ECOLOGICAL IMPACT ASSESSMENT
REPORT
FOR
STRATEGIC HOUSING DEVELOPMENT
AT
BRICKFIELD DRIVE, CRUMLIN, DUBLIN 12
April 2021
ON BEHALF OF
Durkan (Brickfield Drive) Ltd.
Prepared by Enviroguide Consulting Dublin Kerry www.enviroguide.ie 3D Core C, Block 71, The Plaza, 19 Henry Street [email protected] Park West, Dublin 12 Kenmare, Co. Kerry April+353 2021 1 565 4730 Page i
Enviroguide Consulting Strategic Housing Development Ecological Impact Assessment Report Brickfield Drive, Crumlin, Dublin 12
DOCUMENT CONTROL SHEET
Client Durkan (Brickfield Drive) Ltd.
Project Title Strategic Housing Development
Document Title Ecological Impact Assessment Report
Revision Status Author(s) Reviewed Approved Issue Date
Draft for Siobhan Atkinson Jim Dowdall 1.0 internal - - Ecologist Director Review
Draft for Siobhan Atkinson Jim Dowdall Jim Dowdall 2.0 21/08/2020 Client Ecologist Director Director
Draft for Siobhan Atkinson Liam Gaffney Colin Lennon 3.0 27/08/2020 Client Ecologist Ecologist Technical Director
Siobhan Atkinson Jim Dowdall Jim Dowdall 4.0 Final 03/09/2020 Ecologist Director Director
Draft for Siobhan Atkinson Jim Dowdall 5.0 internal - - Ecologist Director Review
Draft for Siobhan Atkinson Jim Dowdall Jim Dowdall 6.0 26/03/2021 Client Ecologist Director Director
Siobhan Atkinson Jim Dowdall Jim Dowdall 7.0 Final 21.04.2021 Ecologist Director Director
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Enviroguide Consulting Strategic Housing Development Ecological Impact Assessment Report Brickfield Drive, Crumlin, Dublin 12
TABLE OF CONTENTS
LIST OF TABLES ...... III LIST OF FIGURES ...... IV 1 INTRODUCTION ...... 1
1.1 QUALITY ASSURANCE AND COMPETENCE ...... 1 2 RELEVANT LEGISLATION ...... 3
2.1 NATIONAL LEGISLATION...... 3 2.1.1 Wildlife Act 1976 and amendments ...... 3 2.1.2 EU Habitats Directive 1992 and EC (Birds and Natural Habitats) Regulations 2011 ...... 3 2.1.3 Flora (Protection) Order, 2015 ...... 4 2.2 INTERNATIONAL LEGISLATION ...... 4 2.3.1 EU Birds Directive ...... 4 2.3.2 EU Habitats Directive ...... 4 2.3.3 Water Framework Directive ...... 4 2.3.4 Bern and Bonn Convention ...... 4 2.3.5 Ramsar Convention ...... 5 3 METHODOLOGY ...... 6
3.1 SCOPE OF ASSESSMENT ...... 6 3.2 DESK STUDY ...... 6 3.3 FIELD SURVEYS ...... 7 3.3.1 Bird Surveys ...... 7 3.3.2 Bat Surveys...... 7 3.3.3 Habitat Surveys ...... 7 3.3.4 Invasive Species Surveys ...... 7 3.4 CONSULTATION ...... 7 3.5 ASSESSMENT ...... 7 3.6 LIMITATIONS ...... 8 4 BASELINE ECOLOGICAL CONDITIONS ...... 9
4.1 SITE OVERVIEW ...... 9 4.1.1 Surface Water ...... 9 4.1.2 Geology and Hydrogeology ...... 9 4.2 DESIGNATED SITES ...... 10 4.3 HABITATS ...... 15 4.4 SPECIES AND SPECIES GROUPS ...... 19 4.4.1 Flora ...... 19 4.4.2 Mammals (excl. bats) ...... 23 4.4.3 Bats ...... 25 4.4.4 Birds ...... 27 4.4.5 Fish ...... 28 4.4.6 Amphibians ...... 30 4.4.7 Invertebrates ...... 30 4.4.8 Other species and species groups ...... 31 4.4.9 Designated sites, habitat and species evaluation ...... 31 5 DESCRIPTION OF THE PROPOSED DEVELOPMENT ...... 34
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Enviroguide Consulting Strategic Housing Development Ecological Impact Assessment Report Brickfield Drive, Crumlin, Dublin 12
5.1 LOCATION ...... 34 5.2 DESCRIPTION OF DEVELOPMENT ...... 34 5.3 LANDSCAPE SPECIFICATIONS ...... 37 5.3.1 Existing trees ...... 37 6 POTENTIAL IMPACTS OF THE PROPOSED DEVELOPMENT ...... 41
6.1 IMPACTS ON WATERBODIES ...... 41 6.1.1 Surface water ...... 41 6.1.2 Foul water from Ringsend WwTP ...... 41 6.2 IMPACTS ON HABITATS AND FLORA...... 41 6.3 IMPACTS ON FAUNA ...... 42 6.3.1 Mammals excl. bats ...... 42 6.3.2 Bats ...... 42 6.3.3 Birds ...... 42 6.4 DO NOTHING IMPACT ...... 43 6.5 CUMULATIVE IMPACTS ...... 43 6.5.1 Existing granted planning permissions ...... 43 6.5.2 Relevant policies and plans ...... 46 6.5.3 Operation of Ringsend WwTP ...... 46 7 MITIGATION AND ENHANCEMENT MEASURES ...... 48
7.1 DESIGNATED SITES ...... 48 7.2 WATERBODIES ...... 48 7.2.1 Surface water ...... 48 7.2.2 Groundwater ...... 49 7.3 HABITATS AND FLORA ...... 49 7.4 FAUNA ...... 50 7.4.1 Reduction of noise and dust related impacts ...... 50 7.4.2 Mammals excl. bats ...... 52 7.4.3 Bats ...... 53 7.4.4 Birds ...... 54 7.5 PLANTING OF NATIVE FLORA AND PROTECTING POLLINATORS ...... 56 7.6 INVASIVE SPECIES ...... 56 7.7 BIOSECURITY ...... 57 8 RESIDUAL IMPACTS ...... 58 9 CONCLUSION ...... 62 10 REFERENCES ...... 63 APPENDIX I – VALUE OF ECOLOGICAL RESOURCES ...... 67 APPENDIX II – EPA IMPACT ASSESSMENT CRITERIA ...... 69 APPENDIX III – BAT SURVEY REPORT (MAY 2020 & MARCH 2021) ...... 71
LIST OF TABLES
Table 1. Designated sites within the zone of influence (15km)...... 11 Table 2. Records of rare or protected flora for the surounding 10km (O13) grid square fom the NBDC...... 19
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Enviroguide Consulting Strategic Housing Development Ecological Impact Assessment Report Brickfield Drive, Crumlin, Dublin 12
Table 3. Invasive plant species within the 10km (O13), 2km (O13G) and 1km (O1332 and O1232) grid squares. The records are dated within the last 20 years and are provided by the NBDC...... 21 Table 4. Terrestrial mammal species within the 10km (O13), 2km (O13G) and 1km (O1332 and O1232 grid squares. The records are dated within the last 20 years and are provided by the NBDC...... 23 Table 5. Records of bats within the 10km (O13), 2km (O13G) and 1km (O1332 and 01232) grid squares and the habitat suitability index for each species in the locality. The records are dated within the last 20 years and are provided by the NBDC...... 25 Table 6. Bat results summary data- May 11th 2020 between 21.13 and 23.30...... 26 Table 7. RESULTS OF WINTER BIRD SURVEYS CARRIED OUT IN BRICKFIELD PARK. PEAK COUNTS OF QI SPECIES - LIGHT-BELLIED BRENT GEESE (PB) AND BLACKHEADED GULL (BH) - ARE SHOWN...... 27 Table 8. Bird species recorded at the Site of the Proposed Dvelopment on the 9th May 2020. Status' are based on Gilbert et al (2021)...... 28 Table 9. Records of fish species within the 10km (O13), 2km (O13G) and 1km (O1332 and O1232) grid squares. The records are dated within the last 20 years and are provided by the NBDC...... 29 Table 10. RECORDS OF amphibian SPECIES WITHIN THE 10KM (O13), 2KM (O13G) AND 1KM (O1332 AND O1232) GRID SQUARES. THE RECORDS ARE DATED WITHIN THE LAST 20 YEARS AND ARE PROVIDED BY THE NBDC...... 30 Table 11. Threatened invertebrate species listed as 'vulnerable', 'engangered' or ‘critically endangered' within the 10km (O13), 2km (O13G) and 1km (O1322 and O1232) grid squares. The records are dated within the last 20 years and are provided by the NBDC...... 30 Table 12. Evaluation of designated sites, habitats and fauna recorded within the surounding area. .. 32 Table 13. Summary of proposed planting at the Site of the Proposed Development. Details on the “pollinator friendly” status and whether the plants are native or non-native are provided...... 39 Table 14. Summary of potential impacts on KER(s), mitigation proposed and residual impacts...... 59
LIST OF FIGURES
Figure 1. Designated sites within 15km of the Proposed Development...... 14 Figure 2. Tree constraints plan by Arborists Associates, 2021...... 15 Figure 3. Discarded waste at the Site...... 16 Figure 4. Images of the Site showing (a) the amenity grassland area to the south, (b) the entrance to the Site with treelines to the right and left, and ornamental shrubs to the left, (c) the carpark bordered by ornamental shrubs and (d) buildings at the site...... 17 Figure 5. Habitats at the Site of the Proposed Development ...... 18 Figure 6. Mammal Trails within the area of amenity grassland to the south of the Site...... 23 Figure 7. Otter sign distribution on the surveyed reaches of the Camac and Poddle rivers as surveyed April 2018-April 2019 by Triturus Environmental Ltd. (adapted from Macklin et al., 2019)...... 25 Figure 8. Site Location ...... 36 Figure 9. Landscape proposal drawing of the Proposed Development showing the ground floor layout (Park Hood, April 2021)...... 38 Figure 10. Example of a Hedgehog Highway in a concrete wall and the signage available for it...... 52 Figure 11. total window surface area relative to the entire façade on all elevations (Provided by John Flemming Architects)...... 55
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Enviroguide Consulting Strategic Housing Development Ecological Impact Assessment Report Brickfield Drive, Crumlin, Dublin 12
1 INTRODUCTION
Enviroguide Consulting was commissioned by Durkan (Brickfield Drive) Ltd. to undertake an Ecological Impact Assessment for a proposed Strategic Housing Development at Brickfield Drive, Crumlin, Dublin 12.
This Ecological Impact Assessment (EcIA) assesses the potential effects of the Proposed Development at Brickfield Drive, Crumlin, Dublin 12 on habitats and species; particularly those protected by National and International legislation or considered to be of particular nature conservation importance. This report will describe the ecology of the Proposed Development area, with emphasis on habitats, flora and fauna, and will assess the potential effects of the Construction and Operational Phases of the Proposed Development on these ecological receptors. The report follows Guidelines for Ecological Impact Assessment in the UK and Ireland, by the Chartered Institute of Ecology and Environmental Management (CIEEM, 2018).
1.1 Quality assurance and competence Synergy Environmental Ltd., T/A Enviroguide Consulting, is wholly Irish Owned multi- disciplinary consultancy specialising in the areas of the Environment, Waste Management and Planning. All of our consultants carry scientific or engineering qualifications and have a wealth of experience working within the Environmental Consultancy sectors, having undergone extensive training and continued professional development.
Enviroguide Consulting as a company remains fully briefed in European and Irish environmental policy and legislation. Enviroguide staff members are highly qualified in their field. Professional memberships include the Chartered Institution of Wastes Management (CIWM), the Irish Environmental Law Association and Chartered Institute of Ecology and Environmental Management (CIEEM).
All surveying and reporting have been carried out by qualified and experienced ecologists and environmental consultants. Aisling Walsh, Professional Bat Ecologist with Ash Ecology and Environmental Ltd. undertook the on-site bat surveys. Eric Dempsey, Project Ecologist and Ornithologist with Enviroguide Consulting, undertook the biodiversity and bird surveys. Siobhán Atkinson, Ecologist with Enviroguide undertook the desktop research and habitat surveys for this report.
Siobhán has a B.Sc. (Hons) in Environmental Biology and a Ph.D. in Freshwater Biology from University College Dublin, and extensive experience in desktop research, literature review and reporting, as well as practical field and laboratory experience including environmental DNA analysis, freshwater macroinvertebrate sampling and identification, fish sampling and processing and habitat surveying. Siobhán has prepared Ecological Impact Assessments (EcIA), Stage I and Stage II Appropriate Assessment Reports, Habitat Surveys and Invasive Species Surveys and input and reviewed Ecological and Environmental assessments for several EIA Reports.
Eric Dempsey is an Environmental Consultant and Ornithologist who has worked on a wide range of conservation, research and ecological monitoring projects across Ireland. Eric is the author of the best-selling books, The Complete Field Guide to Ireland’s Birds and Finding Birds in Ireland and is experienced in coordinating and undertaking surveys along with being highly
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Enviroguide Consulting Strategic Housing Development Ecological Impact Assessment Report Brickfield Drive, Crumlin, Dublin 12 proficient in report writing and data management. Eric is very experienced with all survey methodology and has inputted in various Environmental Impact Assessment Reports, Environmental Assessments and Appropriate Assessments. Eric is currently part of the team of field ornithologists undertaking the long-term Dublin Bay Wetlands Survey.
Aisling Walsh is a Professional Ecologist and director of Ash Ecology Environmental Ltd. Aisling has a wealth of academic qualification having studied a MSc in Biodiversity and Conservation (TCD), A BSc (Hons) Zoology (NUIG), a Diploma in Applied Aquatic Sciences (GMIT), a Post Graduate Diploma in Statistics (TCD), and a Certificate in Environmental Noise (Institute of Acoustics); while also holding a full membership of the Chartered Institute of Ecology and Environmental Management (CIEEM). Aisling has written numerous Ecological Impact Assessments (EcIA), Screening for Appropriate Assessment Stage I and Stage II Natura Impact Statement, Environmental Impact Assessments/Statements, Badger Surveys, Bat Surveys, Habitat Surveys. She has also provided input and reviewed Ecological and Environmental assessments for several EIS and EIA Reports and conducted numerous noise surveys for EPA licensed facilities. AEE is listed as a Registered Practice by the CIEEM.
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Enviroguide Consulting Strategic Housing Development Ecological Impact Assessment Report Brickfield Drive, Crumlin, Dublin 12
2 RELEVANT LEGISLATION
An Ecological Impact Assessment (EcIA) is a process of identifying, quantifying, and evaluating potential effects of development-related or other actions on habitats, species and ecosystems (CIEEM, 2016). The Proposed Development at Brickfield Drive, Crumlin, Dublin 12 is a sub-threshold for an Environmental Impact Assessment (EIA) under the Planning and Development Regulations 2011-2018.
When an EcIA is undertaken as part of an EIA process it is subject to the EIA Regulations (under the EU Planning and Development [Environmental Impact Assessment] Regulations 2001-2018). An EcIA is not a statutory requirement, however it is a best practice evaluation process. This EcIA has been undertaken to support and assess the Proposed Development planning application and assesses the potential impacts that the Proposed Development may have on the ecology of the site and its environs. Where potential for a risk to the environment is identified, mitigation measures are proposed on the basis that by deploying these mitigation measures the risk is eliminated or reduced to an insignificant level. This EcIA is provided to assist An Bord Pleanala with its decision making in respect of the Proposed Development.
2.1 National Legislation
2.1.1 Wildlife Act 1976 and amendments The Wildlife Act 1976 was enacted to provide protection to birds, animals, and plants in Ireland and to control activities which may have an adverse impact on the conservation of wildlife. With regard to the listed species, it is an offence to disturb, injure or damage their breeding or resting place wherever these occur without an appropriate licence from the National Parks and Wildlife Service (NPWS). This list includes all wild birds along with their nests and eggs. Intentional destruction of an active nest from the building stage up until the chicks have fledged is an offence. This includes the cutting of hedgerows from the 1st of March to the 31st of August. The act also provides a mechanism to give statutory protection to Natural Heritage Areas (NHAs). The Wildlife Amendment Act 2000 widened the scope of the Act to include most species, including the majority of fish and aquatic invertebrate species which were excluded from the 1976 Act.
2.1.2 EU Habitats Directive 1992 and EC (Birds and Natural Habitats) Regulations 2011 The EU Directive on the Conservation of Natural Habitats and of Wild Fauna and Flora (Habitats Directive 1992) provides protection to particular species and habitats throughout Europe. The Habitats Directive has been transposed into Irish law through the EC (Birds and Natural Habitats) Regulations 2011.
Annex IV of the EU Habitats Directive provides protection to a number of listed species, wherever they occur. Under Regulation 23 of the Habitats Directive, any person who, in regards to the listed species, “Deliberately captures or kills any specimen of these species in the wild, deliberately disturbs these species particularly during the period of breeding, rearing, hibernation and migration, deliberately takes or destroys eggs from the wild or damages or destroys a breeding site or resting place of such an animal shall be guilty of an offence.”
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Enviroguide Consulting Strategic Housing Development Ecological Impact Assessment Report Brickfield Drive, Crumlin, Dublin 12
2.1.3 Flora (Protection) Order, 2015 The Flora (Protection) Order (S.I. No. 356/2015) affords protection to several species of plant in Ireland, including 68 vascular plants, 40 mosses, 25 liverworts, 1 stonewort and 1 lichen. This Act makes it illegal for anyone to uproot, cut or damage any of the listed plant species and it also forbids anyone from altering, interfering, or damaging their habitats. This protection is not confined to within designated conservation sites and applies wherever the plants are found.
2.2 International Legislation
2.3.1 EU Birds Directive The Birds Directive constitutes a level of general protection for all wild birds throughout the European Union. Annex I of the Birds Directive includes a total of 194 bird species that are considered rare, vulnerable to habitat changes or in danger of extinction within the European Union. Article 4 establishes that there should be a sustainable management of hunting of listed species, and that any large scale non-selective killing of birds must be outlawed. The Directive requires the designation of Special Protection Areas (SPAs) for: listed and rare species, regularly occurring migratory species and for wetlands which attract large numbers of birds. There are 25 Annex I species that regularly occur in Ireland and a total of 153 Special Protection Areas have been designated.
2.3.2 EU Habitats Directive The Habitats Directive aims to protect some 220 habitats and approximately 1000 species throughout Europe. The habitats and species are listed in the Directives annexes, where Annex I covers habitats and Annex II, IV and V cover species. There are 59 Annex I habitats in Ireland and 33 Annex IV species which require strict protection wherever they occur. The Directive requires the designation of Special Areas of Conservation for areas of habitat deemed to be of European interest. The SACs together with the SPAs from the Birds Directive form a network of protected sites called Natura 2000.
2.3.3 Water Framework Directive The EU Water Framework Directive (WFD) 2000/60/EC is an important piece of environmental legislation which aims to protect and improve water quality. It applies to rivers, lakes, groundwater, estuaries, and coastal waters. The Water Framework Directive was agreed by all individual EU member states in 2000, and its first cycle ran from 2009 – 2015. The Directive runs in 6-year cycles, so the second (current) cycle runs from 2016 – 2021.The aim of the WFD is to prevent any deterioration in the existing status of water quality, including the protection of good and high water quality status where it exists. The WFD requires member states to manage their water resources on an integrated basis to achieve at least ‘good’ ecological status, through River Basin Management Plans (RBMP), by 2027.
2.3.4 Bern and Bonn Convention The Convention on the Conservation of European Wildlife and Natural Habitats (Bern Convention 1982) was enacted to conserve all species and their habitats. The Convention on the Conservation of Migratory Species of Wild Animals (Bonn Convention 1979, enacted 1983) was introduced to give protection to migratory species across borders in Europe.
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Enviroguide Consulting Strategic Housing Development Ecological Impact Assessment Report Brickfield Drive, Crumlin, Dublin 12
2.3.5 Ramsar Convention The Ramsar Convention on Wetlands is an intergovernmental treaty signed in Ramsar, Iran, in 1971. The treaty is a commitment for national action and international cooperation for the conservation of wetlands and their resources. In Ireland there are currently 45 Ramsar sites which cover a total area of 66,994 Ha.
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Enviroguide Consulting Strategic Housing Development Ecological Impact Assessment Report Brickfield Drive, Crumlin, Dublin 12
3 METHODOLOGY
This section details the steps and methodology employed to undertake an Ecological Impact Assessment of the Proposed Development.
3.1 Scope of Assessment The specific objectives of the study were to:
• Undertake baseline ecological surveys and evaluate the nature conservation importance of the Site of the Proposed Development; • Identify and assess the direct, indirect, and cumulative ecological implications or impacts of the Proposed Development during its lifetime; and • Where possible, propose mitigation measures to remove or reduce those impacts at the appropriate stage of development.
3.2 Desk Study A desktop study was carried out to collate and review available information, datasets and documentation sources pertaining to the site’s natural environment. The desktop study relied on the following sources:
- Information on species records and distributions, obtained from the National Biodiversity Data Centre (NBDC) at www.maps.biodiversityireland.ie ; - Information on waterbodies, catchment areas and hydrological connections obtained from the Environmental Protection Agency (EPA) at www.gis.epa.ie ; - Information on bedrock, groundwater, aquifers and their statuses, obtained from Geological Survey Ireland (GSI) at www.gsi.ie ; - Information on the network of designated conservation sites, boundaries, qualifying interests and conservation objectives, obtained from the National Parks and Wildlife Service (NPWS) at www.npws.ie ; - Satellite imagery and mapping obtained from various sources and dates including Google, Digital Globe, Bing and Ordnance Survey Ireland; - Information on the existence of permitted developments, or developments awaiting decision, in the vicinity of the Proposed Development from Dublin City Council available at: http://www.dublincity.ie/main-menu-services-planning/planning-search - Information on the extent, nature and location of the Proposed Development, provided by the applicant and/or their design team; - The conservation status of birds in Ireland taken from Gilbert et al. (2021). - The list of pollinator friendly plants provided by The Royal Horticultural Society (RHS) website available at https://www.rhs.org.uk/ - The pollinator friendly planting code provided by The All-Ireland Pollinator Plan (2015- 2020) available at www.pollinators.ie - The Dublin City Development Plan 2016–2022 - The Dublin City Biodiversity Action Plan 2015-2020
A comprehensive list of all the specific documents and information sources consulted in the completion of this document is provided in Section 10, References.
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Enviroguide Consulting Strategic Housing Development Ecological Impact Assessment Report Brickfield Drive, Crumlin, Dublin 12
3.3 Field surveys
3.3.1 Bird Surveys Breeding bird and ecological surveys were undertaken by Enviroguide Senior Ecologist Eric Dempsey at the Site on 19th May 2020.
Data from previous bird surveys carried out by Benson (2008/09), Enviroguide Consulting (2018/19; 2019/20 and 2020/21) and Scott Cawley Ltd. (2016/17) were used to determine the potential impact of the Proposed Development on Light-Bellied Brent Geese Branta bernicla hrota, which is a species of Special Conservation Interest in South Dublin Bay and River Tolka Estuary SPA, North Bull Island SPA and Baldoyle Bay SPA. There is a possibility that Light- Bellied Brent Geese may utilise Brickfield Park, which is adjacent to the Site of the Proposed Development, as ex-situ feeding habitat.
3.3.2 Bat Surveys Bat surveys of the Site of the Proposed Development were undertaken by Ash Ecology & Environmental Ltd (AEE) on the 11th of May 2020 and the 15th March 2021. A desk study, bat activity survey, bat potential tree survey, buildings surveys and landscape evaluation were also undertaken. Each of the 20 no. trees which have been identified for felling was surveyed on 15th March 2021 to determine the presence of Potential Roost Features. Details of the bat surveys can be found in the Bat Survey Reports in Appendix III.
3.3.3 Habitat Surveys A habitat survey was undertaken on the 22nd July 2020. Habitats were identified and classified according to Fossitt (2000) and Smith et al. (2011).
3.3.4 Invasive Species Surveys The Site was assessed for the presence of invasive plant species during the breeding bird and ecological surveys undertaken at the Site on 19th May 2020 and the habitat surveys undertaken on the 22nd July 2020.
3.4 Consultation No consultation was undertaken as part of this Ecological Impact Assessment.
3.5 Assessment The value of the ecological resources, i.e. the habitats and species present or potentially present, was determined using the ecological evaluation guidance given in the National Roads Authority’s Ecological Assessment Guidelines (NRA, 2009a), presented in Appendix I. This evaluation scheme, with values ranging from locally important to internationally important, seeks to provide value ratings for habitats and species present that are considered ecological receptors of impacts that may ensue from a proposal. As per the NRA guidelines, impact assessment is only undertaken of key ecological receptors (KERs).
The assessment of the potential effect or impact of the Proposed Development on the identified key ecological receptors was carried out with regard to the criteria outlined in the draft EPA Guideline (EPA, 2017), presented in Appendix II. These guidelines set out a number of parameters such as quality, magnitude, extent and duration that should be considered when
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Enviroguide Consulting Strategic Housing Development Ecological Impact Assessment Report Brickfield Drive, Crumlin, Dublin 12 determining which elements of the Proposed Development could constitute impact or sources of impacts.
3.6 Limitations An extensive search of available datasets for records of rare and protected species within proximity of the Proposed Development has been undertaken as part of this assessment. However, the records from these datasets do not constitute a complete species list. The absence of species from these datasets does not necessarily confirm an absence of species in the area.
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Enviroguide Consulting Strategic Housing Development Ecological Impact Assessment Report Brickfield Drive, Crumlin, Dublin 12
4 BASELINE ECOLOGICAL CONDITIONS
4.1 Site Overview The Site of the Proposed Development is located on the west side of Brickfield Drive in Crumlin, Dublin 12. The Site is adjacent to Brickfield Park, Sunshine Industrial Estate and Crumlin College of Further Education. It is located on the former Dolphin’s Barn Brick and Tile Company Ltd. (1900-1942). The brick manufactured here was made from clay obtained from clay pits adjacent to the Site of the Proposed Development at the Iveagh Grounds (now Brickfield Park) (Roundtree, 2007).
4.1.1 Surface Water The Site of the Proposed Development is within the Liffey and Dublin Bay catchment and Liffey_SC_090 subcatchment. There are no river waterbodies within the Site of the Proposed Development. The closest river waterbodies are the Camac and Poddle rivers.
The River Camac is located c.1.1km to the north of the Site of the Proposed Development and is within the Liffey_SC_090 subcatchment. The River Camac flows in a north-east direction before discharging into the Upper Liffey Estuary (Figure 8). The River Camac was assigned Poor water quality status (assessment was made in 2019) and is considered At Risk of not achieving its Water Framework Directive status objectives.
The Poddle is located c.1.4km to the south-east of the Site of the Proposed Development and is within the Dodder_SC_01 subcatchment (note that this is a separate subcatchment to the Site of Proposed Development). It flows in a north-east direction before discharging into the Upper Liffey Estuary (Figure 8). The River Poddle was assigned Poor water quality status (assessment was made in 2007) and is considered At Risk of not achieving its Water Framework Directive status objectives. The Poddle is culverted for most of its length within Dublin city.
The status of the Upper Liffey Estuary is classed as Good.
The Grand Canal is located c.473 metres to the north-east of the Site of the Proposed Development. Canals are required to achieve good ecological potential rather than good ecological status because they are artificial water bodies. The Grand Canal achieved good ecological potential during the 2013-2018 Water Framework Directive reporting period (O’Boyle et al. 2019).
4.1.2 Geology and Hydrogeology The Site of the Proposed Development is situated on the Dublin groundwater body, which is Not At Risk of not meeting its WFD objectives. The aquifer type in the area is Locally Important (LI) on bedrock which is moderately productive in local zones only. The groundwater rock units underlying the aquifer are classified as Dinantian Upper Impure Limestones. The level of vulnerability to groundwater contamination from human activities ranges from High in the southern and western sections to Extreme (E) in the middle sections to Extreme (X – rock at or near the surface) in the northern corner. The majority of the subsoil is made ground (Made), with a section of bedrock at the surface (Rck) which overlaps with the Extreme (X) groundwater vulnerability area in the northern corner. In addition, there is a small area of limestone till
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Enviroguide Consulting Strategic Housing Development Ecological Impact Assessment Report Brickfield Drive, Crumlin, Dublin 12
(Carboniferous) (TLs) at the north-western corner of the Site of the Proposed Development. The soil is classed as urban.
4.2 Designated Sites The Habitats Directive (92/43/EEC) seeks to conserve natural habitats and wild fauna and flora by the designation of Special Areas of Conservation (SACs) and the Birds Directive (2009/147/EC) seeks to protect birds of special importance by the designation of Special Protection Areas (SPAs). It is the responsibility of each member state to designate SPAs and SACs, both of which will form part of Natura 2000, a network of protected sites throughout the European Community. SACs are selected for the conservation of Annex I habitats (including priority types which are in danger of disappearance) and Annex II species (other than birds). SPAs are selected for the conservation of Annex I birds and other regularly occurring migratory birds and their habitats. The annexed habitats and species for which each site is selected correspond to the qualifying interests of the sites; from these the conservation objectives of the site are derived.
National Heritage Areas (NHAs) are designations under the Wildlife Acts to protect habitats, species, or geology of national importance. The boundaries of many of the NHAs in Ireland overlap with SAC and/or SPA sites. Although many NHA designations are not yet fully in force under this legislation (referred to as ‘proposed NHAs’ or pNHAs), they are offered protection in the meantime under planning policy which normally requires that planning authorities give recognition to their ecological value.
Table 1 below presents details of the key ecological features of the designated sites within a 15km radius of the Proposed Development. In addition, the potential for connectivity with designated sites at distances of greater than 15km from the Development was also considered in this initial assessment. In this case, there is no potential connectivity between the Development site and designated sites located at a distance greater than 15km from the Proposed Development.
The result of this preliminary screening concluded that there is a total of nine SACs, four SPAs and 23 pNHAs located within the Zone Of Influence of the Proposed Development Site. The distances to each site listed are taken from the nearest possible point of the Proposed Development Site boundary to nearest possible point of each Natura 2000 site or pNHA. In addition, Dublin Bay is designated as a UNESCO Biosphere1. Dublin Bay Biosphere contains three different zones, which are managed in different ways:
• The core zone of Dublin Bay Biosphere comprises 50km² of areas of high natural value. Key areas include the Tolka and Baldoyle Estuaries, Booterstown Marsh, Howth Head, North Bull Island, Dalkey Island and Ireland’s Eye.
• The buffer zone comprises 82km² of public and private green spaces such as parks, greenbelts and golf courses, which surround and adjoin the core zones.
• The transition zone comprises 173km² and forms the outer part of the Biosphere. It includes residential areas, harbours, ports and industrial and commercial areas.
1 A biosphere is a special designation awarded by the United Nations Educational, Scientific and Cultural Organisation (UNESCO) but managed in partnership by communities, NGOs and local and national governments (https://www.dublinbaybiosphere.ie/).
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Enviroguide Consulting Strategic Housing Development Ecological Impact Assessment Report Brickfield Drive, Crumlin, Dublin 12
TABLE 1. DESIGNATED SITES WITHIN THE ZONE OF INFLUENCE (15KM).
Site Distance Site Name Reasons for Designation ( *= priority habitats) Code to Site
Special Areas of Conservation (SAC)
Annex I Habitats: [1140] Tidal Mudflats and Sandflats South Dublin 000210 [1210] Annual vegetation of drift lines 6.0 km Bay SAC [1310] Salicornia and other annuals colonising mud and sand [2110] Embryonic shifting dunes
Annex I Habitats: [1140] Tidal Mudflats and Sandflats [1210] Annual Vegetation of Drift Lines [1310] Salicornia Mud [1330] Atlantic Salt Meadows North Dublin 000206 [1410] Mediterranean Salt Meadows 8.75 km Bay SAC [2110] Embryonic Shifting Dunes [2120] Marram Dunes (White Dunes) [2130] Fixed Dunes (Grey Dunes)* [2190] Humid Dune Slacks Annex II Species: [1395] Petalwort Petalophyllum ralfsii
Annex I Habitats: Glenasmole 001209 [6210] Orchid-rich Calcareous Grassland* 8.95 km Valley SAC [6410] Molinia Meadows [7220] Petrifying Springs* Annex I Habitats: [3110] Oligotrophic Waters containing very few minerals [3160] Dystrophic Lakes [4010] Wet Heath [4030] Dry Heath [4060] Alpine and Subalpine Heaths Wicklow [6130] Calaminarian Grassland 002122 Mountains [6230] Species-rich Nardus Grassland* 10.14 km SAC [7130] Blanket Bogs (Active)* [8110] Siliceous Scree [8210] Calcareous Rocky Slopes [8220] Siliceous Rocky Slopes [91A0] Old Oak Woodlands Annex II Species: [1355] Otter Lutra lutra Annex I Habitats: Rye Water [7220] Petrifying Springs* 001398 Valley/Carton Annex II Species: 12.75 km SAC [1014] Narrow-mouthed Whorl Snail Vertigo angustior [1016] Desmoulin's Whorl Snail Vertigo moulinsiana Annex I Habitats: [1140] Tidal Mudflats and Sandflats Baldoyle Bay 000199 [1310] Salicornia Mud 13.68 km SAC [1330] Atlantic Salt Meadows [1410] Mediterranean Salt Meadows
Rockabill to Annex I Habitats: 003000 Dalkey Island [1170] Reefs 14.23 km Annex II Species: SAC [1351] Harbour Porpoise Phocoena phocoena Knocksink 000725 Annex I Habitats: 14.40 km Wood SAC [7220] Petrifying Springs*
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Site Distance Site Name Reasons for Designation ( *= priority habitats) Code to Site [91A0] Old sessile oak woods with Ilex and Blechnum in the British Isles [91E0] Alluvial Forests*
Howth Head Annex I Habitats: 000202 [1230] Vegetated Sea Cliffs 14.43 km SAC [4030] Dry Heath
Special Protected Area (SPA)
Special Conservation Interest Species: [A046] Light-bellied Brent Goose Branta bernicla hrota [A130] Oystercatcher Haematopus ostralegus [A137] Ringed Plover Charadrius hiaticula [A141] Grey Plover Pluvialis squatarola South Dublin [A143] Knot Calidris canutus Bay and River [A144] Sanderling Calidris alba 004024 [A149] Dunlin Calidris alpina alpina 5.86 km Tolka Estuary [A157] Bar-tailed Godwit Limosa lapponica SPA [A162] Redshank Tringa totanus [A179] Black-headed Gull Chroicocephalus ridibundus [A192] Roseate Tern Sterna dougallii [A193] Common Tern Sterna hirundo [A194] Arctic Tern Sterna paradisaea [A999] Wetlands Special Conservation Interest Species: [A046] Light-bellied Brent Goose Branta bernicla hrota [A048] Shelduck Tadorna tadorna [A052] Teal Anas crecca [A054] Pintail Anas acuta [A056] Shoveler Anas clypeata [A130] Oystercatcher Haematopus ostralegus [A140] Golden Plover Pluvialis apricaria North Bull [A141] Grey Plover Pluvialis squatarola 004006 [A143] Knot Calidris canutus 8.73 km Island SPA [A144] Sanderling Calidris alba [A149] Dunlin Calidris alpina alpina [A156] Black-tailed Godwit Limosa limosa [A157] Bar-tailed Godwit Limosa lapponica [A160] Curlew Numenius arquata [A162] Redshank Tringa totanus [A169] Turnstone Arenaria interpres [A179] Black-headed Gull Chroicocephalus ridibundus [A999] Wetlands
Wicklow Special Conservation Interest Species: 004040 Mountains [A098] Merlin Falco columbarius 10.18 km SPA [A103] Peregrine Falco peregrinus
Special Conservation Interest Species: [A046] Light-bellied Brent Goose Branta bernicla hrota [A048] Shelduck Tadorna tadorna Baldoyle Bay 004016 [A137] Ringed Plover Charadrius hiaticula 13.95 km SPA [A140] Golden Plover Pluvialis apricaria [A141] Grey Plover Pluvialis squatarola [A157] Bar-tailed Godwit Limosa lapponica [A999] Wetlands
Natural Heritage Areas
There are no NHAs within 15km of the Proposed Development
proposed Natural Heritage Areas
002104 Grand Canal 0.46km
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Site Distance Site Name Reasons for Designation ( *= priority habitats) Code to Site
000128 Liffey Valley 3.96km
002103 Royal Canal 4.18km
00991 Dodder Valley 4.86km
North Dublin 000206 5.56km Bay
South Dublin 000210 5.99km Bay
Booterstown 001205 7.14km Marsh
Dolphins, 000201 7.20km Dublin Docks
Fitzsimon’s 001753 8.08km Wood
Santry 000178 8.34km Demesne
Glenasmole 001209 8.95km Valley
001212 Lugmore Glen 9.41km
Slade of There are no formal qualifying interests listed for proposed Natural Saggart and 000211 Heritage Areas. A general site synopsis is available for most sites on 11.83km Crooksling the NPWS website. Glen
Dalkey Coastal Zone 001206 12.34km and Killiney Hill Rye Water 001398 12.75km Valley/ Carton
001207 Dingle Glen 12.75km
Ballybetagh 001202 13.33km Bog
001208 Feltrim Hill 13.62km
000199 Baldoyle Bay 13.68km
000202 Howth Head 14.26km
Sluice River 001763 14.34km Marsh
Knocksink 000725 14.39km Wood
Loughlinstown 001211 14.61km Woods
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FIGURE 1. DESIGNATED SITES WITHIN 15KM OF THE PROPOSED DEVELOPMENT.
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4.3 Habitats The majority of the habitat on the Site is comprised of Buildings and Artificial Surfaces (BL3) between the existing buildings and the carpark and access roads around the Site. An area of Amenity Grassland (GA2) occurs to the south of the Site. Species recorded here include Cock’s foot Dactylis glomerata, False Oat-grass Arrhenatherum elatius, Yorkshire Fog Holcus lanatus, Creeping Cinquefoil Potentilla reptans, Clover and Trefoil species Trifolium spp.,Vetch Vica sp., Ribwort Plantain Plantago lanceolata, Dock Rumex spp., Creeping Buttercup Ranunculus repens and Dandelion Taraxacum spp.
Treelines (WL2) and ornamental/non-native shrub (WS3) occur along the northern boundary of Site. The trees within this treeline are all category C trees (trees of low quality/value with a minimum of 10 years life expectancy). A treeline also occurs along the southern boundary of the Site as well as the western boundary of the amenity grassland area (Figure 2; Figure 5). Here again, all the trees are comprised of category C trees, apart from a single category U tree (trees in such a condition that any existing value would be lost within 10 years or being recommended for removal by sound arboricultural practice.) The remainder of the Site is either bounded by walls or ornamental/non-native shrub (WS3). As well as various ornamental shrubs, the invasive Butterfly bush Buddleja davidii and Sycamore samplings Acer pseudoplatanus occur within the ornamental/non-native shrub habitat, as well as Ivy Hedera helix and Elder Sambucus nigra. A considerable treeline occurs within Brickfield Park, immediately adjacent to the northern boundary of the Site and within the playing pitches immediately west of the Site (Figure 2).
FIGURE 2. TREE CONSTRAINTS PLAN BY ARBORISTS ASSOCIATES, 2021.
A small area of scrub (WS1) dominated by Butterfly bush, Sycamore and Ash Fraxinus excelsior samplings and Bramble R. fruticosus occurs to the east of the Site. Adjacent to this habitat is an area comprised of a mosaic of recolonising bare ground (ED3) and ornamental/non-native shrub (WS3). Species in this habitat include Ragwort Senecio spp.,
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Pineapple-weed Matricaria discoidea, Biting Stonecrop Sedum acre, White Stonecrop Sedum album, Rosebay Willowherb Chamerion angustifolium, Herb Robert Geranuim robertianum, Broadleaf Plantain Plantago major and Butterfly Bush.
General waste and rubbish are scattered throughout the Site, in particularly within the western areas (Figure 3).
FIGURE 3. DISCARDED WASTE AT THE SITE.
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FIGURE 4. IMAGES OF THE SITE SHOWING (A) THE AMENITY GRASSLAND AREA TO THE SOUTH, (B) THE ENTRANCE TO THE SITE WITH TREELINES TO THE RIGHT AND LEFT, AND ORNAMENTAL SHRUBS TO THE LEFT, (C) THE CARPARK BORDERED BY ORNAMENTAL SHRUBS AND (D) BUILDINGS AT THE SITE.
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FIGURE 5. HABITATS AT THE SITE OF THE PROPOSED DEVELOPMENT
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4.4 Species and species groups The Site of the Proposed Development is located within the Ordnance Survey Ireland National Grid 10km square O13, 2km square 013G and 1km squares O1232 and O1332. Species records from the National Biodiversity Data Centre (NBDC) online database for these grid squares were studied for the presence of rare or protected flora and fauna. In addition, data from various sources (e.g. Inland Fisheries Ireland) were used to determine the presence of species in the vicinity of the Proposed Development. The following sections (4.4.1 to 4.4.8) outline the results of this assessment.
4.4.1 Flora
4.4.1.1 Rare and Protected Flora Species records from the NBDC online database were studied for the presence of rare of protected flora species. Table 2 presents details of the rare and protected flora species found within the relevant grid squares pertaining to the Site of the Proposed Development. No rare or protected flora were recorded at the Site.
TABLE 2. RECORDS OF RARE OR PROTECTED FLORA FOR THE SUROUNDING 10KM (O13) GRID SQUARE FOM THE NBDC.
Name Species Grid Date of last Database Designation Group square record Betony Stachys officinalis Flowering O13 18/05/2012 Ireland's - Flora Protection Order plant BioBlitz (2015) - Near Threatened Dittander Lepidium latifolium Flowering O13 31/12/2000 Irish Crop Wild - Vulnerable plant Relative Database Great Burnet Sanguisorba Flowering O13 30/09/2016 Ireland's - Flora Protection Order officinalis plant BioBlitz (2015) - Vulnerable Hairy St. John’s Wort Flowering O13 23/07/2020 Aras an - Vulnerable Hypercium hirsutum plant Uachtaráin Biodiveristy Audit 2019- 2020 Hairy violet Viola hirta Flowering O13 18/05/2012 Ireland's - Flora Protection Order plant BioBlitz (2015) - Order - Vulnerable Meadow Barley Hordeum Flowering O13 31/12/2007 Irish Crop Wild - Flora Protection Order secalinum plant Relative (2015) Database - Vulnerable Meadow Crane's-bill Flowering O13 30/09/2016 Ireland's - Vulnerable Geranium pratense plant BioBlitz Purple Spurge Euphorbia Flowering O13 30/09/2016 Ireland's - Regionally Extinct peplis plant BioBlitz Small Cudweed Filago Flowering O13 12/07/2012 Online Atlas of - Flora Protection Order minima plant Vascular (2015) Plants 2012- - Near Threatened 2020 Blunt-fruited Pottia Tortula Moss O13 29/01/2011 Bryophytes of - Threatened Species: modica Ireland Vulnerable
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4.4.1.2 Invasive Plant Species The NBDC have records (dated within the last 20 years) of 30 invasive plant species within the 10km (O13) grid square. Seventeen of these are medium impact, whereas twelve are considered to be high impact. The Spanish Bluebell Hyacinthoides hispanica does not have an impact designation. The high impact Japanese knotweed Fallopia japonica was recorded in all grid squares (10km, 2km and 1km) related to the Site.
Some invasive plant species were recorded at the Site including Butterfly Bush Buddleja davidii and Sycamore Acer pseudoplatanus.
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TABLE 3. INVASIVE PLANT SPECIES WITHIN THE 10KM (O13), 2KM (O13G) AND 1KM (O1332 AND O1232) GRID SQUARES. THE RECORDS ARE DATED WITHIN THE LAST 20 YEARS AND ARE PROVIDED BY THE NBDC.
Name Grid Date of last Database Legal status / Designaion square record American Skunk-cabbage (Lysichiton americanus) O13 29/03/2019 Online Atlas of Vascular Plants 2012-2020 - Medium Impact Invasive Species - EU Regulation No. 1143/2014 - Regulation S.I. 477 (Ireland) Brazilian Giant-rhubarb (Gunnera manicata) O13 29/03/2019 Online Atlas of Vascular Plants 2012-2020 - Medium Impact Invasive Species - Regulation S.I. 477 (Ireland) Butterfly-bush (Buddleja davidii) O13 13/08/2020 Online Atlas of Vascular Plants 2012-2020 - Medium Impact Invasive Species O13G 19/04/2020 Canadian Fleabane (Conyza canadensis) O13 26/10/2020 Online Atlas of Vascular Plants 2012-2020 - Medium Impact Invasive Species Canadian Waterweed (Elodea canadensis) O13 08/07/2020 Ireland's BioBlitz; - High Impact Invasive O13G 31/07/2009 National Invasive Species Database - Regulation S.I. 477 (Ireland) O1332 31/07/2018 Cherry Laurel (Prunus laurocerasus) O13 14/07/2020 Online Atlas of Vascular Plants 2012-2020 - High Impact Invasive Species Common Broomrape (Orobanche minor) O13 24/06/2020 Online Atlas of Vascular Plants 2012-2020 - Medium Impact Invasive Species Evergreen Oak (Quercus ilex) O13 01/06/2020 Online Atlas of Vascular Plants 2012-2020 - Medium Impact Invasive Species Fallopia japonica x sachalinensis = F. x bohemica O13 17/06/2015 National Invasive Species Database - High Impact Invasive O13G 31/07/2009 - Regulation S.I. 477 (Ireland) Giant Hogweed (Heracleum mantegazzianum) O13 21/06/2020 Online Atlas of Vascular Plants 2012-2020 - High Impact Invasive Species - Regulation S.I. 477 (Ireland) Giant Knotweed (Fallopia sachalinensis) O13 03/08/2017 Online Atlas of Vascular Plants 2012-2020 - High Impact Invasive Species - Regulation S.I. 477 (Ireland) Giant-rhubarb (Gunnera tinctoria) O13 28/06/2020 National Invasive Species Database - High Impact Invasive - Regulation S.I. 477 (Ireland) Himalayan Honeysuckle (Leycesteria formosa) O13 24/07/2020 Online Atlas of Vascular Plants 2012-2020 - Medium Impact Invasive Species Indian Balsam (Impatiens glandulifera) O13 06/08/2020 Online Atlas of Vascular Plants 2012-2020; - High Impact Invasive Species O13G 31/07/2009 National Invasive Species Database - Regulation S.I. 477 (Ireland) Japanese Knotweed (Fallopia japonica) O13 09/08/2020 Online Atlas of Vascular Plants 2012-2020 - High Impact Invasive Species O13G 05/10/2018 - Regulation S.I. 477 (Ireland) O1232 05/10/2018 28/09/2018 O1332 Japanese Rose (Rosa rugosa) O13 19/05/2018 Online Atlas of Vascular Plants 2012-2020 - Medium Impact Invasive Species Narrow-leaved Ragwort (Senecio inaequidens) O13 09/08/2020 Online Atlas of Vascular Plants 2012-2020 - Medium Impact Invasive Species O13G 09/08/2020 New Zealand Pigmyweed (Crassula helmsii) O13 31/07/2009 National Invasive Species Database - High Impact Invasive Species 31/07/2009 - Regulation S.I. 477 (Ireland)
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Name Grid Date of last Database Legal status / Designaion square record O13G 31/07/2009 O1332 Nuttall's Waterweed (Elodea nuttallii) O13 22/07/2019 Online Atlas of Vascular Plants 2012-2020; - High Impact Invasive Species O13G 31/07/2009 National Invasive Species Database - Regulation S.I. 477 (Ireland) O1332 31/07/2009 Pampas-grass (Cortaderia selloana) O13 15/01/2019 Online Atlas of Vascular Plants 2012-2020 - Medium Impact Invasive Species Parrot's-feather (Myriophyllum aquaticum) O13 31/07/2009 National Invasive Species Database - High Impact Invasive O13G 31/07/2009 - EU Regulation No. 1143/2014 - Regulation S.I. 477 (Ireland) Rhododendron ponticum O13 17/06/2004 Species Data from the National Vegetation - High Impact Invasive Species O13G 17/06/2004 Database - Regulation S.I. 477 (Ireland) Sea-buckthorn (Hippophae rhamnoides) O13 20/08/2019 Online Atlas of Vascular Plants 2012-2020 - Medium Impact Invasive Species - Regulation S.I. 477 (Ireland) Spanish Bluebell (Hyacinthoides hispanica) O13 06/05/2018 Online Atlas of Vascular Plants 2012-2020 - Regulation S.I. 477 (Ireland) Sycamore (Acer pseudoplatanus) O13 14/07/2020 Online Atlas of Vascular Plants 2012-2020; - Medium Impact Invasive Species O13G 28/10/2008 River Biologists' Database (EPA) Three-cornered Garlic (Allium triquetrum) O13 22/04/2020 Online Atlas of Vascular Plants 2012-2020 - Medium Impact Invasive Species - Regulation S.I. 477 (Ireland) Traveller's-joy (Clematis vitalba) O13 10/07/2020 Online Atlas of Vascular Plants 2012-2020 - Medium Impact Invasive Species Tree-of-heaven (Ailanthus altissima) O13 25/10/2009 Heritage Trees of Ireland - Medium Impact Invasive Species Turkey Oak (Quercus cerris) O13 09/05/2019 Online Atlas of Vascular Plants 2012-2020 - Medium Impact Invasive Species Wild Parsnip (Pastinaca sativa) O13 03/08/2020 Online Atlas of Vascular Plants 2012-2020 - Medium Impact Invasive Species
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4.4.2 Mammals (excl. bats) A single Grey Squirrel Sciurus carolinensis was recorded during the May 2020 field survey. Furthermore, a Red Fox Vulpes vulpes was observed in the scrub habitat to the west of the Site during the survey carried out in July 2020. The grassy area to the south of the Site showed trails and resting areas consistent with the presence of Red Fox but no fur or scat was found. The Site may also attract Hedgehogs Erinaceus europaeus.
FIGURE 6. MAMMAL TRAILS WITHIN THE AREA OF AMENITY GRASSLAND TO THE SOUTH OF THE SITE.
Records for terrestrial mammals were retrieved from the NBDC online database. Table 4 lists these species, their last record date and summarises their legal status/designation. Nine native terrestrial mammals were recorded within the 10km grid square (O13), seven of which are afforded protection under the Wildlife (Amendment) Act, 2000. Eight non-native terrestrial mammals were recorded within the 10km grid square, six of which are considered ‘High Impact’.
TABLE 4. TERRESTRIAL MAMMAL SPECIES WITHIN THE 10KM (O13), 2KM (O13G) AND 1KM (O1332 AND O1232 GRID SQUARES. THE RECORDS ARE DATED WITHIN THE LAST 20 YEARS AND ARE PROVIDED BY THE NBDC.
Name Grid Date of last Database Legal Status / Designation square record NATIVE SPECIES Eurasian Badger (Meles meles) O13 01/09/2020 Aras an Uachtaráin - Wildlife (Amendment) Act, 2000 Biodiversity Audit 2019-2020
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Name Grid Date of last Database Legal Status / Designation square record Eurasian Pygmy Shrew (Sorex O13 01/09/2020 Aras an Uachtaráin - Wildlife (Amendment) Act, 2000 minutus) Biodiversity Audit 2019-2020 Eurasian Red Squirrel (Sciurus O13 02/08/2017 Mammals of Ireland - Wildlife (Amendment) Act, 2000 vulgaris) 2016-2025 European Otter (Lutra lutra) O13 16/07/2018 Mammals of Ireland - EU Habitats Directive O13G 12/02/2016 2016-2025; Atlas of [92/43/EEC] Annex II & IV O1332 10/08/2014 Mammals in Ireland - Wildlife (Amendment) Act, 2000 2010-2015 West European Hedgehog O13 10/09/2015 Atlas of Mammals in - Wildlife (Amendment) Act, 2000 (Erinaceus europaeus) Ireland 2010-2015 Irish Hare (Lepus timidus subsp. O13 17/09/2015 Atlas of Mammals in - EU Habitats Directive hibernicus) Ireland 2010-2015 [92/43/EEC] Annex V - Wildlife (Amendment) Act, 2000 Irish Stoat (Mustela erminea O13 26/02/2016 Mammals of Ireland - Wildlife (Amendment) Act, 2000 subsp. hibernica) 2016-2025
Red Fox (Vulpes vulpes) O13 01/09/2020 Aras an Uachtaráin n/a O13G 12/12/2017 Biodiversity Audit O1332 02/07/2016 2019-2020; Mammals of Ireland 2016-2025 Wood Mouse (Apodemus O13 31/08/2020 Aras an Uachtaráin n/a sylvaticus) O13G 21/08/2015 Biodiversity Audit O1332 21/08/2015 2019-2020; Atlas of Mammals in Ireland 2010-2015 NON-NATIVE SPECIES American Mink (Mustela vison) O13 27/02/2016 Mammals of Ireland - High Impact Invasive 2016-2025 - Species Regulation S.I. 477 (Ireland) Brown Rat (Rattus norvegicus) O13 26/05/2020 Aras an Uachtaráin - High Impact Invasive Species O13G 22/05/2016 Biodiversity Audit - Regulation S.I. 477 (Ireland) O1332 22/05/2016 2019-2020; Mammals of Ireland 2016-2025 Eastern Grey Squirrel (Sciurus O13 01/09/2020 Aras an Uachtaráin - High Impact Invasive carolinensis) O13G 01/09/2018 Biodiversity Audit - EU Regulation No. 1143/2014 O1232 30/09/2015 2019-2020; - Regulation S.I. 477 (Ireland) Mammals of Ireland 2016-2025; Atlas of Mammals in Ireland 2010-2015 European Rabbit (Oryctolagus O13 15/06/2020 Aras an Uachtaráin - Medium Impact Invasive cuniculus) Biodiversity Audit Species 2019-2020 Fallow Deer (Dama dama) O13 16/09/2018 Mammals of Ireland - High Impact Invasive Species 2016-2025 - Regulation S.I. 477 (Ireland) - Wildlife (Amendment) Act, 2000 Feral Ferret (Mustela furo) O13 12/08/2018 Mammals of Ireland - High Impact Invasive Species 2016-2025 Greater White-toothed Shrew O13 19/06/2017 Mammals of Ireland - Medium Impact Invasive (Crocidura russula) 2016-2025 Species House Mouse (Mus musculus) O13 25/07/2018 Mammals of Ireland - High Impact Invasive Species 2016-2025
There are no watercourses within or close to the Site of the Proposed Development, thus it is not anticipated that Otter would utilise the Site due to lack of suitable habitat for this species. However, according to the Dublin City Otter Survey, carried out as part of an Action of the
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Dublin City Biodiversity Action Plan 2015-2020 (Macklin et al., 2019), Otters do utilise the Camac and Poddle rivers, which are approximately 1.1km and 1.4km from the Site of the Proposed Development, respectively. Eight Otter signs (4 spraints, 1 couch, 1 latrine and 1 active hold) were recorded on the Camac River (Macklin et al., 2019; Figure 7). Two Otter signs were recorded along the River Poddle, both of these were a considerable distance upstream of the Site of the Proposed Development (Figure 7).
FIGURE 7. OTTER SIGN DISTRIBUTION ON THE SURVEYED REACHES OF THE CAMAC AND PODDLE RIVERS AS SURVEYED APRIL 2018-APRIL 2019 BY TRITURUS ENVIRONMENTAL LTD. (ADAPTED FROM MACKLIN ET AL., 2019).
4.4.3 Bats Eight species of bat have been recorded within the 10km grid square (O13) by the NBDC. Three species were recorded within the 2km grid square (O13G). No bat species were recorded in either of the 1km grid squares (O1332 and O1232). Records are listed in Table 5.
The NBDC maps landscape suitability for bats based on Lundy et al. (2011). The index ranges from 0 to 100 with 0 being least favourable and 100 most favourable for bats. The overall habitat suitability index for bats is poor (18.33) however the suitability for individual species ranges from 37 for Leisler’s Bat Nyctalus leisleri to 7 for Natterer's Bat Myotis nattereri.
TABLE 5. RECORDS OF BATS WITHIN THE 10KM (O13), 2KM (O13G) AND 1KM (O1332 AND 01232) GRID SQUARES AND THE HABITAT SUITABILITY INDEX FOR EACH SPECIES IN THE LOCALITY. THE RECORDS ARE DATED WITHIN THE LAST 20 YEARS AND ARE PROVIDED BY THE NBDC.
Name Suitability Grid Date of last Database Legal Status / Designation Index square record Brown Long-eared Bat 23 O13 25/05/2020 Aras an - EU Habitats Directive Annex Plecotus auritus Uachtaráin IV
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Name Suitability Grid Date of last Database Legal Status / Designation Index square record Biodiveristy Audit - Wildlife (Amendment) Act, 2019-2020 2000 Daubenton's Bat Myotis 11 O13 25/05/2020 Aras an - EU Habitats Directive Annex daubentonii O13G 05/08/2013 Uachtaráin IV Biodiveristy Audit - Wildlife (Amendment) Act, 2019-2020; 2000 National Bat Database of Ireland Leisler’s Bat Nyctalus 37 O13 08/06/2020 Aras an - EU Habitats Directive Annex leisleri O13G 28/08/2008 Uachtaráin IV Biodiveristy Audit - Wildlife (Amendment) Act, 2019-2020; 2000 National Bat Database of Ireland Nathusius's Pipistrelle 10 O13 25/05/2020 Aras an - EU Habitats Directive Annex Pipistrellus nathusii Uachtaráin IV Biodiveristy Audit - Wildlife (Amendment) Act, 2019-2020 2000 Natterer's Bat Myotis 7 O13 25/05/2020 Aras an - EU Habitats Directive Annex nattereri Uachtaráin IV Biodiveristy Audit - Wildlife (Amendment) Act, 2019-2020 2000 Pipistrelle Pipistrellus 31 O13 03/08/2013 National Bat - EU Habitats Directive Annex pipistrellus sensu lato O13G 28/08/2008 Database of IV Ireland - Wildlife (Amendment) Act, 2000 Soprano Pipistrelle 33 O13 25/05/2020 Aras an - EU Habitats Directive Annex Pipistrellus pygmaeus Uachtaráin IV Biodiveristy Audit - Wildlife (Amendment) Act, 2019-2020 2000 Whiskered Bat Myotis 13 O13 13/08/2007 National Bat - EU Habitats Directive Annex mystacinus Database of IV Ireland - Wildlife (Amendment) Act, 2000
4.4.3.1 Bat Recordings The results of the bat surveys are summarized in Table 6. The complete dataset of bat species identified in real time in the field can be viewed in the full reports presented in Appendix III. In total, three species of bat were detected (8 bat passes) for May 2020 and two species (15 passes) for March 2021. As expected, due to the lighting regime on the Site a low rate of bat activity was recorded during both surveys. The most frequent bat species heard was Common Pipistrelle and Leisler’s Bat. During the March 2021 survey an individual bat repeatedly circled the surveyor. This repeated circling resulted in the same individual being recorded on multiple occasions and should not be interpreted as a higher level of activity towards the rear of the Site than was actually the case.
TABLE 6. BAT RESULTS SUMMARY DATA- MAY 11TH 2020 BETWEEN 21.13 AND 23.30.
Species Name – Species Name – Latin Total Number of Peak Common Number of Passes Frequency Calls (kHz) 11th May 2020 Common Pipistrelle Pipistrellus pipistrellus 8 2 46.5 Leisler’s Bat Nyctalus leisleri 6 5 26.9 Brown Long Eared Plecotus auritus 1 1 33.2
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Species Name – Species Name – Latin Total Number of Peak Common Number of Passes Frequency Calls (kHz) 15th March 2021 Common Pipistrelle Pipistrellus pipistrellus 61 12 46.5 Leisler’s Bat Nyctalus leisleri 5 3 26.9
4.4.3.2 Bat Survey Overview No bat emergence was detected or observed from the buildings and structures onsite during the surveys of May 2020 and March 2021. In addition, the bat potential of the buildings and structures onsite was deemed to be low with no suitable bat roost features observed on external examination of the buildings.
4.4.3.3 Bat Potential Tree Assessment A total of 20 trees have been identified for felling. Of the 20 trees the majority (16) were classed as ‘Negligible/low’ bat potential. Three (3 no.) trees with Low/Moderate bat potential were identified and 1 no. tree has ‘Low’ potential. There was limited or no bat activity at these trees. Refer to the Bat Report for March 2021 for full details and images.
4.4.3.4 Landscape Evaluation The landscape is considered of local importance (Lower value) for bats due to the presence of Brickfield Park adjacent to the Site. The wider area however is highly urbanised location and assigned a low landscape suitability score for bats.
4.4.4 Birds There are several known ex-situ feeding sites for Light-bellied Brent Geese within the vicinity of the Site. These include Brickfield Park, which is located immediately adjacent to the Site, Dolphin’s Barn Green, which is located approximately 380m to the north east of the Site, and Good Counsel GAA Club, which is approximately 420m to the north of the Site. Data from the Light-bellied Brent Geese surveys carried out at Brickfield Park by Benson (2008/09), Enviroguide Consulting (2018/19, 2019/20 and 2020/21) and Scott Cawley Ltd. (2016/17) are presented in Table 7 (Enviroguide Consulting, 2019; Enviroguide Unpublished Data).
Light-bellied Brent Geese were not recorded utilising the park in the 2008/09 season and in the 2016/17, 2018/19 and 2019/20 seasons. However, Light-bellied Brent Geese droppings were recorded at the park during the 2020/21 season (Table 7).
TABLE 7. RESULTS OF WINTER BIRD SURVEYS CARRIED OUT IN BRICKFIELD PARK. PEAK COUNTS OF QI SPECIES - LIGHT-BELLIED BRENT GEESE (PB) AND BLACKHEADED GULL (BH) - ARE SHOWN.
Season Months Surveyor Peak Peak No. site visits by Additional Count Count surveyor during notes PB BH overall survey period 2020/21 Nov- Enviroguide 0 48 6 Droppings March Consulting recorded 2019/20 Nov- Enviroguide 0 81 6 No March Consulting droppings recorded
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2018/19 Dec-April Enviroguide 0 110 8 No Consulting droppings recorded 2016/17 March Scott 0 - 2 No Cawley Ltd. droppings recorded 2008/09 unknown Lorraine 100 - unknown Geese Benson were present during two months of the survey season
4.4.4.1 Breeding Bird Surveys There were no species recorded breeding on site during the May 2020 breeding bird survey which are on the Red List of the Birds of Conservation Concern in Ireland. However, two species, Greenfinch and Goldcrest, were recorded which are on the Amber List of the Birds of Conservation Concern in Ireland (Table 8). However, it was the considered opinion of the surveyor that these species were not breeding on site but were using the boundary trees to Brickfield Park for feeding. The two species are most likely breeding in Brickfield Park.
TABLE 8. BIRD SPECIES RECORDED AT THE SITE OF THE PROPOSED DVELOPMENT ON THE 9TH MAY 2020. STATUS' ARE BASED ON GILBERT ET AL (2021).
Species Comments Status Chaffinch Fringilla coelebs A single bird was noted along the hedgerow on Green the north section Greenfinch Carduelis chloris Two birds recorded in trees close to site entrance Amber Magpie Pica pica Several recorded on site Green Hooded Crow Corvus cornix Two birds recorded along southern section of Green grass Jackdaw Corvus monedula Several recorded on site Green Wren Troglodytes troglodytes Two birds heard in song on site Green Robin Erithacus rubecula Two birds recorded, one at entrance and second Green on southern area Woodpigeon Columba palumbus Several recorded on site Green Collared Dove Streptopelia decaocto Two birds at entrance to site Green Blackbird Turdus merula One feeding on the grassy area to the south of Green the site Goldcrest Regulus regulus One calling from trees near entrance Amber
4.4.5 Fish
4.4.5.1 Salmonidae A fish survey of the River Camac was carried out by Inland Fisheries Ireland (IFI) in 2017. Four age classes of brown trout 0+, 1+, 2+ and 3+ were recorded in the river, with 0+ individuals the most abundant cohort (Matson et al., 2018). Of all the fish species captured in
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the Camac, brown trout was the most abundant. Furthermore, a single brown trout was captured during a transitional water survey carried out by IFI in the Upper Liffey Estuary in 2010 (Kelly et al. 2010).
Fish surveys were carried out by IFI on the River Liffey in 2009 and 2014, downstream of Lucan bridge (several other sites further upstream have also been surveyed by IFI in different years, however, this report focuses on surveys carried out at Lucan bridge as these are closest to the Site of the Proposed Development). Here, Atlantic salmon was the most common species consisting of 0+ and 1+ and older age classes (Kelly et al., 2015). Brown trout were the third most common species present after minnow (Kelly et al., 2015).
4.4.5.2 Petromyzonidae (Lamprey species) IFI surveys of the River Camac in 2017 (noted above) identified lamprey species Lampetra spp. in one of the five sites surveyed (Matson et al., 2018). The 2009 and 2014 surveys of the River Liffey (noted above) identified lamprey species in both years (Kelly et al., 2015). Furthermore, river lampreys were captured during a transitional water survey carried out by IFI in the Upper Liffey Estuary in 2010 (Kelly et al., 2010).
It is highly unlikely that Sea Lamprey will be affected by the Proposed Development. The most important locations for Sea Lamprey in Ireland are the Lower Shannon, the River Suir in Clonmel, the River Nore in Kilkenny, the River Moy in Ballina and the River Corrib in Galway (Igoe et al., 2004). Sea lamprey were recorded in the River Liffey at Island Bridge in 1906 (Igoe et al., 2004).
4.4.5.3 Anguillia anguilla European eel The European Eel Anguilla anguilla is a red listed, native Irish species and is considered one of the most threatened fish species in Ireland (King et al., 2011). There are NBDC records of European Eel within grid squares O13 (10km) and O13G (2km) (Table 9). Furthermore, Eels were captured during IFI fish surveys of the Camac River in 2011 (Kelly et al., 2012). The 2009 and 2014 surveys of the River Liffey (noted above) identified European eels in both years (Kelly et al., 2014). Eels were also captured in a transitional water survey carried out by IFI in the Upper Liffey Estuary in 2010 (Kelly et al., 2010) and both the Upper and Lower Liffey Estuary in 2008 (Central and Regional Fisheries Boards, 2008).
TABLE 9. RECORDS OF FISH SPECIES WITHIN THE 10KM (O13), 2KM (O13G) AND 1KM (O1332 AND O1232) GRID SQUARES. THE RECORDS ARE DATED WITHIN THE LAST 20 YEARS AND ARE PROVIDED BY THE NBDC.
Name Grid Date of last Database Legal Status / Designation square record NATIVE SPECIES European Eel (Anguilla anguilla) O13 09/06/2008 River Biologists' - OSPAR Convention O13G 09/06/2008 Database (EPA) - Critically Endangered Three-spined Stickleback O13 30/09/2016 Ireland's BioBlitz (Gasterosteus aculeatus)
NON-NATIVE SPECIES Minnow (Phoxinus phoxinus) O13 19/05/2012 Ireland's BioBlitz
Roach (Rutilus rutilus) O13 19/05/2012 Ireland's BioBlitz - Medium Impact Invasive Species - Regulation S.I. 477 (Ireland)
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Name Grid Date of last Database Legal Status / Designation square record Rudd (Scardinius O13 20/05/2020 Aras an Uachtaráin erythrophthalmus) Biodiveristy Audit 2019-2020
4.4.6 Amphibians The Common Frog Rana temporaria and Smooth Newt Lissotriton vulgaris were recorded within the 10km (O13) grid square associated with the Site of the Proposed Development. However, no amphibian species were recorded within the 2km (O13G) and 1km (O1332 and O1232) grid squares or during the field survey carried out on the 19th May 2020.
TABLE 10. RECORDS OF AMPHIBIAN SPECIES WITHIN THE 10KM (O13), 2KM (O13G) AND 1KM (O1332 AND O1232) GRID SQUARES. THE RECORDS ARE DATED WITHIN THE LAST 20 YEARS AND ARE PROVIDED BY THE NBDC.
Name Grid Date of last Database Legal Status / Designation square record Common Frog (Rana temporaria) O13 28/08/2020 Amphibians and - EU Habitats Directive Annex V reptiles of Ireland - Wildlife (Amendment) Act, 2000 Smooth Newt (Lissotriton vulgaris) O13 09/05/2020 Amphibians and - Wildlife (Amendment) Act, 2000 reptiles of Ireland
4.4.7 Invertebrates Marsh Fritillary, which is listed under the Habitats Directive, was recorded within the 10km grid square (O13) by the NBDC. In addition, records of several butterfly (lepidoptera), bee (hymenoptera) and mollusc species, as well as one damselfly (odonata), classed as either 'vulnerable', 'engangered' or ‘critically endangered' were available from the NBDC database (Table 11). Furthermore, point data provided by the Environmental Protection Agency (EPA) indicate the presence of white-clawed crayfish Austropotamobius pallipes in the Camac river in 2007 and 2013. These data are based on opportunistic field observations made by EPA staff while undertaking routine biological monitoring between the years 2007 and 2016.
No butterfly species were recorded during the Site survey on the 19th May 2020.
TABLE 11. THREATENED INVERTEBRATE SPECIES LISTED AS 'VULNERABLE', 'ENGANGERED' OR ‘CRITICALLY ENDANGERED' WITHIN THE 10KM (O13), 2KM (O13G) AND 1KM (O1322 AND O1232) GRID SQUARES. THE RECORDS ARE DATED WITHIN THE LAST 20 YEARS AND ARE PROVIDED BY THE NBDC.
Name Group Grid Date of Database Legal Status / square last Designation record Dark Green Fritillary (Argynnis Lepidoptera O13 04/06/2010 Irish Butterfly - Vulnerable aglaja) Monitoring Scheme Marsh Fritillary (Euphydryas Lepidoptera O13 27/05/2020 Butterflies of - EU Habitats Directive aurinia) Ireland Annex II - Vulnerable Small Blue (Cupido minimus) Lepidoptera O13 14/08/2010 Irish Butterfly - Endangered Monitoring Scheme Wall (Lasiommata megera) Lepidoptera O13 27/08/2011 Irish Butterfly - Endangered Monitoring Scheme Scarce Blue-tailed Damselfly Odonata O13 04/07/2017 Dragonfly - Vulnerable (Ischnura pumilio) Records
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Name Group Grid Date of Database Legal Status / square last Designation record Andrena (Melandrena) Hymenoptera O13 05/05/2020 Bees of Ireland - Vulnerable nigroaenea Gooden's Nomad Bee (Nomada Hymenoptera O13 05/05/2020 Bees of Ireland - Endangered goodeniana) Hylaeus (Prosopis) brevicornis Hymenoptera O13 30/07/2003 Bees of Ireland - Endangered Moss Carder-bee (Bombus Hymenoptera O13 10/08/2019 Bees of Ireland - Near threatened (Thoracombus) muscorum) Trimmer's Mining Bee (Andrena Hymenoptera O13 07/05/2003 Bees of Ireland - Critically Endangered (Hoplandrena) trimmerana) English Chrysalis Snail Mollusc O13 18/05/2012 Ireland's BioBlitz - Vulnerable (Leiostyla (Leiostyla) anglica) Glutinous Snail (Myxas Mollusc O13 16/10/2003 All Ireland Non- - Endangered glutinosa) O13G 05/10/2003 Marine Molluscan Database Lake Orb Mussel (Musculium Mollusc O13 18/05/2012 Ireland's BioBlitz; - Vulnerable lacustre) O13G 05/10/2003 All Ireland Non- Marine Molluscan Database Pisidium pseudosphaerium Mollusc O13 16/10/2003 All Ireland Non- - Endangered Marine Molluscan Database Pisidium pulchellum Mollusc O13 05/10/2003 All Ireland Non- - Endangered Marine Molluscan Database
4.4.8 Other species and species groups There are no records of common lizard Zootoca vivipara within the 10km grid square (O13). In addition, this species is associated with coastal and heathland habitats, but also locally in rural gardens, stone walls and roadside verges (King et al., 2011). The habitat at the Site of the Proposed Development is not considered suitable for this species.
4.4.9 Designated sites, habitat and species evaluation Fauna which have the potential to utilise areas within the immediate area of the Proposed Development, or for which records exist in the wider area, have been evaluated below in Table 12 for their conservation importance. In addition, designated sites and habitats have been evaluated. This evaluation follows the Guidelines for Assessment of Ecological Impacts of National Road Schemes (NRA, 2009b). The rationale behind these evaluations is also provided. The term ‘ecological receptors’ is used when impacts upon them are likely.
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TABLE 12. EVALUATION OF DESIGNATED SITES, HABITATS AND FAUNA RECORDED WITHIN THE SUROUNDING AREA.
Designated Sites/Species/Habitats Evaluation Key Rationale Ecological Receptor (KER) Designated Sites SACs & SPAs International Importance No Protections addressed in NIS. pNHAs National Importance No Water quality protection addressed in NIS will serve to protect designated sites. Dublin Bay Biosphere International Importance No Water quality protection addressed in NIS will serve to protect this designated site. Habitats Buildings and artificial surfaces (BL3) Local importance (lower No Man-made habitat of low biodiversity value. value) Amenity grassland (GA2) Local importance (lower No Low diversity highly managed grassland not considered to be of conservation value. value) Ornamental/Non-native shrub (WS3) Local importance (higher Yes Given the maturity and function of this habitat as a biodiversity corridor, with value) connections to Brickfield Park, this habitat is considered a KER. Treelines (WL2) Local importance (higher Yes Although the treelines around the site are comprised of many non-native ornamental value) shrubs and trees, given their maturity and function as a biodiversity corridor, with connections to Brickfield Park this habitat is considered a KER. Scrub Local importance (lower No Small area of low diversity scrub habitat dominated by invasive Butterfly Bush. value) Mammals Eurasian Badger Meles meles National Importance No The badger is an adaptable species of lowland grassland and woodland habitats, also occasionally occurs in upland and suburban areas (Marnell et al., 2009). The habitats at the Site of the Proposed Development are not considered suitable for this species. Eurasian Pygmy Shrew Sorex minutus National Importance Yes There is suitable habitat within the grassland, ornamental shrub and scrub habitat at the Site of the Proposed Development and the adjacent Brickfield Park for pygmy shrew. Eurasian Red Squirrel Sciurus vulgaris National Importance No The Site of the Proposed Development is not located within the two areas of remaining red squirrel populations in Dublin. European Otter Lutra lutra International importance No No hydrological connectivity to Camac, Poddle or Grand Canal.
West European Hedgehog Erinaceus National Importance Yes There is suitable habitat within the mature ornamental shrub at the Site of the europaeus Proposed Development and the adjacent Brickfield Park for hedgehog. Irish Hare Lepus timidus subsp. National Importance No The favoured habitat of the Irish hare is improved grassland (Marnell et al., 2009). hibernicus There is no suitable habitat present for hare within the Proposed Development Site, and the managed nature of Brickfield Park makes this nearby potential habitat unsuitable.
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Designated Sites/Species/Habitats Evaluation Key Rationale Ecological Receptor (KER) Irish Stoat Mustela erminea subsp. National Importance No Stoat are found in various habitats from coastal grasslands to woodlands and hibernica uplands, however they tend to avoid open habitats (Marnell et al., 2009). It is considered unlikely that the habitat at the Site of the Proposed Development and its environs would be suitable for stoat. Red Fox Vulpes vulpes No Although this species was observed at the Site, it is not considered to be of conservation concern and therefore is not assessed further in this report Wood mouse Apodemus sylvaticus National Importance No Wood mice can be found in wide range of habitats from sand dunes to their preferred forest habitat. They are frequently found in urban gardens and parks, and therefore may inhabit Brickfield Park. However, this species is not considered to be of conservation concern and therefore is not assessed further in this report Bat Assemblage International Importance Yes Three bat species were detected at the Site of the Proposed Development during dedicated surveys. Birds Bird assemblage (Amber listed) National Importance Yes There are records of Light-bellied Brent Geese utilising Brickfield Park, adjacent to the Site of the Proposed Development, as ex-situ habitat. Greenfinch and Goldcrest were recorded on site during the May 2020 breeding bird survey. Bird assemblage (Green listed) County Importance Yes A number of green-listed species were recorded on site during the May 2020 breeding bird surveys. Amphibians Common Frog Rana temporaria International Importance No No ponds or suitable breeding sites within or in the vicinity of the Site of the Proposed Development. Smooth Newt Lissotriton vulgaris National Importance No No ponds or suitable breeding sites within or in the vicinity of the Site of the Proposed Development. Fish Atlantic salmon Salmo salar; Brown International-National No No hydrological connectivity to Camac or Poddle Rivers. Water quality protection in trout Salmo trutta; European Eel Importance addressed in NIS will serve to protect species in Dublin Bay/the Liffey Estuary. Anguilla anguilla; Brook and river lamprey Lampetra spp. Invertebrates White-clawed crayfish International Importance No Records indicate the presence of this species in the River Camac. However, surface- Austropotamobius pallipes water discharges are likely to be transported to the Liffey Estuary via the Grand Canal Trunk Sewer. Marsh Fritillary Euphydryas aurinia International Importance No The Marsh Fritillary can be found in a range of habitats including calcareous grassland, degraded bogs, wet heath, transition mires and fens up to 300m (Regan et al., 2010). The habitats at the Site of the Proposed Development are not considered suitable for this species.
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5 DESCRIPTION OF THE PROPOSED DEVELOPMENT
5.1 Location The Site comprises an industrial / warehouse facility, located on Brickfield Drive, Dublin 12, just north of the Crumlin Road. The site is roughly T-shaped and comprises an area of 1.233ha excluding the area of public road. It is bounded to the north by Brickfield Park. The northern boundary in part comprises palisade fencing over a low wall, while the reminder comprises a high wall topped with security fencing. Crumlin College of Further Education bounds the Site to the south, while the Iveagh sports grounds lie to the west of the Site. Sunshine Industrial Estate also bounds Site to the south and west. The Site has frontage of approx. 55m to Brickfield Drive to the east, while 4 no. semi-detached houses back onto the remainder of this boundary.
The Proposed Development Site is currently zoned “Z6 – Enterprise and Employment’ under the objective ‘To provide for the creation and protection of enterprise and facilitate opportunities for employment creation’ in the Dublin City Development Plan 2016-2022 (CDP). However, during the March 10th Monthly Dublin City Council meeting that the Council resolved to rezone the site to “Z12” – Predominantly residential as part of this variation. The Z12 zoning has an objective to “Ensure the existing environmental amenities are protected in the predominantly residential future use of these lands”.
The surrounding land falls under a variety of different Dublin City Development Plan zones, with some nearby sites falling under zone 15 ‘Institutional and Community’ with the objective ‘To protect and provide for Institutional and community use’ and nearby open spaces falling under zone 9 ‘Amenity/Open Space Lands/Green Network’ with the objective ‘To preserve, provide and improve recreational amenity and open space and green networks’. In addition, some nearby lands fall under zone 4, ‘District Centres’ with the objective ‘To provide for and improve mixed-services facilities’ and zone 1 ‘Sustainable Residential Neighbourhoods’ with the objective ‘To protect, provide and improve residential amenities.’
5.2 Description of Development The Site (approx. 1.3691 ha or 1.232ha excluding area of public road) consists of the Former Eason’s Warehouse, Brickfield House, Brickfield Drive, Crumlin, Dublin 12, D12 AF58.
The Proposed Development shall provide for: (a) the demolition (total area approx. 5,757 sqm) of the existing buildings on site and the existing front boundary treatment; and (b) the construction of a new residential and mixed use scheme of 282 no. apartment units in 4 no. blocks (Blocks A to D) ranging from 4 to 10 storeys in height as follows:
• Block A (8 - 10 storeys) comprising 96 no. apartments (38 no. 1 bed and 58 no. 2 bed units) • Block B (7 - 8 storeys) comprising 68 no. apartments (1no. studio, 29 no. 1 bed and 38 no. 2 bed units) • Block C (4 - 6 storeys) comprising 40 no. apartments (11 no. 1 bed and 29 no. 2 bed units) • Block D (5 - 7 storeys) comprising 78 no. apartments (48 no. 1 bed and 30 no. 2 bed units)
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Block C will accommodate a Childcare Facility/creche of approx. 281 sqm at ground floor level.
The proposal will also provide for a café of 140 sqm at the ground floor of Block C. Residential amenity areas will be provided in the form of a reception of approx. 67.5sqm, resident lounge and meeting room of approx. 151sqm and a public remote working hub of approx. 140sqm, all at the ground floor level of Block C.
At Level 01 of Block C, the accommodation includes a public gym (approx. 229 sqm), a yoga / multi purpose room (approx. 42.5sqm) and an office and lobby area.
Each residential unit will be afforded with private open space in the form of a balcony or terrace. Public open space is proposed in the form of play areas, courtyards, outdoor seating and terraced planting and pedestrian and cyclist links (approx. 3,593 sqm).
Basement areas (total approx. 4,625 sqm) are proposed on one level, below part of Blocks B & C and under Block D, and include parking areas, waste management, stair and lift cores and plant areas.
A total of 119no. car parking spaces (113no. at basement level), including 4 car share spaces (1no. at surface and 3no. at basement level) and 5 no. set-down/drop-off spaces at surface level; 558 no. bicycle spaces (438no. stacked spaces at basement level, and 120 no. bicycle paces at surface level in open air and secure storage format); and 7no. motorcycle spaces (at basement level) are proposed.
The Development shall be served via two new vehicular access points from Brickfield Drive. Upgrade works are proposed to the vehicular access points to facilitate the Proposed Development and to provide for improved access and egress for the overall Development. New pedestrian and cyclist access points will be provided via Brickfield Drive.
The associated site and infrastructural works include provision for water services; foul and surface water drainage and connections; attenuation proposals; permeable paving; all landscaping works; boundary treatment; internal roads and footpaths; waste storage areas and electrical services and all associated site development works.
The incorporation of Sustainable Urban Drainage Systems (SUDS) into the design of the Proposed Development is mandatory for all new developments under the Greater Dublin Regional Code of Practice for Drainage Works. As such, the Proposed Development design entails a suite of SuDS measures. SUDS is a series of management practices and control structures that aim to mimic natural drainage. SUDS reduces flood risk, improves water quality and provides amenity through the use of permeable paving, swales, green roofs, rain water harvesting, detention basins, ponds and wetlands2.
2 https://www.dublincity.ie/dublin-city-development-plan-2016-2022/9-sustainable-environmental-infrastructure/95-policies-and- objectives/954-surface-water-drainage-and
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FIGURE 8. SITE LOCATION
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5.3 Landscape Specifications The planting scheme uses a mix of native and ornamental tree and shrub species to create a seasonal landscape that is functional, whilst also being sympathetic to the surrounding environment. Of note to this EcIA Report is that it is proposed to retain existing vegetation along the northern boundary where possible and to supplement it with a proposed Hawthorn hedge Crataegus monogyna. This will be beneficial for a diversity of wild fauna (birds, bats, hedgehogs). Refer to the Landscape Proposal for full details on ground preparation, tree, hedgerow, shrub and groundcover planting, grass seeding and maintenance.
5.3.1 Existing trees An Arboricultural Assessment of the Site has been carried out, and a tree protection plan has been prepared for the Site. As part of the assessment, 37 no. trees were tagged individually and one tree belt (within Brickfield Park), one tree line (growing on the adjoining property side of the western boundary wall), one hedge (along the eastern boundary of the Site and is mostly located on the adjoining property side of a low boundary wall) and seven shrub borders were identified.
Twenty of the 37 individually tagged trees along with a number of shrub borders are proposed to be removed to facilitate the Proposed Development works or as part of management.
The existing Lawson Cypress trees located along the eastern side of the Site to the rear side of No. 21-27 Brickfield Drive are to be retained. In addition, it is proposed to retain a line of self-seeded Sycamore trees which are growing along the south-western boundary wall.
Regarding the boundary of existing trees in Brickfield Park along the northern side of the Site (the tree belt), it is expected that the boundary wall has sufficient depth of foundations that will have restricted root growth into the Site area. Therefore, construction works within the Site area are not expected to impact negatively on these trees (Tree Protection Plan - Arborist Associates Ltd, 2021).
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FIGURE 9. LANDSCAPE PROPOSAL DRAWING OF THE PROPOSED DEVELOPMENT SHOWING THE GROUND FLOOR LAYOUT (PARK HOOD, APRIL 2021).
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TABLE 13. SUMMARY OF PROPOSED PLANTING AT THE SITE OF THE PROPOSED DEVELOPMENT. DETAILS ON THE “POLLINATOR FRIENDLY” STATUS AND WHETHER THE PLANTS ARE NATIVE OR NON-NATIVE ARE PROVIDED.
Latin name Common name Native/non-native RHS Plant for All Ireland Pollinator All Ireland Pollinator Pollinators Plan “pollinator Plan particularly friendly” “pollinator friendly” in Ireland Trees and Hedgerows Crataegus monogyna Hawthorn Native Yes Yes No Betula pendula Birch Native No No No Aesculus hippocastanum Horse chestnut Non-native Yes Yes No Tilia cordata ‘Greenspire’ Lime Non-native No Yes No Tilia x euchlora Caucasian lime Non-native No No No Pyrus calleryana ‘Chanticleer’ Chanticleer pear Non-native No Yes No Prunus ‘Tai-Haku’ Japanese flowering cherry Non-native No Yes No Crataegus monogyna ‘Stricta’ Upright Hawthorn Native hybrid cultivar No Yes No Sorbus sargentiana Sargent’s Rowan Non-native No Yes* No High Ornamental Shrubs Pyracantha ‘Orange Glow’ Firethorn Non-native Yes* Yes* Yes* Cornus alba ‘Sibirica’ Siberian dogwood Non-native Yes Yes No Elaeagnus x ebbingei Ebbinge’s silverberry Non-native No Yes No Photinia x fraseri ‘Red Robin’ Christmas berry 'Red Robin' Non-native No No No Sarcococca hookeriana Sweet box Non-native Yes Yes No Medium/Low Ornamental Shrub Planting Euonymus fortunei ‘Emerald’n Gold Spindle ‘Emerald’n Gold’ Non-native No No No Lavandula angustifolia ‘Hidcote’ English Lavender Non-native Yes Yes Yes Potentilla fruticosa ‘Goldfinger’ Shrubby cinquefoil Non-native Yes Yes* No Skimmia japonica Skimmia Non-native Yes Yes No Spiraea japonica ‘Goldmund’ Japanese spiraea Non-native Yes Yes No Hebe ‘Green Globe’ Shrubby Veronica Non-native Yes* Yes* Yes* Skimmia x confusa ‘Kew Green’ Skimmia ‘Kew Green’ Non-native No No No Understorey Planting Pachysandra terminalis ‘Green Carpet’ Japanese spurge 'Green Carpet Non-native No No No Vinca minor Lesser Periwinkle Non-native No No No Narcissus ‘Minnow’ Daffodil ‘Minnow’ Non-native No No No Narcissus ‘Juanita’ Daffodil ‘Juanita’ Non-native No No No
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Latin name Common name Native/non-native RHS Plant for All Ireland Pollinator All Ireland Pollinator Pollinators Plan “pollinator Plan particularly friendly” “pollinator friendly” in Ireland Wildlife Corridor Planting Sarcococca confusa Sweet Box Non-native Yes Yes No Cytisus scoparius Broom Native No Yes No Echinops bannaticus ‘Taplow Blue’ Blue Globe Thistle Non-native Yes* Yes* Yes* Helenium ‘Waltraut’ Helen’s flower Non-native Yes Yes Yes Rosa rugosa Japanese Rose Non-native Yes No No Viburnum opulus Guelder Rose Native Yes Yes No Crocus ‘Ruby Giant’ Crocus Non-native Yes* Yes* Yes* Hyacinthoides non-scripta Bluebell Native No Yes No *Genera (rather than specific species) listed as pollinator friendly ** Note that the pollinator friendly list provided by All-Ireland Pollinator Plan is not exhaustive
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6 POTENTIAL IMPACTS OF THE PROPOSED DEVELOPMENT
6.1 Impacts on waterbodies
6.1.1 Surface water Surface water discharges to the River Camac are unlikely due to the location of the river relative to the Site. There is no direct open-water pathway between the Site and nearby surface water bodies. Given its location, the Site of the Proposed Development will likely be served by the Grand Canal Trunk Sewer. This sewer is divided into two segments: one for foul sewage comprising approximately one third of the cross-sectional area of the tunnel with the remainder for surface water flows. Foul flows drain to the Main Lift Pumping Station at Ringsend for delivery to the Ringsend Wastewater Treatment Works. The surface waterside of the tunnel currently discharges into the Grand Canal Dock and receives direct flows from Crumlin, excess flow from the River Poddle and spilled flow from combined sewer overflows in the Rathmines and Pembroke area (GDSDS, 2005). The Site of the Proposed Development is not within the River Camac Storm Level 1 catchment (GDSDS, 2005). It is likely that surface water run-off from the Site of the Proposed Development will discharge into Grand Canal Dock. In the absence of mitigation, surface water run-off from the Construction Phase could result in a negative, short-term, slight impact on surface water quality in Grand Canal Dock and areas of Dublin Bay.
It is a policy of Dublin City Council (SI18) to “require the use of Sustainable Urban Drainage Systems in all new developments, where appropriate, as set out in the Greater Dublin Regional Code of Practice for Drainage Works”. As such, the Proposed Development design entails a suite of SuDS measures that will be incorporated into the Proposed Development. This will reduce the flow rate of surface water run-off and largely eliminate the risk of pollution to waterbodies arising from surface water run-off during the Operational Phase of the Proposed Development. Impacts on surface water bodies during the Operational Phase are therefore considered negligible.
6.1.2 Foul water from Ringsend WwTP The increase of a maximum load of 861 Population Equivalent (PE) at the facility as a result of the Proposed Development, assuming each PE unit was not previously supported by the WwTP, is considered to be an insignificant increase in terms of the overall scale of the facility. This potential maximum increased load of 861 PE does not have the capacity to alter the effluent released from the WwTP to such an extent as to result in likely significant effects on the habitats, species and Natura 2000 sites connected hydrologically with Ringsend WwTP. In addition, upgrade works are currently on-going at Ringsend WwTP to increase the capacity of the facility from 1.6 million PE to 2.4 million PE. This plant upgrade will result in an overall reduction in the final effluent discharge of several parameters from the facility including BOD, suspended soils, ammonia, DIN and MRP (Irish Water, 2018). Impacts on surface water bodies during the Operational Phase are therefore considered negligible.
6.2 Impacts on habitats and flora The habitats listed as KERs for this Site include:
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• Treelines (WL2) • Ornamental/Non-native shrub
These habitats were selected as KERs due to their maturity and function as a biodiversity corridor, with connections to Brickfield Park.
In the absence of mitigation, the loss of these habitats has the potential to cause negative, permanent, moderate impacts at a local level. It is considered that construction works within the Site area are not expected to impact negatively on the trees in Brickfield Park (refer to section 5.3.1).
6.3 Impacts on fauna
6.3.1 Mammals excl. bats Negative impacts on mammals that may be present at or in the environs of the Site of the Proposed Development as a result of removal of habitat is considered unlikely due to the general lack of suitable habitat at the Site, as well as the fact that several existing trees and shrub habitat is to be retained. However, disturbance of species during the Construction Phase is possible. Noise and dust generated during the Construction Phase has the potential to cause negative, short-term, slight impacts in the form of disturbance at a local level. Furthermore, hedgehogs are known to inhabit residential areas (BHPS, 2019), and therefore may inhabit/frequent the Site of the Proposed Development. Increased human presence during both the Construction and Operational Phases, in addition to increased lighting at the Site, also have the potential to cause negative, permanent, slight disturbance to mammals in the locality, particularly those in Brickfield Park.
Small mammal species, especially Hedgehogs, can become entangled in construction materials such as netting and plastic sheeting, as well as other waste materials. This can lead to entrapment and injury or death. This constitutes a negative, short-term, significant risk at a local level associated with the Construction Phase of the Proposed Development.
6.3.2 Bats There will be some loss of habitat for bats at the Site of the Proposed Development as some of the treelines will be removed, and disturbance of species during the Construction Phase is possible. This could have a negative, permanent, moderate impact on bats in the locality. Furthermore, light pollution could have a negative, permanent, moderate impact on bats in the locality in the absence of mitigation.
6.3.3 Birds The Light-bellied Brent Goose droppings recorded at Brickfield Park during the 2020/21 winter bird surveys carried out by Enviroguide indicate that this species has been recently utilising the park as ex-situ habitat. Furthermore, Black-headed Gull, a QI species associated with South Dublin Bay and River Tolka Estuary SPA and North Bull Island SPA, has also been recorded, albeit in low numbers, at Brickfield Park.
Given the close proximity of the Site to this ex-situ habitat, it is possible that the Proposed Development could cause disturbance and/or displacement to these SCI species due to disturbance from environmental nuisances such as noise, dust and lighting.
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There will be some loss of habitat for birds at the Site of the Proposed Development as some of the treelines and shrub vegetation will be removed, and disturbance of species during the Construction Phase is possible. This could have a negative, permanent, moderate impact on birds in the locality.
The increased noise and dust levels associated with the Construction Phase of the Proposed Development may have the potential to cause negative, short-term, slight impacts to local bird populations. Increased human presence during both the Construction and Operational Phases, in addition to increased lighting at the Site also have the potential to cause negative, permanent, slight disturbance to birds in the locality, particularly those in Brickfield Park. According to Toronto City’s Best Practices Effective Lighting (2007), light pollution in the form of glare, light trespass, over lighting and sky glow can have a negative impact on birds as well as the health of humans and the natural environment. There is strong evidence to suggest that the increasing use of artificial light at night is having a negative effect on bird populations, particularly on those that migrate at night (Gauthreaux and Belser, 2006).
The height of the building, coupled with the use of glass in the proposed design has the potential to cause negative, permanent, significant impacts on birds due to collisions. The design proposal stipulates building heights will range from 4-10 storeys.
Glass in buildings can pose a potentially lethal threat to bird species. This is a result of birds being unable to distinguish between reflections in glass and the natural environment (resulting in birds flying into windows that appear to be trees or sky), and their inability to perceive clear glass as a solid object (Toronto City Bird-Friendly Best Practices: Glass). Birds will strike clear glass while attempting to reach habitat and sky seen through corridors, windows positioned opposite each other in a room, ground floor lobbies, glass balconies or glass corners. The impact of striking a reflective or clear window in full flight often results in death.
As the size of buildings increases, so typically does the amount of glass, making larger buildings more of a threat. In general, however, the lower stories of buildings are the most dangerous because they are at the same level as trees and other landscape features that attract birds. Nevertheless, monitoring programs assessing setbacks and roofs of tall buildings are finding that birds also collide with higher levels especially during bad weather at night. It is especially important that glass near rooftop gardens, green roofs and other features such as green walls is treated to be bird-friendly.
6.4 Do nothing impact Under the do-nothing scenario, large areas of the Site would remain as they are. The shrub habitat is likely to increase in size and potentially offer suitable habitat for a number of species. Given the large proportion of built land on the Site (the Site comprises an industrial/warehouse facility) the ecological value of this Site is relatively low.
6.5 Cumulative impacts
6.5.1 Existing granted planning permissions There are several existing granted planning permissions on record in the Crumlin area, ranging from small-scale extensions and alterations to existing residential properties to larger- scale developments.
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Relatively large-scale projects which have been granted permission in the Crumlin area are outlined below:
ABP Ref.: 303435-18: Former Dulux factory site, Davitt Road, D12. Permission granted for 265 no. units resulting in a density of 321 units per hectare. The site is located c. 500 metres to the west of the subject site. An Appropriate Assessment Stage 1 Screening Report that concluded that there will be no impacts upon the conservation objectives of the Natura sites identified (Inspector’s Report ABP-303435-19).
2747/20: Former Dulux factory site, Davitt Road, D12. The development will consist of modifications to development previously permitted under Reg. Ref. ABP-303435-19 (DCC Ref. SHD0002/19). The modifications for permission consist of (a) alteration to window format at third and fourth floor level on east and west elevation to provide windows to corridor only; (b) window format altered at sixth floor level of south elevation of Blocks A and B; (c) balconies and windows removed from eastern elevation of 4no. apartments at fifth and sixth floor level of Block B due to internal layout requirements related to fire safety; (d) extension of elevator and lift core within Block A from fourth floor to fifth floor level for fire safety purposes, giving an overall height increase of 3.7m; (e) communal lounge extended by 3sqm to connect to extended lift/stair core at fifth floor level; (f) ESB Kiosk (approx. 23.47sqm) at Galtymore Road elevation relocated approximately 6m to the east and redesigned to ESB standards; (g) bin store added to internal layout of ESB substation building (approx. 7.09sqm); (h) bin store (approx. 9.77sqm) added to eastern courtyard; (i) accessible rest room added to guest room at fifth floor level; (j) glazed balconies converted to brick at ground floor level of south elevation and east and west internal courtyard elevations; (k) alteration to glazing at street level of Block B fronting Davitt Road; (l) alterations to selected balconies (8no.) at third and fifth floor to convert from cladding to glazed treatment; and (m) unit layouts of apartments 104 and 110 at first and second floor of block B, fronting Davitt Road, reconfigured to allow sufficient separation distance between proposed balconies and ground floor ESB substation entrance. (Decision: Additional Information; Decision Date: 07/07/2020).
3078/09: Planning permission for development at this site at Crumlin Shopping Centre with frontage onto Crumlin Road at Crumlin Road, Crumlin, Dublin 12 (total site area 3.3 hectares). The development will consist of the demolition and redevelopment of a substantial part of the existing Crumlin Shopping Centre (existing gross floor area (GFA) 10,805sqm total GFA proposed 17,193sqm) and the upgrading and resurfacing of the existing car park. The existing public house at first floor level and three existing retail units below the public house fronting Crumlin Road will be retained as part of this development, these forming part of an existing ''terrace'' of buildings on the Crumlin Road frontage. The new development ranges in height between 11 metres and 15 metres above finished ground floor level. The development will include the redevelopment of the two anchor retail units, with redeveloped anchor unit no. 1 having a GFA of 9,288sqm containing 3,500sqm net convenience floor space excluding off licence sales and comparison floor space. A restaurant/cafe (538sqm) is provided at mezzanine level together with associated storage areas, staff canteen, changing facilities and ancillary office space. Retail anchor unit no. 2 will contain 2,316sqm net convenience sales floor area with storage and staff areas at mezzanine level (1,435sqm GFA). The redeveloped centre will also include four retail units (513sqm total) (in addition to the 3no. units to be retained), and a cafe (136sqm) accessed from a new internal mall (354sqm) that opens onto the existing and reconfigured surface car park (containing 490no. car parking spaces) on the western part of the application site. Customer toilets (58sqm) will also be provided. A
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Enviroguide Consulting Strategic Housing Development Ecological Impact Assessment Report Brickfield Drive, Crumlin, Dublin 12 management suite (108sqm) is provided at mezzanine level with access from the new internal mall. The first floor, facing Crumlin Road will contain floor space that can be used as a library (1,330sqm) or for office accommodation (1,330sqm) with new entrance from Crumlin Road and open space areas at first floor level (3no. at 125sqm each). The existing service/delivery areas to the east and west of the shopping centre will be retained and accessed via two existing separate entrances from Crumlin Road. The eastern entrance will be restricted to service/delivery vehicles only and staff parking. This planning application includes all site development works, signage, boundary treatments, landscaping and associated plant machinery and 2no. ESB substations for the Proposed Development and will be accompanied by an Environmental Impact Statement (EIS).
3078/09/X1: EXT OF DURATION: Request for an extension of permission for development at Crumlin Shopping Centre (detail description above). Permission for this extension was granted on the 25th of March 2015. The final granted permission stated the following providing a date certain for substantial completion:
The Planning Officer recommends that an extension of the duration of the permission be granted in this instance, this extension to be until 17-Mar-2020.
Work has not commenced for this development on site, so this permission has therefore expired.
2882/12/X1: EXT OF DURATION: The development will consist of the provision of a residential care facility to include; EXT OF DURATION: a) A 4 storey nursing home building to accommodate 122 no. bedrooms, terrace areas at first, second and third floor levels, ancillary amenity and service areas and staff facilities; b) 6 no. 3-4 storey Sheltered Accommodation buildings to accommodate 120 no. Independent Living Units; each with private balcony or optional winter garden; c) Widening of existing access road, surface level car parking for 59 cars, boundary treatments, landscaping and all ancillary services and development. (Decision date 09/01/2018, extension granted to 01/10/ 2023. Distance to Site c. 1.2 km).
2131/18: Development at a 0.147 hectare site. The site is bounded to the west by lands to the rear of Nos. 17-23 Sundrive Park and Nos. 35 Sundrive Park, to the south by No. 37 Sundrive Park; to the east by No. 30 Mount Argus Park, No. 14 Mount Argus Crescent and by Eamon Ceannt Park to the north. The application site includes the laneway to the south west of the application site. The Proposed Development comprises of the construction of 9 no. residential units, comprising 3 no. two bed two-storey houses to the southern end of the site and 3 no. three-storey duplex units to the northern end of the site, comprising 1 no. one bedroom apartment at ground floor of each (3 no. one bedroom units in total), and 3 no. two bedroom apartments at first and second floor of each (3 no. two-bedroom units in total). Each duplex unit comprises of a balcony/ terrace at first floor to the north elevation. The total gross floorspace of the Proposed Development is 765 sq.m. The Proposed Development includes 10 no. surface car parking spaces, 10 no. resident and visitor bicycle parking spaces, an enclosed refuse storage area, an enclosed refuse storage area, all associated and ancillary works including hard and soft landscaping, upgrades/ repairs to existing boundaries, provision of a controlled pedestrian access/ egress in the existing northern boundary wall to provide access to Eamon Ceannt Park to residents of the Proposed Development, and all associated site infrastructure works, including works to the laneway to the south-west of the site. (Decision date: 04-May-2018. Distance to Site c. 1.2 km).
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6.5.2 Relevant policies and plans Plans and policies that may result in possible in-combination effects with the Proposed Development include:
- Dublin City Biodiversity Action Plan 2015 ‐ 2020
- Dublin City Development Plan 2016-2022
- Dublin City Council Development Plan 2016-2022 Appropriate Assessment
The Dublin City Biodiversity Action Plan 2015 ‐ 2020 is set out to protect and improve biodiversity, and as such will not result in negative in-combination effects with the Proposed Development. There is potential for proposed plans and projects within the Dublin City Development Plan 2016-2022 land area, to have cumulative, negative impacts on conditions in Dublin Bay via rivers, other surface water features and foul waters treated at Ringsend WWTP and discharged into Dublin Bay. However, the core strategy, policies and objectives of the Dublin City Development Plan have been developed to anticipate and avoid the need for developments that would be likely to significantly affect the integrity of any European site. Furthermore, such developments are required to conform to the relevant regulatory provisions for the prevention of pollution, nuisance or other environmental effects likely to significantly affect the integrity of Natura 2000 sites (Dublin City Development Plan 2016–2022: Appropriate Assessment). In addition, sustainable development including SuDS measures for all new developments is inherent in the objectives of all development plans within the Greater Dublin Area. Therefore, there is no potential for in-combination impacts to arise due to surface water discharges during the Construction and Operational Phases of the Proposed Development.
Given that work has not commenced on the redevelopment of the existing Crumlin Shopping Centre (planning permission has expired), the large distances (>1km) and urban buffer between the remaining aforementioned large-scale developments in the area and the Proposed Development Site, as well as the aforementioned elements of the Dublin City Development Plan, there is no potential for significant in-combination impacts to arise as a result of the Proposed Development.
6.5.3 Operation of Ringsend WwTP In June 2018 Irish Water applied for (and subsequently received) planning permission for upgrade works to the Ringsend Wastewater Treatment (WwTP) facility. These are currently on-going and will increase the capacity of the facility from 1.6 million PE to 2.4 million PE. This plant upgrade will result in an overall reduction in the final effluent discharge of several parameters from the facility including BOD, suspended soils, ammonia, DIN and MRP. An Environmental Impact Assessment Report (EIAR) was submitted by Irish Water as part of this application. The EIAR contains sections relating to Marine Biodiversity and Terrestrial Biodiversity, and each contains a section on the ‘do-nothing scenario’. These review the effects of the WwTP on biodiversity in Dublin Bay in the absence of the upgrade works and so are relevant to this report.
The EIAR report acknowledges that under the do-nothing scenario “the areas in the Tolka Estuary and North Bull Island channel will continue to be affected by the cumulative nutrient loads from the river Liffey and Tolka and the effluent from the Ringsend WwTP”, which could result in a decline in biodiversity (Irish Water, 2018). Nevertheless, the negative impacts of
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Enviroguide Consulting Strategic Housing Development Ecological Impact Assessment Report Brickfield Drive, Crumlin, Dublin 12 nutrient over-enrichment, which could result in the deterioration of the biological status of Dublin Bay are considered “unlikely” (Irish Water, 2018). This is because historical data suggests that pollution in Dublin Bay has had little or no effect on the composition and richness of the benthic macroinvertebrate fauna. The EIAR notes that “although a localised decline could occur, it is not envisaged to be to a scale that could pose a threat to the shellfish, fish, bird or marine mammal populations that occur in the area.” Furthermore, the EIAR notes that significant impacts on waterbird populations foraging on invertebrates in Dublin Bay due to nutrient over-enrichment are “unlikely” to occur (Irish Water, 2018). What is important in the context of this EcIA is that the do-nothing scenario predicts that nutrient and suspended solid loads from the WwTP will “continue at the same levels and the impact of these loadings should maintain the same level of effects on marine biodiversity” and that “if the status quo is maintained there will be little or no change in the majority of the intertidal faunal assemblages found in Dublin Bay which would likely continue to be relatively diverse and rich across the bay.”
Therefore, it can be concluded that significant effects on marine biodiversity and the Natura 2000 sites within Dublin Bay from the current operation of Ringsend WwTP are unlikely. Importantly, this conclusion is not dependent upon any future works to be undertaken at Ringsend. Thus, in the absence of any upgrading works, significant effects to habitats, fauna and Natura 2000 sites are not likely to arise.
On examination of the above it is considered that there are no means for the Proposed Development to act in-combination with any plans or projects.
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7 MITIGATION AND ENHANCEMENT MEASURES
7.1 Designated sites The mitigation measures outlined in the NIS accompanying this application will ensure that the potential impacts on designated sites within Dublin Bay are negligible.
7.2 Waterbodies It is essential that appropriate mitigation is adhered to throughout the Construction and Operational Phases of the Proposed Development to protect waterbodies hydrologically linked with the Site. Lack of mitigation on construction sites leading to localised pollution of watercourses has been highlighted as a key existing environmental issue relating to biodiversity, flora and fauna in the Strategical Environmental Assessment (SEA) for the Dublin City Development Plan 2016-2022. The following mitigation measures for the protection of surface waters are also outlined in the NIS accompanying this application.
7.2.1 Surface water
7.2.1.1 Construction Phase The following measures set out below will protect surface waters throughout the Construction Phase:
General Surface water mitigation measures
• Any imported materials will, as much as possible, be placed on site in their proposed location and double handling will be avoided. Where this is not possible designated temporary material storage areas will be used.
• Refuelling of plant during Construction Phase will only be carried out at designated refuelling station locations on site. Each station will be fully equipped for spill response and a specially trained and dedicated Environmental and Emergency Spill Response team will be appointed before the commencement of works on site.
• Only emergency breakdown maintenance will be carried out on site. Drip trays and spill kits will be available on site to ensure that any spills from vehicles are contained and removed off site.
• All personnel working on site will be trained in pollution incident control response.
• Any other diesel, fuel or hydraulic oils stored on site will be stored in bunded storage tanks- the bunded area will have a volume of at least 110% of the volume of the stored materials as per best practice guidelines (Enterprise Ireland, BPGCS005).
• Portaloos and/or containerised toilets and welfare units will be used to provide facilities for site personnel. All associated waste will be removed from site by a licenced waste disposal contractor.
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• Runoff from machine service and concrete mixing areas will not enter the nearby drainage network. • Storm drain inlets which could receive stormwater from the project will be protected throughout the Construction Phase. Inlet protection will be installed before soil- disturbing activities begin. All wastewater generated on-site during the Construction Phase will be stored and disposed of appropriately. Under no circumstances will any untreated wastewater generated onsite (from equipment washing, road sweeping etc.) be released into the foul/surface water drainage network.
Contaminated soils if encountered will be segregated. If dewatering is required groundwater will be treated as required prior to discharge as agreed with Local Authority.
7.2.1.2 Operational Phase A suite of Sustainable Urban Drainage Systems will be incorporated into the development design. The surface water drainage design for the Site will comply with the Greater Dublin Strategic Drainage Strategy (GDSDS).
7.2.2 Groundwater Shallow groundwater may be encountered during the construction works of the basement excavation. Disposal of this water to sewer will require, a consent/licence issued under Section 16 of the Local Government (Water Pollution) Acts and Regulations and must be obtained from Irish Water. Any such discharge licence is likely to be subject to conditions regarding the flow (rates of discharge, quantity etc.); effluent quality prior to discharge and pre-treatment (e.g. settlement/filtration, hydrocarbon separation etc.) and monitoring requirements. All dewatering will be undertaken in strict compliance with the conditions of the discharge licence for the project.
7.3 Habitats and Flora The existing boundary trees to the rear and side of no. 27 Brickfield Drive will be retained. In addition, it is proposed to retain a line of self-seeded Sycamore trees which are growing along the south-western boundary wall.
The proposed landscaping for the Site includes the planting of various trees, hedgerows and shrubs as well as ornamental shrubs and understorey plants. Landscape planting has been designed in such a way that trees and high-hedges planted around the boundary of the site will form a treeline/hedgerow (Figure 9). The hedgerow to be planted will consist of native hawthorn. This additional planting will result in positive, permanent, moderate impacts for local biodiversity.
Furthermore, the well-established shrub borders at the northern boundary of the Site will be retained as much as reasonably possible to allow for suitable hedgehog habitats. This will also be complemented with new planting of hawthorn and a wildlife corridor consisting of a range of “pollinator friendly” species (Figure 9, Table 13) and wood piles.
A large proportion of the trees and shrubs to be planted are non-native (Table 13). Nevertheless, according to the All-Ireland Pollinator Plan, non-native horticultural or ornamental plants, when planted in towns and villages (not in natural or semi-natural habitats),
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Enviroguide Consulting Strategic Housing Development Ecological Impact Assessment Report Brickfield Drive, Crumlin, Dublin 12 can be an important additional food source for pollinators (All-Ireland Pollinator Plan 2015- 2020). The majority of the proposed trees, hedgerows and shrubs are considered “pollinator- friendly” by either the RHS, the All-Ireland Pollinator Plan or both (Table 13).
7.4 Fauna
7.4.1 Reduction of noise and dust related impacts Reduction of noise impacts
Short-term increases in disturbance levels as a direct result of human activity and through increased generation of noise during the Construction Phase can have a range of impacts depending upon the sensitivity of the ecological receptor, the nature and duration of the disturbance and its timing.
Noise generated during the Construction Phase of the Proposed Development could cause temporary disturbance to a number of faunal species in the vicinity of the Site of the Proposed Development. To mitigate this disturbance, the following measures will be implemented:
• Selection of plant with low inherent potential for generating noise. • Siting of plant as far away from sensitive receptors as permitted by site constraints. • Avoidance of unnecessary revving of engines and switch off plant items when not required. • Keep plant machinery and vehicles adequately maintained and serviced. • Proper balancing of plant items with rotating parts. • Keep internal routes well maintained and avoid steep gradients. • Minimise drop heights for materials or ensure a resilient material underlies. • Use of alternative reversing alarm systems on plant machinery. • Where noise originates from resonating body panels and cover plates, additional stiffening ribs or materials should be safely applied where appropriate. • Limiting the hours during which site activities likely to create high levels of noise are permitted. • Appointing a site representative responsible for matters relating to noise. • Monitoring typical levels of noise during critical periods and at sensitive locations.
These measures will ensure that any noise disturbance to nesting birds or any other fauna species in the vicinity of the Site of the Proposed Development will be reduced to a minimum.
Reduction of dust related impacts
The following general dust control measures will be followed for the duration of the Construction Phase of the Proposed Development and will ensure no significant dust related impacts occur to nearby sensitive receptors including local faunal species. A detailed Dust Minimisation Plan is provided in the NIS accompanying this application.
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• In situations where the source of dust is within 25m of sensitive receptors screens (permeable or semi-permeable) will be erected. • Haulage vehicles transporting gravel and other similar materials to site will be covered by a tarpaulin or similar. • Access and exit of vehicles will be restricted to certain access/exit points. • Vehicle speed restrictions of 20km/hr will be in place. • Bowsers will be available during periods of dry weather throughout the construction period. • During dry and windy periods, and when there is a likelihood of dust nuisance, a bowser will operate to ensure moisture content is high enough to increase the stability of the soil thereby reducing the amount of dust. • Stockpiles will be stored in sheltered areas of the site, covered, and watered regularly or as needed if exposed during dry weather. • Gravel should be used at site exit points to remove caked-on dirt from tyre tracks. • Equipment should be washed at the end of each work day. • Hard surfaced roads will be wet swept to remove any deposited materials. • Unsurfaced roads will be restricted to essential traffic only. • If practical, wheel-washing facilities should be located at all exits from the construction sites. • Dust production as a result of site activity will be minimised by regular cleaning of the site access roads using vacuum road sweepers and washers. Access roads should be cleaned at least 0.5km on either side of the approach roads to the access points. • Public roads outside the site shall be regularly inspected for cleanliness, as a minimum daily, and cleaned as necessary. A road sweeper will be made available to ensure that public roads are kept free of debris. • The frequency of cleaning will be determined by the site agent and is weather and activity dependent • The height of stockpiles will be kept to a minimum and slopes should be gentle to avoid windblown soil dust. • The following will be dampened during dry weather: o Unpaved areas subject to traffic and wind o Stockpiles o Areas where there will be loading and unloading of dust-generating materials • Under no circumstances should wastewater from equipment, wheel or surface cleaning enter the surface water drainage network.
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7.4.2 Mammals excl. bats There will be a minor loss of habitat for mammals potentially utilising the Site through the loss of scrub habitat. However, the landscaping design involves the planting of new hedgerows and trees around the majority of the Site boundary, which will ultimately increase the amount of linear vegetative habitat at the Site of the Proposed Development. Furthermore, the well- established shrub borders at the northern boundary of the Site will be retained as much as reasonably possible to create a biodiversity corridor and allow for suitable hedgehog habitats. This will also be complemented with new planting of native hawthorn and wildflowers.
As part of the landscape plan, it is proposed that 5 no. hedgehog highways are placed along the boundary wall to Brickfield Park, in order to improve connectivity between the Site and the park. Ground-level boundary holes will measure 13x13cm and will establish links between the new biodiversity corridor and the adjacent landscape within Brickfield park3.
It is recommended that any biodiversity features (e.g. wildflower meadows and hedgehog highways) are sign posted to raise awareness of them for biodiversity education purposes and also to prevent future management from reversing these features, e.g. blocking the holes in the wall or mismanaging a wildflower meadow. Hedgehog Highway plaques can be purchased from both People’s Trust for Endangered Species (PTES) and British Hedgehog Preservation Society (BHPS) online stores (Figure 10).
FIGURE 10. EXAMPLE OF A HEDGEHOG HIGHWAY IN A CONCRETE WALL AND THE SIGNAGE AVAILABLE FOR IT.
As noted in the British Hedgehog Preservation Society’s publication Hedgehogs and development, during the Construction Phase of the Proposed Development Hedgehogs have the potential to be significantly impacted through the loss of suitable hibernation and nest sites in the form of piles of dead wood, vegetation and leaves. This can be mitigated through the careful removal of dead wood/leaves to another part of the Site where they will not be affected.
3 https://www.britishhedgehogs.org.uk/wp-content/uploads/2019/03/Hedgehog-Street-HEMP-guide.pdf
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Woody debris from the proposed clearance of vegetative areas on site can also be left in this out-of-the way location as compensatory Hedgehog habitat during the Construction and Operational Phases. Work likely to cause disturbance during hibernation – for example removal of hibernation habitats such as log piles and dense scrub – ideally should not take place during November to March unless under the supervision of a qualified ecologist.
As best-practice, all construction-related rubbish on site e.g. plastic sheeting, netting etc. should be kept in a designated area on site and kept off ground level so as to protect small mammals from entrapment and death.
7.4.3 Bats Given that some trees are to be retained as part of the proposal, and that it is unlikely that bats utilise the existing buildings there will be no significant loss of habitat for bats. In addition, the landscaping design involves the planting of new hedgerows and trees around the majority of the site boundary, which will ultimately increase the amount of linear vegetative habitat at the Site of the Proposed Development.
As noted in the Bat Survey Report (2021), the majority of bat activity is associated with Brickfield Park which lies adjacent to the Site. The Site itself is considered to be of Lower Importance for bats for the following reasons:
• The Site is currently well lit up. • A small number of trees (3) with low/moderate bat potential were identified with limited bat activity in their vicinity. • The buildings onsite have low bat potential. A series of recommendations to minimise disturbance to bats utilising the Site in general are provided in the Bat Survey Reports (2020 and 2021) appended to this document.
The public lighting design has addressed these recommendations, specifically:
• There will be an avoidance of the use of direct lighting onto the trees at Brickfield park as well as any hedgerows that will be planted along the boundary of the Site
• All lights are full shut off fitting, i.e. designed not to spill light
• No floodlighting will be used
• Poles have been kept to a minimum height for compliance (4m)
• Lights have been selected at minimum output for efficiency and light pollution.
• Luminaires have latest LED technology and UV components for efficiency and light distribution.
In order to minimise disturbance to bats utilising the Site in general, the lighting has been designed to minimise light-spill onto habitats both within and adjacent to it that are used by the local bat population for foraging or commuting. It is noted that the public lighting design references best practice guidelines as outlined in the Bat Survey Report. Careful consideration has been given to the design of Public Lighting with regard to the existing natural habitat and the wildlife (Fallon Design M&E Engineering, Public Lighting Report). The chosen luminaire Veelight Tech Series has a full cut off lantern type, that offers with a G6 Glare rating and no
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Enviroguide Consulting Strategic Housing Development Ecological Impact Assessment Report Brickfield Drive, Crumlin, Dublin 12 upward light making it dark sky friendly. An inbuilt multi step dimming program within this luminaire allows for night time hours to be dimmed by up to 25%. This means during peak hours of nocturnal foraging, feeding and activity the adjacent public lighting can be further designed to minimize impact on the local wildlife. The colour rendering of the selected light fitting is 3000k making the LED fittings a warmer light, helping to further minimize the impact on the local wildlife (Fallon Design M&E Engineering, Public Lighting Report).
Importantly, as noted in the Public Lighting Report, an important aspect of the lighting design is the avoidance of the use of direct lighting onto the trees at Brickfield park as well as any hedgerows that will be planted along the boundary of the Site. Four-meter poles along with low level recessed ramp lighting for the creche walkway have been selected, which will minimize light pollution into the park and any potential impact to the natural wildlife (Fallon Design M&E Engineering, Public Lighting Report).
Of the 37no. trees on the Site, a total of 20no. trees are recommended for removal. Of these, 16no. trees have no bat potential, 1no. tree has ‘Low’ potential and 3no. trees have ‘Low/Moderate’ potential. The following protocol will be followed for trees classed as ‘Low/Moderate’:
• Tree-felling will ideally be undertaken in the period late August to late October/early November. During this period bats are capable of flight and may avoid the risks of tree- felling if proper measures are undertaken.
• Felling during the winter months will ideally be avoided as this creates the additional risk that bats may be in hibernation and thus unable to escape from a tree that is being felled. Additionally, disturbance during winter may reduce the likelihood of survival as the bats’ body temperature is too low and they may have to consume too much body fat to survive.
• Tree-felling can be undertaken using heavy plant and chainsaw. There is a wide range of machinery available with the weight and stability to safely fell a tree. Normally trees are pushed over, with a need to excavate and sever roots in some cases. In order to ensure the optimum warning for any roosting bats that may still be present, an affected tree will be pushed lightly two to three times, with a pause of approximately 30 seconds between each nudge to allow bats to become active. Any affected trees will then be pushed to the ground slowly and should remain in place for a period of at least 24 hours, and preferably 48 hours to allow bats to escape.
• Trees which have been identified as having low/moderate bat potential should not be sawn up or mulched immediately.
• A derogation licence from the National Parks and Wildlife Services (NPWS) may be required for felling if, during tree removal works bats are found to be roosting in any affected trees.
A total of 10+ bat boxes will be erected on trees around the Site to provide future roosting opportunities.
7.4.4 Birds Any clearance of vegetation will ideally be carried out outside the main breeding season, i.e. 1st March to 31st August, in compliance with the Wildlife Act 2000. Should any vegetation removal be required during this period, this vegetation will be checked for bird nests, and if
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Enviroguide Consulting Strategic Housing Development Ecological Impact Assessment Report Brickfield Drive, Crumlin, Dublin 12 any are noted during this evaluation prior to removal, a derogation licence will be required from the NPWS. This would note the section of habitat that is a nest site, the precise location within the hedgerow/trees, the species of bird present; and also elaborate the means by which the birds would be protected prior to nest removal. If eggs have been laid, the nest will be protected until the young have fledged after which time the nest could be destroyed (under licence from the NPWS only). This would also require further compensatory measures including nesting sites for birds if practicable.
Regarding potential collisions with birds, a building design comprising total window surface area of 25-40 percent relative to the entire facade (low window to wall ratio) can reduce fatal bird collisions (Toronto City’s Bird-Friendly Best Practice: Glass). The design of blocks A, B, C and D results in a total window surface area of between 22.2% and 51.4% relative to the entire facade on all elevations (Figure 11). Several of the facades exceed the recommended range of 25-40%, however, there are numerous balconies and setbacks which provide visual cues for birds to avoid, as well as reduce the amount of visible glass and the corresponding collision threat. In addition to the protruding balcony structures, glazing with a low reflective index will be installed to reduce reflections. The projecting balconies should reduce the reflection on the windows and the setback will introduce a shadow as a visual marker. As part of the design evolution, elimination of potential fly-through conditions in all blocks will reduce the potential collision hazards the development presents to birds. The public area of Block C presents a collision risk with increased levels of glazing. To address this issue, coping and transparent bands have been added to the facade to reduce the transparency. Elements such as perpendicular corners have been removed from the design, and additional fritting and fenestration of the glazed panels will be included. These measures coupled with the built-up nature of the immediate area (it is surrounded by buildings to the north, east, west and south- west) will reduce the collision risk within this area to negligible.
FIGURE 11. TOTAL WINDOW SURFACE AREA RELATIVE TO THE ENTIRE FAÇADE ON ALL ELEVATIONS (PROVIDED BY JOHN FLEMMING ARCHITECTS).
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7.5 Planting of native flora and protecting pollinators The planting of native flora will improve local biodiversity and increase insect abundance. This will provide additional food for bats and birds at the Site. Actions which can be taken to boost pollinators include:
• Protecting areas that are already providing food and shelter for pollinators
• Reducing the frequency of the mowing regime (during the Operational Phase)
• Planting native, pollinator friendly species (in lawns, containers, flowerbeds etc)
• Providing nesting habitat for insects (e.g. hedgerows, earth banks for solitary mining bees, installing (and maintaining) a bee hotel)
• Reducing the use of pesticides (during the Operational Phase). Particularly around edging, the base of trees hedgerows and earth-banks.
7.6 Invasive Species To prevent the spread of Butterfly Bush within and outside the Site boundary management options for its removal are provided below:
The Butterfly Bush is a member of the Buddlejaceae family. It is very fast growing and can reach 2m in its first year, producing flowers and setting seed. As Butterfly Bush tolerates very poor soils, it is capable of growing on walls, rock outcrops or sub-soils (NRA, 2010). The following is based on NRA (2010) guidelines:
Management methods such as digging it out are applicable only to minor infestations at the initial stage of invasion. Hand-picking of young plants is feasible but should be undertaken with care to avoid soil disturbance which can give rise to a flush of new seedling. Grubbing of mature stands as a sole attempt at control is not recommended for the same reason. After uprooting, it is essential to plant the ground in order to prevent a flush of new seedling growth. When it is cut, Buddleia grows back from the stump very vigorously. Mowing of young plants does not provide control as they re-sprout with vigour. Where removal of mature plants is not feasible in the short term, the flower heads should be cut off in June before seed set. Chemical control recommended practice for the application of herbicides requires cutting back of plants to a basal stump during active growth (late spring to early summer) which is then treated (brushed on) immediately with a systemic weed killer mix (Starr et al, 2003). Foliar application of approved herbicides may be adequate for limited infestations of younger plants, but should be followed up at 6 monthly intervals. At this point it must be stressed that all Plant Protection Products must be used in accordance with the product label and with Good Plant Protection Practice as prescribed in the European Communities (Authorization, Placing on the Market, Use and Control of Plant Protection Products) Regulations, 2003 (S.I. No. 83 of 2003). Again, it should be noted that it is an offence to use Plant Protection Products in a manner other than that specified on the label. The methods outlined are not in accordance with the product label and so it will be necessary to discuss the use of such methods with the Pesticides Control Service with a view to seeking approval under the derogation procedures provided under the Plant Protection Regulations.
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7.7 Biosecurity The following will be adhered to, to avoid the introduction of invasive species to the Proposed Development site.
• Any material required on the site will be sourced from a stock that has been screened for the presence of any invasive species by a suitably qualified ecologist and where it is confirmed that none are present. • All machinery will be thoroughly cleaned and disinfected prior to arrival on site to prevent the spread of invasive species.
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8 RESIDUAL IMPACTS
Residual impacts are impacts that remain once mitigation has been implemented or impacts that cannot be mitigated. Table 13 provides a summary of the impact assessment for the identified Key Ecological Resources (KERs) and details the nature of the impacts identified, mitigation proposed and the classification of any residual impacts.
Provided all mitigation measures are implemented in full and remain effective throughout the lifetime of the Development, no significant negative residual impacts on the local ecology or on any designated nature conservation sites are expected from the Proposed Development.
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TABLE 14. SUMMARY OF POTENTIAL IMPACTS ON KER(S), MITIGATION PROPOSED AND RESIDUAL IMPACTS.
Key Level Potential Impact Impact Without Mitigation Proposed Mitigation Residual Ecological of Impact Resource Significance Magnitude / Quality Duration Significance Extent
Designated Sites
Mitigation measures are addressed in the NIS.
Habitats
Loss and/or damage to some Negative Permanent Moderate Some existing trees and Negligible sections of habitat during hedgerows to be retained. Local Construction Phase. Treelines importance Local Permanent; (WL2) (higher value) Supplementing of existing Positive Permanent Significant Additional planting of shrub and Positive treelines and hedgerows via tree species to take place as part additional planting of project design.
Loss and/or damage to some Negative Permanent Moderate Well established sections of the Negligible sections of habitat during habitat to be retained, where Construction Phase. possible, at the northern boundary Ornamental/ Local of the Site. Non-native importance Local shrub (WS3) (higher value) Supplementing of existing Positive Permanent Significant Additional planting of shrub and Permanent; treelines and hedgerows via tree species to take place as part Positive additional planting of project design.
Mammals
Loss and/or damage to some Permanent Slight Some existing trees and Permanent; Mammals National sections of hedgerow habitat. Negative Local hedgerows to be retained. Well Positive (Hedgehog, Importance established sections of the
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Key Level Potential Impact Impact Without Mitigation Proposed Mitigation Residual Ecological of Impact Resource Significance Magnitude / Quality Duration Significance Extent pygmy ornamental/non-native shrub shrew) habitat to be retained, where possible, at the northern boundary of the Site. Additional planting of shrub and tree species to take place as part of project design. Hedgehog highways to be installed at northern boundary of the Site,
Disturbance due to noise, Short-term Slight Construction related noise Negligible landscaping during Construction control/minimisation measures to Phase. be implemented.
Possible mortality due to Short-term Significant Incorporation of protective Negligible construction site hazards (Plastic mitigation measures to reduce sheeting etc.). impact of Construction Phase.
Some existing trees and Negligible Potential loss and/or damage to hedgerows to be retained. some sections of potential Additional planting of shrub and roosting, foraging and commuting tree species to take place as part Moderate habitat. of project design.
Bat International assemblage Importance Permanent Bat sensitive lighting measures Positive; Negative Local Disturbance/removal of foraging implemented during Construction long-term Moderate routes/habitat due to increased Phase, and incorporation of lighting as a result of the measures described in section Proposed Development. 7.4.3.
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Key Level Potential Impact Impact Without Mitigation Proposed Mitigation Residual Ecological of Impact Resource Significance Magnitude / Quality Duration Significance Extent
Placement and maintenance of bat boxes (minimum 10) on trees along the Site boundary.
Birds
Loss and/or damage to some Negative Permanent Moderate Some existing trees and Positive; sections of potential foraging hedgerows to be retained. Well Permanent. habitat during Construction established sections of the Phase. ornamental/non-native shrub Bird County habitat to be retained, where assemblage Importance possible, at the northern boundary (Green-listed) of the Site. Additional planting of shrub and tree species to take place as part of project design. Ideally no removal of vegetation to Local take place during the nesting season.
Construction related noise Disturbance due to noise Negative Short-term Slight control/minimisation measures to Negligible. Bird generated during Construction be implemented. National assemblage Phase. Importance (Amber-listed) Bird-friendly design features Potentially fatal collisions with Negative Permanent Signficant incorporated into final project Negligible. proposed buildings. design will ensure no significant risk of collisions.
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9 CONCLUSION
It is considered that provided the mitigation measures proposed are carried out in full, there will be no significant negative impact to any valued habitats, designated sites or individual or group of species as a result of the Proposed Development.
Based on the successful implementation of these measures and proposed works, to be carried out in accordance with the landscape plan, there will be no significant negative ecological impacts arising from Construction and Operational Phases of the Proposed Development.
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10 REFERENCES
Bat Conservation Ireland. (2014). Bats in Buildings, Guidance Notes for: Planners, engineers, architects and developers.
Central and Regional Fisheries Boards. 2008. Sampling Fish for the Water Framework Directive – Transitional Waters 2008. Liffey Estuary.
CIEEM. (2018). Guidelines for Ecological Impact Assessment in the UK and Ireland: Terrestrial Freshwater, Coastal and Marine. Chartered Institute of Ecology and Environmental Management, Winchester, UK.
City of Toronto. (2016). Bird-Friendly Best Practices: Glass. City Planning, Toronto, Canada.
City of Toronto. (2017). Best Practices Effective Lighting. City Planning, Toronto, Canada.
Department of the Environment, Heritage and Local Government. (2010). Appropriate Assessment of Plans and Projects in Ireland: Guidance for Planning Authorities. DEHLG, Dublin. (Rev. Feb 2010).
Dublin City Council (DCC). (2019). Basement Development Guidance Document Version 1.0. [ONLINE]. Available at: https://www.dublincity.ie/sites/default/files/content/Planning/Documents/Basement/Basement DevelopmentGuidanceDocument.pdf
Eastern Regional Fisheries Board. (2004). Requirements for the Protection of Fisheries Habitat during Construction and Development Works at River Sites. Blackrock, Dublin, Ireland.
Environmental Protection Agency. (2017). Guidelines on the information to be contained in Environmental Impact Assessment Reports (Draft). Published by the Environmental Protection Agency, Ireland.
Environmental Protection Agency. (2020). Environmental Protection Agency Online Mapping [ONLINE] Available at: http://www.epa.ie/ [Accessed April 2020].
European Commission. (2000). Managing Natura 2000 Sites: The Provisions of Article 6 of the ‘Habitats’ Directive 92/43/EEC. European Communities, Luxembourg.
European Communities. (2002). Assessment of Plans and Projects Significantly Affecting Natura 2000 Sites: Methodological Guidance on the Provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC. European Communities, Luxembourg.
Fossitt, J. (2000). A Guide to Habitats in Ireland. The Heritage Council, Kilkenny.
Gauthreaux, S. A., and Belser, C. G. (2006). Effects of artificial night lighting on migrating birds. Pages 67–93 in C. Rich and T. Longcore, editors. Ecological consequences of artificial night lighting. Island Press, Washington, D.C., USA.
Geological Survey Ireland. (2020). Geological Survey of Ireland website [ONLINE] Available at: http://www.gsi.ie/ [Accessed April 2020].
Greater Dublin Strategic Drainage Study. (2005). Final Strategy Report. [ONLINE] Available at: http://www.greaterdublindrainage.com/wp-content/uploads/2011/11/GDSDS- Final-Strategy-Report-April-051.pdf [Accessed May 2020].
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Gilbert, G., Stanbury, A and Lewis, L. (2021). Birds of Conservation Concern in Ireland 4: 2020–2026. Irish Birds. 43:1-22
Igoe F., Quigley D.T.G., Marnell F., Meskell E., O’Connor W. & Byrne C. 2004. The sea lamprey Petromyzon marinus (L.), river lamprey Lampetra fluviatilis (L.) and brook lamprey Lampetra planeri (Bloch) in Ireland: General biology, ecology, distribution and status with recommendations for conservation. Biology and Environment 104: 43–56.
Inland Fisheries Ireland. (2016). Guidelines on Protection of Fisheries During Construction Works in and Adjacent to Waters. Available at: https://www.fisheriesireland.ie/documents/624- guidelines-on-protection-of-fisheries-during-construction-works-in-and-adjacent-to- waters/file.html
Institute of Lighting Professionals (ILP). (2018). Guidance note 08/18: Bats and artificial lighting in the UK. Bats and the Built Environment Series. [Online] Available at: https://cdn.bats.org.uk/pdf/Resources/ilp-guidance-note-8-bats-and-artificial-lighting- compressed.pdf?mtime=20181113114229
Kelleher, C. and Marnell, F. (2006). Bat Mitigation Guidelines for Ireland. Irish Wildlife Manuals, No. 25. National Parks and Wildlife Service, Department of Environment, Heritage and Local Government, Dublin, Ireland.
Kelly, F.L., Harrison, A., Matson, R., Connor, L., O’Callaghan, R., Feeney, R., Morrissey, E., E., Wogerbauer, C. and Rocks, K. 2010. Sampling Fish for the Water Framework Directive, Transitional Waters 2010, Liffey Estuary. Inland Fisheries Ireland, 3044 Lake Drive, Citywest Business Campus, Dublin 24, Ireland.
Kelly, F.L., Matson, R., Connor, L., Feeney, R., Morrissey, E., Wogerbauer, C. and Rocks, K. (2012). Water Framework Directive Fish Stock Survey of Rivers in the Eastern River Basin District. Inland Fisheries Ireland, Swords Business Campus, Swords, Co. Dublin, Ireland.
Kelly, F.L., Connor, L., Matson, R., Feeney, R., Morrissey, E., Coyne, J. and Rocks, K. (2015). Sampling Fish for the Water Framework Directive, Rivers 2014. Inland Fisheries Ireland, 3044 Lake Drive, Citywest Business Campus, Dublin 24, Ireland.
King, J.L., Marnell, F., Kingston, N., Rosell, R., Boylan, P., Caffrey, J.M., FitzPatrick, Ú., Gargan, P.G., Kelly, F.L., O’Grady, M.F., Poole, R., Roche, W.K. & Cassidy, D. (2011). Ireland Red List No. 5: Amphibians, Reptiles & Freshwater Fish. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht, Dublin, Ireland.
Lundy, M.G., Aughney, T., Montgomery, W.I., & Roche, N. (2011). Landscape conservation for Irish bats and species specific roosting characteristics. Bat Conservation Ireland.
Macklin, R., Brazier, B. & Sleeman, P. (2019). Dublin City otter survey. Report prepared by Triturus Environmental Ltd. for Dublin City Council as an action of the Dublin City Biodiversity Action Plan 2015- 2020.
Matson, R., Delanty, K., Gordon, P., O’Briain, R., Garland, D., Cierpal, D., Connor, L., Corcoran, W., Coyne, J., McLoone, P., Morrisey-McCaffrey, E., Brett, T., Ní Dhonnabhain, L. and Kelly, F.L. (2018). Sampling Fish in Rivers 2017 – Camac, Factsheet No. 3. National Research Survey Programme. Inland Fisheries Ireland.
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NBDC. (2020). National Biodiversity Data Centre online mapping [ONLINE]. Available at: http://maps.biodiversity.ie/Map.aspx. [Accessed April 2020].
NPWS. (2009a). Grand Canal pNHA Site Synopsis.
NPWS. (2009b). Booterstown Marsh pNHA Site Synopsis.
NPWS. (2010). Circular NPW 1/10 & PSSP 2/10. Appropriate Assessment under Article 6 of the Habitats Directive: Guidance for Planning Authorities. Department of Environment, Heritage and Local Government.
NPWS. (2012). Conservation Objectives: Baldoyle Bay SAC [000199]. Version 1.0. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.
NPWS. (2013a). The Status of Protected EU Habitats and Species in Ireland. Overview Volume 1. Unpublished Report, National Parks & Wildlife Services. Department of Arts, Heritage and the Gaeltacht, Dublin, Ireland. Editor: Deirdre Lynn
NPWS. (2013b). Conservation Objectives: South Dublin Bay SAC [000210]. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.
NPWS. (2013c). Conservation Objectives: North Dublin Bay SAC [000206]. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.
NPWS. (2013d). Conservation Objectives: Rockabill to Dalkey Island SAC [003000]. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.
NPWS. (2016). Conservation Objectives: Howth Head SAC [000202]. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage, Regional, Rural and Gaeltacht Affairs.
NPWS. (2017). Conservation Objectives: Wicklow Mountains SAC [002122]. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage, Regional, Rural and Gaeltacht Affairs.
NPWS. (2018a). Conservation objectives for Glenasmole Valley SAC [001209]. Generic Version 6.0. Department of Culture, Heritage and the Gaeltacht.
NPWS. (2018b). Conservation objectives for Rye Water Valley/Carton SAC [001398]. Generic Version 6.0. Department of Culture, Heritage and the Gaeltacht.
NPWS. (2018c). Conservation objectives for Knocksink Wood SAC [000725]. Generic Version 6.0. Department of Culture, Heritage and the Gaeltacht.
NRA. (2009a). Environmental Assessment and Construction Guidelines. National Roads Authority (now Transport Infrastructure Ireland), Dublin.
NRA. (2009b). Guidelines for Assessment of Ecological Impacts of National Road Schemes. National Roads Authority (now Transport Infrastructure Ireland), Dublin.
NRA. (2010). Guidelines on The Management of Noxious Weeds and Non-Native Invasive Plant Species on National Roads(now Transport Infrastructure Ireland), Dublin.
O’Boyle, S., Trodd, W., Bradley, C., Tierney, D., Wilkes, R., Ní Longphuirt, S., Smith, J., Stephens, A., Barry, J., Maher, P., McGinn, R., Mockler, E., Deakin, J., Craig, M. and
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Gurrie, M. 2019. Water Quality in Ireland 2013-2018. Environmental Protection Agency, Johnstown.
Roundtree, S. (2007). Dublin Bricks & Brickmakers. Dublin Historical Record, 60(1), 61-70.
Smith, G.F., O’Donoghue, P., O’Hora, K. and Delaney, E. (2011). Best practice guidance for habitat survey and mapping. The Heritage Council, Kilkenny.
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APPENDIX I – VALUE OF ECOLOGICAL RESOURCES
The criteria outlined in the table below, taken from the Guidelines for Assessment of Ecological Impacts of National Road Schemes published by the NRA, were used for assigning value to designated sites, habitats and species within the Site of the Proposed Development and surrounding area.
Importance Criteria - ‘European Site’ including Special Area of Conservation (SAC), Site of Community Importance (SCI), Special Protection Area (SPA) or proposed Special Area of Conservation. - Proposed Special Protection Area (pSPA). - Site that fulfills the criteria for designation as a ‘European Site’ (see Annex III of the Habitats Directive, as amended). - Features essential to maintaining the coherence of the Natura 2000 Network. - Site containing ‘best examples’ of the habitat types listed in Annex I of the Habitats Directive. - Resident or regularly occurring populations (assessed to be important at the national level) of the following: - Species of bird, listed in Annex I and/or referred to in Article 4(2) of the Birds Directive; and/or International - Species of animal and plants listed in Annex II and/or IV of the Habitats Importance Directive. - Ramsar Site (Convention on Wetlands of International Importance Especially Waterfowl Habitat 1971). - World Heritage Site (Convention for the Protection of World Cultural & Natural Heritage, 1972). - Biosphere Reserve (UNESCO Man & The Biosphere Programme). - Site hosting significant species populations under the Bonn Convention (Convention on the Conservation of Migratory Species of Wild Animals, 1979). - Site hosting significant populations under the Berne Convention (Convention on the Conservation of European Wildlife and Natural Habitats, 1979). - Biogenetic Reserve under the Council of Europe. - European Diploma Site under the Council of Europe. - Salmonid water designated pursuant to the European Communities (Quality of Salmonid Waters) Regulations, 1988, (S.I. No. 293 of 1988). - Site designated or proposed as a Natural Heritage Area (NHA). - Statutory Nature Reserve. - Refuge for Fauna and Flora protected under the Wildlife Acts. - National Park. - Undesignated site fulfilling the criteria for designation as a Natural Heritage Area (NHA); Statutory Nature Reserve; Refuge for Fauna and Flora protected under the National Wildlife Act; and/or a National Park. Importance - Resident or regularly occurring populations (assessed to be important at the national level) of the following: - Species protected under the Wildlife Acts; and/or - Species listed on the relevant Red Data list. - Site containing ‘viable areas’ of the habitat types listed in Annex I of the Habitats Directive. County - Area of Special Amenity. Importance - Area subject to a Tree Preservation Order.
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- Area of High Amenity, or equivalent, designated under the County Development Plan. - Resident or regularly occurring populations (assessed to be important at the County level) of the following: - Species of bird, listed in Annex I and/or referred to in Article 4(2) of the Birds Directive; - Species of animal and plants listed in Annex II and/or IV of the Habitats Directive; - Species protected under the Wildlife Acts; and/or - Species listed on the relevant Red Data list. - Site containing area or areas of the habitat types listed in Annex I of the Habitats Directive that do not fulfil the criteria for valuation as of International or National importance. - County important populations of species, or viable areas of semi-natural habitats or natural heritage features identified in the National or Local BAP (Biodiversity Action Plan), if this has been prepared. - Sites containing semi-natural habitat types with high biodiversity in a county context and a high degree of naturalness, or populations of species that are uncommon within the county. - Sites containing habitats and species that are rare or are undergoing a decline in quality or extent at a national level. - Locally important populations of priority species or habitats or natural heritage features identified in the Local BAP, if this has been prepared; - Resident or regularly occurring populations (assessed to be important at the Local level) of the following: - Species of bird, listed in Annex I and/or referred to in Article 4(2) of the Birds Directive; Local - Species of animal and plants listed in Annex II and/or IV of the Habitats Importance Directive; (Higher - Species protected under the Wildlife Acts; and/or Value) - Species listed on the relevant Red Data list. - Sites containing semi-natural habitat types with high biodiversity in a local context and a high degree of naturalness, or populations of species that are uncommon in the locality; - Sites or features containing common or lower value habitats, including naturalised species that are nevertheless essential in maintaining links and ecological corridors between features of higher ecological value. Local - Sites containing small areas of semi-natural habitat that are of some local Importance importance for wildlife; (Lower - Sites or features containing non-native species that are of some importance in Value) maintaining habitat links.
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APPENDIX II – EPA IMPACT ASSESSMENT CRITERIA
Criteria used to define quality of effects.
In line with the draft EPA Guidelines (EPA, 2017), the following terms are defined when quantifying the quality of effects:
Quality Definition A change which improves the quality of the environment (for example by Positive Effects increasing species diversity; or improving the reproductive capacity of an ecosystem, or by removing nuisances or improving amenities). No effects or effects that are imperceptible, within normal bounds of variation Neutral Effects or within the margin of forecasting error. A change which reduces the quality of the environment (for example, Negative/adverse lessening species diversity or diminishing the reproductive capacity of an Effects ecosystem; or damaging health or property by causing nuisance).
Criteria used to define significance of effects.
In line with the draft EPA Guidelines (EPA, 2017), the following terms are defined when quantifying significance of impacts:
Significance of Effects Definition An effect capable of measurement but without significant Imperceptible consequences. An effect which causes noticeable changes in the character of the Not significant environment but without significant consequences. An effect which causes noticeable changes in the character of the Slight environment without affecting its sensitivities. An effect which alters the character of the environment in a manner Moderate that is consistent with existing and emerging baseline trends. An effect which, by its character, magnitude, duration or intensity Significant significantly alters most of a sensitive aspect of the environment. An effect which, by its character, magnitude, duration or intensity Very significant significantly alters most of a sensitive aspect of the environment. Profound An effect which obliterates sensitive characteristics.
Criteria used to define duration of effects.
In line with the draft EPA Guidelines (EPA, 2017), the following terms are defined when quantifying duration and frequency of effects:
Quality of Effects Definition
Momentary Effects lasting from seconds to minutes
Brief Effects lasting less than a day
Temporary Effects lasting less than a year
Short-term Effects lasting one to seven years
Medium term Effects lasting seven to fifteen years
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Long-term Effects lasting fifteen to sixty years
Permanent Effects lasting over sixty years
Effects that can be undone, for example through remediation or Reversible restoration.
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APPENDIX III – BAT SURVEY REPORT (MAY 2020 & MARCH 2021)
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August
2020
Bat Survey Report
Brickfield House,
Brickfield Drive, Crumlin, Dublin 12
Aisling Walsh M.Sc MCIEEM Trading as Ash Ecology & Environmental Ltd. Tel: 089 4991181 / Company Reg: 630819 / Office:Ash Monine Ecology &Kilfinane, Environmental Co. Limerick Ltd – October / Full membership2019 of the CIEEM Page 1
Bat Survey Report – Brickfield House, Brickfield Drive, Crumlin, Dublin 12.
Contents
1. INTRODUCTION ...... 4 1.1 Purpose of the Report ...... 4 1.2 Competency of Assessor ...... 5 1.3 Bat Legislation ...... 5 2. METHODOLOGY ...... 7 2.1 Information Sources ...... 7 2.2 Desk Study ...... 8 2.3 Bat Survey...... 12 2.4 Landscape Evaluation ...... 16 3. RESULTS ...... 17 3.1 Site Overview ...... 17 3.2 Bat Recordings ...... 17 3.3 Bat Survey Overview ...... 19 3.4 Landscape Evaluation ...... 19 4. RECOMMENDATIONS ...... 20 4.1 Lighting and Bats ...... 20 4.2 Potential Bat Roosts in Trees ...... 21 5. CONCLUSION ...... 21
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Tables Table 1 Historical Bat Records in 10km2 Grid Ref O13 (NBDC website www.nbdc.ie accessed 14/05/2020) Table 2 Suitability of the study area for the bat species found in the Brickfield area (based on the NBDC data) with Irish Red list status indicated Table 3 Classification and Survey Requirements for Bats in Trees Table 4 Bat Results Summary Data–May 11th 2020 between 21.13 and 23.30
Figures Figure 1 Site Location Figure 2 Bat Activity Map with Legend
Appendices Appendix A Bat Data Appendix B Plates
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1. INTRODUCTION
1.1 Purpose of the Report
A Bat Survey was undertaken by Ash Ecology & Environmental Ltd (AEE) on behalf of Enviroguide Consulting as part of a new planning application for a Stategic Housing Development. The site is currently operating as a store for St. James Hospital.
The site is located along Brickfield Drive (Grid Ref: 53.330586, -6.303485) in the townland of Crumlin, Dublin 12, see Figure 1. A bat survey was required to assess the value of the site for bats, namely the existing buildings on the site for demolition.
Figure 1 Site Location
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1.2 Competency of Assessor
This report has been prepared by Ash Ecology & Environmental Ltd (AEE) whose managing director and leading ecologist is Aisling Walsh who is a full member of the Chartered Institute of Ecological & Environmental Management (CIEEM) and whose qualifications include M.Sc. (Dist) in Biodiversity and Conservation (TCD) and B.Sc. (Hons) Zoology (NUIG). Aisling has over 13 years of experience providing environmental consultancy and environmental assessment services. Aisling has written numerous Ecological Impact Assessments (EcIA), Screening for Appropriate Assessment Stage I and Stage II Natura Impact Statement, Environmental Impact Assessments/Statements, Badger Surveys, Bat Surveys, Habitat Surveys. She has also provided input and reviewed Ecological and Environmental assessments for several EIS and EIA Reports and conducted numerous noise surveys for EPA licensed facilities. AEE is listed as a Registered Practice by the CIEEM and a member of Bat Conservation Ireland.
1.3 Bat Legislation
All species and their roost sites are strictly protected under both European and Irish legislation including:
Wildlife Act 1976 and Wildlife (Amendment) Act, 2000 (S.I. No. 38 of 2000); Council Directive on the Conservation of Natural Habitats and of Wild Flora and Fauna 1992 (Council Directive 92/43/EEC); and European Communities (Birds and Natural Habitats) Regulations, 2011-2015.
It is an offence under Section 23 of the Wildlife Acts 1976-2012 and under Section 51 of the European Communities (Birds and Natural Habitats) Regulations, 2011- 2015 to kill a bat or to damage or destroy the breeding or resting place of any bat species. Under the European Communities (Birds and Natural Habitats) Regulations 2011-2015 actions that intentionally or unintentionally harm, damage or destroy a bat or its roosting site are committing an offence. In addition, if it is possible to establish a clear cause-effect relationship between one or more human-induced activities and the deterioration of a breeding site or resting place of a European protected species, then an offence is likely under the regulations. This places an onus of due diligence on anyone proposing to carry out works that might result in such damage, deterioration or destruction. Furthermore, as a signatory to the European Bats Agreement (Agreement on the Conservation of Bats in Europe) 1993, Ireland is required to protect their habitats, requiring the identification and protection from damage or disturbance, of important feeding areas.
All species of bats in Ireland are listed on Schedule 5 of the 1976 Act, and are therefore subject to the provisions of Section 23, which make it an offence to:
1. Intentionally kill, injure or take a bat, 2. Possess or control any live or dead specimen or anything derived from a bat, 3. Wilfully interfere with any structure or place used for breeding or resting by a bat,
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4. Wilfully interfere with a bat while it is occupying a structure or place which it uses for that purpose.
All Irish bat species are listed in Appendix II of the Bern Convention (1979), as species requiring protection. Finally, all but two bat species in Ireland are listed as internationally important in the Irish Red Data Book (Whilde, 1993). Natterer’s bat (Myotis nattereri) and the Whiskered bat (M. mystacinus) are both listed as indeterminate. In the updated red list, Common pipistrelle (Pipistrellus pipistrellus), Soprano pipistrelle (P. pygmaeus) and Nathusius’ pipistrelle (P. nathusii), Brown Long-eared (Plecotus auritus), Lesser Horseshoe (Rhinolophus hipposideros), Daubenton’s (M. daubentoni), Natterer’s and Whiskered bats are listed as “least Concern”, while Leisler’s bat (Nyctalus leisleri) is listed as “Near Threatened” and Brandt’s bat (M. brandtii) is listed as “data deficient” (Marnell et al., 2009). The Greater Horseshoe Bat (R. ferrumequinum) status is not yet determined in Ireland as only one record has been confirmed.
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2. METHODOLOGY
2.1 Information Sources
A desk-based review of information sources was completed. Information contained on the websites of the National Parks and Wildlife Service (NPWS)1 and the National Biodiversity Data Centre (NBDC)2 was reviewed.
The following publications and websites were also reviewed and consulted:
Bat Conservation Ireland https://www.batconservationireland.org/ Bat Roosts in Trees: A Guide to Identification and Assessment for Tree-Care and Ecology Professionals (2018) Bat Conservation Trust (2018) Bats and artificial lighting in the UK Bats and the Built Environment series3 Kelleher, C. & Marnell, F. (2006) Bat Mitigation Guidelines for Ireland. Irish Wildlife Manuals, No. 25. National Parks and Wildlife Service, Department of Environment, Heritage and Local Government, Dublin, Ireland. Bat Conservation Ireland (2012) Bats and Appropriate Assessment Guidelines, Version 1, December 2012. Bat Conservation Ireland, www.batconservationireland.org4 Bat Conservation Trust (2015) Bat Surveys for Professional Ecologists: Good Practice Guidelines 3rd edition Bat Conservation Ireland (2010) Bats & Lighting Guidance Notes for: Planners, engineers, architects and developers5 Best Practice Guidelines for the Conservation of Bats in the Planning of National Road Schemes (National Roads Authority, 2005). Guidelines for the Treatment of Bats during the Construction of National Road Schemes (National Roads Authority, 2005). NPWS (2018) Conservation objectives supporting document – lesser horseshoe bat (Rhinolophus hipposideros)6 Roche, N., Aughney T. and Langton S. (2015) Lesser horseshoe bat: population trends and status of its roosting resource. Irish Wildlife Manuals, No. 85. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht, Ireland7 Marnell, F., Looney, D. & Lawton, C. (2019) Ireland Red List No. 12: Terrestrial Mammals. National Parks and Wildlife Service, Department of the Culture, Heritage and the Gaeltacht, Dublin, Ireland.
1 The National Parks and Wildlife Services map viewer http://webgis.npws.ie/npwsviewer/ 2 The National Biodiversity Data Centre www.NBDC.ie 3 https://www.theilp.org.uk/documents/guidance-note-8-bats-and-artificial-lighting/ 4https://www.batconservationireland.org/wp-content/uploads/2013/09/BCIreland-AA- Guidelines_Version1.pdf 5https://www.batconservationireland.org/wp- content/uploads/2013/09/BCIrelandGuidelines_Lighting.pdf 6https://www.npws.ie/sites/default/files/publications/pdf/Lesser_horseshoe_bat_supporting_docume nt_Jan_2018_V1.pdf 7 https://www.npws.ie/sites/default/files/publications/pdf/IWM85.pdf
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2.2 Desk Study
2.2.1 Previous Records
A desktop review was carried out to identify the previous records of Bat species within the proposed development site and its environs. The study area occurs in 10km2 Grid Square O13. The website the NBDC (www.nbdc.ie) was accessed on 14/05/2020 to establish any previous bat records and shown below in Table 1.
Table 1 Historical Bat Records in 10km2 Grid Square O13 (NBDC website www.nbdc.ie accessed 14/05/2020) Species Name - Common Species Name - Latin Last Documented Record O13 Brown Long-eared Bat Plecotus auritus 25/07/2013 Daubenton's Bat Myotis daubentonii 11/08/2014 Lesser Noctule Nyctalus leisleri 28/05/2016 Nathusius's Pipistrelle Pipistrellus nathusii 15/09/2010 Natterer's Bat Myotis nattereri 30/09/2016 Common Pipistrelle Pipistrellus pipistrellus 03/08/2013 Soprano Pipistrelle Pipistrellus pygmaeus 30/09/2016 Whiskered Bat Myotis mystacinus 13/08/2007
2.2.2 Species Background
Ireland had ten known bat species until February 2013, when a single live greater horseshoe bat (Rhinolophus ferrumequinum) was found roosting in Co. Wexford8. The ten species (excluding the greater horseshoe) are briefly described overleaf. For a more comprehensive overview see McAney, 2006.9
The dependence of Irish bat species on insect prey has left them vulnerable to habitat destruction, land drainage, agricultural intensification and increase use of pesticides. Also, their reliance on buildings as roosting sites has made them particularly vulnerable to renovation works and the use of timber chemical treatment. Buildings are highly important as roosting sites for bats and all Irish bat species use buildings for all roost types. Most significant in terms of roosts in houses are maternity roosts, but cellars and even attics may serve as hibernation sites for bats. Roosts within buildings can far exceed the numbers encountered in trees, bridges, caves or cliffs and roosts of over 1,000 bats have been recorded in buildings.10
8 National Biodiversity Data Centre http://www.biodiversityireland.ie/new-bat-species-found-in- ireland/ 9 McAney, K. (2006) A Conservation Plan for Irish Vesper Bats. Irish Wildlife Manual No.20. National Parks and Wildlife Service, Department of the Environment, Heritage and Loca lGovernment. 10 NRA (2005) Guidelines for the Treatment of Bats Prior to the Construction of National Road Schemes. National Roads Authority, Dublin
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2.2.2.1 Family Vespertilionidae:
Common pipistrelle Pipistrellus pipistrellus This species was only recently separated from its sibling, the soprano or brown pipistrelle P. pygmaeus11, which is detailed below. The common pipistrelle's echolocation calls peak at 45 kHz. The species forages along linear landscape features such as hedgerows and treelines as well as within woodland.
Soprano pipistrelle Pipistrellus pygmaeus The soprano pipistrelle's echolocation calls peak at 55 kHz, which distinguishes it readily from the common pipistrelle on detector. The pipistrelles are the smallest and most often seen of our bats, flying at head height and taking small prey such as midges and small moths. Summer roost sites are usually in buildings but tree holes and heavy ivy are also used. Roost numbers can exceed 1,500 animals in mid-summer.
Nathusius' pipistrelle Pipistrellus nathusii Nathusius' pipistrelle is a recent addition to the Irish fauna and has mainly been recorded from the north-east of the island in Counties Antrim and Down12 and also in Fermanagh, Longford and Cavan. It has also recently been recorded in Counties Cork and Kerry.13 However, the known resident population is enhanced in the autumn months by an influx of animals from Scandinavian countries. The status of the species has not yet been determined.
Leisler’s bat Nyctalus leisleri This species is Ireland’s largest bat, with a wingspan of up to 320mm; it is also the third most common bat, preferring to roost in buildings, although it is sometimes found in trees and bat boxes. It is the earliest bat to emerge in the evening, flying fast and high with occasional steep dives to ground level, feeding on moths, caddis-flies and beetles. The echolocation calls are sometimes audible to the human ear being around 15 kHz at their lowest. The audible chatter from their roost on hot summer days is sometimes an aid to location. This species is uncommon in Europe and as Ireland holds the largest national population the species is considered as Near Threatened here.
Brown long-eared bat Plecotus auritus This species of bat is a ‘gleaner’, hunting amongst the foliage of trees and shrubs, and hovering briefly to pick a moth or spider off a leaf, which it then takes to a sheltered perch to consume. They often land on the ground to capture their prey. Using its nose to emit its echolocation, the long-eared bat ‘whispers’ its calls so that the insects, upon which it preys, cannot hear its approach (and hence, it needs oversize ears to hear the returning echoes). As this is a whispering species, it is extremely difficult to monitor in the field as it is seldom heard on a bat detector.
11 Barratt, E. M., Deauville, R., Burland, T. M., Bruford, M. W., Jones, G., Racey, P. A., & Wayne, R. K. (1997) DNA Answers the Call of Pipistrelle Bat Species. Nature 387: 138 - 139. 12 Richardson, P. (2000) Distribution Atlas of Bats in Britain and Ireland 1980 - 1999. The Bat Conservation Trust, London, England. 13 Kelleher, C. (2005) International Bat Fieldcraft Workshop, Killarney, Co. Kerry. National Parks and Wildlife Service, Department of the Environment, Heritage and Local Government.
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Furthermore, keeping within the foliage, as it does, it is easily overlooked. It prefers to roost in old buildings.
Natterer’s bat Myotis nattereri This species has a slow to medium flight, usually over trees but sometimes over water. It usually follows hedges and treelines to its feeding sites, consuming flies, moths, caddis-flies and spiders. Known roosts are usually in old stone buildings but they have been found in trees and bat boxes. The Natterer’s bat is one of our least studied species and further work is required to establish its status in Ireland.
Daubenton's bat Myotis daubentonii This bat species feeds close to the surface of water, either over rivers, canals, ponds, lakes or reservoirs but it can also be found foraging in woodlands. Flying at 15 kilometres per hour, it gaffs insects with its over-sized feet as they emerge from the surface of the water - feeding on caddis flies, moths, mosquitoes, midges etc. It is often found roosting beneath bridges or in tunnels and also makes use of hollows in trees.
Whiskered bat Myotis mystacinus This species, although widely distributed, has been rarely recorded in Ireland. It is often found in woodland, frequently near water. Flying high, near the canopy, it maintains a steady beat and sometimes glides as it hunts. It also gleans spiders from the foliage of trees. Whiskered bats prefer to roost in buildings, under slates, lead flashing or exposed beneath the ridge beam within attics. However, they also use cracks and holes in trees and sometimes bat boxes. The whiskered bat is one of our least studied species and further work is required to establish its status in Ireland.
Brandt’s bat Myotis brandtii This species is known from five specimens found in Counties Wicklow (Mullen, 2007), Cavan, and Clare in 2003, a specimen in Kerry in 200514 and another in Tipperary in 2006.15 No maternity roosts have yet been found. It is very similar to the whiskered bat and cannot be separated by the use of detectors. Its habits are similar to its sibling.
2.2.2.2 Family Rhinolophidae:
Lesser horseshoe bat Rhinolophus hipposideros
This species is the only representative of the Rhinolophidae or horseshoe bat family in Ireland. It differs from our other species in both habits and looks, having a unique nose leaf with which it projects its echolocation calls. It is also quite small and, at rest, wraps its wings around its body. Lesser horseshoe bats feed close to the ground, gleaning their prey from branches and stones. It often carries its prey to a perch to consume, leaving the remains beneath as an indication of its presence.
14 Kelleher, C. 2006a Nathusius pipistrelle Pipistrellus nathusii and Brandt’s Bat Myotis brandtii - New Bat Species to Co. Kerry – Irish Naturalists’ Journal 28: 258. 15 Kelleher, C. 2006b Brandt’s Bat Myotis brandtii, New Bat Species to Co. Tipperary. Irish Naturalists’ Journal 28: 345.
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The echolocation call of this species is of constant frequency and, on a heterodyne bat detector, sounds like a melodious warble. The species is confined to six counties along the Atlantic seaboard: Mayo, Galway, Clare, Limerick, Kerry and Cork. The current Irish national population is estimated at 12,500 animals. This species is listed on Annex II of the EC Habitats Directive and 41 Special Areas of Conservation have been designated in Ireland for its protection. Where it occurs, it is often found roosting within farm buildings.
2.2.3 Landscape Suitability
The National Biodiversity Data Centre (NBDC) maps landscape suitability bats based on Lundy et al. (2011). The maps are a visualisation of the results of the analyses based on a ‘habitat suitability’ index. The index ranges from 0 to 100 with 0 being least favourable and 100 most favourable for bats. The overall assessment of bat habitats for the current study area is given as 18.33, relatively low. Table 2 gives the suitability of the study area for the bat species found in the study area (based on NBDC) along with their Irish Red List Status (from Marnell et al., 2019).16
Table 2 Suitability of the study area for the bat species found in the Brickfield area (based on the NBDC data) with Irish Red list status indicated Common name Scientific name Suitability index Irish red list status All bats - 18.33 Least Concern Soprano pipistrelle Pipistrellus pygmaeus 33 Least Concern Brown long-eared bat Plecotus auritus 23 Least Concern Common pipistrelle Pipistrellus pipistrellus 31 Least Concern Lesser-horseshoe bat Rhinolophus hipposideros 0 Least Concern Leisler’s bat Nyctalus leisleri 37 Least Concern Whiskered bat Myotis mystacinus 13 Least Concern Daubenton’s bat Myotis daubentonii 11 Least Concern Nathusius' pipistrelle Pipistrellus nathusii 10 Least Concern Natterer’s bat Myotis nattereri 7 Least Concern
2.2.4 Bat Roosts
Bats were originally cave and tree dwelling animals but many now find buildings just as suitable for their needs. Bats are social animals and most species congregate in large colonies during summer. These colonies consist mostly of females of every reproductive class, with some juvenile males from the previous year. Male bats normally roost individually or in small groups meeting up with the females in the late autumn-early winter, when it is time to mate. In summer, bats seek warm dry buildings in which they can give birth and suckle their young. In winter, they seek out places with a constant low temperature and high humidity where they can become torpid and hibernate during adverse weather conditions. However, bats do not hibernate continuously during winter and will awake and hunt during mild nights when there are insects available and it is energetically advantageous to forage.
16 Marnell, F., Looney, D. & Lawton, C. (2019) Ireland Red List No. 12: Terrestrial Mammals. National Parks and Wildlife Service, Department of the Culture, Heritage and the Gaeltacht, Dublin, Ireland.
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2.2.4.1 Maternity Roosts
Maternity roosts are the most significant roosts and they are predominantly all- female aggregations that are formed from late May onwards and remain as a relatively cohesive unit until mid to late August. Not all female bats give birth annually. These females that do bear young in a given year avail of a suitable building, tree and sometimes cave (or equivalent). The young are flightless for several weeks and hence are vulnerable to dangers such as tree felling and restoration, reinforcement or demolition of structures such as buildings and bridges.
2.2.4.2 Mating Roosts
Most bat species mate in autumn but pregnancy does not occur until the following spring. During this time males will take possession of a cavity in a building, tree, bridge, cave or mine and attract females to these sites to establish a harem. Male bats call both from a perch and in flight in much the same manner that male birds sing.
2.2.4.3 Hibernation Roosts
Bats have a high metabolic rate and in temperate countries, such as Ireland, flying insects are not available in sufficient numbers during winter to sustain bats. Therefore, bats hibernate during winter. In hibernation sites, bats are often completely inactive for several days and are extremely vulnerable to disturbance by human activities due to the time taken for them to become sufficiently active to allow escape. Hibernation may extend from November to the end of March, during which time bat activity will take place sporadically.
2.2.4.4 Night Roosts
These are roosts which are used as resting places for bats between foraging bouts. They also provide retreats for bats from predators or during inclement weather conditions. They also function as feeding perches and may be important for socialising.
2.3 Bat Survey
2.3.1 Bat Activity Survey
A bat emergence and activity survey of the affected buildings on the site was carried out on the 11th of May 2020 so ascertain if any bat species were using the buildings on the site and assess the bat activity within the site.
The equipment used included 2 x Elekon Bat Logger M detectors. Visual observations were taken with the aid of a powerful L.E.D. torch (AP Pros-Series 220 Lumens High Performance Spotlight). A Seek Thermal Reveal Pro High-Resolution Thermal Imaging Camera was also used along with a RIDGID 36848 Micro CA-150 Hand-Held Borescope for inspection of any crevices on bat potential trees if present.
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The bat emergence survey began at 21.13 (which was sunset) and lasted until 23.30. The survey was undertaken during favourable weather conditions e.g. dry with mild temperatures fluctuating mainly between 10 and 11oC with a gentle breeze. Surveys are best carried out mid-March to end of September in suitable weather conditions which this survey was.17
The detector picked up frequencies between 25 kHz - 115 kHz as this frequency range is able to pick up the calls of all Irish bat species, including Lesser horseshoe bats (highly unlikely given the suitability index of 0, see Table 2).
2.3.2 Bat Potential Trees
During the survey, the features listed below on the boundary treelines/hedgerows were sought:
Natural holes (e.g. knot holes) arising from naturally shed branches or branches previously pruned back to a branch collar. Man-made holes (e.g. cavities that have developed from flush cuts or cavities created by branches tearing out from parent stems). Cracks/splits in stems or braches (horizontal and vertical). Partially detached, loose or bark plates. Cankers (caused by localised bark death) in which cavities have developed. Other hollows or cavities, including butt rots. Compression of forks with included bark, forming potential cavities. Crossing stems or branches with suitable roosting space between. Ivy stems with diameters in excess of 50mm with suitable roosting space behind (or where roosting space can be seen where a mat of thinner stems has left a gap between the mat and the trunk). Bat or bird boxes. Other suitable places of rest or shelter.
Certain factors such as orientation of the feature, height from the ground, the direct surroundings and its location in respect to other features may enhance or reduce the potential value.
Treelines/hedgerows were classified into general bat roost potential groups based upon the presence of these features. An evaluation table is shown as Table 3.
17 Kelleher, C. & Marnell, F. (2006) Bat Mitigation Guidelines for Ireland. Irish Wildlife Manuals, No. 25. National Parks and Wildlife Service, Department of Environment, Heritage and Local Government, Dublin, Ireland.
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Table 3 Classification and Survey Requirements for Bats in Trees18 Classification Description of Category Likely Further Survey Work / Actions of Tree and Associated Features (based on Potential Roosting Features listed above) Confirmed Roost Evidence of roosting bats in A National Parks and Wildlife (NPWS) the form of live / dead bats, derogation licence application will be droppings, urine staining, required if the tree or roost site is mammalian fur oil staining, affected by the development or etc. proposed arboricultural works. This will require a combination of aerial assessment by roped access bat workers (where possible, health and safety constraints allowing) and nocturnal survey during appropriate periods (e.g. nocturnal survey - May to August) to inform on the licence.
Works to tree undertaken under supervision in accordance with the approved good practice method statement provided within the licence.
However, where confirmed roost site(s) are not affected by works, work under a precautionary good practice method statement may be possible. High Potential A tree with one or more Aerial assessment by roped access bat Potential Roosting Features workers (if appropriate) and / or that are obviously suitable for nocturnal survey during appropriate larger numbers of bats on a period (May to August). more regular basis and potentially for longer periods Following additional assessments, tree of time due to their size, may be upgraded or downgraded shelter protection, conditions based on findings. (height above ground level, light levels, etc) and If roost sites are confirmed and the tree surrounding habitat. Examples or roost is to be affected by proposals a include (but are not limited licence from the NPWS will be required. to); woodpecker holes, larger cavities, hollow trunks, hazard After completion of survey work (and beams, etc. the presence of a bat roost is discounted), a precautionary working method statement may still be appropriate. Moderate A tree with Potential Roosting A combination of aerial assessment by Potential Features which could support roped access bat workers and / or one or more potential roost nocturnal survey during appropriate sites due to their size, shelter period (May to August).
18 Bat Surveys for Professional Ecologists: Good Practice Guidelines (J., Collins (Bat Conservation Trust), 201618).
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Classification Description of Category Likely Further Survey Work / Actions of Tree and Associated Features (based on Potential Roosting Features listed above) protection, conditions (height above ground level, light Following additional assessments, tree levels, etc) and surrounding may be upgraded or downgraded based habitat but unlikely to support on findings. a roost of high conservation status (i.e. larger roost, After completion of survey work (and irrespective of wider the presence of a bat roost is conservation status). discounted), a precautionary working Examples include (but are not method statement may still be limited to); woodpecker appropriate. holes, rot cavities, branch socket cavities, etc. If a roost site/s is confirmed a licence from the NPWS will be required. Low Potential A tree of sufficient size and No further survey required but a age to contain Potential precautionary working method Roosting Features but with statement may be appropriate. none seen from ground or features seen only very limited potential. Examples include (but are not limited to); loose/lifted bark, shallow splits exposed to elements or upward facing holes. Negligible/No Negligible/no habitat features None. potential likely to be used by roosting bats
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2.3.3 Buildings Survey
A daytime inspection of the affected buildings was carried out following methodology outlined in Bat Mitigation Guidelines for Ireland by Kelleher & Marnell (2006). All spaces that could potentially allow bats access the buildings were visually examined in detail for bats, signs of bats, or evidence of bat activity, using a torch where necessary. Cracks, crevices etc. were investigated for ingress / egress points and evidence of bat habitation, such as smearing lines, droppings and staining. Tight crevices and concealed ingresses were examined in detail using an RIDGID 36848 Micro CA-150 Hand-Held Borescope. This piece of equipment is fitted with a camera and allows visibility of confined spaces and narrow passages potentially used by hibernating/roosting bats. It allows spaces up to 3m from ground level to be inspected.
2.4 Landscape Evaluation
Ecological survey results were evaluated to determine the significance of identified features located in the study area on an importance scale ranging from international-national-county-local (from NRA, 2009) The local scale is approximately equivalent to one 10km square but can be operationally defined to reflect the character of the area of interest. Because most sites will fall within the local scale, this is sub-divided into two categories: local importance (higher value) and local importance (lower value).
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3. RESULTS
3.1 Site Overview
Habitats were identified and classified according to Fossitt (2000)19 and Smith et al. (2011)20. The majority of the habitat on the site comprises of ‘Buildings and Artificial Surfaces - BL3 between the existing buildings and the carpark and access roads around the site. An area of Amenity Grassland (GA2) occurs to the south of the site (GA2) and the site boundary itself is mature treelines (WL2) and Hedging (WL1). Brickfield Park is adjacent to the site to the north.
The only affected habitats due to the proposed works would be ‘Buildings and Artificial Surfaces’ and some ‘Amenity Grassland’. These habitats are no and low ecological importance prospectively (unless buildings were found to be used by protected species such as bats). The treelines and hedging around the site is made up of many non-native ornamental shrubs and trees however given its maturity and presence of a biodiversity corridor, with connections to Brickfield Park, ideally this habitat should be retained, left intact and not fragmented. Bat potential trees are apparent throughout. If it is not possible to retain all the treeline/hedging, at least some of the tree lines should be retained, and additional planting of native hedgerows should be carried out to compensate for this loss of connectivity in the final landscape plan.
3.2 Bat Recordings
The results of the bat survey are summarized in Table 4 with the complete dataset of bat species identified in real time in the field using the Elekon Batlogger M detectors presented in Appendix A as a combined data set. A map outlining the locations of the bat calls is also shown in Figure 2. Plates illustrating the existing building on site are shown in Appendix B.
In total three species of bat were detected (8 bat passes). A low rate of bat activity was recorded - as expected due to a lighting regime on the site. The most frequent bat species heard was Common Pipistrelle and Leisler’s Bat.
Table 4 Bat Results Summary Data–May 11th 2020 between 21.13 and 23.30 Species Name – Species Name – Total Number of Peak Common Latin Number of Passes Frequency Calls (kHz) Common Pipistrelle Pipistrellus pipistrellus 8 2 46.5 Leisler’s Bat Nyctalus leisleri 6 5 26.9 Brown Long Eared Plecotus auritus 1 1 33.2
19 Fossitt, J. (2000). A Guide to Habitats in Ireland. The Heritage Council, Kilkenny. 20 Smith, G.F., O’Donoghue, P., O’Hora, K. and Delaney, E. (2011) Best practice guidance for habitat survey and mapping. The Heritage Council, Kilkenny.
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Figure 2 Bat Activity Map with Legend
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3.3 Bat Survey Overview
The majority of the activity occurred along the mature treeline to the north of the site. No bats were observed emerging from the existing buildings.
The recommendations set out in Section 4 will offset any negative impacts to bats via the installation of bat boxes post construction and bat friendly lighting to ensure no bats are affected.
3.4 Landscape Evaluation
The wider landscape is considered to be of local importance (Lower value) for bats. While Brickfield Park which is adjacent to the site has mature trees present, outside of this park there are limited wooded areas. The majority of habitats in the wider landscape are buildings and artificial surfaces (BL3) as the area it is located within a city. Therefore the mature treelines and hedgerows onsite are important in this broader context and should be retained as much as possible for foraging and possibly roosting bats with the presence of a number of over-mature trees. As noted above, if it is not possible to retain all the treeline/hedging, at least some of the tree lines should be retained, and additional planting of native hedgerows should be carried out to compensate for this loss of connectivity in the final landscape plan.
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4. RECOMMENDATIONS
4.1 Lighting and Bats
In order to minimise disturbance to bats utilising the site in general, the lighting should be designed to minimise light-spill onto habitats both within and adjacent to it that are used by the local bat population foraging or commuting. This can be achieved by ensuring that the design of lighting accords with guidelines presented in the Bat Conservation Trust & Institute of Lighting Engineers 'Bats and Lighting in the UK - Bats and Built Environment Series', the Bat Conservation Trust ‘Artificial Lighting and Wildlife Interim Guidance’ and the Bat Conservation Trust 'Statement on the impact and design of artificial light on bats'. Therefore, where possible, the lighting scheme should include the following:
The avoidance of direct lighting of existing trees.
Unnecessary light spill controlled through a combination of directional lighting and hooded / shielded luminaires.
Where appropriate, luminaires on the site boundary could be fitted with light baffles to prevent light spill onto adjacent habitats.
Lighting levels should be the minimum required for health and safety requirements, where possible.
Vegetated areas around the perimeter should not be lit up nor lighting directed towards it. Lighting in these areas should not increase beyond existing lux levels or 1 lux, whichever is the lesser.
Vertical light spill at light sources should be below 3m to avoid potential bat flight paths.
No floodlighting should be used – this causes a large amount of light spillage into the sky. The spread of light should be kept below the horizontal.
Hoods, louvres, shields or cowls should be fitted on the lights to reduce light spillage.
Lights should be of low intensity. It is better to use several low intensity lights than one strong light spilling light across the entire area.
Narrow spectrum lighting should be used with a low UV component. Glass also helps reduce the UV component emitted by lights.
The source of light should be Light Emitting Diodes (LEDs) as this is a narrow beam that is highly directional and a highly energy efficient light source. The lighting should allow for a light level of 3 lux at ground level at the perimeter of the development area. This low lighting is thus easier to control both the direction but also the actual light level because it is so close to the target area.
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4.2 Potential Bat Roosts in Trees
All boundary hedgerows and treelines around the site should be retained if possible as they form part of an important biodiversity corridor to Brickfield Park. Several of the over-mature trees have potential for bats with cracks and crevices apparent and others had a thick covering of ivy. If trees require felling with bat potential features listed in Table 3, a bat survey should be carried out prior to felling and the a ‘soft’ felling methodology should be used where they are left lie for 24 hours thereafter for any animals to escape and NOT mulched immediately.
If it is not possible to retain all the treeline/hedging, at least some of the treelines should be retained, and additional planting of native hedgerows should be carried out to compensate for this loss of connectivity in the final landscape plan. It is noted that the existing trees located along the Eastern side of the site to the rear side of No. 21-27 Brickfield Drive are to be retained in order to maintain the existing buffer, and that boundary hedgerows are to be planted with native hawthorn Crataegus monogyna. This will ultimately restore habitat connectivity
A total of 10+ bat boxes should be erected on trees around the site to provide future roosting opportunities.
Any extra trees planted should comprise of native Irish species.
5. CONCLUSION
The following conclusions were made from the survey, which if implemented will ensure impacts to bats from the proposed development are negligible:
- The habitat type ‘Buildings and Artificial Surfaces (BL3)’ and ‘Amenity Grassland (GA2)’ will be affected for the proposed development, however no bats were observed using the affected buildings during the emergence survey. - All trees and hedgerows around the site boundary should be retained if possible and positive impacts for bats will be via the supplementary planting of native Irish species - If it is not possible to retain all the treeline/hedging, at least some of the treelines should be retained, and additional planting of native hedgerows should be carried out to compensate for this loss of connectivity in the final landscape plan. - The erection of 10+ bat boxes around the site is recommended. - Tthe lighting and layout of the proposed works should be designed to minimise light-spill onto habitats both within and adjacent to the site that are used by the local bat population foraging or commuting.
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APPENDICES APPENDIX A
Plate 1 A view of the existing site buildings. Limited bat access points.
Plate 2 A view of the existing site buildings. Some bat potential with thick ivy.
Plate 3 A view of the existing site buildings.
Plate 4 A view of the existing site buildings to the west of site.
Plate 5 A view of the existing site buildings, looking northwest.
Plate 6 A view of the existing site buildings, to the south of site. No access for bats.
Plate 7 A view of the existing site to the front – carpark with mature treelines/hedging for the majority of site boundary.
Plate 8 A view of the existing site to the front – carpark with mature treelines/hedging for the majority of site boundary.
Plate 9 A view of the existing site to the front –entrance lane with mature treelines/hedging for the majority of site boundary.
Plate 10 A view of the existing site to the northern side – mature treelines/hedging for the majority of site boundary. Area of most bat activity most likely as it is adjacent to brickfield public park.
Plate 11 A view of the existing site to the southern side – mature treelines/hedging for the majority of site boundary. No bat activity recorded in this area.
Plate 12 A view of the existing site at night which was lit up, a likely deterrent for bats (northern part of site).
APPENDIX B Mean Peak Mean Max Mean Min Frequency Frequency Frequency Mean Call Temperature Latitude Longitude 11/05/2020 Species Calls [#] [kHz] [kHz] [kHz] Length [ms] [°C] [WGS84] [WGS84] 21:18:43 Leisler's Bat 1 21.4 22.3 20.7 9.2 11 53.33074 -6.30488 Common 21:58:14 Pipistrelle Bat 7 46.9 54.4 46.5 3 10 53.33085 -6.30464 22:46:54 Leisler's Bat 1 21.7 24.1 20.1 6.6 10 53.3308 -6.30445 Brown Long 22:50:13 Eared Bat 1 33.2 35.1 32.6 2 10 53.33067 -6.3039 22:51:56 Leisler's Bat 2 24.4 24.4 24.1 7.2 10 53.33044 -6.30376 23:08:13 Leisler's Bat 1 24.1 24.4 24.1 9.2 10 53.33066 -6.30544 23:11:47 Leisler's Bat 1 24.4 24.4 24.1 12.5 10 53.33053 -6.30372 Common 23:27:37 Pipistrelle Bat 1 44.5 44.8 44.5 6.6 10 53.33053 -6.30566
March 2021
Bat Survey Report
Brickfield House, Brickfield Drive, Crumlin, Dublin 12
Aisling Walsh M.Sc MCIEEM Trading as Ash Ecology & Environmental Ltd. Tel: 089 4991181 / Company Reg: 630819 / Office:Ash Monine Ecology &Kilfinane, Environmental Co. Limerick Ltd – March / Full 2021 membership of the CIEEM Page 1
Bat Tree Assessment Report – Brickfield House, Brickfield Drive, Crumlin, Dublin 12
Contents
1. INTRODUCTION ...... 4 1.1 Purpose of the Report...... 4 1.2 Competency of Assessor ...... 4 1.3 Bat Legislation ...... 5 2. METHODOLOGY ...... 6 2.1 Information Sources ...... 6 2.2 Desk Study ...... 7 2.2.1 Previous Records ...... 7 2.2.2 Species Background ...... 7 2.2.3 Landscape Suitability ...... 10 2.2.4 Bat Roosts ...... 10 2.3 General Activity Survey ...... 12 2.4 Buildings Assessment Methodology ...... 12 2.5 Bat Potential Tree Assessment ...... 12 2.6 Landscape Evaluation ...... 17 3. RESULTS – May 2020 & March 2021 ...... 17 3.1 General Activity Survey ...... 17 3.2 Buildings Assessment Survey ...... 19 3.3 Bat Potential Tree Assessment ...... 19 3.4 Landscape Evaluation ...... 20 4. MITIGATION ...... 21 4.1 Tree Removal ...... 21 4.2 Lighting for Bats ...... 21 4.3 Roosting Opportunities ...... 22 5. CONCLUSION ...... 22
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Tables Table 1 Historical Bat Records in 10km2 Grid Ref O13 (NBDC website www.nbdc.ie accessed 17/03/2021) Table 2 Suitability of the study area for the bat species found in the Brickfield area (based on the NBDC data) with Irish Red list status indicated. Table 3 Summary Table of trees suggested for removal from the Arboricultural Assessment (Aborists Associates Ltd, Feb 2021) Table 4 Classification and Survey Requirements for Bats in Trees Table 5 Bat Results Summary Data – May 11th 2020 and March 15th 2021 Table 6 Bat Tree Assessment Summary with Recommendations (March 2021), see Plates in Appendix A Figures Figure 1 Site Location Map Figure 2 Tree Plan, areas circled in Red for removal Figure 3 Bat Activity Map (11th May 2020 (blue dots) and March 15th 2021 (red dots). Orange oval is area of Tree 0270 (Plate 12) and Tree 0272 (Plate 13). Yellow circle is Tree 0285 (Plate 16) Figure 4 Proposed Landscaping Plan (Park Hood Chartered Landscape Architects, March 2021)
Appendices Appendix A Plates (March 2021) Appendix B Bat Data (May 2020 and March 2021 combined)
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1. INTRODUCTION
1.1 Purpose of the Report
Ash Ecology and Environmental Ltd (AEE) was commissioned by Enviroguide Consulting to carry out a follow up bat survey at Brickfield House, Brickfield Drive, Crumlin, Dublin 12, see Figure 1. A previous bat emergence and activity survey was carried out on May 11th 2020. The current survey also includes a bat potential assessment of trees for removal.
Figure 1 Site Location Map
1.2 Competency of Assessor
This report has been prepared by Ash Ecology & Environmental Ltd (AEE) whose managing director and leading ecologist is Aisling Walsh who is a full member of the Chartered Institute of Ecological & Environmental Management (CIEEM) and whose qualifications include M.Sc. (Dist) in Biodiversity and Conservation (TCD) and B.Sc. (Hons) Zoology (NUIG). Aisling has over 14 years of experience providing environmental consultancy and environmental assessment services. Aisling has written numerous Ecological Impact Assessments (EcIA), Screening for Appropriate Assessment Stage I and Stage II Natura Impact Statement, Environmental Impact Assessments/Statements, Badger Surveys, Bat Surveys, Habitat Surveys. She has also provided input and reviewed Ecological and Environmental assessments for several EIS and EIA Reports and conducted numerous noise surveys for EPA licensed facilities. AEE is listed as a Registered Practice by the CIEEM and a member of Bat Conservation Ireland. Aisling Walsh is a licenced bat ecologist (DER/BAT 2020 – 46 EUROPEAN, DER/BAT 2020 – 48 EUROPEAN).
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1.3 Bat Legislation
In view of their sensitive status across Europe, all species of bat have been listed on Annex IV of the EC ‘Habitats and Species Directive’ and some, such as the lesser horseshoe bat, are given further protection and listed on Annex II of this Directive. This Directive was transposed into Irish law as the European Communities (Natural Habitats) Regulations, 1997, and combined with the Wildlife Acts (1976 to 2018), ensures that individual bats and their breeding sites and resting places are fully protected. This has important implications for those who own or manage sites where bats occur.
All bat species are protected under the Wildlife Acts 1976-2018 which make it an offence to wilfully interfere with or destroy the breeding or resting place of these species; however, the Acts permit limited exemptions for certain kinds of development.
All species of bats in Ireland are listed on Schedule 5 of the 1976 Act, and are therefore subject to the provisions of Section 23, which make it an offence to:
1. Intentionally kill, injure or take a bat, 2. Possess or control any live or dead specimen or anything derived from a bat, 3. Wilfully interfere with any structure or place used for breeding or resting by a bat, 4. Wilfully interfere with a bat while it is occupying a structure or place which it uses for that purpose.
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2. METHODOLOGY
2.1 Information Sources
A desk-based review of information sources was completed. Information contained on the websites of the National Parks and Wildlife Service (NPWS)1 and the National Biodiversity Data Centre (NBDC)2 was reviewed.
The following publications and websites were also reviewed and consulted:
• Bat Conservation Ireland https://www.batconservationireland.org/ • Bat Roosts in Trees: A Guide to Identification and Assessment for Tree-Care and Ecology Professionals (2018) • Bat Conservation Trust (2018) Bats and artificial lighting in the UK Bats and the Built Environment series3 • Kelleher, C. & Marnell, F. (2006) Bat Mitigation Guidelines for Ireland. Irish Wildlife Manuals, No. 25. National Parks and Wildlife Service, Department of Environment, Heritage and Local Government, Dublin, Ireland. • Mitchell-Jones, A.J, & McLeish, A.P. (eds). 2004., 3rd Edition Bat Workers' Manual, JNCC, Peterborough, ISBN 1 86107 558 8 • Bat Conservation Ireland (2012) Bats and Appropriate Assessment Guidelines, Version 1, December 2012. Bat Conservation Ireland, www.batconservationireland.org4 • Bat Conservation Trust (2016) Bat Surveys for Professional Ecologists: Good Practice Guidelines 3rd edition • Bat Conservation Ireland (2010) Bats & Lighting Guidance Notes for: Planners, engineers, architects and developers5 • Best Practice Guidelines for the Conservation of Bats in the Planning of National Road Schemes (National Roads Authority, 2005). • Guidelines for the Treatment of Bats during the Construction of National Road Schemes (National Roads Authority, 2005). • Arboriculture Impact Plan and Tree Constraints Plan (Aborists Associates Ltd, Oct 2020) • Bat Survey Report (August 2020) Ash Ecology and Environmental Ltd. • Arboricultural Assessment of the Site Area at ‘Brickfield Drive’, Crumlin, Dublin 12 (Feb 2021) Aborists Associated Ltd. • Landscape Design and Access Statement, Brick Field Drive, Dublin (March 2021) Park Hood Chartered Landscape Architects • Landscape Management and Maintenance Plan, Brick Field Drive, Dublin (March 2021) Park Hood Chartered Landscape Architects • Fallon Design, M&E Engineering (March 2021) Public Lighting Report Residential Development Brickfield Drive Development
1 The National Parks and Wildlife Services map viewer http://webgis.npws.ie/npwsviewer/ 2 The National Biodiversity Data Centre www.NBDC.ie 3 https://www.theilp.org.uk/documents/guidance-note-8-bats-and-artificial-lighting/ 4https://www.batconservationireland.org/wp-content/uploads/2013/09/BCIreland-AA- Guidelines_Version1.pdf 5https://www.batconservationireland.org/wp- content/uploads/2013/09/BCIrelandGuidelines_Lighting.pdf
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2.2 Desk Study
2.2.1 Previous Records
A desktop review was carried out to identify the previous records of Bat species within the Proposed Development Site and its environs. The study area occurs in 10km2 Grid Square O13. The website the NBDC (www.nbdc.ie) was accessed on 17/03/2021 to establish any previous bat records and shown below in Table 1.
Table 1 Historical Bat Records in 10km2 Grid Square O13 (NBDC website www.nbdc.ie accessed 17/03/2021) Species Name - Common Species Name - Latin Last Documented Record O13 Brown Long-eared Bat Plecotus auritus 25/07/2013 Daubenton's Bat Myotis daubentonii 11/08/2014 Lesser Noctule Nyctalus leisleri 28/05/2016 Nathusius's Pipistrelle Pipistrellus nathusii 15/09/2010 Natterer's Bat Myotis nattereri 30/09/2016 Common Pipistrelle Pipistrellus pipistrellus 03/08/2013 Soprano Pipistrelle Pipistrellus pygmaeus 30/09/2016 Whiskered Bat Myotis mystacinus 13/08/2007
2.2.2 Species Background
Ireland had ten known bat species until February 2013, when a single live greater horseshoe bat (Rhinolophus ferrumequinum) was found roosting in Co. Wexford6. On 8th June 2020, a single audio recording was confirmed in the Glendaough area, Co. Wicklow. It was found on two more occasions in the same area in early July 2020 (Bat Conservation Ireland, July 2020).
The ten species (excluding the greater horseshoe) are briefly described overleaf. For a more comprehensive overview see McAney, 2006.7
The dependence of Irish bat species on insect prey has left them vulnerable to habitat destruction, land drainage, agricultural intensification and increase use of pesticides. Also, their reliance on buildings as roosting sites has made them particularly vulnerable to renovation works and the use of timber chemical treatment. Buildings are highly important as roosting sites for bats and all Irish bat species use buildings for all roost types. Most significant in terms of roosts in houses are maternity roosts, but cellars and even attics may serve as hibernation sites for bats. Roosts within buildings can far exceed the numbers encountered in trees, bridges, caves or cliffs and roosts of over 1,000 bats have been recorded in buildings.8
6 National Biodiversity Data Centre http://www.biodiversityireland.ie/new-bat-species-found-in- ireland/ 7 McAney, K. (2006) A Conservation Plan for Irish Vesper Bats. Irish Wildlife Manual No.20. National Parks and Wildlife Service, Department of the Environment, Heritage and Local Government. 8 NRA (2005) Guidelines for the Treatment of Bats Prior to the Construction of National Road Schemes. National Roads Authority, Dublin
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2.2.2.1 Family Vespertilionidae:
Common pipistrelle Pipistrellus pipistrellus This species was only recently separated from its sibling, the soprano or brown pipistrelle P. pygmaeus9, which is detailed below. The common pipistrelle's echolocation calls peak at 45 kHz. The species forages along linear landscape features such as hedgerows and treelines as well as within woodland.
Soprano pipistrelle Pipistrellus pygmaeus The soprano pipistrelle's echolocation calls peak at 55 kHz, which distinguishes it readily from the common pipistrelle on detector. The pipistrelles are the smallest and most often seen of our bats, flying at head height and taking small prey such as midges and small moths. Summer roost sites are usually in buildings, but tree holes and heavy ivy are also used. Roost numbers can exceed 1,500 animals in mid-summer.
Nathusius' pipistrelle Pipistrellus nathusii Nathusius' pipistrelle is a recent addition to the Irish fauna and has mainly been recorded from the north-east of the island in Counties Antrim and Down10 and also in Fermanagh, Longford and Cavan. It has also recently been recorded in Counties Cork and Kerry.11 However, the known resident population is enhanced in the autumn months by an influx of animals from Scandinavian countries. The status of the species has not yet been determined.
Leisler’s bat Nyctalus leisleri This species is Ireland’s largest bat, with a wingspan of up to 320mm; it is also the third most common bat, preferring to roost in buildings, although it is sometimes found in trees and bat boxes. It is the earliest bat to emerge in the evening, flying fast and high with occasional steep dives to ground level, feeding on moths, caddisflies and beetles. The echolocation calls are sometimes audible to the human ear being around 15 kHz at their lowest. The audible chatter from their roost on hot summer days is sometimes an aid to location. This species is uncommon in Europe and as Ireland holds the largest national population the species is considered as Near Threatened here.
Brown long-eared bat Plecotus auritus This species of bat is a ‘gleaner’, hunting amongst the foliage of trees and shrubs, and hovering briefly to pick a moth or spider off a leaf, which it then takes to a sheltered perch to consume. They often land on the ground to capture their prey. Using its nose to emit its echolocation, the long-eared bat ‘whispers’ its calls so that the insects, upon which it preys, cannot hear its approach (and hence, it needs oversize ears to hear the returning echoes). As this is a whispering species, it is extremely difficult to monitor in the field as it is seldom heard on a bat detector. Furthermore, keeping within the foliage, as it does, it is easily overlooked. It prefers to roost in old buildings.
9 Barratt, E. M., Deauville, R., Burland, T. M., Bruford, M. W., Jones, G., Racey, P. A., & Wayne, R. K. (1997) DNA Answers the Call of Pipistrelle Bat Species. Nature 387: 138 - 139. 10 Richardson, P. (2000) Distribution Atlas of Bats in Britain and Ireland 1980 - 1999. The Bat Conservation Trust, London, England. 11 Kelleher, C. (2005) International Bat Fieldcraft Workshop, Killarney, Co. Kerry. National Parks and Wildlife Service, Department of the Environment, Heritage and Local Government.
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Natterer’s bat Myotis nattereri This species has a slow to medium flight, usually over trees but sometimes over water. It usually follows hedges and treelines to its feeding sites, consuming flies, moths, caddisflies and spiders. Known roosts are usually in old stone buildings but they have been found in trees and bat boxes. The Natterer’s bat is one of our least studied species and further work is required to establish its status in Ireland.
Daubenton's bat Myotis daubentonii This bat species feeds close to the surface of water, either over rivers, canals, ponds, lakes or reservoirs but it can also be found foraging in woodlands. Flying at 15 kilometres per hour, it gaffs insects with its over-sized feet as they emerge from the surface of the water - feeding on caddis flies, moths, mosquitoes, midges etc. It is often found roosting beneath bridges or in tunnels and also makes use of hollows in trees.
Whiskered bat Myotis mystacinus This species, although widely distributed, has been rarely recorded in Ireland. It is often found in woodland, frequently near water. Flying high, near the canopy, it maintains a steady beat and sometimes glides as it hunts. It also gleans spiders from the foliage of trees. Whiskered bats prefer to roost in buildings, under slates, lead flashing or exposed beneath the ridge beam within attics. However, they also use cracks and holes in trees and sometimes bat boxes. The whiskered bat is one of our least studied species and further work is required to establish its status in Ireland.
Brandt’s bat Myotis brandtii This species is known from five specimens found in Counties Wicklow (Mullen, 2007), Cavan, and Clare in 2003, a specimen in Kerry in 200512 and another in Tipperary in 2006.13 No maternity roosts have yet been found. It is very similar to the whiskered bat and cannot be separated by the use of detectors. Its habits are similar to its sibling.
2.2.2.2 Family Rhinolophidae:
Lesser horseshoe bat Rhinolophus hipposideros
This species is the only representative of the Rhinolophidae or horseshoe bat family in Ireland. It differs from our other species in both habits and looks, having a unique nose leaf with which it projects its echolocation calls. It is also quite small and, at rest, wraps its wings around its body. Lesser horseshoe bats feed close to the ground, gleaning their prey from branches and stones. It often carries its prey to a perch to consume, leaving the remains beneath as an indication of its presence.
The echolocation call of this species is of constant frequency and, on a heterodyne bat detector, sounds like a melodious warble. The species is confined to six counties along the Atlantic seaboard: Mayo, Galway, Clare, Limerick, Kerry and Cork. The current Irish national population is estimated at 12,500 animals. This
12 Kelleher, C. 2006a Nathusius pipistrelle Pipistrellus nathusii and Brandt’s Bat Myotis brandtii - New Bat Species to Co. Kerry – Irish Naturalists’ Journal 28: 258. 13 Kelleher, C. 2006b Brandt’s Bat Myotis brandtii, New Bat Species to Co. Tipperary. Irish Naturalists’ Journal 28: 345.
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species is listed on Annex II of the EC Habitats Directive and 41 Special Areas of Conservation have been designated in Ireland for its protection. Where it occurs, it is often found roosting within farm buildings.
2.2.3 Landscape Suitability
The National Biodiversity Data Centre (NBDC) maps landscape suitability bats based on Lundy et al. (2011). The maps are a visualisation of the results of the analyses based on a ‘habitat suitability’ index. The index ranges from 0 to 100 with 0 being least favourable and 100 most favourable for bats. The overall assessment of bat habitats for the current study area is given as 18.33, relatively low. Table 2 gives the suitability of the study area for the bat species found in the study area (based on NBDC) along with their Irish Red List Status (from Marnell et al., 2019).14
Table 2 Suitability of the study area for the bat species found in the Brickfield area (based on the NBDC data) with Irish Red list status indicated. Common name Scientific name Suitability index Irish red list status All bats - 18.33 Least Concern Soprano pipistrelle Pipistrellus pygmaeus 33 Least Concern Brown long-eared bat Plecotus auritus 23 Least Concern Common pipistrelle Pipistrellus pipistrellus 31 Least Concern Lesser-horseshoe bat Rhinolophus hipposideros 0 Least Concern Leisler’s bat Nyctalus leisleri 37 Least Concern Whiskered bat Myotis mystacinus 13 Least Concern Daubenton’s bat Myotis daubentonii 11 Least Concern Nathusius' pipistrelle Pipistrellus nathusii 10 Least Concern Natterer’s bat Myotis nattereri 7 Least Concern
2.2.4 Bat Roosts
Bats were originally cave and tree dwelling animals but many now find buildings just as suitable for their needs. Bats are social animals and most species congregate in large colonies during summer. These colonies consist mostly of females of every reproductive class, with some juvenile males from the previous year. Male bats normally roost individually or in small groups meeting up with the females in the late autumn-early winter, when it is time to mate. In summer, bats seek warm dry buildings in which they can give birth and suckle their young. In winter, they seek out places with a constant low temperature and high humidity where they can become torpid and hibernate during adverse weather conditions. However, bats do not hibernate continuously during winter and will awake and hunt during mild nights when there are insects available, and it is energetically advantageous to forage.
14 Marnell, F., Looney, D. & Lawton, C. (2019) Ireland Red List No. 12: Terrestrial Mammals. National Parks and Wildlife Service, Department of the Culture, Heritage and the Gaeltacht, Dublin, Ireland.
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2.2.4.1 Maternity Roosts
Maternity roosts are the most significant roosts and they are predominantly all- female aggregations that are formed from late May onwards and remain as a relatively cohesive unit until mid to late August. Not all female bats give birth annually. These females that do bear young in a given year avail of a suitable building, tree and sometimes cave (or equivalent). The young are flightless for several weeks and hence are vulnerable to dangers such as tree felling and restoration, reinforcement or demolition of structures such as buildings and bridges.
2.2.4.2 Mating Roosts
Most bat species mate in autumn but pregnancy does not occur until the following spring. During this time males will take possession of a cavity in a building, tree, bridge, cave or mine and attract females to these sites to establish a harem. Male bats call both from a perch and in flight in much the same manner that male birds sing.
2.2.4.3 Hibernation Roosts
Bats have a high metabolic rate and in temperate countries, such as Ireland, flying insects are not available in sufficient numbers during winter to sustain bats. Therefore, bats hibernate during winter. In hibernation sites, bats are often completely inactive for several days and are extremely vulnerable to disturbance by human activities due to the time taken for them to become sufficiently active to allow escape. Hibernation may extend from November to the end of March, during which time bat activity will take place sporadically.
2.2.4.4 Night Roosts
These are roosts which are used as resting places for bats between foraging bouts. They also provide retreats for bats from predators or during inclement weather conditions. They also function as feeding perches and may be important for socialising.
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2.3 General Activity Survey
A general bat activity survey was also undertaken on the 15th March 2021 from 18.00 to 20.00 (sunset was 18.29) by walking the Site boundary to include all structures onsite. The weather was optimal for a bat survey with temperatures on the night 14-15oC in calm conditions.
A previous bat survey was carried out on the 11th May 2020, also in suitable conditions. Bat activity and emergence surveys are best carried out mid-March to end of September in suitable weather conditions15 which these surveys were.
The equipment used for the bat activity surveys included 2 x Elekon Bat Logger M detectors. Visual observations were taken with the aid of a powerful L.E.D. torch (AP Pros-Series 220 Lumens High Performance Spotlight).
General Site photos are contained in Appendix A.
2.4 Buildings Assessment Methodology
A bat potential assessment of the buildings and structures onsite was carried out on the 11th May 2020 & 15th March 2021. A Seek Thermal Reveal Pro High- Resolution Thermal Imaging Camera was also used along with a RIDGID 36848 Micro CA-150 Hand-Held Borescope for inspection of any crevices/roof spaces on the building (where accessible). This piece of equipment is fitted with a camera and allows visibility of confined spaces and narrow passages potentially used by hibernating/roosting bats. It allows spaces up to 3m from ground level to be inspected. Bat Mitigation Guidelines for Ireland by Kelleher & Marnell (2006) were followed.
2.5 Bat Potential Tree Assessment
The following Figure 2 is taken from the An Arboricultural Assessment (Aborists Associates Ltd, Feb 2021). The categories correspond to the ‘BS5837: 2012 - Category Retention Rating’
• Category A Trees - Trees of high quality/value with a min. of 40 years life expectancy. • Category B Trees – Trees of moderate quality/value with a min. of 20 years life expectancy. • Category C Trees - Trees of low quality/value with a min. of 10 years life expectancy. • Category U Trees - Trees in such a condition that any existing value would be lost within 10 years or being recommended for removal sound arboricultural practice
15 Kelleher, C. & Marnell, F. (2006) Bat Mitigation Guidelines for Ireland. Irish Wildlife Manuals, No. 25. National Parks and Wildlife Service, Department of Environment, Heritage and Local Government, Dublin, Ireland.
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Figure 2 Tree Plan, areas circled in Red for removal
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Table 3 lists the trees assessed by the arboricultural survey. A photo of each of these trees is included in Appendix A. To facilitate the Proposed Development, it is proposed to remove 20no of the 37no. trees assessed by the arboricultural survey.
Table 3 Summary Table of trees for removal (Arboricultural Assessment - Aborists Associates Ltd, Feb 2021)
Each of the 20 no. trees which have been identified for removal was surveyed on 15th March 2021 to determine the presence of the Potential Roost Features listed below and, to assess whether the trees may be used as important commuting and foraging routes.
• Natural holes (e.g., knot holes) arising from naturally shed branches or branches previously pruned back to a branch collar. • Man-made holes (e.g., cavities that have developed from flush cuts or cavities created by branches tearing out from parent stems). • Cracks/splits in stems or braches (horizontal and vertical). • Partially detached or loose bark plates. • Cankers (caused by localised bark death) in which cavities have developed. • Other hollows or cavities, including butt rots. • Compression of forks with included bark, forming potential cavities. • Crossing stems or branches with suitable roosting space between. • Ivy stems with diameters in excess of 50mm with suitable roosting space behind (or where roosting space can be seen where a mat of thinner stems has left a gap between the mat and the trunk). • Bat or bird boxes. • Other suitable places of rest or shelter.
Certain factors such as orientation of the feature, height from the ground, the direct surroundings and its location in respect to other features may enhance or reduce the potential value.
Trees were then classified into general bat roost potential groups based upon the presence of these features. An evaluation table is shown as Table 4.
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Table 4 Classification and Survey Requirements for Bats in Trees16 Classification Description of Category and Likely Further Survey Work / of Tree Associated Features (based on Actions Potential Roosting Features listed above) Confirmed Roost Evidence of roosting bats in the form A National Parks and Wildlife of live / dead bats, droppings, urine (NPWS) derogation licence staining, mammalian fur oil staining, application will be required if the etc. tree or roost site is affected by the development or proposed arboricultural works. This will require a combination of aerial assessment by roped access bat workers (where possible, health and safety constraints allowing) and nocturnal survey during appropriate periods (e.g. nocturnal survey - May to August) to inform on the licence.
Works to tree undertaken under supervision in accordance with the approved good practice method statement provided within the licence.
However, where confirmed roost site(s) are not affected by works, work under a precautionary good practice method statement may be possible. High Potential A tree with one or more Potential Aerial assessment by roped Roosting Features that are obviously access bat workers (if suitable for larger numbers of bats on appropriate) and / or nocturnal a more regular basis and potentially survey during appropriate period for longer periods of time due to their (May to August). size, shelter protection, conditions (height above ground level, light Following additional assessments, levels, etc.) and surrounding habitat. tree may be upgraded or Examples include (but are not limited downgraded based on findings. to); woodpecker holes, larger If roost sites are confirmed and cavities, hollow trunks, hazard beams,
16 Bat Surveys for Professional Ecologists: Good Practice Guidelines (J., Collins (Bat Conservation Trust), 201616).
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Classification Description of Category and Likely Further Survey Work / of Tree Associated Features (based on Actions Potential Roosting Features listed above) etc. the tree or roost is to be affected by proposals a licence from the NPWS will be required.
After completion of survey work (and the presence of a bat roost is discounted), a precautionary working method statement may still be appropriate.
Moderate A tree with Potential Roosting A combination of aerial Potential Features which could support one or assessment by roped access bat more potential roost sites due to their workers and / or nocturnal size, shelter protection, conditions survey during appropriate (height above ground level, light period (May to August). levels, etc.) and surrounding habitat but unlikely to support a roost of high Following additional assessments, conservation status (i.e., larger roost, tree may be upgraded or irrespective of wider conservation downgraded based on findings. status). After completion of survey Examples include (but are not limited work (and the presence of a to); woodpecker holes, rot cavities, bat roost is discounted), a branch socket cavities, etc. precautionary working method statement may still be appropriate.
If a roost site/s is confirmed a licence from the NPWS will be required. Low Potential A tree of sufficient size and age to No further survey required contain Potential Roosting Features but a precautionary but with none seen from ground or working method statement features seen only very limited may be appropriate. potential. Examples include (but are not limited to); loose/lifted bark, shallow splits exposed to elements or upward facing holes.
Negligible/No Negligible/no habitat features likely None. potential to be used by roosting bats
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2.6 Landscape Evaluation
Ecological survey results were evaluated to determine the significance of identified features located in the study area on an importance scale ranging from international-national-county-local (from NRA, 2009) The local scale is approximately equivalent to one 10km square but can be operationally defined to reflect the character of the area of interest. Because most sites will fall within the local scale, this is sub-divided into two categories: local importance (higher value) and local importance (lower value).
3. RESULTS – May 2020 & March 2021
3.1 General Activity Survey
The results of bat surveys carried out in May 2020 and March 2021 are summarized in Table 5 with the complete dataset of bat species identified in real time in the field using the Elekon Batlogger M detectors presented in Appendix B as a combined data set for both surveys. A map outlining the locations of the bat calls for May 2020 (blue dots) and March 2021 (red dots) is also shown in Figure 3.
In total three species of bat were detected (8 bat passes) for May 2020 and two species (15 passes) for March 2021.
As expected due to the lighting regime on the Site a low rate of bat activity was recorded during both surveys. The most frequent bat species heard was Common Pipistrelle and Leisler’s Bat. During the March 2021 survey an individual bat repeatedly circled the surveyor. This repeated circling resulted in the same individual being recorded on multiple occasions and should not be interpreted as a higher level of activity towards the rear of the Site than was actually the case.
Table 5 Bat Results Summary Data–May 11th 2020 and March 15th 2021 Species Name – Species Name – Total Number of Peak Common Latin Number of Passes Frequency Calls (kHz) 11th May 2020 Common Pipistrelle Pipistrellus pipistrellus 8 2 46.5 Leisler’s Bat Nyctalus leisleri 6 5 26.9 Brown Long Eared Plecotus auritus 1 1 33.2
15th March 2021 Common Pipistrelle Pipistrellus pipistrellus 61 12 46.5 Leisler’s Bat Nyctalus leisleri 5 3 26.9
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Figure 3 Bat Activity Map (11th May 2020 (blue dots) and March 15th 2021 (red dots). Orange oval is area of Tree 0270 (Plate 12) and Tree 0272 (Plate 13). Yellow circle is Tree 0285 (Plate 16)
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3.2 Buildings Assessment Survey
The existing buildings and structures onsite were inspected as per the methodology set out in Section 2.4. All spaces that could potentially allow bats access the buildings were visually examined in detail for bats, signs of bats, or evidence of bat activity, using a torch where necessary. Cracks, crevices etc. were investigated for ingress / egress points and evidence of bat habitation, such as smearing lines, droppings, and staining.
No bat emergence was detected or observed from the buildings and structures onsite during the surveys of May 2020 and March 2021. In addition, the bat potential of the buildings and structures onsite was deemed to be low with no suitable bat roost features observed on external examination of the buildings.
3.3 Bat Potential Tree Assessment
A total of 20 trees have been identified for felling, see Table 3 however, of the 20 trees (see Appendix A – Plates) the majority (16) were classed as ‘Negligible/low’ bat potential. Table 6 gives a summary of the trees assessment for bat potential and should be read in conjunction with the corresponding plates in Appendix A). Figure 3 shows the location of the 3 No. trees with Low/Moderate potential. There was limited or no bat activity at these trees, Trees 0270 and 0272 were located close to street lighting. No bat activity was detected at Tree 0285.
Table 6 Bat Tree Assessment Summary with Recommendations (March 2021), see Plates in Appendix A Plate Tree No. Bat Potential (Potential Roost Recommendations No. Features) 1 0264 2 0263 3 0262 4 0261 Trees should ideally be removed as per 5 0260 Section 40 of the Wildlife Act 1976 - 2000 6 0259 None (as amended) 7 0267
8 0266 9 0265 10 0268 11 0269 12 0270 Low-Moderate bat potential Leave trees for removal in 13 0272 due to presence of holes and September/October 2021. Retain trees if joining limbs on main trunk. Thick possible. ivy and fungi suggesting hollows. 14 0283 Low Trees should ideally be removed as per 15 0284 None Section 40 of the Wildlife Act 1976 - 2000 (as amended)
16 0285 Low-Moderate bat potential Leave tree for removal in due to presence of thick ivy. September/October 2021. Retain tree if possible. 17 0286 None Trees should ideally be removed as per 18 0287 Section 40 of the Wildlife Act 1976 - 2000 19 0288 (as amended) 20 0289
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3.4 Landscape Evaluation
The landscape is considered of local importance (Lower value) for bats due to the presence of Brickfield Park adjacent to the Site. The wider area however is highly urbanised location and assigned a low landscape suitability score for bats.
A Landscaping plan (Park Hood Chartered Landscape Architects, March 2021) is shown as Figure 4 below. This plan incorporates and retains the well-established sections of the ornamental shrub borders to the north of the Site. This section will also be supplemented with native hawthorn to serve as a wildlife corridor which is beneficial to bats. The landscape plan also incorporates high hedges around the main site boundaries of the Site.
Figure 4 Proposed Landscaping Plan (Park Hood Chartered Landscape Architects, March 2021)
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4. MITIGATION
4.1 Tree Removal
Specifically, for removal of trees on Site boundaries, where tree felling is absolutely necessary, the following protocol should be followed for trees classed as ‘Low/Moderate’. No trees of ‘High’ potential were identified:
• Tree-felling should ideally be undertaken in the period late August to late October/early November. During this period bats are capable of flight and may avoid the risks of tree-felling if proper measures are undertaken.
• Felling during the winter months is to be avoided as this creates the additional risk that bats may be in hibernation and thus unable to escape from a tree that is being felled. Additionally, disturbance during winter may reduce the likelihood of survival as the bats’ body temperature is too low and they may have to consume too much body fat to survive.
• Tree-felling can be undertaken using heavy plant and chainsaw. There is a wide range of machinery available with the weight and stability to safely fell a tree. Normally trees are pushed over, with a need to excavate and sever roots in some cases. In order to ensure the optimum warning for any roosting bats that may still be present, an affected tree will be pushed lightly two to three times, with a pause of approximately 30 seconds between each nudge to allow bats to become active. Any affected trees will then be pushed to the ground slowly and should remain in place for a period of at least 24 hours, and preferably 48 hours to allow bats to escape.
• Trees which have been identified as having low/moderate bat potential should not be sawn up or mulched immediately.
4.2 Lighting for Bats
The Public Lighting Report (Fallon Design, M&E Engineering, March 2021) for the proposed development list the following mitigation for ecological consideration:
• The luminaire Veelight Tech Series was chosen which is a full cut off lantern type, that offers with a G6 Glare rating and no upward light making it dark sky friendly. • An inbuilt multi step dimming program within this luminaire allows for night time hours to be dimmed by up to 25%. This means during peak hours of nocturnal foraging, feeding and activity the adjacent public lighting can be further designed to minimize impact on the local wildlife. • The colour rendering of the selected light fitting is 3000k making the LED fittings a warmer light, helping to further minimize the impact on the local wildlife.
The public lighting design references the following documents and best practice guides as outlined by:
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• Bats and Lighting in the UK – Bats and the Built Environment Series (Institute of Lighting Professionals, September 2011 • Guidance Notes for the Reduction of Obtrusive Light GN01 (Institute of Lighting Professionals, 2011. • Bats and Lighting – Guidance Notes for Planners, Engineers, Architects and Developers (Bat Conservation Ireland); • The Eurobats Mitigation of Lighting Document
Finally an important part of the lighting design is the avoidance of using direct lighting onto the trees at Brickfield park (along the Northern boundary of the site) as well as any hedgerows that will be planted along the boundary of the site. Four-meter poles, along with low level recessed ramp lighting for the creche walkway have been selected, which will minimize light pollution into the park and any potential impact to the natural wildlife.
4.3 Roosting Opportunities
A series of 10+ bat boxes will be erected on trees around the Site to provide future roosting opportunities for bats. The type recommended is the 2F Schwegler Bat Box.
5. CONCLUSION
A total of 37no. trees were assessed as part of the Arboriculture Impact Plan. Of these 37no. trees a total of 20no. trees were recommended for removal. Within this cohort a total of 80% of the trees assessed (16no. trees) have no bat potential, 5% (1no. tree) has ‘Low’ potential and 15% (3no. trees) have Low/Moderate Potential. Trees classed as ‘No/Low’ potential should ideally be felled outside the bird nesting season as per Wildlife Acts 1976-2000 as they do not contain potential roost features. Trees classed as ‘Moderate’ should be felled September to late October/early November.
A derogation licence from the National Parks and Wildlife Services (NPWS) may be required for felling if, during tree removal works bats are found to be roosting in any affected trees.
The majority of bat activity is associated with Brickfield Park which lies adjacent to the Site. The Site itself is considered to be of Lower Importance for bats for the following reasons:
• The Site is currently well lit up. • A small number of trees (3) with low/moderate bat potential were identified with limited bat activity in their vicinity. • The buildings onsite have low bat potential.
On the basis of the findings of the survey works completed in May 2020 and March 2021 it is concluded that the overall impact on bats, arising from the Proposed Development, will be most likely negligible given the:
• Overall low rate of bat activity, and the proposed landscape plan (Park Hood Chartered Landscape Architects, March 2021, see Figure 4) to incorporate and retain well-established sections of the ornamental shrub
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borders to the north of the Site. This section will also be supplemented with native hawthorn to serve as a wildlife corridor which is beneficial to bats. The landscape plan also incorporates high hedges around the main site boundaries of the Site. • The public lighting plan (Fallon Design, M&E Engineering, March 2021) which incorporates lighting mitigation for bats.
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APPENDICES APPENDIX A
Plate 1 Tree 0264 (No Potential) Plate 2 Tree 0263 (No Potential) Plate 3 Tree 0262 (No Potential) Plate 4 Tree 0261 (No Potential)
Plate 5 Tree 0260 (No Potential) Plate 6 Tree 0259 (No Potential) Plate 7 Tree 0267 (No Potential) Plate 8 Tree 0266 (No Potential)
Plate 9 Tree 0265 (No Potential) Plate 10 Tree 0268 (No Potential) Plate 11 Tree 0269 (No Potential) Plate 12 Tree 0270 (Low/Mod Potential)
Plate 13 Tree 0272 (Mod Potential) Plate 14 Tree 0283 (Low Potential) Plate 15 Tree 0284 (No Potential) Plate 16 Tree 0285 (Mod Potential)
Plate 17 Tree 0286 (No Potential) Plate 18 Tree 0287 (No Potential) Plate 19 Tree 0288 (No Potential) Plate 20 Tree 0289 (No Potential)
Plate 21 General Site Photos. Plate 22 General Site Photos.
Plate 23 Buildings to the rear. Plate 24 Hedgerow/treelines boundary between site and Brickfield Park.
Plate 25 Trees at entrance to site, no bat potential. Plate 26 Area to rear of site.
APPENDIX B Mean Peak Mean Max Mean Min Calls Frequency Frequency Frequency Mean Call Temperature Latitude Longitude 11/05/2020 Species [#] [kHz] [kHz] [kHz] Length [ms] [°C] [WGS84] [WGS84] 21:18:43 Leisler's Bat 1 21.4 22.3 20.7 9.2 11 53.33074 -6.30488 21:58:14 Common Pipistrelle 7 46.9 54.4 46.5 3 10 53.33085 -6.30464 22:46:54 Leisler's Bat 1 21.7 24.1 20.1 6.6 10 53.3308 -6.30445 Brown Long Eared 22:50:13 Bat 1 33.2 35.1 32.6 2 10 53.33067 -6.3039 22:51:56 Leisler's Bat 2 24.4 24.4 24.1 7.2 10 53.33044 -6.30376 23:08:13 Leisler's Bat 1 24.1 24.4 24.1 9.2 10 53.33066 -6.30544 23:11:47 Leisler's Bat 1 24.4 24.4 24.1 12.5 10 53.33053 -6.30372 23:27:37 Common Pipistrelle 1 44.5 44.8 44.5 6.6 10 53.33053 -6.30566
15/03/2021 19:33:48 Common Pipistrelle 4 46.8 50.8 46.4 4 15 53.33068 -6.30566 19:33:52 Common Pipistrelle 10 45.3 52.7 44.8 6 15 53.33068 -6.30565 19:35:06 Common Pipistrelle 1 44.5 47 44.5 3.3 15 53.33072 -6.30546 19:41:10 Common Pipistrelle 3 46.3 50.7 45.9 4.4 14 53.3307 -6.30528 19:42:00 Common Pipistrelle 5 47.5 54.3 46.3 5.4 15 53.33056 -6.30552 19:43:54 Common Pipistrelle 5 48 56.5 47.6 5 15 53.33033 -6.30549 19:45:55 Common Pipistrelle 6 47.6 53.4 47.2 5.2 14 53.33056 -6.30565 19:46:19 Leisler's Bat 2 27 27.3 26.8 13.1 14 53.33058 -6.30558 19:46:21 Common Pipistrelle 12 46.9 50.7 46.6 5 14 53.33058 -6.30558 19:50:22 Leisler's Bat 4 24.9 26.1 23.5 9.5 15 53.33064 -6.30417 19:50:32 Leisler's Bat 10 25 26.8 23.5 9.8 15 53.33064 -6.30417 19:57:38 Common Pipistrelle 1 47.3 51.9 47 2.6 15 53.33051 -6.30578 19:57:42 Common Pipistrelle 3 47 52.8 46.7 2.6 15 53.33048 -6.30577 19:58:06 Common Pipistrelle 5 46.7 48.5 46.1 8.9 15 53.33055 -6.30587 19:58:39 Common Pipistrelle 5 45.8 53.1 45.5 5 15 53.3305 -6.30572