salt meadows (Glauco-Puccinellietalia maritimae) 1 330 Mediterranean salt meadows (Juncetalia maritimi) 1410 Water courses of plain to montane levels with the Ranunculion fluitantis and 3260 Callitricho-Batrachion veoetation Old sessile oak woods with llex and Blechnum in British lsles 9140 Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-Padion, 91 E0 Alnion incanae, Salicion albae) Hydrophilous tall herb fringe communities of plains and of the montane to 6430 aloine levels

Table 2 Annex ll of Directive 92l43lEÊC (the Habitats Directive) listed for the Lower Suir SAC Species Species Name Gode Mammals listed on Annex ll of the Habitats Otter (Lutra lutra) 1 355 Directive Fishes listed on Annex ll of the Habitats Salmo salar (Atlantic salmon) 1 106 Directive Petromvzon marinus (Sea lamprev) 1 095 Lamoetra olaneri (Brook lamprev) 1096 Lamoetra fl uviatilis (River lamorev) 1 099 Alosa fallax (Twait shad) 1 103 Alosa alosa (Allis shad) 1102 lnvertebrates listed on Annex ll of the Austropotamobius pallioes 1092 Habitats Directive Marqaritifera marqaritifera 1029

Conservation Objectives European and national legislation places a collective obligation on lreland and its citizens to maintain at favourable conservation status areas designated as candidate Special Areas of Conservation. The Government and its agencies are responsible for

Malone O'Regan 5 N atura lm pact Statement August 2011 Site lnvestigations for River Training Wall Port of Waþrtord Company Belview Port, Co. Watertord the implementation and enforcement of regulations that will ensure the ecological integrity of these s¡tes.

According to the EU Habitats Directive, favourable conservation status of a habitat is achieved when:

a Its natural range, and area it covers within that range, is stable or increasing, and a The ecological factors that are necessary for its long-term maintenance exist and are likely to continue to exist for the foreseeable future, and a The conservation status of its typical species is favourable as defined below.

The favourable conservation status of a species is achieved when

a Population data on the species concerned indicate that it is maintaining itself, and a The natural range of the species is neither being reduced or likely to be reduced for the foreseeable future, and a There is, and will probably continue to be, a sufficiently large habitat to maintain its populations on a long-term basis.

Draft conservation objectives for SAC 002137 are as follows

Objective 1 To maintain the Annex I habitats for which the ISAC has been selected at favourable conservation status: Alluvial foresfs with Alnus glutinosa and Fraxinus excelsior (Alno-Padion, Alnion incanae, Salicion albae); Old sessi/e oak woods with llex and Blechnum in British /s/es; Iaxus baccata woods of the British /s/es; Atlantic salt meadows (Glauco-Puccinellietalia maritimae); Mediterranean salt meadows (Juncetalia maritimi); Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation; Hydrophilous tall herb fringe communities of plains and of the montane to alpine levels

Objective 2 To maintain the Annex // specles for which fhe cSAC has been selected at favourable conservation sfafus; Petromyzon marinus, Lampetra planeri, Lampetra fluviatilis, Alosa fallax, Salmo salar, Lutra lutra, Austropotamobius pallipes, Marg aritifera margaritife ra

Objective 3: To maintain the extent, specres richness and biodiversity of the entire sife.

Objective 4: To establish effective liaison and co-operation with landowners, legal users and relevant authorities.

It is possible that some species which are listed in Table 1 and 2 above may not be included in these conservation objectives and possibly others may be added but for the meantime it is assumed that all listed species will be included. Other species of interest may include European smelt (Osmerus eperlanus).

Other Annex I habitats and Annexed species present within the SAG Annex I habitats which are not listed on the Natura 2000 Standard Data Form or included in the conservation objectives, are shown in Table 3.

Malone O'Regan 6 N atu ra I m pact Statem ent August 2011 Site lnvestigations for River Training Wall Port of Wateñord Company Belview Por7, Co. Waterford

Table 3 Annexed Habitats present within the Natura site but which are not listed on the Natura 2000 Standard Data Form or on the Conservation Objectives for the Site

Annex I Habitats Code Estuaries 1130 Mudflats and sandflats not covered bv sea water at low tide 1140

3.1.2 River Barrow & Nore SAC (site code 002162) This site is even bigger than the Lower Suir SAC and consequently has more habitats and species as qualifying interests. ln particular it contains the qualifying estuarine habitat types, which are present in below the Suir - Barrow confluence. ln terms of anadromous species (salmon, lamprey and shad) all the same species as listed for the Lower Suir cSAC are also listed for the River Barrow & Nore SAC(Tables4&5).

Table 4 Qual habitats for the River Barrow & Nore SAC Qualifvinq Habitats (* denotes Prioritv Habitat) Code Old sessile oak woods with llex and Blechnum in British lsles 9140 Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-Padion, Alnion 91 E0 incanae. Salicion albae) Water courses of plain to montane levels with the Ranunculion fluitantis and 3260 Callitricho-Batrachion veoetation Salicornia and other annuals colonizinq mud and sand 't310 Atlantic salt meadows (Glauco-Puccinellietalia maritimae) 1 330 Mediterranean salt meadows (Juncetalia maritimi) 1410 European drv heaths 4030 Petrifuinq sþrinos with tufa formation (Cratoneurion) 7220 Hydrophilous tall herb fringe communities of plains and of the montane to alpine 6430 levels Soartina swards (Soartinion maritimae) 1320 Mudflats and sandflats not covered bv seawater at low tide 1140 Estuaries 1 130

Table 5 Annex ll of Directive 92l43lEEC Habitats Directive Species Species Name Gode Mammals listed on Annex ll of the Habitats Otter (Lutra lutra) 1 355 Directive Fishes listed on Annex ll of the Habitats Salmo salar (Atlantic salmon) I 106 Directive Petromyzon marinus (Sea lamprey) 1 095 Lampetra planeri (Brook lamprey) 1 096 Lampetra fl uviatilis (River lamprey) 1 099 Alosa fallax (Twait shad) 1 103 Alosa alosa (Allis shad) 1102 lnvertebrates listed on Annex ll of the Habitats Austroootamobius oallioes 1092 Directive Maroaritifera maroaritifera 1029 M a rqa ritife ra d u rrove n si s 1 990 Ver-tiqo moulinsiana 1016

Malone O'Regan 7 N atura lm pact Statement August 2011 Site lnvestigations for River Training Wall Port of Watedord Company Belview Pott, Co. Watertord

Conservation Ob¡ect¡ves

Draft conservation objectives for SAC 002162 are as follows:

Objective 1 To maintain the Annex I habitats for which the SAC has been selected at favourable conseruation sfafus: Estuaries; Mudflats and sandflats not covered by seawater at low tide; Salicornia and other annuals colonising mud and sand; Atlantic sa/f meadows (Glauco-Puccinellietalia maritimae); Mediterranean salt meadows (Juncetalia maritimi); Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrach ion vegetation ; European dry heaths; Hydroph ilous tall herb fringe communities of plains and of the montane to alpine levels; Petrifying spnngs with tufa formation (Cratoneurion); Old sess/e oak woods with llex and Blechnum in British Isles; Alluvial foresfs with Alnus glutinosa and Fraxinus excelsior (Alno-Padion, Alnion incanae, Salicion albae)

Objective 2: To maintain the Annex // specres for which the SAC has been selected at favourable conseruation sfafus: Veftigo moulinsiana; Margaritifera m a rg a ritife ra ; Au stro pota m o b i u s p al I i pe s ; P etro myzo n m a ri n u s; La m petra planeri; Lampetra fluviatilis; Alosa fallax; Salmo salar; Lutra lutra; T rich o m a n es speciosum ; M a rg a ritife ra d u rrove n si s

Objective 3: To maintain the extent, specres rrchness and biodiversity of the entire slfe.

Objective 4: To establish effective liaison and co-operation with landowners, legal users and relevant authorities.

Malone O'Regan I N atura lmpact Statement August 2011 Siúe lnvesfiþations for River Training Wall Port of Waterîord Company Belview Port, Co. WaErtord

4.0 Description and Assessment of Likely lmpacts Only those features of the proposed development that have the potential to impact on features and conservation objectives of the identified Natura sites are considered. A number of factors were examined at this stage for dismissal or for carrying forward for impact assessment as relevant. The following factors have been considered:

a Direct impacts on Annex I Habitats arising from the proposed site investigation works; a Direct impacts on Annex ll Species arising from the proposed site investigation works; and Drilling activities giving rise to potential impacts on water quality indirectly affecting Annex ll fish species.

4.1 Potential lmpacts on Annex I Habitats ln the context of the present project, all of the Annex I Habitats are not relevant to the assessment due to their localised or restricted distributions within the SAC. ln this regard, an overview is given below for each habitat. The below information on the habitats of the Lower Suir SAC was derived from a NIS completed by Dr. Brian Madden of Biosphere Environmental Services (BES) in relation to a separate development at Belview Port. The full reference for this source is provided in Section 7.0.

Annex I Habitats (Lower River Suir SAC)

Atlantic Salt Meadows and Mediterranean Salt Meadows This habitat occurs in the stretch of the Suir just below Waterford City, often along tidal stretches of inflowing or in old meadows where the river embankment is absent or has been breached.

Alluvial Wet Woodland This habitat is found in both the tidal and freshwater stretches of the main river channels but is generally limited in distribution. The best examples occur on the islands just below Carrick-on-Suir and at Fiddown lsland.

Old Oak Woods Old oak woods occur in patches within the site (Lower Suir cSAC), with the best stands at Woods on the Clodiagh River. There are no known stands in the vicinity of Belview.

Eutrophic Tall Herb Veqetation This is a fairly specialised habitat that occurs over small areas associated with flood plains and especially alluvial forest. lt would not be expected in the Belview area.

Floatinq River Veqetation Floating River Vegetation refers to watercourses characterised by submerged or floating leaved vegetation (Ranunculion fluitantis and Callitricho-Batrachionn vegetation). The definition of watercourses characterised by Ranunculion fluitantis and Callitricho-Batrachion communities is very wide, in practice covering the majority of rivers and streams with aquatic plant communities of note. Floating River Vegetation is mainly confined to the freshwater stretches of the River Suir and would not be expected in tidal areas such as at Belview.

Malone O'Regan 9 N atu ra I m pact Statem ent August 201 1 Site lnvestigations for River Training Wall Port of Waterford Company Belview Port, Co. Wate¡ford

Annex I Habitats (River Barrow and Nore SAC)

Estuaries The proposed works will occur within the Lower Suir Estuary and the BarroMSuir/Nore Estuary. Significant impacts on the estuarine habitat are not anticipated. Disturbance of estuarine deposits will occur due to the drilling works but this will be localised and temporary in nature.

Mudflats and Sandflats Mudflats and sandflats do not occur at the location of the proposed investigation works and hence no significant impact is anticipated.

Salicornia and Other Annuals Colonisinq Mud and Sand Plant species are not present at the location of the proposed works as it is within the River Suir.

European Drv Heaths Plant species are not present at the location of the proposed works as it is within the River Suir.

Petrifyino Sprinqs with Tufa Formation (Crafoneurion) Tufa formation is associated with hard-water springs, where groundwater rich in calcium bicarbonate comes to the surface (Joint Nature Conservation Committee, 2007). This habitat does not occur at the site of the proposed site investigation as it is within the River Suir.

4.2 Potential lmpacts on Annex ll Species ln the context of the present project, many of the Annex ll species listed under the Lower River Suir and the River Barrow and Nore SAC are not relevant to the assessment due to their localised or restricted distributions and these include pearl mussel (Margaritifera margaritifera). freshwater crayfish (Austropotamobius pallipes) and brook lamprey (Lampetra planari) who are not present in the tidal stretches of the SACs and hence are not discussed further. Atlantic Salmon (Salmo salar), sea lamprey (Petromyzon marinus), river lamprey (Lampetra fluviatilis), twait shad (Alosa fallax) and otter (lutra lutra) can however be expected at the location of the proposed site investigation works and therefore are relevant to the context of the present project.

Annex ll Species The information below is derived from a NIS completed by Mr. Ger Morgan of the Aquatic Services Unit (ASU) for the proposed Belview Port Oil Berth and the proposed Grattan Quay, Quarry Road and Bilberry Road lmprovement Works. lnformation on otter, pearl mussel, freshwater crayfish and brook lamprey is derived from a NIS completed by Dr. Brian Madden of Biosphere Environmental Services (BES) in relation to a separate development at Belview Port (see Section 7.0 for full references). The information presented below is in relation to the presence of species within the River Suir. This is considered appropriate as all site investigation works are proposed to occur within the River Suir.

Atlantic salmon, twait shad, allis shad, sea lamprey, river lamprey, and brook lamprey are all qualifying species for both SACs. Allis shad (Alosa a/osa) is also a qualifying species for the Lower River Suir SAC but it is not included in the draft Conservation Objectives for the SAC. Sea trout (Sa/mo trutta) and european smelt (Osmerus eperlanus) are also notable species within the Lower River Suir SAC. All these species

Malone O'Regan 10 N atura lmpact Statement August 201 1 Site lnvesfþations for River Tra¡ning Wall Port of Waþrtord Company Belview Port, Co. Watertord

pass through the Suir at Waterford City either on their way to spawning grounds around Carrick on Suir (sea lamprey, twait shad and smelt) or to spawning areas further up the system (salmon, trout and lampreys). lt is clear therefore that none of these species spawn within or below the project area on the main channel of the Suir and in the main only use it as a migratory route.

Atlantic Salmon The Suir is one of lreland's most important salmonid rivers and salmon spawn throughout the very extensive headwater streams and tributary rivers of the Suir system. Until recently, salmon were fished by snap-net teams in the upper estuary and middle estuary while in the lower estuary drift nets were deployed in a significant commercial fishery for the species. A ban on all commercial fishing since 2007 in an effort to improve the conservation status of the species appears to be bearing fruit, with a reported large run of salmon into the lower estuary this summer-autumn - (pers. comm. Mr. Andrew Gillespie lFl, ). The immediate project area and adjoining channel is used as a migratory channel for adult salmon returning to spawn, spent species returning to sea and smolts running to sea. The main smolt run is between March and mid-June, while the inward adult migration is from July to October and again in December, with the latter apparently the larger run (pers comm.. Padraig Kilfeather, lFl Clonmel). For both adults and smolts, high river flows are often associated with larger movements. While, smolts will not delay their journey once they initiate it and continue directly to sea, the summer-autumn returnees will often spend extended periods holding station in the estuary depending on flow, however, adult salmon are not known to congregate around Rice Bridge in the city stretch (pers. comm.. lFl Clonmel). Salmon do not spawn or feed within the Belvrew area.

Shad Twait Shad are reported to have declined in numbers in the Suir over the past two decades (King and Roche, 2008). They are a migratory member of the herring family which spawns in freshwater. On the Suir they spawn in calm waters about 1km upstream of the old bridge in Carrick-on-Suir principally during the month of May when they used to be recreationally fished by local anglers. The spent adults commence their migration to the outer estuary immediately after spawning and spent fish have been taken in nets in the lower and outer estuary (King and Roche, 2008). Little is known of what happens on the Suir to the emerging fry. However, based on a review of data from other rivers (in Europe and the UK - Aprahamian et al,2O03) the fry emerge after about 3 to 5 days and commence their gradual move down the estuary feeding on crustacean plankton (Aprahamian, 1989) and appear in the outer estuary in the late summer and autumn.

Small numbers of the Annex ll allis shad have been found in the upper estuary of the Suir which were shown to have mature gonads (from May to August). A single fish in the lower estuary in July was in a post-spawning condition (King and Roche, 2008). This suggests that the fish may spawn in the Suir either alone or with Twait shad with whom they may also hybridise.

Sea Lamprev Sea Lamprey probably migrate upriver in April-June to spawn in June and July in the freshwater reaches of the Suir. O'Connor has recorded the juveniles (ammocoetes) in the main channel as far upstream as Caher; they were also present in the lower reaches of the River Tar. Their status in the Suir is classed as unfavourable in accordance with a UK Environment Agency method (O'Connor 2007). The ammocoetes live in marginal silty areas where the gradually develop over several years. They then begin to metamorphose to the adult starting in July. This takes about 3 months after

Malone O'Regan 11 N atura I m pact Statement August 2011 Site lnvestigations for River Training Wall Port of Watedord Company Belview Port, Co. Waterford

which they migrate to the lower estuary in about October, where they commence their parasitic life on fish.

River Lamorey River lamprey appears to have less well-defined adult migrations than Sea lamprey, and have been observed far less than Sea lamprey while migrating, in lrish rivers. From the literature it seems that they may have two migratory peaks the first in the August-November period and a second in spring (March-April). Metamorphosed young adults begin their downstream migration over an extended period from late winter to early summer. O'Connor (2007) encountered 'nominal' numbers of transformers downstream of Clonmel in October. While O'Connor was unable to distinguish in most cases between the ammocoetes of River and Brook lamprey on the Suir (due to the season of survey), he suggests, nevertheless, that both species are at favourable status within the Suir catchment.

Olher (Lutra lutra\ Otter is a widespread species throughout the Suir system and can be expected anywhere within the SAC (Bailey and Rochford 2006).

The species listed above are common to both the Lower River Suir and the River Barrow and Nore SAC. However, the River Barrow and Nore SAC contains additional species which are discussed further below.

Desmoulin's Whorl Snai I ( Verfioo Moulrnsrana) This snail lives on vegetation in swamps, fens and marshes. This habitat does not occur at the location of the proposed site investigation works.

Killarnev F ern (T ri ch o m a n e s S pe ci osu m\ The Killarney Fern occurs in dripping caves, cliff faces, crevices by waterfalls and cascades, rock crevices in woodlands and very occasionally on the floor of damp woodlands (NPWS, 2008). lt would therefore not be present at the location of the proposed site investigations works.

N o re F reshwate r Pea rl M u sse I ( Marqarlflfera Durrovensr,s) This pearl mussel is a sub species of the freashwater pearl mussel (margaritifera margaritifera) and is found in freshwaters. lt would therefore not be present in the tidal waters of the River Suir at the location of the proposed site investigation works.

Based on the above it is concluded that in the context of the present project, all of the Annex I habitats are not relevant to the assessment due to their localised or restricted distributions within the SACs. Some Annex ll species are expected to occur within the SACs however and potential impacts in this respect are discussed further below.

Some data is available on the migrations of some of the fish species outlined above and their migration windows. The information in Figure 1 overleaf was derived from a NIS completed by Mr. Ger Morgan of the Aquatic Services Unit (ASU) for the proposed Belview Port Oil Berth and the proposed Grattan Quay, Bilberry Road and Quarry Road lmprovement Works. This information is considered tentative especially for juvenile stages, mainly because their passage through estuaries is poorly documented, especially in lreland. As noted in Figure 1 overleaf, there are very little windows of opportunity for completion of works when fish are unlikely to be affected.

Malone O'Regan 12 N atura I m pact Statement August 2011 Site lnvestigations for River Training Wall Port of Watertord Company Belview Port, Co. Waterford

Figure I Tentative Migration Windows of Protected Species through the Suir

f.t Salmon Smolts L- I Adults Sea Lamprey Adulls I --l Metâmorohosed t- R¡ver Lamprey Adults (?) I I Mêlañorohosed f?l I I Iwait Shad Adults E Juven¡les l?ì I Smelt Adults Juveniles (?) I I

Noise from Drilling Works Direct impacts on listed fish species from noise generated during the drilling of boreholes, coreholes and dynamic probes has been considered here. Drilling will occur throughout the eight week programme within the River Suir. The no¡se generated from such drilling is difficultto predict as itwould be influenced by a variety of factors such as the nature of the river bed i.e. whether drilling is into bedrock or not. Data on the noise levels generated from underwater drilling and the effect on fish is also extremely scarce. It is generally accepted however that underwater noise is damaging to fish species with effects reported including behavioural changes, auditory and non-auditory tissue damage and mortality. As there is virtually no data available on the impact of noise generated by drilling methods, such as those proposed for the site investigation works, data relating to pile driving in water is presented below. Table 6 details the recommended criteria for avoiding injuries to fish from pile driving operations (Carlson et al.,2007).

Table 6 Recommended Griteria for Avoidi ries to Fish from Pile Drivi Peak Cumulative Application Notes SEL Based on results of previous research Mass of (Yelverton ef a/. 1975; Stuhmiller et a/. Not 183 dB 1996), the relationship between SEL and Non- fish <0.59 Relevant fish body mass will most likely be linear on a auditory log-log scale. Therefore for body mass tissue between 0.5 and 200 grams: Cumulative damage Mass of Not SEL=186.47+11.53"1o91s(mass) >21 3 dB fish >2009 Relevant Extrapolations below 0.5 g and above 200 g are conservative based on available data. Hearing Accumulation of SEL should not be >206 dB >213 dB Auditory generalist reinitiated if cumulative SEL >213 dB. tissue Hearing After an 'l 8-hour period of non-exposure, >206 dB >1 89 dB damage qeneralist accumulation of SEL to the values given (hair cells) Hearing here should be reinitiated. >205 dB >185 dB specialist Hearing After an 18-hour period of non-exposure, 207 dB 185 dB tTTS qeneralist accumulation of SEL should be reinitiated. Hearing 205 dB 183 dB specialist

Based on the above recommendations (Table 6), in June 2008, the Federal Highway Administration (FHWA) in the US approved the following interim criteria from the Fish Hydroacoustics Working Group designed to prevent injury to fish as set out in Table 7 overleaf.

t TTS = Temporary Threshold Shift which means that the hearing is temporarily impaired due to exposure to loud noise

Malone O'Regan 13 N atura I m pact Statement August 2011 Site Investigations for River Training Wall Port of Waterford Company Belview Port, Co. Waterfoñ

Table 7 lnterim Criteria for ln Peak 206 dB (for all size of fish) Cumulative SEL 187 dB - for fish size of two grams or greater 183 dB - for flsh size of less than two qrams.

SEL (Sound Exposure Level) is the constant sound level in one second, which has the same amount of acoustic energy as the original time-varying sound (i.e., the total energy of an event). SEL is calculated by summing the cumulative pressure squared over the time of the event; it is given in dB re '1¡rPa2s. The cumulative SEL is derived by adding together the individual SEL outputs across the duration of the noise source (i.e. the duration of drilling works).

Nedwell and Howell (2004) described the transmission of drilling sound in water as consisting of either ground borne or structure borne. Ground borne vibration is created at the drill-rock interface by the movement of the drill head which then rad¡ates outwards as compressional and shear waves. The mechanical vibrations that are generated may also be transmitted to the water via the drill shaft. These transmission mechanisms are in relation to drilling of wind turbine pile foundations but it is expected that they would also apply to smaller scale drilling such as that proposed for the investigation works.

As noted earlier, literature on the noise levels to be expected from drilling equipment such as that proposed for the investigation works is extremely scarce. Nedwell and Howell (2004) presented a synopsis of undenruater drilling noise measurements and reported levels of 125d8 at 130m and 86dB at 480m for drill rigs in shallow water (6-7m deep). McCauley (1998) reported levels of 115d8 at 405m and 117dB at 125m in relation to exploratory rig drillers. The Naval Oceans System Centre (1982) monitored the noise at source from offshore oil and gas drilling activities and reported levels ranging from 190d8 - 220d8 at 1m at Prudhoe Bay in Alaska. The production of tones from drilling activities has also been reported (McCauley, 1998 and Hall ef a/., 1991). ln addition to the noise generated from the drilling, noise from the ancillary equipment i.e rigs, barges etc. would also contribute to the noise levels generated. lt should be noted that the levels presented above are not however directly comparable to the SEL criteria outlined in Tables 6 and 7.

Release of Suspended Solids during Drilling Suspended solids may be released due to localised disturbance of soft sediment during the drilling works. Release of sediment in sufficient quantities could blanket the bottom and possible smothering of macroinfauna. lt could also damage the gills of fish locally. However, the site is only moderately sensitive to this form of impact because the substrate is already composed of fine sediment and the waters already moderately to very turbid depending on the tide and river flow. Furthermore, works will occur in a small section of the river channel meaning that fish can avoid any localised suspended solids in the channel.

Release of Contaminants during Drilling The release of contaminants during drilling could occur due to leaks (fuel etc.) from the barge which will be used to hold and transport the drilling equipment. Mitigation measures in relation to the release of contaminants are therefore addressed in Section 5.0.

Malone O'Regan 14 Natura lmpact Statement August 201 1 Site lnvestigations for River Tra¡n¡ng Wall Port of Wateñord Company Belview Port, Co. Wate¡-ford

4.3 ln-Combination Effects The Habitats Directive requires that due consideration needs to be given to any plan or project which is likely to have a significant effect alone or in combination with other plans and projects.

Other projects in the vicinity, which have the potential to have a cumulative impact in combination with the proposed works, include:

Belview Port Tank Farm/Mooring Dolphin Construction; Waterford Haven Development including a proposed marina (commencement date unknown); and The Grattan Quay, Bilberry Road and Quarry Road lmprovement Works (commencement date unknown).

The proposed Belview Port Tank Farm/Mooring Dolphin is located approximately 600m upstream of the proposed investigation works. Some pile driving will be involved in this project and in theory migratory fish could be exposed to both piling noise from the proposed Belview Port Tank Farm/Mooring Dolphin and drilling noise from the proposed investigation works within a 24 hour period. However, planning permission has not yet been obtained for the mooring dolphin and hence it is extremely unlikely that any element of this project would be carried out at the same time as the proposed site investigations works.

The site of the proposed investigation works is located approximately 7.5km from the proposed Water Haven Development and the Grattan Quay, Bilberry Road and Quarry Road lmprovement Works. Both these projects will involve piling works and in theory migratory fish could be exposed to piling noise from either of these projects and drilling noise from the proposed investigation works within a 24 hour period. However, both the Water Haven development and the Grattan Quay, Bilberry Road and Quarry Road lmprovement Works are unlikely to commence in the near future and therefore the likelihood of the proposed investigation works being carried out at the same time as either of the aforementioned projects is extremely low or nil.

Malone O'Regan 15 N atura I m pact Statement August 2011 Site lnvesfþations for River Training Wall Port of Waþrtord Company Belview Port, Co. Waþrtord 5.0 MitigationMeasures

5.1 Noise from Drilling Works Using the interim criteria presented in Tables 6 and 7 as a gu¡de it is evident that the noise levels reported in literature (see Section 4.2) could cause injury to fish in the vicinity of the drilling works. However, the levels reported in the literature are in relation to noise levels generated from offshore oil and gas drilling activities and are considered to be higher than the levels expected to be generated from the equipment proposed for the investigation works. The drills proposed for the investigation works are on a much smaller scale than oil and gas drilling equipment and would also have a much lower power output and hence sound power level.

British Standard (BS) 5228 (2009) presents a sound levelof 74dB (A) at 10m for ground investigation drilling using a cable percussion drilling rig. lt would be expected that this noise level would be indicative of that produced by the drilling equipment proposed for the investigation works. However, a noise source is approximately 15 - 20dB louder when undenruaterand hence a noise level in the region of 97 - 100 dB at 10m would be expected when drilling undenruater. At this level it would not be anticipated that significant injuries to fish would be sustained as expected levels are well below the interim criteria presented in Tables 6 and 7.

It is clear from Figure 1, which illustrates migration windows of protected fish species in the R. Suir Estuary, that there is very little opportunity where fish are not on the move in the River Suir. However there are periods from mid November to the end of January when fish migratory activity is lower. However, as mentioned previously, this data is tentative and therefore is it not considered appropriate to recommend scheduling the proposed works during periods of perceived lower migratory activity.

Drilling will not be carried out at night which will leave significant downtime for migratory fish to pass the proposed site. Furthermore there will be downtime between the drilling of individual boreholes, coreholes and dynamic probes which will also provide an opportunity for fish to pass the proposed site. Fish species in the area are likely already exposed to significant noise sources in the area due to port activities and it is not anticipated that the additional noise generated from the proposed site investigation works will significantly contribute to this. Based on this and the expected noise level from the drilling equipment it is not expected that there will be significant impacts on fish species as a result of the proposed investigation works.

5.2 Release of Gontaminants during Drilling ln order to prevent the release of contaminants from drilling equipment it is recommended that the measures outlined in CIRIA C584 - Coastal and Marine Environmental Site Guide are implemented. The use of drip trays for the collection of spills/leaks from drilling equipment is also recommended. All refuelling of equipment and the barge should take place away from the waters edge where possible and all fuel should be stored in appropriately bunded containers.

Malone O'Regan 16 N atura lmpact Statement August 2011 Site Investigations for River Training Wall Port of Wateñord Company Belview Pont, Co. Watertord 6.0 Residual lmpacts and Gonclusions

6.1 Annex I Habitats No significant impacts on Annex I Habitats in either the River Barrow and River Nore SAC or the Lower River Suir SAC are anticipated.

6.2 Annex ll Species It is not anticipated that significant impacts are likely on the Annex ll Species of the Lower River Suir and the River Barrow and River Nore SAC. lt is however recommended that downtime is provided between drilling events to ensure that any fish species in the vicinity of the proposed site have an opportunity to pass. These rest periods will ensure that a balance is achieved between ecological and project requirements.

Malone O'Regan 17 Natura lmpact Statement August 2011 Site lnvestigations for River Training Wall Po¡7 of Watedord Company Belview Port, Co. Waterford 7.0 References

Aprahamian, M.W., Bagliniere J L., Sabatie M.R., Alexandr¡no P., Thiel R. and Aprahamian C.D (2003). Biology, status, and conservation of the anadramous Atlantic twait shad (Alosa fallax fallax. American Fisheries Symposium 35,103-124.

Aprahamian M.W., (1989) The diet of juvenile and adult twaite shad Alosa fallax fallax (Lacépède) from the rivers Severn and Wye (Britain). Hydrobiologia 179,173-182.

Carlson T.J., Hastings M., Popper N.A. (2007) Update on Recommendations for Reyrsed lnterim Sound Exposure Criteria for Fish during Pile Driving Activities. Retrieved from

Aquatic Services Unit (2011) Belview Port Oil Berth Natura lmpact Statement (NlS) - An Ecological lmpact Assessment to Support the Appropriate Assessment Process. University College Cork.

Aquatic Services Unit (2010) Grattan Quay, Bilberry Road and Quarry Road lmprovement Works - An Ecological lmpact Assessment to Support the Appropriate Assessment Process. University College Cork.

Bailey M., and Rochford J. (2006) Otter Survey of lreland 2004/2005. lrish Wildlife Manuals No. 23 National Parks and Wildlife Service, Department of Environment, Heritage and Local Government, Dublin, lreland. Biosphere Environmental Services (2010) Development at Belview Port - Natura lmpact Statement.

Hall J, et al., (1991) Measurements of underuvater sounds from a concrete island drilling structure located in the Alaskan sector of the Beaufort Sea. Acoustical. Soclefy of America.,5l, 51 5-517.

Joint Nature Conservation Committee (2007) Second Report by the UK under Añicle 17 on the implementation of the Habitats Directive from January 2001 to December 2006. Peterborough: JNCC. Retrieved from: www.jncc.qov.uldarticlel 7

King J.J., and Roche W.K. (2008). Aspects of anadromous Allis shad (Alosa alosa Linnaeus) and Twait shad (Alosa fallax Lacepede) biology in four lrish Special Areas of Conservation (CSACs): status, spawning indications and implications for conservation designation . Hydrobiologia 602, 145-154.

McCauley R. (1998) Radiated Unden¡vater Noise Measured from The Drilling Ocean Rig Ocean General, Rig Tenders, Pacific Ariki and Pacific Frontier, Fishing Vessel Reef Venture and Natural Sources in the Timor Sea, Northern Australia. Retrieved from:

Naval Oceans Systems Centre (1982) Possible Effects of Noise From Offshore Oil and Gas Drilling Activities on Marine Mammals: A Survey of the Literature. Retrieved from:

79

National Parks and Wildlife Service (2008) All-lreland Species Action Plan Killarney Fern. Retrieved from:

Malone O'Regan 18 N atura lmpact Statement August 2011 Site lnvestigations for River Training Wall Port of Wateúord Company Belview Port, Co. Watertord

Nedwell J., Howell D. (2004) A Review of Offshore Windfarm Related Underwater Noise Source. Collaborative Offshore Wind Energy Research into the Envirnoment (COWIE). Retrieved from: htto://citeseerx.ist.psu.edu/viewdoc/download?

O'Connor W., (2007) A Survey of Juvenile Lamprey Populations in the Corrib and Suir Catchments. lrish Wildlife Manuals No. 26. National Parks and Wìldlife Service, Department of Environment, Heritage and Local Government, Dublin, lreland.

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