Natura Impact Statement Shannon Airport Embankments

Natura Impact Statement

Shannon Airport Embankments Refurbishment,

Shannon, Co. Clare

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19986-6002-C Natura Impact Statement March 2020

ISSUE FORM Project number 19986 Document number 6002 Document revision D (31.7.2020) Document title Natura Impact Statement: Shannon Airport Embankments Refurbishment, Shannon, Co. Clare Document status Final Document prepared by Document checked by

19986-6002-D Natura Impact Statement June 2020

Table of contents

1 SUMMARY OF FINDINGS ...... 7 2 INTRODUCTION ...... 8

2.1 CLARE COUNTY COUNCIL OBSERVATIONS...... 9 3 METHODOLOGY ...... 11

3.1 APPROPRIATE ASSESSMENT GUIDANCE ...... 11 3.2 CONSULTATION ...... 11 3.3 DESK STUDY ...... 11 3.4 FIELD SURVEYS ...... 12 3.4.1 Site Walkover/Habitats ...... 12 3.4.2 Flora ...... 13 3.4.3 Otter ...... 13 3.5 WAVE MODELLING...... 13 3.6 ASSESSMENT OF POTENTIALLY SIGNIFICANT EFFECTS ...... 13 3.7 BRIEF OVERVIEW OF SCREENING FOR APPROPRIATE ASSESSMENT ...... 14 3.8 CONCLUSIONS OF THE SCREENING FOR APPROPRIATE ASSESSMENT ...... 14 3.9 REASONS FOR ASSESSMENT ...... 14 4 DESCRIPTION OF THE PROJECT ...... 15

4.1 BRIEF PROJECT DESCRIPTION ...... 15 4.2 PURPOSE OF THE PROJECT ...... 15 4.3 SITE LOCATION AND CONTEXT ...... 17 4.4 CHARACTERISTICS OF THE PROJECT ...... 18 5 DESCRIPTION OF THE RECEIVING ENVIRONMENT ...... 21

5.1 GEOLOGY/LAND USE ...... 21 5.2 HYDROGEOLOGY ...... 22 5.3 INTERTIDAL PROCESSES ...... 22 5.4 SURFACE WATER ...... 22 5.4.1 Watercourses ...... 22 5.4.2 Shannon Airport Lagoon ...... 23 5.5 HUMAN POPULATION AND LAND USE ...... 25 5.6 HABITATS AND FLORA ...... 25 5.7 FAUNA ...... 31 5.7.1 Otter ...... 31 5.7.2 Avifauna ...... 31 5.7.3 Fish ...... 34 6 IDENTIFICATION OF OTHER PROJECTS, PLANS AND ACTIVITIES ...... 35

6.1 WASTEWATER TREATMENT PLANT ...... 35 6.2 LICENSED SITES ...... 36 6.3 PLANS ...... 37 6.4 PLANNING APPLICATIONS ...... 38 6.5 ONGOING ACTIVITIES ...... 41 6.5.1 Shannon Airport ...... 41 7 IDENTIFICATION OF NATURA 2000 SITES ...... 43

7.1 LOWER RIVER SHANNON CSAC (002165) ...... 44 7.1.1 Description of the Natura 2000 Site ...... 44

19986-6002-D Natura Impact Statement June 2020

7.1.2 Identification of Potential for Significant Impacts to Qualifying Features ...... 46 7.1.3 Qualifying Features Selected for Further Assessment ...... 55 7.2 RIVER SHANNON AND RIVER FERGUS ESTUARIES SPA (004077) ...... 66 7.2.1 Description of the Natura 2000 Site ...... 66 7.2.2 Identification of Potential for Significant Impacts to Qualifying Features ...... 69 7.2.3 Qualifying Features Selected for Further Assessment ...... 75 8 ASSESSMENT OF POTENTIALLY SIGNIFICANT EFFECTS ...... 81

8.1 WATER QUALITY ...... 81 8.1.1 Construction Phase ...... 81 8.1.2 Operational Phase ...... 82 8.2 HABITAT LOSS/ALTERATION ...... 82 8.2.1 Lower River Shannon cSAC ...... 82 8.2.2 River Shannon and River Fergus Estuaries SPA (004077) ...... 86 8.3 DISTURBANCE AND/OR DISPLACEMENT OF SPECIES ...... 87 8.4 HABITAT OR SPECIES FRAGMENTATION ...... 88 8.5 ASSESSMENT OF SIGNIFICANCE OF POTENTIAL IMPACTS ...... 88 8.5.1 Habitat Loss and Alteration ...... 88 8.5.2 Habitat or Species Fragmentation ...... 90 8.5.3 Disturbance and/or Displacement of Species ...... 91 8.5.4 Water Quality ...... 91 8.6 ASSESSMENT OF EFFECT ON CONSERVATION OBJECTIVES ...... 92 8.6.1 Lower River Shannon cSAC ...... 92 8.6.2 River Shannon and River Fergus Estuaries SPA ...... 99 8.7 ASSESSMENT OF POTENTIALLY SIGNIFICANT CUMULATIVE EFFECTS ...... 114 9 MITIGATION ...... 115 9.1.1 CEMP and Method statements ...... 116 9.1.2 Protection of Habitats ...... 117 9.1.3 Project Ecologist ...... 117 9.1.4 Temporary Construction Compound(s) ...... 118 9.1.5 Excavation and Embankment Works ...... 118 9.1.6 Storage and Stockpiles of Excavated Material ...... 119 9.1.7 Storage of Other Materials ...... 120 9.1.8 Timing of Works ...... 121 9.1.9 Hydrocarbon Control ...... 121 9.1.10 Waste Management ...... 122 9.1.11 Emergency Response Plan ...... 122 9.1.12 Construction Noise...... 124 9.1.13 Otters ...... 124 9.1.14 Invasive Species Control ...... 124 10 RESIDUAL IMPACTS ...... 125 10.1.1 Lower River Shannon cSAC ...... 125 10.1.2 River Shannon and River Fergus Estuaries SPA ...... 137 11 CONCLUSION ...... 1 12 REFERENCES ...... 2

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19986-6002-D Natura Impact Statement June 2020

Table of tables Table 1 Items of concern and where in the NIS they have been addressed...... 9 Table 2 Natura 2000 sites within 15km radius of the proposal site ...... 14 Table 3 Habitats identified within the study area ...... 28 Table 4 Waterbird species recorded during surveys at Sub-sites 0H510 and 0H512 at low and high tides across all behaviours and habitats (2010/2011 Waterbird Survey Programme) ...... 32 Table 5: Proportional use of subsites in the study area by species relative to the whole area surveyed on each survey occasion during 2017 and 2018: L = Low; M = Moderate; H = High; V = Very High. Adapted from MKO (2019)...... 34 Table 6: Incidence of Whooper Swans from weekly counts at the Shannon Airport Lagoon 2005 to 2019 (data provided by SAA)...... 34 Table 7 List of planning permissions granted by Clare County Council in surrounding townlands for the period 2014-2019 ...... 38 Table 8 Impacts and activities with high effect on the Lower River Shannon cSAC (Adapted from the Natura 2000 Standard Data Form) ...... 41 Table 9 Key Points extrapolated from DAA Sustainability Report 2011 on Shannon Airport ...... 43 Table 10 Identification of potential for significant impacts to qualifying features of the Lower River Shannon cSAC ...... 48 Table 11 Attributes and targets for ‘Estuaries’ within the Lower Shannon SAC (NPWS, 2012a) ...... 55 Table 12 Attributes and targets for ‘Mudflats and sand flats not covered by sea water at low tide’ within the Lower River Shannon cSAC (NPWS, 2012a) ...... 57 Table 13 ‘Coastal Lagoons’ within the Lower River Shannon cSAC (NPWS, 2012a) ...... 59 Table 14 Attributes and targets for ‘Coastal lagoons’ within the Lower River Shannon cSAC (NPWS, 2012a) ...... 60 Table 15 Attributes and targets for ‘Atlantic salt meadows’ within the Lower River Shannon cSAC (NPWS, 2012a) ...... 61 Table 16 Attributes and targets for ‘Vegetation of flowing waters’ within the Lower River Shannon cSAC (NPWS, 2012a) ...... 63 Table 17 Attributes and targets of otter within the Lower River Shannon cSAC (NPWS, 2012a) ...... 65 Table 18 Ecological Characteristics, requirements and specialities of non-breeding waterbird SCI species for River Shannon and River Fergus Estuaries SPA ...... 68 Table 19 Identification of potential for significant impacts to qualifying features of the River Shannon & Fergus River Estuaries SPA ...... 69 Table 20 Attributes and targets of cormorant in the River Shannon and River Fergus estuaries SPA (NPWS, 2012b) ...... 75 Table 21 Attributes and targets for relevant SCIs in the River Shannon and River Fergus estuaries SPA (NPWS, 2012b) ...... 79 Table 22 Attributes and targets for wetlands in the River Shannon and River Fergus Estuaries SPA (NPWS, 2012b) ...... 79 Table 23 Assessment of potential impacts of the project on ‘wetlands’...... 87 Table 24 Assessment of potential impacts of the project on estuaries...... 93 Table 25 Assessment of potential impacts of the project on mudflats ...... 93 Table 26 Assessment of potential impacts of the project on coastal lagoons ...... 94 Table 27 Assessment of potential impacts of the project on Atlantic salt meadows...... 95 Table 28 Assessment of potential impacts of the project on ‘Vegetation of flowing waters’ ...... 97 Table 29 Assessment of conservation objectives and potential impact for Cormorant [A017] ...... 100

19986-6002-D Natura Impact Statement June 2020

Table 30 Assessment of conservation objectives and potential impacts for Whooper Swan [A038] 102 Table 31 Assessment of conservation objectives and potential impacts for Light-bellied Brent Geese [A046] ...... 103 Table 32 Assessment of conservation objectives and potential impacts for Shelduck [A048] ...... 103 Table 33 Assessment of conservation objectives and potential impacts for Wigeon [A050] ...... 104 Table 34 Assessment of conservation objectives and potential impacts for Teal [A052] ...... 105 Table 36 Assessment of conservation objectives and potential impacts for Shoveler [A056] ...... 105 Table 39 Assessment of conservation objectives and potential impacts for Golden Plover [A140] .. 106 Table 40 Assessment of conservation objectives and potential impacts for Grey Plover [A141] ...... 107 Table 41 Assessment of conservation objectives and potential impacts for Lapwing [A142] ...... 107 Table 42 Assessment of conservation objectives and potential impacts for Knot [A143] ...... 108 Table 43 Assessment of conservation objectives and potential impacts for Dunlin [A149] ...... 109 Table 44 Assessment of conservation objectives and potential impacts for Black-tailed Godwit [A156] ...... 109 Table 45 Assessment of conservation objectives and potential impacts for Bar-tailed Godwit [A157] ...... 110 Table 46 Assessment of conservation objectives and potential impacts for Curlew [A160]...... 111 Table 47 Assessment of conservation objectives and potential impacts for Redshank [A162] ...... 112 Table 48 Assessment of conservation objectives and potential impacts Greenshank [A164] ...... 112 Table 49 Assessment of conservation objectives and potential impacts for Black-headed Gull [A179] ...... 113 Table 50 Assessment of conservation objectives and potential impacts to wetlands [A999] ...... 114 Table 51 Example of a significance indicator (from EC, 2002)...... 126 Table 52 Intertidal habitats directly affected and percentage loss within the Lower River Shannon cSAC...... 126 Table 53 Summary of residual impacts of the proposed embankments refurbishment project on ‘estuaries’ in the lower River Shannon SAC ...... 128 Table 54 Summary of residual impacts of the proposed embankments refurbishment project on ‘mudflats and sandflats not covered by seawater at low tide’ in the lower River Shannon SAC...... 129 Table 55 Summary of residual impacts of the proposed embankments refurbishment project on ‘coastal lagoons’ in the Lower River Shannon cSAC ...... 130 Table 56 Summary of residual impacts of the proposed embankments refurbishment project on ‘Atlantic salt meadows’ in the lower River Shannon SAC...... 133 Table 57 Assessment of potential impacts of the project on ‘Vegetation of flowing waters’ ...... 135 Table 58 Assessment of conservation objectives and potential impact for Cormorant [A017] ...... 137 Table 59 Assessment of conservation objectives and potential impacts for Whooper Swan [A038] 139 Table 60 Assessment of conservation objectives and potential impacts for Light-bellied Brent Geese [A046] ...... 140 Table 61 Assessment of conservation objectives and potential impacts for Shelduck [A048] ...... 140 Table 62 Assessment of conservation objectives and potential impacts for Wigeon [A050] ...... 141 Table 63 Assessment of conservation objectives and potential impacts for Teal [A052] ...... 142 Table 65 Assessment of conservation objectives and potential impacts for Shoveler [A056] ...... 142 Table 68 Assessment of conservation objectives and potential impacts for Golden Plover [A140] .. 143 Table 69 Assessment of conservation objectives and potential impacts for Grey Plover [A141] ...... 144 Table 70 Assessment of conservation objectives and potential impacts for Lapwing [A142] ...... 144 Table 71 Assessment of conservation objectives and potential impacts for Knot [A143] ...... 145

19986-6002-D Natura Impact Statement June 2020

Table 72 Assessment of conservation objectives and potential impacts for Dunlin [A149] ...... 146 Table 73 Assessment of conservation objectives and potential impacts for Black-tailed Godwit [A156] ...... 146 Table 74 Assessment of conservation objectives and potential impacts for Bar-tailed Godwit [A157] ...... 147 Table 75 Assessment of conservation objectives and potential impacts for Curlew [A160]...... 148 Table 76 Assessment of conservation objectives and potential impacts for Redshank [A162] ...... 148 Table 77 Assessment of conservation objectives and potential impacts Greenshank [A164] ...... 149 Table 78 Assessment of conservation objectives and potential impacts for Black-headed Gull [A179] ...... 150 Table 79 Assessment of conservation objectives and potential impacts to wetlands [A999] ...... 150

Table of figures Figure 1 Indicative proposed embankments work extent, Shannon Airport, Co. Clare...... 17 Figure 2 Habitats at the western embankment ...... 26 Figure 3 Habitats at the eastern embankment ...... 27 Figure 4 Count sub-site boundaries for the 2010/11 Waterbird Survey Programme (Source NPWS, 2012b) ...... 31 Figure 5 Distribution of estuaries within the Lower River Shannon cSAC (NPWS, 2012a) ...... 56 Figure 6 Distribution of mudflats and sandflats within the Lower River Shannon cSAC (NPWS, 2012a) ...... 57 Figure 7 Distribution of marine community types within the inner Shannon Estuary (NPWS, 2012a) 58 Figure 8 Shannon Airport Lagoon (NPWS, 2012a) ...... 59 Figure 9 Distribution of saltmarsh habitats within the Lower River Shannon cSAC (NPWS, 2012a) .... 62 Figure 10 Distribution of floating river vegetation within the Lower River Shannon cSAC (NPWS, 2012a) ...... 64 Figure 11 Extent of mapped ‘commuting buffer’ for otter within the Lower River Shannon cSAC (NPWS, 2012a) ...... 66 Figure 12 Extent of proposed armorflex ...... 90

Appendices Appendix 1 Screening for Appropriate Assessment Appendix 2 Shannon Embankment Modelling Appendix 3 Outline Construction Environment Management Plan

19986-6002-C Natura Impact Statement March 2020

1 SUMMARY OF FINDINGS

Project Title Shannon Airport Embankments Refurbishment Project Proponent Shannon Airport Authority Project Location Shannon Airport Embankments, Shannon, Co. Clare In cases where an Appropriate Assessment is required a Natura Impact Statement (NIS) is prepared. This is a report based on a scientific examination of Natura Impact evidence and data, carried out by competent persons with the aim of identifying Statement and classifying any implications of a proposal, either individually, or in combination with other plans or projects, on Natura 2000 sites in view of the conservation objectives of the sites. Mitigation measures have been outlined primarily in relation to maintaining Summary of Mitigation existing water quality. In conclusion, provided the recommended mitigation measures are implemented in full it is not expected that the proposed Shannon Embankments refurbishment will result in any significant adverse residual impacts on the Natura 2000 sites considered in this NIS, namely: Conclusion

 Lower River Shannon cSAC (002165)  River Shannon and River Fergus Estuaries SPA (004077)

19986-6002-D Natura Impact Statement June 2020

2 INTRODUCTION Appropriate Assessment is the consideration of the impact on the integrity of the Natura 2000 site of the project, either alone or in combination with other plans or projects, with respect to the site’s ecological structure and function, and conservation objectives. Additionally, mitigation of these impacts can be considered. A Screening for Appropriate Assessment was completed and determined the need for full Appropriate Assessment (Appendix 1).

In cases where an Appropriate Assessment is required a Natura Impact Statement (NIS) shall be prepared and shall include a report of a scientific examination of evidence and data, carried out by competent persons to identify and classify any implications for Natura 2000 sites in view of the conservation objectives of the site. The aim of the assessment is to provide a sufficient level of information to the competent authority on which to base their appropriate assessment of the plan or project. The plan or project should be fully described, particularly in relation to the aspects that could interact with the surrounding environment. The proposed Shannon Embankments refurbishment works are described in Section 4 below.

The focus of the assessment is to determine whether the proposed Shannon Airport Authority (SAA) refurbishment works at the existing Shannon Embankments at Shannon Airport, Shannon, County Clare, will have a significant negative impact on the features of interest of the Natura 2000 site i.e. habitats and species. This assessment identifies the environmental aspects of the project that will interact with the ecological requirements or sensitivities of the habitats and species, and in this case these relate mainly to loss of loss/alteration of estuarine habitat and potential impacts to water quality during the construction phase of the project, as well as potential cumulative/in-combination effects throughout the undertaking of the project.

An NIS (19986-6002-B) was prepared and submitted to the Development Application Unit (DAU) of the Department of Culture, Heritage and Gaeltacht. The DAU forwarded their observations to Clare County Council (CCC) on the 31st January 2020. CCC wrote to SAA on 20th February outlining a number of environmental related observations. CCC considered that the information submitted with this application was insufficient to enable the Planning Authority make a complete planning assessment of the proposal. In order to proceed with the application, further information/revised plans were required by CCC. Further information/revisions as required have been included in this updated report. The CCC observations relating to the NIS, as well as where addressed are provided in Section 1.1. Additional information and noteworthy changes to the former NIS have been underlined throughout this document.

The ‘test’ of the assessment is whether the plan or project will have an adverse effect on the integrity of the Natura 2000 site. Where potentially significant effects are identified proven, mitigation measures will be recommended. This Natura Impact Statement has been completed by staff ecologists with Malachy Walsh and Partners, Engineering and Environmental Consultants.

Concerns in relation to potential impacts on coastal processes at the east embankment have been dealt with in a coastal processes modelling report.

19986-6002-D Natura Impact Statement June 2020

2.1 CLARE COUNTY COUNCIL OBSERVATIONS Having reviewed the Natura Impact Statement (NIS), CCC considered that there was insufficient scientific evidence to allow it to conclude a finding of no adverse effects on the integrity of the associated European sites. It was stated, as per Point 2, that the NIS did not contain complete, precise and definitive findings, and it was considered there were lacunae (gaps) in the information provided. CCC stated that it could not be demonstrated beyond scientific doubt that the proposal was in keeping with the conservation objectives for the Lower River Shannon cSAC and River Shannon and Fergus Estuaries SPA. In light of these concerns, the project proponent was requested to submit a revised NIS which addressed a number of items. Table 1 lists the items of concern and where in the NIS they have been addressed.

Table 1 Items of concern and where in the NIS they have been addressed. a) The Natura Impact Statement (NIS) identifies a series Residual impacts Section “10.1.1 Lower of potential impacts arising from the proposed works which River Shannon cSAC” provides a scientific may impact on the SAC, the likely significant impacts of which rationale for the conclusion of loss of are not clearly identified or explained. In order for the Planning habitats being “not significant”. Authority as the Competent Authority to fully assess and come to a definitive conclusion on the proposed coastal defence An additional section has been added to the refurbishment works and its suitability against all other report: Section 10 sets out the Conservation feasible options and alternatives considered, the importance Objectives of both the Lower River Shannon of the direct loss of the Annex I Habitat - Estuaries (1130) and SAC and the River Shannon and River Fergus the removal/alteration of the Annex I habitat, Mudflats and Estuaries SPA (as identified in the zone of sand flats not covered by seawater at low tide (1140) are influence). This section measures the impact required to be scientifically justified. of the project against conservation objectives for these sites, taking account of The loss of these habitats is noted as being “not significant” mitigation. however there is no clear scientific justification for this conclusion. The NIS clearly states that there will be land-take The 2009 Department of Environment, within both the SAC and SPA. The target for the attribute Heritage and Local Government Guidance on “Habitat Area” for the conservation objectives for habitat Appropriate Assessment, as well as EC types 1130 & 1140 is that “the permanent habitat area is (2006) and EC (2018) has been applied. stable or increasing, subject to natural processes”. The impact of this permanent habitat loss from the SAC needs to be considered in the context of the conservation objectives and a scientifically robust assessment provided as to why it is deemed “insignificant” in the context of the Conservation Objectives. You are advised to have regard to The 2009 Department of Environment, Heritage and Local Government Guidance on Appropriate Assessment in respect of this item. b) lt is noted that a100m section of the east Additional information has been provided in embankment will have armourflexing so as not to disturb the Section 8.5.1 in relation to armorflex and salt marsh habitat. This element of the project is not explained disturbance to saltmarsh and impacts on the fully in the NIS even though it proposed as a solution to avoid SAC, including a map illustrating the extent loss of Annex 1 habitat (salt marsh). Detailed drawings of proposed armorflex. indicating the location of the armourflexing in proximity to the Annex 1 habitat is required together with an analysis of the impact of this material on the SAC. c) It is noted that field surveys were carried out on the Site surveys were undertaken by Malachy 24th February and 2nd April 2018 and a botanical survey on Walsh and Partners on February 24th and the 8th August 2018. However the habitats identified are April 2nd 2019. The aim of these surveys was referred to from site visit in July 2018. It is not clear in the NIS to characterise the site and environs and what survey this was related to and whether it was part of the establish the ecological features and initial screening for AA report. Please clarify this issue. resources at the site, particularly in relation to the conservation interests of the Lower River Shannon cSAC.

19986-6002-D Natura Impact Statement June 2020

A dedicated botanical survey was undertaken on August 8th 2019 by Michelle O’Neill of Cluain Ecology. A qualitative assessment was made of plant species diversity, vegetation structure, topography and drainage, disturbance and management. Habitats were categorised according to the Heritage Council’s A Guide to Habitats in Ireland (Fossitt, 2000). Notes were made on all habitats encountered, including notes on dominant and indicative vegetation.

These surveys were carried out to inform the Screening Report, the findings were also used in the NIS report. d) With regard to the SPA, all detail in respect of birds The Final Survey Report for Waterfowl focuses on the IWeBs data (2010- 2011). You are advised that Numbers, Usage and Distribution of the there is more up to date data from Birdwatch Ireland which River Shannon and the River Fergus Estuaries should also be considered by you in the analysis relating to (MKO, 2019) has been used to assess the potential disturbance of species that use the Shannon Airport importance of the study area for the birds of Lagoon. You are also advised to have regard to the Bird usage SCI in the SPA. A data request was submitted Survey of the River Shannon and Fergus Estuaries 2017- 2018 to IWEBS/Birdwatch Ireland for subsites in undertaken by the SIFP Steering Group. the study area. The only relevant Birdwatch data for the proposed development is for the lagoon (subsite 0H492), with 2019/2020 data available. No data was available for 0H491 (Shannon & Fergus estuaries ) since 2012 due to lack volunteer counters in this area, and therefore nothing recent enough for review. e) The NIS identifies a series of potential impacts arising Works will be carried out during daylight from the proposed works which may impact on the SPA, the hours. There will be no requirement for likely significant impacts of which are not clearly identified or lighting during the works either at the site explained. Please indicate if it is intended to use lighting during compound or by machinery within the work the works either at the site compound or by machinery within zone. The predicted working hours are from the work zone. Please also indicate the predicted working 8.30 – 18.30. hours. Should lighting be deemed necessary this should be assessed within the relevant environmental assessments. f) The timing of works is particularly important with The duration of the proposed works is regard to the potential for disturbance on over wintering bird approximately 6-9 months. It is envisaged species. Please indicate the length of time required to that the works will take place between complete the project, as details submitted in this regard are January 2021 and December 2021. It is not clear. recommended as per section 9.1.8 that works will be undertaken between February and October inclusive to limit disturbance during the peak wintering season. Works will be undertaken at each embankment in a staged manner (at a number of locations (2 to 3) on each embankment at the same time). This will be governed by access and storage space limitations. g) Please submit full details of all mitigation measures Additional mitigation has been included in proposed together with any emergency response measures. the NIS as follows: The likely effects of the mitigation measures should be  Outline CEMP (Section 9.1.1 and Appendix assessed in the NIS demonstrating their effectiveness on a site 3); and specific basis. These measures need to form part o the  Emergency Response Plan (Section 9.1.11) assessment within the NIS in particular, but also the EIA

19986-6002-D Natura Impact Statement June 2020 screening. The mitigation as outlined in Chapter 9 of the NIS Extra mitigation has also been providing in relies heavily on post consent mitigation and lacks the the following sections: scientific evidence for the Competent Authority to assess (if any) the resulting residual effects. Mitigation measures such as  Protection of Habitats (Section 9.1.2); “Minimise the footprint of the development to avoid  Excavation and Embankment Works impacting the lagoon and reduce insofar as possible the extent (Section 9.1.5); of mudflat directly affected” is difficult to assess as it may  Storage of Other Materials (Section 9.1.7); require alteration to the design, methodology etc post consent  Timing of Works (Section 9.1.8); and and therefore cannot be fully assessed. Please therefore  Construction Noise (Section 9.1.12) submit a revised NIS which addresses the mitigation measures. Additional assessment has been included in Section 10 (Residual impacts), where Conservation Interests of the ‘Lower River Shannon SAC’ (Section 10.1) and ‘The River Shannon and River Fergus Estuaries SPA’ (Section 10.2) identified as being potentially affected have been assessed in relation to potential impacts, mitigation measures and residual impacts against conservation objectives h) lt is indicated as part of the application that a An Outline CEMP has been prepared and will Construction Environmental Management Plan (CEMP) will be be submitted with the application. This prepared by the appointed contractor for the project in incorporates all of the proposed mitigation advance of works commencing. Given the extremely sensitive measures. nature of the surrounding environment the Planning Authority considers that an Outline CEMP should be submitted. This CEMP should be prepared in close consultation with the project ecologist and should incorporate all of the proposed mitigation measures and method statements.

3 METHODOLOGY

3.1 APPROPRIATE ASSESSMENT GUIDANCE This Natura Impact Statement, Stage 2, has been undertaken in accordance with the European Commission Methodological Guidance on the provision of Article 6(3) and 6(4) of the ‘Habitats’ Directive 92/43/EEC (EC, 2001) and the European Commission Guidance ‘Managing Natura 2000 sites’ (EC, 2000) and guidance prepared by the NPWS (DoEHLG, 2009).

The aim of the assessment is to provide a sufficient level of information to the competent authority on which to base their appropriate assessment of the plan or project.

3.2 CONSULTATION Consultation was undertaken with the Development Applications Unit of the Department of Culture, Heritage & The Gaeltacht.

3.3 DESK STUDY In order to complete the Natura Impact Statement certain information on the existing environment is required. A desk study was carried out to collate available information on the subject site’s natural environment. This comprised a review of the following publications, data and datasets:

 OSI Aerial photography and 1:50000 mapping, and other mapping sources (online)

19986-6002-D Natura Impact Statement June 2020

 National Parks and Wildlife Service (NPWS) (online) including: o Conservation Objectives o Site data o Article 17 reports for habitats and species  National Biodiversity Data Centre (NBDC) (online)  BirdWatch Ireland, IWeBS and the Final Survey Report for Waterfowl Numbers, Usage and Distribution of the River Shannon and the River Fergus Estuaries (MKO, 2019)  Teagasc soil area maps (NBDC website)  Geological Survey Ireland (GSI) area maps (online)  Environmental Protection Agency (EPA)(online) including: o EPA maps o Licence reports  Shannon River Basin District (ShIRBD) datasets (Water Framework Directive) (online)  IFI WFD Fish Survey Map  Clare County Development Plan 2017 – 20231  Shannon Town and Environs Local Area Plan 2012 – 2018 (amendment 1)2  Other information sources and reports footnoted or referenced in the course of the report.

The Final Survey Report for Waterfowl Numbers, Usage and Distribution of the River Shannon and the River Fergus Estuaries (MKO, 2019) has been used to assess the importance of the study area for the birds of SCI in the Shannon Estuary.

Shape files downloaded from the websites of the NPWS and EPA were used to generate maps on a Geographic Information System (GIS) platform. This mapping was used to illustrate information, including SAC boundaries, and display important habitats and species of conservation interest in the study area.

3.4 FIELD SURVEYS

3.4.1 Site Walkover/Habitats An ecological field survey was conducted by staff ecologists with Malachy Walsh and Partners Environmental Consultants on February 24th and April 2nd 2019. The aim of these surveys was to characterise the site and environs and establish the ecological features and resources at the site, particularly in relation to the conservation interests of the Lower River Shannon cSAC.

Aerial photography was used together with GPS to accurately enable field navigation. Notes were made on all habitats encountered, including notes on dominant and indicative vegetation. A qualitative assessment was made of plant species diversity, vegetation structure, topography and drainage, disturbance and management. Habitats were categorised according to the Heritage Council’s A Guide to Habitats in Ireland (Fossitt, 2000). The presence of invasive plant species was noted.

1 http://www.clarecoco.ie/services/planning/publications/clare-county-development-plan-2017-2023-volume-3a-ennis-municipal-district- written-statement-and-maps-24146.pdf [accessed 10/07/2019] 2 http://www.clarecoco.ie/services/planning/local-area-plans/shannon-town-and-environs-local-area-plan%202012-2018/ [accessed 10/07/2019] 12

19986-6002-D Natura Impact Statement June 2020

The survey included an aquatic habitat assessment of the surface water features adjacent to the site. Physical characteristics were noted and evaluated in cognisance of the leaflet ‘The Evaluation of habitat for Salmon and Trout’ (DANI, 1995) and the publication ‘Ecology of the Atlantic Salmon’ (Hendry and Cragg-Hine, 2003) to assess habitat suitability for salmonids. An evaluation of lamprey nursery habitat was also carried out based on the habitat requirements of juvenile lampreys as outlined in Maitland (2003).

3.4.2 Flora A dedicated botanical survey was undertaken on August 8th by of Cluain Ecology.

3.4.3 Otter Searches for signs of otter including tracks, spraints, slides, hauling-out sites and holts were carried out. The otter survey was conducted according to methodology described in Animal Tracks and Signs (Bang and Dahlstrom, 2001), and The Mammal Detective (Strachan, 1995).

3.5 WAVE MODELLING In order to allay possible concerns regarding the potential impact such refurbishment works might have on coastal processes in the vicinity of the works modelling of a number of wave, tide and sediment transport conditions have been undertaken for the existing situation and following refurbishment works. Modelling was undertaken of the combined wave and water level conditions and the resulting sediment transport of the intertidal muds (silt sized material) for the existing case and with the works in place.

The modelling examined the case of a neap tide, a spring tide and a surge tide with a joint wave water level probability of 0.05% selected for maximum wave height at the embankment, obtained from the OPW's Irish Coastal Wave and Water Level Study modelling results for the more exposed area of the east embankment. A reflection wave assessment was carried out, based on equation 5.72 and Table 5.14 of the CIRIA guide, C683, the Rock Manual (CIRIA et al, 2007). The modelling report is provided (See Appendix 2).

3.6 ASSESSMENT OF POTENTIALLY SIGNIFICANT EFFECTS As set out in the NPWS guidance, the task of establishing whether a plan or project is likely to have an effect on a Natura 2000 site(s) is based on a preliminary impact assessment using available information and data, including that outlined above, and other available environmental information, supplemented as necessary by local site information and ecological surveys. This is followed by a determination of whether there is a risk that the effects identified could be significant. The precautionary principle approach is required.

Once the potential impacts that may arise from the proposal are identified the significance of these is assessed through the use of key indicators in the screening process:

 Habitat loss  Habitat alteration  Habitat or species fragmentation  Disturbance and/or displacement of species  Water quality and resource.

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3.7 BRIEF OVERVIEW OF SCREENING FOR APPROPRIATE ASSESSMENT A screening for Appropriate Assessment was carried out for the proposal. The full screening for Appropriate Assessment report is available in Appendix 1. The test for the screening for Appropriate Assessment is to assess, in view of best scientific knowledge, if the proposal, individually or in combination with other plans/projects is likely to have a significant affect on a Natura 2000 site. If there are any significant, potentially significant, or uncertain effects, it will be necessary to proceed to Appropriate Assessment and submit an NIS. Adopting the precautionary principle in identifying potentially affected European sites, all SACs and SPAs within a 15km radius of the proposal site were included. Designated SAC and SPA sites within 15km of the proposal including their proximity are shown in Table 2 below.

Table 2 Natura 2000 sites within 15km radius of the proposal site No. Designated Sites Site Code Proximity of subject site to nearest point of designated site 1 Lower River Shannon cSAC 002165 Within and adjacent to the proposal site 2 River Shannon and River Fergus 004077 Within and adjacent to the proposal site Estuaries SPA 3 Askeaton Fen Complex SAC 002279 5.5km to the south of the proposal site 4 Lough Gash Turlough SAC 000051 6.3km to the north of the proposal site 5 Curraghchase Woods SAC 000174 7.5km to the south-east of the proposal site 6 Ratty River Cave SAC 002316 11km to the north-east of the proposal site 7 Barrigone SAC 000432 11km to the south-west of the proposal site 8 Knockanira House SAC 002318 13km to the north-west of the proposal site 9 Newhall and Edenvale Complex SAC 002091 13.3km to the north-west of the proposal site 10 Poulnagordon Cave (Quin) SAC 000064 13.3km to the north-east of the proposal site 11 Kilkishen House SAC 002319 14.9km to north-east of the proposal site

3.8 CONCLUSIONS OF THE SCREENING FOR APPROPRIATE ASSESSMENT Potential impacts on nine of the eleven Natura 2000 sites which occur within the zone of potential impact influence have been screened out due to a lack of credible or tangible source-pathway- receptor links between these sites and the proposal site. The comprehensive reasoning for this conclusion is available in the Screening for Appropriate Assessment appended to this report (Appendix 1). Site synopses for the Natura sites considered in this NIS are appended to the Screening report.

The screening assessment concluded that water quality, habitat loss and alteration, species disturbance and/or displacement impacts, habitat and species fragmentation, and potential cumulative/in-combinations effects could not be ruled out for the Lower River Shannon cSAC (002165) and the River Shannon and River Fergus Estuaries SPA (004077) and therefore further assessment is required for these Natura 2000 sites.

3.9 REASONS FOR ASSESSMENT The focus of this NIS is to determine whether the proposed development will have a significant negative impact on the qualifying features (i.e. features of interest of the Natura 2000 site or reason for designation) of the Lower River Shannon cSAC and the River Shannon and River Fergus Estuaries SPA, as outlined in Table 2 above.

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This NIS identifies the environmental aspects of the project which may lead to significant impacts, and which may interact with the ecological requirements or sensitivities of the qualifying features of the Natura 2000 sites listed in Section 3.7 above. These aspects are primarily related to water quality and habitat loss/alteration associated with the dredging phase of the project. The test of the assessment is whether the project will have ‘an adverse effect on the integrity of the site’. Where potentially significant effects are identified, proven mitigation measures will be recommended.

4 DESCRIPTION OF THE PROJECT

4.1 BRIEF PROJECT DESCRIPTION Shannon Airport was constructed in the late 1930’s and 1940’s. As significant areas of the site lie below High Tide Level, a series of flood defence measures were included in the original design of the airport. These measures, installed to protect the site from high tides, included the construction of sea walls from the mainland to Dernish Island (now lying at the south-east tip of the Shannon Airport Drainage Lagoon) and the provision of a number of drainage systems for the airport.

It is proposed to carry out refurbishment works to existing coastal defence structures, namely the East Embankment and West Embankment at Shannon Airport (see Plate 1 and Plate 2 below). The proposed works at the East embankment consist of the placement of rock armour on the front slope of the embankment. The crest of this embankment will also be strengthened using either small rock armour or a gravel filled geotextile. There will be a short (approx. 100m) section of the east embankment where the armouring of the front face will be undertaken using an alternative method (armorflex or similar mattressing) within the existing profile in order not to disturb the salt marsh habitat fronting this area. The proposed works to the West Embankment consist of the armouring of the crest and back slope using either small rock armour or a gravel filled geo-synthetic cellular confinement system. See planning drawings for details.

4.2 PURPOSE OF THE PROJECT The purpose of the project is to refurbish the existing West and East Embankments following the winter storms of 2013/2014. The embankments are essential to the protection of the airport from flooding from the River Shannon Estuary. The existing embankments and drainage system are essential to the airport for the following reasons:

 To protect life and property at Shannon Airport and its environs;  To facilitate the proper protection of the aerodrome to provide a safe aviation environment;  To ensure that critical infrastructure and equipment including navigational aids and pavements are not undermined through flooding;  To ensure that the Shannon Airport Drainage Lagoon is protected from flooding events;  To ensure that bird activity within the airfield is minimised and that there are no other unavoidable areas of standing water at the airport that could give rise to bird hazard (e.g. flooding of the airfield).

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Plate 1 View of eastern embankment

Plate 2 View of western embankment

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4.3 SITE LOCATION AND CONTEXT The subject embankments are located at two locations along the shoreline to the south of Shannon Airport in County Clare as shown in Figure 1 below.

The proposed development areas form part of the boundary with and lie directly adjacent to the Shannon Estuary. The Shannon Estuary and some areas on the landward side of the West Embankment are designated as a Special Area of Conservation (Lower River Shannon cSAC 002165) and a Special Protection Area (River Shannon and River Fergus Estuaries SPA 004077).

Figure 1 Indicative proposed embankments work extent, Shannon Airport, Co. Clare.

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4.4 CHARACTERISTICS OF THE PROJECT The proposal is described below and has been confirmed with the project engineer.

It is proposed to carry out refurbishment works on the East Embankment and West Embankment at Shannon Airport.

The East Embankment is:  Approximately 1.3km long;  Has an average crest level of approximately +4.20mODM to +5.20mODM (varies);  An average crest width of approximately 1.5m to 5m (varies greatly);  An average seaward toe level of approximately +0.40mODM to +1.80mODM (varies);  An average landward toe level of approximately +0.5mODM to +2.00mODM (varies);  The embankment has a plan area of approximately 23,985m2.

The proposed works are to the front face and crest of the east embankment. The works to the front will extend for much of the length some 5m seawards of the existing embankment toe. There are two areas where this will not occur: firstly, along an approximately 150m section that has in the past been faced with rock armour; and, secondly a length some 100m long immediately north Size, scale, area, land-take east of this rock armour.

The West Embankment is:  Approximately 1.6km long;  Has an average crest level of approximately +4.80mODM to +5.50mODM (varies);  An average crest width of approximately 1.5m to 3m (varies);  An average seaward toe level of approximately -0.50mODM to +1.60mODM (varies);  An average landward toe level of approximately +2.00mODM to +3.40mODM (varies);  The embankment has a plan area of approximately 22,320m2.

The proposed works are to the crest and backslope of the west embankment. There will be no works on the seaward side of this embankment.

There is spatial overlap between the proposed areas of work and both the Lower River Shannon cSAC (002165) and River Shannon and River Fergus Estuaries SPA (004077). There will be land-take within both the SAC and SPA as a result of the proposal. East Embankment In summary the works are to consist of the placement of rock armour on the Details of physical changes front slope of the east embankment and the strengthening of the crest of this that will take place during embankment using either small rock armour or a gravel filled geotextile. This the various stages of will result in an increase in the width of the east embankment (the footprint implementing the proposal will extend seawards by 5m from the existing toe - except where there is existing rock armour in place and a length some 100m just north east of this armour).

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The following works to the East Embankment are proposed:

 Material will be excavated to approximately -1.0mODM for foundation pocket of proposed rock armour to the seaward face;  The excavator will be located either on the crest of the existing embankment or on the partly completed rock armour immediately adjacent. Plant movement will be restricted to the embankment and the footprint of the works.  Gravel will be placed to blind the face of existing pitched stone on seaward face of the section of embankment being worked on – this gravel blinding will have a layer thickness of 100mm perpendicular to the slope face;  Geotextile will be placed on the gravel blinding layer;  2 layers of 1.3T rock armour will be placed on the geotextile;  Turf and top soil layer will be removed from the section of embankment being worked on (estimated length of sections to be worked on at a time approx. 50m) to facilitate the formation of crest protection;  Geotextile will be placed on the prepared crest;  Required rock armour/geosynthetic cellular confinement system will be placed on the crest, over the geotextile;  Gravel will be placed to blind face of armouring works on crest of embankment – this gravel blinding will have a layer thickness of 100mm;  Turf and topsoil will be reinstated to complete the works.  In the case of the 100m section north east of the existing armour it is proposed to widen the embankment landwards by some 1m in this area; to place a layer of proprietary protection (armorflex or similar) within the existing front face; and to provide protection to the crest and backface of the widened embankment. Prior to the placing of protection (rock armour or proprietary armouring) turf and topsoil will have been removed from the existing embankment, stored and replaced on the newly armoured crest and backslope.

West Embankment The works to the West Embankment are to consist of the armouring of the crest and back slope using either small rock armour or a gravel filled geo-synthetic cellular confinement system.

The following works to the West Embankment are proposed:

 There are no proposed works to the seaward slope of the embankment;  Turf and top soil layer will be removed to form crest and landward slope protection;  Landward slope protection will extend a minimum of 1m beyond the embankment toe;  Geotextile will be placed on the prepared crest and landward slope;  Required rock armour/geo-synthetic cellular confinement system will

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be placed on the crest and landward slope, over the geotextile;  Gravel will be placed to blind face of armouring works on crest of embankment – this gravel blinding will have a layer thickness of 100mm;  Turf and topsoil will be reinstated to complete the works.

In general, machinery required for the works will track along the access path east of the west embankment. Plant and vehicle movement will be precluded on the adjacent shoreline due to ground conditions.

Several (perhaps 3) ramps will be constructed along the access road of both embankments. These ramps will be used primarily to bring materials to the top of the embankments, and potentially for future maintenance works. The equipment and resources required for the works will include:

 Rock armour, gravel (Imported material will be clean and will be Description of resource sourced from a licensed establishment) requirements for the construction/operation and  Geo-textile membrane decommissioning of the  Geo-synthetic cellular confinement system proposal (water resources,  Excavator for lifting rock armour and geo-synthetic materials into place construction material,  Trucks for transport of rock armour/geo-synthetic materials human presence etc)  Total number of excavators could range from 1 to 3 on each

embankment. Personnel on each embankment 2 to 6 plus truck drivers.  Welfare facilities, potable water, power source, secure site compound Description of timescale for  Duration of approximately 6-9 months between January 2021 and the various activities that December 2021. will take place as a result of  Works will be undertaken at each embankment in a staged manner (at implementation (including a number of locations (2 to 3) on each embankment at the same time). likely start and finish date) This will be governed by access and storage space limitations. East Embankment:  1.3T Rock armour to front face: 22,000m3  Geotextile: 24,000m2  Gravel: 1,400m3  Proprietary armour (armorflex or similar):1,000m3  75kg rock armour to crest: 1,900m3 Or:  Geo-synthetic cellular confinement system: 6,500 m2 Key Quantities  Geo-synthetic cellular confinement system fill: 1,000m3

West Embankment  75kg Rock armour: 5,300m3  Geotextile: 18,000m2 Or:  Geo-synthetic cellular confinement system: 18,000m2  Geo-synthetic cellular confinement system fill: 2,700m3 Description of wastes  Turf and top layer spoil generated by works will be inert and will be arising and other residues stockpiled at locations adjacent to the works until reinstatement. All (including quantities) and turf and top-soil is to be reinstated on-site prior to completion of the their disposal works at each section.

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 Fuels/oil/lubricants associated with plant and machinery  Effluent from temporary on-site welfare facilities will be transported to a suitably licensed facility for treatment  No hazardous waste material will be generated.  Turf and top layer spoil generated by works will be inert and will be Identification of wastes arising and other residues reinstated on-site prior to completion of the works. (including quantities) that  Fuels/oil/lubricants associated with plant and machinery may be of particular  Fuels/oils etc will be stored within a bunded area in the enclosed concern in the context of compound along with tools, materials etc. All plant is to be refuelled in the Natura 2000 network this compound and a drip tray fitted to any stationary plant working in

proximity to the watercourse. Description of any additional services required  A site compound will be required for the successful contractor to to implement the project or undertake the works. This will be situated at either end of the plan, their location and embankment. means of construction  Temporary welfare facilities will be located within the site compound.

5 DESCRIPTION OF THE RECEIVING ENVIRONMENT This section describes the existing environment within the proposed development site, as well as other wider environmental factors that occur within, or influence the brackish components of the Lower River Shannon cSAC. The site, overall, sits on the northern shore of the Shannon Estuary which is the largest estuary in Ireland and one of the most important deep-water navigational channels in the country3. The Shannon Estuary forms part of both the Lower River Shannon cSAC (002165) and the River Shannon and River Fergus Estuaries SPA (004077).

5.1 GEOLOGY/LAND USE The geology surrounding both the western and eastern embankments at Shannon Airport is comprised of ‘Dark Muddy Limestone and Shale’ extending into ‘Massive Unbedded Lime Mudstone’, with some pockets of ‘Old Red Sandstone, Shale and Mudstone’ to the northeast, inland, and to the southeast along the southern bank of the River Shannon4.

Soil cover at Shannon Airport consists of made (man-made) land, while the area comprising the lagoon and western embankment which occurs along the estuary margins consists of marine deposits of estuarine sediments (silts/clays). Soil cover extending away from the area is comprised of a mosaic of marine deposits, Limestone Till (Carboniferous) with some bedrock at the surface’ (EPA, 2019).

The surrounding land cover of Shannon Airport is classified as ‘Artificial surfaces (124) comprised of industrial, commercial and transport units’, which extends into the Shannon Free zone ‘Artificial Surfaces (121)’, and Shannon Town which is largely comprised of industrial units and housing estates that make up the ‘urban fabric (112)’ of the area. The area extending north of Shannon Airport is comprised of ‘Agricultural Areas (231)’ with small localised areas of ‘Forest and Semi-natural Areas

3 https://shannonestuarysifp.files.wordpress.com/2015/08/executive_summary_22112013.pdf [Accesssed 10/07/2019] 4 https://dcenr.maps.arcgis.com/apps/MapSeries/index.html?appid=a30af518e87a4c0ab2fbde2aaac3c228 [accessed 10/07/2019]

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(313/321)’, while the land directly contiguous to the Shannon Airport embankments is classified as ‘Coastal Wetlands (423)’5.

5.2 HYDROGEOLOGY The proposed development overlies the Tulla-Newmarket on Fergus ground waterbody (IE_SH_G_229), which has a Ground Waterbody WFD Status 2010-2015 of ‘Good’. In terms of risk status, this ground waterbody is currently under review.

The Summary of Initial Characterisation report for this GWB indicates that the water table is above or close to the base of the sub-soils and that the streams crossing the aquifer are gaining. Due to the shallow groundwater flow in this aquifer the groundwater and surface waters are closely linked. There are several ecosystems in the GWB at least partially dependent on groundwater6.

5.3 INTERTIDAL PROCESSES The existing tidal currents in the vicinity of the works are very low, given that the main tidal flows are out in the deeper water and are pushed away from the embankment by the existing rock armour breakwater to the west that extends some 800m towards the channel from the embankment. Such an effect would be dominant on the flood tide. The headlands and in river islands to the east also help deflect the strongest currents into the main channel on the ebb. These effects result in a wide intertidal area fronting the east embankment - some 800m wide. Wave conditions at the east embankment are locally generated and because of the relatively short fetch are relatively small, with a significant wave height less than 0.8m and period of less than 3 seconds except in the more extreme cases.

The intertidal area consists of silt sized material. Such material is deposited along the sides of estuaries in areas of lower tidal currents. The material is a cohesive material so called because the weak bonding between the clay/silt particles. This complicates their transport regime. While apart the individual particles can stay in the water column for a very long time only being deposited out in areas of quiescent water and are easily transported by low velocities. However, once bonded to other particles they can require high currents to overcome the bonding and reabsorb them into the water column. Mud flats would have a thin layer of very mobile individual particles or flocs of mud overlying a much more cohesive layer that is much more resistant to erosion.

5.4 SURFACE WATER

5.4.1 Watercourses There are two 2nd order watercourses within the vicinity of the Shannon Free Zone. These drain an industrial/residential area to the east of the Airport both discharging to the Shannon Estuary7. These watercourses are the Urlan Beg Stream which is mapped as running through the eastern limit of the eastern embankment, and the Clonloghan Stream which flows into the estuary ca. 150m east of the eastern embankment, at Drumgeely Creek. These streams are highly modified waterbodies as they have been straightened and some reaches have been culverted.

There is an artificial waterbody that runs at the landward side of and parallel to the East Embankment, however (see Plate 3). This channel is connected to the Shannon Estuary via a sluice

5 https://gis.epa.ie/EPAMaps/ [Corine 2018, accessed 10/07/2019] 6 http://spatial.dcenr.gov.ie/GSI_DOWNLOAD/Groundwater/Reports/GWB/TullaNewmarketOnFergusGWB.pdf [Accessed 29/08/2019] 7 http://maps.biodiversityireland.ie/#/Map [Accessed 10/07/2019]

19986-6002-D Natura Impact Statement June 2020 gate located near the western limit of the East Embankment (see Plate 4). It is considered that this channel carries the Urlan Beg Stream to the sea. It was obvious during the site visit that this channel had some water quality problems, as evident by an oil film on the surface near the sluice.

Compliance with the reporting requirements of the Water Framework Directive (Directive 2000/60/EC) obliges each member state to publish reports providing summary information about individual water bodies relating to their status, risks and objectives. Within this reporting framework the Urlan Beg and Clonloghan Streams are situated within the WFD Catchment ‘Shannon Estuary North’, the WFD Sub-catchment ‘Ballygirreen_SC_010’ and the WFD River Sub-basin ‘Urlan Beg_010’8. With regards to WFD Risk status the ‘Urlan Beg_010’ river waterbody is under review due to its ‘Unassigned’ status. Significant pressures which have been identified in relation to this river waterbody are ‘Urban run-off’ and ‘Diffuse sources run-off’9. Biological water quality values, or Q values, are unavailable for both of these water courses; they are not monitored presumably due to their size and urban context.

With regards to the WFD Transitional Waterbody identified as the ‘Upper Shannon Estuary’ into which both watercourses flow this has been assigned a WFD Status (2010-2015) of ‘Poor’ and a Risk category of ‘at risk’. Significant pressures which have been identified in relation to the ‘Upper Shannon Estuary’ comprise ‘Agriculture’.

Plate 3 Modified channel which runs behind and Plate 4 Sluice gate at junction of modified channel parallel to the East Embankment and carries the (which runs parallel to East Embankment) and the Urlan Beg Stream to the sea estuary

5.4.2 Shannon Airport Lagoon An artificial lagoon, known as the Shannon Airport Lagoon, is located behind the West Embankment. This drainage lagoon is separated from the sea by artificial barriers comprising the embankment and an access road. The lagoon was developed in the 1940’s when a seawall was constructed out into the estuary to prevent Shannon Airport from flooding. The water level in the lagoon was managed via a sluiced outlet through which water drains via a drainage channel located in the lagoons north- western corner. As noted by ASU (2004), the sluice/flap valve became totally silted over by the mid 1990’s despite concerted attempts by Aer Rianta to keep it clear. In 1996 the company began summer pumping of water from the lagoon to the estuary, as a means of level control and since

8 https://gis.epa.ie/EPAMaps/ [Accessed 21/08/2019] 9 https://www.catchments.ie [Accessed 21/08/2019] 23

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2002, pumping has been more or less continuous. In that time, water levels have dropped and are now considerably less than one metre over the entire lagoon. It is possible that from that time, in particular, the salinity in the lagoon began to drop and a state of total freshwater may eventually arise under the current water management regime (ASU, 2004).

Pumping ceased in March 2014 following the opening and ongoing maintenance of the sluice outlet/gate.

The area of the Shannon Airport lagoon is given as 24.2ha. The area of this habitat has decreased considerably in recent times since pumping has been used to lower the water level by ca. 1m. The result has been encroachment of reeds and other vegetation from the marginal areas, which was first observed in 2001 (ASU, 2004).

Fluctuations in water depth are a natural feature of lagoon hydrology. However, if water levels fluctuate beyond their natural values due to issues such as drainage, the condition of the habitat can deteriorate. When visited briefly in 1996, salinity measured 13psu and water depth was approximately 1m, but when sampled in 2002, a large part of the lagoon was dry and salinity measured 0psu. Shannon Airport lagoon was classified as an Oligohaline waterbody (NPWS Conservation objectives supporting document - Lagoons). The western embankment does not allow seepage from the sea to the lagoon and vice-versa.

Plate 5 View of Shannon Airport Lagoon Plate 6 Groenlandia densa in the channel drainage between the lagoon and the western embankment

In 2002 only 9 floral taxa were recorded in the lagoon, but one of these species may have been the rare charophyte, C. connivens which is a lagoonal specialist. None of the other species are of particular note. When visited in 2003 water covering the muddy bottom was only a few centimetres deep and the only charophytes recorded appeared to be Chara aspera (Roden, 2004). Based on aquatic vegetation, as a lagoon, conservation value was regarded as low (Oliver, 2007). Generally, the fauna of the site is poor and does not appear at this stage to include any rare or threatened species, except possibly Pungitius pungitius (Oliver, 2007). As lagoon specialist species do not easily recolonise, their presence is one of the indicators of long-term continuity of quality. Based on animal diversity, the conservation value as a lagoon was regarded as low (Oliver, 2007).

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The risk status of the WFD Transitional Waterbody identified as the ‘Shannon Airport Lagoon’ which is located on the landward side of the West Embankment is also under review due to its ‘Unassigned’ status. ‘Anthropogenic pressures’ have been identified in relation to this drainage waterbody.

5.5 HUMAN POPULATION AND LAND USE Shannon Airport occurs within the Electoral Division (ED) of Clenagh (027) with a reported population of 355 persons in a 2016 national census10. The Shannon Free Zone is located immediately adjacent to Shannon Airport which is one of the country’s main airports and the airport's runways bound the western side of this industrial area. The Shannon Airport and Shannon Free Zone are bounded by the fringes of Shannon town to the east and by predominantly agricultural land to the north.

5.6 HABITATS AND FLORA The site comprises the entire estuarine habitat from Limerick City westwards as far as Doonaha in Co. Clare and Dooneen Point in Co. Kerry, and is surrounded by the largest port and some of the most extensive areas of industrial development in the west of Ireland. The Shannon Estuary is subject to permanent marine inundation and is macro-tidal, having the largest tidal range (5.44 m at Limerick Docks) on the Irish coast. Extensive reclamation of intertidal mudflats has been carried out around the site. These areas are protected from tidal flooding by flood embankments, a common feature across the site. The site includes the Shannon Airport Lagoon; an artificial brackish lake that was developed in the 1940’s when a seawall was constructed out to the estuary to prevent Shannon Airport from flooding11.

The habitats identified within the proposed development site during July 2018, as well as the Shannon Estuary in the zone of influence of the project, are listed in Table 3. The extents of these habitats are illustrated in Figure 3. These habitats are described below with an outline of their spatial distribution within the site. The River Shannon Estuary in the vicinity of the study area, given the nature of the surrounding airfield/industrial environment, is in an urbanized setting with existing rock armour providing a tidal defence.

10 http://airomaps.nuim.ie/id/Census_2016/P1_Housing/ [accessed 10/07/2019] 11https://www.npws.ie/sites/default/files/publications/pdf/004077RiverShannonandRiverFergusEstuariesSPASupportingD ocV1.pdf [Accessed 03/09/2019] 25

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Figure 2 Habitats at the western embankment

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Figure 3 Habitats at the eastern embankment

The habitats extant in the proposal site and surrounding environs were classified according to Fossitt classification (2000) and were determined to be locally defined by; estuaries (MW4), coastal lagoons (CW1), dry meadows and grassy verges (GS2), sea walls (CC1), buildings and artificial surfaces (BL3), re-colonising bare ground (ED3), muddy and sandy shores (LS3), upper salt marsh (CM2) and reed and large sedge swamps (FS1).

Plate 7 Overview of typical GS2 on eastern Plate 8 Overview of typical GS2 on western embankment embankment

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Table 3 Habitats identified within the study area Habitat Habitat Spatial description within site code Estuaries MW4 This comprises the estuarine tidal habitat of the Upper Shannon Estuary to which the existing West and East Embankments form the landward boundary. Sea water within the estuary is diluted by freshwater input from several waterbodies in the surrounding area. This combined with tidal processes results in variable salinity. Lagoons and saline CW1 This comprises the brackish artificial lagoon located behind the West lakes Embankment (Shannon Airport Lagoon). This habitat is separated from the sea by artificial barriers comprising the embankment and an access road. Water levels are managed via a sluiced outlet and the lagoon is surrounded by a range of habitats including saltmarsh, reed bed and freshwater marsh12. Dry meadows and GS2 This is the dominant habitat present along both embankments. Where grassy verges this occurs, this habitat is unmanaged and tends to be dominated by rank and tussock-forming grasses. Dominant species recorded include abundant False-oat Grass (Arrhenatherum elatius) and Red Fescue (Festuca rubra) and frequent Creeping Bent (Agrostis stolonifera), Yorkshire Fog (Holcus lanatus), Cock’s-foot (Dactylis glomerata), Rough Meadow Grass (Poa Trivialis), Tall Fescue (Festuca arundinacea) and Common Couch (Elytrigia repens). As the grassland sward is rank broadleaved herb cover is low overall, but includes typical species; Bush Vetch (Vicia sepium), Creeping Thistle (Cirsium arvense), Tufted Vetch (V. crecca), Bird’s-foot Trefoil (Lotus corniculatus), Ribwort plantain (Plantago lanceolata), Creeping Cinquefoil (Potentilla reptans) and Lady’s Bedstraw (Galium verum). Sea walls CC1 The seawards side of the embankments are comprised of natural stone, with occasional mortar persisting in parts, particularly on the western embankment. A narrow band of loose large rock and small stone is present along the base of sections of the western embankment. A section of newer and larger rock armour has also been installed on part of the eastern embankment. Vegetation cover is occasional to very rare with just occasional Sea Plantain (P. maritima), Buck’s-horn Plantain (P. coronopus), Sea Aster (Aster tripolium), Sea Beet (Beta vulgaris subsp. Maritima) and Common Scurvy Grass (Cochlearia officinalis) on lower sections of the walls. Buildings and artificial BL3 A gravel track is present along the landward side of each of the surfaces embankments. As these tracks are not in regular use vegetation has re- colonised the gravel substrate. Re-colonising bare ED3 Vegetation has re-colonised the gravel substrate of the trackways, ground particularly along the central verges, where dry calcareous and neutral grassland is establishing. Typical species recorded for both re-colonising tracks include; Yorkshire Fog, Creeping Bent, Red Fescue, Wild Carrot (Daucus carota), Common Centaury (Centaurium erythraea), Lesser Bird’s-foot Trefoil, Prickly Sow-thistle (Sonchus asper), Ribwort Plantain, Red Clover (Trifolium pratense), White Clover (T. repens), Fairy Flax (Linum catharticum) and Common Ragwort (Senecio jacobaea). The

12 https://www.npws.ie/sites/default/files/publications/pdf/004077_RiverShannonandRiverFergusEstuariesSPASupporting Doc_V1.pdf 28

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Habitat Habitat Spatial description within site code tracks and associated re-colonising vegetation along the western embankment was being managed at the time of the site visit. Dry meadow and grassy verge (GS2) is present along the tracks immediately inland, where drainage channels (FW4) are also present. Drainage channels FW4 An artificial channel runs at the landward side of and parallel to the East Embankment. This channel is connected to the Shannon Estuary via a pump station located near the western limit of the East Embankment. It is considered that this channel carries the Urlan Beg Stream to the sea. Muddy sand shores LS3 Muddy and Sandy Shore is present along the seaward side of the sea walls at both embankments. This habitat is exposed at low tide. Inter- tidal mudflats are a dominant feature of the estuarine environment. This may correspond to the Annex I habitat ‘mudflats and sandflats not covered by sea water at lower tide (1140)’. Upper salt marsh CM2 Upper salt marsh was recorded at two locations at the northern end of the West Embankment and two locations at the northern end of the East Embankment. Of note is that previously mapped areas of Atlantic Salt Meadow ASM (1330) to the north-east of the eastern embankment was not recorded in 2019, with such areas now dominated by reed and large sedge swamp (FS1) along and immediately out from the embankment. Some small pockets may persist outside the reed and large sedge swamp (FS1), but were not visible from the shoreline.

Typical species recorded for Atlantic Salt Meadow include; Common Saltmarsh-grass (Puccinellia maritima), Saltmarsh Rush (Juncus geradii), Creeping bent, Common Scurvygrass, Sea Aster and Sea Plantain. Common Cord-grass (Spartina anglica) is abundant along the outer edges of each of the Atlantic Salt Meadow habitat areas. Reed and large sedge FS1 Reed and large sedge swamp dominated by dense stands of Common swamps Reed is present towards the north-west end of the West Embankment and is the dominant habitat towards the northern end of the East Embankment.

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Plate 9 Mud-flat adjacent to the eastern embankment Plate 10 Existing track between western embankment and showing where some works similar to those proposed lagoon have been undertaken

Plate 11 Overview of typical sea-wall on eastern Plate 12 Overview of typical sea-wall on western embankment embankment

Plate 13 Salt-marsh located west of the western Plate 14 Salt-marsh located east of the eastern embankment embankment

Plate 15 Overview of typical Atlantic Salt Meadow (1300) Plate 16 Overview of extent of Spartina along edge of habitat showing area located at northern end of western Atlantic Salt Meadow at eastern embankment embankment

19986-6002-D Natura Impact Statement June 2020

5.7 FAUNA

5.7.1 Otter Otters likely utilise the shoreline and intertidal habitats adjacent to the site for both foraging and commuting. No evidence of otter holts or couches were recorded along the embankments within the study area, or within 50m of the site boundary. The built-up nature of the landscape and level of disturbance through human activity in the surrounding area would make the study area less favourable relative to less disturbed areas of the estuary shoreline.

5.7.2 Avifauna The River Shannon and River Fergus Estuaries SPA is the largest wetland complex in Ireland; the SPA covering some 32,261 hectares. The site encompasses the entire estuarine habitat west from Limerick City and south from Ennis, extending west as far as Killadysert and Foynes on the north and south shores of the Shannon respectively (a distance of some 25 km from east to west). In addition to the Shannon and Fergus, the site has numerous sub-estuaries including Ballylongford Creek (Ballylongford Bay), the Glencorbly river at Glin, the White river at Loghill, Robertstown River and Poulweala creek at Foynes and Aughinish, the River Deel at Courtbrown Point and the Maigue at Rinekirk Point.

Figure 4 Count sub-site boundaries for the 2010/11 Waterbird Survey Programme (Source NPWS, 2012b)

Both the Fergus and inner Shannon estuaries feature vast expanses of intertidal mudflats with tidal creeks and channels which provide rich foraging grounds for wintering birds. Saltmarsh vegetation frequently fringes the mudflats and this provides important high tide roost areas for the wintering birds. This vast area is home to a large number of important wintering and migratory wildfowl.

Non-breeding waterbirds have been counted regularly at the River Shannon and River Fergus Estuaries as part of the Irish Wetland Bird Survey (I-WeBS) since the survey commenced in 1994.

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Table 4 below shows species recorded during waterbird counts undertaken at two of the River Shannon and River Fergus Estuaries count sub-sites for the 2010/11 Waterbird Survey Programme (Sub-site: 0H510, located adjacent to the West Embankment and Sub-site: 0H512, located adjacent to the East Embankment – see Figure 4 below). The table is adapted from data tables included in the River Shannon and River Fergus Estuaries SPA (004077) Conservation Objectives Supporting Document (Version 1) (NPWS, 2012b).

Table 4 Waterbird species recorded during surveys at Sub-sites 0H510 and 0H512 at low and high tides across all behaviours and habitats (2010/2011 Waterbird Survey Programme) Site Special Conservation Interests Species OH510 (West OH512 (East (SCIs) codes Embankment) Embankment) Whooper Swan WS Light-bellied Brent Goose PB Shelduck SU X X Wigeon WN X X Teal T. X Cormorant CA X Ringed Plover RP Golden Plover GP X Grey Plover GV X X Lapwing L. X X Knot KN X X Dunlin DN X X Black-tailed Godwit BW X X Bar-tailed Godwit BA Curlew CU X Greenshank GK X Redshank RK X X Pintail PT Shoveler SV Scaup SP Black-headed Gull BH X X

The Final Survey Report for Waterfowl Numbers, Usage and Distribution of the River Shannon and the River Fergus Estuaries (MKO, 2019) presents the results of a waterbird survey of the River Shannon and River Fergus Estuaries carried out in 2017/18. This survey was the most comprehensive waterbird survey of the River Shannon and Fergus Estuaries that has ever been undertaken, with year-round coverage of around 85% of the SPA.

During the survey, internationally important numbers of two SCI species (Whooper Swan and Black- tailed Godwit) were recorded. However, there are striking apparent declines in numbers of Light- bellied Brent Goose, Shelduck, Pintail, Scaup, Lapwing, Bar-tailed Godwit, Knot, Dunlin, compared with the mean annual peak counts from the baseline period of 1995/96-1999/00 used for the SPA designation, particularly so given that the latter are based on more limited survey coverage. Comparison of the 2010/11 and 2017/18 counts shows consistent patterns of increases in Wigeon and Greenshank and decreases in Pintail, Cormorant, Black-tailed Godwit, Bar-tailed Godwit and Dunlin.

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Whooper swans are migratory arriving in late September/early October and winter in Ireland until April. Whooper Swan, which occurred almost exclusively in the terrestrial zone, mainly occurred in the Upper Shannon and Fergus Estuary. The overall numbers were higher in the Upper Shannon but this was due to the large numbers that occurred at one site (Bunlicky Lake). The other concentration of birds was along the northern and eastern shore of the Fergus Estuary. Whooper Swan and Light- bellied Bent Goose occurred in the study area between October and April, but mainly between November and March.

The subsites indicated in Figure 4 give survey subsites area coverage for the MKO (2019) study. Table 5 gives proportional bird use of subsites in the environs of the proposed development areas. All these subsites were surveyed in all counts from May 2017 to April 2018. Based on the observations of subsites in the study area, it can be seen that the lagoon is most important for Wigeon and Shoveler (Very High proportional use), with Moderate use by Teal, and Low use by Cormorant and Black-headed Gull. Subsite OH509 (Airport lagoon) was one of the peak subsites for Shoveler during the MKO (2019) study. Subsite 0H509 registered a peak number of 55 foraging Shoveler in Low Tide Surveys and a Peak Number of 15 foraging Shoveler in High Tide Surveys.

There was no incidence of Whooper Swan at the sites relevant to the proposed development during the 2017/2018 study (MKO, 2019). Incidence of Whooper Swans from weekly counts at the Shannon Airport Lagoon between 2005 and 2019 were provided by SAA (See Table 6). Based on this data, Whooper Swan were recorded at the lagoon in 8 of the 15 years between 2005 and 2019. Usage of the lagoon site appears to be random. Murphy et al. (2003) described the Whooper swan as a regular winter visitor to Shannon Lagoon. Typically the birds arrive in mid October and occasionally frequent the lagoon throughout the winter, depending on water levels and weather conditions. There are some nearby flocks or Whooper swans on the north shore of the Shannon Estuary in Limerick and at the salt marshes of Ing and Islandavanna, near Clarecastle. One of the largest flocks on the Lagoon was 144 on November 1997. In the years leading to 2003, the Whooper swan seemed to use the site as staging post on arrival and then disperse to other sites, presumably to join the flock at River Rine about 8 km away, for the 2nd half of the winter. Nonetheless the total number of birds present there between 1996 and 1998 were very significant and would identify the site as being very important for Whooper swans. However, with the exception of Oct – Dec 2001, few birds have used the site. There have been very few Whooper swans present, particularly with the low water levels (See Section 5.4) and birds usually arrive in early October and are rarely present after December (ASU, 2004). Since 2001 there were 4 winters when there were flocks of 34 to 64, 5 winters with a maximum of 6 birds and 10 years when they were absent. In the last 30 years, the flock on the grasslands at nearby Latoon maintains a high count, even after that initial arrival in November when 100-150 can be found. During the following months it stays high, usually in the 60-70 range.

The subsite encapsulating the eastern embankment (OH512) has Very High proportional use by Golden Plover and is ranked as one of the top 5 roosting subsites for the species. The subsite between the eastern and western embankment (OH511) has Moderate proportional use by Black- tailed Godwit but is ranked as one of the top 5 roosting subsites for the species.

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Table 5: Proportional use of subsites in the study area by species relative to the whole area surveyed on each survey occasion during 2017 and 2018: L = Low; M = Moderate; H = High; V = Very High. Adapted from MKO (2019).

Bird Species

tailedGodwit headed Gull

- -

Shelduck Wigeon Teal Cormorant GoldenPlover Plover Grey Lapwing Knot Dunlin Bla Curlew Redshank Shoveler Black Code SU WN T. CA GP GV L. KN DN BW CU RK SV BH 0H509 V M L H V L

0H510 L M L M M L H H M M H 0H511 H L M L L M

Subsite 0H512 H L H V L M M L H H

Table 6: Incidence of Whooper Swans from weekly counts at the Shannon Airport Lagoon 2005 to 2019 (data provided by SAA). Year Count 2005 Max of 5 in Oct 2006 None 2007 None 2008 Max of 10 in Oct and 64 in Nov 2009 Max of 6 in Nov 2010 None 2011 Max of 10 in Jan, 38 in Nov, 7 in Dec 2012 Max of 34 in Oct, 20 in Nov 2013 None 2014 None 2015 Max of 5 in Nov 2016 Max of 60 in Nov, 43 in Dec 2017 None 2018 Max of 6 in Oct 2019 None

5.7.3 Fish Inland Fisheries Ireland have published WFD reports on fish stock surveys held in transitional waters in Ireland. The River Shannon and River Fergus Estuaries are divided into four components; the Limerick Docks (Limerick City), the Shannon Estuary (upper), the Shannon Estuary (lower) and the Fergus Estuary. Detailed surveys have been carried out at each location13 and are available online in the following report ‘Sampling Fish for the Water Framework Directive; Transitional Waters 2014, Shannon and Fergus Estuaries’.

The proposed refurbishment works will take place in the Lower Shannon Estuary. During the October 2014 survey a total of 29 fish species were recorded in the Lower Shannon Estuary. Sprat was the most abundant fish species recorded at this location, followed by sand goby, thick-lipped mullet, sand smelt and flounder (which was found throughout this water body).

13 http://wfdfish.ie/wp-content/uploads/2015/03/Shannon_Estuary_final_report.pdf [accessed 18/07/2019] 34

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Comparisons with previous surveys completed in 2008 showed several newly recorded species in the Lower Shannon River in more recent years, including bib, coalfish/saithe, grey gurnard, mackerel and sand sole. Other species caught but not captured during the 2014 survey included black goby, thornback ray (which was only recorded in this waterbody), cod, European sea bass and European Eel. It is noted that European eel (Anguilla Anguilla) is listed as ‘Critically endangered’ and is now ‘Red Listed’ according to the recently published ‘Red List No. 5: Amphibians, Reptiles & Freshwater Fish’ (King et al., 2011).

The Urlan Beg Stream which flows into the estuary through the eastern embankment is an unsuitable watercourse for Salmonids and Lampreys, owing to apparently degraded water quality and the absence of spawning areas. There are no suitable nursery habitats in the lower reaches of this watercourse.

6 IDENTIFICATION OF OTHER PROJECTS, PLANS AND ACTIVITIES

6.1 WASTEWATER TREATMENT PLANTS (WWTPS)

6.1.1 Shannon Town The Shannon Town Wastewater Treatment Plant (Licence No. D0045-01)14 is located south-east of Shannon on Inishbonane Point. This WWTP, which has a Plant Capacity (Population Equivalent, PE) of 12,500, has a primary effluent discharge point to the Shannon Estuary east of the proposed development.

The treatment process for the industrial stream is no longer operational, while the supernatant from the centrifuge and leachate continues to be sent to the industrial side of the plant and is discharged into the large final effluent lagoon before being discharged to the Shannon estuary. According to the Annual Environmental Report15 (AER 2017) which has been prepared for D0045-01, in accordance with the requirements of the wastewater discharge licence, the final effluent from the primary discharge point for this WWTP was found to be non-compliant with the Emission Limit Values in 2017 (EPA). The overall plant compliance for this WWTP is ‘Fail’. The overall results for Shannon Town WWTP are poor. In the 2017 AER assessment of the operation criteria, the SWO, code name: ‘SW2’ (E143381 N159426), was found to be non-compliant with DoEHLG guidance, while compliance of other criteria were ‘unknown’ and their significance in relation to the Lower River Shannon cSAC was unknown due to a lack of data. Therefore, further assessment of the agglomeration SWOs is required. Design improvements are planned at the Shannon Town WWTP, which will serve to address the issues of SWO non-compliance. Consultants have been appointed to carry out design improvements to the plan, and to undertake a design upgrade in the interim. These improvements are included in the Capital Investment Plan 2017-2021 (Irish Water).

The proposed embankment works will not act in combination with the Shannon Town WWTP emissions to negatively affect water quality in the Shannon Estuary to a significant degree, given their separation by ca. 4km.

14 http://www.epa.ie/terminalfour/wwda/wwda-view.jsp?regno=D0045-01 [accessed 26/07/2019] 15 http://www.epa.ie/licences/lic_eDMS/090151b280670e36.pdf [accessed 26/07/2019] 35

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6.1.2 Airport WWTP The airport waste water treatment plant became fully operational in March 2007 and is designed for a population equivalent of 5,000. It encompasses primary, secondary and tertiary treatment elements in order to remove physical and chemical components from the waste water before the final treated effluent stream is released into the Shannon Estuary.

The plant is operated and maintained by Response Group on behalf of the airport authority and is charged with operating all elements of the plant including the environmental monitoring programme. Samples are taken monthly and tested for Ph, BOD, COD, Total Nitrogen, Ammonia, Total Phosphates and Suspended solids. Tests for Residual Chlorine, Sulphates and Oils/Fats and Greases are also carried out.

The discharging of treated wastewater to waters is licensed by Clare County Council and Shannon Airport holds a current discharge licence as required under the Local Government (Water Pollution) Act 1977 and 1990. The wastewater discharged must meet certain minimum standards as outlined in the conditions of the licence16. Monitorng data supplied by SAA indicate that the WWTP is operating well within its design capacity and discharge limits are not being exceeded. Based on the 2018 results for example, the design flow of the WWTP is 1349m3/day but the average flow is only 336 m3/day, and the design Biochemical Oxygen Demand (BOD) is for a PE 5000 m3/day but the average treated is for a PE of only 969 m3/day BOD.

The proposed embankment works will not act in combination with the Airport WWTP emissions to negatively affect water quality in the Shannon Estuary to a significant degree, taking account of the loadings relative to capacity, standards of operation and quantities and quality of the effluent released.

6.2 LICENSED SITES A search of the Environmental Protection Agency (EPA) online resources17 indicates that there are four licensed IPC and four licensed IEL facilities within the vicinity of the proposal site. These licenses pertain to:

 Lufthansa Technik Painting Shannon Limited (Surface coatings)(IPC License No. P0069-02);  International Aerospace Coatings Ltd (Coatings) (IPC License No.P0497-02);  Elements Six Limited (Synthetic materials) (IPC License No. P0533-01);  Heraeus Metal Processing Limited (Metals) (IPC Licence No. P0145-01);  Badgers Blinds Limited (Blinds) (IEL Licence No. P0132-02);  AVARA Shannon Pharmaceutical Companies (Pharmaceutical) (IEL Licence No. P0020-02);  Molex Ireland Limited (Electronics) (IEL Licence No. P0288-02); and  ITW Ireland Unlimited Company (Polymers) (IEL Licence No. P0072-04).

Another four IEL licensed facilities are located further north-east of the proposed site in Smithstown Industrial Estate. While these facilities are not in the immediate vicinity, the adoption of the precautionary principal approach for this assessment means that these facilities have been included for the purposes of this report. These licenses pertain to:

16 https://www.shannonairport.ie/corporate/about/community-and-sustainability/ [accessed 26/07/2019] 17 http://gis.epa.ie/Envision [accessed 10/07/2019]

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 Chemifloc Limited (Chemicals) (IEL Licence No. P0076-01);  Shannon Circuit Technology (Technology) (IEL Licence No. P0240-01);  Enva Ireland Limited (Waste disposal) (IEL Licence No. W0041-01); and  Galvotech International Limited (Construction) (IEL Licence No. P0292-01).

6.3 PLANS Plans in place for the area include:  Irish Water Capital Investment Plan 2017-202118;  Clare County Development Plan 2017 – 202319; and  Shannon Town and Environs Local Area Plan 2012 – 2018 (amendment 1).

18 https://www.cru.ie/wp-content/uploads/2019/04/CRU190426-CRU-Monitoring-Report-No-2-Irish-Water-Capital- Investment-Plan-2017-2021.pdf [accessed 26/07/2019] 19 http://www.clarecoco.ie/services/planning/publications/clare-county-development-plan-2017-2023-volume-3a-ennis- municipal-district-written-statement-and-maps-24146.pdf [accessed 10/07/2019]

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6.4 PLANNING APPLICATIONS Other activities, such as residential, commercial, infrastructural or recreational development could potentially give rise to either direct impacts on habitats or species (loss of habitat, disturbance to species) or indirect impacts (e.g. activities which could affect water quality or hydrology which could in turn affect the status/health of populations of water dependant habitats or species). A review of the Clare County Council’s on-line planning enquiry system was carried out to determine what development has been permitted in the area.

Table 7 below lists planning applications granted within the last five years for development within the surrounding townlands, namely Rineanna South, Drumgeely, Lismacleane and Shannon Airport20 together with summary development descriptions.

Table 7 List of planning permissions granted by Clare County Council in surrounding townlands for the period 2014-2019

File Number Decision Date Applicant Name Townland Development Description Transaero

14587 18/11/2014 Engineering Shannon Airport To use an existing Aircraft Hangar for the breakup of end-of-life aircraft for recycling Ireland Ltd. Shannon Airport Lismacleane For the construction of a new single storey office extension, ancillary car parking including all associated

15121 21/04/2015 Authority Shannon Airport site services, and minor internal hangar work space modifications at the existing Hangar Development Shannon Town Drumgeely 1517 08/04/2015 For the construction of changing rooms at existing Soccer Pitch, including ancillary works United Tullyglass Drumgeely 15234 07/10/2015 Playground Drumgeely To construct a community playground and activity park, perimeter fencing and all ancillary site works Association For the extension of the landside covered walkway. The development will comprise of an extension to Shannon Airport the existing landside covered walkway located across from the airport terminal building including some

15329 07/07/2015 Shannon Airport Authority minor landscaping works and footpath re-instatement. An Appropriate Assessment screening statement accompanies this Planning Applications. For the refurbishment and localised reconfiguration of the existing Arrivals/Immigration Hall, Transit Lounge and Block A, Departure Gates areas within the Shannon Airport Terminal Building. All works are to take place 'Airside' ( past security checks) and comprise of the following : 1) Arrivals/Immigration Hall: Shannon Airport Shannon Airport

15450 25/08/2015 The relocation of the existing 'European Arrivals Door', localised replacement of the existing cladding Authority and curtain walling facade at ground and first floor levels and associated reconfiguration and refurbishment of the internal office and arrivals, immigration and baggage hall areas; 2) Transit Lounge: The reconfiguration and refurbishment of the existing internal public areas resulting in the generation of

20 http://www.eplanning.ie/ClareCC/searchresults/Default/1 [Accessed 10/07/2019]

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File Number Decision Date Applicant Name Townland Development Description 46m2 of new airside retail space; 3) Block 'A' Departure gates 1-5: The localised replacement of the existing cladding and curtain walling facade at ground and first floor levels as well as the refurbishment of the internal public waiting and toilet areas, including all ancillary site and service works Shannon Airport Rineanna South To Extend the Appropriate Period of Planning Permission P08-1992(APB Ref 03.233151 for demolition of 1557 26/03/2015 Authority Ballyhenessy existing buildings, construction of new facade and adjoining building and construction of staff car park For construction of a ground floor extension (118m2) to the existing fire station whereby the new space Shannon Airport Shannon Airport is to be used as a gym. This will be completed using modular units and will require the removal of the

1614 01/03/2016 Fire Station Authority existing portacabin type gym as well as some minor alterations to the existing fire station and all Shannon Airport ancillary works at Shannon Airport Fire Station Shannon Lismacleane For the demolition of 3 No existing industrial/office buildings within Shannon Industrial Estate and 16361 27/06/2016 Commercial Drumgeely associated site clearance works along with all other associated site works Properties For RETENTION permission to RETAIN alterations carried out to two apartment blocks including 16543 19/08/2016 Derk Estates Drumgeely alterations to corridor and window arrangement, enclosing of some open balconies and elevational changes at Hawthorn and Linden Apartment Blocks, Drumgeely, Shannon For the development within a Strategic Development Zone of a Fire Training Ground at the Secondary Surveillance Radar Equipment site on the north side of Runway 06-24, Shannon Airport, Co Clare. The development will comprise of the installation of a Simulated Steel Aircraft Shell, a Fire Screen and Shannon Airport Shannon Engine Rig for the purpose of training fire-fighting personnel. Also included in the development will be

16788 20/01/2017 Authority Airport an overground Water Storage Tank, 2 No. 2 Tonne LPG Gas Tanks, a 300 Gallon Jet A1 Fuel Tank, 3 No. sheds to house controls and fuel pressurisation unit, security fencing to surround site perimeter, concrete hardstanding areas, site lighting and all other associated site works. An Appropriate Assessment screening statement accompanies this planning Application. Rocktwist Caherteige Construct an industrial unit with office accommodation for industrial, warehouse and logistic usage, 17125 22/05/2017 Holdings Ltd. Drumgeely including ancillary site development works Nan & Mul Ballymurtagh To construct new mezzanine floor space of 120m2 for use as storage area at existing unit ( Originally 17494 04/08/2017 Catering Ltd. t/a Drumgeely granted under Planning Ref. P01-626) including ancillary site works Freshtoday For the following proposed development which will comprise of the construction of a new steel framed Lismacleane & aircraft hangar within the airport lands at Shannon Airport, Co. Clare. The hangar building includes for Shannon Airport Ballyhennessy ancillary office space, workshops, plant rooms and storage space. The building will have signage on the

1724 15/03/2017 Authority DAC Bunratty Lower, eastern, southern and western facades. Ancillary buildings and structures within the curtilage of the site Shannon including an external pump house, gas skid and fire suppression tank are also proposed. Site works proposed include car parking, hardstands, landscaping, and all ancillary site developments at this

19986-6002-A Natura Impact Statement March 2020

File Number Decision Date Applicant Name Townland Development Description address. An Integrated Pollution and Control License is required for the facility

Rineanna South For development which will consist of the extension of existing covered walkways at car parks. An

17602 27/09/2017 Shannon Airport Shannon Airport appropriate assessment screening statement accompanies this application For proposed alterations and refurbishment works to the New Terminal Building at Shannon Airport. The development, within a Strategic Development Zone, will consist of upgrade works to the existing Shannon Airport Shannon Airport

17910 19/01/2018 arrivals Hall at Shannon Airport including alterations to the existing southern and eastern elevations and Authority DAC provision of additional floor area of 42.5m2 to facilitate new Café and 16m2 for ancillary accommodation Further to previously granted planning application Ref: P16-405 for amendments and additions to the Shannon Shannon Airport car parking area and all associated site works and services. Previously granted were 202 nr. parking 17998 23/02/2018 Commercial Shannon spaces. The new total will be 298 nr spaces (96 nr. additional) including 15 nr. accessable spaces and 29 Properties nr. electrical car recharge spaces Shannon For the demolition of existing industrial / office buildings within Block K, within Shannon Industrial Caherteige 18417 24/09/2018 Commercial Estate and associated site clearance works along with all other associated site works to allow for future Drumgeely Properties development on site New Terminal Shannon Airport 18514 16/08/2018 Building For alterations and refurbishment works which were carried out to the New Terminal Building Authority Shannon Airport The Board of Drumgeely For the installation of a portacabin to be used as a pre-school facility with connection to services 18545 20/08/2018 Management, St. Tullyglass including ancillary site works. John’s NS Shannon Town Drumgeely 19207 15/05/2019 For the construction of changing rooms at existing Soccer Pitch, including ancillary site works Ltd. Tullyglass

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6.5 ONGOING ACTIVITIES The most important impacts and activities with high effect on the Lower River Shannon cSAC are outlined in the sites Natura 2000 Standard data form. These are limited to ‘Medium’ and ‘Low’ ranking threats and pressures, as listed in Table 8 below. The main threats to the site, ranked as medium include agriculture (fertilisation, grazing), urbanisation, residential and commercial development, and reclamation of land. Lesser threats include invasion by non-native species, sylviculture, forestry and removal of beach materials.

Table 8 Impacts and activities with high effect on the Lower River Shannon cSAC (Adapted from the Natura 2000 Standard Data Form) Rank Threats and Description inside/outside/both pressures [code] [i|o|b] Medium A08 Fertilisation o E01 Urbanisation, residential and commercial o development H04 Air pollution, air-borne pollutants o E03 Discharges o K02.03 Eutrophication (natural) o A04 Grazing i J02.01.01 Polderisation i J02.01.02 Reclamation of land from sea, estuary or marsh o Low I01 Invasive non-native species i D01.01 Paths, tracks, cycling tracks i G01.01 Nautical sports i B Sylviculture, forestry i F01 Marine and Freshwater Aquaculture i F03.01 Bait digging / collection i C01.01.02 Removal of beach materials i

The discharge of polluting substances from point (industrial pollutants, wastewater effluents, storm- water sewers) and diffuse (urban runoff) sources associated with ongoing activities in Shannon, Co. Clare, but also point (industrial pollutants, wastewater effluents) and diffuse (e.g. agriculture and forestry) sources along the entire River Shannon Catchment upstream of Shannon Airport have the potential to contribute to a cumulative impact on the Natura 2000 sites of the lower catchment and estuary.

6.5.1 Shannon Airport

6.5.1.1 Bird Strike Birds pose an air safety hazard and present a risk of collision or bird strike with aircrafts operating in and out of Shannon Airport. According to NPWS the risk of collision/bird strikes with aircrafts is greatest during take-off, approach, climb and landing21. Many of these collisions will result in little to no effect on the aircraft, in terms of damage, but some more serious collisions have the potential to damage the structural integrity of aircrafts (Soldatini et al. 2010).

21 https://www.npws.ie/sites/default/files/files/Public%20Consultation%20Document%20Art9%20Birds%20Directive.pdf [section 4.2. accessed 26/07/2019]

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The Irish Aviation Authority (IAA) has published a detailed report in July 2019 which outlines regulations and procedures for aircrafts and airports in Ireland, and also includes a section on Bird Migration and Areas with Sensitive Fauna22 (ENR 5.6). This brief section of the report assesses bird concentrations and movements in Ireland, identifies important bird areas/areas of sensitivity and outlines the procedure for reporting incidences of bird strikes/collisions23 to the relevant person(s). This report takes note of the key areas where birds are concentrated that pose a risk to aircrafts and personnel such as shallow estuaries, inland waters, exposed headlands, cliffs and offshore islands.

Flocks of gulls are recognised as the birds most responsible for the majority of Irish bird strikes, and as such maps have been included in the report showing where these flocks occur, which happens to be heavily concentrated along the west coast of Ireland, as-well as along areas of the east coast such as Cork, Waterford, Wexford, Dublin and County Down. Pilots are instructed to be cognisant of the fact that bird concentrations are subject to constant change and they should familiarise themselves with these changes to stay updated. Shannon Airport is listed as an area of high bird sensitivity all year round owing to the proximity of the site to important bird habitats, namely estuaries, wetlands and inland waters.

There have been incidences of collisions/bird strikes that have occurred at Shannon Airport, where aircraft had to be diverted or landed in order to avoid further risk of damage or harm to passengers. These incident reports have been detailed in local and national newspapers in Ireland, with one incident cited as most recently as December 2018, where an executive jet had to be grounded at Shannon airport following a bird strike.

6.5.1.2 Lagoon water level management An independent evaluation of the Shannon Airport Lagoon at Rineanna, Shannon, Co. Clare was undertaken in the context of Aer Rianta’s desire to lower the water levels in the lagoon (ASU, 2004). Lowering of the lagoon’s water levels is the company’s main strategy to prevent swans from using the lagoon and it’s margins as a feeding or nesting site. The following information was obtained from the report prepared by ASU (2004).

Swan count data for Shannon Airport Lagoon for the period 1974-2004 indicates that substantial numbers of Mute Swans and occasionally Whooper swans also, used the lagoon. Over much of this period average monthly numbers of birds have ranged from about 60 to 120. For example in November 1997, almost 200 swans were present at the Lagoon, which had they been crossing the airfield would clearly have posed a potential hazard for aircraft. Since about the mid 1990’s summer pumping began at the lagoon in an effort to dissuade swans from using it. The numbers began to drop since pumping began. In recent years with a drop in water levels the site has become much less attractive for both Whooper and Mute swans. As per the ASU (2004) recommendation, the water level is kept low to prevent flocks reforming.

In order to maintain these low numbers, it was recommended that the water levels be kept below ca. 8cm when it is expected that the swans would find it difficult if not impossible to take off from the lagoon and would consequently avoid it. It was also recommended that the plant refugia or ponds (referred to in the flora section above) should not be more than 10m in diameter so that

22 http://iaip.iaa.ie/iaip/Published%20Files/AIP%20Files/ENR/EI_ENR_5_6_EN.pdf [accessed 26/07/2019] 23 https://www.iaa.ie/general-aviation/forms/wildlife-strike-form [accessed 26/07/2019]

19986-6002-D Natura Impact Statement June 2020 swans would be unlikely to use them as take-off areas. Furthermore, the connecting channels between the ‘ponds’ should not be linear, again to discourage their use by swans for take-off.

6.5.1.3 Airport Activities Activities at Shannon Airport and all other Irish airports are monitored in terms of their potential impacts on air quality, water quality, energy and carbon consumption, noise emissions, waste, and biodiversity, all of which can be found in sustainability reports which are published online by the DAA and SAA website24; a global airports and travel retail group, which are owned by the Irish State. The table below, extrapolated from a 2011 Sustainability Report25, contains the following information about potential impacts of Shannon Airport Activities on the receiving environment.

Table 9 Key Points extrapolated from DAA Sustainability Report 2011 on Shannon Airport Parameter Report Air Quality The average nitrogen dioxide and particulate matter concentrations at Shannon Airport were significantly below the national limit value for 2011 Water Quality Tests taken throughout the year indicate that the water quality at Shannon Airport is in good status throughout the site. Shannon Airport had the second highest consumption of potable water (300000-350000 M3) in 2010 and 2011, when compared against Dublin (the highest) and Cork (second highest). Energy Energy consumption was lowest in Shannon Airport when compared with Cork and Dublin Consumption Airport. Consumption fell to 21,239 (MWh) in 2011 from 24,266 (MWh) in 2010. Noise The report shows an overall decline in the number of noise complaints received for all Emissions airports over the years, with a slight increase in complaints in 2011, which was attributed to increased runway usage of runway 16. Waste Total waste at Shannon Airport (<1000 overall) was the second highest compared with the two other airports, with over 12% of this being recycled in 2010 and 2011. Biodiversity Measures to improve this include:  Chemicals used only where necessary  Efficient water systems in place  Greenhouses in place  Grass clippings reused on flower beds  Significant range of trees and grassed areas maintained at airports

7 IDENTIFICATION OF NATURA 2000 SITES The screening for AA undertaken for this project concluded that significant effects on the Conservation Objectives of two Natura 2000 sites could potentially ensue from the proposed development. It has been concluded that the proposed development at Shannon Airport Embankments is likely to have a significant effect, or significant effects cannot be ruled out at this stage, on the following Natura 2000 sites:

 Lower River Shannon cSAC (002165)  River Shannon and River Fergus Estuaries SPA (004077)

24 https://www.daa.ie/our-company/our-team/ [accessed 26/07/2019] 25 https://www.daa.ie/wp-content/uploads/2016/04/sustainability-2011.pdf [accessed 26/07/2019]

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Therefore, further assessment is required to determine whether the project is likely to adversely affect the integrity of these Natura 2000 sites.

7.1 LOWER RIVER SHANNON CSAC (002165)

7.1.1 Description of the Natura 2000 Site The Lower River Shannon cSAC is very large, long site approximately 14km wide and 120km long encompassing: the drained river valley which forms the River Shannon Estuary; the broader River Fergus Estuary, plus a number of smaller estuaries e.g. Poulnasherry Bay; the freshwater lower reaches of the Shannon River between Killaloe and Limerick, plus the freshwater stretches of much of the Feale and Mulkear catchments; a marine area at the mouth of the Shannon estuary with high rocky cliffs to the north and south; ericaceous heath on Kerry Head and Loop Head; and several lagoons. The underlying geology ranges from Carboniferous limestone (east of Foynes) to Namurian shales and flagstones (west of Foynes) to Old Red Sandstone (at Kerry Head). The salinity of the system varies daily with the ebb and flood of the tide and with annual rainfall fluctuations seasonally.

Both the Fergus and inner Shannon Estuaries feature vast expanses of intertidal mudflats. Plant species are typically scarce on the mudflats, although there are some eelgrass (Zostera spp.) beds and patches of green algae (e.g. Ulva sp. and Enteromorpha sp.). In the transition zone between mudflats and saltmarsh, specialised colonisers of mud predominate e.g. Common Cord-grass (Spartina anglica) which frequently occurs in the upper parts of the estuaries. In the innermost parts of the estuaries, the tidal channels or creeks are fringed with species such as Common Reed (Phragmites australis) and club-rushes (Scirpus maritimus, S. tabernaemontani and S. triquetrus).

Saltmarsh vegetation frequently fringes the mudflats. Over twenty areas of estuarine saltmarsh have been identified within the site. The dominant type of saltmarsh present is Atlantic salt meadow occurring over mud. Characteristic species occurring include Common Saltmarsh-grass (Puccinellia maritima), Sea Aster (Aster tripolium), Thrift (Armeria maritima), Sea-milkwort (Glaux maritima), Sea Plantain (Plantago maritima), Red Fescue (Festuca rubra), Creeping Bent (Agrostis stolonifera), Saltmarsh Rush (Juncus gerardi), Long-bracted Sedge (Carex extensa), Lesser Sea-spurrey (Spergularia marina) and Sea Arrowgrass (Triglochin maritima). Areas of Mediterranean salt meadows, characterised by clumps of Sea Rush (Juncus maritimus), occur occasionally.

Saltmarsh vegetation also occurs around a number of lagoons within the site, two of which have been surveyed as part of a National Inventory of Lagoons. Cloonconeen Pool (4-5 ha) is a natural sedimentary lagoon impounded by a low cobble barrier. This lagoon represents a type which may be unique to Ireland since the substrate is composed almost entirely of peat. The fauna is not diverse, but is typical of a high salinity lagoon and includes lagoon specialist species. In contrast, Shannon Airport Lagoon is an artificial saline lake with an artificial barrier and sluiced outlet. However, it supports two Red Data Book species of stonewort (Chara canescens and Chara cf. connivens).

Most of the site west of Kilcredaun Point/Kilconly Point is bounded by high rocky sea cliffs, which are sparsely vegetated with lichens, Red Fescue, Sea Beet (Beta vulgaris subsp. maritima), Sea Campion (Silene vulgaris subsp. maritima), Thrift and plantains (Plantago spp.), particularly in the outer part of the site. Cliff-top vegetation usually consists of either grassland or maritime heath. The site supports an excellent example of a large shallow inlet and bay. The sediment communities in the

19986-6002-D Natura Impact Statement June 2020 mouth of the Shannon Estuary occur in areas that are exposed to wave action and also in areas extremely sheltered from wave action. Characteristically, exposed sediment communities are composed of coarse sand and have a sparse fauna. Species richness increases as conditions become more sheltered. The intertidal reefs in the Shannon Estuary are exposed or moderately exposed to wave action and subject to moderate tidal streams. Other coastal habitats that occur within the site include stony beaches and bedrock shores, shingle beaches, sandbanks which are slightly covered by sea water at all times and sand dunes.

Freshwater rivers have been included in the site, most notably the Feale and Mulkear catchments, the Shannon from Killaloe to Limerick (along with some of its tributaries), the Fergus up as far as Ennis and the Cloon River. These systems are very different in character: the Shannon is broad, generally slow flowing and naturally eutrophic; the Fergus is smaller and alkaline; while the narrow, fast flowing Cloon is acid in nature. Semi-natural habitats, such as wet grassland, wet woodland and marsh occur by the rivers, but improved grassland is the most common habitat type. One grassland type of particular conservation significance, Molinia meadows, occurs in several parts of the site. Here are found areas of wet meadow dominated by rushes (Juncus spp.) and sedges (Carex spp.), and supporting a diverse and species-rich vegetation. Floating river vegetation characterised by species of water-crowfoot (Ranunculus spp.), pondweeds (Potamogeton spp.) and the moss Fontinalius antipyretica are present throughout the major river systems within the site.

Alluvial woodland occurs on the banks of the Shannon and on some islands. The most prominent woodland type is gallery woodland where White Willow (Salix alba) dominates the tree layer with occasional Alder (Alnus glutinosa). On slightly higher ground above the wet woodland and on the raised embankment remnants of mixed oak-ash-alder woodland occur. The ground flora is species rich. While woodland is infrequent within the site, Cahiracon Wood contains an area of old oak woodland. Sessile Oak (Q. petraea) forms the canopy, with an understorey of Hazel and Holly (Ilex aquifolium). Patches of semi-natural broadleaf woodland dominated by Ash, Hazel, oak and birch occur on higher ground north-east of Cappamore. There is a small area of actively regenerating cut- away raised bog at Ballyrorheen, Co. Limerick. The bog contains some wet areas with good cover of bog mosses (Sphagnum spp.). Species of particular interest include Cranberry (Vaccinium oxycoccos) and White Sedge (Carex curta), along with two regionally rare mosses.

There is a resident population of Bottle-nosed Dolphin in the Shannon Estuary. This is the only known resident population of this E.U. Habitats Directive Annex II species in Ireland. Otter, a species also listed on Annex II of this Directive, is commonly found on the site. Five species of fish listed on Annex II of the E.U. Habitats Directive are found within the site. These are Sea Lamprey (Petromyzon marinus), Brook Lamprey (Lampetra planeri), River Lamprey (Lampetra fluviatilis), Twaite Shad (Allosa fallax fallax) and Salmon (Salmo salar). The three lampreys and Salmon have all been observed spawning in the lower Shannon or its tributaries. Twaite Shad is not thought to spawn within the site. There are few other river systems in Ireland which contain all three species of lamprey. Freshwater Pearl Mussel (Margaritifera margaritifera), a species listed on Annex II of the E.U. Habitats Directive, occurs abundantly in parts of the Cloon River.

This site is of great ecological interest as it contains a high number of habitats and species listed on Annexes I and II of the E.U. Habitats Directive, including the priority habitats lagoon and alluvial woodland, the only known resident population of Bottle-nosed Dolphin in Ireland and all three Irish

19986-6002-D Natura Impact Statement June 2020 lamprey species. A number of species listed on Annex I of the E.U. Birds Directive are also present, either wintering or breeding. Most of the estuarine part of the site has been designated a Special Protection Area (SPA), under the E.U. Birds Directive, primarily to protect the large numbers of migratory birds present in winter (adapted from Lower River Shannon cSAC 002165 Site Synopsis).

This SAC is designated for the following habitats and species: • Sandbanks which are slightly covered by sea water all the time [1110] • Estuaries [1130] • Mudflats and sand flats not covered by seawater at low tide [1140] • Coastal lagoons [1150]* • Large shallow inlets and bays [1160] • Reefs [1170] • Perennial vegetation of stony banks [1220] • Vegetated sea cliffs of the Atlantic and Baltic coasts [1230] • Salicornia and other annuals colonising mud and sand [1310] • Atlantic salt meadows (Glauco-Puccinellietalia maritimae) [1330] • Mediterranean salt meadows (Juncetalia maritimi) [1410] • Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation [3260] • Molinia meadows on calcareous, peaty or clayey-silt-laden soils (Molinion caeruleae) [6410] • Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-Padion, Alnion incanae, Salicion albae) [91E0]* • Freshwater Pearl Mussel (Margaritifera margaritifera) [1029] • Sea Lamprey (Petromyzon marinus) [1095] • Brook Lamprey (Lampetra planeri ) [1096] • River Lamprey (Lampetra fluviatilis) [1099] • Salmon (Salmo salar ) [1106] • Common Bottlenose Dolphin (Tursiops truncates) [1349] • Otter (Lutra lutra) [1355]

7.1.2 Identification of Potential for Significant Impacts to Qualifying Features When Natura 2000 sites are selected for stage 2 assessments, then all the qualifying features of conservation interest must be included in that stage of the assessment. However, when assessing impact, qualifying features are only considered relevant where a credible or tangible source- pathway-receptor link exists between the proposed development and a protected species or habitat type. In order for an impact to occur there must be a risk initiated by having a 'source' (e.g. excavation works), a 'receptor' (e.g. a protected species associated aquatic or riparian habitats), and an impact pathway between the source and the receptor (e.g. a watercourse which connects the proposed development site to the Natura 2000 site). Identifying a risk that could, in theory, cause an impact does not automatically mean that the risk event will occur, or that it will cause or create an adverse impact. However, identification of the risk does mean that there is a possibility of ecological or environmental damage occurring, with the level and significance of the impact depending upon the nature of the risk, the extent of the exposure to the risk and the characteristics of the receptor.

Bearing in mind the scope, scale, nature and size of the project, its location relative to the distribution of the species and habitats listed and the degree of connectedness that exists between

19986-6002-D Natura Impact Statement June 2020 the project and the potential receptors, it is considered that not all of them are within the zone of potential impact of the proposal. An evaluation based on these factors to determine which species and habitats are the plausible ecological receptors for potential impacts of the unmitigated proposal has been conducted below.

The following table lists the qualifying features of the Lower River Shannon cSAC and evaluates through a scientific examination of evidence and data whether or not these features should or should not be selected for further assessment in the NIS. The qualifying features that are selected for further assessment are then discussed further followed by an assessment of potentially significant effects arising from the proposed development.

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Table 10 Identification of potential for significant impacts to qualifying features of the Lower River Shannon cSAC26 Qualifying Potential for Rationale Feature Significant Impacts Sandbanks which No The extent of mapped ‘sandbanks which are slightly covered by seawater all the time’ in the Lower River Shannon cSAC is given in are slightly NPWS (2012a). This habitat is mapped as occurring south of Rinevella Point, Co. Clare and west of Ballybunion, Co. Kerry in the mouth covered by sea of the Shannon Estuary. This habitat is in excess of 50km to the west of the proposed development. Given the intervening distance water all the time between the proposal and this habitat it is considered that the project does not have potential for significant effects on sandbanks. Thus, the project will not affect the conservation objectives for ‘sandbanks which are slightly covered by sea water all the time’ and the habitat is not considered further in the NIS. Estuaries Yes The Shannon and Fergus Estuaries form a unit stretching from the upper tidal limits of the Shannon and Fergus Rivers to the mouth of the Shannon Estuary (considered being a line across the narrow strait between Kilcredaun Point and Kilconly Point). Within this main unit, there are several tributaries with their own ‘sub-estuaries’ e.g. the Deel River, Mulkear River, and Maigue River. Estuarine habitat surrounds the proposed development as the existing embankments form the land boundary with the estuary channel (NPWS, 2012a). While it is considered that any potential water quality impacts will be localised in view of the localised nature, extent and scale of the proposed works and due to the dilution potential of the River Shannon and estuary, there is the potential for significant impacts to occur, and as such, ‘Estuaries’ are to be considered further in the NIS. Mudflats and Yes ‘Mudflats and sandflats not covered by seawater at low tide’ occur extensively throughout the site, in particular along the edges of the sandflats not Shannon Estuary channel. They occur within the vicinity of Shannon Airport, beginning at Shannon Bridge and increasing in extent covered by further downstream as the estuary channel widens. This habitat is mapped as occurring immediately adjacent to both the West and seawater at low East Embankments (NPWS, 2012a). The proposal will result in removal/alteration of mudflat habitat as a result of excavation works and tide installation of rock armour. Given the characteristics of the project, it is considered that there is potential for significant effects to occur, and as such, this habitat is to be considered further in the NIS. Coastal lagoons* Yes According to habitat mapping presented in NPWS (2012a), there are four coastal lagoons within the SAC, namely Quayfield and Poulaeala Loughs, Shannon Airport Lagoon, Scattery Lagoon, and Cloonconneen Pool. The west embankment, to which works are proposed, lies adjacent to the Shannon Airport Lagoon. While there is some land intervening, the lagoon is in close proximity to the proposed works, therefore the project has the potential to affect the lagoons conservation objectives and thus ‘Coastal lagoon’ habitat is to be considered further in the NIS. Large shallow No The habitat ‘large shallow inlets and bays’ is a large physiographic feature that may wholly or partly incorporate other Annex I habitats inlets and bays including reefs, sandbanks and mudflats and sandflats within its area. In contrast to estuaries, large shallow inlets and bays have limited

26 https://www.npws.ie/sites/default/files/protected-sites/conservation_objectives/CO002165.pdf [accessed 25/07/2019]

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Qualifying Potential for Rationale Feature Significant Impacts freshwater influence. This habitat-type, with an estimated area of approximately 25,000ha, is mapped as occurring west of Shannon towards the mouth of the estuary. The habitat comprises the channel south of Kilrush, Co. Clare extending westwards to the outer extent of the estuary (NPWS, 2012a). This habitat is in excess of 40km to the west of the proposed development. Given the intervening distance between the proposal and this habitat it is considered that the project does not have potential for significant effects on this habitat. Thus, the project will not affect the conservation objectives for ‘large shallow inlets and bays’ and the habitat is not considered further in the NIS. Reefs No ‘Reef’ occurs throughout the estuary, mainly as scattered and isolated pockets within the inner estuary and covering more extensive areas towards the middle and outer reaches of the channel. A review of mapping available for this habitat-type determined that the closest areas of reef to the proposed development comprise an area located on the shoreline approximately 950m west of the northern end of the West Embankment and another area located out in the main channel, approximately 670m south-east of the southern end of the West Embankment (NPWS, 2012a). It is considered that any potential water quality impacts will be localised in view of the localised nature, extent and scale of the proposed works and due to the dilution potential of the River Shannon and estuary, there is no potential for significant impacts to occur, and as such, ‘Reefs’ will not be considered further in the NIS. Perennial No This habitat occurs along the coast where shingle (cobbles and pebbles) and gravel have accumulated to form elevated ridges or banks vegetation of above the high tide mark. This habitat is recorded in 9 locations along the Shannon River and Estuary. At its closest, this habitat occurs stony banks at Ballymacrinan Bay (NPWS, 2012a), a distance in excess of 39km west of the project. Given the characteristics of the project, and the distance intervening, it is not considered that the proposal has any potential to significantly impact on this habitat-type. Thus, the project will not affect the conservation objectives for ‘perennial vegetation of stony banks’ and the habitat is not considered further in the NIS. Vegetated sea No ‘Vegetated sea cliffs of the Atlantic and Baltic coasts’ occur at the western extent of the Shannon Estuary. At its closest, this habitat is cliffs of the located at Baurrane on the southern coast of Co. Clare (NPWS, 2012a), in excess of 30km west of the proposed development. Given the Atlantic and characteristics of the project, and the distance intervening, it is not considered that the proposal has any potential to significantly Baltic coasts impact on this habitat-type. Thus, the project will not affect the conservation objectives for ‘Vegetated sea cliffs of the Atlantic and Baltic coasts’ and the habitat is not considered further in the NIS. Salicornia and No Salicornia and other annuals colonizing mud and sand are classified by Fossitt (2000) as lower salt marsh. A review of habitat mapping other annuals and the coastal habitats supporting document available for the SAC determined that of the ten sub-sites surveyed, mapped and colonizing mud assessed as part of the Saltmarsh Monitoring Project (McCorry & Ryle, 2009) the closest site to the proposal site where Salicornia and sand habitat is mapped as occurring is the ‘Inishdea, Owenshere’ sub-site (SMP 0083)(NPWS, 2012a). Inishdea saltmarsh is located in southern Co. Clare, along the western side of the Fergus Estuary, in excess of 10km north-west of the proposed development. Within

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Qualifying Potential for Rationale Feature Significant Impacts the sub-site Salicornia habitat is not well-developed occupying a single patch of ground of 0.003ha (NPWS, 2012a). Given the characteristics of the project including the localised nature, extent and scale of the proposed works, and the distance intervening, it is not considered that the proposal has any potential to significantly impact on this habitat-type. Thus, the project will not affect the conservation objectives for ‘Salicornia and other annuals colonizing mud and sand’ and the habitat is not considered further in the NIS. Atlantic salt Yes ‘Atlantic salt meadows’ (ASM) generally occupy the widest part of the salt marsh gradient. A review of habitat mapping and the coastal meadows habitats supporting document available for the SAC determined that of the ten sub-sites surveyed, mapped and assessed as part of the (Glauco- Saltmarsh Monitoring Project (McCorry & Ryle, 2009) the closest site to the proposal site where ASM habitat is mapped as occurring is Puccinellietalia the ‘Bunratty’ sub-site (SMP 0081)(NPWS, 2012a). Bunratty saltmarsh is located in the upper part of the Shannon Estuary in Co. Clare, maritimae) approximately 2.8km east of the proposal area. Within the sub-site, ASM is the most extensive of all the saltmarsh habitats, estimated to measure approximately 27ha. Typically it occurs within this sub-site as a narrow band at the landward side of the brackish vegetation. However, potential ASM is mapped as occurring along the shoreline extending westwards from this area as far as and immediately adjacent to the northern extent of the East Embankment (NPWS, 2012). During habitat surveys undertaken for the proposed works two small areas of previously unmapped Upper salt-marsh (CM2) corresponding to Annex I ‘Atlantic salt meadow’ were identified immediately adjacent to the East Embankment towards its northern end. The proposal will result in works immediately adjacent to and in the general vicinity of these areas of ASM. Given the characteristics of the project, it is considered that there is potential for significant effects to occur, and as such, ‘Atlantic salt meadows’ is to be considered further in the NIS. Mediterranean No ‘Mediterranean salt meadows’ (MSM) occupy the upper zone of salt marshes and usually occur adjacent to the boundary with salt meadows terrestrial habitats. They are widespread on the Irish coastline; however, they are not as extensive as Atlantic salt meadows. A review of (Juncetalia habitat mapping and the coastal habitats supporting document available for the SAC determined that of the ten sub-sites surveyed, maritimi) mapped and assessed as part of the Saltmarsh Monitoring Project (McCorry & Ryle, 2009) the closest site to the proposal site where MSM habitat is mapped as occurring is the ‘Bunratty’ sub-site (SMP 0081)(NPWS, 2012a). Bunratty saltmarsh is located in the upper part of the Shannon Estuary in Co. Clare, approximately 2.8km east of the proposal area. The MSM is not well-developed or as widespread as the ASM within the sub-site and is generally confined to narrow fragmented patches in the ASM or towards the back of the marsh. The MSM is estimated to measure approximately 0.9ha within the site. Given the characteristics of the project including the localised nature, extent and scale of the proposed works, and the distance intervening, it is not considered that the proposal has any potential to significantly impact on this habitat-type. Thus, the project will not affect the conservation objectives for ‘Mediterranean salt meadows’ and the habitat is not considered further in the NIS. Watercourses of Yes This annexed habitat has a broad definition, covering from upland, flashy, oligotrophic, bryophyte- and algal-dominated rivers, to tidal

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Qualifying Potential for Rationale Feature Significant Impacts plain to montane reaches dominated by higher plants. The full distribution of this habitat and its sub-types within the SAC are currently unknown. The levels with the Groenlandia densa (L.) Fourr., Opposite-leaved Pondweed sub-type has been identified as a high conservation element in the site. In Ranunculion Ireland, this particular sub-type is associated with tidal reaches of rivers and other periodically disturbed watercourses (e.g. canals and fluitantis and drains) (NPWS, 2012a). Groenlandia densa was identified within a drainage channel associated with the Shannon Airport Lagoon during Callitricho- habitat surveys carried out on-site. Therefore, ‘Floating river vegetation’ as the habitat is commonly known is considered to be within Batrachion the zone of influence of the project and thus, there is potential for significant effects to this habitat. vegetation Molinia meadows No ‘Molinia meadows on calcareous, peaty or clayey-silt-laden soils’ is represented in Ireland by both fen and grassland communities on calcareous, onnutrient-poor soils. The habitat is either managed as traditional hay meadows or more usually by extensive pasture. Molinia peaty or clayey- meadows occur in lowland plains on neutral to calcareous gleys, sometimes with a marl layer beneath the surface, or on peaty soils silt-laden soils both in lowland and upland situations (NPWS, 2019). The full extent of this habitat within the SAC is currently unknown. It has been (Molinion recorded on the eastern bank of the Shannon, just north of Castleconnell, Co. Limerick NPWS (2012a). caeruleae) Given the characteristics and location of the project, it is not considered that the proposal has any potential to significantly impact on this habitat-type. Thus, the project will not affect the conservation objectives for ‘Molinia meadows’ and the habitat is not considered further in the NIS. Alluvial forests No Alluvial woodland is a priority Annex I habitat. A number of variants of this habitat exist, of which riparian forests of Fraxinus excelsior with Alnus and Alnus glutinosa of temperate and Boreal Europe lowland and hill watercourses are the most common type found in Ireland. The glutinosa and Interpretation Manual of EU habitats (2013) states that all types occur on heavy soils which are periodically inundated by the annual Fraxinus excelsior rise of river levels, but which are otherwise well-drained and aerated during low water. In addition, there are gallery forests of tall (Alno-Padion, willows alongside river channels and occasionally on river islands, where the tree roots are almost continuously submerged (NPWS, Alnion incanae, 2019a). Salicion albae)* Alluvial woodlands occur along the Shannon, in the valley bottoms of the tributaries and on seepage zones on valley sides. Within the SAC five sites have been surveyed as part of the National Survey of Native Woodlands. These are small stands, restricted to narrow bands where the ground is subject to flooding (NPWS, 2012a). The nearest mapped area of this habitat is at Clare Glen along the main channel of the Clare River, approximately 25km east of the proposal area. Given the characteristics and location of the project, it is not considered that the proposal has any potential to significantly impact on this habitat-type. Thus, the project will not affect the conservation objectives for ‘Alluvial forests’ and the habitat is not considered further in the NIS. Freshwater Pearl No The freshwater pearl mussel is a large, long-lived bivalve mollusc found in clean, fast-flowing, well-oxygenated rivers with Mussel unconsolidated substrates. Stable, clean gravel and sand with adequate availability of dissolved oxygen provides ideal habitat for

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Qualifying Potential for Rationale Feature Significant Impacts (Margaritifera juveniles. Water pH and hardness is also important with distribution mainly restricted to acidic, soft waters over-lying non-calcareous margaritifera) rock-types. Low nutrient status is also critical such that excess macrophyte and algal growth is prevented; therefore oligotrophic waterbodies are required. Conservation objectives for this species within the SAC apply to the freshwater pearl mussel population in the Cloon River, County Clare. This population is confined to the main channel and is distributed from Croany Bridge to upstream of Clonderalaw Bridge (NPWS (2012a). The Cloon River enters the main Shannon Estuary in excess of 23km west of the proposal site. Given the characteristics and location of the project, and the ecology of this species, it is not considered that the proposal has any potential to significantly impact on freshwater pearl mussel. Thus, the project will not affect the conservation objectives for ‘Freshwater Pearl Mussel’ and the species is not considered further in the NIS. Sea Lamprey No The life cycle of the sea lamprey (Petromyzon marinus) contains both a marine phase and a freshwater phase. Sea lampreys spend (Petromyzon their adult life in marine and estuarine waters, living as external parasites on other fish species. They migrate up rivers in spring to marinus) spawn in areas of clean gravel, after which they die. Sea lamprey is known to spawn within the lower Shannon and its tributaries (Kelly and King, 2001). The two 10km grid squares, R35 and R36, which encompass the proposal site, are included within the current known range for sea lamprey (NPWS, 2019b). This distribution is based on records in freshwater habitats, but adult sea lamprey, and transformers (intermediate stage between larvae and adult) occur in the Shannon Estuary. The early life stages of this species require clean substrates in fast flowing freshwater habitats during spawning and ova development. The proposed development will not adversely affect these habitats. The proposed development will not affect the attributes and targets for this species, namely: distribution; population structure of juveniles; juvenile density in fine sediment, extent and distribution of spawning habitat and availability of juvenile habitat. It is considered that any potential water quality impacts will be localised in view of the localised nature, extent and scale of the proposed works and the dilution potential of the River Shannon Estuary. There is therefore no potential for significant impacts to sea lamprey, and as such ‘Sea lamprey’ will not considered further in the NIS. Brook Lamprey No Unlike sea and river lamprey, brook lamprey is not parasitic and is non-migratory, spending its entire life in freshwater. Species (Lampetra distribution within river catchments is dependent on the availability of suitable habitat; adults require fine sand/gravel areas in which to planeri) spawn while the juvenile form needs clean, fine sediment into which to burrow (King, et al., 2011). Given the characteristics and location of the project, and the exclusively freshwater ecology of this species, it is not considered that the proposal has any potential to significantly impact on brook lamprey. Thus, the project will not affect the conservation objectives for ‘Brook Lamprey’ and the species is not considered further in the NIS. River lamprey No River lamprey has a similar life history to sea lamprey. River lampreys spend their adult life in marine and estuarine waters, living as (Lampetra external parasites on other fish species. River lamprey is known to spawn within the lower Shannon and its tributaries (Kelly and King,

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Qualifying Potential for Rationale Feature Significant Impacts fluviatilis) 2001). The two 10km grid squares, R35 and R36, which encompass the proposal site, are included within the current known range for river lamprey (NPWS, 2019b). This distribution is based on records in freshwater habitats, but adult river lamprey, and transformers (intermediate stage between larvae and adult) occur in the Shannon Estuary. It is considered that any potential water quality impacts will be localised in view of the localised nature, extent and scale of the proposed works and the dilution potential of the River Shannon Estuary. The early life stages of this species require clean substrates in fast flowing freshwater habitats during spawning and ova development. The proposed development will not adversely affect these habitats. The proposed development will not affect the attributes and targets for this species, namely: distribution; population structure of juveniles; juvenile density in fine sediment, extent and distribution of spawning habitat and availability of juvenile habitat. There is therefore no potential for significant impacts to river lamprey, and as such ‘River lamprey’ will not considered further in the NIS. Atlantic Salmon No Salmon is an anadromous species, living in freshwater for at least the first two or three years of life before migrating to sea. Most Irish (Salmo salar) fish spend one winter at sea before returning to their natal rivers. Salmon has been observed spawning in the lower Shannon and its tributaries. The 10km grid square, R35, which encompasses the proposal site, is included within the current known range and distribution for Atlantic salmon (NPWS, 2019b). This distribution is based on records in freshwater habitats. Adult salmon occur in the Shannon Estuary prior to returning to natal streams to spawn, and smolts occur in the estuary on their journey from influent rivers to the sea. It is considered that any potential water quality impacts will be localised in view of the localised nature, extent and scale of the proposed works, and the dilution potential of the River Shannon Estuary, therefore there is no potential for significant impacts to salmon, and as such ‘Atlantic salmon’ is not considered further in the NIS. Common No There is a resident population of bottle-nosed dolphin in the Shannon Estuary. This is the only known resident population of this Annex Bottlenose II species in Ireland. The majority of the Shannon Estuary is considered to comprise suitable habitat for this species, apart from the Dolphin (Tursiops inter-tidal areas of the Fergus Estuary and the inner estuary channel in the vicinity of Shannon town stretching east towards Limerick; truncates) however, a review of on-line species records shows that sightings are concentrated in the outer channel. Within the SAC two ‘critical areas’, representing habitat used preferentially by bottlenose dolphin, have been identified. These are located in the vicinity of Tarbert/Killimer and further west towards the mouth of the estuary in the vicinity of Ballybunion and Kilcredaun Point (NPWS, 2012). A review of studies (unpublished reports) available on the NPWS website on the Shannon Estuary bottlenose dolphin population determined that previous surveys have focussed on the outer estuary channel, including these ‘critical areas’, rather than in the inner estuary in the vicinity of Shannon and the proposed works. Given the characteristics and location of the project including the localised nature, extent and scale of the proposed works, the dilution

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Qualifying Potential for Rationale Feature Significant Impacts potential of the River Shannon and estuary and the distribution of bottlenose dolphin habitat and records within the estuary, it is not considered that the proposal has any potential to significantly impact on this species. Thus, the project will not affect the conservation objectives for ‘Common Bottlenose Dolphin’ and the species is not considered further in the NIS. Otter (Lutra Yes Otter are widespread in Ireland throughout freshwater and coastal habitats. Otter has two basic requirements: aquatic prey and safe lutra) refuges in which to rest. In Ireland, otters are found along rivers, lakes and coasts, where fish and other prey are abundant, and where the bank-side habitat offers sufficient cover. The presence of freshwater, a sufficient prey-base and suitable sites for holts/couches are key factors in determining otter distribution. The 10km grid square, R35, which encompasses the proposal site, is included within the current known range and distribution for otter (NPWS, 2019b). A review of on-line records held by the NBDC determined that there are no records of otter within the vicinity of Shannon Airport; however, based on the ubiquitous nature of this species and the abundance of suitable foraging and commuting habitat in the area it is considered that otter are likely to occur in the general vicinity of the proposed works, and as such may be subject to impacts. There is, therefore, potential for significant impacts to otter, and as such ‘Otter’ is to be considered further in the NIS.

This evaluation has determined that certain habitats and species, which are listed as qualifying interests for the Natura 200 site, should be selected for further assessment as plausible ecological receptors, as outlined in Table 10 above.

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7.1.3 Qualifying Features Selected for Further Assessment 7.1.3.1 Estuaries [1130] The Shannon and Fergus Estuaries form the largest estuarine complex in Ireland. They form a unit stretching from the upper tidal limits of the Shannon and Fergus Rivers to the mouth of the Shannon Estuary.

Estuaries are semi-enclosed bodies of water which have a connection with the open sea and so are subject to tidal influence while also having significant freshwater influence. They differ from other coastal inlets, such as ‘large shallow inlets and bays’ in that there is dilution of seawater with freshwater which results in permanent variability in salinity. Estuaries are frequently observed to be composed of a range of distinct substrates stretching from the high water mark to the sub-tidal zone. The high water points of estuaries are often formed from boulders/shingle and frequently from man-made margins in urban areas. The intertidal flanks exposed to the forces that form the estuarine habitat can be composed of deposited material such as sand and mud/silt. The estuarine bed or channel is eroded to the greatest extent by the movement of the river channel and is consequently generally coarse material or bedrock. The current conservation status for estuaries has been assessed as ‘Inadequate’ (NPWS, 2019b).

The conservation objective is to maintain the favourable conservation condition of ‘Estuaries’ in the Lower River Shannon cSAC, which is defined by the following list of attributes and targets.

Table 11 Attributes and targets for ‘Estuaries’ within the Lower Shannon SAC (NPWS, 2012a) Attribute Measure Target/Notes The permanent habitat area is stable or increasing, subject to natural processes. Habitat Area Hectares Habitat area estimated as 24,273ha. Conserve the following community types in a natural condition: Intertidal sand to mixed sediment with polychaetes, molluscs and crustaceans community complex; Estuarine sub-tidal muddy sand to mixed sediment with gammarids community Community complex; Sub-tidal sand to mixed sediment with Nucula nucleus community Hectares Distribution complex; Sub-tidal sand to mixed sediment with Nephtys spp. community complex; Fucoid‐dominated intertidal reef community complex; Faunal turf‐dominated sub-tidal reef community; and Anemone‐dominated sub-tidal reef community.

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Figure 5 Distribution of estuaries within the Lower River Shannon cSAC (NPWS, 2012a)

7.1.3.2 Mudflats and sandflats not covered by seawater at low tide [1140] These sediment habitats are found between the low water and mean high water tide marks. It is often a sub-set of the Annex I habitats ‘large shallow inlets and bays’ and ‘estuaries’ but is not dependent on those habitats for occurrence. The finer silt and clay sediments are dominant in mudﬂats and the larger sand particles are associated with areas exposed to greater wave forces. A range of physical pressures operate resulting in significant changes in salinity, temperature, and exposure to air. The competing forces of seaward-flowing freshwater meeting the flooding tide reduces net flow velocity and consequently the carrying capacity for sediment leading to deposition. These sediments are often rich in nutrients. The depth of sediment habitat suitable for fauna is limited by oxygen levels. Where tide and wave exposure conditions are suitable the sediment can form into stable mixed sediment ﬂats. The current conservation status for mudflats and sandflats has been assessed as ‘Inadequate’ (NPWS, 2019b).

Conservation objectives are to maintain the favourable conservation condition of ‘Mudflats and sandflats not covered by seawater at low tide’ in the Lower River Shannon cSAC, as defined by the following attributes and targets.

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Table 12 Attributes and targets for ‘Mudflats and sand flats not covered by sea water at low tide’ within the Lower River Shannon cSAC (NPWS, 2012a) Attribute Measure Target/Notes The permanent habitat area is stable or increasing, subject to natural processes. Habitat Area Hectares Habitat area estimated using OSi data as 8,808ha. Conserve the following community types in a natural condition: Intertidal sand Community with Scolelepis squamata and Pontocrates spp. community; and Intertidal sand Hectares Distribution to mixed sediment with polychaetes, molluscs and crustaceans community complex.

Figure 6 Distribution of mudflats and sandflats within the Lower River Shannon cSAC (NPWS, 2012a)

Two marine community types occur within the channel in the vicinity of Shannon Airport, as shown in Figure 7 below. These are:

 Inter-tidal sand to mixed sediment with polychaetes, molluscs and crustaceans community complex  Sub-tidal sand to mixed sediment with Nephtys spp. community complex

7.1.3.2.1 Inter-tidal sand to mixed sediment with polychaetes, molluscs & crustaceans community complex This intertidal community is found extensively throughout the site. Mixed sediment is the dominant sediment type within this community. The sediment type is highly variable throughout this community evidenced by the wide ranges in sediment fractions (NPWS, 2012a). This community type is mapped as occurring along the seaward face of the East Embankment.

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7.1.3.2.2 Sub-tidal sand to mixed sediment with Nephtys spp. community complex This community complex occurs extensively east of Battle Island to Foynes; elsewhere it is recorded from Labasheeda Bay, Clonderalaw Bay, Ballymacrinan Bay, Ballylongford Bay and Carrigaholt Bay. The sediment of the complex is that of sand to mixed sediment with a great deal of variation within the sediment fractions. The community is distinguished by the polychaete genera Nephtys spp. NPWS, 2012a).

Figure 7 Distribution of marine community types within the inner Shannon Estuary (NPWS, 2012a)

7.1.3.3 Coastal Lagoons [1150]* A coastal lagoon is defined as a lake or a pond that may be fully or partially separated from the sea by a permeable barrier, which may be entirely natural (shingle) or unnatural (artificial barrier such as an embankment). All the lagoons identified within the Lower River Shannon cSAC can be classified as shallow, thus even small changes in water depth can cause significant losses in habitat area. Shannon Airport Lagoon has a sluiced inlet (NPWS, 2012). Salinity can vary greatly due to factors such as freshwater/saltwater inputs and barrier permeability. Lagoons support unique assemblages of flora and fauna, in particular, a unique assemblage of invertebrates. Typical species include Chara canescens, Chara baltica, Chara connivens, Lamprothamnium papulosum, Palaemon adspersus and Ruppia maritima. Coastal lagoons are a priority Annex I habitat. The current conservation status for coastal lagoons has been assessed as ‘Bad’ (NPWS, 2019a). There are four coastal lagoons listed for the Lower River Shannon cSAC, as outlined in Table 13 below.

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Table 13 ‘Coastal Lagoons’ within the Lower River Shannon cSAC (NPWS, 2012a) Code Name County Salinity Conservation Assessment IL031 Quayfield & Limerick Oligohaline/ Unfavourable - inadequate Poulaweala Loughs polyhaline IL032 Shannon Airport Clare Oligohaline Unfavourable - Bad Lagoon IL033 Scattery Lagoon Clare Euhaline Unfavourable - inadequate IL034 Cloonconeen Pool Clare Euhaline Unfavourable - inadequate

Figure 8 Shannon Airport Lagoon (NPWS, 2012a)

Shannon Airport Lagoon lies south-west of Shannon Airport at the landward side of the West Embankment. The lagoon comprises an area of approximately 24.2ha. This artificial drainage lagoon is separated from the sea by man-made barriers comprising the embankment and an access road. The lagoon was developed in the 1940’s when a seawall was constructed out into the estuary to prevent Shannon Airport from flooding. The water level in the lagoon is managed via a sluiced outlet through which water drains via a drainage channel located in the lagoons north-western corner. Pumping ceased in March 2014 following the opening and ongoing maintenance of the sluice outlet (See Section 5.4).

Conservation objectives are to restore the favourable conservation condition of ‘Coastal lagoons’ in the Lower River Shannon cSAC, as defined by the following attributes and targets.

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Table 14 Attributes and targets for ‘Coastal lagoons’ within the Lower River Shannon cSAC (NPWS, 2012a) Attribute Measure Target/Notes Area stable or increasing subject to natural processes. Favourable reference area 33.4ha ‐ Shannon Airport Lagoon 24.2ha; Habitat area Hectares Cloonconeen Pool 3.9ha; Scattery Lagoon 2.8ha; Quayfield and Poulaweala Loughs 2.5ha. Habitat distribution Occurrence No decline, subject to natural processes. Practical Median annual salinity and temporal variation within natural Salinity regime salinity units ranges. The lagoons in the site vary from oligohaline to euhaline. (psu) Annual water level fluctuations and minima within natural ranges. Hydrological regime Metres Lagoons listed for this site are all considered to be shallow. Appropriate hydrological connections between lagoons and sea, Barrier connectivity: including where necessary, appropriate management. The lagoons between lagoon and Permeability within this site exhibit a variety of barrier types including sea cobble/shingle, karst and artificial embankment. Water quality: Annual median chlorophyll a within natural ranges and less than µg/L Chlorophyll a 5μg/L. Water quality: Molybdate Reactive mg/L Annual median within natural ranges and <0.1mg/l. Phosphorous (MRP) Water quality: Dissolved Inorganic mg/L Annual median within natural ranges and <0.15mg/l. Nitrogen (DIN) Macrophyte colonisation to maximum depth of lagoons. As these Depth of macrophyte Metres lagoons are all shallow, it is expected the macrophytes should colonisation extend to their deepest points. Maintain number and extent of listed lagoonal specialists, subject Typical plant species Number and m2 to natural variation. Typical animal Maintain listed typical lagoonal specialists, subject to natural Number species variation. Negative indicator Number and % Negative indicator species absent or under control. species cover

7.1.3.4 Atlantic salt meadows (Glauco-Puccinellietalia maritimae) [1330] Atlantic salt meadow generally occupies the widest part of the saltmarsh gradient. They also contain a distinctive topography with an intricate network of creeks and salt pans occurring on the medium to large sized salt marshes. Atlantic salt meadows contain several distinctive zones that are related to elevation and submergence frequency. The lowest part along the tidal zone is generally dominated by common saltmarsh-grass (Puccinellia maritima) with species like glassworts (Salicornia spp.), annual seablite (Suaeda maritima) and lax-flowered sea-lavender (Limonium humile) also important. The invasive common cordgrass (Spartina anglica) can be locally abundant in this habitat. The mid-marsh zones are generally characterised by thrift (Armeria maritima) and/or sea plantain (Plantago maritima).This zone is generally transitional to an upper marsh herbaceous community.

This habitat is also important for other wildlife including wintering waders and wildfowl. Atlantic salt meadows are distributed around most of the coastline of Ireland. The intricate topography of the

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Irish coastline with many inlets has created an abundance of sites that are sheltered and allow muddy sediments to accumulate, leading to the development of saltmarsh. The current conservation status for Atlantic salt meadow has been assessed as ‘Inadequate’ (NPWS, 2012a).

Conservation objectives are to restore the favourable conservation condition of ‘Atlantic salt meadows’ in the Lower River Shannon cSAC, as defined by the following attributes and targets.

Table 15 Attributes and targets for ‘Atlantic salt meadows’ within the Lower River Shannon cSAC (NPWS, 2012a) Attribute Measure Target/Notes Habitat area Hectares Area stable or increasing, subject to natural processes, including erosion and succession. For sub‐sites mapped: Carrigafoyle‐ 6.774ha; Barrigone, Aughinish‐ 10.288ha; Beagh‐ 0.517ha; Bunratty‐ 26.939ha; Shepperton, Fergus Estuary‐ 37.925ha; Inishdea, Owenshere;‐ 18.127ha; Killadysert, Inishcorker‐ 2.604ha; Knock‐ 0.576ha; Querin‐ 3.726ha; Rinevilla Bay‐ 11.883ha. Habitat distribution Occurrence No decline or change in habitat distribution, subject to natural processes. Physical structure: Presence/absence of Maintain natural circulation of sediments and organic matter, sediment supply physical barriers without any physical obstructions Physical structure: Occurrence Maintain creek and pan structure, subject to natural processes, creeks and pans including erosion and succession Physical structure: Hectares flooded, Maintain natural tidal cycle flooding regime frequency Vegetation Occurrence Maintain the range of coastal habitats including transitional structure: zonation zones, subject to natural processes including erosion and succession Vegetation Centimetres Maintain structural variation within sward structure: vegetation height Vegetation Percentage cover at a Maintain more than 90% of the saltmarsh area vegetated structure: representative vegetation cover sample of monitoring stops Vegetation Percentage cover at a Maintain range of sub‐communities with typical species listed composition: representative in Saltmarsh Monitoring Project (McCorry and Ryle, 2009) typical species and sample sub‐communities of monitoring stops Vegetation Hectares No significant expansion of common cordgrass (Spartina structure: negative anglica), with an annual spread of less than 1% indicator species‐ Spartina anglica

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Figure 9 Distribution of saltmarsh habitats within the Lower River Shannon cSAC (NPWS, 2012a)

A review of habitat mapping and the coastal habitats supporting document available for the SAC determined that of the ten sub-sites surveyed, mapped and assessed as part of the Saltmarsh Monitoring Project (McCorry & Ryle, 2009) the closest site to the proposal site where ASM habitat is mapped as occurring is the ‘Bunratty’ sub-site (SMP 0081)(NPWS, 2012a). Bunratty saltmarsh is located in the upper part of the Shannon Estuary in Co. Clare, approximately 2.8km east of the proposal area. Within the sub-site, ASM is the most extensive of all the saltmarsh habitats, estimated to measure approximately 27ha. Typically it occurs within this sub-site as a narrow band at the landward side of the brackish vegetation. However, potential ASM is mapped as occurring along the shoreline extending westwards from this area as far as and immediately adjacent to the northern extent of the East Embankment (NPWS, 2012a).

During habitat surveys undertaken for the proposed works in 2019 a previously mapped area of potential Atlantic Salt Meadow ASM (1330) located to the north-east of the eastern embankment was found to be dominated by reed and large sedge swamp (FS1) along and immediately out from the embankment. However, two small areas of Upper salt-marsh (CM2) corresponding to Annex I ‘Atlantic salt meadow’ were identified to the south of this area, immediately adjacent to the East Embankment towards its northern end.

7.1.3.5 Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho- Batrachion vegetation [3260] This habitat-type, commonly known as ‘Vegetation of flowing waters’, is typically characterised by species of water-crowfoot (Ranunculus spp.), pondweeds (Potamogeton spp.) and the moss Fontinalius antipyretica and is present throughout the major river systems within the SAC. Although the full distribution of this habitat and its sub-types within the SAC is currently unknown, it will occur in most watercourses in Ireland. The highest riverine conservation interest is associated with

19986-6002-D Natura Impact Statement June 2020 lowland depositing and tidal rivers and unmodified, fast-flowing, low-nutrient rivers. River connectivity with the floodplain is essential for the functioning of this habitat.

A number of rare submerged and marginal species are found in the former including opposite-leaved pondweed (Groenlandia densa), starworts (e.g. Callitriche truncata), triangular club-rush (Schoenoplectus triqueter), needle spike rush (Eleocharis acicularis) and mud-dwelling mosses (e.g. Ephemerum spp.) (NPWS, 2019a). Review of the available data identifies three high conservation elements (sub-types) in the site, namely:

1. Groenlandia densa (L.) Fourr., Opposite-leaved Pondweed; 2. Schoenoplectus triqueter (L.) Palla, Triangular Club-rush; 3. Bryophyte-rich streams and rivers.

The sub-types of this habitat are poorly understood and their typical species have not yet been defined. The typical species may include higher plants, bryophytes, macroalgae, and microalgae. The first two sub-types are associated with tidal reaches of rivers, while the latter sub-type is found in fast-flowing stretches of unmodified streams and rivers. In addition to these three sub-types, it is likely that other high conservation value sub-types exist within the site (NPWS, 2012a).

Table 16 Attributes and targets for ‘Vegetation of flowing waters’ within the Lower River Shannon cSAC (NPWS, 2012a) Attribute Measure Target/Notes Habitat area Kilometres Area stable or increasing, subject to natural processes. Three sub‐types of high conservation value are known to occur in the site Habitat distribution Occurrence No decline, subject to natural processes. Hydrological regime: Metres per Maintain appropriate hydrological regimes river flow second Hydrological regime: Daily water Maintain natural tidal regime tidal influence level fluctuations ‐ metres Hydrological regime: Metres per Maintain appropriate freshwater seepage regimes freshwater seepages second Substratum Millimetres The substratum should be dominated by the particle size ranges, composition: appropriate to the habitat sub‐type (frequently sands, gravels and particle size range cobbles) Water quality: Milligrammes The concentration of nutrients in the water column should be nutrients per litre sufficiently low to prevent changes in species composition or habitat condition. The specific targets may vary among sub‐ types Vegetation Occurrence Typical species of the relevant habitat sub‐type should be present composition: and in good condition typical species

Floodplain Area The area of active floodplain at and upstream of the habitat should connectivity be maintained Riparian habitat Area The area of riparian woodland at and upstream of the bryophyte‐rich sub‐type should be maintained

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Shannon Airport Embankments

Figure 10 Distribution of floating river vegetation within the Lower River Shannon cSAC (NPWS, 2012a)

The current conservation status of floating river vegetation is considered ‘Inadequate’ (NPWS, 2019a). Conservation objectives are to maintain the favourable conservation condition of ‘Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation’ in the Lower River Shannon cSAC, as defined by the following attributes and targets.

In Ireland, the Groenlandia densa sub-type is associated with tidal reaches of rivers and other periodically disturbed watercourses (e.g. canals and drains) (NPWS, 2012a). Groenlandia densa was identified within a drainage channel associated with the Shannon Airport Lagoon during habitat surveys carried out on-site.

7.1.3.6 Otter [1355] Otters are found in a variety of aquatic habitats in Ireland such as lakes, rivers, streams, estuaries, marshland, and canals and along the coast. Their preferred habitat has good cover of vegetation, such as scrub with a herbaceous under layer. Because otters are mainly nocturnal they require access to safe refuges to use as denning sites, known as holts, within which they remain for most of the day. Holts are the main den locations used by otters and these are most commonly situated underground along a river’s bank or among the root systems of trees. Several holts will be located within an individual’s territory and lying up sites known as couches will also be used at ground level within vegetated areas. In freshwater areas, a variety of fish from sticklebacks to salmon and eels will be taken, while crayfish and frogs can be important locally or seasonally.

Otters maintain territories and will defend their stretches of river bank or lake shore from other individuals. Territories are only held against members of the same sex, so those of males and females may overlap (Erlinge, 1968). In lowland rivers and fish-rich lakes, otters only need to

19986-6002-D Natura Impact Statement June 2020 maintain small territories. The breeding season is variable, with a peak of births from May to August – though cubs may be born at any time of year.

While no otter holts were identified along the stretch of the Shannon River Estuary within 50m of the proposed development site, results of the ecological field survey (see Section 5.6 above) indicated that otters may potentially utilise habitats in the vicinity of the proposed development site due to their suitability for this species. The shoreline in the general area of the proposal site and extending along the banks of the Shannon River, and of islands in the main channel, is mapped as ‘commuting buffer’ within the Conservation Objectives for the Lower River Shannon cSAC (NPWS, 2012a).

The current conservation status of otter is considered ‘Favourable’ (NPWS, 2012b). Conservation objectives are to restore the favourable conservation condition of ‘Otter’ in the Lower River Shannon cSAC (only in fresh water), as defined by the following attributes and targets:

Table 17 Attributes and targets of otter within the Lower River Shannon cSAC (NPWS, 2012a) Attribute Measure Target/Notes Distribution Percentage positive No significant decline survey sites Extent of Hectares No significant decline. Area mapped and calculated as 596.8ha terrestrial habitat above high water mark (HWM); 958.9ha along river banks/ around ponds. No field survey. Areas mapped to include 10m terrestrial buffer along shoreline (above HWM and along river banks) identified as critical for otters Extent of marine Hectares No significant decline. Area mapped and calculated as 4,461.6ha. habitat No field survey. Area mapped based on evidence that otters tend to forage within 80m of the shoreline (HWM) Extent of Kilometres No significant decline. Length mapped and calculated as 500.1km. freshwater (river) No field survey. River length calculated on the basis that otters will habitat utilise freshwater habitats from estuary to headwaters Extent of Hectares No significant decline. Area mapped and calculated as 125.6ha. No freshwater field survey. Area mapped based on evidence that otters tend to (lake/lagoon) forage within 80m of the shoreline habitat Couching sites Number No significant decline. Otters need lying up areas throughout their and holts territory where they are secure from disturbance Fish biomass Kilograms No significant decline. Broad diet that varies locally and seasonally, available but dominated by fish, in particular salmonids, eels and sticklebacks in freshwater and wrasse and rockling in coastal waters Barriers to Number No significant increase. Otters will regularly commute across connectivity stretches of open water up to 500m. E.g. between the mainland and an island; between two islands; across an estuary. It is important that such commuting routes are not obstructed

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Shannon Airport Embankments

Figure 11 Extent of mapped ‘commuting buffer’ for otter within the Lower River Shannon cSAC (NPWS, 2012a)

7.2 RIVER SHANNON AND RIVER FERGUS ESTUARIES SPA (004077)

7.2.1 Description of the Natura 2000 Site The estuaries of the River Shannon and River Fergus form the largest estuarine complex in Ireland. The site comprises the entire estuarine habitat from Limerick City westwards as far as Doonaha in Co. Clare and Dooneen Point in Co. Kerry. The site has vast expanses of intertidal flats which contain a diverse macro-invertebrate community, e.g. Macoma-Scrobicularia-Nereis, which provides a rich food resource for the wintering birds. Salt marsh vegetation frequently fringes the mudflats and this provides important high tide roost areas for the wintering birds. Elsewhere in the site the shoreline comprises stony or shingle beaches.

The site is selected as a Special Protection Area because it regularly supports over 20,000 waterbirds during the non-breeding season making this a site of international importance. The site regularly supports in excess of 50,000 wintering waterfowl (57,133 - five year mean for the period 1995/96 to 1999/2000) making it one of the most important coastal sites in the country. The E.U. Birds Directive pays particular attention to wetlands and, as these form part of this SPA, the site and its associated waterbirds are of special conservation interest for Wetland & Waterbirds. The site holds internationally important populations of three species, namely dunlin (C. alpina), light bellied Brent goose (B. bernicla hrota) and whooper swan (C. cygnus)(I-WeBS: Waterbird Monitoring 2015/16). The remaining 18 species have populations of national importance. The site previously supported an internationally-important population of black-tailed godwit (L. limosa), now listed as nationally-

19986-6002-D Natura Impact Statement June 2020 important27. Of particular note is that three of the species which occur regularly are listed on Annex I of the E.U. Birds Directive, i.e. whooper swan, golden plover and bar-tailed godwit.

This is the most important coastal site in Ireland for a number of the waders including lapwing, dunlin, snipe and redshank. It also provides an important staging ground for species such as black- tailed godwit and greenshank. The site also supports a nationally important breeding population of cormorant (93 pairs in 2010). Other species that occur include mute swan, mallard, red-breasted merganser, great-crested grebe, grey heron, oystercatcher, turnstone and common gull. Apart from the wintering birds, large numbers of some species also pass through the site whilst on migration in spring and/or autumn (adapted from River Shannon and River Fergus Estuaries SPA 004077 Site Synopsis). This site is a designated Special Protection Area (SPA) under the E.U. Birds Directive for the special conservation interest of the following features of interest:

• Cormorant (Phalacrocorax carbo) [A017] • Whooper Swan (Cygnus cygnus) [A038] • Light-bellied Brent Goose (Branta bernicla hrota) [A046] • Shelduck (Tadorna tadorna) [A048] • Wigeon (Anas penelope) [A050] • Teal (Anas crecca) [A052] • Pintail (Anas acuta) [A054] • Shoveler (Anas clypeata) [A056] • Scaup (Aythya marila) [A062] • Ringed Plover (Charadrius hiaticula) [A137] • Golden Plover (Pluvialis apricaria) [A140] • Grey Plover (Pluvialis squatarola) [A141] • Lapwing (Vanellus vanellus) [A142] • Knot (Calidris canutus) [A143] • Dunlin (Calidris alpina) [A149] • Black-tailed Godwit (Limosa limosa) [A156] • Bar-tailed Godwit (Limosa lapponica) [A157] • Curlew (Numenius arquata) [A160] • Redshank (Tringa totanus) [A162] • Greenshank (Tringa nebularia) [A164] • Black-headed Gull (Chroicocephalus ridibundus) [A179] • Wetland and Waterbirds [A999]

Species vary considerably in different aspects of their ecology with regards to trophic (foraging) guild, food/prey requirements, principal supporting habitat within the site, ability to use alternative habitats within the site and site fidelity/faithfulness (NPWS, 2012b). Species will vary in this use of habitats within a site. This may vary between times of day, seasons and between different sites. The following table outlines the ecological characteristics, requirements and specialities for non- breeding waterbird SCIs within the River Shannon and River Fergus Estuaries SPA (table adapted from NPWS, 2012b).

27 https://birdwatchireland.ie/app/uploads/2019/03/2015-16-I-WeBS-Report-Final.pdf [Accessed 03/09/2019] 67

19986-6002-B Natura Impact Statement December 2019

Table 18 Ecological Characteristics, requirements and specialities of non-breeding waterbird SCI species for River Shannon and River Fergus Estuaries SPA28 Trophic Food Prey Ability to use alternative Species DistributionA Principal Habitat within siteD GuildB RequirementsC habitatsE Bar-tailed godwit Localised 4 Wide Intertidal mud/sand flats 2 Black-headed gull N/C 1,2,4,6,7 Wide Intertidal flats and shallow and sheltered subtidal 2 Black-tailed godwit Localised 4 Wide Intertidal mud/sand flats 2 Cormorant Widespread 3 Highly specialised Sheltered and shallow subtidal 1 Curlew Widespread 4 Wide Intertidal mud/sand flats 2 Dunlin Intermediate 4 Wide Intertidal mud/sand flats 3 Golden plover Intermediate 4 Wide Intertidal mud/sand flats 2 Green shank Intermediate 6 Wide Intertidal mud/sand flats 3 Grey plover Localised 4 Wide Intertidal mud/sand flats 3 Knot Localised 4 Narrower Intertidal mud/sand flats 3 lapwing Widespread 4 Wide Intertidal mud/sand flats 2 Light-bellied Brent Goose Localised 1,5,7 Highly specialised Intertidal mud/sand flats 2 Red shank Intermediate 4 Wide Intertidal flats and sheltered shallow subtidal 2 Ringed Plover Localised 4 Wide Intertidal mud/sand flats 3 Pintail Localised 1 Wide Intertidal mud/sand flats, sheltered and shallow subtidal 2 Scaup Highly Restricted 2 Wide Subtidal 1 Shelduck Localised 1,5 Wide Intertidal mud/sand flats, shallow subtidal 3 Shoveler Localised 1 Wide Lagoon, brackish and freshwater lakes, plus intertidal sand and mud flats 3 Teal Widespread 1 Wide Intertidal mud/sand flats, shallow subtidal and lagoons 3 Whooper Swan Widespread 1,7 Wide Lagoon and associated habitats, intertidal mudflats and shallow subtidal 2 Wigeon Widespread 1,5 Narrower Intertidal mud/sand flats, sheltered and shallow subtidal lagoons 2 A: Distribution – Very Widespread (>300 sites), Widespread (200-300 sites), Intermediate (100-200 sites), Localised (50-100 sites), Highly Restricted (<50 sites) (based on Boland & Crowe, 2012). B: Trophic Guild – 1= surface swimmer, 2= water column diver (Shallow), 3= water column diver (deeper), 4/5= Intertidal walker (out of water), 6= Intertidal walker (in water), 7= terrestrial walker C: Food/Prey Requirements – species with a wide prey/food range, a narrow prey range (e.g. a species that forage upon a few species/taxa only), and species with highly specialised foraging requirements (e.g. piscivores). D: Principal Supporting Habitat present within the SPA (Note that this is the main habitat used when foraging with the exception of Whooper Swan that utilise wetland habitats for roosting and forage within terrestrial grasslands outside of the SPA). E: Ability to Use Alternative Habitat – refers to the species ability to utilise other habitats adjacent to the site: 1= wide-ranging species, 2= reliant on site but highly likely to use alternative habitat at certain times (e.g. high tide), 3= considered totally reliant on wetland habitats due to unsuitable surrounding habitats and/or species limited by habitat requirements. F: Site fidelity on non-breeding grounds: Unknown; Weak; Moderate; or High.

28 https://www.npws.ie/sites/default/files/publications/pdf/004077RiverShannonandRiverFergusEstuariesSPASupportingDoc_V1.pdf

19986-6002-D Natura Impact Statement June 2020

7.2.2 Identification of Potential for Significant Impacts to Qualifying Features Bearing in mind the scope, scale, nature and size of the project, its location relative to the distribution of the species and habitats listed and the degree of connectedness that exists between the project and the potential receptors, it is considered that not all features of interest are within the zone of potential impact of the proposal. An evaluation based on these factors to determine which species and habitats are the plausible ecological receptors for potential impacts of the unmitigated proposal has been conducted below.

The following table lists the qualifying features of the River Shannon and River Fergus Estuaries SPA and evaluates through a scientific examination of evidence and data whether or not these features should or should not be selected for further assessment in the NIS. The qualifying features that are selected for further assessment are then discussed further followed by an assessment of potentially significant effects arising from the proposed development.

Table 19 Identification of potential for significant impacts to qualifying features of the River Shannon & Fergus River Estuaries SPA Qualifying Feature Potential Rationale for Significant Impacts Cormorant Yes A review of waterbird distribution for SCI species within the SPA carried (Phalacrocorax out as part of the sub-site assessments for the 2010/11 Waterbird carbo) Survey Programme, as outlined in NPWS (2012b) determined that cormorant was recorded within the vicinity of the proposal site (0H511, 0H512). Based on this, this species is considered to be within the zone of potential influence of the proposal and will be considered further in the NIS. Whooper swan Yes Relatively few intertidal/sub-tidal observations of whooper swan were (Cygnus cygnus) made during the 2010/11 surveys (no records of foraging whooper swan within the vicinity of the proposal site). Whooper swan were recorded roosting at Shannon Airport Lagoon (0H509) in October 2011. Shannon Airport Lagoon has been noted previously as a regularly-used site during autumn (Robinson et al. 2004a). A review of waterbird distribution for SCI species within the SPA carried out as part of the sub-site assessments for the 2010/11 Waterbird Survey Programme, as outlined in NPWS (2012b) determined that whooper swan was recorded within the vicinity of the proposal site (0H509). Based on this, this species is considered to be within the zone of potential influence of the proposal and will be considered further in the NIS. Light-bellied brent No The site is designated for wintering light-bellied Brent goose. This goose (Branta species is amber-listed as the majority winter at less than ten sites and bernicla hrota) the Irish population is also internationally significant. It winters on coastal estuaries during the autumn and early winter as well as on grasslands from mid-winter before departing to breeding grounds in Canada in late April. Brent Geese are grazers and are known for their preference for foraging in intertidal areas with the Eelgrass Zostera sp. (Robinson et al. 2004b). Where this food source is absent the birds feed

19986-6002-D Natura Impact Statement June 2020

Qualifying Feature Potential Rationale for Significant Impacts upon algae and saltmarsh plants and the species also grazes terrestrially.

A review of waterbird distribution for SCI species within the SPA carried out as part of the sub-site assessments for the 2010/11 Waterbird Survey Programme, as outlined in NPWS (2012b), determined that Brent geese exhibited a relatively restricted distribution occurring in only seven sub-sites, and were associated mostly with the outer section of the site. There were no records of foraging or roosting Brent Geese within the vicinity of the proposal site. Based on this, this species is not considered to be within the zone of potential influence of the proposal and will not be considered further in the NIS. Shelduck (Tadorna Yes A review of waterbird distribution for SCI species within the SPA carried tadorna) out as part of the sub-site assessments for the 2010/11 Waterbird Survey Programme, as outlined in NPWS (2012b) determined that shelduck was recorded within the vicinity of the proposal site (0H510, 0H511, 0H512). Based on this, this species is considered to be within the zone of potential influence of the proposal and will be considered further in the NIS. Wigeon (Anas Yes A review of waterbird distribution for SCI species within the SPA carried penelope) out as part of the sub-site assessments for the 2010/11 Waterbird Survey Programme, as outlined in NPWS (2012b) determined that wigeon was recorded within the vicinity of the proposal site (0H509 – including birds foraging at the Shannon Airport Lagoon, 0H511, 0H510, 0H512). Based on this, this species is considered to be within the zone of potential influence of the proposal and will be considered further in the NIS. Teal (Anas crecca) Yes A review of waterbird distribution for SCI species within the SPA carried out as part of the sub-site assessments for the 2010/11 Waterbird Survey Programme, as outlined in NPWS (2012b) determined that teal was recorded within the vicinity of the proposal site (0H509 – including birds foraging at the Shannon Airport Lagoon, 0H512). Based on this, this species is considered to be within the zone of potential influence of the proposal and will be considered further in the NIS. Pintail (Anas acuta) No Pintail is red-listed due to a decline in its non-breeding (wintering) population. It is an extremely rare breeding species with records from the Midlands and north (Dempsey and O’ Cleary, 2002). Wintering takes places primarily within estuaries or coastal brackish lagoons. Pintail feed on a variety of plant and animal material obtained from shallow water although they can be observed foraging on land.

A review of waterbird distribution for SCI species within the SPA carried out as part of the sub-site assessments for the 2010/11 Waterbird Survey Programme, as outlined in NPWS (2012b) determined that pintail was recorded in only two sub-sites: 0H519 (Poulnasherry outer bay) and 0K509 (Carrig Island), both in the outer section of the site. Pintail populations were not recorded in the Inner Shannon River

19986-6002-D Natura Impact Statement June 2020

Qualifying Feature Potential Rationale for Significant Impacts Estuary during the winter Low Tide Counts (2010) There was no record of this species during IWeBS counts for the species in the lagoon between the 2013/2014 and 2019/2020 seasons save 2016/17 (peak count = 2), or at subsites containing/adjacent to the proposed development by MKO (2019). Based on this, this species is not considered to be within the zone of potential influence of the proposal and will not be considered further in the NIS. Shoveler (Anas Yes A review of waterbird distribution for SCI species within the SPA carried clypeata) out as part of the sub-site assessments for the 2010/11 Waterbird Survey Programme, as outlined in NPWS (2012b) determined that shoveler was recorded in six sub-sites overall including 0H509 (otherwise known as Shannon Airport Lagoon), where peak numbers were recorded during low tide surveys. Shoveler was also recorded here during high tide surveys. Low numbers of shoveler in roosting/other behaviour were also recorded within 0H509 (Shannon Airport Lagoon). Based on this, this species is considered to be within the zone of potential influence of the proposal and will be considered further in the NIS. Scaup (Aythya No Scaup are a winter visitor to Ireland, arriving from breeding sites to the marila) north between November and April to coastal areas, estuaries, brackish lagoons and freshwater lakes close to the coast. They forage in subtidal areas, diving to hunt for molluscs and crustaceans as well as feeding on marine plants in areas typically with a depth of less than 10m. Scaup is amber-listed for its small breeding population and its localised wintering range.

This species was not recorded in the area containing or surrounding the proposed works (MKO, 2019). There has been no record of this species during IWeBS counts for the species in the lagoon from 2012/2013.

A review of waterbird distribution for SCI species within the SPA carried out as part of the sub-site assessments for the 2010/11 Waterbird Survey Programme, as outlined in NPWS (2012b) determined that scaup was recorded in only three sub-sites: 0H519 (Poulnasherry outer bay), 0H521 (Clonderlaw Bay outer) and 0H522 (Clonderlaw Bay inner). Based on this, this species is not considered to be within the zone of potential influence of the proposal and will not be considered further in the NIS. Ringed plover No Ringed plovers are ‘visual foragers’ searching the sediment surface for (Charadrius the visible signs of prey such as worms, crustaceans and insects. A hiaticula) substantial proportion of ringed plovers occur on non-estuarine coasts, the species exhibiting a degree of plasticity in habitat choice and being found in habitats such as shingle shores, saltmarsh and short grassland as well as artificial habitats. Ringed plover is amber-listed as internationally important numbers winter in Ireland. They breed on shingle and sandy beaches (Dempsey and O’Cleary, 2002) and rough ground around the coast. They are found in the outer estuary on

19986-6002-D Natura Impact Statement June 2020

Qualifying Feature Potential Rationale for Significant Impacts intertidal mudflats.

A review of waterbird distribution for SCI species within the SPA carried out as part of the sub-site assessments for the 2010/11 Waterbird Survey Programme, as outlined in NPWS (2012b) determined that ringed plover was not recorded anywhere in the vicinity of the proposal site. There has been no record of this species during IWeBS counts for the species in the lagoon from 2012/2013. Based on this, this species is not considered to be within the zone of potential influence of the proposal and will not be considered further in the NIS. Golden plover Yes A review of waterbird distribution for SCI species within the SPA carried (Pluvialis apricaria) out as part of the sub-site assessments for the 2010/11 Waterbird Survey Programme, as outlined in NPWS (2012b) determined that golden plover was recorded regularly (three low tide surveys or more) within 12 sub-sites including 0H512 (Connor's Rock), where significant numbers (>1500 individuals) were recorded. Based on this, this species is considered to be within the zone of potential influence of the proposal and will be considered further in the NIS. Grey plover (Pluvialis Yes A review of waterbird distribution for SCI species within the SPA carried squatarola) out as part of the sub-site assessments for the 2010/11 Waterbird Survey Programme, as outlined in NPWS (2012b) determined that grey plover was recorded regularly (three low tide surveys or more) within 0H510. The February 2011 roost survey recorded birds in 0H511 (Rinnanna South) in the inner estuary. Supratidal roosting was recorded in 0H512 (Connor's Rock). Based on this, this species is considered to be within the zone of potential influence of the proposal and will be considered further in the NIS. Lapwing (Vanellus Yes A review of waterbird distribution for SCI species within the SPA carried vanellus) out as part of the sub-site assessments for the 2010/11 Waterbird Survey Programme, as outlined in NPWS (2012b) determined that lapwing was regularly recorded foraging inter-tidally in 0H512 (Connor's Rock). This sub-site also supported roosting birds. Lapwings were also recorded in 0H510 and 0H511. Based on this, this species is considered to be within the zone of potential influence of the proposal and will be considered further in the NIS. Knot (Calidris Yes A review of waterbird distribution for SCI species within the SPA carried canutus) out as part of the sub-site assessments for the 2010/11 Waterbird Survey Programme, as outlined in NPWS (2012b) determined that knot was recorded in the sub-sites 0H510, 0H511 and 0H512. Based on this, this species is considered to be within the zone of potential influence of the proposal and will be considered further in the NIS. Dunlin (Calidris Yes A review of waterbird distribution for SCI species within the SPA carried alpina) out as part of the sub-site assessments for the 2010/11 Waterbird Survey Programme, as outlined in NPWS (2012 4077 CO supp doc) suggest that dunlin have a widespread foraging distribution across the site and as a versatile species, they are likely to exploit a variety of

19986-6002-D Natura Impact Statement June 2020

Qualifying Feature Potential Rationale for Significant Impacts intertidal food resources. Dunlin was found to occur regularly during low tide surveys within sub-sites 0H510 and 0H512. Dunlin was also recorded in 0H511. Based on this, this species is considered to be within the zone of potential influence of the proposal and will be considered further in the NIS. Black-tailed godwit Yes A review of waterbird distribution for SCI species within the SPA carried (Limosa limosa) out as part of the sub-site assessments for the 2010/11 Waterbird Survey Programme, as outlined in NPWS (2012b) found that black- tailed godwits were relatively widespread in their distribution within the site. The species was found to occur in all four sub-sites in the vicinity of the works.

They were found to occur regularly within 0H510 (Brackinish Rock to Carrigkeal) with peak numbers recorded during low tide surveys. 0H512 (Connor’s Rock) held peak numbers during low tide surveys in October. 0H509 (Golf Tee- Shannon), otherwise known as Shannon Airport Lagoon, held 1,068 foraging individuals during the October 2010 low tide survey. Terrestrial foraging, outside of the SPA boundary, was not recorded regularly but is likely to be widespread around the site. Records of black-tailed godwits in roosting/other behaviour during low tide surveys were irregular (of note was the count of 2,400 roosting within 0H512 (Connor's Rock) on 21/10/10. Although relatively versatile in terms of habitat choice, black-tailed godwits are generally found in muddier sediments within inner estuaries, favouring biotopes that support favoured prey such as bivalves Macoma balthica, Scrobicularia plana or polychaete Hediste diversicolor. This is in agreement with the pattern of distribution noted above i.e. the preference for inner estuary sub-sites. Based on this, this species is considered to be within the zone of potential influence of the proposal and will be considered further in the NIS. Bar-tailed godwit No Bar-tailed godwits forage by probing within intertidal sediment for (Limosa lapponica) invertebrate species, predominantly large polychaete worms such as Arenicola marina and Nepthys sp. They often feed at the tide edge with their heads in water. The species is characteristic of sites with sandy substrates (e.g. Hill et al. 1993) or sections of a site that have sandy (as opposed to muddy) sediment. The dominant intertidal benthic community type across the site is ‘intertidal sand to mixed sediment with polychaetes, molluscs and crustaceans’ (NPWS, 2012b). This broad community type has a wide variability in sediment type from gravel to fine sand to muds. Of note are high abundances of Nephtys hombergii that occur from the lower Fergus Estuary westwards, this polychaete a known prey species of bar-tailed godwits. The bar-tailed godwit is amber-listed in Ireland as the majority winter at less than ten sites.

19986-6002-D Natura Impact Statement June 2020

Qualifying Feature Potential Rationale for Significant Impacts godwits to have a relatively restricted foraging distribution within the site. They were not recorded in any of the sub-sites in the vicinity of the proposal site. Based on this, this species is not considered to be within the zone of potential influence of the proposal and will not be considered further in the NIS. Curlew (Numenius Yes A review of waterbird distribution for SCI species within the SPA carried arquata) out as part of the sub-site assessments for the 2010/11 Waterbird Survey Programme, as outlined in NPWS (2012b) found that curlew exhibited a widespread foraging distribution across the site. Curlews were recorded in the sub-sites 0H510, 0H511 and 0H512. Based on this, this species is considered to be within the zone of potential influence of the proposal and will be considered further in the NIS. Redshank (Tringa Yes A review of waterbird distribution for SCI species within the SPA carried totanus) out as part of the sub-site assessments for the 2010/11 Waterbird Survey Programme, as outlined in NPWS (2012b) found that redshank to be widespread within the site. Redshanks were recorded roosting in the sub-site 0H511 (Rinnanna South) where a single intertidal roost of 90 individuals was recorded. Redshanks were recorded regularly (three or more low tide surveys) in 0H512. Redshank was also recorded in 0H510. Based on this, this species is considered to be within the zone of potential influence of the proposal and will be considered further in the NIS. Greenshank (Tringa Yes A review of waterbird distribution for SCI species within the SPA carried nebularia) out as part of the sub-site assessments for the 2010/11 Waterbird Survey Programme, as outlined in NPWS (2012b) determined that greenshank were recorded in the sub-site 0H512. Based on this, this species is considered to be within the zone of potential influence of the proposal and will be considered further in the NIS. Black-headed gull Yes A review of waterbird distribution for SCI species within the SPA carried (Chroicocephalus out as part of the sub-site assessments for the 2010/11 Waterbird ridibundus) Survey Programme, as outlined in NPWS (2012b) determined that black-headed gull was recorded in all four sub-sites in the vicinity of the works (0H509, 0H510, 0H511 and 0H512). Based on this, this species is considered to be within the zone of potential influence of the proposal and will be considered further in the NIS. Wetlands & Yes The River Shannon and River Fergus Estuaries SPA is designated for the waterbirds protection of ‘Wetlands’. The proposed works will result in an increase in the overall footprint of both embankments. There is spatial overlap between the proposal site and the SPA. Therefore, there is potential for direct/indirect impacts to wetland habitat within the River Shannon and River Fergus Estuaries SPA, and as such ‘Wetlands’ will be considered further in the NIS.

19986-6002-D Natura Impact Statement June 2020

7.2.3 Qualifying Features Selected for Further Assessment 7.2.3.1 Cormorant (Phalacrocorax carbo) Cormorant is a resident species in Ireland occurring along the coast and breeding in colonies mainly on off-shore islands and rocky coast-lines although there are some inland breeding populations. This diving species feeds on fish, foraging mainly in shallow waters (<30m depth) and may roost in intertidal or supra-tidal areas. The species is amber-listed in Ireland due to a localised breeding population. Cormorant is the only qualifying species with a breeding population within the River Shannon and River Fergus Estuaries SPA (NPWS, 2012b).

Conservation objectives are to maintain the favourable conservation condition of ‘Cormorant’ in the River Shannon and River Fergus Estuaries SPA, as defined by the following attributes and targets.

Table 20 Attributes and targets of cormorant in the River Shannon and River Fergus estuaries SPA (NPWS, 2012b) Attribute Measure Target/Notes Breeding population Number No significant decline. abundance: apparently occupied nest (AONs) Productivity rate Mean number No significant decline. Distribution: breeding colonies Number, location, No significant decline. area (hectares) Prey biomass available Kilograms No significant decline. Barriers to connectivity Number, location, No significant increase. shape, area (hectares) Disturbance at breeding site Level of impact Human activities should occur at levels that do not adversely affect the breeding cormorant population Population trend Percentage change Long term population trend stable or increasing Distribution Range, timing and There should be no significant decrease in the intensity of use of range, timing or intensity of use of areas by areas cormorant other than that occurring from natural patterns of variation

7.2.3.2 Whooper swan (Cygnus cygnus) The site is designated for wintering whooper swan that visits lakes and marshes and can be found grazing in fields and slob lands. Birds arrive in Ireland in late autumn and leave by mid-April and a few may remain throughout the summer (Dempsey and O’Cleary, 2002). Whooper swan tends to congregate at discrete and safe wetland sites during the evening to roost, and disperse by day to forage. They are primarily herbivorous, feeding on aquatic plants, grasses and agricultural plants such as grain, vegetables and stubble. Whooper swans that spend the winter at the Shannon and Fergus estuaries complex forage primarily outside of the SPA boundary NPWS (2012b). Whooper swan is amber-listed as Ireland hosts more than 20% of the European wintering population.

7.2.3.3 Shelduck (Tadorna tadorna) Shelduck is amber-listed in Ireland as the majority of the wintering population occurs at less than ten sites. Shelduck nest on islands and grassy embankments of the estuary. In July the adults depart to

19986-6002-D Natura Impact Statement June 2020 the Waddenzee to moult returning to the Shannon Estuary in November. Shelduck forage in a variety of ways from scything their bill through wet mud on exposed tidal flats, to dabbling and scything in shallow water and up-ending in deeper waters. They can therefore forage throughout the tidal cycle. The benthic community of the Fergus Estuary and Poulnasherry Bay is assigned the broad classification ‘Intertidal sand to mixed sediment with polychaetes, molluscs and crustaceans’ (NPWS, 2012b). The gastropod mollusc Hydrobia ulvae, a favoured prey of shelduck, is a distinguishing invertebrate of this community, occurring in moderate to high abundances.

7.2.3.4 Wigeon (Anas penelope) Wigeon is red-listed due to a decline in its non-breeding (wintering) population. Wigeon are highly- migratory, arriving to Ireland in August/September and wintering in ponds and flooded fields around the estuary .Their diet is almost entirely vegetarian and a major part of the diet comprises seagrass and algae species which are taken by grazing or dabbling in shallow water. Wigeon also forage within grasslands and agricultural crops for seeds, stems and rhizomes. A gregarious bird, they are rarely seen far from water.

7.2.3.5 Teal (Anas crecca) Teal are largely migratory, moving south of their breeding range during winter. Being highly responsive to cold spells they can show rapid and extensive movement during these periods. Teal is amber-listed due to a decline in the breeding population. Teal is a very common winter visitor to the estuary. They are omnivorous and have a variety of foraging methods (e.g. dabbling and up-ending) within differing habitats. Areas of shallow water are favoured including shallow estuaries, tidal creeks and the edges of salt and freshwater marsh.

7.2.3.6 Shoveler (Anas clypeata) The small numbers of shoveler breeding in Ireland are largely sedentary or dispersive and are supplemented during winter by migratory birds from other locations within northwest and central Europe. Shovelers are omnivorous, taking a range of items from planktonic crustaceans and small molluscs, to insects, larvae, plant material and seeds. A true dabbling duck, shovelers feed by surface-feeding, swimming with head and neck immersed, up-ending, and less often, by shallow dives. Shoveler is red-listed due to a decline in its non-breeding (wintering) population.

7.2.3.7 Golden plover (Pluvialis apricaria) During winter, golden plovers feed primarily within agricultural grassland and arable land. Tidal flats are used more as a roosting/resting habitat and the birds tend to favour large, open tidal flats. As a consequence, golden plovers tend to be in large aggregations when observed upon tidal flats. Intertidal feeding is observed to a greater degree during cold weather periods when grassland feeding areas are frozen over. Although golden plovers eat a wide range of invertebrate species, relatively little is known about intertidal feeding patterns (Gillings et al. 2006). Golden plover is red- listed as a breeding species due to a decline in the breeding and non-breeding (wintering) population.

7.2.3.8 Grey plover (Pluvialis squatarola) Grey plovers forage intertidally and have a characteristic mode of foraging whereby they stand motionless watching the mudflat surface before snatching a prey item (often a worm) from the sediment surface. Grey plovers take a wide range of prey species including lugworms (Arenicola

19986-6002-D Natura Impact Statement June 2020 marina), ragworms (Hediste diversicolor), amphipod crustaceans and small bivalves (e.g. Macoma balthica and Scrobicularia plana). A degree of sub-site preference is therefore evident although the sub-sites favoured are not clustered and occur in both the inner and outer site. The benthic community of sub-sites used by grey plovers is classified as ‘intertidal sand to mixed sediment with polychaetes, molluscs and crustaceans’ (NPWS, 2012b). This broad community type has a wide variability in sediment type from gravel to fine sand to muds. Grey plover is amber-listed as the majority winter at less than ten sites in Ireland.

7.2.3.9 Lapwing (Vanellus vanellus) Lapwings are traditionally ‘inland’ waders. During winter they can be observed across a wide variety of habitats, principally using lowland farmland and freshwater wetlands (e.g. turloughs and callows) but also coastal wetlands where they feed on a variety of soil and surface-living invertebrates. They are opportunistic and mobile birds and will readily exploit temporary food sources such as newly- ploughed fields. Estuaries are typically used as roosting areas where large flocks may be observed upon the tidal flats. Coastal habitats tend to be used more during cold weather events when farmland and freshwater habitats freeze over. Lapwing is red-listed due to a decline in the breeding and non-breeding population.

7.2.3.10 Knot (Calidris canutus) During the winter knots are coastal in their distribution with preferred sites mainly comprising estuaries with extensive mudflats. They are specialist foragers of molluscs and crustaceans in intertidal areas, being particularly adapted to hunt prey buried in the substrate. The preferred prey items are bivalve molluscs including Scrobicularia plana, Macoma balthica and Mytilus edulis of smaller size-classes. Although knot was red-listed in Ireland the wintering population has increased in recent times and as such knot has now been re-assigned as amber-listed.

7.2.3.11 Dunlin (Calidris alpina) Dunlin is a common wader along Irish coasts. Wintering populations favour coastal areas such as estuaries and mudflats with the population peaking in mid-winter. They tend in feed in groups on mudflats, often at the water’s edge, taking a variety of prey including molluscs, crustaceans and worms. Dunlin is widespread within the site favouring inter-tidal foraging areas. Dunlin is amber- listed in Ireland as the majority winter at less than ten sites.

7.2.3.12 Black-tailed godwit (Limosa limosa) Black-tailed godwits are large long-billed wading birds that forage within intertidal flats for their preferred prey of bivalves such as Macoma balthica, Scrobicularia plana and Mya arenaria. At some sites, polychaete worms form a larger proportion of the diet and the species is relatively adaptable, utilising other habitats for foraging where available, such as terrestrial grassland, coastal marshes or freshwater callows. Black-tailed godwit is amber-listed in Ireland as the majority winter at less than ten sites.

7.2.3.13 Curlew (Numenius arquata) Curlews are the largest wader to spend the non-breeding season within Ireland. Within intertidal areas they seek out larger prey items such as crabs, large worms and bivalves and their de-curved bill is ideally suited to extracting deep-living worms such as Lugworms (Arenicola marina). Curlews also feed amongst damp grasslands where they take terrestrial worms. Ireland supports a small and

19986-6002-D Natura Impact Statement June 2020 declining population of breeding curlew. Irish breeding curlew are thought to make only short migrations, many are resident during winter. Wintering numbers are enhanced by birds moving in from breeding grounds. Curlew is red-listed due to a long-term decline in the breeding and wintering population and its breeding range. Curlews winter in the estuary and coastal grasslands and feed on intertidal mudflats. Numbers of curlew of all-Ireland importance were recorded in all but one of the surveys completed within the site.

7.2.3.14 Redshank (Tringa totanus) Redshank feed along the upper shore of estuaries and along muddy river channels. Redshanks forage mainly by pecking at the surface or probing within intertidal mudflats; often favouring the muddier sections of sites where they prey upon species such as the Ragworm Hediste diversicolor and Mud Snail Hydrobia ulvae. A particularly favoured prey is the burrowing amphipod Corophium volutator which occurs within the dominant intertidal benthic community type across the site ‘intertidal sand to mixed sediment with polychaetes, molluscs and crustaceans’ (NPWS, 2012b). Redshank is red-listed due to a long-term decline in its breeding population.

7.2.3.15 Greenshank (Tringa nebularia) Ireland supports a small population of greenshank during winter, mainly on estuaries with some occurring along non-estuarine coasts. Apart from certain times when they flock together (e.g. passage birds), greenshanks are generally widely distributed due to their territorial nature over their foraging patch; hence a relatively wide distribution is to be expected. Greenshanks usually forage within (wading) or beside watercourses where they exhibit a variety of feeding methods to take a diversity of prey including insects, polychaete worms and small fish. Greenshank is green-listed for its wintering population.

7.2.3.16 Black-headed gull (Chroicocephalus ridibundus) Black-headed gull is resident in Ireland throughout the year with winter numbers boosted by wintering individuals arriving from mainland Europe. The species over-winters and breeds in both coastal and inland locations, nesting in colonies in sand dunes, coastal islands, moorland polls, bogs and on freshwater lake islands. They take a wide variety of food items including fish, worms, molluscs, insects and plant material and are opportunistic feeders, taking advantage of any available food-source including domestic/fishing waste. They are widely-distributed within the SPA favouring inter-tidal foraging areas. Black-headed gull is red-listed due to a long term decline in its breeding population and distribution.

Conservation objectives are to maintain the favourable conservation condition of the above SCIs in the River Shannon and River Fergus Estuaries SPA, as follows:

 Whooper swan  Shelduck  Wigeon  Teal  Shoveler  Golden plover  Grey plover  Lapwing

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 Knot  Dunlin  Black-tailed godwit  Curlew  Redshank  Greenshank  Black-headed gull

The conservation objective, with regards to these SCIs is defined by the following attributes and targets:

Table 21 Attributes and targets for relevant SCIs in the River Shannon and River Fergus estuaries SPA (NPWS, 2012b) Qualifying Feature Attribute Measure Target/Notes Whooper swan Population Percentage change Long term population trend stable or Shelduck trend increasing Wigeon Teal Shoveler Golden plover Grey Plover Lapwing Distribution Range, timing and There should be no significant decrease Knot intensity of use of in the range, timing or intensity of use of Dunlin areas areas other than that occurring from Black-tailed godwit natural patterns of variation Curlew Redshank Greenshank Black-headed gull

7.2.3.17 Wetlands [A999] The wetland habitats contained within the River Shannon and River Fergus Estuaries SPA are identified to be of conservation importance for non-breeding (wintering) migratory waterbirds. Therefore the wetland habitats are considered to be an additional Special Conservation Interest.

Conservation objectives are to maintain the favourable conservation condition of the wetland habitat in the River Shannon and River Fergus Estuaries SPA as a resource for the regularly-occurring migratory waterbirds that utilise it, as defined by the following attributes and targets.

Table 22 Attributes and targets for wetlands in the River Shannon and River Fergus Estuaries SPA (NPWS, 2012b) Parameter Attribute Measure Target/Notes Area Wetland Area (ha) The permanent area occupied by the wetland habitat habitat should be stable and not significantly less than the area of 32,261 ha, other than that occurring from natural patterns of variation.

The boundary of the River Shannon and River Fergus Estuaries SPA was defined to include the primary wetland habitats of this expansive site. The wetland habitats can be categorised into five broad types: sub-tidal; inter-tidal; supra-tidal; lagoon and associated; and freshwater and associated. 79

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Over time and though natural variation these subcomponents of the overall wetland complex may vary due to factors such as changing rates of sedimentation, erosion etc. Many waterbird species will use more than one of the habitat types for different reasons throughout the tidal cycle NPWS, 2012b).

Sub-tidal areas refer to those areas contained within the SPA that lie below the mean low water mark and are predominantly covered by marine water. Tidal rivers, creeks and channels are included in this category. For the River Shannon and River Fergus Estuaries SPA this broad category is estimated to be 20,636 ha. Sub-tidal areas are continuously available for benthic feeding and dabbling ducks (e.g. Wigeon and Teal) and piscivorous/other waterbirds (e.g. Cormorant). Various waterbirds roost in sub-tidal areas.

The intertidal area is defined, in this context, as the area contained between the mean high water mark and the mean low watermark. For the River Shannon and River Fergus Estuaries SPA this is estimated to be 9,085 ha. When exposed or partially exposed by the tide, inter-tidal habitats provide important foraging areas for many species of waterbirds, particularly wading birds, as well as providing roosting/loafing areas. When the intertidal area is inundated by the tide it becomes available for benthic and surface-feeding ducks and piscivorous/other waterbirds. During this tidal state this area can be used by various waterbirds as a loafing/roosting resource NPWS, 2012 b).

The supra-tidal category, in this context, refers to areas that are not frequently inundated by the tide (i.e. occurring above the mean high watermark) but contain shoreline and coastal habitats and can be regarded as an integral part of the shoreline. For the River Shannon and River Fergus Estuaries SPA this is estimated to be 2,448 ha. Supratidal areas are used by a range of waterbird species as a roosting resource as well as providing feeding opportunities for some species.

The category known as ‘Lagoon and associated habitats’ in this context refers to lagoons and brackish lakes and their associated habitats. For the River Shannon and River Fergus Estuaries SPA this habitat category is estimated to be 36 ha, and relates to Mangan’s Lagoon, near Aughinish Island, and the larger Shannon Airport Lagoon. This latter area provides was included in the SPA primarily for supporting large concentrations of Black-tailed Godwit but it also provides both feeding and roosting/refuge habitats for a several other waterbird species.

The category known as ‘Freshwater and associated habitats’ in this context refers to freshwater lakes and their associated habitats. For the River Shannon and River Fergus Estuaries SPA this habitat category is estimated to be 56 ha, and relates specifically to Bunlickey Lake and Cooperhill Lakes. These habitats provide both feeding and roosting/refuge habitats for a variety of waterbird species that also use the wider estuarine habitats NPWS, 2012 b).

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8 ASSESSMENT OF POTENTIALLY SIGNIFICANT EFFECTS There follows an evaluation of significance of potential impacts of the proposed project on the qualifying features that have been selected for impact assessment. This section considers the habitats and species identified in the preceding sections together with any potential impacts, and determines whether the proposed works are likely to have significant effects on any of the Natura 2000 sites designated for the protection of the qualifying features selected.

The likelihood of adverse effects to each Natura 2000 site from the project was determined based on a number of indicators including:

 Habitat loss and/or alteration  Water quality  Disturbance and/or displacement of species  Habitat or species fragmentation

The likelihood of significant cumulative/in-combination effects is assessed in Section 6.5 below.

8.1 WATER QUALITY

8.1.1 Construction Phase The footprint of the proposal overlaps with the Shannon River and Estuary, which forms part of the Lower River Shannon cSAC and the River Shannon and River Fergus Estuaries SPA.

There are several aspects of the proposal which could potentially result in impairment of water quality within either the SAC or SPA. Potential water quality effects arising as a result of the proposal could potentially occur as a result of erosion and run-off of fines/nutrient-enriched material from excavations, denuded embankments or temporary storage areas for turf and top-soil. Adverse water quality effects could also potentially arise due to the accidental release of pollutants such as fuels, oils and other such substances to the aquatic environment. These impacts are considered to have the most potential to occur during the construction phase of the project. The drainage channel to the north of the eastern embankment could be polluted by runoff from the works area. This channel discharges to the Shannon Estuary, thereby acting as a potential pollution vector to the Shannon Estuary. Similarly, the Airport lagoon could be impacted by overland flow from works areas at the western embankment. Contamination or water quality impacts on the Shannon Estuary could result in impacts on the intertidal-marine ecosystem and therefore the species that are dependent on good water quality for survival.

The potential significant impacts of the project on intertidal-marine ecology (without mitigation) are summarised as follows:

 Risk to water quality via suspended solids pollution, through mobilisation of soils and other substances that can occur in suspension in water, associated with excavations and stockpiles;

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 Pollution of watercourses with nutrients due to ground disturbance during construction. The main potential sources of nutrient inputs to brackish/marine water due to ground disturbance are from nutrients adsorbed or chemically bound to eroded suspended solids; and  Pollution, with other substances such as fuels, lubricants, waste water from wash facilities, etc.; and  Potential risk of organic pollution of the intertidal zone-marine environment during construction phase through accidental spillage of hydrocarbons from construction related vehicles, machinery and equipment.

In conclusion, the release of non-attenuated suspended solids and potentially contaminated run-off waters into the Shannon Estuary or nearby connecting drains/watercourses has the potential to have a negative impact on water quality, and thus the Lower River Shannon cSAC and the River Shannon and River Fergus Estuaries SPA. This would potentially be a temporary negative impact. The risk of occurrence however can be adequately prevented by the implementation of standard best management practices and controls. Therefore, certain mitigation measures are recommended with regards to protection of water quality and are included in Section 9 below.

8.1.2 Operational Phase Post construction, storm activity may result in loss of some loose sediment from the upgraded embankment, but stability of sediments can be expected following a few such episodes. No significant operational phase water quality impacts are envisaged.

8.2 HABITAT LOSS/ALTERATION

8.2.1 Lower River Shannon cSAC 8.2.1.1 Estuaries Excavation works for the foundation pocket required to facilitate installation of rock armour along the seaward face of the East Embankment and installation of rock armour will result in the permanent removal and alteration of littoral benthic habitat and associated infaunal species within the estuarine habitat of the Lower River Shannon cSAC. Excavations to -1.0ODM will be required along approximately 0.8km of the East Embankment, extending seawards to approximately 5m from the existing embankment toe.

In the context of overlap with estuarine habitat, this will result in permanent removal of approximately 0.4ha of littoral estuarine sediment. Installation of rock armour in this same area will result in the alteration of littoral estuarine habitat of an approximate area of 4,000m2. A greater area could be directly affected with inappropriate site management.

A review of maps contained within the Conservation Objectives for the SAC determined that the proposed area of excavation along the seaward face of the East Embankment overlaps with the mapped distribution of the ‘Intertidal sand to mixed sediment with polychaetes, molluscs & crustaceans’ community complex (see Figure 7 above for mapped extent of community complex as per Conservation Objectives documentation). Mixed sediment is the dominant sediment type within this community. The sediment type is highly variable throughout this community evidenced by the wide ranges in sediment fractions. The polychaete Hediste diversicolor and the bivalve Macoma balthica are recorded in moderate to high abundances throughout this community complex. The

19986-6002-D Natura Impact Statement June 2020 gastropod Hydrobia ulvae also generally occurs in moderate to high abundances. Distinguishing species of this community complex include Hediste diversicolor, Macoma balthica, Hydrobia ulvae, Nephtys hombergii and Corophium volutator (NPWS, 2012b).

While infauna present within the foundation pocket will be completely removed from the area by excavation works, and potentially subsequently covered over with rock armour, the species which occur there are distributed throughout the surrounding area as this intertidal community is found extensively throughout the estuary (NPWS, 2012b). Such species as are found in these estuarine community complexes have typically evolved to take advantage of disturbed habitats and consequently thrive in such environments. For example, Nephtys hombergii can move very quickly through the substratum, downwards on the ebb tide and up again on the flood tide (Clay, 1967). It is also capable of swimming short distances with an undulatory movement. It also releases planktotrophic (planktonic-dispersing larva that derives its nourishment by feeding in the plankton) and lecithotrophic (a planktonic-dispersing larva that lives off yolk supplied via the egg) larvae. Such species typically have the ability to re-establish themselves from surrounding populations through the colonisation of larvae.

There also exists the potential for surrounding habitat communities to be indirectly impacted via sedimentation effects as re-suspended sediment settles out of the water column following bed disturbance associated with excavation works. This can also occur as a result of accidental spillage of material during transportation via excavator to the trucks. Mudflats are accreting environments where deposition rather than erosion is the primary process. As a result, the communities which exist there have evolved to withstand smothering by light sedimentation. Any sedimentation impacts are not expected to be significant on estuarine habitat.

With installation of additional rocks along the intertidal zone fronting the east embankment, there would be a concern with regard to potential changes to local hydrodynamics and therefore erosive- deposition processes. The concern would be that the works could alter the intertidal zone at the seaward side of the proposed development fronting the east embankment. The magnitude of any changes of the estuarine habitats would be expected to decrease with distance from the upgraded embankment.

Anthropogenic disturbance may be considered significant when it causes a change in biotic and/or abiotic variables in excess of what could reasonably be envisaged under natural processes. The capacity of the habitat to recover from this change is obviously an important consideration (i.e. habitat resilience) thereafter. Excavation works will result in the permanent loss of approximately 4,000m3 of littoral estuarine sediment comprising the community type ‘Intertidal sand to mixed sediment with polychaetes, molluscs & crustaceans’ within the Lower River Shannon cSAC. Similarly, installation of rock armour within the same footprint will result in the alteration of approximately 0.4ha of estuarine littoral habitat within the SAC.

In the context of the overall community extent within the site, a review of the marine habitats supporting document for the SAC has determined the estimated area of the community type ‘Intertidal sand to mixed sediment with polychaetes, molluscs & crustaceans’ within the ‘Estuaries’ habitat to be approximately 8,130ha (NPWS, 2012b). Therefore, the area of proposed excavation works/rock armour installation represents approximately 0.004% of the overall estimated area of

19986-6002-D Natura Impact Statement June 2020 this community type within the estuary. Loss/alteration of this littoral area is therefore not considered to be significant in the context of the overall community extent within the site.

Common Cord-grass (Spartina anglica) is abundant along the outer edges of each of the Atlantic Salt Meadow habitat areas. Interference with saltmarsh through excavation or otherwise could spread this non-native invasive plant.

In summary, with regards to the Conservation Objectives for the Annex I habitat ‘Estuaries’, there will be no change in permanent habitat area and significant impacts to community distribution are not envisaged given the scale of the works, and the natural life traits and resilience of estuarine benthic communities.

With regards to the potential for indirect habitat impacts to estuaries through water quality effects it has been determined that there is potential for significant water quality effects within the SAC, or significant water quality effects cannot be ruled out at this stage, as a result of the unmitigated proposal. Therefore, certain mitigation measures are recommended with regards to protection of water quality and are included in Section 9 below.

8.2.1.2 Mudflats and sandflats not covered by seawater at low tide [1140] Excavation works will result in the removal of littoral benthic habitat within the foundation pocket along the seaward face of the East Embankment in the SAC. With regards to the Annex I habitat ‘Mudflats and sandflats not covered by seawater at low tide’ there is overlap between the proposal area and this habitat-type, as mapped in the Lower River Shannon cSAC Conservation Objectives supporting documentation (NPWS, 2012b), therefore there will be removal of mudflat habitat as a result of the proposal (see Figure 6 above for mapped extent of mudflat habitat as per Conservation Objectives documentation).

In order to maintain the favourable conservation condition of ‘Mudflats and sandflats not covered by seawater at low tide’ within the SAC, targets have been defined pertaining to permanent habitat area, which should be stable or increasing subject to natural processes, and the conservation of defined community types in a natural condition.

The overall area of mudflat habitat within the SAC has been estimated to be approximately 8,808ha (NPWS, 2012b). The area of overlap between mapped mudflat habitat and the proposed works will be approximately 0.4ha. Therefore, there will be loss/alteration to approximately 0.004% of mudflat habitat within the SAC. Significant loss of ‘Mudflats and sandflats not covered by seawater at low tide’ within the SAC is therefore not envisaged.

With regards to potential impacts to the ‘Intertidal sand to mixed sediment with polychaetes, molluscs & crustaceans’ community complex, which is considered to be a structurally important community type within the Annex I marine habitat ‘Mudflats and sandflats not covered by seawater at low tide’, potential direct and indirect impacts to community distribution are assessed in terms of ‘Estuaries’. Modelling indicates that the proposed remedial works to the existing eastern embankment as represented in the model domain does not have a significant impact on the morphodynamics of the adjacent mudflats.

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In summary, with regards to the Conservation Objectives for the Annex I habitat ‘Mudflats and sandflats not covered by seawater at low tide’, there will be no change in permanent habitat area and significant impacts to community distribution are not envisaged given the scale of the works, and the natural life traits and resilience of estuarine benthic communities.

With regards to the potential for indirect habitat impacts to mudflats and sandflats through water quality effects it has been determined in Section 8.2.1.1 above that there is potential for significant water quality effects within the SAC, or significant water quality effects cannot be ruled out at this stage, as a result of the unmitigated proposal. Therefore, certain mitigation measures are recommended with regards to protection of water quality and are included in Section 9 below.

8.2.1.3 Coastal Lagoons [1150]* Shannon Airport Lagoon is artificial waterbody that lies at the landward side of the West Embankment. Based on the area of lagoon mapped by NPWS (2012a), the proposed works at the West Embankment are at a remove of approximately 15m proposed works. It is noted however that the surface area of water in the lagoon is contracting due to colonisation of the margins by reeds, the proposed works at the West Embankment are at a remove of approximately 80m the main lagoonal waterbody. Shannon Airport Lagoon lagoon is separated from the sea by man-made barriers comprising the embankment and an access road. The water level in the lagoon is managed via a sluiced outlet through which water drains via a drainage channel located in the lagoons north- western corner.

With regards to direct habitat loss/alteration there is no spatial overlap between the proposed works and the lagoon; therefore, there will be no direct habitat loss/alteration of this Annex I priority habitat. There will be no reduction or decline in habitat area or distribution as a result of the proposed works.

With regards to indirect habitat alteration, it is considered that there is potential for indirect impacts to lagoon habitat via potential water quality effects which may arise as a result of the unmitigated proposal. Such effects, which could arise as a result of ingress of un-attenuated surface run-off or the accidental release of fuels/oils etc, could also indirectly impact on the assemblage of typical plant and animal species associated with this habitat, thus potentially impacting on the conservation objectives of ‘Coastal lagoons’ within the SAC. As there is potential for significant water quality effects within the SAC, or since significant water quality effects cannot be ruled out at this stage, as a result of the unmitigated proposal, certain mitigation measures are recommended with regards to protection of water quality and are included in Section 9 below.

8.2.1.4 Atlantic salt meadows (Glauco-Puccinellietalia maritimae) [1330] A review of mapping available for this habitat-type determined that the closest areas of Atlantic salt meadows to the proposed development comprises an area located ca. 5m from the bottom of the northern end of the East Embankment. Another area of this habitat is indicated approximately 1.1km west West Embankment (NPWS, 2012a). During the habitat survey, two areas of upper saltmarsh Atlantic salt meadows habitat was recorded west of the western embankment, and the extent of this habitat adjacent to the East embankment was greater than that mapped in NPWS.

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As there is no spatial overlap between the works and Atlantic salt meadows there will be no direct loss or alteration of reef habitat within the SAC. There will be no reduction or decline in habitat area or distribution as a result of the proposed works.

With regards to indirect habitat alteration, it is considered that there is potential for indirect impacts to reef habitat via potential water quality effects which may arise as a result of the unmitigated proposal. Such effects, which could arise as a result of ingress of un-attenuated surface run-off or the accidental release of fuels/oils etc, could also indirectly impact on the community complexes associated with this habitat, thus potentially impacting on the conservation objectives of ‘Atlantic salt meadows’ within the SAC. As there is potential for significant water quality effects within the SAC, or since significant water quality effects cannot be ruled out at this stage, as a result of the unmitigated proposal, certain mitigation measures are recommended with regards to protection of water quality and are included in Section 9 below.

8.2.1.5 Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho- Batrachion vegetation [3260] This habitat is associated with running fresh water. It comprises submerged or floating vegetation of the Ranunculion fluitantis and Callitricho-Batrachion (low water level during summer) or aquatic mosses. Within the Lower River Shannon cSAC, this habitat consists of three high conservation elements (sub-types), one being Opposite-leaved Pondweed Groenlandia densa.

Groenlandia densa was identified within a drainage channel associated with the Shannon Airport Lagoon during habitat surveys carried out on-site. The drainage channel supporting this plant lies adjacent and downslope of the proposed development. Works at the East Embankment could adversely affect water quality in the drainage channel and therefore result in habitat loss or alteration. This assessment takes account that Groenlandia densa appears to be sensitive to eutrophication (Preston, 2003).

As there is potential for significant water quality effects within the SAC, or since significant water quality effects cannot be ruled out at this stage, as a result of the unmitigated proposal, certain mitigation measures are recommended with regards to protection of water quality and are included in Section 9 below.

8.2.2 River Shannon and River Fergus Estuaries SPA (004077) 8.2.2.1 Wetlands [A999] The wetlands of northwest Europe are a vital resource for millions of northern and boreal nesting waterbird species that overwinter on these wetlands or visit them when migrating further south. To acknowledge the importance of Ireland's wetlands to wintering waterbirds the term ‘Wetland & Waterbirds’ can be included as a Special Conservation Interest for a Special Protection Area that has been designated for wintering waterbirds, and is or contains a wetland site of significant importance to one or more of the species of Special Conservation Interest.

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Table 23 Assessment of potential impacts of the project on ‘wetlands’. Assessment of Potentially Significant Effects Mitigation Attribute/Measure Target required The permanent area occupied by the wetland The wetland habitat area was estimated as habitat should be 32,261ha (NPWS, 2012a). The estuarine habitat stable and not adjacent to the proposed development likely Wetland habitat significantly less forms part of this wetland area. The proposed Yes area/hectares than the area of development would not have any direct impacts 32,261ha, other on habitat area but could have indirect impacts than that occurring on water quality and therefore habitat quality. from natural patterns of variation

The Shannon Estuary features this conservation interest, with mudflats and mixed sediment shores providing feeding opportunities for over-wintering birds. The loss and alteration of wetlands habitat in the River Shannon and River Fergus Estuaries SPA correspond to habitats listed as conservation interests of the Lower River Shannon cSAC i.e. estuaries, mudflats, sandflats and lagoons.

As there is potential for significant water quality effects within the SPA, or since significant water quality effects cannot be ruled out at this stage, as a result of the unmitigated proposal, certain mitigation measures are recommended with regards to protection of water quality and are included in Section 9 below.

8.3 DISTURBANCE AND/OR DISPLACEMENT OF SPECIES Intertidal habitats areas adjacent to the proposed works provide important foraging areas for many species of waterbirds, especially wading birds. The lagoon is recognised as a roosting/loafing area (loafing can be described as any behaviour not connected with breeding or feeding, and includes preening and resting). When the intertidal area is inundated by the tide it becomes available for diving ducks and piscivorous/other waterbirds. When exposed or partially exposed by the tide, intertidal habitats provide important foraging areas for many species of waterbirds, especially wading birds. The proposed works have the potential to disturb birds of conservation interest the SPA.

The proposed works at the shore will take 6 - 9 months to complete. The fauna of conservation interest in the Shannon Estuary in the environs of the proposed works would be disturbed during this period. Disturbance of Otter and birds can be expected to result in their movement to other parts of the estuary.

There is potential for indirect disturbance or displacement of species arising from potential pollutants entering the Shannon Estuary during the construction phase of the proposed works. Pollutants include silt, chemicals or hydrocarbons associated with construction activities. Siltation of the substrate and eutrophication leading to increased biomass of filamentous algae would reduce the available suitable habitat.

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8.4 HABITAT OR SPECIES FRAGMENTATION Habitat fragmentation has been defined as ‘reduction and isolation of patches of natural environment’ (Hall et al., 1997 cited in Franklin et al., 2002) which results in spatial separation of habitat areas which had previously been in a state of greater continuity. Adverse effects of habitat fragmentation on species include the increased isolation of populations which can detrimentally impact on the resilience or robustness of the populations.

There is potential for pollutants to enter the Shannon Estuary during the construction phase. Habitat and species fragmentation can be caused by polluted bodies of water, where fish cannot survive. Impacts on fish could have negative consequences for Otter. The proposed development is not expected to cause any significant fragmentation of habitats or species given its location adjacent to an existing embankment, spatial extent and short-term construction phase.

8.5 ASSESSMENT OF SIGNIFICANCE OF POTENTIAL IMPACTS

8.5.1 Habitat Loss and Alteration The proposal site occurs along existing rock armour embankments contiguous to estuarine mudflats and adjacent to Shannon Airport Lagoon. As the embankments lie within/adjacent to the Lower River Shannon cSAC and the River Shannon and River Fergus Estuaries SPA, these sites will be subject to direct/indirect habitat loss to the intertidal mudflats and sandflats or along rock armour structure at the upper intertidal zone. In addition, there lies a direct pathway between the proposed development site and the Shannon Airport Lagoon.

However, the impact is considered to be low, given the localised and temporary nature of the works and that the works will be restricted to the existing rock armour structure. Target 1 of the conservation objectives for ‘mudflats and sandflats not covered by seawater at low tide’ refers to the stability of the permanent habitat area, subject to natural processes (NPWS, 2012a). There will be some loss of mudflat habitat to accommodate the works. ‘Mudflats and sandflats not covered by seawater at low tide’ area was estimated using OSI data as 8,808ha.

One of the concerns regarding potential impact of the rock armour facing relates to the potential change in reflectivity of the front face of the embankment as the rock protection becomes larger. Modelling was undertaken of the combined wave and water level conditions and the resulting sediment transport of the intertidal muds (silt sized material) for the existing case and with the proposed armouring installed. An assessment of wave reflection indicated that the reflection coefficients of the existing armourstone, which for the purposes of the assessment is considered to be a one layer rock armour revetment, and that of the proposed larger stone, which for the purposes of the assessment is considered to be a two layer rock armour revetment are both relatively low in the range 0.15 to 0.2. This is due for the most part to the relative shortness of the locally generated waves. This means that the total significant wave height in front of the embankment is close to that of the incoming wave because the reflection coefficient is relatively low. The difference between the total significant wave height for the existing and new structures is in the order of 2%. If the existing armour was considered to be smooth the reflection coefficient is greater and the difference between the existing and proposed would be greater, but still in the order of 10%, which is equivalent to a difference of less than 0.1m for the more extreme waves at the site. Hydrodynamic/morphodynamic differences between the existing environment and those expected

19986-6002-D Natura Impact Statement June 2020 following construction are not considered to be at a level that will significantly change the local estuarine environment.

The extent of proposed armorflex is ca. 100 along the eastern embankment, as illustrated in Figure 12. Armorflex is a flexible, interlocking matrix of cellular concrete blocks of uniform size, shape, and weight used for hard armour erosion control. ArmorFlex has 20% open area so allows vegetation of the area affected.

The saltmarsh within the Lower River Shannon cSAC is located in excess of 6m from the proposed armorflex. There is some potential for impacts on saltmarsh, through improper storage of excavated materials or tracking of machinery. For example, use of heavy machinery in the intertidal zone at/adjacent to saltmarsh could have direct and indirect impacts on saltmarsh. Mitigation will be required to avoid such impacts. Post construction, estuarine sediment from the intertidal zone can be expected to be deposited into voids in the armorflex. This will likely be vegetated with plants, either by seed dispersion from the local floral bank, or plant fragments. As is the case with elsewhere, mitigation will be required to prevent the importation and/or spread of alien invasive species. With implementation of mitigation, there will be no disturbance (direct impacts) on saltmarsh within the SAC during construction. At operation statge, the saltmarsh will not be prone to erosion, taking into account differences between the existing embankment and those expected following armorflex installation, as morphodynamics will be altered in any significant way due to the relatively low energy environment in this part of the estuary.

The works may temporarily displace commuting or foraging otters, however, the impact is considered to be limited given the localised and temporary nature of the works and the wide availability of suitable habitat in the vicinity of the works, it is not expected that otter will be significantly impacted by the proposed repair works.

With the appropriate mitigations in place, it is concluded that significant habitat loss or alteration impacts to the Lower Shannon River SAC during the construction phase of the proposal are not likely to occur as a result of the proposed works.

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Figure 12 Extent of proposed armorflex at the eastern embankment

8.5.2 Habitat or Species Fragmentation Given that the works occur in such close association with the Lower River Shannon cSAC and the River Shannon and River Fergus Estuaries SPA, there is the potential for habitat or species fragmentation to occur. The primary concern in terms of habitat fragmentation lies with the localised floating river vegetation, and the mudflats and sandflats, which, will likely be fragmented due to the proposed works, along the Shannon embankments.

However, accounting for the fact that floating river vegetation is considered to be widespread in water systems throughout Ireland and given the abundance of available alternative habitat along the estuary, it is determined that the potential impact to qualifying habitats and species will be low, temporary and very localised in nature as the species will make use of the available surrounding habitats during the construction phase of the works. Once works are complete they will be available for use again, with the impact on the qualifying habitats being temporary and localised. The CEMP will ensure that the works keep to the existing footprint of the site and that all steps necessary to ensuring the conservation of qualifying interest habitats and species are protected.

With the appropriate mitigations in place, it is concluded that significant habitat or species fragmentation impacts to the Lower Shannon River SAC during the construction phase of the proposal are not likely to occur as a result of the proposed works.

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8.5.3 Disturbance and/or Displacement of Species A primary impact associated with construction and maintenance is displacement and avoidance of foraging birds from the works areas and surrounding environment. The Lower River Shannon cSAC and the River Shannon and River Fergus Estuaries SPA are designated for the protection of a variety of species, as listed in Section 7 above. The proposed development site area may be used by foraging SCI species. A certain amount of activity already exists in the area, including the Shannon Airport and Shannon Free Zone, the Shannon Golf Course, and the surrounding dwellings of Shannon Town to the northeast and beyond, vehicular/air traffic associated with the main road and airport, and agricultural activities in the areas extending further away from the built area (agricultural grassland/silage harvesting/arable land, etc). However, the previous sections have concluded that the works will not impede the movement of these species and the biggest risk to these species lies with potential water quality impacts, which is assessed in section 8.5.4 below.

There is the potential for some very localized and temporary disturbance and/or displacement to otter potentially foraging in the area. Chanin (2003a) indicate that otters will rest under roads, in industrial buildings, close to quarries, and at other sites close to high levels of human activity, clearly indicating that otters are very flexible in their use of resting sites and do not necessarily avoid ‘disturbance’ in terms of noise or proximity to human activity. Though not found during the surveys carried out in 2019, it is possible that otter could use the proposed development site for a holt, so the proposed works could potentially displace a pair of breeding otter.

Bearing in mind the scale of the proposed works, the level of activity currently in the area, in the location of the proposed works are situated at the extremity of the SAC/SPA site, and the wide availability of suitable habitat in the vicinity of the works, it can be concluded that any potential disturbance/displacement impacts during the construction phase will be localized and short-term in nature. Any impacts are considered limited given the localised and short-term nature of the works. Mitigation will be required for otter i.e. preconstruction otter survey.

8.5.4 Water Quality The receiving environment of the proposed refurbishment works to Shannon Airport Embankments is the River Shannon and River Fergus Estuary. The main risk to water quality arises as a result of the potential for discharge of polluting substances required to carry out the repair works such as grout and concrete wastewaters and fuels/oils. There is potential for uncontrolled discharge of polluting substances from the following activities:

 The potential risk of organic pollution through accidental spillage of hydrocarbons from construction-related vehicles, machinery, and equipment  Surface water run-off  Increased nutrients/sedimentation

It is considered that the main threat to the habitat types of the Lower River Shannon cSAC relate to water quality impacts. The habitat and species types that may suffer potentially significant impacts are:

 Estuaries/Mudflats and sandflats not covered by seawater at low tide  Atlantic salt meadows

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 Coastal lagoon  Floating river vegetation  Otter

Estuaries support a diverse range of plant and animal species dependent on good water quality for optimum ecological functioning. There is potential for significant water quality impacts to occur to the estuarine habitat type and associated dependent species.

In the event a relatively large accidental spillage of fuels/oils occurred during the repair work from machinery and equipment being used to facilitate the repair works, this may have a significant impact on local small mudflats exposed at low tide in the vicinity of the works. In the event of a reduction in water quality as a result of the discharge of polluting substances to the river, otter may be directly or indirectly impacted should their food source be significantly affected.

Floating river vegetation of the sub-type Opposite-leaved Pondweed Groenlandia densa occurs in a channel connected to the lagoon in the vicinity of the repair works. A reduction in water quality could result in indirect significant impacts to this floating water vegetation.

With the appropriate mitigations in place, it is concluded that significant water quality impacts to the Lower Shannon River SAC during the construction phase of the proposal are not likely to occur as a result of the proposed works.

8.6 ASSESSMENT OF EFFECT ON CONSERVATION OBJECTIVES Detailed conservation objectives (COs) have been developed for the Lower River Shannon cSAC and for the River Shannon and River Fergus Estuaries SPA. In Section 7 above, an evaluation was undertaken to determine which of the qualifying interests of the potentially lie within the zone of influence of the project and required further assessment in the NIS. This was done through a scientific examination of ecological evidence and data. The effects of the project on the qualifying interests which have been identified as being potentially within the zone of influence have been assessed against the measures designed to achieve the conservation objectives. An assessment of the effect of the project on Cos selected for further assessment has been presented below under the Lower River Shannon cSAC and the River Shannon and River Fergus Estuaries SPA. Where a measure may be negatively affected by the project the need for mitigation is indicated.

8.6.1 Lower River Shannon cSAC The following tables give the assessment of effect of the project on the Conservation Objectives for special conservation interests identified as being potentially significantly affected by the proposed development i.e. ‘Estuaries’, ‘Mudflats and sandflats not covered by seawater at low tide’ and ‘Coastal Lagoons’.

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Table 24 Assessment of potential impacts of the project on estuaries Attribute/ Target Assessment of Potentially Significant Effects Mitigation Measure Required Habitat area/ Area stable or increasing, The project will not result in a significant reduction in area of this habitat type. The area of overlap between Yes hectares subject to natural processes the proposed excavation works/rock armour installation and ‘estuaries’ represents approximately 0.00165% of this conservation interest. It is possible, in the event of a poorly managed site that the impacted area is greater than that anticipated. Community To conserve the community The project has the potential to result in significant water quality impacts which may affect the communities Yes distribution/ types for which this habitat for which this habitat type is designated. hectares is designated in a natural condition

Table 25 Assessment of potential impacts of the project on mudflats Attribute/ Mitigation Target Assessment of Potentially Significant Effects Measure Required The project will not result in a significant reduction in area of this habitat type. The area of overlap between Habitat area/ Area stable or increasing, mapped mudflat habitat and the proposed works will be approximately 0.4ha (approximately 0.0045% of Yes hectares subject to natural processes mapped mudflat habitat within the SAC). It is possible, in the event of a poorly managed site that the impacted area is greater than that anticipated. The area of overlap between the proposed excavation works/rock armour installation and the distribution of ‘Intertidal sand to mixed sediment with polychaetes, molluscs & crustaceans’ community complex represents Community To conserve the community approximately distribution/ types for which this habitat 0.004% of the overall estimated area of this community type within the estuary. The project will not result in a Yes hectares is designated in a natural significant reduction in area of this community type. condition The project has the potential to result in significant water quality impacts which may affect the communities for which this habitat type is designated.

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Table 26 Assessment of potential impacts of the project on coastal lagoons Attribute/ Target Assessment of Potentially Significant Effects Mitigation Measure Required Habitat area/ Area stable or increasing, subject to The area of the Shannon Airport lagoon is given as 24.2ha. The area of this habitat has Yes Hectares natural processes decreased considerably in recent times with the encroachment of reeds and other vegetation from the marginal areas. This was first observed in 2001 when year-round pumping commenced (ASU, 2004). Pumping has ceased since March 2014. Using aerial imagery together with GIS, the estimated surface area of the lagoon (not covered by reedbeds) is in the range 13 – 15h.a. An existing track between the lagoon and the embankment will be used to access the works area and there will be no infringement with the wetland associated with the lagoon. Inappropriate site management such as storage of excavated material could potentially result in a reduction wholly or in part of the Shannon Airport Lagoon. Habitat distribution/ No decline, subject to natural The project will not result in a decline in the distribution or occurrence of this habitat No Occurrence processes type Salinity regime/ Practical Median annual salinity and temporal The project will not result in any change in salinity regime. No salinity units (psu) variation within natural ranges. Hydrological regime/ Annual water level fluctuations and The tidal regime is a very important influence on coastal lagoons. However, the No metres minima within natural ranges. extremely low permeability of the embankment does not allow lagoon seepage to/from the estuary, apart from a sluice. The project would not disturb the existing drainage situation nor affect connectivity between Shannon Airport Lagoon and the sea. Barrier connectivity: Appropriate hydrological Connectivity between the lagoon and the sea is an important attribute of coastal lagoons. No between lagoon and sea/ connections between lagoons and There is a tidal sluice gate between the lagoon and the Shannon Estuary Permeability sea, including where necessary, appropriate management. The project would not disturb the existing situation and alter connectivity between Shannon Airport Lagoon and the sea. Water quality: Chlorophyll Annual median chlorophyll a within The construction phase of the project could potentially result in the release of Yes a/ µg/L natural ranges and less than 5μg/L. sediment/pollutants and affect the quality of the water associated with the lagoon. Therefore, there is potential for this conservation objective to be negatively affected. Water quality: Annual median within natural The construction phase of the project could potentially result in the release of Yes Molybdate Reactive ranges and <0.1mg/l. sediment/pollutants and affect the quality of the water associated with the lagoon.

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Attribute/ Target Assessment of Potentially Significant Effects Mitigation Measure Required Phosphorous (MRP)/ mg/L Therefore, there is potential for this conservation objective to be negatively affected. Water quality: Dissolved Annual median within natural The construction phase of the project could potentially result in the release of Yes Inorganic Nitrogen (DIN)/ ranges and <0.15mg/l. sediment/pollutants and affect the quality of the water associated with the lagoon. mg/L Therefore, there is potential for this conservation objective to be negatively affected. Depth of macrophyte Macrophyte colonisation to The project will could affect the depth of macrophyte colonisation within the lagoon in Yes colonisation/ Metres maximum depth of lagoons the event of mobilisation of sediment and consequent increase in suspended solids (decreasing light penetration). Typical plant species/ Maintain number and extent of The project will could affect the plant species typical of lagoonal specialists in the event Yes Number and m2 listed lagoonal specialists, subject to of mobilisation of sediment and consequent increase in suspended solids (decreasing natural variation light penetration). Typical animal species/ Maintain listed typical lagoonal The project could affect the typical animal species typical associated with the lagoon in Yes number specialists, subject to natural the event that it impacted water quality. variation Negative indicator species/ Negative indicator species absent or The project could potentially introduce non-native biota to the lagoon and affect the Yes Number and % cover under control number or cover of negative indicator species associated with the lagoon.

Table 27 Assessment of potential impacts of the project on Atlantic salt meadows Attribute/Measure Target Assessment of Potentially Significant Effects Mitigation required Habitat area/Hectares Area stable or increasing, subject to This habitat occurs adjacent to both eastern and western embankments. There will be Yes

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Attribute/Measure Target Assessment of Potentially Significant Effects Mitigation required natural processes, including erosion and no impact on this habitat at the western embankment as the works are confined to the succession. crest and landward side of the embankment. Due to the proximity of the proposed works to the saltmarsh at the eastern embankment, impacts relating to uncontrolled access and runoff from the works area could reduce the area, or quality of the habitat. Habitat No decline or change in habitat The project will not result in a decline in the distribution or occurrence of this habitat No distribution/Occurrence distribution, subject to natural processes. type. Physical structure: sediment Maintain natural circulation of sediments There will be no additional barriers other than those (pitched stone on front face of No supply/Presence absence of and organic matter, without any physical embankments) that have always been in existence. physical barriers obstructions Physical structure: creeks and Maintain creek and pan structure, subject The project footprint will not incur any significant physical change to the foreshore in No pans/ Occurrence to natural processes, including erosion the environs of this habitat. and succession Physical structure: flooding Maintain natural tidal regime The project will not affect the flooding regime or impact the area of the habitat. No regime/ Hectares flooded; frequency Vegetation structure: Maintain the range of coastal habitats The project footprint will not incur any significant physical change to the foreshore in No zonation/Occurrence including transitional zones, subject to the environs of this habitat, so no change to this attribute is expected. natural processes including erosion and succession Vegetation structure: Maintain structural variation within sward The saltmarsh habitat adjacent to the proposed development is apparently not grazed. No vegetation height/ Centimeters The proposal will not change access to the foreshore, so no change to this attribute is expected. Vegetation structure: Maintain more than 90% of the saltmarsh No poaching was noted at the saltmarsh habitat adjacent to the proposed No vegetation cover/ Percentage area vegetated development. The proposal will not change access to the foreshore, so no change to cover at a representative this attribute is expected. sample of monitoring stops Vegetation composition: typical Maintain range of sub‐ communities with The project footprint will not incur any significant physical change to the foreshore in No species and sub‐communities/ typical species listed in Saltmarsh the environs of this habitat, so no change to this attribute is expected. Percentage cover at a Monitoring Project (McCorry and Ryle,

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Attribute/Measure Target Assessment of Potentially Significant Effects Mitigation required representative sample of 2009) monitoring stops Vegetation structure: negative No significant expansion of common Common Cord-grass (Spartina anglica) is abundant along the outer edges of each of the Yes indicator species‐ Spartina cordgrass (Spartina anglica), with an Atlantic Salt Meadow habitat areas. Interference with saltmarsh through excavation or anglica/ Hectares annual spread of less than 1% otherwise could spread this non-native invasive plant.

Table 28 Assessment of potential impacts of the project on ‘Vegetation of flowing waters’ Attribute/Measure Target Assessment of Potentially Significant Effects Mitigation required Habitat area /Kilometres Area stable or increasing, subject The full extent of this habitat is unknown, but Opposite-leaved Pondweed does occur in a channel Yes to natural processes. Three adjacent to the East embankment. The construction phase of the project could potentially result in sub‐types of high conservation sediment release from excavations and deposit silt in the channel, possibly affecting the area of the value are known to occur in the habitat suitable for colonisation. Therefore, there is potential for this conservation objective to be site negatively affected. Habitat distribution/ No decline, subject to natural The construction phase of the project could potentially result in sediment release from excavations and Yes Occurrence processes. deposit silt in the channel possibly affecting the distribution of the habitat. Therefore, there is potential for this conservation objective to be negatively affected. Hydrological regime: Maintain appropriate A natural flow regime is required for both plant communities and channel geomorphology to be in Yes river flow/Metres per hydrological regimes favourable condition. The project will could affect the hydrological regime of the channel supporting second Opposite-leaved pondweed, for example by interfering with the connection between the channel and the estuary. Effects to this conservation objective are therefore possible. Hydrological regime: Maintain natural tidal regime Tidal regime appears to be an important influence on the distribution of certain pondweed. The project No tidal influence/Daily will not affect the hydrological regime of the channel supporting Opposite-leaved pondweed. The water level connection between the lagoon and the estuary will be maintained, as is necessary for lagoon drainage. fluctuations ‐ metres Hydrological regime: Maintain appropriate freshwater Freshwater seepages are considered important for the Groenlandia densa subtype. The proposed No freshwater seepages/ seepage regimes development would not influence freshwater seepage regimes so this attribute will not be affected. Metres per second Substratum The substratum should be The construction phase of the project could potentially result in sediment release and deposit silt in the Yes

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Attribute/Measure Target Assessment of Potentially Significant Effects Mitigation required composition: dominated by the particle size channel. Therefore, there is potential for this conservation objective to be negatively affected. particle size range/ ranges, appropriate to the Millimetres habitat sub‐type (frequently sands, gravels and cobbles) Water quality: The concentration of nutrients in Phosphorous (MRP) is typically the limiting nutrient, however increased nitrogen negatively impacts Yes nutrients/ Milligrammes the water column should be upon some aquatic plant communities. Nutrient enrichment typically leads to increased filamentous per litre sufficiently low to prevent algae biomass and consequent changes in algae, bryophyte and macrophyte species composition and changes in species composition abundance. The project could potentially result in nutrient release to the channel supporting or habitat condition. The specific Groenlandia densa, through sediment releases. Therefore, there is potential for this conservation targets may vary among sub‐ objective to be negatively affected. types Vegetation Typical species of the relevant The sub-types of this habitat are poorly understood and their typical species have yet to be defined. Yes composition: habitat sub‐type should be The construction phase of the project could potentially result in nutrient release, which could alter typical present and in good condition vegetation composition. Therefore, there is potential for this conservation objective to be negatively species/Occurrence affected. Floodplain The area of active floodplain at River connectivity with the floodplain is essential for the functioning of this habitat and is particularly No connectivity/Area and upstream of the habitat important in terms of sediment sorting and nutrient deposition. The project will not affect floodplain should be maintained connectivity within the catchment. No significant effects to conservation objective anticipated. Riparian habitat/Area The area of riparian woodland at While some trees are potentially affected, riparian woodland of conservation value (alluvial) will not. No and upstream of the bryophyte‐rich sub‐type should be maintaine

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8.6.2 River Shannon and River Fergus Estuaries SPA The overall objective for the River Shannon and River Fergus Estuaries SPA is to maintain or restore the favourable conservation condition of the bird species listed as Special Conservation Interests for this SPA. This section provides the conservation objectives (conservation targets) for the qualifying interest species of the River Shannon and River Fergus Estuaries SPA (004077). The following tables give the assessment of effect of the project on the Conservation Objectives for special conservation interests identified as being potentially significantly affected by the proposed development. The following tables assess the effects of the project against the measures designed to achieve the conservation objectives for SCIs. Where a measure may be negatively affected by the project the need for mitigation is indicated.

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8.6.2.1 Cormorant [A017] Table 29 Assessment of conservation objectives and potential impact for Cormorant [A017] Attribute29 Target Notes Potential Impacts Mitigation Required Breeding No significant decline This measure is based on standard survey methods Subsite OH510 was one of the top 5 foraging locations for this Yes population (Walsh et al., 1995). Mitchell et al. (2004) provides species during the MKO (2019) study. This subsite corresponds to abundance summary population information. The Seabird the area to the west of the western embankment. There is ample Monitoring Programme (SMP) online database suitable habitat along the Shannon Estuary for this species and it is (JNCC, 2012) provides population data for this known to occur throughout the SPA. The project is not expected to species. cause a significant decline in the breeding population of cormorant, but water quality impacts could impact on the prey items of this species. While no significant effects to this measure are expected, mitigation will be applied as a precaution. Productivity No significant decline This measure is based on standard survey methods The project is not expected to cause a significant decline on the No rate (Walsh et al., 1995). Mitchell et al. (2004) provides productivity of this species. Therefore, no significant effects to this summary population information. The Seabird measure are expected. Monitoring Programme (SMP) online database (JNCC, 2012) provides population data for this species. Distribution of No significant decline Cormorant colonies are usually sited on flat or The project is does not affect habitat types for which Cormorant are No breeding rocky islets or sea stack tops, less often on cliffs often sited on, namely’ rocky islets, sea stack tops and cliffs. colonies but they can also nest in trees (Walsh et al., 1995) Therefore, no significant effects to this measure are expected. Prey biomass No significant decline Key prey items include fish (mostly benthic) and Cormorant are pescivorous and use the area surrounding the Yes available some crustaceans. Key habitats include sandy proposed embankment refurbishments for foraging30. Impacts on areas used by populations, rocky and vegetated water quality could therefore impact prey items of this specialist substrate. Foraging range: max. 50km, mean species.

29 Attributes/measures apply to breeding cormorant 30 https://www.npws.ie/sites/default/files/publications/pdf/004077_River%20Shannon%20and%20River%20Fergus%20Estuaries%20SPA%20Supporting%20Doc%20Appendix%208.1_ V1.pdf [accessed 19/07/2019]

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Attribute29 Target Notes Potential Impacts Mitigation Required 31.67km, mean 8.46km. Birdlife International Seabird Database (BirdLife International, 2012) Barriers to No significant increase Seabird species can make extensive use of the The works will be small and localised in nature and are not expected No connectivity marine waters adjacent to their breeding colonies. to cause any barriers to connectivity for this CI species. Therefore no Foraging range: max. 50km, mean max. 31.67km, impact to this measure is expected. mean 8.46km (BirdLife International Seabird Database (BirdLife International, 2012) Disturbance at Human activities Cormorant colonies are usually sited on flat or Key habitats include sandy areas, rocky and vegetated substrate. As Yes the breeding should occur at levels rocky islets or sea stack tops, less often on cliffs the project occurs on the embankments contiguous to the mud and site that do not adversely but they can also nest in trees (Walsh et al., 1995) sand flats, there is potential for disturbance and water quality affect the breeding impacts. Cormorant are recorded to roost along the eastern side of cormorant population the project, however, any impacts that occur will be small and localised in nature, and the River and Estuaries cover an extensive area that will provide an abundance of suitable habitat. Population Long term population Waterbird population trends are presented in part County Clare has experienced a breeding population decrease from No trend trend stable or four of the conservation objectives supporting 162 to 28 pairs between the 1969-70 and 1999-2002 seabird census increasing document. counts (Mitchell et al., 2004). Cormorant occurs largely to the east of the development site. The project is not expected to cause any potential significant impact on this measure. Distribution No significant decrease As determined by regular low tide and other County Clare has experienced a breeding population decrease from No in range, timing or waterbird surveys. (and discussed in the 162 to 28 pairs between the 1969-70 and 1999-2002 seabird census intensity of use of 2010/2011 waterbird survey programme IFI) counts (Mitchell et al., 2004). Cormorant occurs largely to the east areas by cormorant of the development site. The project is not expected to cause any other than that potential significant impact on this measure. occurring from natural patterns of variation

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8.6.2.2 Whooper Swan [A038] Table 30 Assessment of conservation objectives and potential impacts for Whooper Swan [A038] Attribute Target Notes Potential Impacts Mitigation Required Population Long term population Waterbird population trends are The area affected by the project is not a suitable habitat for this SCI species. No Trend trend stable of increasing presented in part four of the The lagoon was once an important habitat (roost) for Whooper Swan but conservation objectives supporting this is no longer the case. This species was not recorded in the environs of documentation the proposed development site during the MKO (2019) study. Potential impacts to this measure are not expected to occur. Distribution No significant decrease in As determined by regular low tide During the most recent international swan census, just over half of habitat No the range, timing or and other waterbird surveys. (and records for Whooper Swans were for dry improved pasture (Boland et al. intensity of use of areas discussed in the 2010/2011 2010). The lagoon was once an important habitat (roost) for Whooper Swan by this species other than waterbird survey programme IFI) but this is no longer the case. This species was not recorded in the environs that occurring from of the proposed development site during the MKO (2019) study. Whooper natural patterns of Swans that spend winter at the Shannon and Fergus estuaries complex are variation known to forage primarily outside of the SPA boundary. Changes in feeding distribution occur through the winter as food supplies become exhausted and new ones are exploited. The project will not impact on any habitats identified above, as such, it is not expected to impact on this measure.

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8.6.2.3 Light-bellied Brent Goose [A046] Table 31 Assessment of conservation objectives and potential impacts for Light-bellied Brent Geese [A046] Attribute Target Notes Potential Impacts Mitigation Required Population Long term population trend Waterbird population trends This species is not recorded in the area containing or surrounding the proposed No Trend stable of increasing are presented in part four of works (MKO, 2019), which are small and localised in nature and not expected to the conservation objectives cause any potential impacts on this measure. supporting documentation Distribution No significant decrease in the As determined by regular low Brent Geese are grazers and are known for their preference for foraging in intertidal No range, timing or intensity of tide and other waterbird areas with the Eelgrass Zostera sp. (Robinson et al. 2004b). Where this food source use of areas by this species surveys. (and discussed in the is absent the birds feed upon algae and saltmarsh plants and the species also grazes other than that occurring 2010/2011 waterbird survey terrestrially. 2010/2011 waterbird distribution (NPWS) records indicate that this from natural patterns of programme IFI) species is found in seven subsites of the SPA, the nearest records occurring further variation downstream of the proposal site, west of Carrig Island (where the only record of roost sites for this species occurred). Due to the significant intervening distance between the nearest population and the project, potential impacts on this measure are not expected to occur.

8.6.2.4 Shelduck [A048] Table 32 Assessment of conservation objectives and potential impacts for Shelduck [A048] Attribute Target Notes Potential Impacts Mitigation Required Population Long term population trend Waterbird population Shelduck individuals have been recorded in the vicinity of the proposed works and the No Trend stable of increasing trends are presented in area adjacent to the eastern embankment was identified by MKO (2019) as having part four of the relatively high use by this species within the SPA. However, there is more suitable conservation objectives habitat in other locations such as the benthic community of the Fergus Estuary and supporting Poulnasherry Bay which is assigned the broad classification ‘Intertidal sand to mixed documentation sediment with polychaetes, molluscs and crustaceans’ where (NPWS, 2012b). The gastropod mollusc Hydrobia ulvae, a favoured prey of Shelduck, is a distinguishing invertebrate of this community, occurring in moderate to high abundances. This species occurs on many subsites (e.g. 21 in the MKO (2019) study) and there is

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Attribute Target Notes Potential Impacts Mitigation Required suitable habitat and prey available, the project is unlikely to cause an impact on this measure. Distribution No significant decrease in As determined by During the 2010/11 waterbird survey programme, Shelduck were recorded within 41 Yes the range, timing or regular low tide and sub sites overall, and within 38 during low tide surveys, with highest densities intensity of use of areas by other waterbird surveys. occurring east of the proposal site, on the River Fergus near Breckinish. Taking this species other than that (and discussed in the account of the ability of this species to use alternative habitats (considered occurring from natural 2010/2011 waterbird totally reliant on wetland habitats due to unsuitable surrounding habitats patterns of variation survey programme IFI) and/or species limited by habitat requirements), the project could impact this measure if there was a deterioration in water quality, or if the species was subject to disturbance during its peak season (January-February).

8.6.2.5 Wigeon [A050] Table 33 Assessment of conservation objectives and potential impacts for Wigeon [A050] Attribute Target Notes Potential Impacts Mitigation Required Population Long term population Waterbird population trends The project is not expected to impact this conservation objective given its widespread No Trend trend stable of increasing are presented in part four of abundance and moderate ability to use alternative habitats. the conservation objectives supporting documentation Distribution No significant decrease in As determined by regular Fifty seven subsites recorded the species foraging intertidally during the MKO (2019 Yes the range, timing or low tide and other study. None of the sites within/bordering the proposed development site were identified intensity of use of areas waterbird surveys. (and as peak foraging / roosting sites. Impacts to this conservation object are not likely. The by this species other than discussed in the 2010/2011 study area, and in particular the lagoon was identified by MKO (2019) as having relatively that occurring from waterbird survey high use by this species within the SPA. The peak 2019/2020 IWeBS count for the species natural patterns of programme IFI) in the lagoon was 35. The project could impact this measure if there was a deterioration variation in water quality in the lagoon or intertidal area, or if the species was subject to disturbance during its peak season (December-January).

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8.6.2.6 Teal [A052] Table 34 Assessment of conservation objectives and potential impacts for Teal [A052] Attribute Target Notes Potential Impacts Mitigation Required Population Long term population Waterbird population trends The project is not expected to impact this conservation objective. No Trend trend stable of increasing are presented in part four of the conservation objectives supporting documentation Distribution No significant decrease in As determined by regular low Teal populations are recorded east of the project site, as-well as further west near Yes the range, timing or tide and other waterbird Aughinish Island and along the River Fergus. Teal are a widespread bird species that use intensity of use of areas by surveys. (and discussed in the Intertidal mud/sand flats, shallow subtidal and lagoon type habitats but will are also this species other than 2010/2011 waterbird survey considered highly likely to use alternative habitat types. The MKO (2019) study found that occurring from programme IFI) that the lagoon was moderately used by this species during the 2017/18 season. The natural patterns of peak 2019/2020 count for the species in the lagoon was 6.The project may possess the variation potential to temporarily deter populations to use the suitable habitat along the western embankment, especially if subject to ongoing disturbance during its peak season (December-January). The project could impact this measure if there was a deterioration in water quality. While unlikely to have impacts this conservation objective, mitigation will be provided to ensure compliance.

8.6.2.7 Shoveler [A056] Table 35 Assessment of conservation objectives and potential impacts for Shoveler [A056] Attribute Target Notes Potential Impacts Mitigation Required Population Long term population trend Waterbird population trends Subsite OH509 (Airport lagoon) was one of the peak subsites for Shoveler during the Yes Trend stable of increasing are presented in part four of MKO (2019) study. Subsite 0H509 (lagoon) registered a peak number of 55 foraging the conservation objectives Shoveler in Low Tide Surveys and a Peak Number of 15 foraging Shoveler in High Tide supporting documentation Surveys. The peak IWeBS 2019/2020 count for the species in the lagoon was 35. Taking account of the ability of this species to use alternative habitats (considered totally reliant on wetland habitats due to unsuitable surrounding habitats and/or species limited by habitat requirements), the project could

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Attribute Target Notes Potential Impacts Mitigation Required impact this measure if there was a deterioration in water quality, or if the species was subject to disturbance during its peak wintering season (January-February). Distribution No significant decrease in As determined by regular low Subsite OH509 (Airport lagoon) was one of the peak subsites for Shoveler during the Yes the range, timing or tide and other waterbird MKO (2019) study. Subsite 0H509 registered a peak number of 55 foraging Shoveler in intensity of use of areas by surveys. (and discussed in the Low Tide Surveys and a Peak Number of 15 foraging Shoveler in High Tide Surveys. this species other than that 2010/2011 waterbird survey Taking account of the ability of this species to use alternative habitats occurring from natural programme IFI) (considered totally reliant on wetland habitats due to unsuitable surrounding patterns of variation habitats and/or species limited by habitat requirements), the project could impact this measure if there was a deterioration in water quality, or if the species was subject to disturbance during its peak wintering season (January-February).

8.6.2.8 Golden Plover [A140] Table 36 Assessment of conservation objectives and potential impacts for Golden Plover [A140] Attribute Target Notes Potential Impacts Mitigation Required Population Long term population Waterbird population trends Subsite OH512 (at/adjacent to eastern embankment) was one of the peak subsites for Yes Trend trend stable of are presented in part four of this species during the MKO (2019) study. Subsite 0H512 registered a peak number of increasing the conservation objectives 3000 roosting Shoveler, so the project could impact this measure if there was a supporting documentation deterioration in water quality, or if the species was subject to disturbance during its peak wintering season (December-January). Distribution No significant decrease As determined by regular low This species has been recorded in abundance across a number of sub sites within the Yes in the range, timing or tide and other waterbird River Shannon Estuary, both east (Shannon and Bunratty) and west (River Fergus and intensity of use of areas surveys. (and discussed in the Carrig Island) of the project. There has been no record of this species during IWeBS by this species other 2010/2011 waterbird survey counts for the species in the lagoon from 2012/2013. The species is an intermediately than that occurring from programme IFI) distributed species with wide food prey requirements that is considered reliant on the natural patterns of sites upon which is occurs buts is likely to use alternative habitats where required. variation Given the importance of the area near the east embankment, the project could potentially impact on this conservation objective.

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8.6.2.9 Grey Plover [A141] Table 37 Assessment of conservation objectives and potential impacts for Grey Plover [A141] Attribute Target Notes Potential Impacts Mitigation Required Population Long term population Waterbird population trends Grey plover is amber-listed as the majority winter at less than ten sites. Yes Trend trend stable of are presented in part four of However, the project will not impact on this conservation objective. Subsite 0H509 increasing the conservation objectives (west of western embankment) registered proportional moderate use by this supporting documentation species during the MKO (2019) study, so the project could impact this measure if there was a deterioration in water quality, or if the species was subject to disturbance during its peak wintering season (December-January). Distribution No significant decrease As determined by regular low This species is a localised (50-100 sites) intertidal (out of the water) walker that has Yes in the range, timing or tide and other waterbird wide food prey requirements and is considered totally reliant on wetland habitats due intensity of use of areas surveys. (and discussed in the to unsuitable surrounding habitats or is limited by habitat requirements. There has by this species other 2010/2011 waterbird survey been no record of this species during IWeBS counts for the species in the lagoon from than that occurring from programme IFI) 2012/2013. The project could impact this measure if there was a deterioration in water natural patterns of quality, or if the species was subject to disturbance during its peak wintering season variation (December-January).

8.6.2.10 Lapwing [A142] Table 38 Assessment of conservation objectives and potential impacts for Lapwing [A142] Attribute Target Notes Potential Impacts Mitigation Required Population Long term population Waterbird population trends The study area is of some importance to this species as indicated by the MKO (2019) Yes Trend trend stable of are presented in part four of study (site OH510 and OH511 proportional moderate and Low importance increasing the conservation objectives respectively). Lapwing is red-listed due to a decline in the breeding and non-breeding supporting documentation population. The project could impact this measure if there was a deterioration in water quality, or if the species was subject to disturbance during its peak wintering season (December-January). Distribution No significant decrease As determined by regular low The site is designated for wintering lapwing, a widespread (200-300 sites) intertidal (out Yes in the range, timing or tide and other waterbird of the water) walker that has wide food prey requirements and is considered highly

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Attribute Target Notes Potential Impacts Mitigation Required intensity of use of areas surveys. (and discussed in the likely to use alternative habitats. It has been recorded upstream (east embankment) by this species other 2010/2011 waterbird survey and downstream (Greenish Islands) of the project site. Lapwing winter on mudflats and than that occurring from programme IFI) estuaries as well as inland on open grasslands or ploughed fields and breed on natural patterns of grasslands and grassy wetlands (Dempsey and O’ Cleary, 2002). There has been no variation record of this species during IWeBS counts for the species in the lagoon from 2012/2013. The project could impact this measure if there was a deterioration in water quality, or if the species was subject to disturbance during its peak wintering season (December-January).

8.6.2.11 Knot [A143] Table 39 Assessment of conservation objectives and potential impacts for Knot [A143] Attribute Target Notes Potential Impacts Mitigation Required Population Long term population trend Waterbird population trends Knot is amber-listed due to a moderate decline over a long -term. It is the only bird No Trend stable of increasing are presented in part four of that has moved from the BOCCI3 red-list to the amber-list due to a short-term the conservation objectives increase in wintering population. The project will not impact this conservation supporting documentation objective. Distribution No significant decrease in As determined by regular low This species is a localised (50-100 sites) intertidal (out of the water) walker that has a Yes the range, timing or tide and other waterbird narrow range of food prey requirements and is considered totally reliant on wetland intensity of use of areas by surveys. (and discussed in the habitats due to unsuitable surrounding habitats or is limited by habitat requirements. this species other than that 2010/2011 waterbird survey Knot mainly occurs in the middle and outer estuary along mudflats and is known to occurring from natural programme IFI) occur to the west (west embankment at Shannon Airport, Fergus River and Greenish patterns of variation Islands) of the proposed works. The works may potentially cause a disturbance to the species if disturbance was to occur during its peak wintering season (January- February).

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8.6.2.12 Dunlin [A149] Table 40 Assessment of conservation objectives and potential impacts for Dunlin [A149] Attribute Target Notes Potential Impacts Mitigation Required Population Long term population Waterbird population trends Dunlin is amber-listed in Ireland as the majority winter at less than ten sites. The project No Trend trend stable of are presented in part four of will not impact this conservation objective. increasing the conservation objectives supporting documentation Distribution No significant decrease As determined by regular low Dunlin mainly occurs in the middle and outer estuary along mudflats but few individuals Yes in the range, timing or tide and other waterbird can also be found around the city. Records (Low Tide Count, 2011) show that Dunlin has intensity of use of surveys. (and discussed in the been recorded extensively using the River Shannon Estuary for foraging, with records of areas by this species 2010/2011 waterbird survey potential roosting Dunlin along the western Bank of the River Fergus. Dunlins are a other than that programme IFI) wintering species. The study area is of some importance to this species as indicated by the occurring from natural MKO (2019) study (site OH510 and OH512 proportional high and moderate importance patterns of variation respectively). There has been no record of this species during IWeBS counts for the species in the lagoon from 2012/2013 to present, save 2017/18 (peak count = 10). The works could potentially cause a disturbance to the species if disturbance was to occur during its peak wintering season (December-January).

8.6.2.13 Black-tailed Godwit [A156] Table 41 Assessment of conservation objectives and potential impacts for Black-tailed Godwit [A156] Attribute Target Notes Potential Impacts Mitigation Required Population Long term population Waterbird population trends High proportional use of subsites OH509 and OH5010 (western embankment) and Yes Trend trend stable of are presented in part four of moderate proportional subsite use at 0H510 and OH512 was recorded by this species increasing the conservation objectives during the MKO (2019) study, so the project could impact this measure if there was a supporting documentation deterioration in water quality, or if the species was subject to disturbance during its peak wintering season (December-January). Distribution No significant decrease As determined by regular low This species is a localised (50-100 sites) intertidal (out of the water) walker that has wide Yes in the range, timing or tide and other waterbird food prey requirements and is considered highly likely to use alternative habitats. It was intensity of use of surveys. (and discussed in the recorde at 57 sites during the MKO (2019) study. These birds have wide prey food

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areas by this species 2010/2011 waterbird survey requirements and feed on intertidal mudflats, brackish pools, and rough grassland. This other than that programme IFI) species occurs primarily west of the site, but has been recorded to use the area directly occurring from natural adjacent to the proposed works on the embankments (Low Tide Count, October 2010). patterns of variation Birds arrive in September and October. There is the potential for disturbance impacts and water quality impacts.

8.6.2.14 Bar-tailed Godwit [A157] Table 42 Assessment of conservation objectives and potential impacts for Bar-tailed Godwit [A157] Attribute Target Notes Potential Impacts Mitigation Required Population Long term population Waterbird population trends The bar-tailed godwit is amber-listed in Ireland as the majority winter at less than ten No Trend trend stable of are presented in part four of sites. This species is not recorded in the area containing or surrounding the proposed increasing the conservation objectives works (MKO, 2019), which are small and localised in nature and not expected to cause supporting documentation any potential impacts on this measure. The project will not affect this conservation objective.

Distribution No significant decrease As determined by regular low This species is a localised (50-100 sites) intertidal mudflat (out of the water) walker that No in the range, timing or tide and other waterbird has wide food prey requirements and is considered a wide-ranging species that likely intensity of use of surveys. (and discussed in the uses a range of alternative habitats. No observations of this species were recorded near areas by this species 2010/2011 waterbird survey the project site during the 2010/2011 High and Low Tide Counts. There has been no other than that programme IFI) record of this species during IWeBS counts for the species in the lagoon since 2012/2013 occurring from natural (peal count = 3). patterns of variation

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8.6.2.15 Curlew [A160] Table 43 Assessment of conservation objectives and potential impacts for Curlew [A160] Attribute Target Notes Potential Impacts Mitigation Required Population Long term population Waterbird population trends Curlew is red-listed due to a long-term decline in its breeding and wintering population No Trend trend stable of are presented in part four of and its breeding range. Based on the observations of MKO (2019) subsites containing increasing the conservation objectives and/or adjacent to the proposed development are vary from moderate to no supporting documentation proportional use. The species is widespread with wide food prey requirements and is considered reliant on the sites upon which is occurs buts is likely to use alternative habitats where required. The project will not affect this conservation objective. Distribution No significant decrease As determined by regular low Curlew winter in the estuary and coastal grasslands and feed on intertidal mudflats. They No in the range, timing or tide and other waterbird nest in bogs, damp meadows and farmland (Dempsey and O’Cleary, 2002), therefore, intensity of use of surveys breeding curlew will not be significantly impacted by the proposal. The site is designated areas by this species for wintering curlew which is a widespread (200-300 sites) intertidal walker that has a other than that wide food prey requirement and is considered highly likely to use alternative habitats. occurring from natural The works will take place outside of the wintering season; therefore, bearing all of this in patterns of variation mind, the project is not expected to significantly affect the distribution of wintering curlew.

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8.6.2.16 Redshank [A162] Table 44 Assessment of conservation objectives and potential impacts for Redshank [A162] Attribute Target Notes Potential Impacts Mitigation Required Population Long term population Waterbird population trends Redshank is red-listed due to a long-term decline in its breeding population. The project No Trend trend stable of are presented in part four of will not impact this conservation objective. increasing the conservation objectives supporting documentation Distribution No significant decrease As determined by regular low Redshank has been recorded to feed along the upper shore of the River Shannon Estuary Yes in the range, timing or tide and other waterbird and River Fergus, as-well as along muddy river channels in small numbers around the intensity of use of areas surveys (and discussed in the project site location. High proportional use of subsites OH512, moderate proportional by this species other 2010/2011 waterbird survey subsite OH510 use and Low subsubsite OH512 use was recorded by this species during than that occurring from programme IFI) the MKO (2019) study. There has been no record of this species during IWeBS counts for natural patterns of the species in the lagoon from 2012/2013, save 2017/18 (peak count = 5). The project variation could impact this measure if there was a deterioration in water quality, or if the species was subject to disturbance during its peak wintering season (November-December).

8.6.2.17 Greenshank [A164] Table 45 Assessment of conservation objectives and potential impacts Greenshank [A164] Attribute Target Notes Potential Impacts Mitigation Required Population Long term population Waterbird population trends Greenshank is green-listed for its wintering population. It was moved from the amber to No Trend trend stable of are presented in part four of the green list in BoCCI3 as 50% of the wintering population occurs at more than ten sites. increasing the conservation objectives This species is not recorded in the area containing or surrounding the proposed works supporting documentation (MKO, 2019), which are small and localised in nature and not expected to cause any potential impacts on this measure. The project will not impact this conservation objective. Distribution No significant decrease As determined by regular low It winters mainly on estuaries within some along non-estuarine coasts. It feeds in shallow No in the range, timing or tide and other waterbird water and soft mud. This species is an intermediate (100-200 sites) intertidal walker (in intensity of use of areas surveys. (and discussed in the water) that has wide food prey requirements and is considered totally reliant on wetland by this species other 2010/2011 waterbird survey habitats due to unsuitable surrounding habitats or is limited by habitat requirements. It

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Attribute Target Notes Potential Impacts Mitigation Required than that occurring from programme IFI) has been recorded (Low Tide Counts, 2011) in small numbers around Aughinish Island natural patterns of and along the upper Fergus River. The works will take place outside of the wintering variation season; therefore, the project will not significantly affect the population trend or distribution of wintering greenshank.

8.6.2.18 Black-headed Gull [A179] Table 46 Assessment of conservation objectives and potential impacts for Black-headed Gull [A179] Attribute Target Notes Potential Impacts Mitigation Required Population Long term population Waterbird population trends Black-headed gull is red-listed due to a long-term decline in its breeding population. The No Trend trend stable of are presented in part four of project will not impact this conservation objective. Based on the MKO (2019) increasing the conservation objectives observations in the area surrounding the proposed development, subsite proportional supporting documentation use varies from low to high for Black-headed Gull. The project will not impact this conservation objective, taking into account of its likelihoood to use alternative habitats wide prey requirements, and broad trophic guild. Distribution No significant decrease As determined by regular low A widespread species in Ireland, this species is can be found in the summer, is a water No in the range, timing or tide and other waterbird column diver, an intertidal walker both in and out of the water and a terrestrial walker. It intensity of use of areas surveys. (and discussed in the has a wide food prey requirement and is considered highly likely to use alternative by this species other 2010/2011 waterbird survey habitats. The site is designated for wintering black-headed gull. Black-headed gull are than that occurring from programme IFI) widespread during the winter along the coast and inland. They are a very common natural patterns of widespread breeding species nesting in colonies in sand dunes, coastal islands, moorland variation polls, bogs and on freshwater lake islands (Dempsey and O’Cleary, 2002) and have been recorded extensively using the habitats from Limerick City as far as Poulnasherry Bay.

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8.6.2.19 Wetlands [A999] Table 47 Assessment of conservation objectives and potential impacts to wetlands [A999] Attribute Target Notes Potential Impacts Mitigation Required Wetland The permanent area The wetland habitat area was There will be a loss Yes habitat occupied by the wetland estimated as 32,261 hectares of ca. 0.4ha of area habitat should be stable using OSI data and relevant mudflat habitat. To and not significantly less ortho-photographs. For ensure that no area than the area of 32,261 further information see part in addition to this is hectares, other than that three of the conservation lost will require occurring form natural objectives supporting mitigation. patterns of variation document.

8.7 ASSESSMENT OF POTENTIALLY SIGNIFICANT CUMULATIVE EFFECTS NPWS have identified the main threats to the SAC from agriculture sources (fertilisation, grazing), urbanisation, residential and commercial development, and reclamation of land.

The current pressures on the Shannon River catchment include discharges to waters from the WWTP, industrial licensed sites and ongoing activities. These are set out in a local context in Section 6 above. There is potential for cumulative effects from these pressures on water quality during the construction phase of the project. The proposed development works do not pose a significant cumulative impact on water quality however. This assessment is based on the proposed works being limited in spatial extent and low magnitude of water quality impacts. This takes into account the large tidal exchange rates coupled with temporal nature of works (i.e. taking between 6 – 9 months). Climate is an important environmental influence on ecosystems. Changing climate affects ecosystems in a variety of ways. For instance, warming may force species to migrate to higher latitudes or higher elevations where temperatures are more conducive to their survival. Similarly, as sea level rises, saltwater intrusion into a freshwater system may force some key species to relocate or die, thus removing predators or prey that are critical in the existing food chain.

Climate change not only affects ecosystems and species directly, it also interacts with other human stressors such as development. Although some stressors cause only minor impacts when acting alone, their cumulative impact may lead to dramatic ecological changes (Settele et al, 2014). For instance, climate change may exacerbate the stress that land development places on fragile coastal areas. Additionally, recently reclaimed land near watercourses within and upstream of the Lower River Shannon cSAC may become vulnerable to erosion if climate change leads to increases in heavy rain storms.

Because species differ in their ability to adjust, asynchronies can develop, increasing species and ecosystem vulnerability. These asynchronies can include mismatches in the timing of migration, breeding, pest avoidance, and food availability. Growth and survival are reduced when migrants arrive at a location before or after food sources are present (Horton et al. 2014).

Ecosystems can serve as natural buffers from extreme events such as wildfires, flooding, and drought. Climate change and human modification may restrict ecosystems’ ability to temper the

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Climate change and shifts in ecological conditions could support the spread of pathogens, parasites, diseases and non-native biota, with potentially serious effects on agriculture and aquatic ecosystems.

NPWS list the threats, pressures and activities with high effect on the Lower River Shannon cSAC. Among these are invasive non-native species, also known as alien invasive species (IAS). Invasive non-native plant and animal species are the second greatest threat to biodiversity worldwide after habitat destruction. They can negatively impact on native species, can transform habitats and threaten whole ecosystems causing serious problems to the environment.

Most of Atlantic salt marsh in the Shannon Estuary is bounded on its seaward side by the extensive Common cordgrass Spartina anglica sward. Spartina was introduced during the 1940s to increase sediment accretion in coastal protection schemes (Bleakley 1979). It has been effective in this respect. In the past Spartina has been associated with lowering invertebrate faunal diversities and densities and changing the course of mudflat-saltmarsh succession by altering plant communities, although there is recent controversy regarding these effects (McCorrey et al. 2003). Spartina replaces the mudflat habitat with a less diverse, monospecific sward and subsequently reduces the intertidal feeding ground for waders and other birds. Mud and saltflat communities based on bottom-dwelling microalgae will decline, being replaced by food webs driven by the supply of Spartina detritus. Spartina also alters the physical shape of coastal areas. Prior to colonization, in areas where the norm is gently-sloping mudflats and shallow estuaries, Spartina alters the landscape to form badly drained marshes that commonly have steeply sloping seaward edges and deep, steep- sided channels (McCorrey et al. 2003). The proposed development is not considered to represent a risk to the spread of Spartina, but there is potential for importation of other IAS to the works site.

The Urlan Beg stream and other surface waters to the north of the embankments in the study area drain predominantly urban lands. These lands include housing estates, light industry, roadways and Shannon Airport (pavements, hydrocarbon storage and waste water treatment). Most surface drainage in this area finds its way to the Shannon Estuary via sluices through the embankments. Ongoing discharge of waters carrying deleterious substances represent a water quality pressure to the habitats and fauna of the estuary in proximity to the Airport and also to the lagoon. With the mitigation, the proposed development will not pose a significant cumulative water quality pressure.

9 MITIGATION The key to avoid impacts to water during the works is good site management practices, tight controls, regular inspections and ongoing vigilance with staff and employees on site.

In order to avoid or reduce the risks associated with the potential impacts, the mitigation measures described below will be followed to reduce impact significance and adhere with the conservation objectives for the Lower River Shannon cSAC.

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A Construction Environmental Management Plan (CEMP) will be prepared by the appointed contractor for the project in advance of works commencing, which will include management and control measures for noise, dust, traffic, waste and surface run-off. It will describe the construction practices and environmental management measures which are to be implemented during the construction phase of the project in order to ensure that the project is constructed in accordance with best practice, with the minimum impact on the surrounding environment and to comply with any planning conditions. The CEMP will be fully implemented by the appointed contractor and audited by the project ecologist during the project to ensure there are no significant negative impacts.

A concise list of the primary mitigation measures are outlined in Appendix 3 (Outline Construction Environment Management Plan). Implementation of the full mitigation will be required by the appointed contractor however by working in accordance with method statements.

At a minimum, the project characteristics listed above in Section 4.4 will be implemented to reduce impacts. The following additional measures will also be undertaken.

9.1.1 CEMP and Method statements An outline Construction and Environmental Management Plan (CEMP) has been prepared by Malachy Walsh and Partners for the proposed embankments refurbishments (Appendix 3). This outline CEMP summaries construction practices and includes the Environmental Management measures which are to be implemented during the construction phase of the project to ensure that it is constructed in accordance with best practice, with minimum impact on the surrounding environment and in adherence with all environmental protection measures.

It should be noted that the outline CEMP is a live document that will be updated by project engineers and the project ecologist for amendment/agreement throughout the pre-construction phase of the project. Upon agreement with Clare County Council, this plan will be finalised and presented to the Project Contractors upon appointment. All works will take place according to the final approved CEMP, including the exact detail of each aspect and timing of works. Any subsequent update to the CEMP will be by improvement only. The proposed mitigation measures hereunder and method statements are incorporated into the outline CEMP.

Method statements will be prepared by the appointed contractor. Method statements will be used to translate the project requirements into planned systems of work instructions to the site staff and operatives. They are prepared for activities identified in the specification and risk assessments and are issued to all personnel responsible for and involved with the activity concerned. They define the proposed method of working for an element or section of work taking into account the particular requirements of the project including site conditions, safety hazards, the contract drawings, specification or code of practice. They define the proposed use of plant, labour and materials, any hold points or permits and may be supplemented by drawings, sketches and produce data as necessary.

The principle aim of a method statement is to ensure that:

 Resources are available prior to start;  Tasks are thought out in advance; and

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 Safe working methods are defined, and workers involved are aware of the risks associated with the task.

9.1.2 Protection of Habitats To describe the measures for the management and protection of habitats on the site, the following measures will be put in place to minimise any disturbance or impact.

 Minimise the ‘footprint’ of the development to avoid impacting the lagoon and reduce insofar as possible the extent of mudflat directly affected;  The drainage channels connected to the Shannon Airport lagoon will be avoided according to Sections 9.1.5 and 9.1.6;  Machinery required for the works will either be located on the crest of existing embankments or will track along the sections of completed works. Plant movement will be restricted to the embankment and the footprint of the works. Plant and vehicle movement will be precluded on the adjacent shoreline due to ground conditions;  Several (perhaps 3) ramps will be constructed along the access road of both embankments. These ramps will be used primarily to bring materials to the top of the embankments, and potentially for future maintenance works;  Access to the proposed development site will be from the local road network;  The site compounds will consist of bunded areas for storage of machinery and material. Temporary secured cabins, toilets and other materials and machinery will also be stored/located in this area. The site compound and machinery etc. will be secured at times when construction staff are not present on site; and  The access from the local road to the site compound, the site compound, and the works area required to carry out construction will be demarcated by secure stakes and robust high visibility tape prior to construction. This layout will be decided to ensure habitats of conservation interest will be avoided insofar as possible. Tracking of machinery, storage and site personnel etc. will be confined to the agreed demarcated boundaries for the duration of the construction stage of the project.

The proposed development will be constructed in cognisance of the following guidelines to minimise the impact on the Shannon Estuary:

 'Guidelines on Protection of Fisheries during Construction Works in and Adjacent to Waters' (IFI, 2016); and  'Control of water pollution from construction sites - Guidance for consultants and contractors' (Masters-Williams et al. 2001).

9.1.3 Project Ecologist A project ecologist will be appointed to monitor the works on a weekly basis for the full duration of the project. The project ecologist shall induct all construction members via ‘tool box talks’ making them aware of the method statement and the sensitivities of the site before they are allowed to access the site. The project ecologist will check that relevant staff are familiar with emergency response procedures and trained in the use of spill kits. Toolbox talks will be undertaken on a weekly

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The project ecologist will have the authority to suspend works if works are not being carried out in line with the agreed method statement or daily monitoring indicates that the proposed measures are not functioning adequately to minimise the potential impact to local ecology.

9.1.4 Temporary Construction Compound(s) The following measures will be undertaken to avoid or minimise negative effects to water quality as a result of the erection of the temporary compound:

 Drainage within the temporary site compound will be directed to an oil interceptor to prevent pollution if any spillage occur;  Temporary toilet facilities will be connected to the public sewer network during the construction phase, alternatively, discharges from the toilets will go to a holding tank where the effluent will be temporarily stored and removed at regular intervals by an appropriate permitted/licensed and approved contractor;  A bunded containment area will be provided within the compound for the storage of fuels, lubricants, oils etc; and  The site compound will be in place for the duration of the construction phase and will be removed once the project is complete.

9.1.5 Excavation and Embankment Works Excavations will take place at the seaward side of the eastern embankment and the landward side of the western embankment. The following measures will be undertaken to avoid or minimise negative effects on habitats and to water quality and as a result of excavations:

 Areas to be excavated will be clearly marked prior to excavations taking place to avoid unnecessary excavation. The demarcated site boundary will be agreed with the site ecologist. Saltmarsh will be avoided. Machinery will not be permitted breach these agreed boundaries, or materials (including excavated soil) will not be stored in areas where runoff caused by precipitation can be conveyed to saltmarsh;  There will be no interference with the drainage channel through the western embankment that links the Airport lagoon to the Shannon Estuary. Works in this area will be carried out in an especially sensitive manner to preserve the potential function of the sluice gate;  Drainage and associated pollution control measures will be implemented on site before the main body of construction activity commences;  Turf and top-soil will only be removed from the section of the embankment being worked on (estimated length of sections to be worked on at a time approx. 50m);  Geo-textile will be laid over coming days so denuded embankment will not be left exposed for any extended period;  The timing of the construction phase soil stripping and excavation works will take account of predicted weather, particularly rainfall;  Excavations and soil stripping activities will be suspended during periods of prolonged rainfall events;

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 The earthworks materials will be placed and compacted in layers to prevent water ingress and degradation of the material;  The 24 hour advance meteorological forecasting service from Met Éireann will be used; and  In the event that petroleum contaminated soils or subsoils containing other potentially contaminated material are discovered during excavation activities (identified through staining, discoloration, or odour), this soil will be segregated, stockpiled, sampled for characterisation purposes sufficient to meet the requirements of the applicable disposal facility, transported off-site by a licensed transporter, and disposed of in an approved treatment or disposal facility;  Careful planning of excavations will be required in the intertidal zone to limit erosion of intertidal substrates – this may require protection of excavated areas from incoming/receding tides;  Excess sediment will require storage. This sediment and other excavated material will be stored in bunded areas within the site for later use or removed from the site;  Any organically rich and/or anoxic substrates excavated will be segregated and stored in a bunded area within the site for later removal or removed immediately from the site to a location approved by Clare Co. Co;  The timing of excavations will be such that they are carried out as required, not weeks in advance, as spring tides will occur bi-weekly and high tides will occur daily;  Works adjacent to saltmarsh will be carried out during dry weather and will be monitored by the site ecologist;  In the case of the 100m section where armorflex or similar is proposed, turf and topsoil will have been removed from the existing embankment, stored and replaced on the newly armoured crest and backslope;  In this area, turf will be removed in strips of size suitable for transport. Strips will be rolled onto stakes in a fashion similar to the manner roll out turf/lawn is packaged31. If not being used to cover the armorflex within 2 days, turf will be rolled out to preserve floral cover. The soil/turf removed will be placed at the landward side of the embankment until used. This aspect of the work will be monitored by the project ecologist;  The armourflexing material will be placed on the embankment which is at a location outside of the SAC and SPA. With the planned methodology, this component of the work will not result in any direct or indirect impacts on the SAC;  Excavations will be carried out in a manner that prevents uncontrolled flows between the lagoon and the sea;  There will be no interference with drainage channels adjacent to the lagoon;  All site excavations will be supervised by the Construction and/or Environmental Manager and inspected by the Site Ecologist; and  The Construction and/or Environmental Manager will oversee the phasing of the excavation and machinery movement across the site.

9.1.6 Storage and Stockpiles of Excavated Material The following measures will be undertaken to avoid or minimise negative effects to water quality as a result of the storage and stockpiling of excavated earth:

31 https://www.landscapedepot.ie/product/roll-out-turf/

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 Temporary stockpiles of excavated earth will be constructed within the lands made available;  Stockpiles of stripped soil will be strored in locations with minimum trafficking to prevent damage and dusting;  Stockpiled sub-soils will be located at suitably sheltered areas to prevent erosion or weathering and shall be shaped to ensure rainfall does not degrade the stored material;  Where unsuitable material is encountered this will be stockpiled separately and removed in accordance with a the Waste Method Statement;  Stockpiles will be located away from drainage systems and silt retaining measures (silt fence, / silt curtain or other suitable materials) and shall be installed along the down-gradient edges of stockpiled earth materials to reduce risk of silt run-off;  All excavated materials from the site or introduced materials for construction will be either used or removed from the site;  No permanent spoil or stockpiles will be left on site, other than those materials required for landscaping, berm construction and construction generally;  At the eastern embankment, there will be no stockpiling or storage of materials within 5m of the drainage channel that runs to the north and parallel to the embankment;  At the western embankment, there will be no stockpiling or storage of materials within 10m of drainage channels or within wetland habitats associated with the lagoon (drainage channels, reedbeds); and  Construction personnel will be informed of the measures to prevent pollution of transitional waters.

9.1.7 Storage of Other Materials The storage of materials, containers, and waste, however temporary, should follow best practice at all times and be stored at designated areas. Storage will be located as follows:

 Away from drains and any watercourses or drains;  Fuel oils etc. should be stored on a sheltered dry elevated site well removed from aquatic zones;  On an impermeable base;  Well away from moving plant, machinery and vehicles;  On land not required until later in the development;  Hazardous material storage areas will be identified, labelled, and properly marked and fitted with spill containment systems;  The scale of potential impacts on water quality will be reduced by only storing the required volume of oils for the works taking place at the time;  Access to oil stores will be controlled by only storing oils within a secure steel container located in the site compound;  Collision with oil stores will be prevented by storing oils within a steel container in a designated area of the site compound away from vehicle movements;  Leakages of oil from oil stores will be prevented by storing these oils in secure bunded areas which have a capacity of 110% of the total volume of the stored oil. Ancillary equipment

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such as hoses and pipes will be contained within the bunded storage container. Taps, nozzles or valves will be fitted with a lock system;  Major leakages will be prevented through monitoring oil storage tanks/drums for leaks and signs of damage;  Long term storage of waste oils will not be allowed on site. These waste oils will be collected in leak-proof containers and removed from the site for disposal or re-cycling by an approved service provider; and  All containers will be stored upright and clearly labelled. Sufficient storage should be supplied near to all working areas.

9.1.8 Timing of Works The Shannon Estuary is known to support an array of wintering waterbirds listed as special conservation interests in the River Shannon and River Fergus Estuaries SPA.

To reduce the potential for disturbance impacts on wintering birds foraging on mudflats, it is recommended that the works are carried out between February and October inclusive. This timing is in cognisance that the works are expected to last 6 - 9 months and that most birds of conservation interest’ peak foraging activity is during the winter months (e.g. Shoveler, Wigeon, Shelduck, Pintail, Teal, Scaup, Lapwing).

Works will be carried out during daylight hours.

The works at the toe of the eastern embankment is within the intertidal zone during all stages of the tidal cycle, perhaps with the exception of neap tides. To further reduce the potential for disturbance impacts on avifauna, the proposed 50m works sections along the toe of the embankments will be carried out as promptly as possible when the tide is low, so that works at higher elevations can be carried out at times when the tide has covered mudflats and consequently birds are not foraging.

9.1.9 Hydrocarbon Control  Fuels/oils etc will be stored within a bunded area in the enclosed compound along with tools, materials etc. All plant is to be refuelled in this compound and a drip tray fitted to any stationary plant working in proximity to surface waters.  All equipment will be in good condition to avoid spillage or discharge of oil, smoke and excessive noise.  An appropriate waste container will be placed at a suitable location at the harbour to collect waste before disposal by an authorised company.  Refuelling will be carried out by competent and trained people away from any environmentally sensitive areas; and dredger to be moored up securely.  Excavators and other equipment will be checked for any fuel/oil leaks on a regular basis by the crew.  Any spills we be reported immediately to the site agent/authorities.  Use absorbent materials from the spill kit to mop up the spill (sand or absorbent materials will be used rather than detergents).  Place boom around any affected water as a precaution.  Do not wash spillage. Washing will only make the situation worse and disperse the pollutant

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 Shovel contaminated sand/earth/absorbent granules into sacks or skips and  A specialist oil removal company or contaminated soil company will remove pooled oil and/or soils contaminated oil.

9.1.10 Waste Management To contain and manage construction phase waste, two types of skip will be provided at the site compound; one for recyclable waste and others for various construction wastes. These skips will be emptied when required by a licensed waste management company.

Any waste lubricants/oils will be collected and stored in drums in the site compound within a prefabricated bunded storage unit and will be removed and disposed of by a licensed waste management company without delay.

There will be no discharge of effluent or waste water on site. Waste water tank and sewage will be emptied as required and removed from site to a licensed facility. These staff facilities will be removed at the end of the construction phase.

9.1.11 Emergency Response Plan This mitigation section describes measures for the prevention of an environmental accident or incident and the response required to minimise the impact of such an event.

All site personnel will be inducted in the provisions of the Emergency Response Plan. In the event of an environmental emergency, all personnel will react quickly and adhere to this procedure. The following outlines some of the information, on the types of emergency, which must be communicated to site staff:

 Release of hazardous substance - fuel or oil spill;  Flood event – extreme rainfall event;  Environmental buffers and exclusion zones breach;  Housekeeping of materials and waste storage areas breach;  Stop works order; due to environmental issue or concern (threat to archaeological or ecological feature) and  Fire on site (cross-reference site Safety Emergency Plan as appropriate).

If any of the above situations occur; the Emergency Response Plan is activated. The Project Environmental Manager will most likely be responsible for overseeing the Emergency Response Plan (to be confirmed upon appointment of Contractor) and will be prepared and ready to implement the plan at all times. The Project Environmental Manager will be immediately informed and report to the scene. He/she must be aware of the

 Nature of the situation – brief description of what has happened;  Location of the incident;  Whether any spill has been released; and  Whether the situation is under control.

The Emergency Response Plan must be completed by the appointed Contractor.

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9.1.11.1 Contacts As an Environmental Control Measure, the Project Environmental Manager will append the relevant contact details to the Emergency Response Plan document. Examples of such contact details include:

 Environmental Manager;  Specialist oil removal Company;  SAA Safety Compliance and Environment Manager;  Specialist oil removal Company;  Clare County Council;  Inland Fisheries Ireland; and  National Parks and Wildlife Service.

9.1.11.2 Oil Leakages

 To minimise the potential for water quality impacts, the bunded refuelling areas will be used for overnight parking of excavators and dump trucks;  Potential leaks from delivery vehicles will be reduced by visually inspecting all delivery vehicles for major leaks. Contractors supplying concrete and crushed stone to the site will be contractually required to supply their products using roadworthy vehicles;  Potential leaks from any other plant used will be mitigated by contractually requiring the suppler to supply plant that are in good working order, up to date in servicing and free of leaks;  Should there be an oil leak or spill, the leak or spill will be contained immediately using oil spill kits; preferential pathways will be blocked with an oil absorbent boom until the fuel/oil spill has been cleaned up and all oil and any contaminated material removed from the area. This contaminated material will be properly disposed of in a licensed facility;  The Environmental Manager will be immediately informed of the oil leak/spill, and will assess the cause and the management of the clean-up of the leak or spill. They will inspect nearby drains for the presence of oil, and initiate the clean-up if necessary;  Immediate action will be facilitated by easy access to oil spill kits. An oil spill kit that includes absorbing pads and socks will be kept at the site compound and also in all site vehicles and machinery;  Correct action in the event of a leak or spill will be facilitated by training all vehicle/machinery operators in the use of the spill kits and the correct containment and cleaning up of oil spills or leaks. This training will be provided by the Environmental Manager at site induction; and  In the event of a major oil spill, a company who provide a rapid response emergency service for major fuel spills will be immediately called for assistance, their contact details will be kept in the site office and in the spill kits kept in site vehicles and machinery.

9.1.11.3 Location of Emergency Spill Kits

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 A map indicating the location of all emergency spill kits will be attached to the Emergency Response Plan document; and  Emergency oil spill kits will also be carried in all site vehicles and machinery and in the site office.

9.1.11.4 Responsibility  The Project Environmental Manager will prepare and finalise an Emergency Response Plan to be ready to respond to any incident;  All site personnel will report any spillages of oil or chemicals to the Project Environmental Manager and Construction Manager immediately; and  As appropriate, the Project Environmental Manager will report the spillage to the western RBD of IFI, local authority and any other relevant authority.

9.1.12 Construction Noise Noise during construction can cause disturbance of birds and other fauna. Measures for the management of impacts from construction noise are as follows:

 Where reasonably practicable, noisy plant or processes will be replaced by less noisy alternatives;  Plant will be properly and regularly maintained;  Compressors, if needed, will be ‘sound related’ models fitted with properly lined and sealed acoustic covers which will be kept closed whenever machines are in use; and  All vehicles and mechanical plant will be fitted with effective exhaust silencers.

9.1.13 Otters A preconstruction otter survey will be carried out in advance of the works to check the proposed development site for otter dwellings. This survey will be carried out by a suitable qualified ecologist. Methodology will follow Monitoring the Otter Lutra lutra by Chanin (2003b). Should a holt be found, protocols for otters will follow Guidelines for the Treatment of Otters prior to the Construction of National Road Schemes (NRA, 2008).

9.1.14 Invasive Species Control Common Cord-grass (Spartina anglica) is abundant along the outer edges of each of the Salt Marsh habitat adjacent to the eastern embankment. The following measures will be put in place to risk of spread and importation of non-native and invasive species:

 All plant and equipment will be checked for attached debris or plant fragments, and if present, these will require power washing prior to entry to site;  If soil is imported to the site for landscaping or embankments, the Contractor shall gain documentation from suppliers that it is free from non-native invasive species;  All plant and equipment will be similarly checked prior to leaving the site, and subsequently properly cleaned if required;  Any areas identified as supporting non-native plants will need to be treated in accordance with established non-native species control guidance;  There will be no excavations within saltmarsh habitat;

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 Non-native species control prevention will be in accordance with NRA (2010) and IFI guidelines32;  The use of equipment that has been used in known infested waters will be avoided;  Measures in the guidelines issued by the National Roads Authority – The Management of Noxious Weeds and Non-native Invasive Plant Species on National Roads (NRA 2010) will be followed to avoid the spread of invasive alien species; and  The IFI documents ‘Invasive species biosecurity guidelines for boaters’ (IFI, 2013)33 and ‘IFI Biosecurity Protocol for Field Survey Work (IFI, 2010)34 will be available at the site compound for the duration of the works. The above guidance documents outline the necessary measures for all staff in contact with the water or using equipment in contact with water. The protocols in these documents and will form the basis of biosecurity in the lagoon during the proposed works.

10 RESIDUAL IMPACTS The residual impacts are the expected impacts that remain after the proposal has been applied and mitigation has been taken into account.

With the proposed refurbishment works, there is a risk to habitats, water quality and birds (disturbance, displacement and impacts to water quality/food sources). A list of mitigation measures has been developed however upon which Method Statements have been devised to reduce environmental risks. Construction and environmental management organisational structure, as well as duties and responsibilities assigned to specific staff undertaking the works to ensure mitigation implementation, in accordance with the CEMP. The contractor will adhere to a range of environmental commitments, including sediment and erosion control measures for the management of water quality and run-off on the site. Other environmental commitments include excavated materials and spoil management, appropriate timing of the works, hydrocarbon control, an emergency response plan, site training and environmental awareness, waste management, and minimising construction noise.

A summary of residual impacts on conservation objectives of Natura 2000 sites potentially affected by the proposed development are provided in Table 53 – Table 79 for the two Natura 2000 sites considered in this report.

10.1.1 Lower River Shannon cSAC The area of overlap between ‘estuaries’ [1130] (inclusive of ‘mudflats and sand flats not covered by seawater at low tide [1140]) and the proposed development will be approximately 0.4ha. With reference to the Conservation objectives for the Lower River Shannon cSAC (NPWS, 2012), the attribute ‘habitat area’ for estuaries is that ‘the permanent habitat area is stable or increasing, subject to natural processes’. EC (2006) states that ‘any element of a plan or project that has the potential to affect the conservation objectives of a Natura 2000 site should be considered

32 https://www.fisheriesireland.ie/Biosecurity/biosecurity.html 33 https://www.fisheriesireland.ie/extranet/invasive-species-1/360-invasive-species-biosecurity-guidelines-for- boaters-leaflet-1.html 34 https://www.fisheriesireland.ie/component/docman/?task=doc_download&gid=73&Itemid=

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As indicated in EC (2002) and DoEHLG (2009) however, a common means of determining the significance of effects is through the use of key indicators, where examples of indicators with suggestions as to how they can be used are provided (see Table 51). It is considered that the significant indicator ‘loss of habitat area’ is applicable to the current project as the proposed development will incur habitat loss. Table 52 gives the intertidal habitats directly affected by the proposed development and percentage loss within the Lower River Shannon cSAC. Approximately 0.0016% and 0.0045% of mapped ‘estuaries’ and ‘mudflat and sand flats not covered by seawater at low tide’ habitats within the SAC would be lost respectively. In the overall context of the Lower River Shannon SAC, these fractions are minute. Any habitat loss would occur for much of the length of the embankment some 5m seawards at the front of the existing embankment toe. The fact that the area affected is linear and abuts an existing artificial structure decreases the magnitude impact for a number of reasons as follows:

 it would not incur partitioning of habitats;  the mudflats adjacent to the embankment are at the periphery of the wider mudflat environment, and have developed/evolved at the upper boundary of the SAC, and as such are of lower value than the mudflat biotope in the wider area.

EC (2002) point out that some indicators, such as percentage of habitat lost, may be more significant for priority habitat types than for others because of their status. EC (2018) state that significance will vary depending on factors such as magnitude of impact, type, extent, duration, intensity, timing, probability, cumulative effects and the vulnerability of the habitats and species concerned. Against this background, it is clear that what may be significant in relation to one site may not be in relation to another. In the current case, the significance of effects on 1130 and 1440 habitats have been determined in relation to environmental conditions and ecological characteristics. While there is a need for objectivity in interpreting the scope of the term ‘significant’ (EC, 2018), clearly such objectivity cannot be divorced from the specific features and environmental conditions of the protected site concerned by the plan or project. In this regard, the conservation objectives of a site as well as prior or baseline information about it can be very important in more precisely identifying conservation sensitivities (EC, 2018). Taking into account the areas and percentages of the habitats concerned, the location of the habitats affected (next to a reclaimed area) and the linear nature of the development, the impact on the Lower River Shannon cSAC is not deemed significant. This statement is made with reference to the concept of objectivity in determining significance of impact, as per EC (2018).

Table 48 Example of a significance indicator (from EC, 2002). Impact type Significance indicator Loss of habitat area Percentage of loss

Table 49 Intertidal habitats directly affected and percentage loss within the Lower River Shannon cSAC.

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Habitat Estuaries [1130] Mudflats and sand flats not covered by seawater at low tide [1140] Area (from Conservation objectives 24,273 (using OSI data and the Transitional 8,808 (using OSI data) for Lower River Shannon SAC) Water Body area as defined under the Water (ha) Framework Directive) Area directly affected by proposed 0.4 0.4 development (ha) % area directly affected by 0.00165 0.00454 proposed development

The overall conservation status of Estuaries has been assessed as Unfavourable-Inadequate. The principal reason for the failure of the habitat to meet Favourable Conservation Status was a change in sediment composition. The large area of the total national resource of the Estuary habitat within Lower River Shannon SAC, where a change in sediment composition was recorded, was a significant factor in the overall failure of the habitat to meet Favourable Conservation Status. It is considered highly likely that the pressures recorded have resulted from increased sedimentation. Estuaries surrounded by urban settlements are vulnerable to the impact of run-off from storm water; they are also impacted by waste water discharge in these areas in Ireland. Those surrounded by, and downstream of, areas of intensive agriculture and/or commercial forestry operations are frequently impacted by the increased sediment input caused by this activity.

The overall trend in conservation status for mudflats and sand flats not covered by seawater at low tide’ is ‘deteriorating’. The principal reason for the failure of the habitat to meet Favourable Conservation Status was a change in sediment composition (two sites) and an increase, or potential for increase, of alien invasive species (one site). It is considered highly likely that the pressures recorded have resulted from increased sedimentation. Mudflats are vulnerable to increased sediment loads, resulting from activities upstream of rivers, entering a bay. The most likely cause of these increased sediment loads is considered to be a combination of the discharge of untreated effluent and intensive agriculture (NPWS, 2019).

It is concluded that there will be no significant cumulative/in combination impacts on ‘estuaries’ and ‘mudflats and sandflats not covered by seawater at low tide’ associated with the proposed development.

Since it is not a sedimentary percolating waterbody, the proper function of Shannon Airport lagoon is based on maintenance of flow from the estuary to/from the lagoon through a sluice gate. Salinity is probably the most important variable in the classification of lagoon types (Roden and Oliver, 2010). This long-term trend will not be altered by the proposed development. The top of the western embankment was breached and saline water entered the lagoon during the winter storms of 2013/2014. This was an unusual event. The proposed works to the crest of the embankment will not significantly change the likelihood of overtopping post works.

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Table 50 Summary of residual impacts of the proposed embankments refurbishment project on ‘estuaries’ in the lower River Shannon SAC Attribute/ Target Summary of impact Mitigation summary Summary of residual impact Measure Habitat Area stable or increasing, subject The project will result in loss of ca. 0.4ha of effective Working within discrete The area of overlap between the area/ to natural processes estuarine habitat with the additional rock armouring to the marked-out boundaries, proposed excavation works/rock hectares seaward side of the eastern embankment. Mudflat habitat controlled excavation and armour installation and ‘estuaries’ will be replaced by embankment of a type similar to existing. appropriate storage/ represents approximately With inappropriate site management, there is potential for stockpiling of material. 0.00165% of the overall estimated additional habitat loss and/or disturbance and/or alteration. Water quality area of this conservation interest. preservation, waste This loss cannot be avoided under management, Emergency the current proposal. In the response plan and overall context of the SAC, the adhering to a CEMP during impact of the proposed the works. development is not considered significant however, for reasons outlined above (Section 10.1.1). Community Conserve the following The proposed development occurs in an area within (eastern Working within discrete The area of overlap between the distribution/ community types in a natural embankment) and adjacent to (western embankment) the marked-out boundaries, proposed excavation works/rock hectares condition: Intertidal sand to community type ‘Intertidal sand to mixed sediment with controlled excavation and armour installation and ‘estuaries’ mixed sediment with polychaetes, polychaetes, molluscs and crustaceans community complex’. appropriate storage/ represents approximately molluscs and crustaceans The project will result in loss of ca. 0.4ha of the above the stockpiling of material. 0.0045% of the overall estimated community complex; Estuarine community type with the additional rock armouring to the Water quality area of this conservation interest. subtidal muddy sand to mixed seaward side of the eastern embankment. This community preservation, waste This loss cannot be avoided under sediment with gammarids type will be replaced by the additional rocks installed at the management, Emergency the current proposal. In the community complex; Subtidal eastern embankment. response plan and overall context of the SAC, the sand to mixed sediment with With inappropriate site management, there is potential for adhering to a CEMP during impact of the proposed Nucula nucleus community additional habitat loss and/or disturbance and/or alteration the works. development is not considered complex; Subtidal sand to mixed of this habitat at both eastern and western embankments. significant however, for reasons sediment with Nephtys spp. The project has the potential to result in significant water outlined above (Section 10.1.1). community complex; quality impacts which may affect the communities for which Fucoid‐dominated intertidal reef this habitat type is designated.

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Attribute/ Target Summary of impact Mitigation summary Summary of residual impact Measure community complex; Faunal turf‐dominated subtidal reef community; and Anemone dominated subtidal reef community.

Table 51 Summary of residual impacts of the proposed embankments refurbishment project on ‘mudflats and sandflats not covered by seawater at low tide’ in the lower River Shannon SAC. Attribute/ Target Summary of impact Mitigation summary Summary of residual impact Measure Habitat Area stable or The project will not result in a significant reduction in Working within discrete The area of overlap between the proposed area/ increasing, subject to area of this habitat type. The area of overlap between marked-out boundaries, excavation works/rock armour installation and hectares natural processes mapped mudflat habitat and the proposed works will controlled excavation and ‘estuaries’ represents approximately 0.0045% of be approximately 0.4ha (approximately 0.0045% of appropriate storage/ the overall estimated area of this conservation mapped mudflat habitat within the SAC). It is possible, stockpiling of material. Water interest. This loss cannot be avoided under the in the event of a poorly managed site that the quality preservation, waste current proposal. In the overall context of the impacted area is greater than that anticipated. management, Emergency SAC, the impact of the proposed development is response plan and adhering to not considered significant however, for reasons a CEMP during the works. outlined above (Section 10.1.1). At operation stage, modelling indicates that the proposed works will not have a significant impact on the morphodynamics of the adjacent mudflats. Community Conserve the following The proposed development occurs in an area within Working within discrete The area of overlap between the proposed distribution/ community types in a (eastern embankment) and adjacent to (western marked-out boundaries, excavation works/rock armour installation and hectares natural condition: embankment) the community type ‘Intertidal sand to controlled excavation and ‘estuaries’ represents approximately 0.0045% of Intertidal sand with mixed sediment with polychaetes, molluscs and appropriate storage/ the overall estimated area of this conservation Scolelepis squamata crustaceans community complex’. stockpiling of material. Water interest. This loss cannot be avoided under the and Pontocrates spp. The project will result in loss of ca. 0.4ha of the above quality preservation, waste current proposal. In the overall context of the

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Attribute/ Target Summary of impact Mitigation summary Summary of residual impact Measure community; and the community type with the additional rock management, Emergency SAC, the impact of the proposed development is Intertidal sand to armouring to the seaward side of the eastern response plan and adhering to not considered significant however, for reasons mixed sediment with embankment. This community type will be replaced by a CEMP during the works. outlined above (Section 10.1.1). polychaetes, molluscs the additional rocks installed at the eastern and crustaceans embankment. community complex. With inappropriate site management, there is potential for additional habitat loss and/or disturbance and/or alteration of this habitat at both eastern and western embankments. The project has the potential to result in significant water quality impacts which may affect the communities for which this habitat type is designated.

Table 52 Summary of residual impacts of the proposed embankments refurbishment project on ‘coastal lagoons’ in the Lower River Shannon cSAC Attribute/ Target Summary of impact Mitigation summary Summary of residual impact Measure Habitat area/ Area stable or The area of the Shannon Airport lagoon is given as There will be no infringement By avoiding lagoon and fringing wetland Hectares increasing, subject to 24.2ha. Inappropriate site management such as within the wetland associated habitats, the area of the lagoon, as mapped in natural processes. storage of excavated material could potentially with the lagoon by working the conservation objectives document for the result in a reduction wholly or in part of the within demarcated areas and site, the area of the lagoon will not be Shannon Airport Lagoon. appropriate storage of excavated decreased. material. Habitat No decline, subject to The project will not result in a decline in the None required None distribution/ natural processes distribution or occurrence of this habitat type. Occurrence Salinity Median annual Shannon Airport lagoon is classified as an None required The proposed works at the crest of the regime/ salinity and temporal Oligohaline waterbody. The project will not result embankment will not change the likelihood of Practical variation within in any change in salinity regime. The proposed overtopping of the embankment post works, salinity units natural ranges. embankment works will not change the hydraulic and the porosity of the structure will not be

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Attribute/ Target Summary of impact Mitigation summary Summary of residual impact Measure (psu) conductivity of the embankment. altered. The proposal will have no residual impact on salinity. Hydrological Annual water level The tidal regime is a very important influence on Avoid interfering with the The project will not affect the hydrological regime/ fluctuations and coastal lagoons. The lagoon and the Shannon drainage channel between the regime of the lagoon or the Shannon Estuary as metres minima within Estuary have a hydrological link via a sluice gate lagoon and the embankment there are no works at the seaward side or natural ranges. installed during creation of the lagoon. The works through proper site management lagoon side of the sluice gate could interfere with lagoon – estuary connectivity e.g. stockpiling away from the if the sluice gate was damaged due to the works. channel, careful treatment of the embankment in the environs of the drainage channel. Barrier Appropriate Connectivity between the lagoon and the sea is an Avoid interfering with the None. There will be no interference with the connectivity: hydrological important attribute of coastal lagoons. There is a drainage channel between the drainage channel through the western between connections between tidal sluice gate between the lagoon and the lagoon and the embankment embankment that links the Airport lagoon to the lagoon and lagoons and sea, Shannon Estuary, albeit redundant due to silt through proper site Shannon Estuary. sea/ including where blockage. management. Works in this area Permeability necessary, The project could disturb the existing situation or will be carried out in an especially appropriate provide further complication to connectivity sensitive manner to preserve the management. between Shannon Airport Lagoon and the sea. potential function of the sluice gate. Water quality: Annual median The construction phase of the project could Water quality preservation, With delivery of mitigation, this conservation Chlorophyll a/ chlorophyll a within potentially result in the release of waste management, Emergency objective will not be negatively affected, taking µg/L natural ranges and sediment/pollutants and affect the quality of the response plan and adhering to a into account cumulative water quality impacts. less than 5μg/L. water associated with the lagoon. CEMP during the works. Water quality: Annual median The construction phase of the project could Water quality preservation, With delivery of mitigation, this conservation Molybdate within natural ranges potentially result in the release of waste management, Emergency objective will not be negatively affected, taking Reactive and <0.1mg/l. sediment/pollutants and affect the quality of the response plan and adhering to a into account cumulative water quality impacts. Phosphorous water associated with the lagoon. CEMP during the works. (MRP)/ mg/L Water quality: Annual median The construction phase of the project could Water quality preservation, With delivery of mitigation, this conservation

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Attribute/ Target Summary of impact Mitigation summary Summary of residual impact Measure Dissolved within natural ranges potentially result in the release of waste management, Emergency objective will not be negatively affected, taking Inorganic and <0.15mg/l. sediment/pollutants and affect the quality of the response plan and adhering to a into account cumulative water quality impacts. Nitrogen water associated with the lagoon. CEMP during the works. (DIN)/ mg/L Depth of Macrophyte The project will could affect the depth of Water quality preservation, With delivery of mitigation, this conservation macrophyte colonisation to macrophyte colonisation within the lagoon in the waste management, Emergency objective will not be negatively affected, taking colonisation/ maximum depth of event of mobilisation of sediment and consequent response plan and adhering to a into account cumulative water quality impacts. Metres lagoons increase in suspended solids (decreasing light CEMP during the works. penetration). Typical plant Maintain number The project could affect the plant species typical of Water quality preservation, With delivery of mitigation, this conservation species/ and extent of listed lagoonal specialists in the event of mobilisation of waste management, Emergency objective will not be negatively affected. This Number and lagoonal specialists, sediment and consequent increase in suspended response plan and adhering to a statement takes into account cumulative water m2 subject to natural solids (decreasing light penetration). CEMP during the works. quality impacts and the poor floral diversity variation recorded by Roden (2004), the latter situation a likely result of low water levels at the time, which have largely been maintained. Typical animal Maintain listed The project could affect the typical animal species Water quality preservation, With delivery of mitigation, this conservation species/ typical lagoonal typical associated with the lagoon in the event that waste management, Emergency objective will not be negatively affected. This number specialists, subject to it impacted water quality. response plan and adhering to a statement takes into account cumulative water natural variation CEMP during the works. quality impacts and the poor floral diversity recorded by Roden (2004), the latter situation a likely result of low water levels at the time, which have largely been maintained. Negative Negative indicator The project could potentially introduce non-native Adhering to a CEMP during the With delivery of mitigation, this conservation indicator species absent or biota to the lagoon and affect the number or cover works, including measures to objective will not be negatively affected. species/ under control of negative indicator species associated with the prevent the importation of Number and lagoon. invasive alien species. % cover

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Table 53 Summary of residual impacts of the proposed embankments refurbishment project on ‘Atlantic salt meadows’ in the lower River Shannon SAC. Attribute/Measure Target Summary of impact Mitigation Summary of residual impact summary Habitat area/ Hectares Area stable or increasing, Uncontrolled access and runoff from the works Protection of The saltmarsh habitats directly adjacent subject to natural processes, area could reduce the area, or quality of the saltmarsh by to the proposed development are not including erosion and habitat at the eastern embankment. adhering to a CEMP included in the baseline habitat map of succession. e.g. working in all saltmarsh in the Lower River discrete Shannon, as based on the findings of demarcated areas, McCorry and Ryle (2009), control of runoff. corresponding to the area given in the Conservation objectives. At operation stage, modelling indicates that the proposed works will not have a significant impact on the morphodynamics of the adjacent mudflats. The residual impact on mapped and unmapped saltmarsh area is assessed as none. Habitat No decline or change in The project will not result in a decline in the None required None distribution/Occurrence habitat distribution, subject distribution or occurrence of this habitat type. to natural processes. Physical structure: sediment Maintain natural circulation There will be no additional barriers other than None required None: At operation stage, modelling supply/Presence absence of of sediments and organic those (pitched stone on front face of indicates that the proposed works will physical barriers matter, without any physical embankments) that have always been in existence. not have a significant impact on the obstructions morphodynamics of the adjacent mudflats, so natural circulation of sediments and organic matter will be maintained. Physical structure: creeks and Maintain creek and pan The project footprint will not incur any significant None required None: At operation stage, modelling pans/ Occurrence structure, subject to natural physical change to the foreshore in the environs of indicates that the proposed works will

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Attribute/Measure Target Summary of impact Mitigation Summary of residual impact summary processes, including erosion this habitat. not have a significant impact on the and succession morphodynamics of the adjacent mudflats, so creek and pan structure will be maintained. Physical structure: flooding Maintain natural tidal The project will not affect the flooding regime or None required None regime/ Hectares flooded; regime impact the area of the habitat. frequency Vegetation structure: Maintain the range of The project footprint will not incur any significant None required None zonation/Occurrence coastal habitats including physical change to the foreshore in the environs of transitional zones, subject this habitat, so no change to this attribute is to natural processes expected. including erosion and succession Vegetation structure: Maintain structural variation The saltmarsh habitat adjacent to the proposed None required None vegetation height/ within sward development is apparently not grazed. The Centimeters proposal will not change access to the foreshore, so no change to this attribute is expected. Vegetation structure: Maintain more than 90% of No poaching was noted at the saltmarsh habitat None required None vegetation cover/ Percentage the saltmarsh area adjacent to the proposed development. The cover at a representative vegetated proposal will not change access to the foreshore, sample of monitoring stops so no change to this attribute is expected. Vegetation composition: Maintain range of sub‐ The project footprint will not incur any significant None required None typical species and communities with typical physical change to the foreshore in the environs of sub‐communities/ species listed in Saltmarsh this habitat, so no change to this attribute is Percentage cover at a Monitoring Project expected. representative sample of (McCorry and Ryle, 2009) monitoring stops Vegetation structure: No significant expansion of Common Cord-grass (Spartina anglica) is abundant Protection of None with implementation of negative indicator species‐ common cordgrass along the outer edges of each of the Atlantic Salt saltmarsh by mitigation

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Attribute/Measure Target Summary of impact Mitigation Summary of residual impact summary Spartina anglica/ Hectares (Spartina anglica), with an Meadow habitat areas. Interference with adhering to a CEMP annual spread of less than saltmarsh through excavation or otherwise could e.g. invasive alien 1% spread this non-native invasive plant. species control.

Table 54 Assessment of potential impacts of the project on ‘Vegetation of flowing waters’ Attribute/Measure Target Summary of impact Mitigation summary Summary of residual impact Habitat area Area stable or increasing, Opposite-leaved Pondweed occurs in a channel connected to Protection of water quality None /Kilometres subject to natural the lagoon adjacent to the West embankment. The by adhering to a CEMP e.g. processes. Three sub‐types construction phase of the project could potentially result in hydrocarbon control, of high conservation value siltation of, or a release of a deleterious substance to the appropriate stockpiling, are known to occur in the channel, possibly affecting the area of the habitat suitable for waste management and site. colonisation. emergency response plan. Habitat No decline, subject to The construction phase of the project could potentially result Protection of water quality None distribution/ natural processes. in sediment release from excavations and deposit silt in the by adhering to a CEMP e.g. Occurrence channel possibly affecting the distribution of the habitat, or hydrocarbon control, by other water quality impacts. appropriate stockpiling, waste management and emergency response plan. Hydrological Maintain appropriate A natural flow regime is required for both plant communities Avoid interfering with the None. There will be no regime: river hydrological regimes and channel geomorphology to be in favourable condition. drainage channel between interference with the drainage flow/Metres per The project will could affect the hydrological regime of the the lagoon and the channel through the western second channel supporting Opposite-leaved pondweed by interfering embankment through embankment that links the with the connection between the channel and the estuary. proper site management. Airport lagoon to the Shannon Works in this area will be Estuary. carried out in an especially sensitive manner to preserve the potential function of the sluice gate Hydrological Maintain natural tidal Tidal regime appears to be an important influence on the None required None

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Attribute/Measure Target Summary of impact Mitigation summary Summary of residual impact regime: tidal regime distribution of certain pondweed. The project will not affect influence/Daily the hydrological regime of the channel supporting Opposite- water level leaved pondweed. The connection between the lagoon and fluctuations ‐ the estuary will be maintained, as is necessary for lagoon metres drainage. Hydrological Maintain appropriate Freshwater seepages are considered important for the None required None regime: freshwater freshwater seepage regimes Groenlandia densa subtype. The proposed development seepages/ Metres would not influence freshwater seepage regimes so this per second attribute will not be affected. Substratum The substratum should be The construction phase of the project could potentially result Protection of water quality None composition: dominated by the particle in sediment release and deposit silt in the channel. Therefore, by adhering to a CEMP e.g. particle size range/ size ranges, appropriate to there is potential for this conservation objective to be hydrocarbon control, Millimetres the habitat sub‐type negatively affected. appropriate stockpiling, (frequently sands, gravels waste management and and cobbles) emergency response plan. Water quality: The concentration of The project could potentially result in nutrient release to the Protection of water quality None nutrients/ nutrients in the water channel supporting Groenlandia densa, through sediment by adhering to a CEMP e.g. Milligrammes per column should be releases. hydrocarbon control, litre sufficiently low to prevent appropriate stockpiling, changes in species waste management and composition or habitat emergency response plan. condition. The specific targets may vary among sub‐types Vegetation Typical species of the The construction phase of the project could potentially result Protection of water quality None composition: relevant habitat sub‐type in nutrient release, which could alter vegetation composition. by adhering to a CEMP e.g. typical should be present and in hydrocarbon control, species/Occurrence good condition appropriate stockpiling, waste management and emergency response plan.

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Attribute/Measure Target Summary of impact Mitigation summary Summary of residual impact Floodplain The area of active floodplain River connectivity with the floodplain is essential for the None required None connectivity/Area at and upstream of the functioning of this habitat and is particularly important in habitat should be terms of sediment sorting and nutrient deposition. The maintained project will not affect floodplain connectivity within the catchment. No significant effects to conservation objective anticipated. Riparian The area of riparian While some trees are potentially affected, riparian woodland None required None habitat/Area woodland at and upstream of conservation value (alluvial) will not. of the bryophyte‐rich sub‐type should be maintained

10.1.2 River Shannon and River Fergus Estuaries SPA Table 55 Assessment of conservation objectives and potential impact for Cormorant [A017] Attribute35 Target Summary of impact Mitigation summary Summary of residual impact Breeding No significant decline Subsite OH510 was one of the top 5 foraging locations for this species during the None required None population MKO (2019) study. This subsite corresponds to the area to the west of the western abundance embankment. There is ample suitable habitat along the Shannon Estuary for this species and it is known to occur throughout the SPA. The project is not expected to cause a significant decline in the breeding population of cormorant. No significant effects to this measure are expected, Productivity No significant decline The project is not expected to cause a significant decline on the productivity of this None required None rate species. Therefore, no significant effects to this measure are expected. Distribution of No significant decline The project is does not affect habitat types for which Cormorant are often sited on, None required None breeding namely’ rocky islets, sea stack tops and cliffs. Therefore, no significant effects to this colonies measure are expected.

35 Attributes/measures apply to breeding cormorant

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Attribute35 Target Summary of impact Mitigation summary Summary of residual impact Prey biomass No significant decline Cormorant are pescivorous and use the area surrounding the proposed Protection of water quality by None available embankment refurbishments for foraging36. Impacts on water quality could adhering to a CEMP e.g. therefore impact prey items of this specialist species. hydrocarbon control, appropriate stockpiling, waste management and emergency response plan. Barriers to No significant The works will be small and localised in nature and are not expected to cause any No connectivity increase barriers to connectivity for this CI species. Therefore no impact to this measure is expected. Disturbance at Human activities Key habitats include sandy areas, rocky and vegetated substrate. As the project Keep noise levels to a minimum Some possible the breeding should occur at levels occurs on the embankments contiguous to the mud and sand flats, there is potential disturbance site that do not adversely for disturbance and water quality impacts. Cormorant are recorded to roost along at outset of affect the breeding the eastern side of the project, however, any impacts that occur will be small and project but no cormorant localised in nature, and the River and Estuaries cover an extensive area that will alteration of population provide an abundance of suitable habitat. breeding at any nest site Population Long term population County Clare has experienced a breeding population decrease from 162 to 28 pairs None required None trend trend stable or between the 1969-70 and 1999-2002 seabird census counts (Mitchell et al., 2004). increasing Cormorant occurs largely to the east of the development site. The project is not expected to cause any potential significant impact on this measure. Distribution No significant County Clare has experienced a breeding population decrease from 162 to 28 pairs None required None decrease in range, between the 1969-70 and 1999-2002 seabird census counts (Mitchell et al., 2004). timing or intensity of Cormorant occurs largely to the east of the development site. The project is not use of areas by expected to cause any potential significant impact on this measure.

36 https://www.npws.ie/sites/default/files/publications/pdf/004077_River%20Shannon%20and%20River%20Fergus%20Estuaries%20SPA%20Supporting%20Doc%20Appendix%208.1_ V1.pdf [accessed 19/07/2019]

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Attribute35 Target Summary of impact Mitigation summary Summary of residual impact cormorant other than that occurring from natural patterns of variation

Table 56 Assessment of conservation objectives and potential impacts for Whooper Swan [A038] Attribute Target Summary of impact Mitigation Summary of summary residual impact Population Long term The area affected by the project is not a suitable habitat for this SCI species. The lagoon was None required None Trend population trend once an important habitat (roost) for Whooper Swan but this is no longer the case. This species stable of increasing was not recorded in the environs of the proposed development site during the MKO (2019) study. Potential impacts to this measure are not expected to occur. Distribution No significant During the most recent international swan census, just over half of habitat records for Whooper None required None decrease in the Swans were for dry improved pasture (Boland et al. 2010). The lagoon was once an important range, timing or habitat (roost) for Whooper Swan but this is no longer the case. This species was not recorded intensity of use of in the environs of the proposed development site during the MKO (2019) study. Whooper areas by this species Swans that spend winter at the Shannon and Fergus estuaries complex are known to forage other than that primarily outside of the SPA boundary. Changes in feeding distribution occur through the winter occurring from as food supplies become exhausted and new ones are exploited. The project will not impact on natural patterns of any habitats identified above, as such, it is not expected to impact on this measure. variation

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Table 57 Assessment of conservation objectives and potential impacts for Light-bellied Brent Geese [A046] Attribute Target Summary of impact Mitigation summary Summary of residual impact Population Long term population trend This species is not recorded in the area containing or surrounding the proposed works None required None Trend stable of increasing (MKO, 2019), which are small and localised in nature and not expected to cause any potential impacts on this measure. Distribution No significant decrease in Brent Geese are grazers and are known for their preference for foraging in intertidal areas None required None the range, timing or with the Eelgrass Zostera sp. (Robinson et al. 2004b). Where this food source is absent the intensity of use of areas by birds feed upon algae and saltmarsh plants and the species also grazes terrestrially. this species other than that 2010/2011 waterbird distribution (NPWS) records indicate that this species is found in occurring from natural seven subsites of the SPA, the nearest records occurring further downstream of the patterns of variation proposal site, west of Carrig Island (where the only record of roost sites for this species occurred). Due to the significant intervening distance between the nearest population and the project, potential impacts on this measure are not expected to occur.

Table 58 Assessment of conservation objectives and potential impacts for Shelduck [A048] Attribute Target Summary of impact Mitigation summary Summary of residual impact Population Long term population trend Shelduck individuals have been recorded in the vicinity of the proposed works and the area None required None Trend stable of increasing adjacent to the eastern embankment was identified by MKO (2019) as having relatively high use by this species within the SPA. However, there is more suitable habitat in other locations such as the benthic community of the Fergus Estuary and Poulnasherry Bay which is assigned the broad classification ‘Intertidal sand to mixed sediment with polychaetes, molluscs and crustaceans’ where (NPWS, 2012b). The gastropod mollusc Hydrobia ulvae, a favoured prey of Shelduck, is a distinguishing invertebrate of this community, occurring in moderate to high abundances. This species occurs on many subsites (e.g. 21 in the MKO (2019) study) and there is suitable habitat and prey available, so the project is unlikely to cause an impact on this measure.

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Attribute Target Summary of impact Mitigation summary Summary of residual impact Distribution No significant decrease in During the 2010/11 waterbird survey programme, Shelduck were recorded within 41 sub Protection of water None the range, timing or sites overall, and within 38 during low tide surveys, with highest densities occurring east of quality by adhering to a intensity of use of areas by the proposal site, on the River Fergus near Breckinish. Taking account of the ability of this CEMP e.g. hydrocarbon this species other than that species to use alternative habitats, it is considered that the project will not impact this control, appropriate occurring from natural measure if there was a deterioration in water quality, or if the species was subject to stockpiling, waste patterns of variation disturbance. management and emergency response plan.

Table 59 Assessment of conservation objectives and potential impacts for Wigeon [A050] Attribute Target Summary of impact Mitigation summary Summary of residual impact Population Long term population trend The project is not expected to impact this conservation objective given its widespread None required None Trend stable of increasing abundance and moderate ability to use alternative habitats. Distribution No significant decrease in Fifty seven subsites recorded the species foraging intertidally during the MKO (2019) Protection of water quality None the range, timing or study. None of the sites within/bordering the proposed development site were identified by adhering to a CEMP e.g. intensity of use of areas by as peak foraging / roosting sites. Impacts to this conservation object are not likely. The hydrocarbon control, this species other than that study area, and in particular the lagoon was identified by MKO (2019) as having relatively appropriate stockpiling, occurring from natural high use by this species within the SPA. The project could impact this measure if there waste management and patterns of variation was a deterioration in water quality in the lagoon or intertidal area, or if the species was emergency response plan. subject to disturbance during peak season (December-January).

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Table 60 Assessment of conservation objectives and potential impacts for Teal [A052] Attribute Target Summary of impact Mitigation summary Summary of residual impact Population Long term population trend The project is not expected to impact this conservation objective. None required None Trend stable of increasing Distribution No significant decrease in the Teal populations are recorded east of the project site, as-well as further west near Protection of water quality None range, timing or intensity of Aughinish Island and along the River Fergus. Teal are a widespread bird species that by adhering to a CEMP e.g. use of areas by this species use Intertidal mud/sand flats, shallow subtidal and lagoon type habitats but will are hydrocarbon control, other than that occurring also considered highly likely to use alternative habitat types. The MKO (2019) study appropriate stockpiling, from natural patterns of found that the lagoon was moderately used by this species during the 2017/18 season. waste management and variation The project may possess the potential to temporarily deter populations to use the emergency response plan. suitable habitat along the western embankment, especially if subject to ongoing Avoiding works during the disturbance during its peak season (December-January). The project is highly unlikely to peak season and keeping affect this measure. While unlikely to have impacts this conservation objective, noise levels to a minimum. mitigation will be provided to ensure compliance.

Table 61 Assessment of conservation objectives and potential impacts for Shoveler [A056] Attribute Target Summary of impact Mitigation summary Summary of residual impact Population Long term population Subsite OH509 (Airport lagoon) was one of the peak subsites for Shoveler during the MKO Yes None Trend trend stable of (2019) study. Subsite 0H509 registered a peak number of 55 foraging Shoveler in Low Tide increasing Surveys and a Peak Number of 15 foraging Shoveler in High Tide Surveys. Taking account of the ability of this species to use alternative habitats (considered totally reliant on wetland habitats due to unsuitable surrounding habitats and/or species limited by habitat requirements), the project could impact this measure if there was a deterioration in water quality, or if the species was subject to disturbance during its peak wintering season (January- February).

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Attribute Target Summary of impact Mitigation summary Summary of residual impact Distribution No significant decrease Subsite OH509 (Airport lagoon) was one of the peak subsites for Shoveler during the MKO Yes None in the range, timing or (2019) study. Subsite 0H509 registered a peak number of 55 foraging Shoveler in Low Tide intensity of use of Surveys and a Peak Number of 15 foraging Shoveler in High Tide Surveys. Taking account of areas by this species the ability of this species to use alternative habitats (considered totally reliant on wetland other than that habitats due to unsuitable surrounding habitats and/or species limited by habitat occurring from natural requirements), the project could impact this measure if there was a deterioration in water patterns of variation quality, or if the species was subject to disturbance during its peak wintering season (January- February).

Table 62 Assessment of conservation objectives and potential impacts for Golden Plover [A140] Attribute Target Summary of impact Mitigation summary Summary of residual impact Population Trend Long term population Subsite OH512 (at/adjacent to eastern embankment) was one of the peak subsites Yes None trend stable of for this species during the MKO (2019) study. Subsite 0H512 registered a peak increasing number of 3000 roosting Shoveler, so the project could impact this measure if there was a deterioration in water quality, or if the species was subject to disturbance during its peak wintering season (December-January). Distribution No significant decrease This species has been recorded in abundance across a number of sub sites within Yes None in the range, timing or the River Shannon Estuary, both east (Shannon and Bunratty) and west (River intensity of use of areas Fergus and Carrig Island) of the project. The species is an intermediately by this species other distributed species with wide food prey requirements that is considered reliant on than that occurring the sites upon which is occurs buts is likely to use alternative habitats where from natural patterns required. Given the importance of the area near the east embankment, the of variation project could potentially impact on this conservation objective.

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Table 63 Assessment of conservation objectives and potential impacts for Grey Plover [A141] Attribute Target Summary of impact Mitigation summary Summary of residual impact Population Trend Long term population Grey plover is amber-listed as the majority winter at less than ten sites. Yes None trend stable of However, the project will not impact on this conservation objective. Subsite increasing 0H509 (west of western embankment) registered proportional moderate use by this species during the MKO (2019) study, so the project could impact this measure if there was a deterioration in water quality, or if the species was subject to disturbance during its peak wintering season (December-January). Distribution No significant decrease This species is a localised (50-100 sites) intertidal (out of the water) walker that Yes None in the range, timing or has wide food prey requirements and is considered totally reliant on wetland intensity of use of areas habitats due to unsuitable surrounding habitats or is limited by habitat by this species other requirements. The project could impact this measure if there was a deterioration than that occurring in water quality, or if the species was subject to disturbance during its peak from natural patterns wintering season (December-January). of variation

Table 64 Assessment of conservation objectives and potential impacts for Lapwing [A142] Attribute Target Notes Potential Impacts Mitigation Required Population Long term population Waterbird population trends The study area is of some importance to this species as indicated by the MKO (2019) Yes Trend trend stable of are presented in part four of study (site OH510 and OH511 proportional moderate and Low importance increasing the conservation objectives respectively). Lapwing is red-listed due to a decline in the breeding and non-breeding supporting documentation population. The project could impact this measure if there was a deterioration in water quality, or if the species was subject to disturbance during its peak wintering season (December-January). Distribution No significant decrease As determined by regular low The site is designated for wintering lapwing, a widespread (200-300 sites) intertidal (out Yes in the range, timing or tide and other waterbird of the water) walker that has wide food prey requirements and is considered highly intensity of use of areas surveys. (and discussed in the likely to use alternative habitats. It has been recorded upstream (east embankment)

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Attribute Target Notes Potential Impacts Mitigation Required by this species other 2010/2011 waterbird survey and downstream (Greenish Islands) of the project site. Lapwing winter on mudflats and than that occurring from programme IFI) estuaries as well as inland on open grasslands or ploughed fields and breed on natural patterns of grasslands and grassy wetlands (Dempsey and O’ Cleary, 2002). The project could variation impact this measure if there was a deterioration in water quality, or if the species was subject to disturbance during its peak wintering season (December-January).

Table 65 Assessment of conservation objectives and potential impacts for Knot [A143] Attribute Target Summary of impact Mitigation summary Summary of residual impact Population Long term population Knot is amber-listed due to a moderate decline over a long -term. It is the only bird None required None Trend trend stable of that has moved from the BOCCI3 red-list to the amber-list due to a short-term increasing increase in wintering population. The project will not impact this conservation objective. Distribution No significant decrease This species is a localised (50-100 sites) intertidal (out of the water) walker that has Avoiding works during the peak None in the range, timing or a narrow range of food prey requirements and is considered totally reliant on season and keeping noise levels to intensity of use of areas wetland habitats due to unsuitable surrounding habitats or is limited by habitat a minimum. by this species other requirements. Knot mainly occurs in the middle and outer estuary along mudflats than that occurring from and is known to occur to the west (west embankment at Shannon Airport, Fergus natural patterns of River and Greenish Islands) of the proposed works. The study area is of low variation proportional importance to this species as indicated by the MKO (2019) study (site OH510 and OH512). The works may potentially cause a disturbance to the species if disturbance was to occur during its peak wintering season (January-February).

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Table 66 Assessment of conservation objectives and potential impacts for Dunlin [A149] Attribute Target Summary of impact Mitigation summary Summary of residual impact Population Long term population Dunlin is amber-listed in Ireland as the majority winter at less than ten sites. The project will None required None Trend trend stable of not impact this conservation objective. increasing Distribution No significant decrease Dunlin mainly occurs in the middle and outer estuary along mudflats but few individuals can Avoiding works during the None in the range, timing or also be found around the city. Records (Low Tide Count, 2011) show that Dunlin has been peak season and keeping intensity of use of areas recorded extensively using the River Shannon Estuary for foraging, with records of potential noise levels to a minimum by this species other roosting Dunlin along the western Bank of the River Fergus. Dunlins are a wintering species. than that occurring from The study area is of some importance to this species as indicated by the MKO (2019) study natural patterns of (site OH510 and OH512 proportional high and moderate importance respectively). The works variation could potentially cause a disturbance to the species if disturbance was to occur during its peak wintering season (December-January).

Table 67 Assessment of conservation objectives and potential impacts for Black-tailed Godwit [A156] Attribute Target Summary of impact Mitigation summary Summary of residual impact Population Trend Long term population High proportional use of subsites OH509 and OH5010 (western embankment) and Protection of water quality None trend stable of moderate proportional subsite use at 0H510 and OH512 was recorded by this species by adhering to a CEMP e.g. increasing during the MKO (2019) study, so the project could impact this measure if there was a hydrocarbon control, deterioration in water quality, or if the species was subject to disturbance during its appropriate stockpiling, peak wintering season (December-January). waste management and emergency response plan. Avoiding works during the peak season and keeping noise levels to a minimum.

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Distribution No significant This species is a localised (50-100 sites) intertidal (out of the water) walker that has Protection of water quality None decrease in the range, wide food prey requirements and is considered highly likely to use alternative by adhering to a CEMP e.g. timing or intensity of habitats. It was recorded at 57 sites during the MKO (2019) study. These birds have hydrocarbon control, use of areas by this wide prey food requirements and feed on intertidal mudflats, brackish pools, and appropriate stockpiling, species other than rough grassland. This species occurs primarily west of the site, but has been recorded waste management and that occurring from to use the area directly adjacent to the proposed works on the embankments (Low emergency response plan. natural patterns of Tide Count, October 2010). Birds arrive in September and October. There is the Avoiding works during the variation potential for disturbance impacts and water quality impacts. peak season and keeping noise levels to a minimum.

Table 68 Assessment of conservation objectives and potential impacts for Bar-tailed Godwit [A157] Attribute Target Summary of impact Mitigation summary Summary of residual impact Population Trend Long term population The bar-tailed godwit is amber-listed in Ireland as the majority winter at less than None required None trend stable of ten sites. This species is not recorded in the area containing or surrounding the increasing proposed works (MKO, 2019), which are small and localised in nature and not expected to cause any potential impacts on this measure. The project will not affect this conservation objective. Distribution No significant This species is a localised (50-100 sites) intertidal mudflat (out of the water) walker None required None decrease in the range, that has wide food prey requirements and is considered a wide-ranging species that timing or intensity of likely uses a range of alternative habitats. No observations of this species were use of areas by this recorded near the project site during the 2010/2011 High and Low Tide Counts. species other than that occurring from natural patterns of variation

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Table 69 Assessment of conservation objectives and potential impacts for Curlew [A160] Attribute Target Summary of impact Mitigation summary Summary of residual impact Population Trend Long term population Curlew is red-listed due to a long-term decline in its breeding and wintering population None required None trend stable of and its breeding range. Based on the observations of MKO (2019) subsites containing increasing and/or adjacent to the proposed development are vary from moderate to no proportional use. The species is widespread with wide food prey requirements and is considered reliant on the sites upon which is occurs buts is likely to use alternative habitats where required. The project will not affect this conservation objective. Distribution No significant decrease Curlew winter in the estuary and coastal grasslands and feed on intertidal mudflats. Works will take place None in the range, timing or They nest in bogs, damp meadows and farmland (Dempsey and O’Cleary, 2002), outside of the peak intensity of use of areas therefore, breeding curlew will not be significantly impacted by the proposal. The site is wintering season by this species other designated for wintering curlew which is a widespread (200-300 sites) intertidal walker than that occurring from that has a wide food prey requirement and is considered highly likely to use alternative natural patterns of habitats. The project is not expected to significantly affect the distribution of wintering variation curlew with mitigation.

Table 70 Assessment of conservation objectives and potential impacts for Redshank [A162] Attribute Target Summary of impact Mitigation summary Summary of residual impact Population Long term population Redshank is red-listed due to a long-term decline in its breeding population. None required None Trend trend stable of The project will not impact this conservation objective. increasing Distribution No significant decrease Redshank has been recorded to feed along the upper shore of the River Protection of water quality by adhering None in the range, timing or Shannon Estuary and River Fergus, as-well as along muddy river channels in to a CEMP e.g. hydrocarbon control, intensity of use of areas small numbers around the project site location. High proportional use of appropriate stockpiling, waste by this species other subsites OH512, moderate proportional subsite OH510 use and Low subsite management and emergency response

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than that occurring from OH512 use was recorded by this species during the MKO (2019) study, so the plan. Minimising works during the peak natural patterns of project could impact this measure if there was a deterioration in water quality, season and keeping noise levels to a variation or if the species was subject to disturbance during its peak wintering season minimum. (November-December).

Table 71 Assessment of conservation objectives and potential impacts Greenshank [A164] Attribute Target Summary of impact Mitigation Summary summary of residual impact Population Long term population Greenshank is green-listed for its wintering population. It was moved from the amber to the green list in None None Trend trend stable of BoCCI3 as 50% of the wintering population occurs at more than ten sites. MKO (2019) did not recorded required increasing this species in the area containing or surrounding the proposed works, which are small and localised in nature and not expected to cause any potential impacts on this measure. The project will not impact this conservation objective. Distribution No significant decrease It winters mainly on estuaries within some along non-estuarine coasts. It feeds in shallow water and soft None None in the range, timing or mud. This species is an intermediate (100-200 sites) intertidal walker (in water) that has wide food prey required intensity of use of areas requirements and is considered totally reliant on wetland habitats due to unsuitable surrounding by this species other habitats or is limited by habitat requirements. It has been recorded (Low Tide Counts, 2011) in small than that occurring from numbers around Aughinish Island and along the upper Fergus River. The works will take place outside of natural patterns of the peak wintering season; therefore, the project will not significantly affect the population trend or variation distribution of wintering greenshank.

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Table 72 Assessment of conservation objectives and potential impacts for Black-headed Gull [A179] Attribute Target Summary of impact Mitigation Summary summary of residual impact Population Long term population Black-headed gull is red-listed due to a long-term decline in its breeding population. The project will not None None Trend trend stable of impact this conservation objective. Based on the MKO (2019) observations in the area surrounding the required increasing proposed development, subsite proportional use varies from low to high for Black-headed Gull. The project will not impact this conservation objective, taking into account of its likelihoood to use alternative habitats wide prey requirements, and broad trophic guild. Distribution No significant decrease A widespread species in Ireland, this species is can be found in the summer, is a water column diver, an None None in the range, timing or intertidal walker both in and out of the water and a terrestrial walker. It has a wide food prey requirement required intensity of use of areas and is considered highly likely to use alternative habitats. The site is designated for wintering black-headed by this species other gull. Black-headed gull are widespread during the winter along the coast and inland. They are a very than that occurring from common widespread breeding species nesting in colonies in sand dunes, coastal islands, moorland polls, natural patterns of bogs and on freshwater lake islands (Dempsey and O’Cleary, 2002) and have been recorded extensively variation using the habitats from Limerick City as far as Poulnasherry Bay.

Table 73 Assessment of conservation objectives and potential impacts to wetlands [A999] Attribute Target Summary of impact Mitigation summary Summary of residual impact Wetland The permanent area occupied by the wetland There will be a loss of ca. 0.4ha Working within discrete marked-out boundaries, None (see Section habitat habitat should be stable and not significantly of mudflat habitat. To ensure controlled excavation and appropriate storage/ 10.1.1 also in relation area less than the area of 32,261 hectares, other that no area in addition to this stockpiling of material. Water quality preservation, to ‘estuaries’ and than that occurring form natural patterns of is lost will require mitigation. waste management, Emergency response plan and mudflats...) variation adhering to a CEMP during the works.

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11 CONCLUSION Provided that the project is built according to the project description and that recommended mitigation measures set out above are implemented in full, it is not expected that significant impacts will result to the qualifying features identified for appraisal in this NIS and thus it is not expected that the proposal will have an adverse impact on the integrity of Natura 2000 sites.

In conclusion, provided the recommended mitigation measures are implemented in full it is not expected that the construction and operation of the proposed Shannon Embankments refurbishments adjacent to Shannon Airport will result in an adverse residual impact on the integrity of Natura 2000 sites considered in this NIS, namely the:

 Lower River Shannon cSAC (002165)  River Shannon and River Fergus Estuaries SPA (004077)

The provisions of Article 6 of the ‘Habitats’ Directive 92/43/EC (2000) defines ‘integrity’ as the ‘coherence of the site’s ecological structure and function, across its whole area, or the habitats, complex of habitats and/or population of species for which the site is or will be classified’. It is considered that the scale of the works, in addition to the implementation of the prescribed mitigation measures, would not give rise to significant impacts affecting the integrity of the Lower River Shannon cSAC. It is concluded that the Shannon Airport Embankments Refurbishment project, subject to the proposed mitigation measures and conditions above, will not result in direct, indirect or cumulative impacts which would have the potential to adversely affect the conservation objectives of the Lower River Shannon cSAC or the River Shannon and River Fergus Estuaries SPA in relation to the relevant Annex II species and Annex I habitats; with regard to their range, population densities or conservation status within these designated areas.

The loss/alteration of estuarine habitat, related to revetment works on mudflat habitat adjacent to the existing embankment within the Shannon Estuary would equate to an area of less than 0.4ha, or less than 0.004% of the overall estimated area of this habitat type within the estuary.

Potential impacts on water quality in the Lower River Shannon cSAC are minimal due to the nature of the proposed works and tidal exchange rates, along with mitigation measures proposed. There would be no changes to the Lower River Shannon cSAC or River Shannon and River Fergus Estuaries SPA with regard to the qualifying interests of these sites or key indicators of conservation value (i.e. water quality) or changes to site integrity.

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12 REFERENCES ASU (2004) Shannon Airport Lagoon: An Assessment of Effectiveness of Lowering the Water Levels as a Control Measure for Swans and its Implications for the Ecology of the Site. Report by Aquatic Services Unit, commissioned by Aer Rianta.

Bleakley, B. 1979. Spartina – an unwelcome immigrant, Irish Hare, 2, 10-12.

Chapman, P.J. and Chapman, L.L. (1982). Otter survey of Ireland Unpublished Report to Vincent Wildlife Trust.

Chanin P (2003a). Ecology of the European Otter. Conserving Natura 2000. Rivers Ecology Series No. 10. English Nature, Peterborough.

Chanin P (2003b). Monitoring the Otter Lutra lutra. Conserving Natura 2000 Rivers Monitoring Series No. 10, English Nature, Peterborough.

CIRIA, CUR, CETMEF (2007). The Rock Manual. The use of rock in hydraulic engineering (2nd edition). C683, CIRIA, London,

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

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

European Commission (2007) Interpretation manual of European Union habitats- EUR 27. DG Environment, Brussels.

EC (2001). 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. Luxembourg: Office for Official Publications of the European Communities.

IFI (2016) Guidelines on Protection of Fisheries during Construction Works in and Adjacent to Waters. Inland Fisheries Ireland, 3044 Lake Drive, Citywest Business Campus Co. Dublin. IFI/2016/1- 4298.

Horton, R., G. Yohe, W. Easterling, R. Kates, M. Ruth, E. Sussman, A. Whelchel, D. Wolfe, and F. Lipschultz (2014) Climate Change Impacts in the United States: The Third National Climate Assessment, Eds., U.S. Global Change Research Program, 16-1-nn.

IFI (2016) Guidelines on Protection of Fisheries during Construction Works in and Adjacent to Waters. Inland Fisheries Ireland, 3044 Lake Drive, Citywest Business Campus Co. Dublin. IFI/2016/1- 4298.

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Kelly, F.L., Matson, R., Connor, L., Feeney, R., Morrissey, E., Coyne, J. and Rocks, K. (2014) Water Framework Directive Fish Stock Survey of Rivers in the South Western River Basin District. Inland Fisheries Ireland, 3044 Lake Drive, Citywest Business Campus, Dublin 24.

Kurz, I. and Costello, M.J. (1999). An Outline of the Biology, Distribution and Conservation of Lampreys in Ireland. Irish Wildlife Manuals, No. 5.

Maitland PS (2003) Ecology of the River, Brook and Sea Lamprey. Conserving Natura 2000 Rivers Ecology Series No. 5. English Nature, Peterborough.

Masters-Williams, H., Heap, A., Kitts, H., Greenshaw, L., Davis, S., Fisher, P., Hendrie, M., Owens, D. (2001) Control of water pollution from construction sites. Guidance for consultants and contractors. DETR/CIRIA. London.

McCorrey, M, Curtis, T.G.F. & Otte, M.L., 2003. Spartina in Ireland. In Wetlands of Ireland, distribution, ecology, uses and economic value. Otte, M.L. (ed.) University College Press Dublin, 44- 50.

McGinnity, P., Gargan, P., Roche W., Mills, P., and McGarrigle M. (2003) Quantification of the freshwater Salmon habitat asset in Ireland using data interpreted in a GIS platform. Issue 3 of Irish Freshwater Fisheries Ecology and Management Series, Central Fisheries Board, Dublin, 3. 131 pp.

MKO (2019) Waterfowl Numbers, Usage and Distribution of the River Shannon and the River Fergus Estuaries - Final Survey Report. McCarthy Keville O’Sullivan Ltd., Planning & Environmental Consultants Block 1, G.F.S.C. Moneenageisha Road, Galway.

Murphy J.N, Cooney, A., Rattigan, J. and Lynch, T. (2003). The Shannon Lagoon, Bird Watch Ireland (www.birdwatchireland.ie)

NPWS (2007) Supporting documentation for the Habitats Directive Conservation Status Assessment ‐ backing documents, Article 17 forms and supporting maps. Unpublished Report to NPWS.

NPWS (2012a) Conservation Objectives: Lower River Shannon cSAC 002165. Version 1.0. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.

NPWS (2012b) Conservation Objectives: River Shannon and River Fergus Estuaries SPA 004077. Version 1.0. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.

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

NPWS (2019a). The Status of EU Protected Habitats and Species in Ireland. Volume 2: Habitat Assessments. Unpublished NPWS report. Edited by: Deirdre Lynn and Fionnuala O’Neill.

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NPWS (2019b). The Status of EU Protected Habitats and Species in Ireland. Volume 3: Species Assessments. Unpublished NPWS report. Edited by: Deirdre Lynn and Fionnuala O’Neill

NRA (2008) Guidelines for the Treatment of Otters prior to the Construction of National Road Schemes. National Roads Authority, St Martin’s House, Waterloo Road, Dublin 4.

NRA (2010) ‘Guidelines on the Management of Noxious Weeds and Non-Native Invasive Plant Species on National Roads’ Revision 1. National Roads Authority, St Martin’s House, Waterloo Road, Dublin 4

NRA (2006) ‘Guidelines for the protection and preservation of trees, hedgerows and scrub prior to, during and post construction of national road schemes. National Roads Authority.

NRA (2008) Guidelines for the Treatment of Otters prior to the Construction of National Road Schemes. National Roads Authority.

NS 2. (2010). Freshwater Pearl Mussel Second Draft Allow Sub-Basin Management Plan. Produced by NS 2, funded by DEHLG.

NRA (2006) A Guide to Landscape Treatments for National Road Schemes in Ireland. National Roads Authority, Dublin.

O’Grady, M. (2006). Channels and Challenges. The enhancement of Salmonid rivers. Central Fisheries Board, Dublin. 142pp.

Preston, C.D. (2003) Pondweeds of Great Britain and Ireland. BSBI Handbook, No. 8, Botanical Society of the British Isles, London.

Reynolds, J.D. (1998). Conservation management of the white-clawed crayfish, Austropotamobius pallipes Part 1. Irish Wildlife Manuals No. 1. Dúchas, the Heritage Service, Dublin.

Settele, J., R. Scholes, R. Betts, S. Bunn, P. Leadley, D. Nepstad, J.T. Overpeck, and M.A. Taboada (2014). Terrestrial and Inland Water Systems. In: Climate Change 2014: Impacts, Adaptation and Vulnerability. Part A: Global and Sectoral Aspects. Contribution of Working Group II to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change. Cambridge University Press.

SNH (2006) Guidance for Competent Authorities when dealing with proposals affecting SAC freshwater sites. Scottish Natural Heritage. http:// http://www.snh.org.uk/pdfs/publications/heritagemanagement/guidanceforcompetentauthorities.p df

TEGOS (2018) Report of the Technical Expert Group on Salmon to Inland Fisheries Ireland (IFI). The Status of Irish Salmon Stocks in 2017 with Catch Advice for 2018.

Whilde, A., (1993) Threatened Mammals, Birds, Amphibians and Fish in Ireland – Irish Red Data Book 2: Vertebrates. HMSO, Belfast.

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Appendix 1 Screening for Appropriate Assessment Report

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Appendix 2 Shannon Embankment Modelling

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Appendix 3 Outline Construction Environment Management Plan

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Note: To be read in conjunction with the full suite of mitigation in Section 9

1. Method statements will be prepared by the appointed contractor. These will be used to translate the project requirements into planned systems of work instructions to the site staff and operatives involved. They will define the proposed method of working for an element or section of work taking into account the particular requirements of the project including site conditions, safety hazards, the contract drawings, specification or code of practice. They define the proposed use of plant, labour and materials, any hold points or permits and may be supplemented by drawings, sketches and produce data as necessary.

2. The site boundary will be marked by secure posts and robust high visibility tape. The site boundary will be demarcated and avoided once this construction element has been completed. These areas will be agreed with the site ecologist to ensure sensitive areas will be avoided. Machinery will not be permitted breach these agreed boundaries during subsequent work.

3. Substances that can cause water quality problems will need to be controlled adequately at all times during the works. The main risks are associated with excavated/bare soils and oils. Measures to prevent erosion of soils and releases of oil will be required. There will be no discharge of effluent or waste water on site. Spill kits and personnel practised in their use will be required in case of an oil spillage.

4. All construction equipment/gear will be stored at a site compound. Wastes generated on- site (construction and waste water) will be managed properly and taken to a licensed waste management company.

5. A good knowledge of working in the marine environment will be necessary, as water levels at the seaward side of the embankment undergo fluctuations according to the tidal cycle.

6. A project ecologist (environmental clerk of works) will be appointed to monitor the works on a weekly basis for the full duration of the project. The contractor will work with the ecologist to deliver environmental compliance on site, as set out in the mitigation in the NIS. The ecologist will audit the construction works from an environmental viewpoint.

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