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

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

 Attachment F.1(iii): Natura Impact Statement as part of the Glenamaddy Sewerage Scheme

Glenamaddy Sewerage Scheme

Natura Impact Statement as part of the Glenamaddy Sewerage Scheme

IW Project No.: 10001648

DOCUMENT AMENDMENT RECORD

Client: Irish Water

Project: Glenamaddy Sewerage Scheme

Title: Glenamaddy Sewerage Scheme – NIS

PROJECT NUMBER: 4458 DOCUMENT REF: 4458-TR14- Glenammaddy Sewerage Scheme NIS

For C DMcD 17/02/2016 MMcD 27/05/16 MMcD 27/05/16 Planning

Revision Description Originated Date Checked Date Authorised Date TOBIN Consulting Engineers

Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Contents

Introduction 1 Legislative Context 2 Relevant Guidance 4 Approach 5 Consultation 7

Stage 1: Screening 9 Introduction 9 Ecological Site Visit and Desk Study 9 Description of the Project 10 Description of the Receiving Environment 15 Proposed WwTP site description 15 Pumping station/Storm Tank and discharge location 18 Glenamaddy Turlough 19 Hydrology and Hydrogeology 20 Identification of Relevant European Sites 27 Likely Significant Impacts from the Proposed Development on European Sites 29 Potential In-Combination Effects 30 Screening Conclusion 35

Stage 2: Information for Appropriate Assessment 36 Introduction 36 Characterisation of European Sites 36 Lough Lurgeen Bog/ Glenamaddy Turlough SAC (Site Code: 000301) 36 Lough Corrib SAC (Site Code: 000297) 40 Identification of Relevant Qualifying Interests 41 Identification of Potential Effects 44 Construction Phase Impacts 44 Operational Phase Impacts 46 Mitigation and Monitoring 55 Construction Phase Mitigation 55 Operational Phase Mitigation and Monitoring 57 Conclusion of Stage 2 of Appropriate Assessment 58 Lough Lurgeen Bog / Glenamaddy Turlough SAC 58 Statement of findings of non-significant effects 63

References 65

i | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Photographic Plates 68

Appendix 1 NPWS Natura 2000 Site Synopses 74

Appendix 2 Department of Arts, Heritage and the Gaeltacht Response in Relation to the NIS Preparation for the Proposed WWTP at Glenamaddy, Co. Galway 83

ii | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Introduction

This report forms a Natura Impact Statement (NIS) for the upgrade of the existing Glenamaddy Sewerage Scheme including a new Waste Water Treatment Plant (WwTP) located at Glenamaddy, County Galway. The purpose of this NIS is to inform the Appropriate Assessment process will be completed by the relevant competent authority. Appropriate Assessment (AA) is an assessment of whether a plan or project, alone and in combination with other plans or projects, could have significant effects on a European site in view of the site’s conservation objectives.

An Appropriate Assessment is a requirement of Article 6 of the EC Directive 92/43/EEC on the Conservation of Natural Habitats and of Wild Fauna and Flora (as amended) (hereafter referred to as the “Habitats Directive”). The overall aim of the Habitats Directive is to maintain or restore the “Favourable Conservation Status” of habitats and species of European Community interest. These habitats and species are listed in the Habitats Directive and also in the Birds Directive (2009/147/EC), leading to the designation of European Sites for conservation of these interests, within the Natura 2000 network. These Natura 2000 sites include both Special Areas of Conservation (SACs) under the Habitats Directive, and Special Protection Areas (SPAs) under the Birds Directive.

European and national legislation places a collective obligation on Ireland and its citizens to maintain habitats and species in the Natura 2000 network at favourable conservation condition. The Government and its agencies are responsible for the implementation and enforcement of regulations (in particular Part XAB of the Planning and Development (Amendment) Act 2010 and the European Communities (Birds and Natural Habitats) Regulations, 2011 (S.I. 477) (often referred to as the Habitats Regulations) to ensure the ecological integrity of these sites.

This report follows the guidance for AA published by the Environmental Protection Agency’s (EPA) ‘Note on Appropriate Assessments for the purposes of the Waste Water Discharge (Authorisation) Regulations, 2007 (S.I. No. 684 of 2007)’ (EPA, 2009); and takes account of the Department of the Environment, Heritage and Local Government’s guidelines ‘Appropriate Assessment of Plans and Projects in Ireland. Guidance for Planning Authorities’ (DoEHLG, 2010) and Circular L8/08

1 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

‘Water Services Investment and Rural Water Programmes – Protection of Natural Heritage and National Monuments’ (DoEHLG, 2008).

This report, and site investigation work, was completed on behalf of Irish Water by TOBIN Consulting Engineers, utilising a qualified team of scientists (ecologist and hydrogeologist), in combination with water services engineers.

Legislative Context

The Appropriate Assessment process (AA) is an assessment of the potential for adverse or negative effects of a plan or project, in combination with other plans or projects, on the conservation objectives of a European Site. These sites consist of Special Areas of Conservation (SACs) and Special Protection Areas (SPAs) and provide for the protection and long-term survival of Europe’s most valuable and threatened species and habitats.

Council Directive 92/43/EEC of 21 May 1992 on the Conservation of Natural Habitats and of Wild Fauna and Flora - ‘The Habitats Directive’, has been transposed into Irish law by The European Community (Natural Habitats) Regulations 2011 (S.I. No. 477). The Birds Directive, Council Directive 79/409/EC on the Conservation of Wild Birds, seeks to protect birds of special importance by the designation of Special Protection Areas (SPAs) whereas the Habitats Directive does the same for habitats and other species groups with Special Areas of Conservation (SACs).

The requirement of AA is outlined in Article 6(3) and 6(4) of the EU Habitats Directive. Article 6(3) of the Habitats Directive requires that:

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

2 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

concerned and, if appropriate, after having obtained the opinion of the general public.” Article 6(4) of the Habitats Directive requires that:

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

If, in spite of a negative assessment of the implications for the site and in the absence of alternative solutions, a plan or project may nevertheless be carried out for “Imperative Reasons Of Overriding Public Interest”, including those of a social or economic nature, the Member State shall take all compensatory measures necessary to ensure that the overall coherence of Natura 2000 network is protected. It shall inform the Commission of the compensatory measures adopted. Where the site concerned hosts a priority natural habitat type and/or a priority species, the only considerations which may be raised are those relating to human health or public safety, to beneficial consequences of primary importance for the environment or, further to an opinion from the Commission, to other imperative reasons of overriding public interest.

An AA should be based on best scientific knowledge and Planning Authorities should ensure that, for Stage 2 of the Appropriate Assessment in particular, ecological and hydrological expertise (if relevant) is utilised. This report details a Natura Impact Statement to inform the AA process which is finalised by the statutory authority. This NIS was informed by desk and field studies undertaken by professionals within TOBIN’s environmental services division (ecology and hydrogeology) utilising data provided by the water services engineers.

3 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Relevant Guidance

This report has been carried out using the following guidance:  Note on Appropriate Assessments for the purposes of the Waste Water Discharge (Authorisation) Regulations, 2007 (S.I. No. 684 of 2007). Environmental Protection Agency, (EPA, 2009).  Circular L8/08 – Water Services Investment and Rural Water Programmes – Protection of Natural Heritage and National Monuments. Department of Environment, Heritage and Local Government, (DoEHLG, 2008).  Appropriate Assessment under Article 6 of the Habitats Directive: Guidance for Planning Authorities. Circular NPW 1/10 & PSSP 2/10.  Appropriate Assessment of Plans and Projects in Ireland - Guidance for Planning Authorities. (Department of Environment, Heritage and Local Government, 2010).  Managing Natura 2000 Sites: the provisions of Article 6 of the ‘Habitats’ Directive 92/43/EEC, Office for Official Publications of the European Communities, Luxembourg (EC 2000);  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, Office for Official Publications of the European Communities, Luxembourg (EC 2001);  Guidance document on Article 6(4) of the 'Habitats Directive' 92/43/EEC – Clarification of the concepts of: alternative solutions, imperative reasons of overriding public interest, compensatory measures, overall coherence, opinion of the commission. Office for Official Publications of the European Communities, Luxembourg (EC 2007).  Nature and biodiversity cases: Ruling of the European Court of Justice. Office for Official Publications of the European Communities, Luxembourg (EC, 2006).

The potential for impacts on nature conservation interests has been assessed in light of habitats and the species that are likely to be affected by the proposals. The approach takes into account the following guidance:  A Guide to Habitats in Ireland (Fossitt, 2000);  Best Practice Guidelines for Habitat Survey and Mapping in Ireland. Heritage Council (2011).

4 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

 Guidelines for Ecological Impact Assessment (CIEEM 2016);  European Communities (Birds and Natural Habitats) (Amendment) Regulations, 2015 (S.I. 355); and  Interpretation Manual of European Union Habitats. Version EUR 28. European Commission (EC, 2013).

Definitions of conservation status, integrity and significance used in this assessment are defined in accordance with ‘Managing Natura 2000 sites: The provisions of Article 6 of the 'Habitats' Directive 92/43/EEC’ (EC, 2000):  The conservation status of a natural habitat is defined as the sum of the influences acting on a natural habitat and its typical species that may affect its long-term natural distribution, structure and functions as well as the long- term survival of its typical species;  The conservation status of a species is defined as the sum of the influences acting on the species concerned that may affect the long-term distribution and abundance of its population;  The integrity of a European Site is defined as the coherence of the site’s ecological structure and function, across its whole area, or the habitats, complex of habitats and/or populations of species for which the site is or will be classified;  Significant effect should be determined in relation to the specific features and environmental conditions of the protected site concerned by the plan or project, taking particular account of the site’s conservation objectives.

Approach

As previously mentioned, there are four main stages in the AA process; the requirements for each depending on likely impacts to European Sites (SAC/SPA).

Stage One: Screening – the process which identifies the likely impacts upon a European site. Its purpose is to determine, on the basis of a preliminary assessment and objective criteria, whether a plan or project which is not directly connected with or necessary to the management of the site as a European Site, individually or in combination with other plans or projects is likely to have a significant effect on the European site.

5 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Stage Two: Appropriate Assessment – consideration is given if the impact of the project or plan would adversely affect the integrity of surrounding European Sites, either alone or in combination with other projects or plans, with respect to the site’s structure and function and its conservation objectives. Additionally, where adverse impacts have been identified, an assessment of the potential mitigation to reduce/minimise/avoid such impacts is required. This stage is the responsibility of the planning authority which is informed by a Natura Impact Statement (NIS). This stage is required where uncertainty of effect arises or a potential effect has been defined which requires further procedures/ mitigation to remove uncertainty of a defined impact.

This NIS report considers likely impacts on European Sites of the project either alone or in combination with other plans and/or projects and considers whether these effects are likely to be significant. Based on the outcomes of the ecology assessments including those undertaken as part of the EIS, detailed precautionary mitigation may be required.

Qualifying interests, threats to the qualifying interests and conservation objectives were identified for those sites which may potentially be affected by the proposal. Threats and pressures in relation to the Qualifying Interests were taken from the NPWS website database and the NPWS Article 17 report ‘Status of EU Protected Habitats and Species in Ireland’ (NPWS, 2013a).

Site specific conservation objectives have been designed to define favourable conservation status for a particular habitat or species at that site. According to the European Commission interpretation document ‘Managing Natura 2000 sites: The provisions of Article 6 of the ‘Habitats’ Directive 92/43/EEC’, paragraph 4.6(3) states: “The integrity of a site involves its ecological functions. The decision as to whether it is adversely affected should focus on and be limited to the site’s conservation objectives.”

Favourable conservation status of a habitat is achieved when:  its natural range, and area it covers within that range, are stable or increasing;

6 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

 the specific structure and functions which are necessary for its long term maintenance exist and are likely to continue to exist for the foreseeable future; and  the conservation status of its typical species is favourable.

The favourable conservation status of a species is achieved when:  population dynamics data on the species concerned indicate that it is maintaining itself on a long-term basis as a viable component of its natural habitats;  the natural range of the species is neither being reduced nor is likely to be reduced for the foreseeable future; and  there is, and will probably continue to be, a sufficiently large habitat to maintain its populations on a long term basis.

Stage Three: Assessment of Alternative Solutions – the process which examines alternative ways of achieving the objectives of the project or plan that avoid adverse impacts on the integrity of the European Site; and

Stage Four: Assessment Where Adverse Impacts Remain – an assessment of compensatory measures where, in the light of an assessment of Imperative Reasons of Overriding Public Interest (IROPI), it is deemed that the project or plan should proceed.

Consultation

A precautionary approach was taken throughout the project with the aim of avoiding, where possible, potential impacts on the ecological constraints identified. The main ecological constraints (including European sites in the surroundings) were identified at the earliest stage in the project. Consultation was undertaken with the Development Applicaitons Unit (DAU) of the National Parks and Wildlife Service (NPWS) and their response comments (received February 02, 2016; Reference G Pre00008/2016, attached in Appendix 2 of this document) were utilised in the preparation of the NIS.

The comments raised by the DAU included advice as to the extent of the assessments needed on all parts of the project including all lands, site preparation,

7 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

construction and operation phases. In particular the DAU noted that “The Primary issue that the NIS will need to focus on is the impact of phosphorus loading from the proposed treatment plant on the structure and functioning of the European Site.

8 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Stage 1: Screening

Introduction

This stage of the process identifies any likely significant impacts upon European Sites from a project or plan, either alone or in combination with other projects or plans. The screening phase was progressed in the following stages.

A series of questions are asked during the Screening Stage of the AA process in order to determine:  Whether a plan or project can be excluded from AA requirements because it is directly connected with or necessary to the management of a European Site.  Whether the project will have a potentially significant effect on a European Site, either alone or in combination with other projects or plans, in view of the site’s conservation objectives or if residual uncertainty exists regarding potential impacts.

Ecological Site Visit and Desk Study

Field walkover surveys of the proposed WwTP site and also the existing WwTP and proposed discharge point at the Glenamaddy Turlough were undertaken by a qualified ecologist on 22nd January 2016, to evaluate the baseline ecological receptors and identify the potential pathways for effects on qualifying interests (species and habitats).The walkover survey was undertaken outside of the botanical growing season; however, it allowed for an evaluation of the habitats present within the entirety of the study area (proposed WwTP site, pumping station/storm tank and existing WwTP site), as well as identification of mammal activity. Water levels within the Glenamaddy Turlough during the winter of 2015/16 were very high; with the existing WwTP site inundated. This precluded an evaluation of the botanical community within the turlough as a whole. However, it is noted that the pumping station/storm tank site and the existing access road to the WwTP were above flood water level.

In addition, a detailed online review of published scientific literature and ‘grey’ literature was conducted. This included a detailed review of the National Parks and Wildlife website, including mapping and available reports for relevant sites and in

9 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

particular sensitive qualifying interests described and their conservation objectives. The recently published report ‘Turlough Hydrology, Ecology and Conservation (Waldren et al., 2015) was reviewed; in addition to the site reports which accompany this document. The desk study included a review of the NPWS conservation objectives for the designated sites identified within the screening assessment, in addition to the conservation objectives supporting document for turlough habitats within the Galway Bay Complex SAC (NPWS, 2013b).

The EPA Envision Map-viewer and available reports were also reviewed. Technical documentation associated with the proposal and prepared by TOBIN Consulting Engineers on behalf of Irish Water, with particular reference to the Tier 3 Groundwater Risk Assessment Report (TOBIN, 2016a) were reviewed and evaluated with regard to baseline and operational water quality within the Glenamaddy Turlough, the groundwater body and the downstream aquatic environment.

The ecological desktop study completed for the proposed development comprised the following elements:  Identification of European Sites within 15km with identification of potential pathways links for specific sites (if relevant) greater than 15km from the proposed development study area (refer to Figure 9).  Review of the NPWS site synopsis and conservation objectives for European Sites with identification of potential pathways from the proposed development.

Description of the Project

The existing Glenamaddy WwTP is located to the east of the village, within the flood zone of the Glenamaddy Turlough, Co. Galway. Partially treated effluent from the existing WwTP discharges directly to the Pollnadeirce swallow hole which forms part of the Glenamaddy Turlough SAC (site code 000301), see Figure 1. Based on an assessment of water quality in the area, undertaken for the proposed upgrade of the Glenamaddy Sewerage Scheme including the proposed waste water treatment plant, the existing discharge has been identified as having an impact on the ground water in the region. Irish Water are now proposing to upgrade parts of the existing sewer network and replace the existing waste water treatment plant with a new

10 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

treatment plant where new and improved final effluent quality discharge standards will be applied to the treated effluent.

Figure 1 Location of Lough Lurgeen Bog/ Glenamaddy Turlough SAC Boundary

The existing WwTP has been in place since circa 1950 and consists of two distinct processes, which are currently overloaded and require upgrade and replacement. These are summarised as:  An inlet screening chamber where coarse bar screens remove gross solids and floating debris.  An Imhoff Settlement tank which was designed to cater for less than 300p.e. This tank when working within its design parameters, should retain the influent for a certain period of time allow gross solids to settle and form a sludge which can periodically removed for dewatering and disposal.

11 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

The existing Population Equivalent estimate for Glenamaddy is 583p.e. Historical treated effluent data from the existing Glenamaddy WwTP is presented in Table 1. It is proposed that the Glenamaddy Wastewater Treatment Plant will be designed with two streams. Each stream will be capable of treating the wastewater generated by an equivalent population of 350 p.e. allowing for partial shutdown of the plant for maintenance purposes over short periods while still maintaining the treated effluent standards.

This proposed scheme relates to the overall waste water treatment plant necessary to cater for a total design population equivalent of 700p.e.The new WWTP will be located on a new greenfield site to the north east of Glenamaddy village, in the townland of Mountkelly, outside of the SAC. The proposed pumping station/storm tank will be located adjacent to, but not within, the Lough Lurgeen Bog/Glenamaddy Turlough SAC. The location of the proposed elements are set out in Figure 2. The boundary of the SAC in relation to the proposed works is shown in Figure 1.

The existing control building, which is located within the Lough Lurgeen Bog/Glenamaddy Turlough SAC, will be decommissioned but will not be demolished and will remain standing in order to avoid the need for demolition works within the SAC. This existing site and the existing pipework are accessed via a gravelled access track. The existing treatment works will be cleaned and retained where it is also proposed to retain the existing outfall pipework and dispose of the highly treated effluent by utilising the existing outfall location.

As identified in Table 1, historical discharge from the existing waste water treatment plant exceeds the treated effluent standards detailed in the Urban Waste Water Treatment Regulations (i.e. 25mg/l BOD and 35mg/l Suspended Solids). Table 2 summarises the proposed final effluent standards for the proposed waste water treatment plant in Glenamaddy and based on a loading of 180l/hd/day, the dry weather flow for the proposed discharge is calculated at 126m3/day. These final effluent standards comply with and exceed the requirements of the Urban Wastewater Treatment Regulations. The BOD and hydraulic loading associated with the proposed Glenamaddy Sewerage Scheme have been calculated, as presented in Table 3.

12 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Alternative Site Considered Proposed WWTW Site

Proposed Pumping Station and Storm Water Tank Site

Existing WWTW

Figure 2 Location of the existing Glenamaddy WwTP, proposed new WwTP site (outlined in red and shaded green in Mountkelly) and the alternative site (outlined in green) investigated during the planning stage of the scheme.

13 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Table 1 Average Final Effluent Quality at Glenmaddy Wastewater Treatment Plant (Aug 1998 to Aug 2008) Date of Suspended Solids Ortho-Phosphate as P BOD (mg/l) Sampling (mg/l) (mg/l) Aug-98 80 64 5.9 Sep-98 160 143 9.5 Oct-98 345 125 6.5 Feb-99 250 188 5.2 Nov-99 180 121 N/A Apr-00 133 78 7.2 Nov-00 130 73 5 Feb-01 252 218 N/A Apr-01 172 112 N/A Oct-01 83 87 N/A Jan-02 222 309 N/A Oct-02 190 82 N/A Jan-03 332 245 N/A Aug-03 250 81 N/A Sept-04 129 133 3.7 Feb 07 122 369 10.3 Mar 07 152 121 21.8 April 07 131 141 21.4 June 07 N/A 138 17.6 Aug 07 240 129 21.8 Mar 08 152 121 21 Aug 08 92 59 9.1 Sept 08 112 66 17.9 Nov 08 136 95 12.9 Dec 08 144 84 6.3 Average 175 123 11.9

Table 2 Proposed Final Effluent Standards for the Glenamaddy WwTP Parameter Discharge Standards

BOD 10 mg/l

Suspended Solids 10 mg/l

Ortho-phosphate (as P) 0.5 mg/l

Total Ammonia (as N) 1.0 mg/l

Pathogenic Reduction 3 Log Reduction

14 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Table 3 Design Parameter for the Proposed Glenamaddy WWTP Description Details Population equivalent 700 p.e.

BOD Loading @ 60g/hd/d (kg/d) 42

Dry Weather Flow @ 180l/hd/day 126m3/day

3DWF Flow to Full Treatment 378 m3/day

Peak Storm Water Flow to Pumping Station 4 hours storage to be provided at new WWTP 380m3

The over-arching objective of the proposed scheme is to cease the current discharge of partially treated effluent to the Glenamaddy Turlough, by providing new waste water infrastructure that will replace the existing discharge with a new highly treated discharge utilising the existing discharge pipeline. This proposal will result in an improvement in the quality of the wastewater discharge, providing protection for the quality of ground water in the region.

Description of the Receiving Environment

Proposed WwTP site description

The proposed wastewater treatment plant is located within an extensively managed, agricultural pasture due north of Glenamaddy Town (see Figure 2). The site is set back from a local road and will be accessed by a proposed access road. The total area of lands required for the proposed waste water treatment plant and access road measure approximately 7,900m2 (0.79ha); the habitats within and surrounding the proposed site are detailed on Figure 3.

The proposed site will be accessed from the existing local road through an improved agricultural grassland pasture (GA1). Between this field and the proposed development site, due north of the local road, the fields become increasingly less managed. The proposed treatment plant site and lands between the site and the local road are characterised as being semi-improved and are characterised by wet grassland (GS4) species communities, including areas dominated by Soft Rush Juncus effusus and Iris Iris pseudocorus, as well as more species rich wet grassland dominated by Purple Moorgrass Molinia caerulea. All fields within the site are delineated by unmanaged, mature hedgerows (WL1), often associated with earth banks (BL2) and ditches (FW4). Low grazing levels within the unmanaged wet

15 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

grassland has led to encroachment of scrub with Willow Salix spp., Gorse Ulex europaeus and Bramble Rubus fruiticosus spp. agg.; often forming single species blocks within the site.

The wet grassland was characterised by the following species: Purple Moorgrass Molinia caerulea, Marsh bedstraw Galium palustre, Devils-Bit Scabious Succisa pratensis, Soft Rush Juncus effusus, Sweet Vernal-grass Anthoxanthum odoratum, Jointed Rush Juncus articulatus, Yellow Flag Iris Iris pseudocorus, Calliergonella cuspidata, Yorkshire Fog Holcus lanatus, Marsh Thistle Cirsium palustre, Orchid spp., Cocksfoot Grass Dactylis glomerata, Ling Heather Calluna vulgaris (restricted to a small stand). The species community within this grassland corresponded to the Juncus acutiflorus – Molinia caerulea grassland group (Martin et al. 2008), with areas of wet grassland within and adjacent to the site boundary broadly aligning with the Annex I habitat ‘Molinia meadows on calcareous, peaty or clayey-silt laden soils (6410)’. The better examples of this habitat were recorded from the southeastern portions of the site, outside of the proposed development site (see T3 in Figure 3) the identified pressures within the habitat area resulted in an overall conclusion that this habitat area is of partially degraded structure, and is of limited to average conservation value and of unfavourable status. The forb ratio within this habitat area is low (ca. 20%), with high scrub cover ranging from 10-100% in places. The ecological quality of the wet grassland has been adversely affected by hedgerow removal, land drainage and ongoing burning of scrub; scrub encroachment is identified as a significant pressure on this habitat. The proposed WwTP site and this wet grassland habitat is outside of and not connected to the Lough Lurgeen Bog / Glenamaddy Turlough SAC.

The site walk over survey identified high levels of fox activity within the fields crossed by the access route and at the proposed treatment plant site. Mammal crossings, identified as fox and rabbit, were also recorded from the road margins to the south of the site. A seven-entrance mammal dwelling was recorded from the hedgerow directly north of the local road, due south of the access route line; with a second single entrance mammal dwelling recorded at the northwestern corner of the same hedgerow. Both dwellings were active at the time of the survey. Although likely established by badgers, only fox prints, scats and fur were recorded at these locations and throughout the site.

16 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Figure 3 Habitats present on the proposed site and surrounding lands

17 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Figure 4 Habitats present at the existing WWTP and surrounding lands

Pumping station/Storm Tank and discharge location

The proposed pumping station/storm tank site consists of an existing animal holding pen and associated fencing (BL3), located within an improved agricultural pasture (GA1). These habitats are of low conservation importance in the local context and are located outside of the Lough Lurgeen / Glenamaddy Turlough SAC site boundary. The site is heavily grazed and dominated by a low diversity sward typical of improved grassland. The site is bordered to the north by the regional road (R362)

18 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

and to the east by an unmanaged hedgerow (WL1) and the surfaced access track to the existing wastewater treatment plant. The habitats within the pumping station/storm tank site are of low ecological value in the local context.

No signs of protected mammals were noted in the vicinity of the proposed development. Bird species recorded from the hedgerows included passerine species common in the wider countryside. A single Heron Ardea cinerea was recorded from the margin of the turlough in adjacent lands.

The proposed pumping station/storm tank is located outside of the SAC site boundary (see Figure 1 and Figure 4) within improved agricultural grassland. Habitats or species listed as conservation objectives for the Lough Lurgeen Bog/Glenamaddy Turlough SAC do not occur withinor immediately adjacent to the works area. therefore, key habitats associated with this designation will not be impacted by the footprint required for the pumping station/storm tank.

The existing Glenamaddy WwTP effluent discharges via a 225mm outfall pipe to the Pollanderice Swallow Hole within the Glenamaddy Turlough, within the Lough Lurgeen Bog/Glenamaddy Turlough SAC. Due to the position of the effluent discharge point (i.e., within the flooded turlough) it has not been possible to locate the end of the pipe or the exact discharge location. However, it is believed that the location is approximately at 53.601807, -8.549668.

Glenamaddy Turlough

The Glenamaddy Turlough was surveyed during the site visit on the 22nd of January 2016; however, high water levels prevented a detailed botanical assessment of the turlough as a whole. A series of photographs from the site are presented in the Plates section of this report. From these photos, it can be seen that the summer water level recedes significantly during summer months, but this varies annually depending on winter flood and summer weather conditions.

The turlough was previously surveyed and evaluated in an unpublished NPWS report (Goodwillie 1992). Although this report is somewhat dated, it provides the most detailed habitat and botanical assessment of this large turlough site. The turlough was not dry during the site visit undertaken by Goodwillie, during the

19 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

months of June and July; however, it was possible to record wave action erosion and bare sand and gravel on the upper shore. Two botanical communities were identified, the first being a mixture of Polygonum amphibium, Glyceria fluitans, Eleocharis palustris, Littorella, Sparganium emersum and Lysimachia vulgaris, with Menyanthes and Potentilla palustris. At the south-western corner this changed to a community described by Potamogeton gramineus and Rorippa amphibium.

Based on the water quality data and botanical communities recorded, Goodwillie (1992) identified that the baseline condition in the Glenamaddy Turlough was low in lime, potentially due to the inputs from the Lough Lurgeen Bog. There was an assumption that the existing WwTP discharge at that time was contributing to eutrophication in the turlough, affecting what was considered to be a more naturally oligotrophic waterbody.

Hydrology and Hydrogeology

There is no surface drainage from Glenamaddy Turlough and it is known that the turlough is linked to Lettera Spring, located 3.5 km due west as identified in the Tier 3 Groundwater Risk Assessment Report (TOBIN, 2016a). Lettera Spring forms a tributary of the Sinking River, itself a tributary of the River Clare. The Sinking River and the River Clare are designated within the Lough Corrib SAC (site code 000297). The SAC boundary on the Sinking River is approximately 1.15 km downstream of Lettera Spring. The Glenamaddy Turlough does not form part of the EPA River Water Quality Monitoring Programme, therefore historical data on its water quality is not available.

From the findings of the Tier 3 Groundwater Risk Assessment Report (TOBIN, 2016a) there are limited data available for Lettera Spring (WS6) therefore the baseline has been supplemented by data collected specifically for this study. The water sampling for this study also included Gortgarrow (WS5), Bushtown (WS7), the Yellow River (WS9) a tributary of the Sinking River, Kingstown Stream (WS8), Springfield river (WS10 Blackers Bridge), two tributaries of the Shiven River (WS2, and WS3), one of the streams leading into Glenamaddy Turlough (WS4), and the waste water at the existing plant (WS11). Site locations are provided in Figure 5. The Tier 3 Groundwater Risk Assessment Report confirms that Lettera spring responds quickly to rainfall events and that the water is more turbid, with increased

20 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

suspended solids and lower electrical conductivity. Additionally, persistent microbial contamination is evident in the majority of the water samples taken for this study. However, at Lettera the faecal coliform counts are greater than 100 per 100 ml in 8 out of 9 samples, and are generally greater than Bushtown and Gortgarrow Springs, and the surface water sampling points, with the exception of WS9 (Yellow River), and WS4 – one of the streams feeding Glenamaddy Turlough. On this basis it is evaluated that the existing partially treated WwTP discharge is registering an impact on the Glenamaddy Turlough; however, this is compounded by unsatisfactory water quality entering the turlough from diffuse sources within the influent tributaries.

In summary, microbial contamination is present in all the sampling points, however, Lettera is nearly always ‘grossly’ contaminated. Ammonium and phosphate concentrations are occasionally elevated at Lettera, though the mean concentrations are low. The mean ammonium concentration at Lettera is 0.12 mg/l as N which is double that at Gortgarrow (0.06 mg/l as N) from the EPA dataset and greater than the groundwater threshold value for the surface water test (0.065 mg/l as N) (Groundwater regulations, S.I. No. 9 of 2010). The phosphate concentrations at Lettera are generally higher than the other springs and generally lower than those taken from the larger streams, and lower than the small stream tributaries (WS2 and WS3). The phosphate concentrations appear to be rapidly attenuated. Concentrations of ammonium and phosphate and coliform counts are notably higher in the northerly surface stream (WS4) feeding Glenamaddy Turlough than the two streams sampled within the study area (WS2 and WS3) which are tributaries of the Shiven River. The sampling results indicate diffuse pollution to the turlough via the WS4 watercourse.

The surface water samples (WS2, WS3 and WS4) provide an indication of the water chemistry of the turlough.Additional sampling was undertaken at the point of discharge of Lettera Spring, which was indicative of fully mixed conditions within the Glenamaddy Turlough. Due to the size and depth profile within the turlough, accounting for discharge from the existing WwTP entering the swallow hole, it was considered that water chemistry sampling within the lentic environment would not provide representative values for the purpose of the current study. The water quality at Lettera Spring was therefore utilised as a representation or proxy for the fully

21 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

mixed conditions within the turlough, accounting for the point source discharge from the existing WwTP.

With respect to ammonium, surface water samples (WS4) have a mean ammonium concentration of 0.4 mg/l and the samples at WS2 and WS3 have means of 0.28 mg/l and 0.15 mg/l respectively. These data suggest that ammonia concentrations in the turlough may be elevated prior to contributions from the waste water plant. With respect to phosphorous, the mean concentration at WS4 is 0.0198 mg/l as P, and at WS2 and WS3 the mean concentrations are 0.013 and 0.014 mg/l as P respectively.

22 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Figure 5 Water sample locations

The environs of Glenamaddy are located in the Clare–Corrib Groundwater body, out of which a subset is delineated for Glenamaddy Turlough, named the Glenamaddy Turlough Groundwater Dependent Terrestrial Ecosystem (GWDTE) Groundwater Body. Both the Clare–Corrib and the Glenamaddy Turlough GWDTE Groundwater bodies are currently classified as being of ‘Good Status’, though were previously classed at ‘Poor Status’ due to failing the WFD Surface Water Quality test, i.e., impact of groundwater quality on surface water ecology with groundwater contributing greater than 50% load to cause a breach of the river phosphate

23 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

environmental quality standard. However, Glenamaddy Turlough GWDTE Groundwater Body is ‘At Risk’ of not achieving ‘Good Status’ due to the risk of the Glenamaddy urban waste water treatment not being upgraded. Ground water flow and dye traces have been completed by the GSI in the Glenamaddy area. An additional study, utilising nine piezometer sites within the wider study area, collected data on groundwater flows. This information is presented in the Tier 3 Groundwater Risk Assessment Report (TOBIN 2016a); Figure 6 summarises the results of these trace studies where tracer dye was injected into the Pollanadeirce Swallow Hole and St Joseph’s Swalllow Hole (marked as Tracer Tests 1 and 2). The point at which the trace dye appears above ground is also identified. These tests have shown that water flowing underground at Pollanadeirce emerges at Lettera Mill 3.5 km west of Glennamaddy and that there is a good link between the swallow holes in Glennamaddy and the spring at Lettera. These dye tests show that the discharge of untreated wastewater into the Pollanadeirce Swallow Hole would have a potential impact on the quality of ground water throughout the area.

Figure 6 Dye Trace Studies in the Glenamaddy Area (GSI Webmapping)

24 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Surface and ground water quality monitoring was undertaken in the surrounding area in 2015. Monitoring results demonstrate the negative impact of the existing discharge from Glenamaddy WwTP on the ground water quality in the region. Monitoring results presented in Table 4 highlight that the concentrations of E-Coli at the Lettera Spring, which is known to be connected to the turlough via underground conduits, are high when compared to other springs in the area such as Bushtown and Gortgarrow that are not connected to the Glenamaddy Turlough. Table 4 Ground Water Quality in the Glenamaddy locality (8 No. Grab Samples taken from January to March 2015 Site Location and Location Description BOD E-Coli Code Description WS4 Townland of A surface water stream Corracullin upstream of the < 4.0 28 (surface water) Glenamaddy Turlough Townland of A surface water stream WS3 Cloonlora South upstream of the < 4.0 29 (surface water) Glenamaddy Turlough WS5 Gortagarrow A spring which is not South (spring) connected to the < 4.0 21 Glenamaddy Turlough WS7 Bushtown (spring) A spring which is not connected to the < 4.0 52 Glenamaddy Turlough WS6 Lettera (spring) A spring which is connected < 4.0 310 to the Turlough WS11 Background Water quality in Turlough Close to the partially treated adjacent to the effluent discharge at the 26 >10000 existing primary Turlough discharge point

With regard to geology, Figure 7 and Figure 8 detail the extent and vulnerability of groundwater bodies in the Glenamaddy area. Figure 7 shows that the bedrock aquifer at the discharge point is a regionally important aquifer. Figure 8 shows the groundwater vulnerability in the area. Aquifer vulnerability at the location of the existing WwTP is “M-Moderate”. The primary discharge point discharges to open water however the Turlough is surrounded by “X-Rock at or near surface or Karst”.

25 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Figure 7 Local Aquifer Importance (GSI Groundwater Data Viewer)

Figure 8 Mapped groundwater vulnerability; karst features; proven underground connections

26 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Identification of Relevant European Sites

An initial distance of 15km from the proposed site boundary was used for consideration of European Sites in accordance with DoEHLG guidance (2010), as shown in Figure 9. A total of thirteen European Sites are located within 15km of the proposed development.

Designated European Sites in excess of this 15km buffer were also subjected to screening, in order to determine potential linkages to the proposed development with regard to potential pathways for impacts. No additional SPA or SAC sites were screened in, following this process. Additional designated sites including proposed Natural Heritage Areas (pNHA’s), Natural Heritage Areas and RAMSAR sites where also reviewed as although they do not form part of the Appropriate Assessment, they often provide important supporting functions to European Sites.

Figure 9 European Sites within 15km of the Proposed Site Boundary (source: NPWS mapviewer)

27 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

An important element of the AA process is the identification of the “Qualifying Interests” of European Sites requiring assessment. Qualifying Interests are the habitats and species for which each European Site has been designated and afforded protection. It is also vital that the threats to the ecological / environmental conditions that are required to support Qualifying Interests are considered as part of the assessment. A list of the designated Natura 2000 sites and their respective Qualifying Interests identified during the screening process is presented in Table 5 below.

The AA process at screening stage requires the identification as to whether the proposal, alone or in combination with other plans or projects, has the potential to result in significant adverse effects on any Natura 2000 sites with respect to their conservation objectives. This was undertaken by identifying European Site specific issues to ensure the assessment and evaluation of potential impacts was correctly informed. Where the potential for significant effects is identified, these Sites will be assessed with regard to integrity level impacts within the NIS (i.e. Stage 2).

Table 5 European Sites and their Qualifying Interests within 15km of the Proposed Works European Site Qualifying Interest(s) and Site Code Lough Lurgeen 7110* Active raised bogs Bog / Glenamaddy 3180* Turloughs Turlough SPA/SAC 7120 Degraded raised bogs still capable of natural regeneration (000301) 7150 Depressions on peat substrates of the Rhynchosporion Lisnageeragh Bog 3180* Turloughs and Ballinastack 7110* Active raised bogs Turlough SAC 7120 Degraded raised bogs still capable of natural regeneration (000296) 7150 Depressions on peat substrates of the Rhynchosporion 7110* Active raised bogs Camderry Bog 7120 Degraded raised bogs still capable of natural regeneration SAC (002347) 7150 Depressions on peat substrates of the Rhynchosporion 7120 Degraded raised bogs still capable of natural regeneration Curraghlehanagh 7110* Active raised bogs Bog SAC (002350) 7150 Depressions on peat substrates of the Rhynchosporion 7110* Active raised bogs Shankill West Bog 7120 Degraded raised bogs still capable of natural regeneration SAC (000326) 7150 Depressions on peat substrates of the Rhynchosporion 3140 Hard oligo-mesotrophic waters with benthic vegetation of Chara spp. 3110 Oligotrophic waters containing very few minerals of sandy plains (Littorelletalia uniflorae) Lough Corrib SAC 91A0 Old sessile oak woods with Ilex and Blechnum in British Isles (000297) 7230 Alkaline fens 7210* Calcareous fens with Cladium mariscus and species of the Caricion davallianae 8240*Limestone pavements

28 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

European Site Qualifying Interest(s) and Site Code 91D0*Bog woodland 7150 Depressions on peat substrates of the Rhynchosporion 7110* Active raised bogs 6410 Molinia meadows on calcareous, peaty or clavey-silt-laden soils (Molinion caeruleae) 6210* Semi-natural dry grasslands and scrubland facies on calcareous substrates (Festuco Brometalia)(*important orchid sites) 7120 Degraded raised bogs still capable of natural regeneration 3260 Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation 7220* Petrifying springs with tufa formation (Cratoneurion) 1095 Petromyzon marinus 1106 Salmo salar 1303 Rhinolophus hipposideros 1355 Lutra lutra 1393 Drepanocladus vernicosus 1833 Najas flexilis 1096 Lampetra planeri 1092 Austropotamobius pallipes 1029 Margaritifera margaritifera 7110* Active raised bogs Carrownagappul 7120 Degraded raised bogs still capable of natural regeneration Bog SAC (001242) 7150 Depressions on peat substrates of the Rhynchosporion 91D0* Bog woodland Corliskea / Trien / 7110* Active raised bogs Cloonfelliv Bog 7120 Degraded raised bogs still capable of natural regeneration SAC (002110) 7150 Depressions on peat substrates of the Rhynchosporion Kilsallagh Bog SAC 7110* Active raised bogs (000285) 7120 Degraded raised bogs still capable of natural regeneration 7150 Depressions on peat substrates of the Rhynchosporion Levally Lough SAC 3180* Turloughs (000295) Coolcam Turlough 3180* Turloughs SAC (000218) Croaghill Turlough 3180* Turloughs SAC (000255) Williamstown Turloughs SAC 3180* Turloughs (002296)

Likely Significant Impacts from the Proposed Development on European Sites

This section documents the final stage of the screening process. It is vital that an assessment of potential source-pathway-receptor links is undertaken to assess potential impact links between the receptor (European Sites) and source (proposed development) to establish the risk of any likely significant effects. Information collected on the pressures and threats affecting the Qualifying Interests of each European Site were identified, and evaluated with regard to the proposal. Likely significant effects from the construction, operation and decommissioning stages of the proposed development are described. This assumes the absence of mitigation

29 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

measures, with the exception of those incorporated in the design stage (e.g. avoidance, standard best environmental practice).

Potential In-Combination Effects

There are no potential direct or indirect impacts identified at the proposed WwTP treatment site to the north of Glenamaddy village that could give rise to in- combination effects on any Natura 2000 site. This is due to the absence of designated sites or their qualifying interests within the site, neither were such sensitivities recorded adjacent to or connected via ecological pathways (e.g. surface water). Water quality in the Glenamaddy Turlough is identified as the principal receptor for in combination effects. The existing and proposed discharge point lies within the Lough Lurgeen Bog/Glenamaddy Turlough SPA/SAC (000301). From a review of discharge licences and planning applications, there are no other existing or planned licensed discharges to the Glenamaddy Turlough within the SAC.

Water from the Pollanadeirce Swallow Hole, which forms part of the Glenamaddy Turlough SAC, emerges at Lettera Spring. Lettera Spring is a headwater tributary of the Sinking River, which is designated within the Lough Corrib SAC (000297). Therefore, discharge from the Glenamaddy WwTP has the potential to give rise to water quality impacts to the Sinking River within this Natura 2000 site. There is currently one other WwTP discharging to the Sinking River, namely Dunmore WwTP, Licence No D0370-01. The EPA has a monitoring station located 0.4km downstream from Dunmore WwTP at the Bridge at Dunmore Castle. The River Water Quality Status 2004-2014 at this location is Q2-3, Q3 Poor Status. The overall Riverbody Risk Score for the Sinking River is “At risk of not achieving good status”.

Glenamaddy Turlough and the Sinking River are both located within the Western River Basin District (Water Framework Directive) and the co-ordinating authority for this basin is Galway County Council. The WFD has characterised water bodies in the Glenamaddy area, these are displayed in Table 6 below. Based on this initial characterisation by the Western River Basin District it is inferred that the continued use of septic tanks and percolation areas and package plants particularly in high concentrations such as small village centres (i.e. diffuse sources of pollution)

30 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

presents a risk to the water quality of both ground water and river water bodies in the Glenamaddy area. The development of the proposed Glenamaddy Wastewater Treatment Plant presents Irish Water with an opportunity to reduce the in combination risk of ground water and river water pollution in the area.

Table 6 Risk Characterisation of Water Bodies in the Glenamaddy Area At Risk of Probably At Strongly Not Expected to Risk of Not expected to Water Body Achieving Achieve Achieving achieve Good Good Status Good Status good status Status Ground Water Bodies in  ------Glenamaddy Area River Water Bodies to  ------the West of Glenamaddy River Water Bodies to  ------the East of Glenamaddy

Further to this, the Western River Basin District Groundwater Action Programme lists the Glenamaddy WWTW as one of the point source pressures identified in the area. Other point source pressures listed include landfills (4No.), mines (1No.), quarries (2No.) and contaminated land (2No.) Diffuse source pressures include agriculture and large urban centres. The Clare River Water Management Unit Action Plan notes that the Glenamaddy WWTP is one of a number of point sources that have been prioritised for capital works upgrades (Western River Basin District, 2010).

The Screening Stage identified likely significant effects of the proposed development both alone and in combination with other plans or projects (Table 7). The potential for adverse effects with respect to water quality with implications for the qualifying interests and conservation objectives of the Lough Lurgeen Bog / Glenamaddy Turlough SAC and the Lough Corrib SAC are assessed further in Stage 2 of the NIS. The NPWS site synopses for these designations are presented in Appendix 1.

31 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Table 7 Potential for adverse effects on designated European Sites and their Qualifying Interests European Site Qualifying Interest(s) and Conservation Threats and Pressures3 Description of potential (including Conservation Status1, 2, 3 Objective2 significant impacts from the distance from proposed development proposed development) Lough Lurgeen Habitats: To maintain or restore Threats to water quality from During construction stage there is Bog/Glenamaddy 7110* Active raised bogs the favourable nutrient enrichment the potential for an increase in Turlough SAC 3180* Turloughs conservation condition Peat Cutting/extraction/ removal levels of silt and suspended solids (000301) 7120 Degraded raised bogs still of the Annex I Drainage in surface water run-off from the capable of natural regeneration habitat(s) for which the Burning site. This could occur as a result Upgraded WwTP 7150 Depressions on peat SAC has been Mowing/cutting of grassland of traffic and construction works. discharge within substrates of the selected. Fertilisation Discharge of waste water to the the SAC boundary. Rhynchosporion Forest planting on open ground SAC could have a negative effect Grazing with respect to nutrient Electricity and phone lines enrichment.

There are no pathways for effects identified arising from the proposed development that would have the potential for significant adverse effects on the peatland habitats designated within this site. Potential effects are therefore limited to the Turlough itself.

1 The Status of EU Protected Habitats and Species in Ireland (Vol II & III), NPWS, 2013: http://www.npws.ie/publications/article17assessments/article172013assessmentdocuments/Article_17_Web_report_habitats_v1.pdf http://www.npws.ie/publications/article17assessments/article172013assessmentdocuments/Article_17_Web_report_species_v1.pdf 2 Sourced from NPWS website – Conservation Objective Documents http://www.npws.ie/protectedsites/ 3 Sourced from Natura 2000 Standard Data Forms (NPWS, November 2013) and/or professional judgement.

32 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

European Site Qualifying Interest(s) and Conservation Threats and Pressures3 Description of potential (including Conservation Status1, 2, 3 Objective2 significant impacts from the distance from proposed development proposed development) Lough Corrib SAC Habitats: To maintain or restore Threats to the quality of the site Potential for impact on the quality (000297) 3140 Hard oligo-mesotrophic the favourable from water polluting activities of the Sinking River, in Approx. 4.6 km waters with benthic vegetation of conservation condition resulting from intensification of combination with surrounding land west Chara spp.; 3110 Oligotrophic of the Annex I agricultural activities on the practices such as slurry spreading waters containing very few habitat(s) and/or the eastern side of the lake Potential for an impact on the minerals of sandy plains Annex II species for Uncontrolled discharge of quality of the water in the Sinking (Littorelletalia uniflorae); 91A0 which the SAC has sewage which is causing River in combination with Old sessile oak woods with Ilex been selected localised eutrophication of the discharges from Dunmore WWTP and Blechnum in British Isles; lake further downstream. 7210* Calcareous fens with Housing and boating Significant impacts on aquatic Cladium mariscus and species development which is causing Qualifying Interests of the SAC of the Caricion davallianae; the loss of native lakeshore cannot be conclusively screened 6410 Molinia meadows on vegetation out due to their sensitivity to calcareous, peaty or clavey-silt- The raised bog habitats are alterations in water quality (in laden soils (Molinion caeruleae); susceptible to further particular aquatic Annex II 6210* Semi-natural dry degradation and during out due species including Atlantic Salmon, grasslands and scrubland facies to drainage and peat cutting and White-clawed crayfish, Brook on calcareous substrates on occasions burning lamprey and Otter; therefore (Festuco Brometalia)(*important Invasive species further assessment in required in orchid sites); 7120 Degraded Fertilisation Stage 2. raised bogs still capable of Forestry natural regeneration; 7150 Pollution There are no pathways for Depressions on peat substrates Hydraulic changes impacts identified that would be of the Rhynchosporion; 3260 Peat cutting threatens likely to give rise to significant Water courses of plain to Addergoold Bog adverse effects on the terrestrial montane levels with the Fishing and shooting are a Annex I habitats or Annex II Ranunculion fluitantis and threat in and around the lake species listed as qualifying Callitricho-Batrachion Introduction of exotic crayfish interests of this site. vegetation; 7220* Petrifying species or the crayfish fungal springs with tufa formation plague could have a serious The distance between the (Cratoneurion); 7230 Alkaline impact on the native crayfish proposed WwTP discharge and

33 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

European Site Qualifying Interest(s) and Conservation Threats and Pressures3 Description of potential (including Conservation Status1, 2, 3 Objective2 significant impacts from the distance from proposed development proposed development) fens; 7110* Active raised bogs; population Lough Corrib, recognising the 8240* Limestone pavements; The bat roost is susceptible to population of Freshwater pearl 91D0* Bog woodland disturbance or development mussel on the western shore of Species: the lake, precludes the likelihood 1095 Petromyzon marinus; of any significant adverse effects 1106 Salmo salar; 1303 on these qualifying interests. Rhinolophus hipposideros; 1355 Lutra lutra; 1393 Drepanocladus vernicosus; 1833 Najas flexilis; 1096 Lampetra planeri; 1092 Austropotamobius pallipes; 1029 Margaritifera margaritifera;

34 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Screening Conclusion

From the thirteen European Sites identified and assessed in the current screening, potential source pathways between the sites and the proposed development have been examined with respect to their conservation objectives. By applying the precautionary principle, it was determined that the proposed development, alone or in combination with other plans or projects may have the potential for significant effects on two designated European Sites, the Lough Lurgeen Bog/Glenamaddy Turlough SAC (site code 000301) and the Lough Corrib SAC (site code: 000297). Further assessment as part of the NIS, is therefore required.

The remaining eleven European Sites were not considered likely to be potentially at risk of significant adverse effects, in the absence of direct or indirect impacts, taking account of pathways for effects. These sites are therefore not considered further within this report.

35 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Stage 2: Information for Appropriate Assessment

Introduction

This stage of the AA process, often referred to as “Stage 2” assesses potential impacts of the proposed development on the integrity of surrounding European Sites, with respect to the conservation objectives of each European Site and its general structure and function. Where potential impacts cannot be avoided, mitigation measures are often applied in order to avoid or minimise the risk. Two European Sites were identified during the AA Screening as potentially being at risk of significant impacts from the proposed development, alone and/or in-combination.

These sites were:  Lough Lurgeen Bog/ Glenamaddy Turlough SAC (Site Code: 000301); and  Lough Corrib SAC (Site Code: 000297)

Specific threats to each European Site and its Qualifying Interests are discussed below.

Characterisation of European Sites

Lough Lurgeen Bog/ Glenamaddy Turlough SAC (Site Code: 000301)

The proposed upgraded Glenamaddy WwTP discharge will utilise the existing discharge pipe infrastructure located within the boundary of the Lough Lurgeen Bog/Glenamaddy Turlough SAC. The SAC is designated for the presence of four Annex I habitats, listed as Qualifying Interests in Table 7 above. No site-specific conservation objectives have been publicised for this SAC; therefore the generic conservation objectives available on the NPWS website were referenced (NPWS 2015).

The habitats given as Qualifying Interests for the Lough Lurgeen Bog / Glenamaddy Turlough SAC are active raised bog (priority habitat), degraded raised bogs still capable of natural regeneration, depressions on peat substrates, and a Turlough (priority habitat). The three peatland habitats are closely inter-linked; where the raised bog feeds a small lake to the south of the turlough; this lake discharges into

36 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

the turlough via a short overground watercourse. The water level in the Glenamaddy Turlough can rise quickly as a result of heavy rain and is prone to flash flooding. The turlough is large, covering in excess of 170 hectares. The raised bog is approximately 1,000 hectares of typical intact, western raised bog. Four bird species listed on Annex I of the Birds Directive have been recorded at the Turlough, the Greenland White-fronted Goose, Bewick’s Swan, Whooper Swan and the Golden Plover (Ni Bhroin, 2008). The primary threats to the Annex I Habitats are as follows (see also Table 7):  Threats to water quality from nutrient enrichment;  Peat Cutting/extraction/ removal;  Drainage;  Burning;  Mowing / cutting of grassland;  Fertilisation;  Forest planting on open ground;  Grazing;  Electricity and phone lines.

Of these nine threats, only the potential for nutrient enrichment is identified with respect to the current proposal, and this is limited to the surface water quality in the turlough, as the bog and associated lake are upstream in the catchment. The existing WwTP, with partially treated effluent is considered to be having an unquantified adverse effect on water quality in the turlough. There are no pressures or threats currently affecting the area, grazing regime or hydrological structure and functions associated with this turlough that may have potential interactions with the proposed WwTP upgrade.

The NPWS conservation objectives for turlough habitats, prepared for the Galway Bay Complex SAC (00268) have been reviewed (NPWS 2013b), due to the absence of detailed conservation objectives for the Glenamaddy Turlough. The Water Framework Directive (WFD) Working Group on Groundwater developed a methodology to assess the risk to turloughs from phosphorus pollution, which established provisional phosphorus thresholds for turlough flood waters and the up- gradient groundwater (Working Group on Groundwater, 2005). Two total phosphorus (TP) thresholds were set for the turlough water, depending on the site’s

37 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

fertility and sensitivity to phosphorus enrichment. A threshold of ≤10μg l-1 TP was set for the least fertile (‘extremely sensitive’) turloughs as defined by the vegetation communities, and a threshold of ≤20μg l-1 TP for all other turloughs. These values were based on the Phosphorus Regulations’ standards for TP in Irish lakes, which indicate that when mean TP is ≤10μg l-1 a lake is oligotrophic and >10 to ≤20μg l-1 mesotrophic. The target for water quality (nutrients) within turlough habitats is to maintain average annual TP concentration of ≤10μg l-1 TP, or ≤20μg l-1 TP, for oligotrophic and mesotrophic turlough habitats, respectively. It is considered that the control of Phosphorus inputs into the Glenamaddy Turlough, to which the proposed WwTP upgrade will contribute significantly, will effectively maintain the additional water quality attributes identified as: colour; phytoplankton biomass; and epiphyton biomass.

The Tier 3 Groundwater Risk Assessment Report (TOBIN, 2016a) sets out mean phosphate (filtered molybdate reactive phosphate) concentrations for samples collected from Lettera Spring. The water sampling for the Tier 3 Groundwater Risk Assessment also included Gortgarrow (WS5), Bushtown (WS7), the Yellow River (WS9) a tributary of the Sinking River, Kingstown Stream (WS8), Springfield river (WS10 Blackers Bridge), two tributaries of the Shiven River (WS2, and WS3), one of the streams leading into Glenamaddy Turlough (WS4), and the waste water at the existing plant (WS11). Sampling locations are set out in Figure 10. Mean Phosphate results for all sampling stations in the study area (2014-2015 sampling period) are presented graphically in Figure 11.

Recognising the hydrogeological connectivity between the turlough and Lettera Spring, via the swallow hole, water quality in Lettera Spring has been utilised as a proxy for background, fully-mixed water quality conditions in the Glenamaddy Turlough; with respect to the existing and proposed discharge. Values for mean Phosphate (filtered molybdate reactive phosphate) in Lettera Spring, recorded over the period October 2014 to March 2015, range from less than the limit of detection (0.05 mg/l as PO43-) to 0.083 mg/l as PO43-, with a mean of 0.05 mg/l as PO43- (8 samples). For Phosphate (PO43-), the range is from 0.0082 to 0.027 mg/l; with a mean of 0.016 mg/l as P. Total Phosphorous concentration at Lettera Spring was recorded as 0.018 mg/l, as P. These values are below the groundwater threshold value for the surface water test (0.035 mg/l as P) (Groundwater Regulations, S.I.

38 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

No. 9 of 2010). Where Lettera Spring represents water quality within the Glenamaddy Turlough it is clear that these concentrations are within the range of 0.01–0.02 mg/l as P for oligotrophic and mesotrophic turloughs (NPWS, 2013).

Glenamaddy Turlough

Figure 10 Tier 3 Groundwater Risk Assessment Sampling Locations

The data presented above demonstrates that phosphate concentrations in Lettra Spring are generally higher than other springs within the study area. This is unsurprising considering that Lettera is directly connected to Glenamaddy Turlough which currently receives partially treated effluent from Glenamaddy WwTP. Notably, Glenamaddy Turlough is fed by three streams, one of which was sampled during

39 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

the Tier 3 Risk Assessment (i.e. WS4). Sample results show that WS4 has a higher mean concentration of phosphate than the concentration at Lettra Spring.

The phosphate concentrations at Lettera are generally higher than the other springs and generally lower than those taken from the larger streams, and lower than the small stream tributaries (WS2 and WS3).

0.0600

0.0500

0.0400

0.0300

0.0200

0.0100 phosphate filtered (mg/l) P (mg/l) asfiltered phosphate

0.0000 18-Sep-14 08-Oct-14 28-Oct-14 17-Nov-14 07-Dec-14 27-Dec-14 16-Jan-15 05-Feb-15 25-Feb-15 17-Mar-15

WS6 Lettera WS5 Gortgarrow WS7 Bushtown WS9 Sinking River WS2

WS3 WS4 WS10 WS8 Kingstown stream River EQS

Figure 11 Chart of mean phosphate concentrations from field data collected for the Tier 3 Groundwater Assessment

The proposed highly treated effluent discharge from the upgraded Glenamaddy WwTP will result in an improved treatment standard, leading to a reduction in the scale and significance of nutrient inputs and enrichment within this habitat. This water quality improvement is expected to have no adverse effects on the conservation objectives of the turlough habitat with regard to vegetation structure, botanical species communities, and faunal species communities (NPWS, 2013).

Lough Corrib SAC (Site Code: 000297)

The Sinking River, hydrologically connected to the Glenamaddy Turlough, is designated within the Lough Corrib SAC, and is located approximately 4.6 km west of the proposed Glenamaddy WwTP discharge at its closest point. This SAC is designated for twenty three Qualifying Interests, including both Annex I habitats and

40 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Annex II species, as detailed in Table 7 above. No specific conservation objectives have been published for this SAC, therefore the generic conservation objectives prepared by NPWS in 2015 have been referenced4. Lough Corrib is situated to the north of Galway city and is the second largest lake in Ireland, with an area of approximately 18,240 ha (the entire site is 20,556 ha). A number of rivers are included within the SAC, as they are important for Atlantic Salmon, in addition to a wider variety of other Annex II aquatic and water-dependant species. These rivers include the Clare and Sinking Rivers. The primary threats to the Annex I habitats listed in Table 7 of the Lough Corrib SAC are as follows:  Threats to the quality of the site from water polluting activities resulting from intensification of agricultural activities on the eastern side of the lake;  Uncontrolled discharge of sewage which is causing localised eutrophication of the lake;  Housing and boating development which is causing the loss of native lakeshore vegetation;  The raised bog habitats are susceptible to further degradation and during out due to drainage and peat cutting and on occasions burning;  Peat cutting threatens Addergoold Bog;  Hydraulic changes;  Pollution

The proposed works at the Glenamaddy WwTP aim to improve the quality of the effluent leaving the WwTP, thus reducing the potential threat of eutrophication and/or pollution of the waterbodies designated within the Lough Corrib SAC.

Identification of Relevant Qualifying Interests

There are no potential pathways for effects arising from the proposed development that would have the potential to adversely affect the terrestrial or wetland Annex I habitats listed as Qualifying Interests of the Lough Corrib SAC. This is evaluated principally on account of the limited footprint of the proposed works, the scale of effects with regard to the improved, upgraded WwTP discharge, and the distance

4 NPWS (2015) Conservation objectives for Lough Corrib SAC [000297]. Generic Version 4.0. Department of Arts, Heritage and the Gaeltacht.

41 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

between the proposed development and the qualifying interests located within or associated with Lough Corrib (ca. 50 km).

The National Biodiversity Data Centre (NBDC) Mapping System documents what is known about the different protected and threatened species that occur in Ireland. The NBDC has the locations of recorded sightings of the Lesser Horseshoe Bat in Ireland5. The closest sighting was at Gallagh, Brownsgrove Tuam, in 1988; approximately 20km from the location of the proposed works. Due to the distance of this sighting from the proposed works, there is no potential for any impact on the Lesser Horseshoe Bat. Slender Naiad and Slender Green Feather-moss were not identified during the site assessment and it is improbable that they would occur, due to the absence of suitable habitat within the footprint of the works, or within the direct zone of effects.

In relation to Brook Lamprey, surveys by King & Linnane (2004); O’Connor (2006a and 2006b); and O’Connor (2007), have evaluated Lamprey stocks in Ireland, and have found that they are widely distributed in catchments where suitable habitat is available. On this basis, Brook Lamprey have been classified in the IUCN Red List as ‘Least Concern’. The Red List identifies ‘pollution’ and ‘barriers to passage’ as particular threats to Brook Lamprey. Sea Lamprey is listed as The ‘Near Threatened’ on the IUCN Red List. This species has been recorded in a number of catchment‐wide surveys (e.g. King & Linnane, 2004; O’Connor, 2004, 2006, 2007) but generally in small numbers and in locations focussed at the downstream end of the main stem channel and below major weirs. Sea lampreys have been reported to regularly spawn below the regulating weir in Galway (Igoe et al, 2004). Consequently, due to the distance of identified spawning sites from the proposed development (i.e. c.50 km) there is no potential that Sea lampreys will be impacted by the proposed works.

Atlantic Salmon is a Qualifying Interest of the Lough Corrib SAC. Salmon use rivers to reproduce and as nursery areas during their juvenile phase. The Ireland Red List No. 5 has identified Atlantic Salmon as a threat status of Vulnerable (VU), as stocks

5 Available online at: http://maps.biodiversityireland.ie/#/Map/NbdcTerrestrial/Species/119456

42 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

have been in decline since the 1970s. The Red List identifies both ‘pollution’ and ‘barriers to passage’ as particular threats to Atlantic Salmon (King et al. 2011).

Moorkens, (1999) has identified the presence of living Freshwater Pearl Mussel populations on the Western Bank of Lough Corrib. According to RPS, (2009) Freshwater Pearl Mussel populations have been identified in the Owenriff (Corrib) River. However, Freshwater Pearl Mussel have not been recorded within the Sinking River. Suitable habitat for this species does not occur due to physical (i.e. no clean sands and gravels) and chemical characteristics (i.e. siliceous geology required not calcareous). Due to the distance (c. 50km) of the Owenriff (Corrib) River and Lough Corrib from the proposed development, there is no potentialthat Freshwater Pearl Mussel populations will be impacted by the proposed works.

Lucey et al. (1987) have identified stream populations of White-clawed Crayfish on the Sinking River. However, at the time of the survey (i.e. 1987), the Sinking River had a biological rating of Q4, i.e. ‘Good Status’. The Sinking River is most recently evaluated with a biological rating of Q3 ‘Moderate Status’. However, it is considered that crayfish populations persist within this watercourse, as they are tolerant of moderate pollution.

No evidence of Otter was noted within the site boundary during field surveys. Although it is considered unlikely that this species regularly frequents the area of the existing and proposed discharge in the Glenamaddy Turlough, there is the potential for this species to be found within permanent watercourses connected to the Sinking River downstream. The National Biodiversity Data Centre was reviewed for records of otter activity, with observations from Kiltullagh Lough (approximately 2km southwest) and from the Sinking River (approximately 8km west); however, no records were available for Glenamaddy Turlough.

Although no specific baseline was available on the distribution of the Annex I habitat ‘Floating River Vegetation’ in the Sinking River, within the Lough Corrib SAC designation, it is considered that there is the potential for this habitat to occur.

Potential therefore exists for the presence of the Annex I habitat ‘Floating River Vegetation’ and the Annex II freshwater species (salmon, otter, brook lamprey, and

43 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

white-clawed crayfish) to occur within the Sinking River. However, the proposal does not require any works within the Lough Corrib SAC which would have the potential to cause a barrier to the passage of these species. The water quality in the Sinking River is Moderate at present (Q3 on the EPA Envision Watermaps). This limits the value of its waters to salmon and adult lampreys though probably not to the lamprey larvae. The proposed works aim to improve the quality of the final discharge from the Glenamaddy WwTP thus reducing the existing loading to the Glenamaddy Turlough and indirectly to the Sinking River within the Lough Corrib SAC downstream. The potential for effects on the Annex I habitat and Annex II species identified are therefore limited to those effects in relation to water quality and, indeed, water quality improvement.

Identification of Potential Effects

Potential impacts arising from the upgrading of the Glenamaddy WwTP which have been identified to result in adverse impacts, either alone or in combination, upon the Qualifying Interests and Conservation Objectives of the Lough Lurgeen Bog / Glenamaddy Turlough SAC and the Lough Corrib SAC, are identified, detailed, and evaluated.

Ecological impact assessment of potential impacts on European Sites is conducted utilising a standard Source-Receptor-Pathway model, where, in order for an impact to be established all three elements of this mechanism must be in place. In addition, in line with the Appropriate Assessment process, mitigation has been discussed and applied to each potential impact to ensure that the proposed development, individually or in combination with other plans or projects will not have a significant effect on, or adversely affect the integrity of any European Site.

Construction Phase Impacts

The proposed Glenamaddy WwTP will require the construction of a new treatment plant at a site in the townland of Mountkelly, to the north of Glenamaddy village. This site is not within or adjacent to the Lough Lurgeen Bog / Glenamaddy Turlough SAC and no pathways for direct or indirect impacts affecting the SAC site are identified with this component of the proposal.

44 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

The construction of a new pumping station/storm tank to be sited between the upgraded WwTP and the existing discharge pipeline is required. This will be located adjacent to, but removed from, the SAC boundary to the north of the turlough margin. The connection of the upgraded WwTP outfall to the existing discharge pipe will be carried out within the footprint of the proposed pumping station/storm tank (see Figure 1 and Figure 4) and works will be accessed from the existing hardstanding and gravel-surfaced access track, located outside the SAC boundary. There are no construction works required within the SAC arising from the above works components; thereby avoiding the potential for direct impacts on this designation.

The construction and upgrade works will require the decommissioning of the existing Glenamaddy WwTP which is located within a fenced site compound, but within the SAC boundary. The decommissioning works of the existing Glenamaddy WwTP will be limited to the cleaning of the existing tanks. Access to this works area will be via the existing gravelled track that is maintained by Galway County Council. All works will be contained within the existing fenceline of the WwTP site and the existing access track / hardstanding area. A photographic overview of the works area within and adjacent to the SAC boundary is presented in the Plates section of this report.

During these works, there is the potential for the following indirect impacts are identified which may occur within the works area, part of which includes the existing WwTP site which is located within the SAC designation. Indirect impacts are identified in relation to the semi-terrestrial grassland habitat within the existing WwTP site compound and also with regard to water quality:  Soil compaction outside of the SAC leading to increased surface runoff;  Runoff from general construction activities;  Dust and fine material entering the water body as a result of improperly maintained stockpiles/ general site activities; and  Spills or leaks of pollutants;

There is existing hardstanding and a gravel-surfaced access track which will be used to access the exising discharge pipe. A connection will be made from the pumping station/storm tank site, outside of the SAC boundary, to the existing

45 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

pipeline, within the SAC pipeline. There will be no additional permanent footprint within the SAC arising from the proposed works. Any temporary footprint of the proposed works within the SAC will be associated with the connection of the pumping station/storm tank to the existing discharge pipe, and the decommissioning (i.e. cleaning) of the existing WwTP structure.

Mitigation measures are proposed to limit the footprint of these works to the improved agricultural grassland habitats which occur at the pumping station/storm tank works area, and within the fenced compound at the existing WwTP site. Such works will utilise low-impact measures to minimise habitat disturbance. Water quality effects will be limited using protection measures specified in the mitigation section below. However, the primary control for water quality effects during construction will be via avoidance, with works completed during the summer season (May to October), when water levels are at a significant distance from the works site.

Operational Phase Impacts

The proposed upgrade to the Glenamaddy WwTP seeks to decommission the existing, partially treated discharge and replace it with a new plant and highly treated effluent discharge that exceeds the requirements of the Urban Waste Water Treatment Regulations.

The existing discharge to the Glenamaddy Turlough is described in the Tier 3 Groundwater Risk Assessment Report (TOBIN, 2016a), with BOD, suspended solids and orthophosphate over the period of 1998 to 2008 presented in Table 8. Approximately 229 kg P/ year is entering the groundwater system based on an estimated dry weather flow of 100 m3/day (though peaks at over 300 m3/day). The proposed design standards are summarised inTable 9. The hydraulic load is presented in Table 10.

Table 8 Effluent Quality (TOBIN 2016 Date of Sampling BOD Suspended Solids Ortho mg/l mg/l Phosphate as P (mg/l) 17th Sept 2004 316 210 2.9 19th Sept 2004 204 105 3.7 25th Sept 2004 129 133 3.8 13th Feb 2007 122 369 10.3

46 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Date of Sampling BOD Suspended Solids Ortho mg/l mg/l Phosphate as P (mg/l) 8th Aug 2007 240 129 21.8 12th Aug 2007 150 87 3.3 28th Mar 2008 152 121 21 7th Aug 2008 92 59 3.1 12th Dec 2008 144 84 6.3 22nd Oct 2014 88 150 6 5th November 2014 37 76 4 10th November 2014 16 98 1 17th November 2014 190 160 6 27th January 2015 55 230 3 3rd February 2015 290 130 5 10th February 2015 58 94 6 3rd March 2015 26 81 2 Average 136 138 6.4

Table 9 Design Effluent Standard (TOBIN 2016a) Parameter Final Effluent Design Standards BOD 10 mg/l Suspended Solids 10 mg/l Total Phosphorus 0.5 mg/l Total Ammonia 1.0 mg/l Pathogen reduction 3 log reduction

Table 10 Design Loading (TOBIN 2016a)

Design Parameter Value Design Population 700p.e. Design Load 42kg/d Hydraulic Load 3 126m /day (Dry Weather Flow) Hydraulic Load 3 378m /day (Peak Flow) Peak Storm Water Flow to Pumping 3 4 hours storage to be provided 380m Station

During the operation phase, the primary potential impact from the proposed project is the pollution of the Glenamaddy Turlough, designated within the Lough Lurgeen Bog/Glenamaddy Turlough SAC. Based on the evaluation of options and alternatives, the Tier 3 Groundwater Risk Assessment Report concludes that discharge of effluent to the Glenamaddy Turlough is the preferred option. This will require an exemption under Regulation 14 (Groundwater Regulations, S.I. No. 9 of 2010). The parameters upon which the discharge and operational phase of the proposal will be measured have been determined and recognise that the catchment to Lettera Spring is reasonably well known; therefore, Lettera Spring would be the main monitoring point. Discharging to the turlough also allows for an assessment of

47 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

assimilative capacity in the groundwater body. Consideration is also given to the turlough water body itself and three hydrological conditions are calculated: 1) when the turlough is ‘full’; 2) when the turlough is nearly empty; and, 3) when the turlough is dry.

The Tier 3 Groundwater Risk Assessment Report (TOBIN 2016a) used the recognised groundwater body calculation as per “Example 13” in EPA guidance document on the Authorisation of Discharges to Groundwater (EPA, 2011); the approach to the turlough calculation is based on EPA guidance on ambient and discharge monitoring in relation to surface water regulations. A complete set of limitations and assumptions for this assimilation capacity are presented in the report (TOBIN 2016a), while the results are summarised inTable 11, Table 12, Table 13, and for phosphate and ammonium over a range of flow, background and discharge concentrations.

A dilution calculation is used to calculate the assimilative capacity for phosphate and ammonia of the design discharge to groundwater body using flow at Lettera as the monitoring point to represent the groundwater body volume and using a representative background concentration from the field data; and, to calculate the assimilative capacity of the turlough itself when the turlough is ‘wet’. This is considered to represent the ‘fully mixed’ condition of the Glenamaddy Turlough and is also evaluated as complying with the precautionary principle, where the baseline conditions measured at Letteragh Spring will be including the exacerbating influence of the partially treated effluent discharge from the existing Glenamaddy WwTP.

Phosphate The background groundwater phosphate concentration is based on the concentrations at Lettera and Gortgarrow springs, and the surface water streams that feed the Glenamaddy Turlough and is taken as approximately 0.015 mg/l as P (as discussed in the description of the turlough site above). The calculations for the turlough indicate that for the design discharge of 0.5 mg/l as P of phosphate, then, with a background concentration of 0.015 mg/l as P, and a depth of 3 m to 0.3 m in the turlough, the concentration would increase slightly; occurring in the range of

48 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme 0.015 to 0.016 mg/l as P. The main critical driver is the background concentration. This calculation assumes that all the ‘plume’ is going into the turlough water body.

The calculations for the groundwater body are done for when the turlough is dry. They demonstrate that for a background groundwater body concentration of 0.008 to 0.015 mg/l as P that the concentration would not exceed 0.035 mg/l as P. The ‘groundwater body’ would be at ‘Good Status’ and the theoretical capacity used up would range from 60% to 97% for a background concentration of 0.015 mg/l as P (45% to 73% for a background concentration of 0.008 mg/l as P).

Ammonia The ammonium data suggest elevated concentrations may be present in the turlough; thus, elevated prior to contributions from the waste water plant. The assimilative capacity calculations are done on both the groundwater body and the turlough but those for the turlough are limited. Only when the background concentrations are in the order of 0.06 mg/l as N do the calculations demonstrate compliance of the design standard against the nutrient conditions expected for ‘Good Status’ in the lake water body.

The calculations for the groundwater body are done for when the turlough is dry. The calculations for the groundwater body indicate that the for the design discharge of 1 mg/l of ammonium as N, then, assuming a range of background concentrations of 0.04 mg/l to 0.06 mg/l as N then the predicted concentration would range from 0.069 mg/l to 0.098 mg/l, which is below the groundwater threshold concentration for drinking water though above the groundwater threshold value for the surface water test (Groundwater regulations, S.I. No. 9 of 2010). This does not take account of attenuation or that the turlough is generally ‘wet’. They indicate an improvement on the current mean value at Lettera (0.12 mg/l).

In summary the potential direct and indirect impacts arising from the proposal include:  Construction works at the pumping station/storm tank outside, but adjacent to the SAC boundary;  Decommissioning works at the existing WwTP site, within the SAC boundary; and  Operational water quality impacts

49 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Table 11 Assimilative capacity phosphate (mg/l as P) in the Turlough

51 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Table 12 Assimilative capacity phosphate (mg/l as P) in the groundwater body when the turlough is dry

Concentration Discharge Lettera exiting dry Background concentration Total Concentration flow (m3/d) turlough (mg/l) (mg/l as P) (m3/d) (mg/l as P)

35 l/s 50 l/s 126 MRP as P 35 l/s 50 l/s 3024 4320 126 4 0.05 0.208 0.167 3024 4320 126 0.5 0.05 0.068 0.065 3024 4320 126 4 0.015 0.174 0.132 3024 4320 126 0.5 0.015 0.034 0.030 3024 4320 126 4 0.008 0.168 0.125 3024 4320 126 0.5 0.008 0.028 0.023

52 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Table 13 Assimilative capacity Ammonia (mg/l as N) in the turlough Turlough (Full, ~3m Factor F Discharge Concentration Background concentration Total Concentration Factor b flow rate Dilution flow in discharge (mg/l) (mg/l as N) (depth) m (m3/hr) 8930 b/F (m3/d) (mg/l)

3 5.25 5102.857 126 Ammonia 0.065 60 0.3 0.312 1 0.3 0.300 60 0.15 0.162 1 0.15 0.150 60 0.06 0.072 1 0.06 0.060 Turlough (0.3m deep) 0.3 5.25 510.2857 126 0.065 60 0.3 0.417 1 0.3 0.301 60 0.15 0.267 1 0.15 0.152 60 0.06 0.177 1 0.06 0.062

53 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Table 14 Assimilative capacity ammonium (mg/l as N) in the groundwater body when the turlough is dry Concentration Discharge Lettera exiting dry Background concentration Total Concentration flow (m3/d) turlough (mg/l) (mg/l as N) (m3/d) (mg/l as N) 35 l/s 50 l/s 126 NH4 35 l/s 50 l/s 3024 4320 126 60 0.06 2.458 1.785 3024 4320 126 1 0.06 0.098 0.089 3024 4320 126 60 0.04 2.438 1.765 3024 4320 126 1 0.04 0.078 0.069

54 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Mitigation and Monitoring

Construction Phase Mitigation

Mitigation measures will include the development and implementation of a Construction Environmental Management Plan (CEMP) prior to commencement of works on site. This will include method statements for various activities and monitoring of the water body. The CEMP will include all measures set out below and will be agreed with Irish Water, with input from a qualified ecologist, with reference to any further consultation or requirements provided by the NPWS. The appointed Contractor will be contractually obliged to implement the CEMP in full and to achieve work practices that avoid impacts to water quality and habitat disturbance within the works site and adjoining SAC habitats.

The Contractor will be required to develop a Construction Management Plan prior to commencement of works onsite. This will include a surface water monitoring regime (i.e. to include a minimum of weekly hydro-chemical samples) and the installation of silt traps/settlement lagoons designed to accept high levels of continuous rainfall. This will also include a soil or excavated material storage, handling and reinstatement management plan.

Works will not be permitted at the proposed pumping station/storm tank site and existing waste water treatment plant when the water level in the turlough is within 50m of the works area. The Contractor will be obliged to complete works within the summer season when water levels are lower or receding, to ensure the site is not inundated. If unseasonal water levels persist within the turlough, and after works have commenced there is a risk of levels rising, the contractor will be required to seal the works site using silt fencing and sand-bags, or equivalent. Works must be postponed or the works site cleaned and evacuated if water levels continue to rise to the level of the works area.

A suitably qualified ecologist, acting as an Ecological Clerk of Works (ECoW), with experience in monitoring construction works in the aquatic environment, will oversee all works and be retained by Irish Water, independant of the Contractor, during the construction period and immediately post construction. The ECoW will monitor all construction activities and success of mitigation measures such as silt

55 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

traps. This will include monitoring of surface and ground waters; minimum weekly hydro-chemical samples, installation of silt traps/settlement lagoons designed to accept high levels of continuous rainfall.

During periods of inclement weather consideration will be given to the cessation of works onsite to reduce levels of silt in surface water run-off. During dry weather periods, this will include use of dust suppressor (e.g. water sprinkler/bowser). To prevent any silting or erosion which will adversely affect the appearance and / or quality of runoff from the working site, areas of exposed soil should be channeled and intercepted for discharge to silt-traps or lagoons.

Soil compaction will be minimised through the use of protective matting and low ground pressure machinery. Excavated or stock-piled material will not be stored within 15m of a temporary watercourse or surface water system.

The contractor must develop a method statement for leaks and/or spills setting out contingency measures for escalating risk e.g. method statement for small leaks and spills including the situation of material reaching a watercourse unmitigated, and method statement for large leak and/or spill which must include the provision of a 24 hour, 7 days a week call out service for leaks and/or spills. Each method statement must include emergency contact numbers including the EPA and NPWS. This method statement must be displayed on a public notice board at all times and be included in all site inductions.

Spill kits will be available across the site, at all working areas, within each site vehicle and at each fuel storage vessel. These will be checked regularly (at least weekly) to ensure all used material is removed and unused material restocked. Adherence to good practice guidelines including: http://www.envirocentre.ie/includes/documents/OilStorageBPG.pdf

All fuel storage containers will be double-skinned and bunded to be able to contain 110% volume. They will be checked regularly (at least weekly) and will be locked at all times. Bund specification will conform to the current best practice for oil storage such as Enterprise Ireland’s Best Practice Guide BPGCS005 Oil Storage Guidelines. All waste oil, empty oil containers and other hazardous wastes will be

56 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

disposed of in conjunction with the requirements of the Waste Management Acts 1996 to 2008, as amended. Drip trays will be installed at static machinery and used for maintenance. Hydrocarbons and chemicals will be stored at least 50m from any ground or surface water feature.

Due to the location of the proposed works the introduction and spread of non- native, invasive species is identified as a potential threat. The scheduling of works during the summer period, when water levels have receded from the works area will negate the potential for contamination from aquatic non-native species. Further measures are required to ensure non-native vegetation, such as Himalayan balsam and Japanese knotweed are not introduced to the site. An action plan for the control of non-native invasive species will be required, to avoid introductions by machinery. These measures will follow the guidance set out the NRA guidelines (20106), and will be included as an Appendix to the Construction Management Plan.

Operational Phase Mitigation and Monitoring

Mitigation for Annex I habitats The principal mitigation during the operational phase of the proposed Glenamaddy WwTP upgrade will be the monitoring and control of the quality of the treated effluent. Irish Water will also put in place a regime of sampling and testing of ground water samples that will be taken from Lettera Spring. This testing will be carried out in accordance with the requirements of the Urban Wastewater Treatment Regulations, where for a plant of this size, a minimum of 12 samples per year will be taken at Lettera Spring.

The development of the proposed wastewater treatment infrastructure, with reference to operational discharge and maintenance will not give rise to adverse impacts on the qualifying interests of the Lough Lurgeen Bog / Glenamaddy Turlough SAC, due to the improved final effluent discharge standards. No further operational mitigation measures are required.

6 NRA (2010). Guidelines on The Management of Noxious Weeds and Non-Native Invasive Plant Species on National Roads. Rev. 1. National Roads Authority.

57 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Mitigation for Annex II Species Water quality mitigation measures specified above for the protection of the turlough habitat and downstream receiving waters within the Lough Corrib SAC (the Sinking River), will result in the avoidance of adverse effects to water dependant Annex II species listed as Qualifying Interests of the Lough Corrib SAC.

Conclusion of Stage 2 of Appropriate Assessment

Lough Lurgeen Bog / Glenamaddy Turlough SAC

As set out in the Tier 3 Groundwater risk Assessment Report (TOBIN, 2016a) the operation of the upgraded WwTP to the proposed design standards will result in a significant improvement in the nutrient loadings entering the Glenamaddy Turlough. The baseline condition of the Glenamaddy Turlough is evaluated as mesotrophic, taking account of surface water and groundwater monitoring data collected for the preparation of the Tier 3 Groundwater Risk Assessment Report. The proposed upgraded discharge will not affect the integrity of this designation, taking account of the fact that the discharge will serve to meet and maintain the conservation objectives of the turlough habitat within the Lough Lurgeen Bog/Glenamaddy Turlough SAC. This will be achieved as demonstrated in the Tier 3 Groundwater Risk Assessment Report assimilation capacity model, where compliance is met with the nutrient value threshold for oligotrophic to mesotrophic turloughs (0.01 mg/l to 0.02 mg/l as P). The calculations for the operational discharge to the turlough indicate that for the design discharge of 0.5 mg/l as P of phosphate, taking a background concentration of 0.015 mg/l as P, and a depth of 3 m to 0.3 m in the turlough, the concentration would increase slightly; occurring in the range of 0.015 to 0.016 mg/l as P.

The calculations for the groundwater body are done for when the turlough is dry. They demonstrate that for a background groundwater body concentration of 0.008 to 0.015 mg/l as P that the concentration would not exceed 0.035 mg/l as P. The ‘groundwater body’ would be at ‘Good Status’ and the theoretical capacity used up would range from 60% to 97% for a background concentration of 0.015 mg/l as P (45% to 73% for a background concentration of 0.008 mg/l as P).

58 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Furthermore the new highly treated effluent discharge standards will result in improved Ammonia concentrations; there is a significant reduction in the design standard (1 mg/l as N) from the current input that averages approximately 60 mg/l as N. However, it is noted that background concentrations in the regional sampling point indicate elevated ammonium concentrations entering the turlough from upstream, diffuse sources.

Although the proposal does not have control over the scale or significance of the diffuse pollution sources affecting the Glenamaddy Turlough catchment, it is evaluated that the proposal is operating to best standards and will effectively meet the conservation objectives of the Lough Lurgeen Bog / Glenamaddy Turlough SAC, which are to maintain and restore the conservation interests of this site. The water quality improvements proposed by the development will result in a significant step, in a catchment-wide context, in reducing Phosphorous loading to within Groundwater Regulation limits and restoring ‘Good’ water quality status in the turlough. The proposal therefore will meet the requirements to maintain the conservation objectives of the designation, and will not impede any future plans by the relevant statutory authorities to progressively restore conservation objectives within this site.

No additional impacts will arise which may indirectly or directly impact the qualifying interests (sensitive ecological receptors described) of the Glenamaddy Turlough SAC from the construction aspects of the proposed development. Taking account of dilution and compliance with groundwater and surface water regulations, no additional measurable negative impacts will arise from the proposed treated effluent discharge affecting water dependant habitats or species within the Lough Corrib SAC located at a distance of approximately 4.6 km downstream. There are therefore no adverse effects on the integrity of the Lough Corrib SAC identified.

The potential effects, mitigation and residual impacts with respect to integrity level impacts are summarised for the Lough Lurgenn Bog / Glenamaddy Turlough SAC and the Lough Corrib SAC, in Table 15 and Table 16 respectively.

59 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Table 15 Summary of Potential Effects, Mitigation and Residual Effects affecting the Integrity of the Lough Lurgeen Bog / Glenamaddy Turlough SAC European Site Description of Potential Impacts Proposed mitigation Residual Impacts and relevant qualifying interests Annex I habitats: There are no pathways for effects on Construction: There are no pathways for effects identified Turloughs*; the Annex I peatland habitats listed as -Works undertaken under dry that would have the potential for significant Active raised bogs; qualifying interests for this site. conditions, when turlough is below adverse effects on the peatland habitats listed Degraded raised bogs 50%ile water level and at at distance as qualifying interests of this site. There are capable of natural Construction Impacts: of >50 m from the existing WwTP no integrity level impacts identified with regard Regeneration; -Spills and leaks of pollutants on site. site. to the conservation objectives or conservation Depressions on peat -Surface water run-off and increased -Presence of a qualified EcOW on status of these Annex I habitats. No mitigation substrates of the suspended solids. site during construction. measures are required or proposed. Rhynchosporion’ -Soils compacted by heavy machinery -Inclusion of water quality and -Importation of invasive species ground protection measures to be There will be no significant adverse effects on included in detailed CEMP. the conservation objectives of the priority Operational Impacts: Annex I Turlough habitat. The proposed -Effluent discharge leading to nutrient Operation: WwTP upgrade will maintain the conservation loading Mitigation by design stage objectives of this turlough habitat, meeting the avoidance. Upgraded discharge to water quality threshold nutrient values the turlough will comply with NPWS specified by NPWS (2013). Monitoring will be water quality conservation objectives undertaken by Irish Water to ensure the for Annex I Turlough habitats. The discharge is in compliance with background discharge to the swallow hole will water quality objectives.There are therefore comply with Groundwater no integrity level impacts identified with Regulations for Phosphorous, and reference to the conservation objectives or will also meet Surface Water conservation status of this site. Regulations in the Lettera Spring. Discharge standards will be monitored by Irish Water for compliance.

60 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Table 16 Summary of Potential Effects, Mitigation and Residual Effects affecting the Integrity of the Lough Corrib SAC European Site Description of Potential Impacts Proposed mitigation Residual Impacts and relevant qualifying interests Annex I Habitats: There are no pathways for effects Construction: There are no pathways for effects Hard oligo-mesotrophic waters on the terrestrial and wetland -Works undertaken under dry identified that would have the potential with benthic vegetation of Chara Annex I habitats designated within conditions, when turlough is for significant adverse effects on the spp.; Oligotrophic waters this site. below 50%ile water level and at at terrestrial or wetland Annex I habitats containing very few minerals of distance of >50 m from the listed as qualifying interests of this site. sandy plains (Littorelletalia The Annex I habitat Floating river existing WwTP site. There are no integrity level impacts uniflorae); Old sessile oak woods vegetation (Ranunculion fluitantis), -Presence of a qualified EcOW on identified with regard to the with Ilex and Blechnum in British likely to occur in the Sinking River site during construction. conservation objectives or conservation Isles; *Calcareous fens with (approx. 4.6 km west of the -Inclusion of water quality and status of these Annex I habitats. No Cladium mariscus and species of proposed discharge) may ground protection measures to be mitigation measures are required or the Caricion davallianae; Molinia potentially be affected indirectly included in detailed CEMP. proposed. meadows on calcareous, peaty or through water quality impacts. clavey-silt-laden soils (Molinion Operation: There will be no significant adverse caeruleae); *Semi-natural dry Construction Impacts: Mitigation by design stage effects on the conservation objectives grasslands and scrubland facies -Spills and leaks of pollutants on avoidance. Upgraded discharge of the Annex I habitat ‘Floating River on calcareous substrates site. to the turlough will comply with Vegetation’. The proposed WwTP (Festuco Brometalia) (*important -Surface water run-off and NPWS water quality conservation upgrade will comply with Groundwater orchid sites); Degraded raised increased suspended solids. objectives for Annex I Turlough Regulations and Surface Water bogs still capable of natural habitats. The discharge to the Regulations at Lettera Spring, allowing regeneration; Depressions on Operational Impacts: swallow hole will comply with for compliance with ‘Good Status’ in the peat substrates of the -Effluent discharge leading to Groundwater Regulations for Sinking River. Monitoring will be Rhynchosporion; Water courses nutrient loading Phosphorous, and will also meet undertaken by Irish Water to ensure the of plain to montane levels with Surface Water Regulations in the discharge is in compliance with the Ranunculion fluitantis and Lettera Spring. Discharge background water quality Callitricho-Batrachion vegetation; standards will be monitored by objectives.There are therefore no *Petrifying springs with tufa Irish Water for compliance. integrity level impacts identified with formation (Cratoneurion); Alkaline reference to the conservation objectives fens; *Active raised bogs; or conservation status of this site. *Limestone pavements; *Bog woodland

61 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

European Site Description of Potential Impacts Proposed mitigation Residual Impacts and relevant qualifying interests Annex II species: There are no pathways for effects Construction: There are no pathways for effects Sea lamprey; Atlantic Salmon; on the terrestrial Annex II species -Works undertaken under dry identified that would have the potential Lesser horseshoe bat; Otter; designated within this site. conditions, when turlough is for significant adverse effects on the Brook Lamprey; Slender green below 50%ile water level and at at terrestrial Annex II species, or the feather moss; Slender naiad; The Freshwater pearl mussel does distance of >50 m from the Freshwater pearl mussel, which are White-clawed crayfish; not occur in the Sinking River or in existing WwTP site. listed as qualifying interests of this site. Freshwater pearl mussel the River Clare catchment and -Presence of a qualified EcOW on There are no integrity level impacts there are no pathways for impacts site during construction. identified with regard to the identified. -Inclusion of water quality and conservation objectives or conservation ground protection measures to be status of these Annex II species. No Annex II species likely to occur in included in detailed CEMP. mitigation measures are required or the Sinking River (approx. 4.6 km proposed. west of the proposed discharge) Operation: may potentially be affected Mitigation by design stage There will be no significant adverse indirectly through water quality avoidance. Upgraded discharge effects on the conservation objectives impacts. These species include to the Glenamaddy Turlough will of the Annex II species occurring within Atlantic salmon, Brook lamprey, comply with NPWS water quality the Sinking River. The proposed WwTP White-clawed crayfish, and Otter. conservation objectives for Annex upgrade will comply with Groundwater I Turlough habitats. The discharge Regulations and Surface Water Construction Impacts: to the swallow hole will comply Regulations at Lettera Spring, allowing -Spills and leaks of pollutants on with Groundwater Regulations for for compliance with ‘Good Status’ in the site. Phosphorous, and will also meet Sinking River. Monitoring will be -Surface water run-off and Surface Water Regulations in the undertaken by Irish Water to ensure the increased suspended solids. Lettera Spring. Discharge discharge is in compliance with standards will be monitored by background water quality Operational Impacts: Irish Water for compliance. objectives.There are therefore no -Effluent discharge leading to integrity level impacts identified with nutrient loading reference to the conservation objectives or conservation status of this site.

62 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Statement of findings of non-significant effects

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’. From the evidence presented in the current assessment, it is concluded, beyond reasonable scientific doubt, that the proposed project, with the implementation of the prescribed mitigation measures, will not give rise to direct, indirect or cumulative impacts that would adversely affect the integrity of any designated Natura 2000 site, with particular reference to the Lough Lurgeen Bog / Glenamaddy Turlough SAC.

The proposed upgraded Glenamaddy WwTP discharge (highly treated effluent) will comply with and exceed the treated effluent standards detailed in the Urban Waste Water Treatment Regulations. The effluent discharge to the turlough will improve overall water quality and will contribute to the turlough maintaining the nutrient thresholds for mesotrophic turlough communities described by NPWS (2013); ranging between 0.01 mg/L to 0.02 mg/L P. The discharge will also comply, subject to exemption conditions with the EPA, with the Groundwater Regulations under low flow conditions, when discharge will be to ground; and will also comply with Surface Water Regulations at the Lettera Spring. There are therefore no adverse effects identified that could adversely affect water quality or water dependant Annex I habitats or Annex II species listed as qualifying interests within the Lough Lurgeen Bog / Glenamaddy Turlough SAC and the Lough Corrib SAC designations.

The mitigation measures proposed for the avoidance and reduction of adverse effects on the qualifying interests and conservation objectives of the Lough Lurgeen Bog / Glenamaddy Turlough SAC and the Lough Corrib SAC include accepted and proven measures to reduce temporary footprint disturbance impacts during construction and avoid water quality impacts during operation. It is concluded that the proposal will not result in direct, indirect or cumulative impacts which would have the potential to adversely affect the qualifying interests of these Natura 2000 sites with regard to the structure and function; range; population densities; or conservation status of their habitats and species. This conclusion statement has been determined recognising the requirements of Article 6(3) of the EC Habitats

63 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Directive (1992), transposed in Ireland as the EC (Birds and Natural Habitats) Regulations (2015).

64 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

References

DoEHLG, (2010). Appropriate Assessment of Plans and Projects in Ireland - Guidance for Planning Authorities (Revised Feb 2010). Department of Environment, Heritage and Local Government, Dublin, Ireland.

European Commission (2000). Communication from the Commission on the precautionary principle. European Commission, Luxembourg, Luxembourg.

European Commission, (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. European Commission Environment Directorate-General, Luxembourg, Luxembourg.

European Commission, (2000). Managing Natura 2000 sites: The Provisions of Article 6 of the Habitat’s Directive 92/43/EEC. EC Environment Directorate-General, Luxembourg, Luxembourg.

Environmental Protection Agency (2013). EPA ENVision Service (internet-based environmental information portal). Available online at: http://maps.epa.ie/internetmapviewer/mapviewer.aspx (Accessed January 2016).

Fossitt, Julie A., (2000). A Guide to Habitats in Ireland. The Heritage Council, Dublin, Ireland.

Galway County Council (2015). Galway County Development Plan 2015-2021. Galway County Council, Glaway, Ireland.

Goodwillie, R. (1992).Turloughs over 10ha: Vegetation Survey & Evaluation. NPWS unpublished report.

King, J.L., Marnell, F., Kingston, N., Rosell, R., Boylan, P., Caffrey, J.M., FitzPatrick, Ú., Gargan, P.G., Kelly, F.L., O’Grady, M.F., Poole, R., Roche, W.K. & Cassidy, D. (2011). Ireland Red List No. 5: Amphibians, Reptiles & Freshwater

65 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Fish. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht, Dublin, Ireland.

King, J.J. & Linnane, S.M. (2004) The status and distribution of lamprey and shad in the Slaney and Munster Blackwater SACs. Irish Wildlife Manuals, No 14. National Parks and Wildlife Service, Department of the Environment, Heritage and Local Government, Dublin Ireland.

McGarrigle, M.L., Lucey, J., Clabby, K.J., (1992). Biological assessment of river water quality in Ireland. In Newman, P.J., Plavaux M.A., Sweeting, R.A. (Eds), River Water Quality: Ecological Assessment and Control Commission of the European Communities, Luxembourg, pp. 371-393

National Biodiversity Data Centre (2016). National Lesser Horseshoe Bat Database. Available online at: http://maps.biodiversityireland.ie/#/Map/NbdcTerrestrial/Species/119456 (Retrieved 29/01/16)

NPWS (2013a). The Status of EU Protected Habitats and Species in Ireland. Habitat Assessments Volume 2. Version 1.1. Unpublished Report, National Parks & Wildlife Services. Department of Arts, Heritage and the Gaeltacht, Dublin, Ireland.

NPWS (2013b) Galway Bay Complex SAC (268) Conservation Objectives Supporting Document – Turloughs. V1. National Parks and Wildlife Service.

NPWS (2015) Conservation objectives for Lough Lurgeen Bog/Glenamaddy Turlough SAC [000301]. Generic Version 4.0. Department of Arts, Heritage and the Gaeltacht.

Ní Bhroin, Niamh (2008). Ecological Impact Assessment of the Effects of Statutory Arterial Drainage Maintenance Activities on Turloughs. The Office of Public Works (OPW), Meath, Ireland. Available online at http://www.opw.ie/media/Issue%20No.%208%20EcIA%20Turloughs.pdf (Accessed January 2016).

66 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

OʹConnor, W. (2006a). A baseline survey of juvenile lamprey populations in the River Feale catchment. Irish Wildlife Manuals No. 22. National Parks and Wildlife Service. Dept. of Environment, Heritage and Local Government, Dublin Ireland.

OʹConnor, W. (2006b). A survey of juvenile lamprey populations in the Boyne catchment. Irish Wildlife Manuals No. 24. National Parks and Wildlife Service. Dept. of Environment, Heritage and Local Government, Dublin Ireland.

OʹConnor, W. (2007). A survey of juvenile lamprey populations in the Corrib and Suir catchments. Irish Wildlife Manuals No. 26. National Parks and Wildlife Service. Dept. of Environment, Heritage and Local Government, Dublin Ireland.

O’Sullivan, Carol (Ed.) (2013). Integrated Water Quality Report 2012, Galway & Mayo. Environmental Protection Agency, Wexford, Ireland.

TOBIN, (2016a). Glenamaddy Sewerage Scheme - Tier 3 Groundwater Risk Assessment, TOBIN Consulting Engineers, Fairgreen Road, Galway. Waldren, S. 2015, Ed. Turlough Hydrology, Ecology and Conservation. Unpublished Report, National Parks & Wildlife Services. Department of Arts, Heritage and the Gaeltacht, Dublin, Ireland.

Western River Basin District (2010). Clare River Water Management Unit Action Plan. Western RBD. Available online at: http://www.wfdireland.ie/docs/1_River%20Basin%20Management%20Plans%2020 09%20- %202015/WRBD%20RBMP%202010/Water%20Management%20Unit%20Action% 20Plans/Clare%20River_WMU_190310.pdf Accessed February 2016

67 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Photographic Plates

68 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Plate 1. View of the existing Glenamaddy WwTP with the fenced compound. View southwest. May 2008.

Plate 2. The existing Glenamaddy WwTP within the fenced compound, including existing discharge pipeline passing through centre-image. View south. May 2008.

69 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Plate 3. The existing Glenamaddy WwTP structure is on an elevated berm, within the fenced compound. View northwest. May 2008.

Plate 4. The existing access track to the Glenamaddy WwTP. View north. May 2008.

70 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Plate 5. View of the existing Glenamaddy WwTP within the fenced compound under low water conditions. View southeast. May 2009.

Plate 6. View of the existing discharge pipeline exiting the Glenamaddy WwTP under low summer conditions. View southeast. May 2009.

71 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Plate 7. Existing Glenamaddy WwTP within the fenced compound, under flooded turlough conditions. View southeast. February 2013.

Plate 8. High flood conditions at the existing Glenamaddy WwTP. View northeast. February 2013.

72 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Plate 9. Site of the proposed pumping station/storm tank, directly west of the existing access road to the Glenamaddy WwTP. View west. January 2016.

Plate 10. The existing Glenamaddy WwTP under flooded turlough conditions. View southeast. January 2016.

73 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Appendix 1 NPWS Natura 2000 Site Synopses

74 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Site Name: Lough Lurgeen Bog/Glenamaddy Turlough SAC Site Code: 000301 The Lough Lurgeen Bog/Glenamaddy Turlough site covers almost 1,200 ha and is situated east of the town of Glenamaddy, Co. Galway. It consists of a large turlough, over 170 ha in extent, and an expanse of over 1,000 ha of typical, intact, western raised bog. A small lake occurs on top of the bog. Water from the bog feeds into the lake, which in turn is linked to the turlough, and thus the three habitats are in close association. This leads to quite a unique ecosystem which is of high conservation value. The site is a Special Area of Conservation (SAC) selected for the following habitats and/or species listed on Annex I / II of the E.U. Habitats Directive (* = priority; numbers in brackets are Natura 2000 codes):  Turloughs [3180]  Active raised bogs [7110]  Degraded raised bogs still capable of natural regeneration [7120]  Depressions on peat substrates of the Rhynchosporion [7150]

Active raised bog comprises areas of high bog that are wet and actively peatforming, where the percentage cover of bog mosses (Sphagnum spp.) is high, and where some or all of the following features occur: hummocks, pools, wet flats, Sphagnum lawns, flushes and soaks. Degraded raised bog corresponds to those areas of high bog whose hydrology has been adversely affected by peat cutting, drainage and other land use activities, but which are capable of regeneration. The Rhynchosporion habitat occurs in wet depressions, pool edges and erosion channels where the vegetation includes White Beak-sedge (Rhynchospora alba) and/or Brown Beak-sedge (R. fusca), and at least some of the following associated species: Bog Asphodel (Narthecium ossifragum), sundews (Drosera spp.), Deergrass (Scirpus cespitosus) and Carnation Sedge (Carex panicea). The site contains an extensive area of uncut raised bog, though the majority of this is classified as degraded bog. The surface is rather flat and the surface morphology is similar to blanket bog in places. A large, peat-bottomed, oligotrophic lake occurs in the middle of the bog and this feature is unique in Ireland. The vegetation on the bog is dominated by peatland species such as Heather (Calluna vulgaris), Hare’s- tail Cottongrass (Eriophorum vaginatum), Deergrass, Cross-leaved Heath (Erica tetralix), Bog Asphodel and Carnation Sedge. In common with most areas of degraded raised bog in the country the Sphagnum cover is low, with typically less

75 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

than 30% ground cover. In these drier bog conditions the main Sphagnum tends to be S. capillifolium, which is tolerant of drier conditions. The moss Hypnum cupressiforme and the lichen Cladonia portentosa also tend to have a higher cover in degraded areas. Within the wet pool systems which occur throughout the high bog area, Rhynchosporion vegetation is well represented. This is typically dominated by the aquatic bog moss S. cuspidatum. There are also a number of fairly extensive quaking lawns dominated by White Beak-sedge, some of which are associated with surface drainage features. Other frequent species of the habitat include Sphagnum auriculatum, Bogbean (Menyanthes trifoliata), Great Sundew (Drosera anglica) and Common Cottongrass (Eriophorum angustifolium). Some of these sections, and also including flushes, correspond with active raised bog. There is also a small area of alkaline fen at the southern end of the lake – again, a very unusual feature to be present in the centre of a raised bog. Glenamaddy Turlough has extensive areas of uniform vegetation, containing large stands of peat grassland, Common Sedge (Carex nigra) and Amphibious Bistort (Polygonum amphibium).

Three rivers flow into the turlough, the largest from Lough Lurgeen bog, and a well- defined swallow hole occurs in the north-west corner. The rare Fen Violet (Viola persicifolia), a protected plant species, has been recorded from the seasonally inundated turlough bed.

The lake is a traditional goose site and the turlough is used by Greenland Whitefronted Goose (74). Other birds reported for the site during 2 seasons between 1984 and 1987 (three counts were made) are Bewick's Swan 14, Whooper Swan 8, Wigeon 472, Teal 73, Mallard 229, Shoveler 15, Pochard 20, Golden Plover 23, Lapwing 62, Snipe 20, Curlew 39, Redshank 15.

Threats to water quality from nutrient enrichment are an issue at the site, along with peat cutting, drainage and burning, all of which would be detrimental to the bog. This is a site of high conservation value due to the presence of a very large turlough in close proximity to an expanse of raised bog. The combination of raised bog, turlough and linking stream is unique in Ireland, and is unlikely to occur anywhere else in the world, and the whole system is therefore of high conservation value.

76 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

Site Name: Lough Corrib SAC Site Code: 000297 Lough Corrib is situated to the north of Galway city and is the second largest lake in Ireland, with an area of approximately 18,240 ha (the entire site is 20,556 ha). The lake can be divided into two parts: a relatively shallow basin, underlain by Carboniferous limestone, in the south, and a larger, deeper basin, underlain by more acidic granite, schists, shales and sandstones to the north. The surrounding lands to the south and east are mostly pastoral farmland, while bog and heath predominate to the west and north. A number of rivers are included within the SAC as they are important for Atlantic Salmon. These rivers include the Clare, Grange, Abbert, Sinking, Dalgan and Black to the east, as well as the Cong, Bealanabrack, Failmore, Cornamona, Drimneen and Owenriff to the west. In addition to the rivers and lake basin, adjoining areas of conservation interest, including raised bog, woodland, grassland and limestone pavement, have been incorporated into the site. The site is a Special Area of Conservation (SAC) selected for the following habitats and/or species listed on Annex I / II of the E.U. Habitats Directive (* = priority; numbers in brackets are Natura 2000 codes):  Oligotrophic waters containing very few minerals of sandy plains (Littorelletalia uniflorae) [3110]  Hard oligo-mesotrophic waters with benthic vegetation of Chara spp. [3140]  Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation [3260]  Semi-natural dry grasslands and scrubland facies on calcareous substrates (Festuco-Brometalia) (* important orchid sites) [6210]  Molinia meadows on calcareous, peaty or clayey-silt-laden soils (Molinion caeruleae) [6410]  Active raised bogs [7110]  Degraded raised bogs still capable of natural regeneration [7120]  Depressions on peat substrates of the Rhynchosporion [7150]  Calcareous fens with Cladium mariscus and species of the Caricion davallianae [7210]  Petrifying springs with tufa formation (Cratoneurion) [7220]  Alkaline fens [7230]  Limestone pavements [8240]  Old sessile oak woods with Ilex and Blechnum in the British Isles [91A0]

77 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

 Bog woodland [91D0]  Margaritifera margaritifera (Freshwater Pearl Mussel) [1029]  Austropotamobius pallipes (White-clawed Crayfish) [1092]  Petromyzon marinus (Sea Lamprey) [1095]  Lampetra planeri (Brook Lamprey) [1096]  Salmo salar (Salmon) [1106]  Rhinolophus hipposideros (Lesser Horseshoe Bat) [1303]  Lutra lutra (Otter) [1355]  Drepanocladus vernicosus (Slender Green Feather-moss) [1393]  Najas flexilis (Slender Naiad) [1833]

The shallow, lime-rich waters of the southern basin of Lough Corrib support one of the most extensive beds of stoneworts (Charophytes) in Ireland, with species such as Chara aspera, C. hispida, C. delicatula, C. contraria and C. desmacantha mixed with submerged pondweeds (Potamogeton perfoliatus, P. gramineus and P. lucens), Shoreweed (Littorella uniflora) and Water Lobelia (Lobelia dortmanna). These Chara beds are an important source of food for waterfowl. In contrast, the northern basin contains more oligotrophic and acidic waters, without Chara species, but with Shoreweed, Water Lobelia, Pipewort (Eriocaulon aquaticum), Quillwort (Isoetes lacustris), Alternate Water-milfoil (Myriophyllum alternifolium) and Slender Naiad (Najas flexilis). The last-named is listed under the Flora (Protection) Order, 1999, and is an Annex II species under the E.U. Habitats Directive. Large areas of reedswamp vegetation, dominated by varying mixtures of Common Reed (Phragmites australis) and Common Club-rush (Scirpus lacustris), occur around the margins of the lake. Reedswamp usually grades into species-rich marsh vegetation characterised by Slender Sedge (Carex lasiocarpa), Water Mint (Mentha aquatica), Water Horsetail (Equisetum fluviatile) and Bogbean (Menyanthes trifoliata). Of particular note are the extensive beds of Great Fen-sedge (Cladium mariscus) that have developed over the marly peat deposits in sheltered bays, particularly in the southeast corner of the lake. Alkaline fen vegetation is more widespread around the lake margins and includes, amongst the typically diverse range of plants, the Slender Cottongrass (Eriophorum gracile), a species protected under the Flora (Protection) Order, 1999. Wet meadows dominated by Purple Moor-grass (Molinia caerulea) occur in seasonally flooded areas close to the lake shore. These support species such as Sharp-flowered Rush (Juncus acutiflorus), Jointed Rush (J.

78 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

articulatus), Carnation Sedge (Carex panicea), Devil’s-bit Scabious (Succisa pratensis), Creeping Bent (Agrostis stolonifera) and Tormentil (Potentilla erecta), amongst others.

This large site contains four discrete raised bog areas and is selected for active raised bog, degraded raised bog, Rhynchosporion and bog woodland. Active raised bog comprises areas of high bog that are wet and actively peat-forming, where the percentage cover of bog mosses (Sphagnum spp.) is high, and where some or all of the following features occur: hummocks, pools, wet flats, Sphagnum lawns, flushes and soaks. Degraded raised bog corresponds to those areas of high bog whose hydrology has been adversely affected by peat cutting, drainage and other land use activities, but which are capable of regeneration. The Rhynchosporion habitat occurs in wet depressions, pool edges and erosion channels where the vegetation includes White Beak-sedge (Rhynchospora alba) and/or Brown Beak- sedge (R. fusca), and at least some of the following associated species, Bog Asphodel (Narthecium ossifragum), sundews (Drosera spp.), Deergrass (Scirpus cespitosus) and Carnation Sedge.

At Addergoole, on the eastern shores of Lough Corrib, there is an important area of western raised bog. This bog area is one of the most westerly, relatively intact raised bogs in the country. There are also other substantial areas of raised bog along various tributaries of the Corrib in east Co. Galway, namely Slieve Bog, Lough Tee Bog and Killaclogher bog. The active parts of these bogs mostly correspond to the wettest areas, where there are well-developed surface features with hummocks, lawns and pools. It is in such areas that Rhynchosporion vegetation is best represented. The dominant species is the aquatic bog moss Sphagnum cuspidatum, which is usually accompanied by Bogbean, White Beak- sedge, Bog Asphodel, Common Cottongrass (Eriophorum angustifolium), Bog Sedge (Carex limosa) and Great Sundew (Drosera anglica). Brown Beak-sedge, a locally rare plant of wet bog pools, has been recorded from a number of the bog areas within the site. At Addergoole a substantial bog lake or soak occurs and this is infilling with large rafts of Rhynchosporion vegetation at present. This area is associated with an important area of wet bog woodland dominated by Downy Birch (Betula pubescens). The largest part of the uncut high bog comprises degraded raised bog. Degraded bog is dominated by a raised bog flora which tends to be

79 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

rather species-poor because of disturbance and/or drying-out. The most conspicuous vascular plant species are usually Carnation Sedge, Heather (Calluna vulgaris), Cottongrasses, Cross-leaved Heath (Erica tetralix), Bog Asphodel and Deergrass. Bog-rosemary (Andromeda polifolia) and Cranberry (Vaccinium oxycoccos), two species indicative of raised bog habitat, are frequent on both degraded and active areas of raised bog. Sphagnum cover is generally low within degraded areas due to a combination of drying-out and frequent burning. Limestone pavement occurs along much of the shoreline in the lower Corrib basin, and supports a rich and diverse flora, including Herb-Robert (Geranium robertianum), Bloody Crane’s-bill (G. sanguineum), Carline Thistle (Carlina vulgaris), Spring Gentian (Gentiana verna), Wild Thyme (Thymus praecox), Rustyback (Ceterach officinarum), Wood Sage (Teucrium scorodonia), Slender St. John’s-wort (Hypericum pulchrum), Quaking-grass (Briza media) and Blue Moor-grass (Sesleria albicans). Areas of Hazel (Corylus avellana) scrub occur in association with exposed limestone pavement and these include species such as Hawthorn (Crataegus monogyna), Buckthorn (Rhamnus catharticus), Spindle (Euonymus europaeus), with occasional Juniper (Juniperus communis). Three Red Data Book species are also found in association with limestone scrub - Alder Buckthorn (Frangula alnus), Shrubby Cinquefoil (Potentilla fruticosa) and Wood Bitter-vetch (Vicia orobus), the latter is also protected under the Flora (Protection) Order, 1999.

Open areas of orchid-rich calcareous grassland are also found in association with the limestone exposures. These can support a typically rich vegetation, including many orchids such as Pyramidal Orchid (Anacamptis pyramidalis), Common Spotted-orchid (Dactylorhiza fuchsii), Early-purple Orchid (Orchis mascula), Frog Orchid (Coeloglossum viride), Fragrant Orchid (Gymnadenia conopsea), Marsh Helleborine (Epipactis palustris), Greater Butterfly-orchid (Platanthera chlorantha) and Irish Lady’s-tresses (Spiranthes romanzoffiana). The latter is protected under the Flora (Protection) Order, 1999. The Hill of Doon, located in the north-western corner of the lake, is a fine example of a Sessile Oak (Quercus petraea) woodland. The understorey is dominated by Sessile Oak, Holly (Ilex aquifolium) and occasional Juniper. There are occasional Yew (Taxus baccata) and Ash (Fraxinus excelsior), and a well developed ground layer dominated by Bilberry (Vaccinium myrtillus), Hard Fern (Blechnum spicant) and Wood Rush (Luzula sylvatica). Woodland also occurs on some of the islands in the lake. A number of the rivers in

80 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

the site support submerged and floating vegetation of the Ranunculion fluitantis and Callitricho-Batrachion, including mosses. For example, in the River Corrib species such as Shining Pondweed (Potamogeton lucens), Perfoliate Pondweed (Potamogeton perfoliatus), Small Pondweed (P. berchtoldii), Yellow Waterlily (Nuphar lutea), White Water-lily (Nymphaea alba) and stoneworts (Chara spp.) occur. The rare and Annex II-listed Slender Green Feather-moss (Drepanocladus vernicosus) is found at the fen at Gortachalla, north-east of Moycullen. Here it is widespread around the margins, and this constitutes a large and significant population in the national context. A very large population of another rare moss, Pseudocalliergon trifarium, is also found in this area. The lake is rated as an internationally important site for waterfowl. Counts from 1984 to 1987 revealed a mean annual peak total of 19,994 birds. In the past a maximum peak of 38,281 birds was recorded.

The lake supports internationally important numbers of Pochard (average peak 8,600) and nationally important numbers of the following species: Coot (average peak 6,756), Mute Swan (average peak 176), Tufted Duck (average peak 1,317), Cormorant (average peak 110) and Greenland Whitefronted Goose (average peak 83). The latter species is listed on Annex I of the E.U. Birds Directive. The Coot population is the largest in the country and populations of Tufted Duck and Pochard are second only to Lough Neagh. Breeding pairs of Common Scoter on the lake number 30-41 (1995 data), as well as breeding populations of Arctic Tern and Common Tern. Other bird species of note recorded from or close to the lake recently include Hen Harrier, Whooper Swan, Golden Plover and Kingfisher. All of these species are listed on Annex I of the E.U. Birds Directive. Otter and Irish Hare have been recorded regularly within this site. Both of these species are listed in the Red Data Book and are legally protected by the Wildlife Act, 1976. Otter is also listed on Annex II of the E.U. Habitats Directive. Lough Corrib is considered one of the best sites in the country for Otter, due to the sheer size of the lake and associated rivers and streams, and also the generally high quality of the habitats. Atlantic Salmon (Salmo salar) use the lake and rivers as spawning grounds. Although this species is still fished commercially in Ireland, it is considered to be endangered or locally threatened elsewhere in Europe and is listed on Annex II of the E.U. Habitats Directive. Lough Corrib is also a well known fishing lake with a very good Trout (Salmo trutta) fishery. The lake has a population of Sea Lamprey

81 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

(Petromyzon marinus), a scarce, though probably under-recorded species listed on Annex II of the E.U. Habitats Directive. Brook Lamprey (Lampetra planeri), also listed on Annex II, are also known from a number of areas within the site. A population of Freshwater Pearl Mussel (Margaritifera margaritifera), a species listed on Annex II of the E.U. Habitats Directive, occurs within the site. White-clawed Crayfish (Austropotamobius pallipes), also listed on Annex II, is well distributed throughout Lough Corrib and its in-flowing rivers over limestone. A summer roost of Lesser Horseshoe Bat, another Annex II species, occurs within the site - approximately 100 animals were recorded here in 1999.

The main threats to the quality of this site are from water polluting activities resulting from intensification of agricultural activities on the eastern side of the lake, uncontrolled discharge of sewage which is causing localised eutrophication of the lake, and housing and boating development, which is causing the loss of native lakeshore vegetation. The raised bog habitats are susceptible to further degradation and drying out due to drainage and peat cutting and, on occasions, burning. Peat cutting threatens Addergoole Bog and already a substantial area of it has been cut away. Fishing and shooting occur in and around the lake. Introduction of exotic crayfish species or the crayfish fungal plague (Aphanomyces astaci) could have a serious impact on the native crayfish population. The bat roost is susceptible to disturbance or development. Despite these ongoing issues, however, Lough Corrib is one the best examples of a large lacustrine catchment system in Ireland, with a range of habitats and species still well represented. These include 14 habitats which are listed on Annex I of the E.U. Habitats Directive, six of which are priority habitats, and nine species which are listed on Annex II. The lake is also internationally important for birds and is designated as a Special Protection Area. (NPWS 19.08.2013: Rev13)

82 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme Appendix 2 Department of Arts, Heritage and the Gaeltacht Response in Relation to the NIS Preparation for the Proposed WWTP at Glenamaddy, Co. Galway

83 | Irish Water Natura Impact Statement – Glenamaddy Sewerage Scheme

¡ ¢ £ ¤ ¥ ¦ §

¨

¢ £ ¤ ¥ ¦ §

©                      

   ¥  £ ¢  £   !

" # $ %  ¥ & " $ ' ¡ ( ( ¥ & &

) ¡  # ( * ¡ ( + ¢ &, # ( - . ( - # ( ¥ ¥ £ +

  # £ - £ ¥ ¥ ( / ¡ ¢ + ¥

  # £ - £ ¥ ¥ ( ¤ ¡  0

1

 & 2 

3 #  ¥ 4  # & , ¡ -  & 2  5 , ¡  # ( 6 # ¥

7 $ %  £ 

¨ 1

(  ¥ %  & ¦ ¡ ¦ , % ¥ ' ¥ 8  £ , 4 ¥ ( , ¡ ¦ 7 £ , + 9 / ¥ £ #,  - ¥  ( 0 , % ¥  ¥ &,  $ % , 9 : £ ¥ ¦ ¥ £ , ¡

$ ¡ £ £ ¥ + 8 ¡ ( 0 ¥ ( $ ¥ ¡ ¦ ;  ; ! 9 ¡ (  ¥ %  & ¦ ¡ ¦ : £ # + % <  , ¥ £ 9 # ( £ ¥ &  , #¡ ( , ¡ , % ¥ 8 £ ¡ 8 ¡ + ¥ 0

1 1 1

& ¥ (  4  0 0 2  + , ¥ 2  , ¥ £ , £ ¥  , 4 ¥ ( , 2 ¡ £ = ¢ 8 - £  0 ¥  , & ¥ (  4  0 0 9 * ¡ 6  & 2  9

# ( $ & ¢ 0 # ( - , % ¥ 0 £  2 # ( - 8 £ ¡ > # 0 ¥ 0 ? £ ¥ ¦ 6 @ @ A B C D E   7 F 6

¨

¢ , & # ( ¥ 0  ¥ &¡ 2  £ ¥ % ¥ £ #,  - ¥ C £ ¥ &  , ¥ 0 ¡  + ¥ £ >  , #¡ ( + ; £ ¥ $ ¡ 4 4 ¥ ( 0  , #¡ ( + ¡ ¦ , % ¥ ' ¥ 8  £ , 4 ¥ ( ,

¢ ( 0 ¥ £ , % ¥ + ,  , ¥ 0 % ¥  0 # ( - ? + F 6

: , # + ¢ ( 0 ¥ £ + , ¡ ¡ 0 , %  , , % ¥ 8 £ ¡ 8 ¡ +  & # + , ¡ # ( > ¡ & > ¥  ( ¥ 2 2  + , ¥ 2  , ¥ £ 8 ¢ 4 8 # ( - + ,  , #¡ (  ( 0

 + + ¡ $ #  , ¥ 0 £ # + # ( - 4  # ( 9  ( 0  ( ¢ 8 - £  0 ¥ 0 2  + , ¥ 2  , ¥ £ , £ ¥  , 4 ¥ ( , 8 &  ( , ? < < ) G F ¦ ¡ £

1

& ¥ (  4  0 0 ¡ (  ( ¥ 2 - £ ¥ ¥ ( ¦ # ¥ & 0 + #, ¥ # ( " ¡ ¢ ( , = ¥ & & 6 : , # +  & + ¡ ¢ ( 0 ¥ £ + , ¡ ¡ 0 , %  , , % ¥

¥ H # + , # ( - ¡ ¢ , ¦  & & 8 # 8 ¥ 2 ¡ £ =  ( 0 0 # + $ %  £ - ¥ 8 ¡ # ( ,  £ ¥ , ¡  ¥ 4  # ( ,  # ( ¥ 0  ( 0 ¢ + ¥ 0 ¦ ¡ £ , % ¥

I JK L M N O P Q R S N T M JP M UV W O Q N W Q I Q S S U X Q Y W Z J Y W M Q S X W X O Q [ N Y I W M N W W M Q Q \ JK W J Y P ] ] ^ _ JK W R ` Q

0 ¥ $ ¡ 4 4 # + + #¡ ( ¥ 0 9 $ & ¥  ( ¥ 0  ( 0 0 ¥ 4 ¡ & # + % ¥ 0 6 ¡ ¢ %  > ¥ $ ¡ ( ¦ # £ 4 ¥ 0 , %  ,  ( a : D # + # (

8 £ ¥ 8  £  , #¡ (  ( 0 , %  , 8 &  ( ( # ( - 8 ¥ £ 4 # + + #¡ ( 2 # & &  ¥ £ ¥ b ¢ # £ ¥ 0 ¦ ¡ £ , % ¥ 8 £ ¡ 8 ¡ +  & 6

) % ¥ ¦ ¡ & &¡ 2 # ( - (  , ¢ £ ¥ $ ¡ ( + ¥ £ >  , #¡ ( ¡  + ¥ £ >  , #¡ ( +  £ ¥ 4  0 ¥  , 8 £ ¥ C 8 &  ( ( # ( - + ,  - ¥ 9  ( 0

 £ ¥ # ( , ¥ ( 0 ¥ 0 , ¡  + + # + , ¡ ¢ # ( 8 £ ¥ 8  £ # ( - , % ¥ a : D  ( 0 # (  0 0 £ ¥ + + # ( - ¡  & #-  , #¡ ( + , %  ,  £ # + ¥

# ( £ ¥ &  , #¡ ( , ¡ . ¢ £ ¡ 8 ¥  ( + #, ¥ +  ( 0  #¡ 0 # > ¥ £ + #, # ( - ¥ ( ¥ £  & # ( , % ¥ $ ¡ ( , ¥ H , ¡ ¦ , % # + 8 £ ¡ 8 ¡ +  & 6

) % ¥ ¡  + ¥ £ >  , #¡ ( + $ ¡ > ¥ £ 9 # (  £ ¡  0  ( 0 4 ¡ £ ¥ + 8 ¥ $ # ¦ # $ , ¥ £ 4 + 9 , % ¥ ¡ > ¥ £  & & 8 £ ¡ c ¥ $ ,  ( 0 #, +

 + + ¥ + + 4 ¥ ( , ? + F 9  >  # &   & ¥ 0  ,   ( 0 # ( ¦ ¡ £ 4  , #¡ ( 9 ¥ $ ¡ &¡ - # $  & ¦ ¥  , ¢ £ ¥ + # ( , % ¥ 8 £ ¡ c ¥ $ ,  £ ¥  9

 ( 0 , % ¥ + ¢ £ > ¥ +  ( 0  + + ¥ + + 4 ¥ ( , + £ ¥ b ¢ # £ ¥ 0 6 G  £ , # $ ¢ &  £ ¥ 4 8 %  + # + # + 8 &  $ ¥ 0 ¡ ( , % ¥

£ ¥ b ¢ # £ ¥ 4 ¥ ( , + ¡ ¦ , % ¥ /   #,  , + ' # £ ¥ $ , # > ¥ 9 # ( $ & ¢ 0 # ( - # ( £ ¥ + 8 ¥ $ , ¡ ¦ 7 £ , # $ & ¥ + ! ?  F 9 ! ? d F  ( 0

! ? @ F 9  + + ¥ , ¡ ¢ , # ( : £ # + % & ¥ - # + &  , #¡ ( 9 8 £ # 4  £ # & 9 # ( , % # + $  + ¥ 9 G  £ , e 7 f ¡ ¦ , % ¥ G &  ( ( # ( -  ( 0

' ¥ > ¥ &¡ 8 4 ¥ ( , 7 $ , 9      +  4 ¥ ( 0 ¥ 0 6 : (  0 0 #, #¡ ( 9 , % ¥ 0 ¢ , # ¥ + ¡ ¦  ( 8 ¢  & # $  ¢ , % ¡ £ #, , ¡

¥ H ¥ £ $ # + ¥ #, + ¦ ¢ ( $ , #¡ ( + 9 # ( $ & ¢ 0 # ( - $ ¡ ( + ¥ ( , ¦ ¢ ( $ , #¡ ( + 9 # ( $ ¡ 4 8 & #  ( $ ¥ 2 #, % ¡ £ + ¡  + , ¡ + ¥ $ ¢ £ ¥

$ ¡ 4 8 & #  ( $ ¥ 2 #, % , % ¥ £ ¥ b ¢ # £ ¥ 4 ¥ ( , + ¡ ¦ , % ¥ /   #,  , + ' # £ ¥ $ , # > ¥  ( 0 , % ¥ f # £ 0 + ' # £ ¥ $ , # > ¥ 9  ( 0

2 #, % , % ¥ . ¢ £ ¡ 8 ¥  ( * ¡ 4 4 ¢ ( #, # ¥ + ? f # £ 0 +  ( 0 a  , ¢ £  & /   #,  , + F ¤ ¥ - ¢ &  , #¡ ( + 9   9 # (

 $ $ ¡ £ 0  ( $ ¥ 2 #, % ¤ ¥ - ¢ &  , #¡ (  g ¡ ¦ , % ¥ + ¥ ¤ ¥ - ¢ &  , #¡ ( + 9 # + + , £ ¥ + + ¥ 0 6

) % ¥ + ¥ ¡  + ¥ £ >  , #¡ ( +  £ ¥ 4  0 ¥ ¡ ( , % ¥   + # + ¡ ¦ , % ¥ # ( ¦ ¡ £ 4  , #¡ ( , %  , # + $ ¢ £ £ ¥ ( , &  >  # &   & ¥ 9

 ( 0  £ ¥ 2 #, % ¡ ¢ , 8 £ ¥ c ¢ 0 # $ ¥ , ¡  ( ¡  + ¥ £ >  , #¡ ( + ¡ £ + ¢  4 # + + #¡ ( + , %  , 4   ¥ 4  0 ¥  , % ¥

1

' ¥ 8  £ , 4 ¥ ( , ¡ ¦ 7 £ , + 9 / ¥ £ #,  - ¥  ( 0 , % ¥  ¥ &,  $ % , , ¡  8 &  ( ( # ( -  ¢ , % ¡ £ #, # ( £ ¥ &  , #¡ ( , ¡ 

¦ ¢ , ¢ £ ¥ 8 £ ¡ 8 ¡ + ¥ 0 0 ¥ > ¥ &¡ 8 4 ¥ ( , 6

: , # + ( ¡ , ¥ 0 , %  , , % ¥ ¥ H # + , # ( - 2  + , ¥ 2  , ¥ £ , £ ¥  , 4 ¥ ( , 8 &  ( ,  ( 0  + + ¡ $ #  , ¥ 0 0 # + $ %  £ - ¥ 8 ¡ # ( ,

, ¡ G ¡ & &  (  0 ¥ # £ $ ¥ D 2  & &¡ 2 / ¡ & ¥  £ ¥ 2 #, % # ( , % ¥ . ¢ £ ¡ 8 ¥  ( + #, ¥ 9 h ¡ ¢ - % h ¢ £ - ¥ ¥ (

1

f ¡ - ; & ¥ (  4  0 0 ) ¢ £ &¡ ¢ - % $ D 7 * ? + #, ¥ $ ¡ 0 ¥    d  F 6 ) % ¥ 8 £ ¡ 8 ¡ + ¥ 0 8 ¢ 4 8 # ( - + ,  , #¡ (

+ #, ¥  ¡ £ 0 ¥ £ + , % ¥ D 7 *  ( 0 9  4 ¡ ( - ¡ , % ¥ £ , % # ( - + 9 4   ¥  , £ # + = ¡ ¦ ¦ &¡ ¡ 0 # ( - 6

) % ¥ ' ¥ 8  £ , 4 ¥ ( , # +  >  # &   & ¥ , ¡ 4 ¥ ¥ ,  , 8 £ ¥ C 8 &  ( ( # ( - + ,  - ¥ , ¡ 0 # + $ ¢ + + , % ¥ 8 £ ¡ 8 ¡ +  & + 9  ( 0

, % ¥ a : D  ( 0 . : D 9 # ¦ £ ¥ b ¢ # £ ¥ 0 6 : , # +  0 > # + ¥ 0 9 % ¡ 2 ¥ > ¥ £ 9 , %  , , % ¥ £ ¥ # + ¦ ¢ & & $ ¡ ( + # 0 ¥ £  , #¡ ( ¡ ¦ , % # +

+ ¢  4 # + + #¡ ( # (  0 >  ( $ ¥ ¡ ¦  ( £ ¥ b ¢ ¥ + , ¦ ¡ £  4 ¥ ¥ , # ( - 6

' # + $ %  £ - ¥ & # $ ¥ ( $ ¥

1

) % ¥ ' ¥ 8  £ , 4 ¥ ( , ( ¡ , ¥ + , % ¥ 2  + , ¥ 2  , ¥ £ 0 # + $ %  £ - ¥ & # $ ¥ ( $ ¥ ¦ ¡ £ & ¥ (  4  0 0 9 '  d g i C  9

2 % # $ % 2  + - £  ( , ¥ 0  , % ¥ . G 7 9 + ¢  c ¥ $ , , ¡ $ ¡ ( 0 #, #¡ ( + 9 ¡ (   ;  A ; A 6 : , # + ¢ ( 0 ¥ £ + , ¡ ¡ 0 , %  ,

$ ¡ ( 0 #, #¡ ( +  8 8 & , ¡ , % # + & # $ ¥ ( $ ¥  ( 0 , %  , 0 # £ ¥ $ , 0 # + $ %  £ - ¥ , ¡ - £ ¡ ¢ ( 0 2  , ¥ £ 4 ¢ + , $ ¥  + ¥ 

d ;  ; ! 6

7 + + ¥ + + 4 ¥ ( , + £ ¥ b ¢ # £ ¥ 0

¡ ¢ %  > ¥ + ,  , ¥ 0 , %  ,  ( a : D # + # ( 8 £ ¥ 8  £  , #¡ ( ¦ ¡ £ , % ¥ 8 £ ¡ 8 ¡ +  & 9  ¢ , ( ¡ $ ¡ 4 4 ¥ ( , # + 4  0 ¥

£ ¥ -  £ 0 # ( - , % ¥ ( ¥ ¥ 0 ¦ ¡ £  ( . : D 6 ) % ¥ £ ¥ + 8 ¡ ( + #  # & #, ¦ ¡ £ + $ £ ¥ ¥ ( # ( - ¦ ¡ £  8 8 £ ¡ 8 £ #  , ¥

 + + ¥ + + 4 ¥ ( ,  ( 0 ¦ ¡ £ . : 7 & # ¥ + 2 #, % , % ¥ 8 &  ( ( # ( -  ¢ , % ¡ £ #,  ( 0 $ ¡ 4 8 ¥ , ¥ ( ,  ¢ , % ¡ £ #, 9 2 % ¥ (

 (  8 8 & # $  , #¡ ( # + 4  0 ¥ j  , 8 £ ¥ C 8 &  ( ( # ( - + ,  - ¥ 9 , % ¥ * ¡ ¢ ( $ # & + % ¡ ¢ & 0  & + ¡  ¥   & ¥ , ¡  0 > # + ¥

¡ ¢ # ( , %  , £ ¥ -  £ 0 6

) % ¥ , ¥ + , + 9 , ¥ £ 4 # ( ¡ &¡ -  ( 0 + ,  - ¥ + ¡ ¦ , % ¥ £ ¥ & ¥ >  ( , & ¥ - # + &  , #¡ ( + % ¡ ¢ & 0  ¥ ¦ ¡ & &¡ 2 ¥ 0 # (

£ ¥ + 8 ¥ $ , ¡ ¦ , % ¥  8 8 £ ¡ 8 £ #  , ¥  + + ¥ + + 4 ¥ ( , 8 £ ¡ $ ¥ + + 9 # 6 ¥ 6 G  £ , e 7 f ¡ ¦ , % ¥ G &  ( ( # ( -  ( 0

' ¥ > ¥ &¡ 8 4 ¥ ( , 7 $ , 9      +  4 ¥ ( 0 ¥ 0 9 ( ¡ , # ( - , %  , , % # + %  + ¢ 8 0  , ¥ 0 $ ¥ £ ,  # (  + 8 ¥ $ , + ¡ ¦

¥ H # + , # ( - (  , #¡ (  & - ¢ # 0  ( $ ¥ ¡ (  8 8 £ ¡ 8 £ #  , ¥  + + ¥ + + 4 ¥ ( , 6 : (  0 0 #, #¡ ( 9 , % ¥ £ ¥ + % ¡ ¢ & 0  ¥ 0 ¢ ¥

£ ¥ -  £ 0 , ¡ $  + ¥ &  2 ¡ ¦ , % ¥ * ¡ ¢ £ , ¡ ¦ k ¢ + , # $ ¥ ¡ ¦ , % ¥ . ¢ £ ¡ 8 ¥  ( l ( #¡ ( ? * k . l F  ( 0 ¡ ¦ , % ¥ : £ # + %

$ ¡ ¢ £ , +  + #, 4   8 8 & , ¡ , % # + 8 £ ¡ 8 ¡ +  & 6

. H # + , # ( - (  , #¡ (  &  ( 0 . ¢ £ ¡ 8 ¥  ( - ¢ # 0  ( $ ¥ ¡ (  8 8 £ ¡ 8 £ #  , ¥  + + ¥ + + 4 ¥ ( , 2 # & &  + + # + , # ( , % ¥

8 £ ¥ 8  £  , #¡ ( ¡ ¦ , % ¥ a : D 9 ( ¡ , # ( - , % ¥ 8 ¡ # ( , +   ¡ > ¥ 6 D ¡ 4 ¥  0 0 #, #¡ (  &  0 > # $ ¥ ¡ ( , % ¥

8 £ ¥ 8  £  , #¡ (  ( 0 $ ¡ ( , ¥ ( , ¡ ¦  ( a : D # + # ( $ & ¢ 0 ¥ 0 # ( 7 8 8 ¥ ( 0 #H 6 D ¥ ¥  & + ¡  ¥ &¡ 2 6

G £ ¡ c ¥ $ , 0 ¥ + $ £ # 8 , #¡ (

) % ¥  + + ¥ + + 4 ¥ ( , ? + F + % ¡ ¢ & 0  ¥   + ¥ 0 ¡ ( ¦ ¢ & &  ( 0 0 ¥ ,  # & ¥ 0 0 ¥ + $ £ # 8 , #¡ ( + ¡ ¦  & & 8  £ , + ¡ ¦ , % ¥

8 £ ¡ c ¥ $ , 9  ( 0  & & 0 ¥ > ¥ &¡ 8 4 ¥ ( , 9 # ( $ & ¢ 0 # ( -  + + ¡ $ #  , ¥ 0  ( 0  ( $ # & &  £ 2 ¡ £ = +  ( 0 + ¥ £ > # $ ¥ + 9  ( 0

 & & &  ( 0 + # ( > ¡ & > ¥ 0 9  , + #, ¥ C 8 £ ¥ 8  £  , #¡ ( 9 $ ¡ ( + , £ ¢ $ , #¡ (  ( 0 ¡ 8 ¥ £  , #¡ ( + ,  - ¥ + 6 : ( , % # + $  + ¥ 9

, % ¥ 0 ¥ $ ¡ 4 4 # + + #¡ ( # ( -  ( 0 0 ¥ 4 ¡ & #, #¡ ( ¡ ¦ ¥ H # + , # ( - # ( ¦ £  + , £ ¢ $ , ¢ £ ¥ + % ¡ ¢ & 0  ¥ $ ¡ > ¥ £ ¥ 0  , % ¥

 + + ¥ + + 4 ¥ ( , ? D F  ( 0  ( ¦ ¢ , ¢ £ ¥ 8 &  ( ( # ( -  8 8 & # $  , #¡ ( 6 7 & & £ ¥ & ¥ >  ( , 8 £ ¡ c ¥ $ , 0 ¥ ,  # & + 9 # ( $ & ¢ 0 # ( -

4  8 +  ( 0 0 £  2 # ( - + 9 + % ¡ ¢ & 0 ¦ ¡ £ 4 8  £ , ¡ ¦  (  8 8 & # $  , #¡ ( ¦ ¡ £ $ ¡ ( + ¥ ( , 9 # ( $ & ¢ 0 # ( - 9 ¦ ¡ £

¥ H  4 8 & ¥ 9 - £ ¡ ¢ ( 0 , ¥ + , # ( - 9 $ ¡ ( + , £ ¢ $ , #¡ (  ( 0 - £ ¡ ¢ ( 0 2 ¡ £ = + 9 £ ¡  0  $ $ ¥ + + 9 + #, ¥  $ $ ¥ + + 9 + #, ¥

$ ¡ 4 8 ¡ ¢ ( 0 +  ( 0 2 ¡ £ = +  £ ¥  + 9 &  # ( - ¡ £ £ ¥ 4 ¡ >  & ¡ ¦ 8 # 8 ¥ 2 ¡ £ = 9 2 ¡ £ = + ¡ ¦ 0 ¥ 4 ¡ & #, #¡ ( 9

&  ( 0 + $  8 # ( -  ( 0  ¡ ¢ ( 0  £ , £ ¥  , 4 ¥ ( , 9 ¥ , $ 6  ¢ & & 0 ¥ ,  # & + ¡ ¦ 4 #, #-  , #¡ ( 4 ¥  + ¢ £ ¥ + + % ¡ ¢ & 0

 & + ¡  ¥ 8 £ ¡ > # 0 ¥ 0  ( 0 + % ¡ 2 ( # ( 4  8 +  ( 0 0 £  2 # ( - + 9  +  8 8 £ ¡ 8 £ #  , ¥ 6 : ( + ¥ ( + #, # > ¥

&¡ $  , #¡ ( + 9 , % ¥ & # = ¥ & ¥ ¦ ¦ ¥ $ , + ¡ ¦ , % ¥ 4 #, #-  , #¡ ( 4 ¥  + ¢ £ ¥ + , % ¥ 4 + ¥ & > ¥ + + % ¡ ¢ & 0  ¥  + + ¥ + + ¥ 0 9

¥ 6 - 6 , % ¥ # ( + ,  & &  , #¡ (  ( 0 + ¢  + ¥ b ¢ ¥ ( , £ ¥ 4 ¡ >  & ¡ ¦ + # &, $ ¡ ( , £ ¡ & 4 ¥  + ¢ £ ¥ + 6 " #, #-  , #¡ (

4 ¥  + ¢ £ ¥ + + % ¡ ¢ & 0  ¥ 0 ¥ 4 ¡ ( + , £  , ¥ 0 , ¡  ¥ ¥ ¦ ¦ ¥ $ , # > ¥ # (  0 0 £ ¥ + + # ( -  ( 0  4 ¥ & #¡ £  , # ( - , % ¥

¦ ¢ & & + $  & ¥  ( 0 (  , ¢ £ ¥ ¡ ¦ , % ¥ ¥ ¦ ¦ ¥ $ , +  £ # + # ( - 9  ( 0 , ¡  ¥ ¦ ¥  + #  & ¥ 2 #, % # ( , % ¥ + 8 ¥ $ # ¦ # $

$ %  £  $ , ¥ £ # + , # $ +  ( 0 $ ¡ ( + , £  # ( , + ¡ ¦ , % ¥ 8 £ ¡ 8 ¡ + ¥ 0 + #, ¥ 6

a  , ¢ £ ¥ $ ¡ ( + ¥ £ >  , #¡ ( + #, ¥ +  ( 0  >  # &   & ¥ # ( ¦ ¡ £ 4  , #¡ (

'  ,   ( 0 # ( ¦ ¡ £ 4  , #¡ (   ¡ ¢ , . ¢ £ ¡ 8 ¥  ( + #, ¥ + 9  ( 0 ¡ , % ¥ £ (  , ¢ £ ¥ $ ¡ ( + ¥ £ >  , #¡ ( + #, ¥ + 9

1

# ( $ & ¢ 0 # ( - : D 0  ,  + ¥ , + 9  £ ¥  >  # &   & ¥ ¦ £ ¡ 4 2 2 2 6 ( 8 2 + 6 # ¥ 6 ) % # + # ( $ & ¢ 0 ¥ + + #, ¥  ¡ ¢ ( 0  £ # ¥ + 9

+ #, ¥ + ( ¡ 8 + ¥ + 9 & # + , + ¡ ¦ b ¢  & # ¦ # ( - # ( , ¥ £ ¥ + , + ? D 7 * + F  ( 0 + 8 ¥ $ #  & $ ¡ ( + ¥ £ >  , #¡ ( # ( , ¥ £ ¥ + , +

? D G 7 + F 9 $ ¡ ( + ¥ £ >  , #¡ ( ¡  c ¥ $ , # > ¥ + ? . ¢ £ ¡ 8 ¥  ( + #, ¥ + F 9 ¦ ¥  , ¢ £ ¥ + ¡ ¦ # ( , ¥ £ ¥ + , ? a / 7 + F 9  ( 0

    q r 

0  , ¥ + ¡ ¦ + #, ¥ 0 ¥ + #- Y N W JR Y m n UQ Y N o N I I V ^ X O UR X P M JK R Y Q R S W M Q K JW Q K J Y W M Q T p

s t  u v r w x q      y   t z { | t     

Z O Q } R O W ` V ~ R P Q O n R R I  J U U JQ €  ‚ ‚ ƒ „ S R O W M JK

' ¥ 8  £ , 4 ¥ ( , 6

1

h ¡ ¢ - % h ¢ £ - ¥ ¥ ( f ¡ - ; & ¥ (  4  0 0 ) ¢ £ &¡ ¢ - % $ D 7 * $ ¢ £ £ ¥ ( , & %  + - ¥ ( ¥ £ # $ $ ¡ ( + ¥ £ >  , #¡ (

¡  c ¥ $ , # > ¥ + , %  ,  £ ¥ 0  , ¥ 0 d ;   ; A 6 ) % ¥ 4 ¡ + , ¢ 8 C , ¡ C 0  , ¥ > ¥ £ + #¡ ( ¡ ¦ , % ¥ $ ¡ ( + ¥ £ >  , #¡ (

¡  c ¥ $ , # > ¥ + + % ¡ ¢ & 0  ¥ + ¡ ¢ £ $ ¥ 0 9 £ ¥ ¦ ¥ £ ¥ ( $ ¥ 0  ( 0 ¢ + ¥ 0 # ( , % ¥ a : D 6 < % ¥ £ ¥ + #, ¥ + 8 ¥ $ # ¦ # $

$ ¡ ( + ¥ £ >  , #¡ ( ¡  c ¥ $ , # > ¥ +  £ ¥  >  # &   & ¥ ¦ ¡ £ £ ¥ & ¥ >  ( , b ¢  & # ¦ # ( - # ( , ¥ £ ¥ + , %   #,  , +  , ¡ , % ¥ £

+ #, ¥ + ? ¥ 6 - 6 D 7 *     ! B ¦ ¡ £ , ¢ £ &¡ ¢ - % + F 9 , % ¥ + ¥  ( 0 , % ¥ # £ + ¢ 8 8 ¡ £ , # ( - 0 ¡ $ ¢ 4 ¥ ( , + 4   + + # + ,

# ( ¢ ( 0 ¥ £ + ,  ( 0 # ( - , % ¥ (  , ¢ £ ¥  ( 0 + $ ¡ 8 ¥ ¡ ¦ , % ¥ - ¥ ( ¥ £ # $ $ ¡ ( + ¥ £ >  , #¡ ( ¡  c ¥ $ , # > ¥ + 6 ) % ¥

 , , £ #  ¢ , ¥ +  ( 0 ,  £ - ¥ , + + 8 ¥ $ # ¦ # ¥ 0 # ( , % ¥ + ¥ ¡  c ¥ $ , # > ¥ + 2 # & &  + + # + , # ( £ ¥ &  , #¡ ( , ¡ , % ¥ + $ ¡ 8 ¥ ¡ ¦

, % ¥ 0  ,  9 + ¢ £ > ¥ +  ( 0  (  & + # + £ ¥ b ¢ # £ ¥ 0 6 : , + % ¡ ¢ & 0  & + ¡  ¥ ( ¡ , ¥ 0 , %  , , % ¥ - ¥ ( ¥ £ # $

$ ¡ ( + ¥ £ >  , #¡ ( ¡  c ¥ $ , # > ¥ +  £ ¥ W R 4  # ( ,  # ( ¡ £ £ ¥ + , ¡ £ ¥ , % ¥ ¦  > ¡ ¢ £   & ¥ $ ¡ ( + ¥ £ >  , #¡ (

L R Y I JW JR Y † R S W M Q ‡ X N U JS V J Y P J Y W Q O Q K W ˆ Y Y Q \ ‰ M N ` JW N W K R S W M Q Š ˆ ‹ m ‰ Y W M Q N ` K Q Y L Q R S K JW Q

+ 8 ¥ $ # ¦ # $ $ ¡ ( + ¥ £ >  , #¡ ( ¡  c ¥ $ , # > ¥ + 9  ( 0 2 % ¥ £ ¥ b ¢  & # ¦ # ( - # ( , ¥ £ ¥ + , %   #,  , +  £ ¥ # (

¢ ( ¦  > ¡ ¢ £   & ¥ + ,  , ¢ +  ,  (  , #¡ (  & & ¥ > ¥ & Œ 9  8 £ ¥ $  ¢ , #¡ (  £  8 8 £ ¡  $ % + % ¡ ¢ & 0  ¥  0 ¡ 8 , ¥ 0 # (

, % ¥ # ( , ¥ £ 8 £ ¥ ,  , #¡ ( ¡ ¦ , % ¥ - ¥ ( ¥ £ # $ $ ¡ ( + ¥ £ >  , #¡ ( ¡  c ¥ $ , # > ¥ + 6

1

: D 0  ,  + ¥ , +  £ ¥  >  # &   & ¥ ¦ ¡ £ 0 ¡ 2 ( &¡  0 ¦ ¡ £ $ ¥ £ ,  # ( %   #,  , +  ( 0 + 8 ¥ $ # ¥ +  £ # + # ( - ¦ £ ¡ 4

¨

>  £ #¡ ¢ + + ¡ ¢ £ $ ¥ + 9 # ( $ & ¢ 0 # ( - (  , #¡ (  & + ¢ £ > ¥ +  6 , % ¥ £ a G < D C % ¥ & 0 0  ,  ¡ ( %   #,  , +  ( 0

K } Q L JQ K o N V ` Q O Q ‡ X Q K W Q I ` V K X ` o JW W J Y P N T Ž N W N ~ Q ‡ X Q K W  R O o Z  6 ) % ¥ /   #,  , + ' # £ ¥ $ , # > ¥

7 £ , # $ & ¥ g £ ¥ 8 ¡ £ , + ¦ ¡ £    g  ( 0   d 9 2 % # $ % + % ¡ ¢ & 0  & + ¡  ¥ $ ¡ ( + ¢ &, ¥ 0 9  £ ¥  >  # &   & ¥ ¦ £ ¡ 4

% , , 8 § ; ; 2 2 2 6 ( 8 2 + 6 # ¥ ;  £ , # $ & ¥ C g C £ ¥ 8 ¡ £ , + C  9  + # + , % ¥ £ ¥ $ ¥ ( , (  , #¡ (  & £ ¥ 8 ¡ £ , ¡ ( 7 £ , # $ & ¥  ¡ ¦

, % ¥ f # £ 0 + ' # £ ¥ $ , # > ¥ 9  , % , , 8 § ; ; 2 2 2 6 ( 8 2 + 6 # ¥ ; ( ¥ 2 + ;  # £ 0 + C 0 # £ ¥ $ , # > ¥ C  £ , # $ & ¥ C  C £ ¥ 8 ¡ £ , # ( - 6

1 As summarised in: NPWS (2013). The Status of EU Protected Habitats and Species in Ireland. Overview Volume 1. Unpublished report, National Parks and Wildlife Service. Department of Arts, Heritage and the Gaeltacht 2 http://www.npws.ie/maps-and-data/habitat-and-species-data 3 http://www.npws.ie/maps-and-data/request-data

'  ,  ¡ ( ¥ $ ¡ &¡ - # $  & ¦ ¥  , ¢ £ ¥ +  ( 0 ¥ ( > # £ ¡ ( 4 ¥ ( ,  & ¦  $ , ¡ £ + # ( ¡ £ ( ¥  £ , % ¥ 8 £ ¡ c ¥ $ ,  £ ¥  2 # & &  ¥

 >  # &   & ¥ ¦ £ ¡ 4 >  £ #¡ ¢ + ¡ , % ¥ £ + ¡ ¢ £ $ ¥ + # ( $ & ¢ 0 # ( - 9 ¦ ¡ £ ¥ H  4 8 & ¥ §

¨

% ¥ £ ¡ £ -  ( # +  , #¡ ( + 9 ¥ 6 - 6 a  , #¡ (  & f #¡ 0 # > ¥ £ + #, '  ,  * ¥ ( , £ ¥ 9 f # £ 0 <  , $ % : £ ¥ &  ( 0 9

 ,

f  , * ¡ ( + ¥ £ >  , #¡ ( : £ ¥ &  ( 0 9 ¥ , $ 6 j

: D + 9 a : D +  ( 0 ¡ , % ¥ £ £ ¥ 8 ¡ £ , + ¦ ¡ £ 8 £ ¡ c ¥ $ , + # ( , % ¥ - ¥ ( ¥ £  &  £ ¥  9 # ( $ & ¢ 0 # ( - , % ¥ a : D

 .

, %  , 2  + 8 £ ¥ 8  £ ¥ 0 # ( $ ¡ ( ( ¥ $ , #¡ ( 2 #, % , % ¥ 2  + , ¥ 2  , ¥ £ 0 # + $ %  £ - ¥ & # $ ¥ ( $ ¥ j

¡ ( #, ¡ £ # ( -  ( 0 £ ¥ 8 ¡ £ , # ( -  + + ¡ $ #  , ¥ 0 2 #, % , % ¥ ¥ H # + , # ( - ¦  $ # & #, j

 "

: ¤ +  ( 0 D . 7 ¥ ( > # £ ¡ ( 4 ¥ ( ,  &  + + ¥ + + 4 ¥ ( , + ¡ ¦ 8 &  ( + # ( , % ¥ - ¥ ( ¥ £  &  £ ¥  9

 a

1

# ( $ & ¢ 0 # ( - , % ¥  & 2  * ¡ ¢ ( , ' ¥ > ¥ &¡ 8 4 ¥ ( , G &  ( 6

1

h ¡ ¢ - % h ¢ £ - ¥ ¥ ( f ¡ - ; & ¥ (  4  0 0 ) ¢ £ &¡ ¢ - % $ D 7 *

) % ¥ 8 £ # 4  £ $ ¡ ( $ ¥ £ ( £ ¥ -  £ 0 # ( - , % ¥ 8 £ ¡ 8 ¡ +  & # + , % ¥ & # = ¥ & + #- ( # ¦ # $  ( , ¥ ¦ ¦ ¥ $ , + ¡ ( , % ¥ 7 ( ( ¥ H

: 8 £ #¡ £ #, %   #,  ,  ( 0 b ¢  & # ¦ # ( - # ( , ¥ £ ¥ + , ¡ ¦ , % ¥ + #, ¥ 9 ) ¢ £ &¡ ¢ - % + 6 "  # ( ,  # ( # ( - ¡ £ £ ¥ + , ¡ £ # ( -

, % ¥ %   #,  , 9  ( 0 #, + (  , ¢ £  & + , £ ¢ $ , ¢ £ ¥  ( 0 ¦ ¢ ( $ , #¡ ( + 9 # + # ( , ¥ - £  & , ¡  $ % # ¥ > # ( - #, + ¦  > ¡ ¢ £   & ¥

$ ¡ ( + ¥ £ >  , #¡ ( $ ¡ ( 0 #, #¡ (  , , % ¥ + #, ¥ 6

) % ¥ a : D + % ¡ ¢ & 0 8 £ ¥ + ¥ ( ,  £ ¡  ¢ + ,  ( 0 £ ¥  + ¡ ( ¥ 0 + $ # ¥ ( , # ¦ # $  + + ¥ + + 4 ¥ ( ,  ( 0  (  & + # + ¡ ¦

, % ¥ # 4 8 & # $  , #¡ ( + ¡ ¦ , % ¥ 8 £ ¡ 8 ¡ +  & ¦ ¡ £ , % ¥ £ ¥ & ¥ >  ( , $ ¡ ( + ¥ £ >  , #¡ ( ¡  c ¥ $ , # > ¥ + 6 f ¥ + , + $ # ¥ ( , # ¦ # $

= ( ¡ 2 & ¥ 0 - ¥ # ( , % ¥ ¦ # ¥ & 0 + % ¡ ¢ & 0  ¥  8 8 & # ¥ 0 , ¡ , % ¥ ¢ ( 0 ¥ £ + ,  ( 0 # ( - ¡ ¦ , % ¥ ¥ ¦ ¦ ¥ $ , + ¡ ¦ , % ¥

¥ H # + , # ( -  ( 0 ¦ ¢ , ¢ £ ¥ 8 £ ¥ 0 # $ , ¥ 0 0 # + $ %  £ - ¥ + ¡ ( , % ¥ , ¢ £ &¡ ¢ - % 9  ( 0 , ¡ , % ¥  + + ¥ + + 4 ¥ ( ,  ( 0

 (  & + # + ¡ ¦ , % ¥ # 4 8 & # $  , #¡ ( + ¡ ¦ , % ¥ 8 £ ¡ c ¥ $ , ¦ ¡ £ , % ¥ $ ¡ ( + ¥ £ >  , #¡ ( ¡  c ¥ $ , # > ¥ +  ( 0 # ( , ¥ - £ #, ¡ ¦

, % ¥ + #, ¥ 6 a ¡ £ ¥  + ¡ (   & ¥ + $ # ¥ ( , # ¦ # $ 0 ¡ ¢  , 4  £ ¥ 4  # (  + , ¡ , % ¥ 2 % ¥ , % ¥ £ , % ¥ £ ¥ 2 # & &  ¥

 0 > ¥ £ + ¥ ¥ ¦ ¦ ¥ $ , + ¡ ( , % ¥ # ( , ¥ - £ #, ¡ ¦ , % ¥ + #, ¥ 2 % ¥ ( , % ¥  8 8 £ ¡ 8 £ #  , ¥  + + ¥ + + 4 ¥ ( , # + $  £ £ # ¥ 0

¡ ¢ ,  , % ¥ $ ¡ 4 8 ¥ , ¥ ( ,  ¢ , % ¡ £ #, 6 ) % ¥ ( ¥ $ ¥ + +  £ 0  ,   ( 0  (  & + # + , ¡ ¢ ( 0 ¥ £ + ,  ( 0 , % ¥

J o } U JL N W JR Y K R S W M Q S X W X O Q T M JP M UV W O Q N W Q I Q S S U X Q Y W Z S R O W M Q L R Y K Q O ‘ N W JR Y R ` ’ Q L W J ‘ Q K N Y I

# ( , ¥ - £ #, ¡ ¦ , % ¥ + #, ¥ 4 ¢ + ,  ¥ 8 £ ¥ + ¥ ( , ¥ 0 6 : , 2 # & & ( ¡ , + ¢ ¦ ¦ # $ ¥ , ¡ £ ¥ & ¡ ( , % ¥ # 4 8 £ ¡ > ¥ 0 b ¢  & #,

¡ ¦ ¥ ¦ ¦ & ¢ ¥ ( ,  &¡ ( ¥ 9 2 #, % ¡ ¢ , , % ¥ ( ¥ $ ¥ + +  £ + ¢ 8 8 ¡ £ , # ( - + $ # ¥ ( , # ¦ # $ ¥ > # 0 ¥ ( $ ¥  ( 0 c ¢ + , # ¦ # $  , #¡ ( 6

¨

, % ¥ £ ¥ $ ¡ &¡ - # $  & + ¢ £ > ¥ +

: (  0 0 #, #¡ ( , ¡ , % ¥   ¡ > ¥ 9 , % ¥ ¦ &¡ £   ( 0 ¦  ¢ (  $ %  8 , ¥ £ ¡ ¦  ( . : D 9 ¡ £ ¡ , % ¥ £ ¥ $ ¡ &¡ - # $  &

# 4 8  $ ,  + + ¥ + + 4 ¥ ( , 9 + % ¡ ¢ & 0  + + ¥ + + , % ¥ & # = ¥ & 0 # £ ¥ $ , 9 # ( 0 # £ ¥ $ ,  ( 0 $ ¢ 4 ¢ &  , # > ¥ ¥ ¦ ¦ ¥ $ , + ¡ ¦

, % ¥ 8 £ ¡ c ¥ $ , ¡ ( , % ¥ ¦ ¡ & &¡ 2 # ( - §

#, ¥ + 2 #, % (  , ¢ £ ¥ $ ¡ ( + ¥ £ >  , #¡ ( 0 ¥ + #- (  , #¡ ( + 9 # ( $ & ¢ 0 # ( - . ¢ £ ¡ 8 ¥  ( + #, ¥ + 9 a / 7 +  ( 0

D

8 a / 7 + j

, ¥ 8 8 # ( - + , ¡ ( ¥ +  ( 0 ¥ $ ¡ &¡ - # $  & $ ¡ £ £ # 0 ¡ £ + $ ¡ > ¥ £ ¥ 0  7 £ , # $ & ¥  ¡ ¦ , % ¥ /   #,  , +

D

' # £ ¥ $ , # > ¥ j

( ( ¥ H : 3 ? /   #,  , + ' # £ ¥ $ , # > ¥ F + 8 ¥ $ # ¥ + ¡ ¦ ¦  ¢ (   ( 0 ¦ &¡ £  9  ( 0 , % ¥ # £  £ ¥ ¥ 0 # ( - + #, ¥ +  ( 0

7

£ ¥ + , # ( - 8 &  $ ¥ + 9 2 % # $ %  £ ¥ + , £ # $ , & 8 £ ¡ , ¥ $ , ¥ 0 ¢ ( 0 ¥ £ , % ¥ . ¢ £ ¡ 8 ¥  ( * ¡ 4 4 ¢ ( #, # ¥ + ? f # £ 0 +

 ( 0 a  , ¢ £  & /   #,  , + F ¤ ¥ - ¢ &  , #¡ ( + 9   j

¨

% ¥ £ + 8 ¥ $ # ¥ + ¡ ¦ ¦  ¢ (   ( 0 ¦ &¡ £  2 % # $ %  £ ¥ 8 £ ¡ , ¥ $ , ¥ 0 ¢ ( 0 ¥ £ , % ¥ < # & 0 & # ¦ ¥ 7 $ , + 9 i g ! C

,

    j

                 r “    

Z [ N K I Q S J Y Q I J Y W M Q ” Y ‘ J O R Y o Q Y W N U • JN ` J U JW V

T

' # £ ¥ $ , # > ¥ ?    @ ; d A ; . * F  ( 0 . ¢ £ ¡ 8 ¥  ( * ¡ 4 4 ¢ ( #, # ¥ + ? . ( > # £ ¡ ( 4 ¥ ( ,  & h #   # & #, F

¤ ¥ - ¢ &  , #¡ ( + 9    B 9 # ( $ & ¢ 0 # ( - §

f # £ 0 + ' # £ ¥ $ , # > ¥ — 7 ( ( ¥ H : + 8 ¥ $ # ¥ +  ( 0 ¡ , % ¥ £ £ ¥ - ¢ &  £ & ¡ $ $ ¢ £ £ # ( - 4 #- £  , ¡ £

–

+ 8 ¥ $ # ¥ + 9  ( 0 , % ¥ # £ %   #,  , + ? 2 % ¥ £ ¥ > ¥ £ , % ¥ ¡ $ $ ¢ £ F j

/   #,  , + ' # £ ¥ $ , # > ¥ — 7 ( ( ¥ H : %   #,  , + 9 7 ( ( ¥ H : : + 8 ¥ $ # ¥ +  ( 0 , % ¥ # £ %   #,  , + 9  ( 0

–

7 ( ( ¥ H : 3 + 8 ¥ $ # ¥ +  ( 0 , % ¥ # £  £ ¥ ¥ 0 # ( - + #, ¥ +  ( 0 £ ¥ + , # ( - 8 &  $ ¥ + ? 2 % ¥ £ ¥ > ¥ £ , % ¥

¡ $ $ ¢ £ F j

¨

% ¥ £ %   #,  , + ¡ ¦ ¥ $ ¡ &¡ - # $  & >  & ¢ ¥ # (  (  , #¡ (  & , ¡ &¡ $  & $ ¡ ( , ¥ H , 9 # ( $ & ¢ 0 # ( - 2 ¥ , &  ( 0 + 6

,

¨

) % ¥ 8 £ ¡ 8 ¡ + ¥ 0 < < ) G + #, ¥ # + 8  £ , & + $ £ ¢  $ ¡ > ¥ £ ¥ 0 # ( D ¡ £ , % ¡ C 8 % ¡ , ¡ - £  8 % + ¦ £ ¡ 4    9

 ( 0 , % ¥ £ ¥  £ ¥ £ ¥ $ ¡ £ 0 + ¡ ¦ , % ¥ 8 ¡ + + #  & ¥ 8 £ ¥ + ¥ ( $ ¥ ¡ ¦ + 8 ¥ $ # ¥ + C £ # $ % 0 £ - £  + + &  ( 0 ? + ¥ 4 #C

(  , ¢ £  & F # ( ¡ £ ( ¥  £ , % ¥ + #, ¥ # ( , % ¥ %   #,  , 0  ,  + ¥ , + % ¥ & 0  a G < D 6

7 >  # &   & ¥ # ( ¦ ¡ £ 4  , #¡ ( ¡ ( + #, ¥ + 9 %   #,  , +  ( 0 + 8 ¥ $ # ¥ + # ( , % ¥ £ ¥ $ ¥ # > # ( - ¥ ( > # £ ¡ ( 4 ¥ ( , + % ¡ ¢ & 0

 ¥ + ¡ ¢ £ $ ¥ 0  ( 0 £ ¥ > # ¥ 2 ¥ 0 9 # ( $ & ¢ 0 # ( - ¦ £ ¡ 4 2 2 2 6 ( 8 2 + 6 # ¥ ? + ¥ ¥   ¡ > ¥ F 6 : (  0 0 #, #¡ ( 9 , % ¥

¦ ¡ & &¡ 2 # ( -  £ ¥ £ ¥ b ¢ # £ ¥ 0 , ¡  + + ¥ + + , % ¥ ¥ $ ¡ &¡ - # $  & ¥ ¦ ¦ ¥ $ , + §

  #,  , + ¢ £ > ¥ ¡ ¦ , % ¥ + #, ¥  ( 0 + ¢ £ £ ¡ ¢ ( 0 + 9 ¦ ¡ & &¡ 2 # ( - , % ¥ / ¥ £ #,  - ¥ * ¡ ¢ ( $ # & ?    F

/

4 ¥ , % ¡ 0 ¡ &¡ - 9  ( 0 2 #, % 8  £ , # $ ¢ &  £ ¦ ¡ $ ¢ + ¡ (  ( 7 ( ( ¥ H : ¡ £ 8 ¡ , ¥ ( , #  & 7 ( ( ¥ H : %   #,  , +

8 £ ¥ + ¥ ( , j

0 ¥ ( , # ¦ # $  , #¡ ( 9 0 ¥ + $ £ # 8 , #¡ ( 9 ¥ >  & ¢  , #¡ (  ( 0 4  8 8 # ( - ¡ ¦  ( 7 ( ( ¥ H : %   #,  , + 8 £ ¥ + ¥ ( , 9

:

# ( $ & ¢ 0 # ( - # ( , ¥ £ 4 + ¡ ¦ , % ¥ > ¥ - ¥ ,  , #¡ ( $ ¡ 4 4 ¢ ( #, # ¥ + 9 ¦ &¡ £   ( 0 ¦  ¢ (  8 £ ¥ + ¥ ( , 9  +

 8 8 £ ¡ 8 £ #  , ¥ 6 * ¡ £ £ ¥ + 8 ¡ ( 0 ¥ ( $ ¥ 2 #, % 7 ( ( ¥ H : ? 8 £ #¡ £ #, F %   #,  , , 8 ¥ + 9 ¡ £ ( ¡ , 9 + % ¡ ¢ & 0  ¥

 (  & + ¥ 0  ( 0 c ¢ + , # ¦ # ¥ 0 ¡ ( + $ # ¥ ( , # ¦ # $ - £ ¡ ¢ ( 0 + 9 2 #, % £ ¥ & ¥ >  ( , + ¢ 8 8 ¡ £ , # ( -

0  ,  ; # ( ¦ ¡ £ 4  , #¡ ( 8 £ ¥ + ¥ ( , ¥ 0 j

%   #,  , 4  8 ¡ ¦ , % ¥ + #, ¥  ( 0 + ¢ £ £ ¡ ¢ ( 0 + 2 #, % , % ¥ ¦ ¡ ¡ , 8 £ # ( , ¡ ¦ , % ¥ 8 £ ¡ c ¥ $ ,  ( 0  & & 2 ¡ £ = +

7

 £ ¥  +  ( 0  $ $ ¥ + + £ ¡ ¢ , ¥ + ¡ > ¥ £ &  # ( 9  ( 0 2 % # $ % # 0 ¥ ( , # ¦ # ¥ +  & & 7 ( ( ¥ H : ? 8 £ #¡ £ #, F %   #,  , + 9

, ¡ ¥ (   & ¥ # 4 8  $ , + ¡ ( %   #,  , + , ¡  ¥ b ¢  ( , # ¦ # ¥ 0  ( 0 b ¢  & # ¦ # ¥ 0 j

¡ ,  ( # $  & + ¢ £ > ¥ ¡ ¦ , % ¥ £ ¥ $ ¥ # > # ( - ¥ ( > # £ ¡ ( 4 ¥ ( , , ¡  ¥ ¢ ( 0 ¥ £ ,  = ¥ (  , , % ¥  8 8 £ ¡ 8 £ #  , ¥

f

, # 4 ¥ ¡ ¦ ¥  £ , ¡ 8 £ ¡ 8 ¥ £ & $ %  £  $ , ¥ £ # + ¥  ( 0 ¥ >  & ¢  , ¥ , % ¥ %   #,  , + 8 £ ¥ + ¥ ( , 9  ( 0 # 0 ¥ ( , # ¦

 ( £  £ ¥ ¡ £ 8 £ ¡ , ¥ $ , ¥ 0 + 8 ¥ $ # ¥ + j

 ¢ (  & + ¢ £ > ¥ + ¡ ¦ , % ¥ £ ¥ $ ¥ # > # ( - ¥ ( > # £ ¡ ( 4 ¥ ( , , ¡  ¥ ¢ ( 0 ¥ £ ,  = ¥ (  ,  8 8 £ ¡ 8 £ #  , ¥ , # 4 ¥ +



¡ ¦ , % ¥ ¥  £ , ¡ # 0 ¥ ( , # ¦  ( £  £ ¥ ¡ £ 8 £ ¡ , ¥ $ , ¥ 0 + 8 ¥ $ # ¥ + , %  , ¢ + ¥ , % ¥ + #, ¥  ( 0 + ¢ £ £ ¡ ¢ ( 0 # ( -

 £ ¥  + 6

: ( ¢ ( 0 ¥ £ ,  = # ( - + ¢ £ > ¥ +  ( 0  + + ¥ + + 4 ¥ ( , + 9 , % ¥ £ ¥ $ ¥ # > # ( - ¥ ( > # £ ¡ ( 4 ¥ ( , + % ¡ ¢ & 0  ¥ 0 ¥ ¦ # ( ¥ 0

, ¡ # ( $ & ¢ 0 ¥  & &  £ ¥  + , %  , 2 # & &  ¥ # 4 8  $ , ¥ 0 0 # £ ¥ $ , & ¡ £ # ( 0 # £ ¥ $ , &   & & 8  £ , + ¡ ¦ , % ¥ 8 £ ¡ c ¥ $ ,  ,

 & & + ,  - ¥ + 9  ( 0 # ( $ & ¢ 0 # ( -  (  ( $ # & &  £  ( 0  + + ¡ $ #  , ¥ 0 2 ¡ £ = + 6 ) % ¥ & # = ¥ & ¥ ¦ ¦ ¥ $ , + ¡ ( + #, ¥ + 9

%   #,  , +  ( 0 + 8 ¥ $ # ¥ + + % ¡ ¢ & 0  ¥  + + ¥ + + ¥ 0 # ( , % ¥ & #- % , ¡ ¦  & &  + 8 ¥ $ , + ¡ ¦ 8 £ ¡ c ¥ $ ,

0 ¥ > ¥ &¡ 8 4 ¥ ( ,  ( 0 ¡ 8 ¥ £  , #¡ (  , , % ¥ >  £ #¡ ¢ + + ,  - ¥ + 6

7 ( ( ¥ $ ¥ + +  £ 4 #, #-  , #¡ ( 4 ¥  + ¢ £ ¥ + + % ¡ ¢ & 0  ¥ 0 ¥ > # + ¥ 0  ( 0 + 8 ¥ $ # ¦ # ¥ 0 # ( 0 ¥ ,  # &  , , % ¥

 8 8 & # $  , #¡ ( + ,  - ¥ 9  ( 0 + % ¡ 2 ( # ( 0 £  2 # ( - + 9  + £ ¥ & ¥ >  ( , 6 ) % # + + % ¡ ¢ & 0 # ( $ & ¢ 0 ¥  ( 4 ¥ , % ¡ 0

+ ,  , ¥ 4 ¥ ( , + 9 ¥ ( > # £ ¡ ( 4 ¥ ( ,  & ¡ 8 ¥ £  , # ( - 8 &  ( + 9 ¥ , $ 6 9 , %  , 4   ¥ £ ¥ b ¢ # £ ¥ 0  , + #, ¥

8 £ ¥ 8  £  , #¡ (  ( 0 $ ¡ ( + , £ ¢ $ , #¡ ( + ,  - ¥ + 6 : , + % ¡ ¢ & 0  ¥ 0 ¥ 4 ¡ ( + , £  , ¥ 0 9  + 8  £ , ¡ ¦  (

 8 8 & # $  , #¡ ( 9 , %  , 4 #, #-  , #¡ ( 4 ¥  + ¢ £ ¥ + $  (  ( 0 2 # & &  ¥ 0 ¥ & # > ¥ £ ¥ 0 9 , %  , , % ¥ 2 # & &  ¥ ¥ ¦ ¦ ¥ $ , # > ¥

# (  0 0 £ ¥ + + # ( -  ( 0  4 ¥ & #¡ £  , # ( - , % ¥ ¥ ¦ ¦ ¥ $ , + # 0 ¥ ( , # ¦ # ¥ 0 9  ( 0 , %  ,  ( ¥ ¦ ¦ ¥ $ , + , %  , $ ¡ ¢ & 0

 £ # + ¥ ¦ £ ¡ 4 4 #, #-  , #¡ ( 4 ¥  + ¢ £ ¥ + , % ¥ 4 + ¥ & > ¥ + ? ¦ ¡ £  & & ¥ ( > # £ ¡ ( 4 ¥ ( ,  & , ¡ 8 # $ + 9 # ( $ & ¢ 0 # ( - 9 ¦ ¡ £

¥ H  4 8 & ¥ 9  £ $ %  ¥ ¡ &¡ - F  £ ¥ ,  = ¥ ( # ( , ¡  $ $ ¡ ¢ ( ,  ( 0 + ¢  c ¥ $ , ¥ 0 , ¡  + + ¥ + + 4 ¥ ( , 6

) % ¥ 8 £ # 4  £ # + + ¢ ¥ , %  , , % ¥ a : D 2 # & & ( ¥ ¥ 0 , ¡ ¦ ¡ $ ¢ + ¡ ( # + , % ¥ # 4 8  $ , ¡ ¦ 8 % ¡ + 8 % ¡ £ ¢ + &¡  0 # ( -

¦ £ ¡ 4 , % ¥ 8 £ ¡ 8 ¡ + ¥ 0 , £ ¥  , 4 ¥ ( , 8 &  ( , ¡ ( , % ¥ + , £ ¢ $ , ¢ £ ¥  ( 0 ¦ ¢ ( $ , #¡ ( # ( - ¡ ¦ , % ¥ . ¢ £ ¡ 8 ¥  ( + #, ¥ 6

: ( £ ¥ &  , #¡ ( , ¡ , % # + # + + ¢ ¥ 9  & &  >  # &   & ¥ 4 #, #-  , #¡ ( 4 ¥  + ¢ £ ¥ + , ¡ £ ¥ 0 ¢ $ ¥ 8 % ¡ + 8 % ¡ £ ¢ + # ( 8 ¢ , +

# ( , ¡ , % ¥ , ¢ £ &¡ ¢ - % 9 , ¡ , % ¥   + ¡ & ¢ , ¥ 4 # ( # 4 ¢ 4 9 + % ¡ ¢ & 0  ¥ $ ¡ ( + # 0 ¥ £ ¥ 0 6 * ¡ ( + # 0 ¥ £  , #¡ ( ( ¥ ¥ 0 +

, ¡  ¥ - # > ¥ ( , ¡ , % ¥ 8 £ ¡ > # + #¡ ( ¡ ¦ ¥ ¦ ¦ & ¢ ¥ ( , 8 ¡ & # + % # ( - 4 ¥  + ¢ £ ¥ + 9 # ( $ & ¢ 0 # ( -  ¢ , ( ¡ , & # 4 #, ¥ 0 , ¡

, % ¥ ¢ + ¥ ¡ ¦ $ ¡ ( + , £ ¢ $ , ¥ 0 2 ¥ , &  ( 0 + 6 ) % # + . ¢ £ ¡ 8 ¥  ( + #, ¥ # + $ %  £  $ , ¥ £ # + ¥ 0   + 4  & &

$  , $ % 4 ¥ ( ,  £ ¥  2 #, %  % #- % 8 £ ¡ 8 ¡ £ , #¡ ( ¡ ¦ , % ¥ 2  , ¥ £ ¥ ( , ¥ £ # ( - , % ¥ , ¢ £ &¡ ¢ - % $ ¡ 4 # ( - ¦ £ ¡ 4

, % ¥  0 c ¡ # ( # ( - £  # + ¥ 0  ¡ - 6 ) % # + 2  , ¥ £ 2 ¡ ¢ & 0  ¥ ¥ H 8 ¥ $ , ¥ 0 , ¡  ¥ (  , ¢ £  & & &¡ 2 # ( ( ¢ , £ # ¥ ( , + 6

: , # + £ ¥ $ ¡ 4 4 ¥ ( 0 ¥ 0 , %  , # ( $  £ £ # ( - ¡ ¢ , , % ¥ a : D 9 , % ¥   $ = - £ ¡ ¢ ( 0 & ¥ > ¥ & + ¡ ¦ 8 % ¡ + 8 % ¡ £ ¢ + # (

2  , ¥ £ ¥ ( , ¥ £ # ( - , % ¥ , ¢ £ &¡ ¢ - % ¦ £ ¡ 4 + ¢ $ % + ¡ ¢ £ $ ¥ +  £ ¥ 4 ¥  + ¢ £ ¥ 0 9 2 #, %  > # ¥ 2 , ¡

$ ¡ ( + , £ ¢ $ , # ( - , % ¥ & ¥ > ¥ & + ¡ ¦ 8 % ¡ + 8 % ¡ £ ¢ + , %  , + % ¡ ¢ & 0 (  , ¢ £  & & 8 ¥ £ ,  # ( # ( , % ¥ , ¢ £ &¡ ¢ - % 9 # ( , % ¥

  + ¥ ( $ ¥ ¡ ¦ , % ¥ # ( 8 ¢ , ¦ £ ¡ 4 , % ¥ ¥ ¦ ¦ & ¢ ¥ ( , , £ ¥  , 4 ¥ ( , 8 &  ( , 6

) % ¥   ¡ > ¥ ¡  + ¥ £ >  , #¡ ( +  ( 0 £ ¥ $ ¡ 4 4 ¥ ( 0  , #¡ ( +  £ ¥   + ¥ 0 ¡ ( , % ¥ 8  8 ¥ £ + + ¢  4 #, , ¥ 0 , ¡

, % # + ' ¥ 8  £ , 4 ¥ ( , ¡ (  8 £ ¥ C 8 &  ( ( # ( -   + # +  ( 0  £ ¥ 4  0 ¥ 2 #, % ¡ ¢ , 8 £ ¥ c ¢ 0 # $ ¥ , ¡  (

¡  + ¥ £ >  , #¡ ( + , % ¥ " # ( # + , ¥ £ 4  4  = ¥ # ( , % ¥ $ ¡ ( , ¥ H , ¡ ¦  ( $ ¡ ( + ¢ &,  , #¡ (  £ # + # ( - ¡ ( ¦ ¡ ¡ , ¡ ¦

 ( 0 ¥ > ¥ &¡ 8 4 ¥ ( ,  8 8 & # $  , #¡ ( £ ¥ ¦ ¥ £ £ ¥ 0 , ¡ , % ¥ " # ( # + , ¥ £ 9   8 &  ( ( # ( -  ¢ , % ¡ £ #, 9 # ( % ¥ £ £ ¡ & ¥

 + + ,  , ¢ , ¡ £ $ ¡ ( + ¢ &, ¥ ¥ ¢ ( 0 ¥ £ , % ¥ G &  ( ( # ( -  ( 0 ' ¥ > ¥ &¡ 8 4 ¥ ( , 7 $ ,     9  +  4 ¥ ( 0 ¥ 0 6

˜ R X N O Q O Q ‡ X Q K W Q I W R K Q Y I S X O W M Q O L R o o X Y JL N W JR Y K W R W M JK Ž Q } N O W o Q Y W ZK Ž Q ‘ Q UR } o Q Y W

? , ¥  4 4 ¡ ( #, ¡ £ ¥ 0 F j # ¦ , % # + # + ( ¡ , 7 8 8 & # $  , #¡ ( + l ( #, ? ' 7 l F  ,

8 ¡ + + #  & ¥ 9 $ ¡ £ £ ¥ + 8 ¡ ( 0 ¥ ( $ ¥ 4   &, ¥ £ (  , # > ¥ &  ¥ + ¥ ( , , ¡ §

) % ¥ "  (  - ¥ £

' ¥ > ¥ &¡ 8 4 ¥ ( , 7 8 8 & # $  , #¡ ( + l ( #, ? ' 7 l F

1

' ¥ 8  £ , 4 ¥ ( , ¡ ¦ 7 £ , + 9 / ¥ £ #,  - ¥  ( 0 , % ¥  ¥ &,  $ % ,

a ¥ 2 , ¡ 2 ( ¤ ¡  0

< ¥ H ¦ ¡ £ 0

d A 7 G i 

: + 4 # + ¥ 9 & ¥ 4 ¥  +

a ¡ , ¥ + ¡ ( , % ¥ 8 £ ¥ 8  £  , #¡ (  ( 0 $ ¡ ( , ¥ ( , ¡ ¦  ( a : D

^ M Q W Q O o T ™ ‰ Š Z JK I Q S J Y Q I J Y UQ P JK UN W JR Y š 6 : ( - ¥ ( ¥ £  & 9  ( a : D 9 # ¦ £ ¥ b ¢ # £ ¥ 0 9 + % ¡ ¢ & 0 8 £ ¥ + ¥ ( ,

, % ¥ 0  ,  9 # ( ¦ ¡ £ 4  , #¡ (  ( 0  (  & + # + ( ¥ $ ¥ + +  £ , ¡ £ ¥  $ %  0 ¥ ¦ # ( #, # > ¥ 0 ¥ , ¥ £ 4 # (  , #¡ (  + , ¡ F

, % ¥ # 4 8 & # $  , #¡ ( + ¡ ¦ , % ¥ 8 &  ( ¡ £ 8 £ ¡ c ¥ $ , 9  &¡ ( ¥ ¡ £ # ( $ ¡ 4  # (  , #¡ ( 2 #, % ¡ , % ¥ £ 8 &  ( +  ( 0

8 £ ¡ c ¥ $ , + 9 ¦ ¡ £  . ¢ £ ¡ 8 ¥  ( + #, ¥ # ( > # ¥ 2 ¡ ¦ #, + $ ¡ ( + ¥ £ >  , #¡ ( ¡  c ¥ $ , # > ¥ + 9  ( 0  F 2 % ¥ , % ¥ £ , % ¥ £ ¥

2 # & &  ¥  0 > ¥ £ + ¥ ¥ ¦ ¦ ¥ $ , + ¡ ( , % ¥ # ( , ¥ - £ #, ¡ ¦  . ¢ £ ¡ 8 ¥  ( + #, ¥ 6 ) % ¥ a : D + % ¡ ¢ & 0  ¥

¢ ( 0 ¥ £ 8 # ( ( ¥ 0   ¥ + , + $ # ¥ ( , # ¦ # $ = ( ¡ 2 & ¥ 0 - ¥  ( 0 ¡  c ¥ $ , # > ¥ # ( ¦ ¡ £ 4  , #¡ ( 9  + £ ¥ b ¢ # £ ¥ 0 # ( , % ¥

$  + ¥ ¡ ¦ + $ £ ¥ ¥ ( # ( - ¦ ¡ £  8 8 £ ¡ 8 £ #  , ¥  + + ¥ + + 4 ¥ ( , 9  ( 0  , % ¥ 8 £ ¥ $  ¢ , #¡ (  £ 8 £ # ( $ # 8 & ¥ 6

› N K Q I R Y W M Q Ž Q } N O W o Q Y W ZK Q \ } Q O JQ Y L Q R S O Q ‘ JQ  J Y P K X L M O Q } R O W K [ W M Q S R U UR  J Y P N I ‘ JL Q JK

¡ ¦ ¦ ¥ £ ¥ 0 # ( £ ¥ &  , #¡ ( , ¡ , % ¥ 8 £ ¥ 8  £  , #¡ (  ( 0 $ ¡ ( , ¥ ( , ¡ ¦  ( a : D §

6 7 ( a : D # +  + $ # ¥ ( , # ¦ # $  + + ¥ + + 4 ¥ ( , , %  , 8 £ ¥ + ¥ ( , + £ ¥ & ¥ >  ( , ¥ > # 0 ¥ ( $ ¥ 9 0  ,   ( 0

 (  & + # + 9  ( 0 ¦ ¡ $ ¢ + ¥ + ¡ ( , % ¥ # 4 8 & # $  , #¡ ( + ¡ ¦ , % ¥ 8 &  ( ¡ £ 8 £ ¡ c ¥ $ , 9 ¡ ( #, + ¡ 2 (  ( 0 # (

$ ¡ 4  # (  , #¡ ( 2 #, % ¡ , % ¥ £ 8 &  ( +  ( 0 8 £ ¡ c ¥ $ , + 9 ¦ ¡ £ , % ¥ $ ¡ ( + ¥ £ >  , #¡ ( ¡  c ¥ $ , # > ¥ + ¡ ¦ , % ¥

£ ¥ & ¥ >  ( , . ¢ £ ¡ 8 ¥  ( + #, ¥ ? + F 9 ,  = # ( - , % ¥ ¦ ¢ & & + $ ¡ 8 ¥ ¡ ¦ , % ¥ + ¥ ¡  c ¥ $ , # > ¥ + 9 2 % ¥ , % ¥ £

- ¥ ( ¥ £ # $ ¡ £ + #, ¥ + 8 ¥ $ # ¦ # $ 9 # ( , ¡  $ $ ¡ ¢ ( , j

 6 . H  4 # (  , #¡ ( ¡ ¦ , % ¥ 8 ¡ , ¥ ( , #  & ¥ ¦ ¦ ¥ $ , + ¡ ¦ , % ¥ 8 &  ( ¡ £ 8 £ ¡ c ¥ $ , 4 ¢ + ,  ¥ ¢ ( 0 ¥ £ ,  = ¥ ( , ¡

# 0 ¥ ( , # ¦ 2 %  , . ¢ £ ¡ 8 ¥  ( + #, ¥ + 9  ( 0 2 % # $ % ¡ ¦ , % ¥ # £ b ¢  & # ¦ # ( - # ( , ¥ £ ¥ + , + ? D 7 * F 9

+ 8 ¥ $ #  & $ ¡ ( + ¥ £ >  , #¡ ( # ( , ¥ £ ¥ + , + ? D G 7 F ¡ £ $ ¡ ( + ¥ £ >  , #¡ ( ¡  c ¥ $ , # > ¥ + 9  £ ¥ 8 ¡ , ¥ ( , #  & &  ,

£ # + = 6 : ( $ ¡ 4  # (  , #¡ ( ¥ ¦ ¦ ¥ $ , + 4 ¢ + ,  & + ¡  ¥ ,  = ¥ ( # ( , ¡  $ $ ¡ ¢ ( , 6 ) % # + # + £ ¥ b ¢ # £ ¥ 0 , ¡

I Q W Q O o J Y Q N T œ R Y Q R S J Y S U X Q Y L Q Z R O T œ R Y Q R S J o } N L W Z S R O W M Q } O R ’ Q L W [ # ¦ + ¢ $ % 

$ ¡ ( $ ¥ 8 , # + ¢ + ¥ 0 6 ) % ¥ A = 4 0 # + ,  ( $ ¥ # ( ¥ H # + , # ( - - ¢ # 0  ( $ ¥ # +  ( # ( 0 # $  , # > ¥ ¦ #- ¢ £ ¥

¡ ( &  ( 0 #, +  8 8 & # $  , #¡ (  ( 0 >  & # 0 #, + % ¡ ¢ & 0  ¥ ¥ H  4 # ( ¥ 0  ( 0 c ¢ + , # ¦ # ¥ 0 # ( ¥  $ %

+ 8 ¥ $ # ¦ # $ $  + ¥ ¡ (  ( ¥ $ ¡ &¡ - # $  & ¡ £ ¡ , % ¥ £   + # + j

d 6 ) % ¥ + $ # ¥ ( , # ¦ # $   + # + ¡ ( 2 % # $ % + #, ¥ +  ( 0 , % ¥ # £ $ ¡ ( + ¥ £ >  , #¡ ( ¡  c ¥ $ , # > ¥ +  £ ¥ # ( $ & ¢ 0 ¥ 0

¡ £ ¥ H $ & ¢ 0 ¥ 0 ¦ £ ¡ 4  + + ¥ + + 4 ¥ ( ,  ( 0  (  & + # + + % ¡ ¢ & 0  ¥ 8 £ ¥ + ¥ ( , ¥ 0  ( 0 c ¢ + , # ¦ # ¥ 0 j

@ 6 ) % ¥ ¦ ¢ & &  £ ¥  ¡ £ ¥ H , ¥ ( , ¡ ¦ , % ¥ & # = ¥ & ¥ ¦ ¦ ¥ $ , + ¡ ¦ , % ¥ 8 &  ( ¡ £ 8 £ ¡ c ¥ $ , + % ¡ ¢ & 0  ¥

0 ¥ , ¥ £ 4 # ( ¥ 0  ( 0 b ¢  ( , # ¦ # ¥ 0 6 < % ¥ £ ¥ , ¥ 4 8 ¡ £  £ 0  4  - ¥  ( 0 0 # + , ¢ £   ( $ ¥ 2 # & & ¡ $ $ ¢ £ 9

8 £ ¥ 0 # $ , ¥ 0 , # 4 ¥ & # ( ¥ + ¦ ¡ £ £ ¥ $ ¡ > ¥ £ + % ¡ ¢ & 0  ¥ 8 £ ¥ + ¥ ( , ¥ 0 j

A 6 ) % ¥ £ ¥ & ¥ >  ( , ¥ ( > # £ ¡ ( 4 ¥ ( ,  &   + ¥ & # ( ¥  ( 0 , £ ¥ ( 0 + # ( . ¢ £ ¡ 8 ¥  ( + #, ¥ + + % ¡ ¢ & 0  ¥

,  = ¥ ( # ( , ¡  $ $ ¡ ¢ ( , 9  ¥  £ # ( - # ( 4 # ( 0 $ %  ( - ¥ +  ( 0 # ( $ ¡ 4  # (  , #¡ ( ¥ ¦ ¦ ¥ $ , + 2 % # $ %

%  > ¥ ¡ $ $ ¢ £ £ ¥ 0 + # ( $ ¥ + #, ¥ 0 ¥ + #- (  , #¡ ( j

! 6 7 ( a : D + % ¡ ¢ & 0  ¥ # ( ¦ ¡ £ 4 ¥ 0   ( ( ¥ $ ¥ + +  £ + ¢ £ > ¥ + ¡ ¦ %   #,  , +  ( 0 + 8 ¥ $ # ¥ +  ,

, % ¥  8 8 £ ¡ 8 £ #  , ¥ , # 4 ¥ ? + F ¡ ¦ ¥  £ , ¡ # 0 ¥ ( , # ¦ 9 0 ¥ + $ £ #  ¥ 9 ¥ >  & ¢  , ¥  ( 0 4  8 , % ¥ # £

8 £ ¥ + ¥ ( $ ¥ 2 #, % # ( , % ¥ £ ¥ $ ¥ # > # ( - ¥ ( > # £ ¡ ( 4 ¥ ( , 6 : (  & & £ ¥ & ¥ >  ( , $  + ¥ + 9 , % ¥ + $ # ¥ ( , # ¦ # $

  + # +  ( 0 c ¢ + , # ¦ # $  , #¡ ( + ¦ ¡ £ $  , ¥ - ¡ £ # + # ( - ¡ £ ( ¡ , $  , ¥ - ¡ £ # + # ( - %   #,  , +  + 7 ( ( ¥ H :

%   #,  , + 9 ¡ £ 8 £ #¡ £ #, , 8 ¥ + 9 + % ¡ ¢ & 0  ¥ 8 £ ¥ + ¥ ( , ¥ 0 j

g 6 7 ( a : D + % ¡ ¢ & 0  ¥ # ( ¦ ¡ £ 4 ¥ 0   ( ( ¥ $ ¥ + +  £ % 0 £ ¡ &¡ - # $  & 9 % 0 £ ¡ - ¥ ¡ &¡ - # $  & ¡ £

- ¥ ¡ , ¥ $ % ( # $  & # ( > ¥ + , #-  , #¡ ( + , ¡  + + ¥ + + # 4 8  $ , + ¡ ( %   #,  , + , £ ¢ $ , ¢ £ ¥  ( 0 ¦ ¢ ( $ , #¡ ( j

B 6 < % ¥ £ ¥ 4 #, #-  , #¡ ( 4 ¥  + ¢ £ ¥ +  £ ¥ £ ¥ b ¢ # £ ¥ 0 9 ¦ ¢ & & 0 ¥ ,  # & + + % ¡ ¢ & 0  ¥ # ( $ & ¢ 0 ¥ 0 # ( , % ¥

8 £ ¡ c ¥ $ , 0 ¥ + $ £ # 8 , #¡ (  ( 0 0 £  2 # ( - + 9 2 #, % 4 ¥ , % ¡ 0 + ,  , ¥ 4 ¥ ( , + 8 £ ¡ > # 0 ¥ 0 9 2 % ¥ £ ¥

4 In accordance with Section 177T of the Planning and Development Act, 2000 as amended, an NIS means a statement, for the purposes of Article 6 of the Habitats Directive, of the implications of a proposed development, on its own and in combination with other plans and projects, for a European site in view of its conservation objectives. It is required to include a report of a scientific examination of evidence and data, carried out by competent persons to identify and classify any implications for the European site in view of its conservation objectives

( ¥ $ ¥ + +  £ 6 : , 4 ¢ + ,  ¥ 0 ¥ 4 ¡ ( + , £  , ¥ 0 , %  , 4 #, #-  , #¡ ( 4 ¥  + ¢ £ ¥ + 2 # & &  ¥ 0 ¥ & # > ¥ £ ¥ 0 # (

¦ ¢ & & 9  ( 0  , , % ¥  8 8 £ ¡ 8 £ #  , ¥ , # 4 ¥ 9  ,  & & 8 ¡ + , C $ ¡ ( + ¥ ( , + ,  - ¥ + 9  ( 0 , %  , , % ¥ 2 # & &  ¥

¥ ¦ ¦ ¥ $ , # > ¥ # (  ( + 8 ¥ $ # ¦ # $ &¡ $  , #¡ ( ¡ £ + ¥ , ¡ ¦ $ ¡ ( 0 #, #¡ ( + 6 ) % ¥ ( ¥ $ ¥ + +  £  (  & + # +

+ % ¡ ¢ & 0  ¥ 8 £ ¥ + ¥ ( , ¥ 0 , ¡ 0 ¥ 4 ¡ ( + , £  , ¥ % ¡ 2 , % ¥ 4 #, #-  , #¡ ( 4 ¥  + ¢ £ ¥ + 2 # & &  > ¡ # 0 ¡ £

£ ¥ 4 ¡ > ¥ , % ¥ £ # + = + ¡ ¦  0 > ¥ £ + ¥ ¥ ¦ ¦ ¥ $ , + ¡ ( , % ¥ # ( , ¥ - £ #, ¡ ¦ . ¢ £ ¡ 8 ¥  ( + #, ¥ + , %  , %  > ¥

 ¥ ¥ ( # 0 ¥ ( , # ¦ # ¥ 0 # (  ( a : D + ¡ , %  , , % ¥ ¦ # (  &  (  & + # + # + ¢ ( 0 ¥ £ ,  = ¥ ( # ( , % ¥ $ ¡ ( , ¥ H , ¡ ¦

, % ¥ 8 £ ¥ 0 # $ , ¥ 0 £ ¥ + # 0 ¢  & ¥ ¦ ¦ ¥ $ , + j

i 6 7 ( a : D + % ¡ ¢ & 0 £ ¥  $ %  $ & ¥  £  ( 0 8 £ ¥ $ # + ¥ $ ¡ ( $ & ¢ + #¡ (  + , ¡ , % ¥ # 4 8 & # $  , #¡ ( + ¡ ¦ , % ¥

8 £ ¡ c ¥ $ , 9 ¡ ( #, + ¡ 2 (  ( 0 # ( $ ¡ 4  # (  , #¡ ( 2 #, % ¡ , % ¥ £ 8 &  ( +  ( 0 8 £ ¡ c ¥ $ , + 9 ¦ ¡ £ , % ¥

$ ¡ ( + ¥ £ >  , #¡ ( ¡  c ¥ $ , # > ¥ + ¡ ¦ , % ¥ £ ¥ & ¥ >  ( , . ¢ £ ¡ 8 ¥  ( + #, ¥ ? + F 6