Proposed Beach Promenade, Downings Natura Impact Statement (Informative)

March 2016

Proposed Beach Promenade, Downings Natura Impact Statement (Informative)

Client: Donegal County Council C/O Doran Consulting

Document number: 7088 Project number: 267797j Status: Final

Author: Gemma Nixon Reviewer: Kathy Dale

Date of issue: 23 March 2016

Glasgow Aberdeen Inverness

Craighall Business Park Banchory Business Centre Alder House 8 Eagle Street Burn O’Bennie Road Cradlehall Business Park Glasgow Banchory Inverness G4 9XA AB31 5ZU IV2 5GH 0141 341 5040 01330 826 596 01463 794 212 [email protected] www.envirocentre.co.uk

This document has been prepared for Donegal County Council C/O Doran Consulting (“the Client”). EnviroCentre accepts no liability or responsibility for any use that is made of this document other than by the Client for the purpose of the original commission for which it has been prepared. Donegal County Council C/O Doran Consulting March 2016 Proposed Beach Promenade, Downings; Natura Impact Statement (Informative)

Contents 1 Introduction ...... 1 1.1 Regulatory Context ...... 1 1.2 Appropriate Assessment ...... 1 1.3 Screening for Appropriate Assessment ...... 3 1.4 Aim of Report ...... 3 2 Method ...... 4 3 Project Description ...... 5 3.1 Site and Surroundings ...... 5 3.2 Preferred Option ...... 6 4 Sheephaven SAC ...... 9 4.1 Synopsis ...... 9 5 Identification and Description of PotentiAl Impacts to Sheephaven SAC features of interest ...... 15 5.1 Mudflats and sandflats not covered by seawater at low tide ...... 15 5.2 Atlantic salt meadows (Glauco-Puccinellietalia maritimae) ...... 17 5.3 Mediterranean salt meadows (Juncetalia maritimi) ...... 18 5.4 Shifting dunes along the shoreline with Ammophila arenaria (white dunes)...... 19 5.5 Machairs (in Ireland) ...... 20 5.6 Old sessile oak woods with Ilex and Blechnum in the British Isles ...... 20 5.7 Petalwort Petalophyllum ralfsii ...... 20 6 In Combination Effects ...... 22 7 Concluding Statement ...... 23 References ...... 24

Figures Figure 3-1: Publically available aerial imagery identifying Downings village, pier, beach and caravan site ...... 5 Figure 3-2: Proposed promenade location ...... 6 Figure 3-3: ‘Alternative Revetment Walkway’ Promenade Design ...... 8 Figure 5-1: Sheephaven SAC location of mudflats and sandflats ...... 16 Figure 5-2: Sheephaven SAC distribution of community types ...... 17 Figure 5-3: Sheephaven SAC location of Atlantic salt meadows and Mediterranean salt meadows ...... 18 Figure 5-4: Sheephaven SAC location of white dunes...... 19 Figure 5-5: Habitats identified at Downings Bay ...... 20 Figure 5-6: Sheephaven SAC Petalwort distribution ...... 21

Tables Table 4.1: Conservation Objectives for Sheephaven SAC ...... 10

i Donegal County Council C/O Doran Consulting March 2016 Proposed Beach Promenade, Downings; Natura Impact Statement (Informative)

1 INTRODUCTION

This report has been prepared by EnviroCentre Ltd in association with Doran Consulting, on behalf of their client, Donegal County Council. The objective is to determine the potential effects, if any, of a proposed Beach Promenade at Downings, County Donegal, on the Sheephaven Special Area of Conservation (SAC, Site Code No. 001190) (on site). The purpose of this assessment is to determine the appropriateness, or otherwise, of the proposed scheme in the context of the conservation status of this site.

1.1 Regulatory Context

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

1.2 Appropriate Assessment

The Habitats Directive requires ‘appropriate assessment’ of plans and projects that are likely to have a significant effect on Natura 2000 sites.

Article 6(3) establishes the requirement for Appropriate Assessment:

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

Article 6(4) goes on to discuss alternative solutions, the test of “imperative reasons of overriding public interest” (IROPI) and compensatory measures:

“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 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”.

A number of guidance documents on the appropriate assessment process have been referred to during the preparation of this Natura Impact Statement (Informative) NIS(I). These are:

• Managing Natura 2000 Sites: The provisions of Article 6 of the ‘Habitats’ Directive 92/43/EEC (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 (Nov. 2001 – published 2002);

Donegal County Council C/O Doran Consulting March 2016 Proposed Beach Promenade, Downings; Natura Impact Statement (Informative)

• EU Guidance document on Article 6(4) of the 'Habitats Directive' 92/43/EEC (2007); and • Appropriate Assessment of Plans and Projects in Ireland - Guidance for Planning Authorities (Department of the Environment, Heritage and Local Government 2009, Revised February 2010).

Should a decision be reached to the effect that it cannot be said with sufficient certainty that the development will not have any significant effect on the Natura 2000 sites, then, as stated above, it is necessary and appropriate to carry out an appropriate assessment of the implications of the development for the sites in view of their conservation objectives.

The guidance for Appropriate Assessment (AA) states (Section 2.4 pg. 23):

“AA is an impact assessment process that fits within the decision-making framework and tests of Articles 6(3) and 6(4) and, for the purposes of this guidance, it comprises two main elements. Firstly a Natura Impact Statement – i.e. a statement of the likely and possible impacts of the plan or project on a Natura 2000 site (abbreviated in the following guidance to “NIS”) must be prepared. This comprises a comprehensive ecological impact assessment of a plan or project; it examines the direct and indirect impacts that the plan or project might have on its own or in combination with other plans and projects, on one or more Natura 2000 sites in view of the sites’ conservation objectives. Secondly, the competent authority carries out the AA, based on the NIS and any other information it may consider necessary. The AA process encompasses all of the processes covered by Article 6(3) of the Habitats Directive, i.e. the screening process, the NIS, the AA by the competent authority, and the record of decisions made by the competent authority at each stage of the process, up to the point at which Article 6(4) may come into play following a determination that a plan or project may adversely affect the integrity of a Natura 2000 site”.

1.2.1 Special Areas of Conservation (SACs)

These sites are protected under legislation from significant damage to their relevant habitats and species on a European as well as a national level. SACs are designated under Article 3 of the Habitats Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and flora, as part of the Natura 2000 network (transposed into Irish law by the European Communities (Birds and Natural Habitats) Regulations 2011 (S.I. No. 477 of 2011)). This network comprises Annex I habitats - "natural habitat types of community interest whose conservation requires the designation of Special Areas of Conservation" and the habitats of Annex II species - "animal and plant species of community interest whose conservation requires the designation of Special Areas of Conservation". In addition, the Directive states that: "The Natura 2000 network shall include the Special Protection Areas classified by the Member States pursuant to Directive 79/409/EEC".

1.2.2 Conservation Objectives

The overriding objective of the Habitats Directive is to ensure that the habitats and species covered achieve ‘favourable conservation status’ and that their long-term survival is secured across their entire natural range within the EU. In its broadest sense, favourable conservation status means that an ecological feature is being maintained in a satisfactory condition, and that this status is likely to continue into the future. Definitions as per the EU Habitats Directive are given below.

Favourable Conservation Status as defined by Articles 1 (e) and 1(i) of the Habitats Directive

The conservation status of a natural habitat is the sum of the influences acting on it 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 natural habitat will be taken as favourable when:

• its natural range and areas it covers within that range are stable or increasing; and

Donegal County Council C/O Doran Consulting March 2016 Proposed Beach Promenade, Downings; Natura Impact Statement (Informative)

• 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 conservation status of a species is the sum of the influences acting on the species that may affect the long- term distribution and abundance of its populations. The conservation status will be taken as ‘favourable’ when:

• the 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; and • 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.

Site-specific conservation objectives define the desired condition or range of conditions that a habitat or species should be in, in order for these selected features within the site to be judged as favourable. At site level, this state is termed ‘favourable conservation condition.’ Site conservation objectives also contribute to the achievement of the wider goal of biodiversity conservation at other geographic scales, and to the achievement of favourable conservation status at national level and across the Natura 2000 network.

1.3 Screening for Appropriate Assessment

Screening relates to Stage 1 of the analysis, which determines whether a plan or project can be clearly said not to require AA (if not, then the assumption is that it will). Screening was undertaken by EnviroCentre, and it was considered that the proposed activity is not directly connected with or necessary to the management of Sheephaven SAC and that it cannot be excluded, on the basis of objective scientific information, that the proposed activity, either alone or in combination with other plans or projects, will have a significant effect on a European site and accordingly determined that an Appropriate Assessment of the proposed activity is required. This determination is based on the nature and scale of the proposed activities and their location within the boundary of Sheephaven SAC.

The Department of Arts, Heritage and the Gaeltacht (Development Applications Unit), considered the AA Stage 1 Screening Report during the consultation process, and agreed with the conclusion of the Screening Report that an AA Stage 2 Natura Impact Statement (NIS) is required.

1.4 Aim of Report

This document provides the information to allow a Stage 2 assessment of the proposed Beach Promenade, Downings, County Donegal on the qualifying interests and conservation objectives of Sheephaven SAC. It includes the consideration of data and information relating to the project and the site, data and information from publically available sources, and consultations with the Department of Arts, Heritage and the Gaeltacht. At Stage 2, the impact of a project alone and in combination with other projects on the integrity of the Natura 2000 site is considered with respect to the conservation objectives of the site and to its structure and function. This document provides the impact assessment and determines whether the integrity of the sites is likely to be affected. Mitigation measures are provided where appropriate.

Donegal County Council C/O Doran Consulting March 2016 Proposed Beach Promenade, Downings; Natura Impact Statement (Informative)

2 METHOD

This study has been entirely desk-based and no site visit has been made. The following information has been obtained:

• Location and characteristics of the promenade site; • Description of operation; • Alternatives to creating the promenade; • Publically available ecological information on the site; • Site information for Sheephaven SAC; • Assessment of impacts on the environment; • Proposed mitigation measures; • Development feasibility study document (The Downings Promenade Feasibility Study Draft Document (November 2007)); • Application for a consent under the Foreshore Act 1933 (as amended); and • Test of Likely Significance Screening Matrix and Supporting Information for Sheephaven SAC.

Whilst following the guidance listed in section 1.2 above, the impact assessment has been carried out according to the guidelines produced by the Chartered Institute of Ecology and Environmental Management (CIEEM):

• Guidelines for Ecological Impact Assessment in Britain and Ireland; Marine and Coastal (2010).

Donegal County Council C/O Doran Consulting March 2016 Proposed Beach Promenade, Downings; Natura Impact Statement (Informative)

3 PROJECT DESCRIPTION

3.1 Site and Surroundings

Downings is a seaside resort situated in North West Donegal located at the centre of the Rosguill peninsula at NQ 28122 03943. Downings is the peninsula’s main fishing village, with a pier situated on the western side of the beach ‘Trá Beg’, which serves as a popular recreational beach all year round. The beach and bay, both situated to the east of the Downings village, are surrounded by a golf course, hotels and a caravan park to the north (Figure 3.1).

Current access to the beach can be gained from three locations. The first access point is a road adjacent to the caravan park and car park north of the beach that allows vehicular access onto the beach approximately half way along it. The second access point is a disused and overgrown track that provides pedestrian access from the R248 road onto the beach adjacent to its western end. The third access point is via concrete steps leading off a designated picnic area adjacent to Downings Pier. These steps lead straight onto the beach; therefore access is not possible during high tide. Although the beach can be accessed via the overgrown track at all times, there is no connection between the beach, the caravan park and the pier at high tide. This is thought to have an economic effect on local businesses that depend on tourism.

Figure 3-1: Publically available aerial imagery identifying Downings village, pier, beach and caravan site

Donegal County Council C/O Doran Consulting March 2016 Proposed Beach Promenade, Downings; Natura Impact Statement (Informative)

3.2 Preferred Option

This project proposes the creation of a beach promenade which links the existing pier and caravan park. The location of the promenade is highlighted in red in Figure 3-2.

Figure 3-2: Proposed promenade location

3.2.1 Feasibility Study

A feasibility study was conducted in 2007 (The Downings Promenade Feasibility Study Draft Document (November 2007) hereafter referred to as the Draft Document). The scope of the study was to propose design options that would allow pedestrian access from the pier to the beach during all tidal conditions. This study included:

 A topographical/bathymetrical survey;  A desk study of local tide levels;  Preliminary evaluation of the wave climate for the proposed promenade site;  Geological desk study review; and  Design options (x5) based on the outcomes of the above bullet points.

3.2.2 Preferred Design

The preferred design for the proposed promenade is the ‘Alternative Revetment Walkway’ design (Design no. 5 in the Draft Document). This design entails the construction of a revetment around the boundary of the beach. From Point A (the existing steps) the path takes a straight route in a north west direction for approximately 20m and joins the cliff face. After this point the path follows the base of the cliff, terminating at Point B

Donegal County Council C/O Doran Consulting March 2016 Proposed Beach Promenade, Downings; Natura Impact Statement (Informative)

(adjacent to the life guard hut) (see Figure 3-3). The walkway would be meandering and approximately 180m long with a single handrail.

The level of the path would be raised from +2.50m OD Malin to +3.50m OD Malin to alleviate one of the predicted problems of waves overtopping and spray during stormy conditions. It is therefore anticipated that this path could be used at all times of the year, as opposed to only during calm sea conditions. The breakwater would be formed using rip rap armour with side slopes of 1:2 to reach the existing bed level. The rock armour would then extend 500mm below the existing beach levels to provide an adequate key for stability. Due to the increased elevation of the proposed path, the weight of rip rap armour would increase from approximately 1,300 tonnes to 3,200 tonnes.

The proposed design is anticipated to have a limited environmental impact on the beach. The rock armour has the potential to alter the reflection characteristics of the waves entering the area, which could lead to shifting of the adjacent sand. Vegetation along the cliff would need to be kept trim to avoid obstructing the path around the edge of the beach.

The proposed design (option 5) was selected over the four alternative design options (described below) based on the following:

 Option 5 could be used by the public at all times of the year, regardless of the wave conditions within the bay (this was not considered feasible for options 1, 2 and 4).  Option 5 would be approximately 15% cheaper to construct and entail less maintenance than the steel bridge structure proposed for option 3.  Option 5 offers public amenity in the form of picnic tables and benched along the route of the walk, the other four options do not include these facilities.

Donegal County Council C/O Doran Consulting March 2016 Proposed Beach Promenade, Downings; Natura Impact Statement (Informative)

Figure 3-3: ‘Alternative Revetment Walkway’ Promenade Design

3.2.3 Alternative Designs

The Draft Document identified four further possible promenade designs including:

 Option 1- Revetment Walkway. Similar to the preferred design, but with a narrower path (without seating) and a lower path level (+2.50m OD Malin instead of +3.50m).  Option 2- Breakwater Walkway. This option would entail the construction of a breakwater across the beach/tidal area from Point A to Point B. Approximately 2000m3 of rock armour would be formed from a base level 500mm below the existing bed level. A 150mm deep and 2000mm wide concrete path would be formed on top of the rock armour to allow pedestrian access during all tidal conditions.  Option 3- Jetty Footbridge. With the jetty footbridge option, a reinforced concrete pad foundation would be formed below the existing seabed level. Cross braced steel columns would be bolted onto the foundation to allow provision of a 2000mm wide steel pedestrian walkway. This walkway would pass directly from Point A to Point B across the tidal beach, with handrails at each side and street lighting providing functionality and decoration along the walkway.  Option 4- Floating Pontoon Walkway. A reinforced concrete pad foundation below seabed level with stainless steel columns cast into the pad foundation on both sides of the proposed walkway to act as guide rails for the pontoon. The pontoon would be formed using polystyrene floats encased on fibre reinforced concrete, with a galvanised steel frame anchored to the steel columns. The pontoon would rise and fall with the tide level. Chain rails could then be hung between the stainless steel columns to provide safety for the pedestrians using the walkway.

More information on the above designs can be found in the Draft Document.

Donegal County Council C/O Doran Consulting March 2016 Proposed Beach Promenade, Downings; Natura Impact Statement (Informative)

4 SHEEPHAVEN SAC

The proposed promenade development is located within the boundary of Sheephaven SAC. The SAC site boundary is shown in Figure 4.1 and a site synopsis is presented in the following sections.

Figure 4.1 Sheephaven SAC boundary at Downings Bay (hatched area within turquoise line)

4.1 Synopsis

Sheephaven Bay is a north-facing bay, situated north of Creeslough on the north-west coast of Co. Donegal. The site includes all of the inner part of the bay, and intertidal area of Carrickgart. The site contains a diverse range of habitats including mudflats, saltmarshes, sand dunes, to lakes, heath and woodland. The main rivers flowing into the site are the Lackagh River, Duntally River, Faymore River and the Carrownamaddy River. Extensive areas of intertidal sands and muds occur at the Back Strand, Ards Strand, Doo Castle Strand and at Carrickgart. Marble Hill Strand is a north-east facing beach on the west side of the bay. Large areas of sand dune occur at Rosapenna and at Marble Hill. Some areas of sand dune at Rosapenna have been damaged through agricultural improvement, and golf course development has also had an impact on the site. Downings Bay is situated at the northwest of Sheephaven Bay, north of Rosapenna and west of Carrickgart.

The site includes several areas of woodland. Creeslough Wood consists of a range of deciduous trees, such as oak (Quercus sp.), Holly (Ilex aquifolium) and Hazel (Corylus avellana), but Downy Birch (Betula pubescens) is also a common tree. Ards Forest Park includes areas of deciduous woodland and conifer plantation.

Donegal County Council C/O Doran Consulting March 2016 Proposed Beach Promenade, Downings; Natura Impact Statement (Informative)

The intertidal mud and sandflats support moderate numbers of waterfowl in autumn and winter. The site is of particular conservation significance for the presence of good examples of several habitats listed on Annex I of the E.U. Habitats Directive and for the important bird populations it supports.

4.1.1 Features of Interest

The Features of Interest of the site are as follows:

 1140 Tidal mudflats and sandflats;  1330 Atlantic salt meadows;  1410 Mediterranean salt meadows;  2120 Marram dunes (white dunes);  2130 Fixed dunes (grey dunes);  21A0 Machairs (*in Ireland);  91A0 Old oak woodlands; and  1395 Petalwort (Petalophyllum ralfsii).

(* priority habitats)

4.1.2 Conservation Objectives

The Conservation Objectives for Sheephaven SAC are to maintain the favourable conservation condition of the Features of Interest, defined by the list of attributes and targets presented in Table 4.1 below:

Table 4.1: Conservation Objectives for Sheephaven SAC Attribute Measure Target Mudflats and sandflats not covered by seawater at low tide Habitat area Hectares The permanent habitat area is stable or increasing, subject to natural processes Community distribution Hectares The following communities should be conserved in a natural condition: Sand to coarse sediment with Pygospio elegans community complex; Sand with Angulus tenuis community Atlantic salt meadows (Glauco-Puccinellietalia maritimae) Habitat area Hectares Area stable or increasing, subject to natural processes, including erosion and succession. For sub-sites mapped: Creeslough - 19.59ha; Rosapenna - 9.13ha Habitat distribution Occurrence No decline or change in habitat distribution, subject to natural processes Physical structure: Presence/ absence of Maintain natural circulation of sediments and sediment supply physical barriers organic matter, without any physical obstructions Physical structure: Occurrence Maintain creek and pan structure, subject to creeks and pans natural processes, including erosion and succession Physical structure: Hectares flooded; Maintain natural tidal regime flooding regime frequency Vegetation structure: Occurrence Maintain range of coastal habitats including zonation transitional zones, subject to natural processes including erosion and succession

Donegal County Council C/O Doran Consulting March 2016 Proposed Beach Promenade, Downings; Natura Impact Statement (Informative)

Attribute Measure Target Vegetation structure: Centimetres Maintain structural variation within sward vegetation height Vegetation structure: Percentage cover at a Maintain more than 90% area outside creeks vegetation cover representative number vegetated of monitoring stops Vegetation Percentage cover at a Maintain range of sub-communities with typical composition: representative sample species listed in SMP (McCorry and Ryle, 2009) typical species of monitoring stops and sub-communities Vegetation Hectares There is no record of common cordgrass (Spartina structure: anglica) in the SAC and its establishment should be negative indicator prevented species - Spartina anglica

Atlantic salt meadows Habitat area Hectares Area stable or increasing, subject to natural processes, including erosion and succession. For sub-sites mapped: Creeslough - 19.59ha; Rosapenna - 9.13ha Habitat distribution Occurrence No decline, subject to natural processes Physical structure: Presence/absence of Maintain natural circulation of sediments and sediment supply physical barriers organic matter, without any physical obstructions Physical structure: creeks Occurrence Maintain creek and pan structure, subject to and pans natural processes, including erosion and succession Physical structure: Hectares flooded; Maintain natural tidal regime flooding regime frequency Vegetation structure: Occurrence Maintain range of coastal habitats including zonation transitional zones, subject to natural processes including erosion and succession Vegetation structure: Centimetres Maintain structural variation within sward vegetation height Vegetation structure: Percentage cover at a Maintain more than 90% of area outside creeks vegetation cover representative sample of vegetated monitoring stops Vegetation composition: Percentage cover at a Maintain range of sub‐communities with typical species and sub‐ representative sample of characteristic species listed in Saltmarsh communities monitoring stops Monitoring Project Vegetation composition: Hectares There is no record of common cordgrass negative indicator species (Spartina anglica) in the SAC and its establishment ‐ Spartina anglica should be prevented Mediterranean salt meadows (Juncetalia maritimi) Habitat area Hectares Area stable or increasing, subject to natural processes, including erosion and succession. For sub-sites mapped: Creeslough - 5.75ha; Rosapenna - 3.92ha Habitat Occurrence No decline or change in habitat distribution, distribution subject to natural processes. Physical structure: Presence/absence of Maintain natural circulation of sediments and sediment supply physical barriers organic matter, without any physical obstructions

Donegal County Council C/O Doran Consulting March 2016 Proposed Beach Promenade, Downings; Natura Impact Statement (Informative)

Attribute Measure Target Physical structure: Occurrence Maintain creek and pan structure, subject to creeks and pans natural processes, including erosion and succession Physical structure: Hectares flooded; Maintain natural tidal regime flooding regime frequency Vegetation structure: Occurrence Maintain range of coastal habitats including zonation transitional zones, subject to natural processes including erosion and succession Vegetation structure: Centimetres Maintain structural variation in the sward vegetation height Vegetation structure: Percentage cover at a Maintain more than 90% of area outside creeks vegetation cover representative number vegetated of monitoring stops Vegetation Percentage cover at a Maintain range of sub-communities with composition: representative sample characteristic species listed in SMP (McCorry and typical species of monitoring stops Ryle, 2009) and sub-communities Vegetation structure: Hectares There is no record of common cordgrass negative indicator (Spartina anglica) in the SAC and its establishment species - Spartina should be prevented anglica Shifting dunes along the shoreline with Ammophila arenaria Habitat area Hectares Area stable or increasing, subject to natural processes including erosion and succession. For subsites mapped: Ards - 0.48ha; Marble Hill - 1.01ha; Rosapenna - 3.98ha. Habitat distribution Occurrence No decline, or change in habitat distribution, subject to natural processes. Physical structure: Presence/ absence of Maintain the natural circulation of sediment and functionality and physical barriers organic matter, without any physical obstructions sediment supply Vegetation structure: Occurrence Maintain the range of coastal habitats including zonation transitional zones, subject to natural processes including erosion and succession Vegetation composition: Percentage cover More than 95% of marram grass (Ammophila plant health of dune arenaria) and/or lyme grass (Leymus arenarius) grasses should be healthy (i.e. green plant parts above ground and flowering heads present) Vegetation composition: Percentage cover at a Maintain the presence of species-poor typical species and sub- representative number communities dominated by marram grass communities of monitoring stops (Ammophila arenaria) and/or lymegrass (Leymus arenarius) Vegetation composition: Percentage cover Negative indicator species (including non-natives) negative indicator to represent less than 5% cover species Fixed coastal dunes with herbaceous vegetation (grey dunes) Habitat area Hectares Area stable or increasing, subject to natural processes including erosion and succession. For subsites mapped: Ards - 11.14ha; Marble Hill - 31.02ha; Rosapenna - 215.74ha

Donegal County Council C/O Doran Consulting March 2016 Proposed Beach Promenade, Downings; Natura Impact Statement (Informative)

Attribute Measure Target Habitat distribution Occurrence No decline, or change in habitat distribution, subject to natural processes Physical structure: Presence/ absence of Maintain the natural circulation of sediment and functionality and physical barriers organic matter, without any physical obstructions sediment supply Vegetation structure: Occurrence Maintain the range of coastal habitats including zonation transitional zones, subject to natural processes including erosion and succession Vegetation structure: Percentage cover Bare ground should not exceed 10% of fixed dune bare ground habitat, subject to natural processes Vegetation structure: Centimetres Maintain structural variation within sward sward height Vegetation composition: Percentage cover at a Maintain range of sub-communities typical species and sub- representative number with typical species listed in Ryle et al. (2009) communities of monitoring stops Vegetation composition: Percentage cover Negative indicator species (including non-natives) negative indicator to represent less than 5% cover species Vegetation composition: Percentage cover No more than 5% cover or under control scrub/trees Machairs (* in Ireland) Habitat area Hectares Area stable or increasing, subject to natural processes including erosion and succession Habitat distribution Occurrence No decline, subject to natural processes Physical structure: Presence/ absence of Maintain the natural circulation of sediment and functionality and physical barriers organic matter, without any physical obstructions sediment supply Physical structure: Presence/ absence of Maintain natural hydrological regime hydrological and water abstraction or flooding regime drainage works Vegetation structure: Occurrence Maintain the range of coastal habitats including zonation transitional zones, subject to natural processes including erosion and succession Vegetation structure: Percentage cover Bare ground should not exceed 10% of machair bare ground habitat, subject to natural processes Vegetation structure: Centimeters Maintain structural variation within sward sward height Vegetation composition: Percentage cover at a Maintain range of sub-communities with typical typical species and sub- representative number species listed in Ryle et.al. (2009) communities of monitoring stops Vegetation composition: Percentage cover Negative indicator species (including non-natives) negative indicator species to represent less than 5%cover Vegetation composition: Percentage cover No more than 5% cover or under control scrub/trees Vegetation composition: Percentage cover Should always be at least an occasional component bryophytes of the vegetation

Old sessile oak woods with Ilex and Blechnum in the British Isles Habitat area Hectares Area stable or increasing, subject to natural processes, at least 4.1ha for sub-sites surveyed

Donegal County Council C/O Doran Consulting March 2016 Proposed Beach Promenade, Downings; Natura Impact Statement (Informative)

Attribute Measure Target Habitat distribution Occurrence No decline Woodland size Hectares Area stable or increasing. Where topographically possible, "large" woods at least 25ha in size and “small” woods at least 3ha in size Woodland structure: Percentage and metres Diverse structure with a relatively closed canopy cover and height containing mature trees; subcanopy layer with semi-mature trees and shrubs; and well-developed herb layer Woodland structure: Hectares Maintain diversity and extent of community types Community diversity and extent Woodland structure: Seedling: sapling: pole Seedlings, saplings and pole age-classes occur in natural regeneration ratio adequate proportions to ensure survival of woodland canopy Woodland structure: m³ per hectare; number At least 30m³/ha of fallen timber greater than dead wood per hectare 10cm diameter; 30 snags/ha; both categories should include stems greater than 40cm diameter Woodland structure: Number per hectare No decline veteran trees Woodland structure: Occurrence No decline indicators of local distinctiveness Vegetation composition: Percentage No decline. Native tree native tree cover cover not less than 95% Vegetation composition: Occurrence A variety of typical native species present, typical species depending on woodland type, including oak (Quercus petraea) and birch (Betula pubescens) Vegetation composition: Occurrence Negative indicator species, particularly non-native negative indicator invasive species, absent or under control species Petalwort Petalophyllum ralfsii Distribution of Number and No decline populations geographical spread of populations

Population size Number of individuals No decline. The population is estimated to be a maximum of 712 thalli. Actual population is more likely to be 50% of this, or c.356 thalli Area of suitable Hectares No decline. Area of suitable habitat at Rosepenna habitat is estimated at c.0.1080ha Hydrological Occurrence of damp soil Maintain hydrological conditions so that conditions: soil conditions substrate is kept moist and damp throughout the moisture year, but not subject to prolonged inundation by flooding in winter Vegetation: open Height and percentage Maintain open, low vegetation, with a high structure cover of vegetation percentage cover of bryophytes (small acrocarps and liverwort turf) and bare ground Source: NPWS, 2014

Donegal County Council C/O Doran Consulting March 2016 Proposed Beach Promenade, Downings; Natura Impact Statement (Informative)

5 IDENTIFICATION AND DESCRIPTION OF POTENTIAL IMPACTS TO SHEEPHAVEN SAC FEATURES OF INTEREST

5.1 Mudflats and sandflats not covered by seawater at low tide

Mudflats and sandflats not covered by seawater at low tide are located within Downings Bay, as shown in Figure 5.1 below. The protection offered by the headland and the pier means that the waves have reduced energy by the time they reach the beach. When these reduced-energy waves hit the promenade rip-rap there may well be localised scour and erosion at the toe. This sand will be redistributed along the beach but should not be of great volume.

The Angulus tenuis community is thought to be present within the sand at Downings Bay (Figure 5.2). The sediment requirements of the Angulus tenuis community comprises of largely mobile medium to fine sand (MERC, 2012). The animals are suspension feeders with a long extendable syphon, often found buried in the first 5-12 cm of sand in the middle of the bay to shallow sublittoral (Carter, 2005). Angulus tenuis can occur in very large populations, particularly near low water-mark, its numbers steadily decreasing up the beach, where the sands dry out at low tide and sand becomes more coarse (de Kluijver et al., undated). Abundance may reach a density of 3000 individuals per square metre (Barrett & Yonge, 1958).

The proposed development is confined to the north east, top edge of the bay in coarser sand, which will be dry at high tide, and few, if any, Angulus tenuis are expected to be present in this area. The redistribution of sand within the bay is not expected to be substantial post development, and Angulus tenuis can bury themselves to a 10cm depth between tides, thus they are unlikely to be smothered by a slight increase in sand volume, and are capable of moving if necessary. As Angulus tenuis communities often occur in large densities, the proposed development is unlikely to impact upon enough individuals to have a significant effect on the population.

Sand to coarse sediment with Pygospio elegans community complex is not found within Downings Bay. The nearest is approximately 2km south east of Downings Bay, separated by land just south of Carrikaholan. The closest communities connected by sea are approximately 3.5km south west of Downings Bay, at Creeslough.

The targets for habitat area and community distribution will continue to be met. It is not anticipated that the proposal will have any significant effect on the conservation objectives for this feature of interest.

Donegal County Council C/O Doran Consulting March 2016 Proposed Beach Promenade, Downings; Natura Impact Statement (Informative)

Figure 5-1: Sheephaven SAC location of mudflats and sandflats

Donegal County Council C/O Doran Consulting March 2016 Proposed Beach Promenade, Downings; Natura Impact Statement (Informative)

Figure 5-2: Sheephaven SAC distribution of community types

5.2 Atlantic salt meadows (Glauco-Puccinellietalia maritimae)

The location of Atlantic salt meadows is shown in Figure 5.3 below. The nearest is approximately 2.7 km south east of Downings Bay, separated by land just south of Carrikaholan. The closest Atlantic salt meadows connected by sea are approximately 8km south west of Downings Bay, at Creeslough. The targets for habitat area, distribution, physical structure, vegetation structure and vegetation composition will continue to be met, as the proposed development will occur in a confined area of Downings Bay. It is therefore not anticipated that the proposal will have a likely significant effect on the conservation objectives for this feature of interest.

Donegal County Council C/O Doran Consulting March 2016 Proposed Beach Promenade, Downings; Natura Impact Statement (Informative)

5.3 Mediterranean salt meadows (Juncetalia maritimi)

The location of Mediterranean salt meadows is shown in Figure 5.3 below. As with the Atlantic salt meadows, the nearest is approximately 2.7km south east, just south of Carrikaholan. The closest Atlantic salt meadows connected by sea are approximately 8km south west of Downings Bay, at Creeslough. The targets for habitat area, distribution, physical structure, vegetation structure and vegetation composition will continue to be met, as the proposed development will occur in a confined area of Downings Bay. It is therefore not anticipated that the proposal will have a likely significant effect on the conservation objectives for this feature of interest.

Figure 5-3: Sheephaven SAC location of Atlantic salt meadows and Mediterranean salt meadows

Donegal County Council C/O Doran Consulting March 2016 Proposed Beach Promenade, Downings; Natura Impact Statement (Informative)

5.4 Shifting dunes along the shoreline with Ammophila arenaria (white dunes)

The location of shifting sand dunes along the shoreline is shown in Figure 5.4 below (blue area), approximately 4km south, on the peninsular south of Tramore Strand. The targets for habitat area, distribution, physical structure, vegetation structure and vegetation composition will continue to be met, as the development of the promenade will be undertaken in a confined area of Downings Bay. It is therefore not anticipated that the proposal will have a likely significant effect on the conservation objectives for this feature of interest.

Figure 5-4: Sheephaven SAC location of white dunes

Donegal County Council C/O Doran Consulting March 2016 Proposed Beach Promenade, Downings; Natura Impact Statement (Informative)

5.5 Machairs (in Ireland)

The nearest machair habitat occurs as a small area on flat to gently undulating ground behind the dune system, to the north-west of Carrigart village, approximately 3.5km south east of the Downings promenade development site. Machair habitat comprises flat or gently undulating sandy plains, vegetation is herbaceous, with low frequency of sand-binding species (NPWS, 2014). The Draft Document contained a map of habitats identified within Downings Bay (Figure 5.5), and the area of the proposed development is dominated by ‘weedy grassland’ habitat, which is not machair. Any management of this grassland habitat associated with the promenade will not affect machair habitat. The proposal will not have a significant effect on the conservation objectives for this feature of interest.

Figure 5-5: Habitats identified at Downings Bay

5.6 Old sessile oak woods with Ilex and Blechnum in the British Isles

As the proposed promenade development is at sea, the proposal will not have any significant effect on this feature of interest of the SAC.

5.7 Petalwort Petalophyllum ralfsii

The only recorded location of petalwort is shown in Figure 5.6 below (yellow star), approximately 1600m SE of the promenade development area, at Rosepenna. Petalwort occurs in sparse low vegetation on pathways grazed by rabbits, short vegetation maintained by mowing, and in compact, damp sandy soil. The map within the Draft Document (Figure 5.5) highlights the proposed development area as being dominated by ‘weedy grassland’ habitat, which is not suitable for petalwort colonisation. It is therefore not anticipated that the proposal will have a likely significant effect on the conservation objectives for this feature of interest.

Donegal County Council C/O Doran Consulting March 2016 Proposed Beach Promenade, Downings; Natura Impact Statement (Informative)

Figure 5-6: Sheephaven SAC Petalwort distribution

Donegal County Council C/O Doran Consulting March 2016 Proposed Beach Promenade, Downings; Natura Impact Statement (Informative)

6 IN COMBINATION EFFECTS

No significant effects are predicted from the proposal on the qualifying interests of the Sheephaven SAC. No plans or programmes have been identified within the County Donegal Development Plan (2012-2018) that could contribute to an in-combination effect with the proposed promenade development. Therefore, it follows that there will be no in combination effects.

Donegal County Council C/O Doran Consulting March 2016 Proposed Beach Promenade, Downings; Natura Impact Statement (Informative)

7 CONCLUDING STATEMENT

It is a policy of the Regional Authority/Council to conserve and protect the ecological integrity of designated sites of international and national importance, and sites proposed for designation, in particular, European sites (including Natura 2000 sites), and Ramsar sites, Natural Heritage Areas and statutory nature reserves.

The integrity of a site is the coherence of its ecological structure and function, across its whole area that enables it to sustain the habitat, complex of habitats and/or the levels of populations for which it was classified (defined in the Habitats Directive).

The potential impacts of constructing a promenade at Downings Bay have been considered in the context of Sheephaven Natura 2000 site and its conservation objectives. The Precautionary Principle has been applied and this statement demonstrates objectively, with supporting evidence already submitted, that there will be no adverse effects on the integrity of the Natura 2000 site, either alone or in combination with other projects.

As noted in the NPWS guidance on undertaking an Appropriate Assessment:

“It is the responsibility of the proponent of the plan or project to have the NIS prepared for submission to the competent authority, i.e. the consenting authority. Having satisfied itself that the Statement is complete and objective, the competent authority carries out the AA on the basis of the Statement and any other necessary information”

Donegal County Council C/O Doran Consulting March 2016 Proposed Beach Promenade, Downings; Natura Impact Statement (Informative)

REFERENCES

Barrett, J. H., Yonge, C. M. (1958). Collins Pocket Guide to the Sea Shore. P. 161. Collins, London.

Campbell, C., Hodgetts, N. & Lockhart, N. (2015) Monitoring methods for Petalophyllum ralfsii (Wils.) Nees & Gottsche (Petalwort) in the Republic of Ireland. Irish Wildlife Manuals, No. 90. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht, Ireland.

Carter, M.C. 2005. Angulus tenuis Thin tellin. In Tyler-Walters H. and Hiscock K. (eds) Marine Life Information Network: Biology and Sensitivity Key Information Reviews, [on-line]. Plymouth: Marine Biological Association of the United Kingdom. Available from: http://www.marlin.ac.uk/species/detail/1957 (Accessed: 17/03/2016). de Kluijver, M.J., Ingalsuo, S.S. & de Bruyne, R.H. Mollusca of the North Sea. (World Wide Web)http://species identification.org/species.php?species_group=mollusca&id=969(Accessed 18/03/2016).

MERC (2012). Intertidal benthic survey of Sheephaven SAC. Carried out by MERC on behalf of National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht and the Marine Institute.

NPWS (2014) Conservation Objectives: Sheephaven SAC 001190. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.