Galway County Council
An Bord Pleanála
Inspector’s Report
File Reference: 07.JA0005
Local Authority: Galway County Council
Scheme: Costelloe Regional Water Supply Scheme, County Galway
Inspector: Daniel O’Connor
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TABLE OF CONTENTS
1.0 Introduction ------p 02
2.0 Proposed Development ------p 05
3.0 Impacts Identified ------p 06
4.0 Additional Information and Submissions received p 11
5.0 Assessment ------p 19
6.0 Recommendation ------p 25
Appendix 1 – Environmental Impact Statement -- p 27
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1.0 INTRODUCTION
1.1 The proposed Development is the provision of phase one of the original Costelloe Regional Water Supply Scheme which is referred to in the documentation as the Costelloe Regional Water Supply Scheme. The limitation and scope of the scheme and its assessment is referred to further below.
1.2 Galway County Council, by letter of 29th June 2007, applied for approval for the Costelloe Regional Water Supply Scheme under Section 175 of the Planning and Development Act,2000. An EIS was included with the application. The EIS was in three volumes as follows: · Volume 1 of 3 Non Technical Summary · Volume 2 of 3 Main Report · Volume 3 of 3 Appendices
All of the volumes are entitled Revision E. The Non-Technical Summary is produced in both the Irish and English languages.
Mar gheall ar an leagan Gaeilge don Achoimre Neamhtheicniúil leantar leis an gclár chéanna agus atá sa leagan Béarla ach go bhfuil na Pleananna, Learscáileanna agus Figúirí léirithe as Béarla amháin.
1.3 In a separate letter, also dated 29th June,2007 the Local Authority stated that notice was sent in accordance with Article 121 of the Planning and Development Regulations 2001 to the following prescribed bodies: · An Chomhairle Ealaíon · Fáilte Ireland · An Taisce – the National Trust for Ireland · The Minister for the Environment, Heritage and Local Government · The Heritage Council · Western Regional Fisheries Board · Minister for Communications, Marine and Natural Resources · Minister for Community, Rural and Gaeltacht Affairs · Údarás na Gaeltachta · Health Service Executive · National Parks and Wildlife Service- Galway City and Letterfrack offices
1.4 The proposed works as described in the newspaper advertisement comprise works at Glenicmurrin Lough and in the townlands of Derrykyle, Derrynea, Glencoh, Lettermuckoo, Muckanaghkillew and Lettermore. It is noted that Lettermore is covered by Phase 2 of the scheme. The description of works to be carried out in the newspaper advertisement include : · Gauging station · Regulating Weir · Intake Works and pumping station at Glenicmurrin
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· Water Treatment Works (at Cashla) · Treated Water Storage Reservoirs (Phase 1 includes Rosmuc(Glencoh) and Glenmore at Carroroe) · Access Roads · Pipelines to convey raw and treated water.
The proposed works follow on from a Water Abstraction Order made by Galway County Council in 1975 which was confirmed by the Minister for the Environment and came into force on 26th January 1979. The amount of water permitted to be abstracted was 3,640 cubic metres per day.
1.5 The development is sub-threshold but based on the information submitted by the Local Authority in relation to environmental impacts and the designation of part of the site as a Special Area of Conservation (SAC), An Bord Pleanála directed that an EIS be prepared for the scheme. There are two cSAC’s impacted by the scheme, namely the Connemara Bog Complex, (area 49,010 hectares, site code 2034 ) and Kilkieran Bay and Islands (area 21,314 hectares, site code 2111). The location of the SAC’s is indicated in Figure 3.10 of the Non Technical Summary of the EIS. The two SAC’s join at several locations and the Connemara Bog Complex SAC effectively surrounds Kilkieran Bay and Islands SAC. The site synopsis for the two SAC’s are included in Appendix 3 of the Scoping Report included in the documentation with the application.
1.6 Nine objections were received to the proposal and two submissions were received from prescribed bodies in the time specified for submissions.
1.7 Additional information was requested by the Board on 24th September in relation to phasing of the scheme, predicted water levels in Glenicmurrin Lough and other issues and this information was submitted by Galway County Council by letter dated 18th October 2007. In accordance with Section 175 (5) (c ) of the Planning Act Galway County Council prepared a further information report which was made available to the public and also issued the further information to the prescribed bodies.
1.8 Submissions were received in relation to the further information by the Western Regional Fisheries Board, the Costello & Fermoyle Fisheries Company and the Department of Environment, Heritage and Local Government.
1.9 On 22nd November 2007, the Board requested information in relation to water quality parameters in Glenicmurrin Lough and in relation to the likely sludge quantities arising at the Water Treatment Plant and the Local Authority response to that request was received on 13th December 2007.
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2.0 PROPOSED DEVELOPMENT
2.1 The proposed works comprise the following: · Gauging Station at the north of Glenicmurrin Lough · Regulating weir (at south of lough) to replace existing weir · Intake works and pumping station at weir site · Raw water rising main to treatment works at Cashla · Water treatment works at Cashla · New watermain network (in phases) · Reservoir at Glenmore (Carroroe) · Reservoir at Glencoh (Rosmuc) · Access roads and ancillary works · Reservoir at Lettermore (phase 2 work)
2.2 The proposal is for a water treatment plant to treat 3,600 m3/d at Cashla (Section 3.2.4 EIS). This is described as phase 1 works and on page 36 of the EIS the phase 1 supply area is defined as comprising the areas of Carraroe, Camus / Screebe and Rosmuc. The areas of Tir an Fhia (including Lettermore) and Gorumna / Lettermullan are not included in Phase 1 works. While it is clear from the documentation submitted that the proposed abstraction level covers only the Phase 1 area, reference is made throughout the EIS to the network serving Lettermore and Gorumna and the reservoir proposed at Lettermore. It is noted also that Drawing 3.6B in the EIS indicates future (phase 2) settlement tanks and filters at the Water Treatment Plant site.
The extent of the scheme being reported on is the works included in Phase 1. The rationale for this conclusion is given in the Assessment chapter (Section 5.2 , pages 19/20 below).
2.3 The abstraction works at Glenicmurrin are set out in Section 3 of the EIS and the impact on water levels and the area of land covered at the different levels was detailed by the Local Authority in the additional information submitted on 2nd November 2007. The proposals for Glenicmurrin Lough include a gauging station at the inlet to the works and a regulating weir and pumping station at its outlet on the Cashla river. It is noted that provision has been made in the intake sump design for a future pump.
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3.0 IMPACTS IDENTIFIED
The EIS sets out the need for the scheme, the scheme description and the alternatives considered before proceeding to examine the individual impacts of the chosen scheme. Appendix 1 of this report gives a more detailed summary of the EIS and the impacts identified.
3.1 Regarding the Need for the Scheme it is noted that the history of the scheme dates back to the early 1970’s. The first Water Abstraction Order was proposed in 1975 and the current Water Abstraction Order for 3640 m3/d dates from January 1979.
The EIS particularly notes the lodging of a petition to the EU in relation to the current Carraroe supply and the need to establish a reliable and clean source of water and notes also that the Galway Rural Water Strategic Plan identified Carraroe, Sceim na nOileán and Camus as having unsatisfactory treated water.
Apart from the stated unsatisfactory nature of some supplies, the need for the scheme is based on population predictions which indicate that if Tir an Fhia (includes Lettermore) and Gorumna are excluded the abstraction order for 3640 m3/d is satisfactory for a design year of 2024. It states that the excluded area may be connected to the scheme in the future and also that the need to develop beyond 3600m3/d would depend on the extent to which demand grows, the need to extend the scheme and the location of the boundary between the Costelloe and Spiddal schemes. (p36, EIS)
3.2 Alternatives :- With regard to Alternatives, the EIS comprehensively examines alternative sources for the supply locally both outside and within the cSAC in addition to remote sites and desalination.
In relation to local sources outside the cSAC, Laughaunwillan, the current source for Carraroe is stated to have an abstraction of 1580 m3 /d against a rated abstraction of 1364 m3/d and has a sewer running at its south-eastern corner which is slightly below top water level. The EIS discounts this source on the basis of low public confidence, the results of a cryptosporidium risk assessment and on lack of capacity to serve either the Costelloe or Carraroe supply areas. Lack of capacity and an impractical level of impoundment is stated to eliminate Lough Hibbert on Gorumna Island, Lough Aroolagh at Rosmuc and Lough Nambroughania at Lettermuckoo.
Sources within the cSAC include the chosen option of Glenicmurrin and Loughs Cloonadoon and Muckanagh. The comparison is made in the EIS between the area of each lake and the height of the required impoundment . It notes that Lough Muckanagh is 7% of the area of Glenicmurrin and that Lough Cloonadoon would not have the capacity to provide water for the phase 1 requirements of the scheme. Both sources are rejected in the EIS.
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Lough Corrib is considered as a remote source but is 30 kms distant and would involve expensive pumping. It notes the requirement to construct a trunk main through the cSAC. Desalination is described on page 46 of the EIS. It is discounted on the basis of operational costs and likely high CO2 emissions. The EIS also draws attention in relation to the chosen option of Glenicmurrin to the formal agreement in relation to the Water Abstraction Order dating from 1979.
Four alternatives are examined in relation to the location of the Water Treatment Plant. Options 1 and 2 are at Derrykyle and were the original location considered in the earlier scheme design. These sites are at high level and levels of 99 metres OD are referred to. The sites are in the cSAC which had not been designated in the 1970’s. Option 3 is outside the cSAC to the west of Glenicmurrin Lough but would require a water tower to achieve the top water level set. Option 4 is the chosen site in Cashla adjacent to the industrial estate and as stated in the EIS required a re-design of the scheme as the top level quoted is 13 metres OD and would therefore involve pumping of the treated water to all the service reservoirs. The EIS compares the sites on ecological and visual impact grounds but does not refer to on-going operational costs. Neither does the EIS refer to the benefits or otherwise of the water pressure differences between Options 1 to 3 and Option 4.
Three alternatives are considered for the intake works and pumping station and the chosen site is stated to have negative landscape impacts but would be extremely localised and contained within the steep banks of the river. The gauging station is located at the entrance to the lake and its location is dictated by hydraulic factors. The regulating weir is stated to be at the most appropriate location at the outlet of the lake.
3.3 Water Quality: The EIS predicts that in operation there would be no foreseeable water quality issues arising. It lists a number of mitigation measures relating to construction which comprise careful management, consultation with relevant bodies and scheduling of works. As the regulating weir would require maintenance, the EIS states that dredging of settled material could be involved. It states that build up of materials near the intake would not be expected to be a significant problem.
3.4 Hydrology: The EIS notes particularly the modelling which was carried out for the proposed abstraction of 3,600 m3/d and that a minimum compensation flow of 0.15m3/sec could be guaranteed throughout the year. The level of compensation flow for a range of flows is set out for different situations. The detailed Source Assessment in Appendix 2 of the EIS notes that the lowest recorded flow in the Cashla river on 28th August 1974 is two-thirds of the minimum compensation flow proposed. The impacts predicted are that there would be less attenuation for summer floods and water would cover slightly more land in summer than without the weir. It states that the Phase 1 abstraction would be approximately 2% of the median flow and that this
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would be a permanent slight positive impact as it would provide extra attenuation for winter flows.
The prediction is that the lake levels would remain within the current and natural range of variation of levels on the lake and that during very dry spells the compensation flow would be greater than that which would otherwise occur. This section of the EIS refers also to the proposed fish pass which it refers to as a permanent noticeable neutral impact.
3.5 Flora and Fauna: The EIS has an extensive section on flora and fauna and notes that 10 relevant bodies were consulted in the preparation of that section. It lists numerous surveys which were undertaken and refers to both aquatic and terrestrial flora and fauna.
Glenicmurrin Lough is described as being a nutrient poor acidic oligotrophic lake and would be directly affected by the proposed intake and regulating weir. The EIS deals extensively with the fish species including Arctic Char, Atlantic Salmon and Sea Trout as well as Eels. A major potential impact which is identified relates to spawning and the effectiveness of the proposed fish pass. The EIS describes the proposed fish pass as being of the pool type and would be approved by DCMNR.
( Note that as per SI 707 of 2007, a range of functions were transferred from the Minister for Communications, Marine and Natural Resources to the Minister for Agriculture,Fisheries and Food effective from 19/10/2007. The EIS was published prior to that date so all references to DCMNR should relate to the Department of Agriculture and Food).
It states that specific monitoring would be carried out over a three year period and that the fish pass would be suitable for eels. The use of controlled discharges to encourage passage of fish is also set out in the EIS, as is the requirement that there would be no flow control during the winter period.
The EIS notes that the combined area of works is 1.97 hectares of the total combined cSAC area of 70,324 hectares. (Connemara Bog complex is 49,010 hectares and Kilkieran Bay and Islands cSAC is 21,314 hectares). It notes that none of the nine listed legally protected plant species were found during the survey. In relation to terrestrial habitats, the EIS refers to 32 different habitat types and notes that much of the blanket bog / heath is in commonage and subject to grazing pressure. The EIS states that the impact on terrestrial habitats would be imperceptible with suitable mitigation.
The location of Rosmuc reservoir is noted as having been moved slightly to avoid juniper heath. In relation to the regulating weir and intake works the prediction is that vegetation would recover within two seasons.
The EIS states that residual impacts on aquatic ecology would be slight negative for the Connemara Bog complex cSAC and the impact on salmonid spawning would be either none or imperceptible negative.
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The mitigation measures proposed generally refer to site management issues and the compensation flow volumes are also listed, as is the fish pass, which is to be approved by the WRFB and the engineering section of DCMNR* (see note in italics is paragraph 3.5 above). The EIS also states that restoration of peat areas would be covered by a method statement agreed in advance with the NPWS.
3.6 Human Beings: From a public health perspective, the EIS notes the provisions of EC Drinking Water Regulations and notes new provisions on monitoring and the enhanced role of the EPA. It notes also exceedances for iron , manganese and coliforms in the various existing supplies including Carraroe, Rosmuc and Camus / Screebe as well as some supplies outside the proposed phase 1 area. It also refers to the Cryptosporidium Risk Assessments carried out. It is noted that these risk assessments take account of both the risk to the source and the available treatment process and concludes that while Carraroe has a high risk and Rosmuc a moderate risk, with the proposed treatment plant in place, the risk from Glenicmurrin is in the low risk category. The EIS recommends that regular surface water monitoring would be undertaken for the new source.
With regard to socio-economic impacts on human beings the impact is predicted to be positive with some direct negative impacts during construction.
3.7 Noise: Predicted noise levels during construction for dwellings adjacent to specific sites range between 52.9 and 62 dB LAeq 1 hr. A 2-metre acoustic barrier is recommended during the construction of the treatment works. In the operational phase the EIS predicts noise emissions at the treatment plant site boundary of less than 45 dB(A).
3.8 Landscape and Visual: The EIS notes that the assessment is based on a general understanding of the project rather than a detailed design as the scheme procurement is by design, build and operate method. The prediction in the EIS is that the dam / intake works would have a direct impact but was constrained by the adjoining topography such that it would not have any significant impact on the wider area. The choice of site for the treatment plant adjacent to an industrial estate in Cashla is away from sensitive areas and mitigation by planting and mounding is proposed.
It is noted that of necessity, reservoirs are on elevated ground. The EIS states that as a result they can be difficult to screen but refers to the possibility of mounding and using circular plan form to soften the profile of the tank at Glenmore. The Rosmuc reservoir is predicted to have moderate / negative impacts on landscape character and on views from a 2-kilometre radius.
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3.9 Cultural Heritage: In addition to referring to cartographic and other available data, it is noted that a field survey was carried out covering both underwater and terrestrial aspects. It notes the existing derilict lock and weir at the intake works site which are described as modern in construction. It notes that the topsoil depth is particularly shallow and therefore that archaeological deposits below one metre are unlikely. Mitigation measures include regular inspections and supervision of excavations by a suitably qualified archaeologist. The EIS lists the RMP sites and other features where specific attention and care is required during construction.
3.10 Soils – Geology : The receiving environment is noted as having shallow soils. It notes that due to artificial drainage channels in the past the drainage system was altered. Water quality indicated consistently good quality surface water based on monitoring results from 1986 to 2003. Mitigation measures relate to excavation and storage of 2,800 m3 of peat arising from construction and the avoidance of pollution from sediments. An impact predicted is the alteration of the landform following the treatment works construction. The EIS predicts that there would be no short to long-term impacts outside the site boundary.
3.11 Other impacts, Interactions & Conclusions of EIS: Traffic impacts are described in the EIS with the main impact being the potential damage to local roads during construction. A provision is recommended in the EIS for inclusion in the construction contract to cover necessary repairs.
Interactions are noted in the EIS, with the relationship between water quality and flora and fauna being highlighted.
The EIS concludes that the extent of works in the cSAC is limited and is close to it’s boundary and involves less than 2 hectares out of 70,000 if both SAC’s are taken into account. The impact on the aquatic system of the Connemara Bog Complex cSAC is predicted as slight negative after mitigation and on terrestrial habitats as imperceptible negative.
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4.0 ADDITIONAL INFORMATION AND SUBMISSIONS
The Board requested further information on 24th September and 22nd November 2007 and required that the information submitted on foot of the first request be subject of a notice under Section 175 of the Planning and Development Act. Submissions were received from Prescribed Bodies arising from the publication of the EIS and also following the issue of the notice regarding the additional information
4.1 Additional Information
By letter of 24th September 2007, the Board requested additional information from Galway County Council in respect of the following:
· Map showing extent of lake in winter and summer · Details of proposed phasing and extent of the works · Additional information on Loughaunwillan source · PPP assessment report · Water Abstraction Orders · Updated report of EU Committee on Petitions · Clarification on Galway Rural Water Strategic Plan
Galway County Council replied by letter of 11th October 2007band enclosed information as follows: 1. Details of extent of the differences in area covered (Figure 4.20, issue A) This drawing indicates the extent of water coverage at maximum and minimum recorded levels and at the top and bottom of the control band. This indicates (scaling drawing) that to the east of the lough, a horizontal difference of 40 metres separates the bottom from the top of the control band, while at the north west of the lough the horizontal difference is 7 metres. Generally the horizontal difference is of the order of 7 metres with a lesser difference in many parts of the lake.
2. The Local Authority confirmed that Carraroe, Rosmuc and Camus comprise phase 1 and that the pipeline for phase 2 has been included in the EIS for reasons of economy and efficiency as it may be possible to serve that area without increase in abstraction beyond 3,600 m3/d
3. Loughaunwillan supply is stated to lack hydraulic capacity, has a very high cryptosporidium risk and is the subject of a petition to the EU Commission
4. A copy of the PPP assessment report was submitted.
5. Copies of Water Abstraction Order notices were submitted
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6. Updated Report of Committee on Petitions was submitted
7. Clarification was given that Gorumna GWS is not included in the Costelloe RWSS.
8. The Local Authority also gave responses under 152 references to submissions made by prescribed bodies and third parties
The Board wrote to the Local Authority on 23rd October 2007 requiring Galway County Council to publish a notice under Section 175 of the Planning and Development Act advising the public of the additional information and setting a period of 3 weeks for submissions. By letter of 2nd November, Galway County Council submitted a booklet which included the information in points 1 to 8 above and also a response to a submission from DoEHLG regarding archaeology which had been received by the Board on 22nd October 2007.
The Board requested further additional information in respect of water quality and process types proposed by letter of 22nd November 2007 and this information was submitted by the Council by letter of 11th December 2007. It was not considered necessary that this information should be subject of a notice under Section 175 of the Planning and Development Act.
4.2 Submissions Received
Submissions are described from both third parties and prescribed bodies as follows with third parties taken first:
4.2.1 Submission of Mary Conneely – Costello: (tabbed Sub 01) This submission states that the scheme would flood Ms Conneelly-Costello’s Land at the south side of Glenicmurrin Lake and would affect the environment.
4.2.2 Submission on behalf of John Costello by Seán Costello & Co. solicitors dated 11the July 2007. (tabbed Sub 02) This makes a number of points including lack of consideration of alternatives, flooding concerns, lack of concern for local persons’ livelihood, impact on nesting areas and concerns regarding commercial issues.
Regarding environmental impacts, it is submitted that the highest water level recorded was in a flash flood with a sluice closed. It disputes the ability to manage the volume generated in a flood and states that numerous small islands would be flooded and high banks suitable for foxes and badgers would now not be present due to the high water level.
Regarding commercial concerns, the submission notes that the formal agreement with the fishery company was made on 3rd July 1978 and Camus hatcheries were authorised by the Local Authority to abstract 4320 m3/d in 1986. It is submitted that Galway County Council have been extremely generous and attentive to commercial concerns at the expense of landowners.
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It is submitted that there are many viable alternatives to Glenicmurrin Lough as a source.
Photographs (listed 1-8, attached to the submission) are stated to indicate flooding and land erosion in 2004 and 2005. It is submitted that in respect of water levels on 30th September 2004, that all visible land indicated on photographs 3 and 4 would be submerged if the proposed levels were reached. It is submitted that the maximum level should not be anywhere near 29.27 m OD and it would not be factual to state that the impact would be minor and confined to the lake edge.
4.2.3 Submission by Owen Jacob, Lower Glenageary Road, Co Dublin received on 30th July 2007 (tabbed Sub 03) which raised issues regarding impact on fisheries and the adequacy of the proposed fish pass.
The submission notes the role of the Costelloe and Fermoyle Fishery and notes the Annex II status of Salmon and the importance of seat trout in the Red Data Book. It states that the raising of the water level behind a dam would impact on numerous sea trout and salmon spawning and nursery streams flowing into Glenicmurrin.
4.2.4 Submission by Rob Graham of 74 Whitebeam Road, Clonskeagh, Dublin received 10th August 2007. (tabbed Sub 04). This submission states that the project is not in the best interests of Ireland or Europe and the site is a natural asset which has been well looked after by local people. Mr Graham states that the idea smacks of short term thinking which will damage the area permanently
4.2.5 Submission by Owen Jacob / Robert Haughton , Dublin, received 16th August 2007. (tabbed sub 05) This submission raised objections based on the threat posed to spawning of Atlantic Salmon and Sea Trout. It states that there are no imperative or overriding reasons of public interest which would justify the scheme in the particular habitat. It submits that Galway County Council documentation envisages a 6,000m3/d abstraction. (Reference to 6,000 m3/d in Scoping Report of October 2005, page 1)
In relation to Sea Trout the submission states that other sea trout fisheries have been wiped out in the last 20 years and it puts forward reasons why the Costello and Fermoyle fishery has escaped destruction including: · No salmon aquaculture within 20 kms of Cashla River outflow · Annual raking of spawning beds in streams feeding the Lough · Wild sea trout partly maintained by rearing of fingerling seatrout. · Not overfished · Counting of fish movements and catches. · Conservation measures of ‘catch and release’
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Referring to the Habitats Directive, the submission states that raising the level of Glenicmurrin would completely alter the spawning streams, particularly on the eastern side of the lake.
It is also submitted that the height of the top of the dam above high or low water level is not specified. It is also submitted that the Abstraction Order was made at a time of less consideration of the environmental impact of water abstraction and that a fresh order would now be required if approval were obtained and that this makes the existence of the order irrelevant.
It is submitted that it is alarming that no design details are given of the proposed fish pass, given its critical importance to the scheme and no indication is given as to the expertise of the fish pass designers. The submission also refers to the possibility of an exceptionally dry period which would force the use of “stored” water being used and it would only take one very dry season in which the fish did not reach the spawning beds to substantially destroy the fishery.
The submission refers to the alternatives of Loughs Corrib, Screebe, Cloonadoon and Muchanagh and expresses concern at the building of a permanent access road to the dam.
4.2.6 Submission of Geoffrey HT Fitzjohn, Derrough Cottage, Costelloe, County Galway, received on 17th August 2007. (tabbed sub 06) Mr Fitzjohn states he has lived permanently in Cashla since 1979 and is a minor shareholder in Comhlacht Iascaireacht Casla agus Faoirmeola and a regular angler. He notes the history of sluices and small dams used for fishery purposes in the past and notes the experience of the hatchery downstream of the Lough. In relation to maintenance of flows he questions the level of consultation which will be afforded by the Local Authority to WRFB and states that we are heading into uncharted territory.
Mr Fitzjohn states that salmon do spawn in the main river, contrary to suggestions in the EIS. He states that if the survey is done at low flows, young salmonids will migrate to deeper pools in dry periods. He stresses the need for a fully functioning fish pass with video camera and personnel fencing. Mr Fitzjohn says higher lake levels will prejudice the fishing dynamic in the lake. He states that if the sea trout had not collapsed over the last number of years rod angling would not have focussed more towards the main river. Mr Fitzjohn submits that an annual fund of €150,000 should be set aside as an environmental cost of the scheme. He also submits that the water supply should be sourced from the Corrib.
4.2.7 Submission of Jean-Pierre Maire / Nicola Stronach of Fermoyle Lodge, Costello, Co Galway received on 17th August 2007. (tabbed sub 07) This submission states that while there is an ever increasing need for water in the area, it would be extremely short-sighted to dam what is a pristine river. The submission states that the SAC has been given a special extension as a Spate System with excellent spawning potential for salmonids based on Annex 3 of
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the Habitats Directive and that it would no longer be so if a dam is built. The submission refers to the SAC being home to Greenland White- Fronted Geese, Hen Harrier, Merlin, Red Grouse and Golden Plover which are all listed in Annex 1 of the Birds directive. It is submitted that raised water levels would constitute unfavourable conditions and result in flock declines and extinctions.
The submission considers that Galway County Council has failed to protect valuable water sources in the region, such as Loughaunwillan and Lough Corrib. It is submitted that Galway County Council are looking for an immediate solution to the problem of a sub standard water source rather than taking a long term sustainable view. The submission concludes by suggesting that a sustainable alternative water source be sought elsewhere.
4.2.8 Submission of Trevor F Nind, Hillsborough House, Boat Lane, Hoveringham, Notts, United Kingdom, received on 16th August 2007.(tabbed sub 08). Mr Nind states he heard of the proposal from the manager of the Costello and Fermoyle Fishery and has fished the system for 10 years. He submits that the proposal would unbalance the river’s natural ability to let fish pass to its upper system. He requests that the fishery not be allowed go the same route as many others in past years.
4.2.9 Submission of Mr Terry Gallagher, Fishery Manager Costello and Fermoyle Fisheries, received on 16th August, 2007. (tabbed sub 09) Mr Gallagher states that the Costello and Fermoyle Fishery is the last of the viable sea trout and salmon fisheries on the south coast of Connemara. He states the NPWS have extended the SAC on the basis of its importance as a salmonid system, with reference to Annex III of the Directive. He states the NPWS are submitting the extension to the EU Commission. If the development goes ahead, he states the spate nature of the fishery would be altered with disastrous effect on the ecology of the fishery.
The submission states that the Atlantic Salmon is an Annex II species under the Habitats Directive and the Sea Trout is listed as an important species in the Red Data book. He states that salmon and sea trout run into the Casla in the period when water is to be held back and this is also the time for smolts to descend from the system. He submits that there are numerous examples of where fish will not use fish passes.
Mr Gallagher points out that the current regulating sluice has not been operating for at least 10 years and also that it is partial sluice as it does not traverse the entire width of the river. He also notes the largest run of salmon for 10 years occurred in 2007 which he links with the ban on commercial drift netting. He states that when the water abstraction agreement was made in 1979, salmonid populations were far healthier.
Mr Gallager concludes by stating that it is the wish of the owners and management that the extraction scheme proposal should not go ahead.
4.2.10 Submission by Western Regional Fisheries Board, received 13th August 2007. (tabbed PB1) The submission focuses on concerns regarding the
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migration of fish and the operational effectiveness of the proposed fish pass. It raised issues regarding the Water Abstraction Order including the need for digital mapping of the Char population and other issues.
It states that the WRFB has serious concerns arising from the SAC designation which supports Salmon and Arctic Char. It states the scheme gave priority to abstraction over and above ecological and fisheries interests and notes the impoundment period is when fish are more vulnerable. It notes most impoundments involve winter storage.
The submission is for specific attention to a number of parameters namely: · Maximum level of abstraction · Range of levels · Minimum compensation flow · Real time system to monitor flows and levels · System for integration of hydrometric data with fish migration data. · Consultation mechanisms regarding vulnerable times for spawning · Flow regime to maintain flow levels to facilitate upstream migration · Notification of fishery interests regarding system failures. · Leakage detection system required · Distribution pipeline be sized to restrict scheme to phase 1. · Discharge of Alum from water treatment plant not to be permitted to aquatic environment · Digital mapping of char spawning sites and mapping of salmon spawning to be carried out prior to construction · Fish surveillance should be for the life time of the project rather than for 3 years.
In relation to the operation of the regulating weir, the WRFB submits that while compensation flow could exceed lowest recorded flow more would be required to induce fish into the river and a SCADA system is required, and the existence of an electronic system for recording fish migration is noted.
WRFB state that protocols should be agreed regarding the operation of the regulating weir. The submission also notes the importance of water conservation. It also submits that the contractor should liaise with the WRFB in relation to the timing of works including pipelines.
The WRFB express concern over the level of alum discharges from exiting treatment works and also over washwaters, filtrated waters and water from dewatering of sludge. The WRFB urges that a professional hydrologist would critically review the hydrometric basis and flow simulation model underpinning the project.
4.2.11 Submission of Department of Environment, Heritage and Local Government received on 20th August 2007. This submission was made by the Development Applications Unit and is tabbed PB2 and covers Archaeological, Architectural and Nature Conservation Recommendations.
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The DoEHLG recommended that an Archaeological Impact Assessment be carried out. The Local Authority report of 22nd October was submitted in response and this is discussed in paragraph 4.2.12 below.
The recommendations in relation to Architectural Heritage in this submission note that no schedule of structures which would be of architectural heritage merit along the route had been included in the EIS.
In relation to Nature Conservation the submission is that there is a need to have a suitably qualified ecologist employed at project start up who would review all method statements. A specific method statement is required for the works proposed to be undertaken at the regulating weir site.
Mitigation measures are required to prevent invasive non-native plant and aquatic species and the DoEHLG require a final ecological audit report when woks are completed at each location within the cSAC’s.
4.2.12 Response of Galway County Council to the submission of DoEHLG of 17th August was received by the Board on 22nd October 2007. The cover letter notes that the report of the Moore Group should be read in conjunction with Chapter 12 of the EIS and notes that the response to the Nature Conservation recommendations was contained in the report of 11th October 2007.
The Moore Group Report contains 14 figures giving the location of RMP sites which are close or reasonably close to locations at which construction is planned. These include photographs which indicate the locations of the RMP sites relative to Rosmuc Reservoir, the Water Treatment Works site, a section of pipeline and Glenmore Reservoir. It also refers to Lettermore Reservoir site which not in the Phase 1 supply area.
In addition to the submissions made regarding the EIS, there were three further submissions made in response to the publication of additional information as per the provisions of the notice issued under Section 175 of the Planning and Development Act. These submissions were:
4.2.13 Submission by WRFB on additional information received 26th November 2007. This submission commences by putting forward the contention that Article 6.3 / 6.4 of the Habitats Directive would need to be invoked because of the impact on an Annex II species within the SAC. The submission makes 14 individual observations based on the additional information submitted by the Local Authority on 5th November. It concludes that a compensation flow of 0.32 m3/ sec is warranted in this instance It questions the choice of 0.6 metres for the regulating weir and queries if a sudden drop from say 0.5 to the minimum 0.15 m3/sec would leave fish stranded.
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4.2.14 Submission on additional information by Mr Terry Gallagher on behalf of Costello and Fermoyle Fisheries received on 23rd November 2007. This submission did not accept that Galway County Council had carried out a detailed survey of Loughaunwillan (existing Carraroe source) or that a concerted effort had been made to improve the water quality there. It also disputed the inference that the EU petitions committee had sought an alternative source (to Loughaunwillan) to be developed. The submission concludes by stating that one of their greatest concerns had not been addressed namely that water would be extracted when salmonids migrate into and out of the fishery.
4.2.15 Submission by DoEHLG received 29th November 2007. The submission / observations note the large scale of the project and that sub-surface archaeological remains could be encountered. It recommends that Archaeological Monitoring should be undertaken and should consist of:-
· Engagement of a suitably qualified archaeologist to monitor all topsoil stripping. · Work to be stopped if archaeological material found pending a decision on how best to deal with the archaeology. · A report on the results to be submitted to the Heritage and Planning Division of DoEHLG.
In relation to architectural heritage, the submission expresses the view that while there may be little of architectural merit within the vicinity of the sites the impact should be documented in the EIS.
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5.0 ASSESSMENT
This assessment follows the format of Section 3.0 of this report above, considering the Need for the Scheme, alternatives and the specific and interacting impacts identified, having regard also to the additional information and submissions received.
5.1 It is considered that the need for the scheme is well established. The current reliance on a number of small sources and the lack of any obvious standby arrangements is clearly unsatisfactory. As the EIS deals with the population projections and the proposed extent of the scheme in the same section of the EIS this is also assessed at this stage.
It is considered that while the Carraroe supply area has been the subject of very unfavourable mention in EU petitions reports, the abandonment of Loughaunwillan as a source need not be deemed to be implied from these reports. In this regard the contention of Costello and Fermoyle Fisheries is accepted and it is considered that the approach of the Local Authority to this source should be to seek to achieve the overall target of “good quality” which is the overall objective in the Water Framework Directive.
While the objective and policy should be to improve the water quality of Loughaunwillan, the capacity of the source would appear to be insufficient to avoid the need to develop Glenicmurrin as a source. It could however have a role to play in dealing with what is termed phase 2 requirements of the scheme.
5.2 In relation to the definition of the extent of the scheme and the description of phase 1 and phase 2, the EIS appears to be unclear in relation to the definition of the scheme. The statement on page 36 of the EIS is taken as indicating that the abstraction sought is for 3,640 m3/d, and this figure (or 3600 m3/d) is supported by projections for the phase 1 areas for 2024. However the statement that areas not served by phase 1 “may be connected to scheme in the future” appears to indicate that this could happen if it proved possible to do so without increasing the abstraction, a scenario (i.e. increasing the abstraction) which it is acknowledged to require a further EIS to be prepared.
This is further elaborated upon in item 2 (page 3) of the Local Authority response dated 11th October 2007. In that response it states that pipelines had been included for phase 2 for reasons of economy and efficiency as it may be possible to serve that area without an increase in abstraction. In that response it also states that should it be required to expand headworks beyond 3,600 m3/d the appropriate consents, including an EIS if required would be obtained.
Based on the above considerations, it does not appear to be logical to proceed with works (pipelines and reservoirs) outside the specified phase 1 areas on the basis that the combined demands could exceed the 3,600 m3/d distribution input which has been calculated to be appropriate for the phase 1 supply area. The EIS clearly indicates in table 3.4 (p36) that a distribution input for the whole area of 4,013 m3/d is required. In arriving at this conclusion, it is noted
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that the Galway Rural Water strategic plan of 2000 indicates that Scéim na nOileán (a phase 2 area) had unsatisfactory treated water quality.
It is concluded therefore that as the phase 1 works are associated with the demand projections for Carraroe, Rosmuc and Camus / Screebe, and although there is a 44% standby built in to the design figures, the pipelines and reservoirs serving locations outside the phase 1 supply area should be excluded from an approval for this scheme. In arriving at this conclusion, the history of the scheme as outlined in Appendix 2 of the EIS is noted. In that appendix, an overall demand assessment of 12,600 m3/d was estimated in 1986 and at the same time the DoEHLG required that a new water abstraction proposal be made. It is considered that if the extent of the supply area was widened without approval for additional water abstraction it could give rise to a question of project splitting.
5.3 In relation to alternatives, the conclusions reached in the EIS regarding the choice of source, choice of site of intake works , the water treatment works and the reservoirs at Glenmore (Carraroe) and Glencoh (Rosmuc) are considered appropriate.
5.4 Water Quality is predicted by the EIS not to be impacted on in the operational phase. This conclusion is accepted as far as Glenicmurrin Lough is concerned but a potential issue could arise in relation to any discharges arising from the operation of the treatment works which is close to the Cashla river close to its tidal range. A condition is recommended in this regard. A lesser operational issue could arise in relation to any dredging of material during maintenance of the regulating weir, but this should be capable of being catered for in ongoing liaison with WRFB and other fisheries interests.
In the construction phase the mitigating measures listed in the EIS refer mainly to good site management practices and in view of the sensitivity of the site and the potential consequences for salmonids, it is considered important that a formal liaison committee representing the relevant fishery interests should be formed for both the construction and operational phases of the scheme. A condition is recommended in this regard.
5.5 In relation to hydrology, the proposal that lake levels are to maintained within the current and natural range is considered an acceptable approach. The drawing submitted by the Local Authority (Figure 4.20) on 11th October 2007 illustrates the water coverage at the various levels and shows the differences at the top and bottom of the range. The difference is not considered to be significant. The slightly higher flow available in dry spells is listed as a slight positive effect and it is considered relevant that while the impact is not significant it is positive rather than negative.
A significant item being provided as part of the works is the fish pass and its successful operation is the most important aspect of the scheme from a fisheries point of view. The level of consultation proposed, together with the design approval of the Department of Communications, Marine and Natural
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Resources (*now Department of Agriculture, Fisheries and Food) is considered appropriate.
The minimum compensation flow is given as 0.15 m3/sec which is over three times the volume of the proposed abstraction. It is correct to say that without the abstraction and consequent regulation of the lake, minimum flows can drop below the compensation level and therefore the proposed arrangement would be an improvement on the current situation. It is noted that prior to 1996, (Table 5.3 of Appendix 2, Vol 3 of EIS), low flows below 0.25 m3/sec were recorded in 9 of the previous 17 years, while for 1996 - 2003, minimum flows all exceeded 0.25m3/sec.
However, the requirement for upstream migration of salmonid species is noted and a recent publication by the Department of Communications, Energy and Natural Resources (Guidelines on the Planning, Design, Construction and Operation of Small-Scale Hydro-Electric Schemes and Fisheries) gives recommendations in that regard. The Publication (October 2007) in dealing with Residual and Compensation flows mentions throughput for hydro stations being set at 50% of total flow and notes that a flow of 0.03 m3/sec per metre width of river bed as an absolute survival flow for salmonids.
Considering the international importance of the fisheries in the Cashla river system while noting the improvement in low flows being facilitated by the scheme by virtue of the regulation of the lake, a minimum compensation flow of 0.25m3/sec is considered appropriate and a condition is recommended in this regard. (See section 5.15 below where it is noted that the WRFB recommend a compensation flow of 0.32 m3/sec but not based on the above)
5.6 The extensive consultation undertaken in relation to Flora and Fauna is noted and the importance of having a satisfactorily operating fish pass is particularly noted. The importance of Glenicmurrin Lough and the lake and river system generally in relation to the well- being of the Atlantic Salmon, Sea Trout and Arctic Char is acknowledged by the Local Authority and has been stressed by the WRFB, the Costello and Fermoyle Fisheries Company and by a number of private individuals who have experience of fishing in the area.
As stated in the previous paragraph, the effectiveness of the proposed fish pass is critical in relation to fish spawning and migration. It is considered that in addition to the design and installation of the fish pass, the detailed monitoring for three years which is proposed is essential to ensure confirmation as to the effectiveness of the measures taken.
With respect to terrestrial flora and fauna, the conclusion in the EIS that with suitable mitigation the impact on terrestrial habitats would be imperceptible, is considered to be correct.
In relation to the Connemara Bog Complex cSAC it is considered that the proposals would not significantly impact on the SAC and the use of approximately 2 hectares for construction of facilities would not affect the integrity of the SAC. In relation to the Kilkieran Bay and Islands cSAC, it is
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considered that the proposals would not have a significant impact and would not affect the integrity of the cSAC.
5.7 The impact on human beings from the provision of a reliable water supply system from a qualitative and quantitative perspective is clearly positive. The negative impacts during construction are dealt with as far as possible by the mitigation measures listed and the socio- economic impacts are likely to be positive as predicted by the EIS.
5.8 Noise impacts are not likely to be significant during operation of the scheme. The mitigation proposed for the construction phase is considered satisfactory.
5.9 Due to the re-design of the scheme and subsequent relocation of the treatment plant the landscape and visual impacts of the treatment plant are reduced. The EIS sets out the mitigation measures proposed in respect of the service reservoirs and these are considered appropriate
5.10 The Development Applications Unit of the DoEHLG submission of 17th August 2007 gives requirements for archaeological and architectural assessment and this was responded to by the Local Authority by way of a report from the Moore Group received by the Board on 22nd October 2007. The report is considered adequate and the requirement for archaeological supervision is considered the appropriate measure in this instance.
5.11 In relation to Soils and geology the proposal to remove excavated peat outside of the cSAC is considered appropriate. It is accepted that with mitigation there should be no impact on the surrounding geological environment.
5.12 Traffic impacts are likely to be local and the proposal in the EIS to have a provision in the construction contract to cover damage to local road repairs is considered appropriate.
5.13 Assessment of Additional Information: The information submitted by Galway County Council on 11th October indicated that the difference in area covered at the two ends of the control band is relatively small, given the overall area of the lake and is as stated within the natural range of lake levels. The responses in relation to the issue of surface area covered and in relation to the documentation requested on PPP assessment and the Committee on Petitions are considered to be satisfactory.
The response in relation to the reasons for abandonment of Loughaunwillan are not considered to be adequate as it appears to give up on a basic objective of the Water Framework Directive to achieve good quality status by 2015. It is accepted that there is insufficient capacity in Loughaunwillan to supply the Costelloe area, but it is considered that the aim of the Local Authority should be to remedy water pollution issues in the lough so that that source could be considered in the future to augment the current source. It is not considered appropriate to recommend any course of action in relation to
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Loughaunwillan as the scope of this report is considered to be limited to examining the proposals as put forward for the Costelloe area as supplied from Glenicmurrin Lough.
The additional information submitted on 13th December 2007 related to water quality issues and likely impacts on treatment. The response listed as Item 1 indicates an iron value of 658 ug/l and manganese of 50 ug/l. As stated in the response the water is treatable but it was calculated that a sludge load of 4.6 kg/d dry solids may arise. The concern raised regarding discharges to the Cashla river are therefore relevant and a condition is recommended in relation to wastes which would cover supernatant discharges from any water treatment process as well as that arising from removal of iron and/or manganese.
The coliform values are referred to in item 2 and it is noted that the results while high, are influenced by the time of sampling.
Item 3 refers directly to waste generation in the water treatment process and the proposal to treat to EPA Environmental Quality Standards is noted while removing sludge for disposal in accordance with the Galway County (Council) Sludge Management Plan. As this commitment is not contained within the EIS or in any documentation which went on public display a condition is recommended to cover the item.
5.14 Assessment of third party submissions: Referring collectively to the submissions of Mary Conneely – Costello, John Costello, Owen Jacob and Robert Haughton, Rob Graham, Tevor F Nind and Jean – Pierre Maire & Nicola Stronach, and referring to the written responses by the Local Authority which clarifies some issues in relation to water levels quoted, it is considered that subject to the effective implementation of the mitigation measures proposed, the objections made do not give grounds for rejecting the proposal.
In relation to the objection of Mr Fitzjohn, it is considered that, in addition to the commitments by the Local Authority to consultation with the relevant prescribed bodies and the requirement for the approval of the fish pass to be approved by the DCMNR ( *Department of Agriculture, Fisheries and Food , see SI 707 of 2007 ) Marine / Engineering Section, the condition recommended relating to an ongoing local liaison committee should address the issues raised. It is considered that the objection does not give grounds for rejection of the proposal.
The submission / objection of Mr Terry Gallagher on behalf of Costello and Fermoyle Fisheries also includes a response to the further information submitted by Galway County Council. In relation to issues relating to the fish pass, the SAC and the Habitats Directive, it is considered that the EIS, together with the responses of the Local Authority addresses the issues raised. In relation to the abandonment of Loughaunwillan and the comments of the Committee on Petitions, while the issued raised are similar to those noted in section 5.13 above, it is accepted that Loghaunwillan has a lack of capacity to serve the area of the RWSS. A condition is recommended outlining the extent
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of the approval recommended. The objection of Costello and Fermoyle Fisheries is considered not to give grounds for rejection of the scheme.
5.15 Submissions of Prescribed Bodies: The DoEHLG made an original submission in August 2007 and responded to the additional information supplied in November 2007.The submissions covered archaeological, architectural and nature conservation elements. It is considered that the conditions recommended cater for the issues raised by the DoEHLG.
The Western Regional Fisheries Board made an extensive submission in August 2007 which listed a number of specific issues, some of which are included in the Local Authority response matrix as commitments. It is considered that some of the concerns of the WRFB are included in conditions which are recommended to attach to the approval.
In relation to the hydrological assessment, the WRFB comments on the additional information in November 2007 request a compensation flow of 0.32 m3/sec instead of the 0.15m3/sec proposed. While the WRFB questions the origin of the Local Authority Compensation Flow Proposal, it must be pointed out that under the Local Authority proposal, the proposed abstraction accounts for less than 22% of the lowest flows (i.e. Abstraction plus minimum compensation flow) and it is noted that the low flows would not be expected to last for more than 20 days in a year. (If the minimum compensation flow is set at 0.25 m3/sec, the abstraction would be less than 15% of the lowest flow including compensation water)
The limiting of the works to phase 1 supply area (recommended condition) where the actual daily input required in the initial years is likely to be below 3,600 m3/day, is considered to give opportunity to the Local Authority to further examine some other sources and perhaps avoid any proposal to source additional water from Glenicmurrin.
For reasons set out in paragraph 5.5 above it is recommended that a minimum compensation flow of 0.25 m3/sec be maintained and a condition is recommended to that effect.
The WRFB submission indicates the concerns of the Fisheries Board and can be read as an objection to the scheme. The objection is considered not to give grounds for rejection of the proposal.
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6.0 RECOMMENDATION
It is recommended that An Bord Pleanála approve the proposal of Galway County Council for the works described as the Costelloe Regional Water Supply Scheme, as described in the Environmental Impact Statement submitted on 3rd July 2007, subject to conditions as detailed below.
REASONS AND CONSIDERATIONS
Having regard to the following:
· The provisions of the Galway County Development Plan · The Water Abstraction Order of January 1979 · The nature and extent of the mitigation measures proposed · The EIS prepared in respect of the development · The additional information supplied and the submissions made in respect of the EIS and of the additional information
It is considered that, subject to the modifications set out in this order the proposed development would not be in conflict with the proper planning and sustainable development of the area and would not result in significant adverse effects on the environment.
CONDITIONS
1. The scope of the works covered by this approval is limited to the supply area defined as phase 1 in the Environmetal Impact Statement .
Reason: Insufficient information has been submitted in relation to the potential source of supply for areas outside of the Phase 1 area.
2. A minimum compensation flow of 0.25 cubic metres per second shall be provided downstream of the abstraction during the period of operation of the control on the river.
Reason: To provide adequate river flow for upstream migration of fish.
3. A project archaeologist shall be appointed and all topsoil excavations shall be monitored and the protocols as laid out by the Department of Environment, Heritage and Local Government shall be followed. A final archaeological report shall be prepared and made available at the area office of Galway County Council in Carraroe.
Reason: To ensure that all items of archaeological importance are located and evaluated.
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4. A project ecologist shall be appointed to review all method statements regarding works in Special Areas of Conservation and a final ecological audit report on all works shall be prepared and made available for inspection at the area office of Galway County Council in Carraroe.
Reason: To protect terrestrial ecology
5. All wastewater arising from the water treatment works at Cashla shall be treated to the relevant Environmental Quality Standards as published by the Environmental Protection Agency and all sludges shall be removed from the site to be disposed of in accordance with the Galway County Sludge Management Plan .
Reason: To protect water quality and aquatic ecology.
6. A liaison and monitoring committee shall be established by Galway County Council prior to commencement of construction to act as a forum for disseminating information on construction work relating to the development. This Committee shall continue after completion of construction to disseminate information on all monitoring carried out in relation to the development. The committee shall be representative of the Local Authority, their Consultants and Contractor, National Parks and Wildlife Service, Western Regional Fisheries Board and Costello and Fermoyle Fishery company and the local community in the Glenicmurrin area.
Reason: To provide a consultative forum for local community interests likely to be affected by the development.
______Daniel O’Connor Engineer Gd I 22nd January 2008.
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APPENDIX 1
COSTELLOE REGIONAL WATER SUPPLY SCHEME
ENVIRONMENTAL IMPACT STATEMENT
1.0 Foreword – (Chapter 1, Pages 1 – 6)
The EIS states that An Bord Pleanála directed Galway County Council to prepare an EIS in respect of the proposed Costelloe Regional Water Supply Scheme on 1st June 2005. The direction from the Board stated that the development was a sub-threshold development and having regard to the environmental sensitivity of the area and in particular the existing nature conservation designations that the proposed development would be likely to have significant affects on the environment due to potential impact on designated nature conservation areas, visual impact and impact on fishery interest.
The EIS states that the assessment has been carried out with due regard to the criteria set out in the EIA Regulations.
It is stated that the Environmental Impact Statement is one of three constituent parts of the process, the others being the comments of the public, Local or State Authorities or EC Member States and the assessment by the competent Authority. The aspects of the environment examined are stated to be: -
· Human beings, flora and fauna.
· Soil, water, air, climate and landscape.
· Material assets.
· Cultural heritage.
· Inter-relationships.
It is stated that the purpose of the assessment is such as not to dismiss any impacts which may be significant and to focus on issues that need to be resolved. The EIS sets out in tabular form the headings in SI 93 of 1999 and gives the reference where these are covered in the EIS. The document is stated to be presented in a grouped format structure, as recommended in the Draft Guidelines produced by the EPA. The format of the EIS is set out in Section 1.4 of this chapter. Under the heading of difficulties encountered, it is
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stated that adequate knowledge and information has been available in the production of the statement.
Section 1.7 sets out the methodology which includes a list of all the relevant planning documents and guidance documents.
2.0 INTRODUCTION (Pages 7 – 17)
This chapter covers issues including the need for the scheme, planning framework, both national and local, County Development Plans and rural water programme.
2.1 Need for the Scheme
The existing water supply schemes in the study are set out in Table 2.1 and data is given in relation to the average distribution input m3/day, source, whether public or group scheme and an indication of the area served. The schemes include Carraroe, Tir an Fhia, Spiddal and Rosmuc Water Supply Schemes (WSS), as well as Sceim na nOilean, Camus Eighter and Camus Oughter Group Water Schemes (GWS). It is noted that the first four mentioned schemes are public water supply schemes.
The EIS states that a number of the schemes are substandard and it refers to the check monitoring results from 2001 to 2005 provided by the Water Services Section of Galway County Council. The EIS states that the results showed that there were exceedances in iron, manganese, total coliforms, faecal coliforms and odour in some of the schemes. It refers to Appendix 5 where the results of a Cryptosporidium risk assessment is given in relation to the existing supplies at Carraroe, Rosmuc and Tir an Fhia. It notes that the water quality in the existing schemes is referred to further in sections 5 and 8 of the EIS.
The EIS states the most important recent significant development in relation to the need for the scheme was the lodging of a petition to the European Union regarding contaminated drinking water in Carraroe. It states this was followed by the publication of a report from the EU Committee on Petitions in 2003 with updates in 2004, 2005 and 2006. (It is noted that a copy of the updated report, including one for 2007 was submitted as additional information by Galway County Council to the Board in October 2007). The EIS states that the recommendations of the report included: -
· The European Commission should ensure the compliance of the Irish authorities with the provisions of the drinking water directive, in particular, for Carraroe, County Galway.
· The EC and the Irish authorities should urgently discuss the allocation of cohesion fund resources or other funds that may be appropriate
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which would contribute to the establishment of a reliable and clean source of water for the inhabitants of Carraroe.
The EIS states the second major development was the publication of Stage 1 of the Galway Rural Water Strategic Plan of November 2000. It states that this report identified Rosmuc as a zone with high concentration of houses without a piped water supply, with particular reference to the area along the R340. It states that the report also identifies Carraroe PWS, Sceim Na nOilean GWS and Camus GWS as having unsatisfactory treated water quality. The report also noted that Carraroe and Rosmuc Schemes had low-pressure problems.
2.2 Description of the area
The EIS sets out in Section 2.2 the study area for the preliminary report of the General Costelloe Regional South Connemara and this includes Spiddal/Rossaveal, Carraroe, Lettermore area and Rosmuc.
Section 2.3 of the EIS gives the planning context which includes the NSS, Regional Planning Guidelines for the West Region (May 2004) and the Galway County Development Plan 2003 – 2009.
In relation to the National Planning Framework, the EIS sets out the key legislative instruments governing planning. It used the background to the National Spatial Strategy and notes that in the NSS, Carraroe is identified as a village or town in a remote area where the overall urban structure is weak. It states that such towns and villages play a key role in delivering services and supporting employment in physical remote and peripheral areas. The EIS states that towns such as Carraroe would have a vital role in establishing local employment and service functions to drive the process described in the NSS.
The EIS refers to the Regional Planning Guidelines for the West Region and notes that the West Region was expected to achieve significant growth to the year 2020 from 380,000 population in 2004 to approximately 460,000 in 2020. The EIS states that the local authorities in the West Region have an objective to provide water and sewerage infrastructure throughout the region for domestic, industrial, agricultural and other uses. The Guidelines state that the dispersed settlement patterns resulted in a lack of services in some areas and private group schemes and individual wells supplemented the main public water schemes in the region. It notes that Galway County Council currently operates 50 public water supply schemes that serve approximately 12,200 households. It notes that the group water scheme sector operates 400 supplies, but that many rural villages in Galway have inadequate supplies.
The Regional Planning Guidelines list eight strategic goals for the region and the EIS refers to Goal 3 which was to ensure a framework was devised to meet service infrastructure requirements for the region, Goal 5 which was to improve the quality of life for citizens by promoting the concept of sustainable development and protecting the environment and Goal 7 which related to
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tourism and stated that there was a potential for special interest tourism activities in the west.
The EIS states the overall aim of the Regional Planning Guidelines was to provide a broad context that would allow the coordination of the physical planning of the region.
The EIS refers to Section 6 of the Regional Planning Guidelines and notes that a number of schemes have either begun or have been recently completed in the West Region. It states the individual local authorities in the region have their assessment of need documents available outlining their individual priorities.
In Section 2.3.4, the EIS refers to the Galway County Development Plan and notes the policies regarding the rural water programme referring to policies 42 to 52 which includes the requirement to promote better design, cooperate with the private sector, eliminate existing deficiencies and to use a mixture of public and private partnerships.
The Rural Water Programme Objectives 35 to39 are also referred to and include the requirement to rationalise and renew existing water facilities and provide services in un-serviced towns.
The EIS states that the Costelloe Regional Water Supply Scheme is included in the Galway County Council Water Service Assessment of Needs published in 2006. It states that it is also included in the Water Services Investment Programme 2005 – 2007 published by the DoEHLG and is indicated as one of the projects to start in 2007. The EIS states on Page 16 that the Costelloe Regional Water Supply Scheme accords with the policies and objectives of the County Development Plan and is included in the Water Services Investment Programme for the County.
2.3 Scoping
The EIS states that a scoping report was produced and issued to key consultee organisations. It states that following the process and evolution of the scheme design, it was determined that there was no potential for significant affects to occur in relation to climate and odour and therefore no detailed assessment of these aspects was required. It notes that Appendix 1A has a summary of the responses to the Environmental Impact Scoping Report.
2.4 Public Consultation
The EIS states that Tobin Consulting Engineers undertook an extensive public consultation and information process on behalf of Galway County Council which included a briefing note to the Connemara Area Elected Members, a presentation to the Connemara Area Elected Members of Galway County Council on the 22nd January 2007, a public notice and press release which included announcements on local radio. It also states that a public information
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evening was held at Ostín an Dóilín in Carraroe on the 29th January 2007 from 3:00 p.m. to 8:00 p.m.
In relation to the public information evening, the EIS states that the key elements were put on display with both Irish and English versions. It states that 38 members of the general public attended and that while a number of the individuals had reservations about certain aspects of the scheme, the majority expressed their support for the scheme.
The EIS states that the comments from the public information day are summarised in Appendix 1(b). It states that there were also discussions and consultations with key stakeholders, including the NPWS, Western Regional Fisheries Board, DCMNR (*note change in SI 707 of DCMNR to Dept of Agriculture and Food) and the Costelloe and Fermoyle Fisheries.
3.0 PROJECT DESCRIPTION
The objective described in Section 3.1 is to provide an area in South Connemara with a water supply to cater for existing and future developments within the supply area in compliance with the drinking water regulations.
It is noted that two large areas are designated as SAC. These are:
· Connemara Bog Complex – Site Code No. 002034 – area 49,010 hectares. (409 sq kms)
· Kilkieran Bay and Islands – Site Code No. 002111 – area 21,314 hectares. It notes that Figure 3.10 indicates the areas covered by the SAC designation. (abuts Connemara Bog Complex at a number of points and is largely sea-based)
The EIS indicates the proposals as including: -
· Gauging Station entering Glenicmurrin Lough.
· Regulating weir to replace existing weir.
· Intake works and pumping station at regulating weir site.
· 300 millimetre raw water rising main from the pumping station to the proposed treatment works at Cashla.
· Water treatment works at Cashla.
· New water main network to be constructed in a number of phases.
· Reservoir at Glenmore (Carraroe).
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· Reservoir at Rosmuc.
· Reservoir at Lettermore (this is a phase 2 proposal).
· Access roads, site development and ancillary work at each site.
It states the proposed network to serve the overall Costelloe region is to cover the areas of the Carraroe, Cashla, Bealadangan/Muicineach, Lettermore, Tir an Fhia and Rosmuc. The EIS indicates the trunk and distribution mains required (it does not distinguish between Phase 1 and Phase 2 works in this section). It includes: -
· 300-millimetre rising main from the intake to the treatment works.
· 300-millimetre rising main from treatment works to Glenmore (Carraroe) Reservoir.
· 250-millimetre rising main from the junction of the R343 and R374 at Radio na Gaeltachta to Lettermore Village (Phase 2 works).
· 150-millimetre diameter trunk main from Lettermore village to Lettermore Reservoir (Phase 2).
· 200-millimetre distribution main from Lettermore to Tir an Fhia (Phase 2), not included in Phase 1 description.
· 150-millimetre rising main from Glencoh to Rosmuc Reservoir which is described as an extension of an advanced section laid and includes the crossing of Screebe Bridge.
The EIS states the total length of pipe work to be installed is 24 kilometres and it is noted the scoping report had included the section of pipe work from Cashla Cross to Screebe, which was omitted from the EIS as it had been constructed by a Group Water Scheme as an advanced contract. (It is not stated in this section if that water main is in use from an existing source at present). The EIS refers to Figures 3.1 and 3.2 to indicate the water main networks.
Section 3.2.2 describes the gauging station. From Figure 3.1, this indicates that the gauging station is upstream of Glenicmurrin Lough and the EIS states that it would be necessary to construct a timber walkway at ground level to the gauging station over a distance of 175 metres to allow pedestrian access for maintenance of the station. It notes the unit would be powered by a solar panel with a battery providing back up supply.
The EIS states the regulating weir and intake works would be located together at the outlet from Glenicmurrin Lough and just downstream of the existing weir which would be widened as part of the works. It states that there would be a passive type screen incorporated into a 450-millimetre diameter
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intake pipe. It notes that provision has been made in the intake sump design for a future pump. The EIS states that it is intended that two pumps would be installed initially in the intake sump operated on a duty/standby basis. The layout is shown on Figure 3.3 and 3.3A which are included in the list of figures between Pages 36 and 37 of the EIS. It is stated that the control house with a ground level of 28.5 OD and would be finished in local stone, while the regulating weir would incorporate a fish pass to assist the natural migration of fish in the Cashla River. Figures 3.4 and 3.5 show plans and elevations of the regulating weir. It is stated that a CCTV camera would be mounted at the weir to protect the private fishery interests.
The EIS refers to Section 6 which discusses the regulating weir operation in more detail.
The EIS states that the temporary clear span bridge would be used over the Cashla River to enable construction works to take place on the eastern bank of the river. In respect of the 5-metre wide access road proposed, it is stated that the depth of peat is generally 0.5 to 1.5 metres with a short section of up to 3 metres depth. The EIS states that it is proposed to remove the peat and to store it in the section of road that lies outside the SAC. It states that provision would be made in the deeper peat excavation to prevent a longitudinal drainage towards that section of excavation.
If rock excavation is required, the EIS states that environmental impacts of rock blasting would be of a shorter duration and have a lower impact. On Page 23, the EIS shows a cross-section of the proposed road construction.
The EIS states that power would brought from a 10kV overhead line which currently runs along the Cashla to Screebe Road and that power cables would be laid underground in ducts along the access road to the intake works. Fencing is stated to be 1.2-metre high post and sheep wire fencing.
The EIS states that reinstatement would be carried out on areas required to be disturbed for a construction. It states that following completion of works, areas designated for reinstatement would be filled using locally excavated rock to the levels shown on the pre-works survey. The original peat / heather would be replaced onto the filled ground and peat habitats would be allowed to regenerate naturally.
Section 3.2.4 describes the water treatment works at Cashla and it is stated that this would be provided using design build and operate form of contract (DBO). It is noted that because DBO is proposed, it is not possible to describe the site layout in detail. The EIS states that it is proposed to construct a Phase 1 water treatment works at Cashla for 3,600 m3/day and it is noted that the water abstraction order of 1979 allows an abstraction of 3,640 m3/day from the lake.
The EIS states that in the indicative design, there would be a raw water- balancing tank at TWL of 11 metres OD which would hold four hours supply. The EIS sets out the likely elements of the works including chemical dosage
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building, treated water pumping station, administration building and main treatment building. It also states there would likely be a wash water settlement tank, sludge thickening and dewatering facilities. It states that the supernatant liquid would be pumped to the local road drainage system, while thickened sludge would be removed off-site for disposal in accordance with the Galway County Sludge Management Plan. (The issue of discharge from the plant is raised in assessment , Section 5.13 of Report above).
The EIS states that the DBO contractor would design the works, but that the maximum height of buildings would be 13.0 MOD. Figures 3.6 and 3.6A (rev B) show the area, which the DBO contractor would use, and also an indicative layout plan of the treatment works. It is noted that in Fig 3.6 (RevB) there is provision for phase 2 settlement tanks and filters. ( Implies providing for a greater throughput at some later stage- see Section 5.2 Assessment)
Section 3.2.5 describes reservoirs and these include: -
· Glenmore Reservoir (Carraroe)– adjacent to the existing reservoir which has a capacity of 455 m3 and a TWL of 62.3 metres OD – total storage proposed is 2,155 m3 and location and layout plan are shown on Figure 3.7.
· Rosmuc Reservoir – 500 m3 capacity and TWL 63 metres OD. It states that the new reservoir would be 8 metres higher than the existing reservoir and would alleviate current pressure problems in the area. – Both Glenmore and Rosmuc are indicated as Phase 1 works.
· Lettermore Reservoir – TWL 58.3 m OD with the capacity of 1,000 m3 – this is stated to be part of a Stage 2 Scheme.
The reservoirs are indicated on Figures 3.7, 3.8 and 3.9.
Section 3.3 states that the procurement would be by both traditional forms of contract and DBO contracts. Table 3.1 and 3.2 indicates the proposed mix of contracting methods.
Section 3.4 sets out the requirement for method statements for the various construction elements. It states that the method statements would be reviewed by the Project Ecologist who would be appointed by Galway County Council prior to their submission to the National Parks and Wildlife Service (Galway Divisional Office). It states that method statements would be required to take account of the mitigation measures as set out in the EIS.
Section 3.5 describes the existing water abstraction order. This was first proposed in May 1975 and following withdrawal of an objection from the Costelloe and Fermoyle Fisheries, a formal notice under the Water Supplies Act 1942 confirmed that the proposal would come into force on the 26th January 1979. It states that the full procedures for the order had been completed, including the issue of a commencement notice and the issue of
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individual notices to those listed in the Book of Reference. (A copy of the Agreement of 1978 is included in the documentation submitted with the application).
Section 3.6 deals with design data and notes that water demand projections which are used refer to census figures, NSS, Galway County Rural Water Strategic Plan and Customer Data.
The EIS states that the area was divided into sub-regions and each of those were labelled as a water supply area (WSA), which consisted of a discreet network with metres on all inflows. It states that unconnected group schemes served by their own source were also labelled as WSA’s. The areas identified were: -
a. Carraroe b. Tir an Fhia – including Lettermore. c. Rosmuc. d. Gorumna/Lettermullan (Sceim na nOilean GWS). e. Camus – Screebe.
The EIS states that the Preliminary Report included the Rossaveal area and the entire coastal stretch towards Spiddal. It states this was included as there was a linkage between the Spiddal RWSS and the proposed Costelloe RWSS. It states the exact boundary between the two schemes could be moved by opening or closing boundary valves between them.
The EIS states the existing demands were calculated using population data, occupancy rates and per capita water consumption figures. It states there were 28 metered water users within the overall study area. It states the unaccounted-for-water in each supply area was assessed based on the integrated flow method. This, it states, uses logged daily flow data from the field test carried out.
Table 3.3 gives a summary of the existing (2003) distribution input in cubic metres per day. The total demand for the study area is given as 3,139 m3/day with 46% unaccounted for water. The total Costelloe area is indicated as having a total demand of 1,609 m3/day with unaccounted-for-water of 53%.
Future demand projections are stated to have been arrived at by using census figures projected to 2024. A 1% annual growth rate was assumed for non- domestic consumption. It states that in accordance with the recommendations of the National Water Study of 2000, there was no allowance being made for future increases in agricultural demands. Unaccounted for water was assessed separately for each area and is indicated as being 37% for the Costelloe area, 22% for the Spiddal/Rossaveal area and the overall level was estimated to be 31%. The estimation of future distribution input is given in Table 3.4. This
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indicates a distribution input for the Costelloe area of 4,013 m3/day for the year 2024.
In Page 36 of the EIS, the Phase 1 supply area is defined as being Carraroe, Camus/Screebe and Rosmuc areas. It states the total 2003 demand for the areas is estimated at 2,008 m3/day and the proposal was to develop a Phase 1 scheme for 3,600 m3/day with 44% spare capacity based on the 2003 demands. It states that over the next 20 years, demand would grow. It states that the area not served by the Phase 1 scheme which included Tir an Fhia, Lettermore and Gorumna may be connected to the scheme in the future. It states that the need to develop a Phase 2 scheme beyond 3,600 m3/day would depend on the extent to which demand grows in the Phase 1 supply area, the need to extend the scheme and the location of the boundary between the Costelloe and Spiddal Schemes.
Figures 3.1 to 3.10 which comprise maps of the area and layout drawings of works are included after Page 36 of the EIS.
4.0 ALTERNATIVES (EIS PAGES 37 – 67 AND FIGURES 4.1 – 4.11)
The EIS examines alternative water sources in Section 4.2. These are divided into: -
· Sources local to the supply area and outside of the cSAC.
· Sources local to the supply area and within the cSAC.
· Sources remote from the supply area and other sources.
The EIS considers the use of Loughaunwillan which is the current source for Carraroe Village, Muicineach, Bealadangan, Anaghvaan, Ross Island GWS and Lettermuckoo GWS. The location of this lake is shown in Figure 4.1.
The EIS states that Loughaunwillan was proposed as a temporary source in the 1960’s and the abstraction was given as 455 m3/day which was increased in 1979 to 1,364 m3/day. (Noted that in the previous chapter, Table 3.3 indicates a distribution input of 1,580 m3/day which appears to be in excess of the quoted abstraction allowance).
The EIS states that the source was never considered as a viable long-term solution and that recent concerns had undermined the confidence in the source. It refers to correspondence in 1975 indicating that the normal low summer level in the lake was 3.17 metres OD, but that in 1975, the level had dropped to 2.68 metres OD.
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The catchment area of Loughaunwillan is given as 380 hectares and this is stated not have the capacity to provide the required volume of water for the Costelloe RWSS without impoundment. It states that the depth of impoundment required would be 1.63 metres, giving a maximum water level of 4.8 metres OD.
The EIS refers to a second hydrological assessment carried out to establish the level of impoundment required if the projected demand of 2,120 m3/day was to be provided for the Carraroe supply area. (This would exclude Rosmuc, Lettermore, Gorumna, Tir an Fhia and Camus). This stated that an impoundment depth of 907 millimetres would be required to give a maximum water level of 4.08 metres OD.
The EIS states there are several properties on the north-eastern corner of the lake which have floor levels of the order of 5 metres OD and which discharge their sewage to septic tanks. It states that the public foul sewer laid at the lake edge on the south-eastern corner of the lake has a crown level of 3 metres at its lowest point and it states in the EIS that the required impoundment of the lake would submerge that foul sewer leading to a public health risk. (Noted that the normal summer lake level is given as 3.17 metres which would indicate that this sewer is currently below the water level of the lake).
The EIS states that the historical water quality problems on Loughaunwillan were due to agricultural and other discharges and that this would indicate that public confidence in the source is quite low and it is also stated that it would be likely that the development of the source further would be met with significant opposition. In relation to this source, the Cryptosporidium risk assessment carried out (see Appendix 5A of the EIS) indicated that it was a very high risk which is stated to be mainly due to the high number of animals within the catchment and the high number of discharges to the catchment.
The EIS refers to a complaint made to the EU Committee on petitions and to the reports of the Petitions Committee. (It is noted that the more recent reports of the Petitions Committee record progress in relation to sewerageand pollution issues in Carraroe)
The EIS states that in summary, Loughaunwillan is not considered suitable as a source for the Costelloe RWSS as it does not have the capacity to supply the 3,600 m3/day required for the Phase 1 supply of the RWSS or the capacity of 2,100 m3/day which would be the projected demand for the Carraroe supply area, unless impoundment was provided.
The EIS examines Lough Hibbirt which on Gorumna Island. It states that this has a catchment of 372 hectares and would require an impoundment depth of 2,455 millimetres to supply the Costelloe RWSS. It states that the Gorumna area is now not considered part of the Costelloe RWSS supply area, as the island would be served as part of a DBO bundle.
Referring to Lough Aroolagh (Rosmuc), the EIS states that this lake has a very limited catchment area and would require an impoundment depth of over 3
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metres which is stated to be impractical. It is noted that this lake was considered to have a moderate risk of Cryptosporidium outbreak.
Lough Nambroughania (Lettermuckoo) is stated to be the north-west of Glenicmurrin Lough and the catchment area is considered not large enough to supply the Costelloe RWSS at 150 hectares in size. It states the impoundment depth required would be 2.16 metres and this was considered impractical, as it would require a very large structure on a small lake which would have a significant visual impact.
In relation to sources local to supply area inside the cSAC, the EIS describes Glenicmurrin Lough which is the proposed abstraction, as well as Lough Cloonadoon and Lough Muckanagh.
The EIS states that Glenicmurrin Lough has a large catchment of 6,700 hectares and an impoundment of 600 millimetres would be required to deliver the required volume of water for the scheme. It notes that Glenicmurrin Lough is located within the cSAC of the Connemara Bog Complex.
The EIS states that as part of Phase 1 of the Costelloe RWSS, 3,600 m3/day would be abstracted and that Galway County Council has an existing water abstraction order for 3,640 m3/day from Glenicmurrin Lough.
The EIS states that analysis was carried out to determine if the Lough could sustain the abstraction while maintaining sufficient compensation flow to the Cashla River downstream to allow for other users. It states that the proposed operating regime would be as follows: -
· Minimum compensation flow of 0.15 m3/s throughout the year.
· For average flows of greater than 0.5 m3/s compensation flows would be increased.
· Towards the top of the control band, outflow would be greater than half the average inflow in order to control the top level as per fishery requirements.
The EIS states that the control regime would be operated by means of a gauging station, the location and methodology being agreed with NPWS, WRFB and local fisheries owners at the advanced design stage.
The EIS states that Tobin Consulting Engineers carried out an analysis to determine what would have occurred in known dry years if the abstraction had been in place. The EIS notes that the lowest flow recorded at the EPA Gauge on the Cashla River was in 1984.
The EIS states that Glenicmurrin Lough is the lowest lake on the entire system and as such, use can be made of the run-off from the entire catchment upstream of the uptake point. It is stated that it has an area of 164 hectares
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which compares with 86 for Muckanagh and 50 Cloonadoon. It notes that as a result of this, 25-millimetre depth on Glenicmurrin gives storage of 40,915m3 which is much larger than the other lakes. The low level of impoundment is stated to be a major advantage of this lake source.
The EIS states that Bathymetric Survey of Glenicmurrin Lough was carried out in 2006 and this is shown on Figure 4.2A and indicates the water level contours from 7 metres up to 28 metres.
The EIS states the Cryptosporidium Risk Assessment was carried out in 2006 and concluded that there was a low risk of Cryptosporidium outbreak and this was arising mainly from the low level of agricultural activity in the catchment. It also stated that a safeguard would be provided by a state-of-the-art water treatment works which would incorporate settlement, filtration and other treatment processes designed to remove such parasites. (cryptosporidium oocysts).
The EIS describes the potential source of Lough Cloonadoon. It states this is approximately 400 metres east of Glenicmurrin Lough and also located within the Connemara Bog Complex SAC. It states that this catchment does not have the capacity to provide the Costelloe Water Scheme Phase 1 with the required volume of water without requiring a significant impoundment, greatly in excess of that required on Glenicmurrin Lough. It states it also further away from the main supply area of Carraroe than is Glenicmurrin Lough and it would require significant additional capital expenditure in order to develop the source. The third alternative is Lough Muckanagh which comprises two lakes of 47 and 38 hectares respectively. It states the average summer levels for both sections of the lake are 28.04 and 27.43 metres OD respectively. It states the catchment area for both Loughs is approximately 500 hectares and this is rated as being 7% of the overall Glenicmurrin Lough catchment. It states it required the construction of two regulating weirs as opposed to a single regulating weir and the required impoundment depth would be greatly in excess of that required on Glenicmurrin Lough.
In Section 4.2.3 the EIS examines sources remote from the supply and also other sources.
Lough Corrib is considered and this is noted as being more than 30 kilometres from the main population centre of Carraroe. Its states that head losses in the pipeline over a long distance would have to be overcome with pumping and the project would require high-energy usage and not be economically viable. It states that in addition the source itself is a cSAC and the abstraction pipe work would be located on the bed of the lake. It notes that the main trunk route from Lough Corrib via Maam Cross to Screebe also runs through a cSAC. It states that for both economic and environmental reasons, the development of Lough Corrib as a source for the Costelloe RWSS is not appropriate.
On Page 46 of the EIS, desalination is discussed and it notes that a desalination plant could be constructed outside the cSAC with a possible
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location in the industrial area of Rossaveal. The EIS states that operational costs for a desalination plant are greatly in excess of those for a standard surface water treatment works and would likely increase carbon dioxide emissions. It states the construction of a desalination plant for the Greater Dublin area was examined and it was found that the operating costs was a 3.5 times higher than an option that involved conventional treatment of surface water. It states that for both economic and environmental reason, the desalination option was not appropriate for the Costelloe RWSS.
The EIS states in summary that there was no viable source outside the cSAC local to the supply area and Glenicmurrin Lough is considered the optimum source within the cSAC based on both environmental and economic criteria. It sets out the summary of source options in Table 4.1 on Page 47 and 48 of the EIS. Also on Page 48, attention is drawn to the current Water Abstraction Order for Glenicmurrin Lough and the EIS notes the formal agreement under seal executed by Costelloe and Fermoyle Fisheries Company and Galway County Council to allow for the abstraction of 3,640 m3/day.
4.1 Alternative Sites for Treatment Works (Options 1-3)
The EIS states that the selection of the source for the supply sets the framework for the review of the alternatives for other elements of the project, including the water treatment works, the pipeline routes, the reservoirs, the intake works and the gauging station and regulating weir.
In relation to the alternatives for the treatment works, there are four options considered in the EIS. Options 1 and 2 are at Derrykyle with a variation on the location of the treatment works within the site, location of the treatment works to the west of Glenicmurrin Lough with a water tower near Lettermuckoo and the chosen option of a treatment works at Cashla.
Option 1 is at Derrykyle (Figure 4.3) with treatment works and clear water tanks situated together. The EIS states this is the scheme design as proposed in the preliminary reports of 1986 and 2005 and the layout is given in Figure 4.4. The disadvantages of the option are that it is entirely in the SAC and there would be a high visual impact from the south.
Option No. 2 is also at Derrykyle with clear water tanks on higher ground which would involve locating the treatment works on lower ground. The EIS states the treatment plant layout for Option 2 would be designed to minimise impacts on the intact peatland habitats. The location of Option 2 is shown on Figure 4.5 and the main advantages are stated to be that the visual impact of the water treatment works would be reduced in comparison to Option 1, but the disadvantages that the site is located entirely in an SAC. Option No. 2 is stated to have a clear water tank located at 92 metres OD and a ridge to the west is at 99 metres OD which would partly screen the tanks.
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Option No. 3 which sites the treatment works to the west of Glenicmurrin Lough involves a water tower near Lettermuckoo.
The EIS states this option reflects an attempt to locate the main treatment elements outside the SAC boundary. It states that this would require a top water level of 92 metres OD in the clear water tanks, but as the adjacent hill is at 73 metres OD, it would require a water tower. The EIS states that while the site would be outside the SAC, the visual impact of the water tower would be substantial.
4.2 Option No. 4 – Treatment Works at Cashla with the Intake Works adjacent to the Regulating Weir
The EIS states this option reflects a radical scheme redesign when compared to that outlined in the preliminary report and was examined in order to relocate the main treatment elements outside the SAC boundary. It states the site for the water treatment works would be located adjacent to the industrial estate of Cashla outside the SAC. The location is indicated in Figure 4.7 which indicates a top level for tanks of 13 metres OD. The EIS states the main advantages are the location of the water treatment works outside the SAC and combining the intake with the regulating weir, reduces the impact on the SAC. It notes the disadvantages of having treated water storage at a low level which will require pumping to local storage at Carraroe and Rosmuc and it is noted that the treatment works would be located closer to existing development. (In considering the advantages and disadvantages, the EIS does not refer to variations in operating costs for the different options).
In Section 4.3.3, the EIS describes the further technical, economic and environmental evaluation of the sites which is summarised as follows: -
· Option 1 – Derrykyle, treatment works and clear water tanks together – pumped from Glenicmurrin Lough to the treatment works by 300- millimetre main, 2.7 kilometres in length. – Three road options, with the longest and most costly arangement appearing to be the preferred option.
· Option 2 – Derrykyle, the clear water tanks on the higher ground – same requirements for pumping station and rising main. – Preferred access road would be Road C (longest option) as with Site No. 1 – topography of the main part of the treatment works is stated to be flat and more suitable to construction.
· Option 3 – Treatment works to the west of Glenicmurrin Lough and water tower near Lettermuckoo. – Rising main at 500 metres length which is shorter than Sites 1 or 2. – Water tower is more difficult and expensive to construct than the tanks in Options 1 or 2.
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· Option 4 – Water treatment works at Cashla and omission of high level storage. – Requires radical scheme redesign and would involve pumping of treated water to local storage at Carraroe and Rosmuc. The EIS states this option would require the upsizing of Rosmuc reservoir to 500 cubic metres.
The EIS refers to the economic evaluation and states that Sites 1 and 2 would have greater pumping costs than Site 3. It states the construction at Site 3 would be more expensive, as it would involve the construction of a water tower. It states the overall cost of Option No. 4 would be similar to that for Option 3, as the EIS states that the saving in the omission of the clear water tank would be balanced by the additional cost of land acquisition of the treatment works site and other changes.
In relation to the environmental screening evaluation, the EIS examines both ecology and landscape as follows: -
· Option No. 1 – Location is on a hill to the west of Lough Ateriff which is an SAC. – Would result in loss of blanket bog and heath habitat. (See Plates 4.1 and 4.2 on Page 50 of the EIS). In relation to landscape, the EIS notes there are approximately 13 no. dwellings within 500 metres of the site.
· Option No. 2 – Ecology – treatment plant location would result in the loss of blanket bog and heath habitat - impact less than with Option No. 1. With regard to landscape, views from Screebe along the R336 would not be affected and it stated that the highest tanks would be visible from the Lettermore/Carraroe areas to the west. (The EIS states that Option No. 2 offers advantages over Option No. 1).
· Option No. 3 – Ecology – reduced ecological impacts compared to Options 1 and 2, because treatment works is outside the SAC. With regard to landscape, the construction of a water tower at Option 3 would have a significant visual impact. The water tower is stated to impinge on the expansive use provided in the area and would rise 15 metres above the ridgeline.
· Option No. 4 - Water treatment works at Cashla – ecological impacts reduced compared to Options 1 and 2 and substantially less than for Option 3. In relation to landscape, Option 4 is located in proximity to the industrial estate and would not present impacts on views and landscape character compared with the other options. Option 4 is stated to have significant advantages over the other options in relation landscape impacts.
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4.3 Alternative Sites for Gauging Station
The EIS states that given the requirement for steady flow conditions, the location chosen is the optimal location in terms of having most favourable hydraulic conditions for flow measurement.
4.4 Alternative Sites for Regulating Weir
The EIS states that given the choice to use Glenicmurrin Lough as the source, the outlet from the lake that the Cashla River is the most appropriate location for an impoundment in terms of minimising disruption during construction, as the lake narrows considerably immediately upstream of the outlet to the Cashla River.
Several route options are stated have been examined in relation to the access road to be constructed at the regulating weir. It states that an initial route was altered to take account of the revisions to the cSAC boundaries in December 2006 and was revised further in consultation with the NPWS to further reduce the impact on the cSAC.
4.5 Alternative Sites for Intake Works and Pumping Station
Three sites were identified as follow: -
· Site No. 1 – Figure 4.9 on the south-eastern part of the lake.
· Site No. 2 – Figure 4.9 shows this located in the same area as Site No. 1, but nearer to the access road and further away from the dystrophic pool which contains habitats which are listed for the Connemara Bog Complex SAC.
· Site No. 3 – Is the location of the proposed regulating weir and the proposed site of intake works.
The EIS refers to the evaluations carried out and state that the access road to the existing boat slip would give access to Site No. 1 or 2 and would need to be upgraded. A new access road would be required for Site No. 3 which would be the same access road required for the regulating weir. In relation to the economic evaluation, the EIS states the cost of construction of the access road would be higher for Site No. 3, but the overall length of rising main required would be reduced.
In relation to ecology, the impact on the small dystrophic pool is greatest for Site No. 1 and lesser for Site No. 2, while for landscape, the pumping station would be less visible from the road than for Site No. 1. In relation to Site No. 3, the EIS states the ecological impact would be reduced, as the rising main would be laid almost entirely outside of the cSAC. Site No. 3 could result in the permanent loss and/or temporary disturbance of bog, heath and flush
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habitats on both banks of the Cashla River downstream of the existing regulating weir. In relation to landscape, Site No. 3 would have negative impacts, but they would be extremely localised and contained within the steep banks of the river.
Section 4.6.4 sets out the choice of site for the intake works and pumping station and the EIS states that based on technical, economical and environmental criteria, Site No. 3 is the preferred option.
4.6 Alternative Sites for Reservoirs
The existing reservoir at Glenmore is 455 m3 capacity and is located 800 metres to the east of Carraroe village. The EIS states that a new reservoir cell of 1,700 m3 with a TWL of 62.3 mOD is proposed for a site adjacent to the existing reservoir. It states that the access to the site needs to be improved, as a vehicular access is not possible at present. The EIS notes that this reservoir site is outside the boundary of the SAC and states that no alternative sites were examined as the existing reservoir was on the site and the majority of the land was already in ownership of Galway County Council. It states no significant environmental impacts are anticipated, as the reservoir would be constructed adjacent to the existing one.
The EIS describes the choice of location for a reservoir at Lettermore and states this would be at 58.3 mOD with a capacity of 1,000 m3. It is noted that this reservoir not in the Phase 1 proposal.
In relation to Rosmuc Reservoir, this is stated to be located at Glencoh with a 3 TWL of 63 metres OD and a proposed capacity of 500 m . The first site examined was that adjacent to the existing reservoir, but it was discovered that the proposed reservoir footprint covered an area of Annex 1 habitat type (Ref. 5130) “Juniperus Communis on heaths or calcareous grasslands”. Alternative site referred to as No. 2 was examined which was off a boreen servicing residential development east of the church and it is stated that this site is elevated and not well screened, but is the preferred location for the Rosmuc Reservoir, given that the Site No. 1 showed the presence of heath with juniper. The two alternative Rosmuc sites are shown in Figure 4.11.
A “do-nothing-scenario” is referred to in the EIS and this is not recommended, as it is stated a new water supply scheme is urgently required in the Carraroe area.
5.0 WATER QUALITY
Chapter 5 of the EIS deals with the potential impacts of the proposed Costelloe Regional Water Supply Scheme on water quality.
The description of the study area is that it covers 87 km2 and contains 22 lakes with soil in the catchment being dominated by blanket peat overlying granite.
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The EIS states that all water bodies which could be directly or indirectly affected are assessed as part of the appraisal. It states only streams which were shown on the discovery series maps were subjected to detailed assessment. Existing information reviewed included EPA Reports on water quality. The EIS states that a field water quality study was carried out in 2006. It notes that dissolved oxygen and conductivity were measured on site during the survey, while samples were analysed in relation to PH, alkalinity, turbidity, nitrate, nitrite, ammonia, orthophosphate and suspended solids.
Table 5.1 gives the location of the three water quality survey sites located at Cashla Bridge, at Glenicmurrin Lough outflow and at the eastern shore of Glenicmurrin Lough. The EIS gives details of the survey which included macro invertebrate surveys and biological river quality classification. Table 5.3 indicates the parameters determined for chemical analyses in the surface water samples.
In dealing with the receiving environment, the EIS notes that all the affected catchments are located in EPA Hydrometric Area No. 31. The EIS describes the water bodies affected by the Regional Water Supply Scheme and notes the areas where rising mains and gravity mains would cross these water bodies. Table 5.4 indicates the Q-Value at Cashla Bridge which has been consistently either 4 or 4 – 5 between 1986 and 2003. Table 5.5 gives the chemical water values on the Cashla River from 2001 to 2003 for a variety of parameters. It notes that none of the results obtained during the survey were considered to be elevated and these are indicated in Table 5.6. In Table 5.7 the results of the biological water quality assessment are indicated and it is noted that the site located downstream of the Lough outflow was rated as being slightly polluted (Q 3-4). The EIS states the source of the pollution is unknown, but could be a result of local agricultural activities.
Section 5.3 sets out the characteristics of the proposal and includes reference to storage reservoirs at Glenmore, Lettermore and Rosmuc. This description does not differentiate between the Phase 1 and Phase 2 proposals.
Section 5.4 deals with potential impacts and sets out the mitigation required in relation to construction activity. The potential impact from leakage of fuels in relation to the regulation weir is noted, as is the potential for suspended solids due to run-off. The impacts arising from the intake works and the water treatment works are also discussed.
The EIS describes the construction of reservoirs and pipelines and their potential impacts and notes that mitigation measures include restrictions and refuelling, careful management of trench digging and waste management.
In relation to operation, the EIS states there would be no foreseeable water quality issues arising. ( It is noted that the EIS does not mention any potential impact from supernatant liquid arising from the water treatment works at Cashla.)
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In relation to maintenance, the EIS states that the regulating weir may require in-stream works and this could involve dredging of settled material. It states that the build up of materials near the intake is not expected to be a significant problem. It states also that the reservoirs would need both routine and unplanned maintenance and care would be required to be taken in relation to spillage and contamination with suspended solids.
Section 5.5 deals with mitigation which include the following: -
· Carrying out of work near Glenicmurrin Lough during dryer months.
· Retaining a buffer area of existing vegetation along the boundary of all aquatic areas, where possible.
· Diversion of runoff from excavated areas.
· Containment of runoff from access roads.
· Minimisation of in-stream work.
· Method Statement for managing site runoff to be prepared and agreed with the NPWS/WRFB in relation to the access road.
· Excavated materials from raw water rising mains to be stored in bunded areas.
· Cleansing agents to be disposed from the site with appropriate permits.
6.0 HYDROLOGY – (EIS PAGES 88 – 93 AND FIGURE 6.1)
The EIS explains the concepts of a compensation flow which is described as the flow from an impoundment into a downstream watercourse to provide flow sufficient to meet the ecological, recreational and infrastructural requirements of that watercourse. It also notes the use of the term control band to describe the range of levels between which it is proposed to maintain lake levels for water supply purposes.
The source assessment used data from the EPA gauges from July 1976 to January 2003. It states that the minimum outflow from Glenicmurrin Lake was 0.074 m3/s during the period and the 95-percentile outflow was 0.317 m3/s. The mean or average outflow is given as 2.68 m3/s and the median or 50-percentile outflow is stated to be 1.84 m3/s.
The EIS refers to a source assessment report and states that a more detailed analysis of the affect of the Phase 1 abstraction and lake regulation on the flows in the Cashla River was carried out. It states the system was modelled for an abstraction of the 3,600 m3/d and it was found that a minimum
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compensation of 0.15 m3/s could be guaranteed across the entire year. It stated it was also found that when the previous days’ average flow to the lake is greater than 0.5 m3/s, outflow could be increased to 50% of the previous days average flow.
Describing the receiving environment, the EIS states the upstream catchment is approximately 67 km2 and contains more than 50 lakes between 26 mOD on Glenicmurrin Lake and at over 220 mOD at Lake Nahoulartia. It notes the lake sizes range from 200 to 1 million m2.
The EIS states that the peat is the predominant soil and is quite impermeable, but can act as a sponge after a dry spell. It notes that the river including the Lough is a fishery managed by the Costelloe and Fermoyle Fisheries Company and the 1978 agreement for the abstraction of 3,640 m3/d with storage on a 600 mm band between the levels of 25.75 mOD and 26.35 mOD was not progressed further at the time.
Section 6.3 sets out the characteristics of the proposal and states that the control of the impoundment would be from springtime to late autumn. It notes that winter levels on the lake are regularly 26.75 mOD which is 0.4 metres above the control band top level. Figure 6.1 indicates the levels in the lake and notes that the operation of the control would have happened after May 1st in 1994 and 1996 and prior to May 1st in 1995.
Section 6.4 describes potential impacts and notes that the lake levels during the proposed control period would be generally higher than it would be without the control. It notes that this would give less attenuation for summer floods and that the lake would also cover slightly more land during the summer than it would without the regulating weir. It states that the Phase 1 abstraction volume would be 2% approximately of the medium flow and this would be a permanent slight positive impact, as it would provide extra attenuation for winter flows. It states that the lake levels during both summer and winter periods would remain within the current and natural range of variation of levels on the lake.
It states that the proposed regulating weir would have a fish pass to which compensation water would be released into the river. It states that from a hydrological point of view, this would be considered a permanent noticeable neutral impact. It states that during very dry spells when the natural flow in the river would be very low, the compensation flow would be greater than that flow which would otherwise occur, and this would result in a slight positive impact.
The EIS states that the proposed scheme would amalgamate seven existing schemes of which five would be abandoned. (This appears to relate to the combination of Phase 1 and Phase 2 of the proposal).
Section 6.5 refers to mitigation measures and states that a control strategy would be put in place with the operators of the regulating weir to ensure that both water levels in Glenicmurrin Lough and flows into the lower Cashla
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River were managed to reduce the negative impacts associated with the regulation. It states that details of the control strategy would be communicated to both the operators of the private fishery of the lake and the WRFB.
Figure 6.1A is included after Page 93 of the EIS and indicates the catchment boundary.
7.0 FLORA AND FAUNA – (Excluding Mitigation) :-- (EIS PAGES 94 – 135)
In Section 7.1 the introduction states that 10 relevant bodies were consulted in the preparation of the section on flora and fauna. It notes that a desk study and field studies were carried out and specific surveys of the Option 4 treatment plant selection and Site No. 3 of the intake works was undertaken in April 2007. The EIS states that a river corridor study and a quantative and qualitative electrical fishing survey were carried out. It also states that a gill netting survey was carried out in Glenicmurrin Lough in June 2006 and notes that this was a modified version to minimise the likelihood of sea trout mortalities. Surveys were carried out for macro invertebrates in the river and in the lake and it was established also that the Annex II species of the pearl mussel was not present in the Cashla River.
The bird study was carried out in June 2006 and April 2007 and the mammal survey included a bat activity survey and there were also surveys for amphibians, reptiles and terrestrial invertebrates.
The criteria for ecological impact were listed on a seven-point scale and this is discussed in detail in Appendix 3A of the EIS.
Section 7.2 describes the receiving environment with particular reference to the SAC’s which are the Connemara Bog Complex and the Kilkieran Bay and Islands. It notes that Greatman’s Bay and Kilkieran Bay have extensive maerl beds.
It notes that nine plant species legally protected under the flora (protection) order of 1999 occur within the Connemara Bog Complex PcSAC, but none of the plant species were found during the survey. It notes that a list of plant species recorded within the study areas is provided in the technical report in Appendix 3A.
In relation to the fisheries and aquatic fauna, the EIS describes Glenicmurrin Lough as a nutrient poor and acid oligotrophic lake (FL2) located 1.5 kilometres west of the village of Glenicmurrin. It states the Lough is currently regulated for fishery management by the Costelloe and Fermoyle Fisheries Company Limited. The evaluation given in the EIS is that it is a PcSAC, a major salmonid fishery and home to the rare fish species of Arctic Char. It notes that it is therefore of international importance.
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The Cashla River is described as being 4 kilometres long from Glenicmurrin Lough to Clynagh Bay and it is tidal below Cashla Bridge. It is described as being of major amenity fishery value and of international importance. The EIS notes that the other aquatic areas would be directly affected by watermains, as the crossing of watercourses would take place at existing road crossings.
In relation to fisheries, the EIS states that the Costelloe and Fermoyle Fishery is a renowned sea trout fishery and consists of the Cashla River, Glenicmurrin Lough and a number of other lakes in the catchment. It notes that the Glenicmurrin Lough is sometimes referred to as the Costelloe Lake, as together with the out-flowing river, it forms the separate fishery of Costelloe. It notes the rest of Loughs upstream of the system make up the Fermoyle Fishery.
The EIS refers to Marine Institute Fish Count Data, which was available since 1993, and notes that the key period for upstream migrating sea trout and salmon is the period June to July. It states that downstream runs of smolts, kelts and finnock would require suitable water conditions and unimpeded access. The EIS states that to ensure the fish migrations on the river are not significantly impacted by the scheme, a fish pass would be provided at the proposed regulating weir and that no regulation of the lake or river would be carried out during the period October to April inclusive.
The Central Fisheries Board (CFB) are stated to have undertaken a number of assessments since 1994 on the Cashla River and the results of surveys are contained in Appendix 3A.
Section 7.2.2.4 refers to the Arctic Char and states that it considered as being a fish of high conservation importance. It states it does not have any particular designations or form of conservation status and a survey undertaken in June 2005 confirmed the species and 12 specimens were captured in three-gill nets under the authorisation from the DCMNR and WRFB. The results of that survey are carried out in the main technical report in Appendix 3A.
Table 7.1 describes the water bodies affected by the scheme and these include areas involved in Phase 2 of the scheme. Table 7.2 describes the water bodies of the Costelloe and Fermoyle Fishery. Table 7.3 gives the status of aquatic fauna listed in the Habitats Directive within Hydrometric Area 31.
It is noted that in the Cashla River, only the otter is listed as being present, while the Atlantic salmon is listed as being common and the status in Hydrometric Area 31 indicates the pearl mussel as being present, the Atlantic salmon as being common and the otter as being present.
It is noted that it is currently illegal to kill sea trout and a state license is required for sea trout fishing. The EIS states the sea trout have a complex lifecycle which leaves them vulnerable to impacts on fish passage, water flows and aquatic habitats.
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Section 7.2.2.6 describes the marine ecology, including oysters and burrowing anemone in Kilkieran Bay and the presence of six species of whales and dolphins adjacent to the study area is also noted.
Table 7.4 sets out the general characteristics of the lower Cashla River and it gives the mean annual flow as 2.67 m3/s with a flow range of 0.07 – 20.20 m3/s. Table 7.5 gives the general characteristics of Glenicmurrin Lough which has a maximum depth of more than 40 metres. Table 7.6 gives the results of the electro fishing survey of June 2006 at three sites and indicates presence of minnow, eel and salmon.
The EIS refers to the gill netting survey of June 2006 for Arctic Char. It states that Arctic Char and brown trout were recorded in both the benthic and pelagic gill nets. It notes that from the damage to the fish and the nets that there was a significant population of eels in the Lough. It notes that on-going monitoring of char populations in the lake would be undertaken during the construction phase and following commissioning of the scheme. The EIS states that the development had been carefully designed to ensure that there would be no impacts on the fish species during the construction and operation of the scheme. It states that seasonal constraints would be put on construction works would ensure that no impacts on Char occur. It states that during the operational phase, Char would be protected by ensuring that no regulation of the lake would occur during the times when Char were spawning or during their early life history stages which was October to May. It states that the provision of a passive intake screen would avoid entrapment of Char and other fish in the lake intake.
It states that the results of the on-site macro invertebrate study indicated that no rare or protected species were recorded during the survey. It states the community present at the lake site was a typical oligotrophic lake community and no pearl mussels occurred in the Cashla River.
Section 7.2.3 deals with flora and fauna and it is noted that in Table 7.7, the habitat types are recorded and listed. It is noted that Table 7.8 gives a summary of habitats with botanical interest for specific sites. It states that 32 different habitat types were recorded during the survey which reflects the high bio-diversity found in that part of County Galway. It states the habitats range from highly modified areas, such as buildings, houses and gardens to moderately diverse areas of semi-improved grassland to less modified natural habitats, such as blanket bog, heath, rivers, lakes, woodland, scrub and coastal habitats and also to the almost pristine marine habitats. It states much of the blanket bog/heath habitats are within areas of commonage and are subject to varying degrees of grazing pressure by sheep and to a lesser extent, cattle.
The terrestrial mammals noted include the hedgehog, pigmy shrew, rabbit, Irish hare, wood mouse, house mouse, brown rat, red fox, Irish stoat, American mink, badger, otter and grey, common and harbour seals. It notes that no evidence of otter activity was recorded and that the otter is listed in Annex II of the EU Habitats Directive. It notes however that otters are known to present in Glenicmurrin Lough and the Cashla River.
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The EIS states that no bat species had been previously recorded from the general study area, but the common and soprano pippistrelle bats were recorded during the survey carried out in relation to the scheme. It notes that although the marsh fritillary occurs on the Connemara Bog Complex, it had not been observed in the study, but it could be assumed that it successfully inhabits the area. In relation to birds, the EIS notes the importance of Kilkieran Bay which is to the west of the study area in relation to colonies of seabirds. It states that the study found that a very low-density and diversity of bird species were recorded in the affected areas.
Paragraph 7.3 gives the characteristics of the proposal which noted the requirement to install a regulating weir on the Cashla River and the provision of intake works and a pumping station at the outflow from Glenicmurrin Lough and also the construction of reservoirs and the treatment plant.
Potential impacts are described in Section 7.4 and notes the impacts could include drawdown of the lake, reduced water flows in the river or release of deleterious substances during the construction phase. It notes the potential impact from entrapment of fish at the intake and the construction induced impacts on terrestrial ecology. It notes that a total area of the SAC is 70,324 hectares (taking the two SAC’s combined – Connemara Bog complex is over 49,000 hectares) and the total area of land required for the project elements including the access road, regulating weir and pumping station is 1.97 hectares.
The EIS states that the main potential impact would be related to the proposed regulation works of the lake and river and with mitigation, the potential impact could be reduced to a slight negative impact. It describes a slight impact as a change in the ecology of the affected site which has “noticeable ecological consequences, but these are not considered to significantly affect the distribution and/or abundance of species or habitats of conservation importance”. It describes the impact on terrestrial habitats as being imperceptible with suitable mitigation.
Section 7.4.1.2 describes Kilkieran Bay and Islands cSAC and notes that this designated area lies mainly outside the boundaries of the proposed regional water scheme. It notes that the designated area does lie adjacent to the proposed watermains for several kilometres. (This mainly relates to works outside of Phase 1 of the proposal).
Section 7.4.2 describes the fisheries and aquatic ecology and states that potential impacts on the water quality would arise from suspended solids during construction. It describes the impact as slight-negative after mitigation. It notes that moderate to substantial impacts would be possible in relation to other pollutants and the EIS states that potential impacts will be reduced to slight-negative with mitigation.
The EIS refers to potential interference with fish migration and these with both the construction and operational phases. It notes that moderate to substantial
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impacts would be possible during construction and mitigation would reduce these to imperceptible. Angling is stated to be potentially impacted during one angling season and the extent of the impact is predicted to be slight-negative. It notes that no in-stream/in-lake works would be undertaken during the period October to April to avoid impact on trout and salmon spawning or on Arctic Char.
In relation to the operational phase, the EIS describes a potential impact arising from a delay of fish in the river due to the presence of a weir or altered flow regimes. It states that mitigation measures would include a modern fish pass, compensation flows and freshets and no winter regulations. It states that with this mitigation, the impact is predicted to be slight-negative. (The fish pass is not described in any more detail than as being “modern”).
In relation to salmonid spawning, the EIS notes that this takes place during the period October to January and Fry would not emerge until April/May. It notes that juvenile fish stay in the river for a period of one to three years and it is predicted that no impact on salmonid spawning and production is expected with the mitigation measures provided.
In relation to potential hydro-ecological impacts of reduced summer flows, the EIS states that the mitigation measures proposed would reduce the impacts on stream hydro-ecology to slight-negative. It states that during extreme drought events, the provision of a guaranteed compensation flow would be a slight positive impact.
The importance of free access downstream for out-migrating fish is noted and the EIS states that ongoing monitoring of fish movements past the weir would be undertaken following the commissioning of the scheme. In relation to Arctic Char, it notes the regulation of the lake would only take place during the summer period when Char would be less sensitive. It states the area of the proposed intake is thought to be an important area for Char and it also states that ongoing monitoring of Char spawning and recruitment in the lake has been included in the proposal.
In relation to other aquatic areas, the EIS states that mitigation measures have been provided to reduce those impacts along the distribution network and the impacts are assessed as being imperceptible.
Section 7.4.3 describes flora and habitats. It states that during construction, there would be slight negative impacts from the construction of the regulating weir, intake works and access roadway. In particular, disturbance to the bog and heath habitats would be moderate to substantial negative. It states the release of peat or other sediments into the Lough during construction would be of moderate to substantial significance. It states that impacts on rare or protected aquatic plant species would not occur, as the reduction in lake level would be greater than that which occurs naturally.
In relation to the treatment plant at Cashla, it notes a loss of neutral-acid dry grassland from the construction, but this loss is described as having
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imperceptible negative impact. The EIS notes the movement of the Rosmuc reservoir from the original site to avoid the most sensitive areas involving juniper heath. The Glenmore reservoir construction is stated to have slight negative significance and in relation to landscaping, the EIS states that use of a non-native plant species should be avoided. The EIS also describes the potential impacts from dumping of waste arising from water main construction and states that the impact of the lake flow-gauging site would be considered insignificant. In relation to the operational phase, the compensation flow is stated to be designed to mimic natural flow conditions in the river and this would ensure that impacts on the ecology of the river are minimised and it is noted that lake levels would be regulated only from late spring to autumn and would be maintained within existing natural ranges.
In relation to the treatment works at Cashla, it is noted that the daily operation of the water treatment works would involve the discharge of wash water to the aquatic environment. It notes that this would have the potential to impact slightly on flora and habitats if not properly disposed of and regulated. (There is no reference to the quality of the wash-water in the EIS). No anticipated operational impacts are expected from the reservoirs.
Section 7.4.4 describes maintenance and notes the requirements for correct maintenance of water mains, the regulating weir and the intake works. It notes that construction debris and other associated debris could become an impact if not handled in an appropriate manner.
The maintenance of the treatment plant at Cashla is stated to include cleaning blockages, removing sedimentation and flushing. It states that plant maintenance should be scheduled to identify elements that require maintenance and determine the optimum frequency of attention. It notes that these practices may have chemical or other bi-products which may leak into the nearby designated area. It states that provided mitigation measures are followed and the treatment facility is maintained as a working treatment plant according to Irish and European Standards, the maintenance should be minimal and have an imperceptible impact.
The EIS states that in respect of terrestrial fauna, significant populations of mammals are not present in any of the affected areas and the impacts on mammals during construction, operation and maintenance would be imperceptible, as would the impacts on birds.
Section 7.4.6 describes residual impacts from Pages 131 to 135. It states that residual impacts on aquatic ecology would be slight negative for the Connemara Bog Complex cSAC and would be imperceptible for Kilkieran Bay and Islands cSAC. In relation to fisheries and aquatic ecology, the residual impacts are described which have been previously discussed at Section 7.4.2. It states that the construction phase would have imperceptible negative impact on fish migration and the impact on Arctic Char and on trout and salmon spawning would also be either none or imperceptible negative.
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Relating to the operational phase, the monitoring programme previously noted is stated to be required in order to confirm and monitor the impacts and to allow the flow regimes/fish paths to be altered to ensure efficient passage of fish at the site. It notes that as no river regulation is undertaken during October to April, this would ensure the spawning and early life history stages of salmonid spawning in the Cashla River are fully protected. It states that residual impacts are therefore assessed as none.
In relation to potential hydro-ecological impacts, lower flows would have a slight negative impact, but the minimum compensation flow during extreme low water conditions would have a slight positive impact on stream ecology and fisheries. The impact on out-migrating fish is described as being imperceptible negative and that on Char is described as being none to imperceptible, but ongoing monitoring of Char populations would be undertaken to confirm this.
In relation to flora and habitats, the loss of heath and bog habitats at the control house site is described as slight negative and the same rating is given to the Rosmuc and Glenmore reservoirs, while the treatment plant at Cashla is described as having imperceptible negative impact.
8.0 MITIGATION on Flora and Fauna (SECTION 7.5, PAGES 136 – 144)
In Section 7.5.1 in relation to designated areas, the EIS states that the measures outlined in the remainder of the chapter to protect flora, habitats and aquatic ecology would also protect the designated areas. It states that the measures provided in the report are general mitigation measures only and detailed measure statements would be provided for approval by NPWS and the WRFB at pre-construction stage.
In relation to aquatic ecology, the EIS notes that mitigation measures are addressed in detail in the water quality chapter and are discussed in general in Section 7.5.2. It notes suspended solids are the main potential contaminant from various forms of works and silt-laden water would be controlled as follows: -
· Excavation to be carried out during drier months.
· Retention of existing vegetation as far as possible along the lake and river borders.
· Use of geo-textile matt on disturbed areas.
· Diversion of run-off from excavated areas.
· Suitable site vehicles would be used with a ban on quad bikes.
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The EIS states that eroded sediments would be retained on site and notes that in-lake excavation works could result in local disturbance of lake substrates. In relation to lake regulation it repeats that the lake would not be regulated during the period autumn to late spring and notes that it would not be assumed that because the lowest recorded level of the lake was 25.56 mOD that no ecological impacts would occur and therefore the abstraction order would ensure that the lake levels were maintained within the band of 25.75 – 26.35 metres OD. The EIS states that the mitigation measures would protect shoreline ecology, Arctic Char, spawning sea trout and also rod fishery.
In relation to the Cashla River, the proposal is that the regulated river flow would be kept within the existing natural fluctuating band and the compensation flow is as set out earlier in the EIS as follows: -
· Minimum compensation 0.15m3/s in the entire year.
· For flows in excess of 0.5m3/s outflow would be 50% of the previous days average inflow.
· Towards the top of the control band, the outflow would be greater than half the average inflow.
The EIS states that subject to available water freshets (controlled additional flow) would be provided when necessary to encourage fish to move upstream or downstream. It states the proposed flow regime would mimic natural spate conditions, but would protect the river from extreme low flows. This is stated to be a substantial positive impact. It states that the responses of sea trout and salmon movements during and following the freshets would be monitored at the proposed regulating weir using a fish surveillance system. This would occur for a period of three years.
The EIS states that the protection of migratory salmonids would be achieved by the use of a modern fish pass of the pool type with associated eel pass which would be approved by the Engineering Section of the DCMNR (*see SI 707 of 2007 for change in title) and the WRFB and that this would be provided at the proposed regulating weir. It states the responses of sea trout and salmon movements would be monitored using a fish surveillance system for a period of three years following the commissioning of the scheme. In relation to salmonids spawning in the Cashla River, the EIS states that no regulation of the system would be during the period autumn to late spring and this would ensure that the spawning and early life history stages of sea trout and salmon would not be affected by the proposed development. It states that the measures outlined would also protect the Cashla River Rod Fishery.
In relation to eels, the EIS states that a modern eel pass of ramp and brush type approved by the Engineering Section of the DCMNR and the WRFB would be provided at the proposed regulating weir and would be integrated into the proposed salmonid pass.
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Section 7.5.3 deals with flora and habitats and notes that the Costelloe RWSS would have some slight to moderate negative impacts on the study area which could be made less with various mitigations. It states that the proposed permanent structures may require bog-mats or temporary roads for access to avoid causing irreparable damage. It states permanent structures and foundations would be backfilled as the work is done with locally excavated materials.
In relation to the regulating weir, the intake works and the access roadway, the EIS states that it expected following the works, that the vegetation would recover within two seasons. It states the control house would be constructed downstream of the existing regulating weir and notes that the neighbouring habitats of blanket bog and wet and dry heath are somewhat damaged from overgrazing and trampling by cattle. It states that as much of the work would be carried out from the right or west side of the Cashla River and construction work would be confined to a small an area as possible on both banks to minimise impacts on the SAC. It states that a track way would be carefully designed to provide the access road. It states the roadway would follow the driest and/or currently most disturbed area of bog as mapped by the ecologist.
In relation to the treatment plant at Cashla, it states that local biodiversity would benefit from the removal of the conifer tree line/hedgerow and replacement with a hedgerow or tree-line of native species.
The siting of the Rosmuc reservoir to the east of the original proposed site is again noted and in relation to the Glenmore Reservoir, it states that no mitigation is required in relation to grassland habitat at the site. Landscaping is proposed where necessary, using local materials. It states that restoration of peat areas would be covered by a method statement which would be produced at the pre-construction phase. It states also that the method statement would be agreed in advance with NPWS.
In relation to terrestrial fauna and invertebrates, it states no work should take place near Glenicmurrin Lake during the winter months to ensure that no disturbance of wintering birds takes place.
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8.0 HUMAN BEINGS – PUBLIC HEALTH (EIS PAGES 146 – 159)
The EIS states that the objective of the assessment was to examine baseline public health in relation to existing water supply within the study area and to assess the potential impacts of the proposed development on public health in general. In dealing with the receiving environment, it states that the assessment comprises liaison with the Water Services and Environment Sections of Galway County Council, a review of the relevant County Council Drinking and Surface Water Quality Data and the review of relevant EPA Manuals, Literature and Legislation. In describing the background, the EIS refers to the complete area including Phase 1 and Phase 2 of the RWSS. It notes the current supplies and also the reports of the EU Committee and Petitions of April 28th, 2003.
Section 8.2.3 refers to drinking water legislation and notes the EC Drinking Water Regulations of 2007 (SI No. 106 of 2007). These regulations are stated to update and revoke the EC Drinking Water Regulations of 2000 and transpose outstanding aspects of the EU Drinking Water Directive into Irish Law. It notes that the new regulations replicate the existing regulations and provide also for the significant additional provisions, namely: -
· EPA to supervise sanitary authority water supplies, but sanitary authorities to continue to supervise all other supplies.
· Actual monitoring of all supplies would continue to be a function of sanitary authorities, but the monitoring programmes would be subject to approval by the EPA.
· EPA would have powers of enforcement to ensure that sanitary authorities comply with their monitoring obligations.
· Supervisory authorities would be required to undertake periodic audits of all water supplies.
· Duty of the water supplier would be to inform consumers of remedial action taken.
· Supervisory authorities would have power of direct intervention.
· Intervention in the event of health risk would be subject to agreement with the Health Service Executive (HSE).
· Supervisory authorities required to keep a register of water supplies.
· Sanitary authorities required to keep up-to-date records on monitoring results and make them available to the public.
· Register/records may be kept in electronic format (e.g. website).
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· Water suppliers to maintain records of any incidences and make them available to the supervisory authority.
· Offence provisions now applied to all water suppliers.
· Additional offence provisions are included in relation to the failure to inform supervisory authorities of incidences, failure to maintain records and failure to keep internal pipe network and premises supplying water to the public safe.
The EIS summarises the regulations as having the following provisions: -
· Setting of standards in relation to the quality of water.
· Providing for temporary departures from the standard where there is no threat to human health and a requirement that information be made available to consumers in relation to various matters including water quality, exempted suppliers, departures granted, precautionary measures and remedial action in case of non-compliance supplies.
The EIS states that in relation to the seven public or group water supply schemes in the study area (not all of which are in the Group 1 proposal), an area in Rosmuc from Glencoh to Screeb along the R340 has a high concentration of housing without a mains water supply. Table 8.1 of the EIS gives details of the existing supplies.
Section 8.2.5 deals with the existing drinking water quality and Table 8.2 indicates the exceedances observed for the existing supplies. It states that a number of exceedances for iron and manganese have occurred in the Carraroe water supply scheme during the time period. It states that while iron has not exceeded the parametric values since 2001, manganese consistently exceeded the value in 2004 and 2005. It notes that both total and faecal coliforms exceeded parametric values at Rosmuc water supply scheme in 2004. It notes also that exceedences in iron, manganese and total coliforms were observed at Camus/Screeb GWS in the earlier part of the sampling period.
Section 8.2.5.2 refers to water quality at the proposed source. The EIS states that from Table 8.3 which presents recent chemical water quality results, the raw water quality form Glenicmurrin Lough “more or less complies with the parametric values outlined in the EC (Drinking Water) Regulations 2007 (SI 106 of 2007)”. It notes that pH at the lake outfall fell slightly below the indicated range during the first two sampling rounds, but was within the indicated range in the subsequent round.
It refers to the affects of exceeded parameters, in particular, manganese and iron and total and faecal coliforms. (There is no indication of testing for iron and manganese given in Table 8.3 and no coliform counts are given for the lake water in Chapter 8 of the EIS).
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The EIS refers to Cryptosporidium Risk Assessments and refers in particular to Appendix 5A, the results of which are summarised in Table 8.4. This table indicates that the current Carraroe Water Supply Scheme has a very high risk of Cryptosporidium, while Rosmuc is stated to have a moderate risk. Table 8.4 also indicates the situation for Tir an Fhia which is described as having a moderate risk. It is noted that Tir an Fhia is not included in the Phase 1 proposals. The EIS states that the risk assessment carried out on Glenicmurrin Lough and presented in full in Appendix 5B indicates that the treated water would fall within the low-risk category.
Section 8.4 deals with potential impacts and states that the existing schemes would be replaced by Phases 1 and 2 of the proposed Costelloe RWSS. It states that while the exact treatment method for the proposed works has not yet been established, based on the raw water quality data analysed, it was likely the treatment would consist of chemical dosing, including soda ash, alum and poly-electrolyte, settlement and filtration and sludge thickening. It notes that the raw water would be further subject to chlorination and fluoridation treatments which are statutory in public water supplies in Ireland.
The EIS states in Section 8.4.2 that an optimum quality drinking water would be provided for populations in the region, thereby having an overall positive impact on public health. (The EIS does not refer to schemes in Phase 2 which would appear to continue to require to rely on existing sources which include one indicated as having high Cryptosporidium risk).
Mitigation measures are referred to and it is recommended in the EIS that regular surface water monitoring would be undertaken and measures outlined in the Cryptosporidium risk assessment would be implemented.
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9.0 HUMAN BEINGS – SOCIO-ECONOMICS: - (EIS PAGES 160-174)
The EIS describes the receiving environment and includes the description of the entire Phase 1 and Phase 2 area which includes Gorumna Island, Lettermore Island and Lettermullen which are not included in the Phase 1 proposals. Table 9.1 gives the population of the study area as 5,462 in 2002 which is a 3.1% reduction from 1996. It analyses the percentage change for electoral districts in the Costelloe area in Table 9.2. It notes the average household size as having reduced from 3.14 to 2.94 by 2002. Table 9.3 gives the predicted population figures for the study area which are indicated to rise from 7,236 in 2003 to an estimated figure of 9,870 in 2024.
Table 9.4 gives the unemployment rate as 4.3% and lower than the national average with participation rate of 61% which is slightly less than the national average. Table 9.5 refers to the number of persons on the live register and Table 9.6 gives the breakdown by industrial group of persons aged 15 years and over for the State, for Connaught and for Galway excluding the City. Table 9.7 gives the economic status of persons in County Galway and Table 9.8 gives a breakdown of farm types in the study area.
Section 9.2.5 deals with tourism and amenities and estimates the revenue generated for Galway as €350 million in 2004 with a total number of visitors of over one million. The EIS notes the main tourist attractions in the Galway area and refers to the wide range of activities available and also refers to the blue flag beaches in Galway.
Section 9.2.6 deals with material assets and in Table 9.10 a summary of planning permissions granted for quarter 4 of 2005 for Galway County excluding the city is given. It states that it would be envisaged that the additional water supply may lead to an increase in the numbers of planning applications submitted to the Council for both residential and commercial development in the immediate area. It states this would impact on the existing rural landscape and visual amenity of the area.
The EIS notes that the Galway County Development Plan of 2003 – 2009 acknowledges, “that there is little spare capacity in relation to water supply in the study area”. Table 9.11 gives details of the Regional Water Supply Schemes in Galway and notes that the Council currently operates and maintains 50 public water supply schemes serving 12,200 households.
Section 9.2.6.3 deals with transportation and notes that the only public transport that serves the area is Bus Eireann which runs an eight-times daily service to Galway. The EIS refers to the County Galway Settlement Strategy and in Table 9.12 it notes that Carraroe is referred to as a service hub.
Section 9.4 deals with potential impacts and the EIS states that during construction there may be negative impacts on the population. It states that direct negative impacts on the population could relate to the construction phase, as it would result in disturbances to pedestrian and vehicle access. It
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says the impacts on the population would mainly be positive once the system has been put in place. It states that the effect on tourism would be positive.
Section 9.4.4 refers to the affects on Costelloe and Fermoyle Fisheries and refers to the fish hatchery downstream of the lake for which planning permission was granted in the mid-1980’s. It states that monitoring measures would be required to ensure that there was no impact on Costelloe and Fermoyle Fisheries. The EIS states that the regulating weir would have the impact of slightly reducing lands available for grazing for the surrounding landowners on the lake.
Section 9.5 deals with mitigation measures and states that these are proposed to ensure that residential amenity is maintained throughout the construction phase. It states that limiting working hours are between 08:00 a.m. and 6:00 p.m. with no works carried out on weekends and bank holidays would control the affect of the proposed RWSS on amenities and tourism in the study area.
Section 9.5.4 concludes that the impacts would be generally positive and there would however be some minor disturbances during construction.
It states that no monitoring measures are necessary in relation to the socio- economic aspects of the development.
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10.0 NOISE: - (EIS PAGES 175 – 185 AND FIGURES 10.1 – 10.5)
Pages 175 and 176 explain the acoustic terminology use and the noise criteria. Page 177 refers to the impacts of traffic noise and construction and industrial. It notes that a baseline noise survey was carried out in 2006 and 2007.
Table 10.1 indicates that five monitoring points were used of which one reference (N4) is at Lettermore and is not within Phase 1 of the scheme. The other points are adjacent to the proposed treatment works at Cashla, 650 metres from the regulating weir on the Cashla River, adjacent to the existing reservoir at Glenmore and approximately 700 metres from the proposed reservoir at Rosmuc. Table 10.2 gives the baseline noise monitoring results which indicate LAeq, one hour of 57.5 to 73.5 dBA. Page 180 describes the location and includes references to road traffic noise and the impact of continuous bird song, a braying donkey and a barking dog.
Section 10.3 describes the characteristics of the proposal and Section 10.4 refers to the potential impacts of the construction phase and includes calculations and prediction of construction noise. It identifies construction noise levels at a number of locations, namely
· H1 – residential dwelling nearest to the treatment works at Cashla.
· H2 – residential dwelling at Glenmore Reservoir.
· H3 – residential dwelling at Lettermore (not in Phase 1).
· H4 – residential dwelling nearest to Rosmuc Reservoir.
The predicted LAeq, one-hour noise levels are predicted to be between 52.9 and 62 for the relevant locations. The impacts involved in the construction of pipelines and from construction road traffic are described as being short-term in nature and significant noise impacts are predicted.
Section 10.5 relates to mitigation measures and states that all construction traffic would have effective well-maintained silencers. It recommends that a 2-metre high wooden acoustic barrier be erected along the south-western and south-eastern site boundaries (of the treatment works) for the duration of the construction phase. In relation to the operation phase, the EIS states that noise emissions at the site boundary would less than 45 dBA and there would be no night-time tonal noise emissions. The EIS states that all plant and equipment for raw water processing etc. would be regularly maintained to avoid tonal noise emissions at noise-sensitive locations.
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11.0 LANDSCAPE AND VISUAL: - (EIS PAGES 185 – 204 , FIGURES ` 11.1 – 11.9 AND FIGURES 6 AND 7)
Section 11.1 indicates the methodology used and describes the aspects of impact, significance criteria and terms used to describe the quality of change. It notes the information available was influenced by the choice of design , build and operate methodology and states that the assessment is based on a general understanding of the project rather than a detailed design which would be undertaken at a later stage.
Section 11.2 describes the existing environment and sets out the categories of landscape sensitivity rating. It notes that Figure 11.1 shows the scheme as being located between Classes 2, 3 and 4 which would be described as moderate, high and special for sensitivity ratings.
The EIS refers to the Galway County Development Plan, Policies 105, 108, 109 and 110 which relate to landscape sensitivity ratings and preservation of the character of the landscapes. It notes that in Policy 110, it states that in designated settlement centres that are located in Landscape Classes 3, 4 and 5, the preservation of scenic views would be a factor in determining development proposals.
In relation to development control, the classes into which the elements of the project fit are deemed to be Class 3 which referred to those with substantiated cases for a specific location and in compliance with settlement policies and Class 4 which is described as being restricted to essential residential needs of local householders and family farm businesses. The EIS states that the dam and abstraction works would be on the boundary between Classes 3 and 4, while the treatment works are reservoir at Glenmore would be Class 3 where the reservoir at Rosmuc would be Class 4.
In relation to the reservoirs, the EIS notes that they need to be sited at elevated locations, but that they are relatively small and are significantly amenable to mitigation. It states that it was felt there was no alternative to the dam, but alternative methods for access are considered and the requirement for a building on the site is reviewed.
On Page 190, the EIS examines the alternatives for the treatment works and notes the location of the reservoirs. In this respect, it is noted that while the Lettermore Reservoir is described, it is not within the Phase 1 proposal.
Page 191 describes the alternative options for the treatment works and clear water tanks. It notes that Options 2 and 3 are located in landscape sensitivity Class 3 areas. In relation to Option 4, which was the chosen option, it states that this presents none of the larger landscape issues that the other options involved. It states that the incorporation of the abstraction facility at the dam has the potential to increase landscape impacts, but should lead to a significant reduction in impacts arising from the omission of the abstraction facility and pump house from an exposed and attractive location (Options 1&2). It states that in landscape terms, Option 4 (in Cashla) offers significant advantages
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over the other options and reduces the potential impacts on the wider landscape and the sense of solitude characteristic of Connemara.
Section 11.3 describes the characteristics of the proposal and Section 11.4 deals with the potential affects and residual impacts. It breaks down the scheme components and states that the road access to the abstraction works would have a slight effect on landscape character and a negligible affect on views. It notes as elsewhere, the utilisation of bound gravel surface for access roads, rather than bitmac should be incorporated as a mitigation measure. Regarding the concrete dam, fish pass and the control house, the steep riverbanks are stated to provide screening and the elements would be stated to have a moderate affect on landscape character. In relation to views, the dam is stated to have negligible effects on wider views, while the control house would have a moderate effect on views within the immediate vicinity. The use of appropriate concrete finishes and local stone to clad walls is recommended as a mitigation measure.
On Page 195, the impact of the security fence to the dam and weir which is 2.4 metres in height is referred to. It states there would a negligible impact on the overall character of the area and a small impact on views. Use of a rigid wire mesh coloured black is recommended as a mitigation measure. In relation to the overall impact of the dam and associated works, the EIS states that both the views and character would be affected and there would be a slight negative effect on the isolated character of the area.
In relation to the treatment works at Cashla, the EIS states the access road is designed with natural curves to fit into the broken topography of the site. It proposes simple stone walls, similar to that currently on the site as a mitigation measure. The buildings are stated to have a slight affect on character and there would be a slight affect on views from roads on the residential properties in the immediate vicinity. It refers to an apartment building to the south-west of the site which would have limited views over the site, but notes that many of the views already include the industrial facilities to the east and north of the proposed development.
In relation to the buildings, the EIS states that the plant should be below an overall height of 13 metres OD and that finishes to buildings and related structures should be stone clad. It states that a substantial area of site should be mounded and planted with native species. The EIS states that the scale of the proposed development is largely domestic in scale there is ample scope to screen the development from sensitive receptors. It states that the Figure 11.8 was somewhat misleading as the digital model on which the analysis was taken does not take into account of local topographic features which would provide screening. (Figure 11.8 indicates that the works would be visible from an area north of Inveran to Rosmuc and also from high areas near Carraroe.)
In dealing with the reservoir at Glenmore, Figure 11.5 is referred to which indicates that due to the small size of the structure, it would be difficult to discern outside the distance of 2 kilometres. The EIS states that a curved top profile combined with a circular plan form would assist in softening the profile
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of the tank, when viewed from the surrounding landscape. The proposed mitigation measures would include careful design of the earthworks and provision of a substantial element of graded fill on the roof of the tank.
The description of the reservoir at Lettermore states that it will be difficult to screen or conceal. (It is noted that Phase 1 works does not include works at Lettermore).
In relation to the reservoir at Rosmuc, Figure 11.7 is referred to. The EIS states there would be a significant affect on views within the 5-kilometre radius chosen It states that as the tank is situated on a prominent location on elevated ground, good detailing and finishes would be required. It classes the overall impact as being moderate/negative on the landscape character and on views with a 2-kilometre radius.
Section 11.4.2 deals with construction impacts which include those arising from pipelines, access roads and the treatment works. In relation the construction of Glenmore Reservoir is predicted to have significant impact on the residential amenities of the adjoining house. In relation to secondary impacts, reference is made to overhead power lines and the EIS states that to reduce impact, the length of overhead lines should be kept to a minimum.
Section 11.4.4 deals with criteria for specific elements of the development and includes use of local aggregates rather than imported stone, rough finishes on concrete, use of simple structures with dark coloured roofs and stone finish on walls in general.
The EIS states that in relation to landscape and visual impacts in general, the individual elements have been carefully located and the design considered and where possible, modified to alleviate potential impacts. It repeats that the proposed reservoirs would give rise to local impacts by reason of their required location on elevated ground. It states that while the dam and abstraction works would have a significant affect on the immediate locality of the stream, the potential impacts are constrained by the adjoining topography and would not have any significant impact on the wider area.
The EIS states that provided the scheme is undertaken in line with the recommendations outlined and the works are carefully monitored during construction, there should not be an unacceptable impact on the landscape and character of the particular area of Connemara.
Figure 11.1 indicates the landscape sensitivity for the various locations. Figure 11.2 & 11.3 indicate the visibility of the clear water tanks for Option 2 and the water tower for Option 3. Figure 11.4 gives the visibility (ZVI Study) of the treatment works for Option 2. Figure 11.5 – 11.7 indicate the visibility of the reservoirs at Glenmore, Lettermore and Rosmuc. Figure 11.8 gives the visibility of the treatment works at Cashla and Figure 11.9 indicates the landscape treatment at the water treatment works. Figure 6 indicates the landscape value rating for County Galway and Figure 7 gives the landscape sensitivity rating for the county.
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12.0 CULTURAL HERITAGE: - (EIS PAGES 205 – 236 AND FIGURE 12.1)
The EIS states that the work relating to the terrestrial and underwater cultural heritage aspects of the scheme was undertaken by Moore Group on behalf of Tobin Consulting Engineers for Galway County Council. It notes that the section is divided into two component sections with one dealing with terrestrial cultural heritage and the other addressing the underwater cultural heritage.
The EIS sets out the study area and notes that the terrain is mainly comprised of blanket peat with lithosols of granite, sandstone and shallow glacial till. It sets out the legal background, the methodology which included reference to the Record of Monuments and Places (RMP) and the archaeological inventory of County Galway. Reference is also made to the National Museum topographical files, aerial photographs, Irish Excavations Database, the record of protected structures and other sources. It states that the field inspection assessed the topographical context and archaeological potential of the development areas and the potential impact of the proposed scheme. It stated that it also sought to identify any low-visibility archaeological features with little surface expression.
Section 12.2 describes the receiving environment and gives the archaeological and historical background of County Galway. It traces the Mesolithic or Middle Stone Age Period of 9,000 years ago through the megalithic monuments of the Neolithic period and includes reference to the Bronze Age, the Iron Age and early historic period.
The EIS refers to the place name evidence and notes that Glenicmurrin derives from the name Gleann nic Muireann being the Glen of the Daughter of Muireann. The EIS also on Page 212/213 gives the meaning of the various other townlands. Table 12.2 gives the archaeological monuments in the vicinity of the developments and a total of 59 monuments are listed. In relation to the topographical files of the National Museum, the EIS lists recorded finds from the area in Appendix 6B. It notes that aerial photographs highlighted a number of abnormalities but closer inspection during the site visits verified they were of no archaeological significance.
The EIS details the cartographic evidence and refers to the first edition ordnance survey 6-inch series and notes the various features and the indications of their date of construction.
The EIS notes that the National Inventory of Architectural Heritage (NIAH) for County Galway has not been completed and it is noted that the record of protected structures are listed in Appendix 6C. In relation to site inspection, it is stated to have been carried out in January 2006 and the underwater assessment in March 2006. It states that each of the recorded monuments in proximity to the pipeline route was visited, as well as a walkover of the entire length of the route. It is noted there are several river crossings and the EIS
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states there is possibility for the recovery of archaeological material at those sites.
Referring to the area between Glenicmurrin Lough and Costelloe Village, it states the pipeline route passes along a rough un-surfaced road as it travels towards Costelloe. The pipeline route from Screeb to Rosmuc is along the R340. It notes the pipeline route includes crossing of Screeb Bridge. It states that Glencoh has a number of buildings of architectural significance. It describes the area around the Rosmuc Reservoir and notes that Plates 9-19 of Appendix 6D illustrates the items referred to.
The EIS describes the area from Costelloe to Gorumna Island and Lettermore.
The field survey of the route from Costelloe to Carraroe was also carried out and Clynagh Bridge, which is a single arch road bridge, is noted. Referring to the reservoir site at Glenmore in Carraroe, it notes that Plates 39-45 of Appendix 6D are relevant.
The EIS describes the underwater assessment at Glenicmurrin Lough and sets out the methodology used. It gives the historical background to Glenicmurrin Lough and Map 12.1 is an extract from Map No. 79 for Galway, Records of Monuments and Places from 1899.
The EIS states the proposed regulating weir, intake works and pumping station are to be situated downstream of an existing, but now derelict lough and weir. It states the existing features consist of a lough gate with an additional overflow weir, and this appears to be modern in construction. It also states that there is a ruined building (05G32-18) to the west of the river. The EIS on Page 225/226 describes the riverbed from the diver visual survey. It states the metal detection survey of the development area did not record presence of any archaeological ferrous metal and the two metallic contacts in the survey were seen to be modern.
Section 12.3 describes the characteristics of the proposal which is contained in previous section and Section 12.4 describes the potential impacts. It notes that the RMP site locations are shown in Figure 12.1 at the end of the section. The tables on Page 228 – 232 give details of the RMP sites and the Greenfield sites. The description of potential impacts in these tables is mainly the potential for archaeological deposits to be uncovered or destroyed during construction.
Section 12.5 describes mitigation measures and notes that the topsoil of the region is shallow below which is granite bedrock and this indicates that archaeological deposits below a depth of approximately 1 metre are unlikely. The EIS recommends that groundwork be subject to regular inspections and that in the vicinity of recorded monuments, a suitably qualified archaeologist would monitor all excavation works. It also recommends that care should be taken not to alter or damage any buildings or structures of historical and local significance which include bridges, quays, vernacular buildings, rubble stone walls and water pumps. The table on Pages 234 and 235 gives details of the
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mitigation measures in the proximity of four RMP sites, six other features, a graveyard, a house and a number of quays. The EIS also refers to mitigation measures involving monitoring of topsoil and peat stripping at a number of Greenfield sites.
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13.0 SOILS – GEOLOGY: - (EIS PAGES 237 – 248)
The EIS states the information contained in the chapter was concerned with the description of the existing geological character of the site and that the section also addressed the hydro-geological character of the site as the groundwater environment is intrinsically linked to the geological material through which it flows. It sets out the study methodology and notes the protocol followed which included assessing published information, preliminary site investigations, examination of information from the EPA and a site walkover carried out in May 2006 and April 2007.
In relation to the receiving environment, the EIS states that the visual assessment of the Water Treatment Works site at Cashla indicates that shallow soils occur across the entire site. In relation to the regulating weir site access road, it is stated that this is approximately 450 metres in length on which 12 granite outcrops are present. The bedrock geology is described as Galway Granite deposited during the late Silurian to early Devonian Period of approximately 400 million years ago. Table 13.1 indicates the granite types at the different locations.
In Section 13.2.4 the EIS refers to hydrogeology. It notes that a fault is interpreted by the GSI Geological Map Sheet 10 to be present in the southern region of the Glenicmurrin Lough which could result in a higher permeability zone. It states the fault is located close to the area of the proposed regulating weir.
The EIS describes the two layers of natural bog, namely the acrotelm and the underlying catotelm. It states that due to the excavation of artificial drainage channels and historical peat cutting, the drainage system has been altered.
The aquifer classification is given as poor and is generally unproductive in the Galway Granites.
Section 13.2.6 relates to surface water and it states that the biological analyses of the surface waters indicates that surface water quality is consistently rated as satisfactory based on sampling results from 1986 to 2003. It states the physico – chemical summary of results indicates that the water quality is good with the dissolved oxygen at or near saturation. It notes the BOD at the monitoring point is consistently low. The two monitoring points are Knockadoagh which is located on a tributary of Glenicmurrin Lough and at Cashla Bridge. Table 13.3 gives the chemical water quality data at Cashla Bridge. This indicates a median pH of 6.5, median colour of 55 hazen and 101% saturation of dissolved oxygen.
The EIS states that the total volume of peat to be removed during the construction of the access road is approximately 2,880 m3 which would be stored outside the SAC. It states that as the aquifer potential of the bedrock was considered poor, the impact of the development on the hydro geological environment would be low. It notes the potential of heavy equipment to
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generate sediment-laden waters during rainfall events and also notes that impermeable areas provided as part of the development would result in a permanent impact on the geological environment.
Section 13.5 outlines mitigation measures which include the following: -
· Peat to be taken for storage or disposable outside of the SAC.
· Temporary water control measures for sediment settlement to be provided for the duration of excavation.
· Potentially polluting materials to be stored in specified areas.
· Construction method statements to be put in place to ensure that no slippage of peat would occur into Glenicmurrin Lough or the Cashla River.
· A cut-off drain by way of a perimeter ditch to be constructed as part of the construction of the intake works site.
· Silt ponds to be constructed at the perimeter drain on the intake works site.
Section 13.5.1 states that the predicted impact of the development is that with the removal of material required to achieve formation level, the topographic landform within the proposed development site would be permanently altered from the present.
The EIS stresses the need for monitoring of all materials generated and concludes that the proposed development would have no impact on the surrounding geological environment and there would be no short to long-term impacts outside the site boundary.
14.0 TRAFFIC: - (EIS PAGES 249, 243 AND FIGURE 14.1)
The section covers an appraisal of all transport-related issues related to the water supply scheme. It states that the access to the various elements of the works is from local roads and gravel roads which are adjoining regional road route which can be followed in Figure 14.1 from Galway via the R336 to the various elements of the development.
The EIS states that potential impacts could arise from increased traffic flows and traffic disruption during construction. It states also there could be an increase in noise and a negative impact on air quality due to dust. It states the long-term operation of the treatment works at Cashla would lead to a slight increase in vehicle movements on the R336 and long-term operation of the reservoirs would not lead to any significant increase in vehicle movements.
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As mitigation, the EIS suggests the inclusion of an appropriate sum in the construction contract to cover the repair of all routes and states that it is proposed to implement the traffic management measures in accordance with Chapter 8 of the DoEHLG Traffic Design Manual.
Figure 14.1 indicates the road network in the study area.
15.0 INTERACTIONS OF ENVIRONMENTAL AFFECTS: - (EIS PAGES 254 – 255)
This section of the EIS lists the summary of the most important interactions between environmental impacts. These are follows: -
· Interaction between water and ecology – the affects on water quality are stated to have a bearing on the quality of flora and fauna in the river and lake. Sections 5 and 7 are referred to.
· Visual and Human Being impacts – EIS states the impact on human beings can be mitigated only by careful and adequate landscaping measures for the reservoirs.
· Noise and Human Being impacts – construction activity is temporary activity and any impacts would be short-term. All construction works would be carried out during daytime periods.
· Noise and landscape impacts – EIS states there is a direct relationship between landscaping and the abatement of noise impact. Landscaping at the treatment works to reduce visual impact would have a secondary benefit of reducing noise levels from the treatment works.
16.0 CONCLUSIONS: - (EIS PAGES 256 – 257)
The EIS is stated to be based on a preliminary report for the Costelloe RWSS in 2005. It notes that some changes to the proposal in the Preliminary Report had been made to minimise the environmental impact of the scheme. It states that from Figure 3.10, the extent of the works located in the cSAC is limited and is located close to the boundary of the cSAC. It notes that 1.97 hectares of land is required in the SAC out of the total area of 70,324 hectares. (both SAC’s taken together)
The findings of the assessment are stated to be as follows: -
· With mitigation the potential impact on the aquatic system of the Connemara Bog Complex cSAC can be reduced to a slight negative impact.
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· Impact on the terrestrial habitats of the cSAC is assessed as being a slight negative impact which with suitable mitigation, can be reduced to an imperceptible negative impact.
· The impacts on the Kilkieran Bay and Island SAC would be imperceptible negative at most.
The last paragraph of this section states that compensatory measures to offset some of the negative effects are proposed which include the provision of a fish counter at the regulating weir and an additional 0.5 hectares of land north of the access road to the regulating weir would be purchased by Galway County Council and this would be fenced off and protected from grazing to facilitate habitat restoration in an area that had been damaged by grazing and feeding of cattle.
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APPENDICES – VOLUME 3 OF 3 OF THE ENVIRONMENTAL IMPACT STATEMENT
The appendices are contained in a single volume and are headed as follows: -
· Appendix 1 – Summary of Responses.
· Appendix 2 – Glenicmurrin detailed Source Assessment.
· Appendix 3 – Ecology and Fisheries.
· Appendix 4 – Survey of Arctic Char in Glenicmurrin Lough.
· Appendix 5 – Cryptosporidium Risk Assessments.
· Appendix 6 – Cultural Heritage.
APPENDIX 1
Appendix 1 contains appendix 1a and 1b which are the summary of responses to the scoping report and the summary of responses to the public information day respectively. Appendix 1A details 79 references from nine consultees and the responses to these are set out in tabular form. The issues raised include the impact of the fish pass, impacts on upstream and downstream migrational fish, the impact of different levels of flow (approximately 20 comments). The extent of the proposed scheme and its extension Glenicmurrin was raised by one landowner and the disposal of effluent and water from the treatment plant was raised by the DCMNR. The Costelloe and Fermoyle Fisheries raised issues in relation to salmonid spawning, the European eel and the impacts of extreme drought conditions.
The Western River Basin District Project raised issues in relation to alternatives and the likely impacts on the status of the existing water bodies.
The Irish Peatland Conservation Council raised questions of alternative sites and the hydrological implications of water reductions in the Lough.
DoEHLG raised questions in relation to archaeology and ecological impacts. The DoEHLG also raised issues about river crossings and the requirement for method statements for the crossings of rivers with pipes.
Appendix 1B gives the summary of responses to the public information day. The responses are set out in tabular form and are from one company and five individuals. Comments included dissatisfaction with the translation of the proposals into the Irish language and also that the plan was not serving Ceantar Na nOileán.
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APPENDIX 2 - GLENICMURRIN LOUGH DETAILED SOURCE ASSESSMENT
This report has an original date of April 2004 with provisions up to May 2007 when the scenarios were updated. The report contains 15 pages of text and six graphs.
The report details the data collection which elaborates on the main text of the EIS. It outlines the artificial influences, including details of the discharge license for the fishery. It has a maximum daily demand of 4,342 m3/day and notes that the requirement is to abstract no more than one-third of the water from the river. It notes that the demand is equal to 0.05 m3/s which requires 0.15 m3/s to be flowing in the river if recycling of water is not to be used at the hatchery. It notes that the planning application for a larger hatchery was withdrawn in 1986 when the original scheme was built.
The previous reports are referred to and these commenced with the 1972 preliminary report by Patrick J. Tobin & Company which had a demand estimate of 2,810 m3/d. The proposal in May 1975 was to abstract 3,640 m3/d under the Water supplies Act 1942 and this led to the 1978 agreement with the fisheries company to allow that abstraction with storage on a 600-millimetre band between levels of 25.75 mOD and 26.35 mOD. The history of the scheme indicates that in 1981 during the preparation of contract documents an interim report was submitted outlining necessary departures from the preliminary report. The emerging water requirements of Rossaveal Harbour were highlighted and a Stage 1 scheme to cater for demand of 5,455 m3/d was proposed.
The report notes that in March of 1985, DoEHLG indicated that a supplementary report would be required and a new water abstraction proposal would be required before further progress would be made. It notes that in March 1986, the revised preliminary report was submitted and the demand estimated was 12,600 m3/d. The process was not taken any further and consultants were instructed to prepare a revised preliminary report in August 2003.
Section 5 of this report gives a hydrological assessment and refers to the preliminary report of 1986 which indicated that Glenicmurrin Lake has the potential to supply 12,000 m3/d, together with the 9,100 m3/d or 0.15 m3/s of compensation water, if levels are controlled within a 600-millimetre storage band between 25.75 mOD and 26.35 mOD during the summer. It notes that the figure of 9,100 m3/d represented just over three times the maximum permitted abstraction rate by the fisheries from the Cashla River, if the 50% recycling requirement is taken into account. It notes the lowest flow recorded to date in the Cashla River is 0.074 m3/s recorded on 28th August 1984 and this is equivalent to 6,394 m3/d. Table 5.1 gives the recorded flow and levels statistics and Table 5.2 gives the levels and flows in 1989 which were regarded as the lowest flows recorded accurately. The annual minimum flows
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are given in Table 5.3 and these ranges from 6,394 m3/d in 1984 to 39,658 m3/d in 1999.
Section 5.2 gives the details of the computer simulation programme and outlines the philosophy of operations policy which would ensure there was no interference with the natural control of the lake during the winter period. The report notes that the calculation of inflows and uses the reported outflows and the rating curve for 1984 when no artificial level control was exercised and is given in Figure 2, while rating curve from 1995 is shown at Figure 3, when weir boards were used.
The report states that since the compilation of the source assessment report at preliminary report stage, a detailed analysis of the affect of the Phase 1 abstraction was carried out. It states the system was modelled for an abstraction of 3,600 m3/d which is the proposed Phase 1 abstraction rate, together with a minimum compensation of 0.15 m3/s or 12,960 m3/d.
Section 5.3 notes the abstraction rate as 0.042 m3/s and the minimum compensation flow of 0.15 m3/s. It states that under that scenario, compensation flow could be guaranteed across the entire year and it was found that when the previous days average inflow to the lake is greater than 0.5 m3/s, the outflow could be increased to 50% of the previous days average flow. The conclusions of this report are that Glenicmurrin Lough is capable of supporting, (within the proposed control band), an abstraction of up to 3,600 m3/d.
Graphs 3, 4, 5 and 6 at the end of the report give low levels and was recorded and simulated water levels for the years 1984 and 85.
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APPENDIX 3 – FLORA AND FAUNA
This appendix is in two parts with the main technical report which runs to 97 pages and is Appendix 3A, while the Costelloe Habitat Maps comprise Appendix 3B.
Appendix 3a – Main Technical Report on Flora and Fauna
This report was produced by ECOFACT and is dated May 2007.
In the introduction, the report notes the extent of the area lowered by the Regional Water Supply Scheme which is 144 km2 with the majority of the water main installations to take place along the R336. It notes the total area of SAC is 70,324 hectares and the area of the access road, regulating weir and pumping station is 1.97 hectares of land. It notes consultations were carried out with 11 specified bodies.
Chapter 2 of the report indicates the methodology used which included a windshield survey of the proposed water main route and a river corridor study. It also notes the quantitative electrical fishing survey which is referred to in the main text of the EIS as is the qualitative electrical fishing survey and lake gill netting survey. It notes that the macro invertebrates survey used an FBA kick- type sampling net in April 2006.
Additional surveys were carried out in relation to birds, mammals, amphibians and reptiles and terrestrial invertebrates.
Chapter 3 describes the existing environment, with particular to the designated areas of the Connemara Bog Complex and the Kilkieran/Greatman’s Bay and Islands SAC.
Section 3.2 deals with fisheries and aquatic fauna with reference to Glenicmurrin Lough and the Cashla River. The other aquatic areas examined were Loch Uí Chadhain which is approximately 250m2 in area and approximately 1 kilometre north of Costelloe. It also refers to Lough Carrafinla which is part of a cluster of lagoons approximately 1.5 kilometres north of Costelloe. Ten other water bodies are referred to in the report. Table 2 sets out the description of the water bodies and the evaluation of each, together with the distance from the scheme. Pages 17, 18 and 19 contain photographs of the locations of the various elements of the scheme.
Section 3.2.2.1 describes the Costelloe and Fermoyle Fishery and the water bodies making up the area of the fisheries including Glenicmurrin Lough, Cashla River, Lough Cloonadoon, Muckanagh, Rusheen, Fermoyle and what is described as the upper lakes.
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The report refers to the marine institute fish counter data and notes the verification by video surveillance since 2002. It gives the overall exploitation rate of sea trout and salmon on the system in 2002 as 14.34%. Upstream and downstream annual counts and monthly counts are indicated in Figures 2-6 of the report with the annual counts upstream being 52,000 approximately and 12,000 downstream.
The report notes that the patterns of sea trout/salmon movements in the lower Cashla River are similar to that reported for other western catchments including Burrishoole in County Mayo. It notes that to ensure the fish migrations on the Cashla River are not significantly impacted, no regulation of the river would be carried out during the late autumn to early spring period.
Section 3.2.2.3 refers to the Central Fisheries Board (CFB) electrical fishing data. It notes that surveys were carried out following a time when recruitment of sea trout to the catchment was at a low level after the general collapse of sea trout in western Ireland in the late 1980’s. Tables 4, 5 and 6 of Section 3.2.2.4 indicates trout for high densities at un-stocked sites are ranging between 0.01 to 1.94 fish per square metre and the tables indicate locations at which fish-stocking had taken place beforehand.
In relation to protected aquatic fauna, Table 7 indicates that the pearl mussel is present in the hydrometric area 31, but absent in both the Cashla River and Glenicmurrin Lake, while the Atlantic salmon is common, in both the river and the lake and the otter is present in both. Other aquatic fauna listed in the habitats directive are stated to be absent from both the river and the lake. Arctic Char which is considered to be a fish of high conservation importance, although not subject to any particular designations, is stated to occur in Glenicmurrin Lough. In relation to sea trout, the report states that it has a complex lifecycle and this is outlined in Table 8 on Page 30 of the report. The report also describes the marine ecology and notes that Kilkieran Bay has high species diversity present. It states there are eight licensed salmon farm operators in Kilkieran Bay and production was estimated in 1995/6 at 3,602 tonnes.
Section 3.2.7.1 describes the River Corridor Study and Table 9 gives the general characteristics of the lower Cashla River which is generally reproduced in the main text. Table 10 gives the general characteristics of Glenicmurrin Lough, Table 11gives the physical attributes of the lower Cashla River and Table 12 the rating of the river as a habitat for salmon and trout in relation to spawning, nursery, rearing and foraging.
An electrical fishing survey was carried out and the characteristics were given in Table 13 which recorded Atlantic salmon, eel and minnow. It states that results suggested some spawning does take place in the area and it is not known why juvenile salmonids were not present in more significant numbers in the area during June. The report refers to the lake gill netting survey which was undertaken with the permission of the DCMNR, WRFB and the fishery owners during June 2006. It notes the use of benthic and pelagic nets and the
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presence of Arctic Char was recorded. Figure 7 gives the length and frequency of Arctic Char in Glenicmurrin Lough, Figure 8 gives the same data for brown trout and Table 13 gives the electrical fishing site characteristics for the three areas investigated, namely the Cashla River Upper, the lake intake and the lake site.
Table 14 gives the numbers of various fish species recorded during electrical fishing sites with minnow being the most common species and Table 15 and 16 give data in relation to gill netting.
Section 3.2.7.4 refers to aquatic macro invertebrates and a total of 38 different macroinvertebrate taxa were recorded and this information is given on Table 17.
Section 3.2.7.5 deals with fish passage. It differentiates between fish which live in freshwater, but migrate to marine waters to spawn and anadromous fish which live in the sea but migrate to freshwater rivers to spawn. The Atlantic salmon and sea trout are in this category. The report notes for general requirements for fish passes which relate to: -
· Capacity.
· Suitable for slower swimming species at all life stages.
· Permanently operational and functioning over different floor regimes.
· Entrance position readily accessible to migrating fish.
It notes the best fish pass methods are those that simulate as closely as possible, the features of a natural watercourse. It notes that the Arctic Char are likely to mainly confined to the lake, but may occasionally drop downstream into the river. The report notes that the main upstream migration of fish takes place during June and July and a smaller but significant run also takes place during May.
The report deals with swimming speeds and notes the Scottish Office for Agriculture and Fisheries recommends flows through short culverts should not exceed 1.25 metres per second. The report discusses eel passage and notes their behaviour. The report also notes that the difference between the lake surface levels and downstream surface water levels would be less than 1 metre at all times.
Section 3.3 deals with flora and habitats. Table 18 lists 35 habitats indicating their classification, type and corresponding EU Habitat Type. These habitats are described in detail from pages 41 – 49.
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Table 19 gives a summary of habitats with botanical interest for specific sites. Table 20 gives a list of plant species recorded by habitat and covers pages 52 – 56 inclusive.
Section 3.4 deals with terrestrial fauna and the terrestrial mammals are listed which include the otter, badger, Irish hare and the soprano and common pippistrelle bat. The evaluation of the mammal populations in the study area is that there are of high local importance. In relation to amphibians and reptiles, the common frog and the viviparous lizard are noted and these are stated to be of high local importance. Terrestrial invertebrates are rated as being of local value.
Pages 58 – 61 describe the birds in the area and include reference to the Red Grouse which is stated to be a scarce bird in Ireland. It states that no Red Grouse were seen on the study, but that roost droppings were found on one transect. It notes the local NPWS Conservation Ranger has having estimated that Red Grouse were scarce in the general area of the Regional Water Supply Scheme. The report notes that following completion of the survey in April 2007, a pair of Grouse were seen approximately 2 kilometres to the north of the study area. The report evaluates the bird populations as being of high local importance and the bird populations in the designated areas are of international importance. Page 62 and 63 give the Red Grouse breeding ecology and at Table 21 lists the notable bird species associated with the blanket bog type habitat in the Connemara Bog Complex SAC area. Table 22 gives the selected red list species recorded in the general area of the water scheme and Table 23 gives the amber list species. Table 24 gives details of the Red Grouse Survey and Table 25 gives results of the April 2007 survey of adjoining areas of Glenicmurrin Lough.
Chapter 4 of the report deals with potential impacts. The impacts in general are described in the main text of the EIS. In relation to designated areas, the Impact Assessment is that with mitigation, it could be slight negative on the Connemara Bog Complex SAC. In relation to Kilkieran Bay and Islands, the prediction is for it to be imperceptible negative at most.
The report sets out the proposed compensation flows that are detailed in the main text. In relation to potential impacts on water quality, the potential pollution by suspended solids and other substances during construction are noted. The Impact Assessment on potential interference with fish migration is that substantial potential impacts are possible in the absence of mitigation measures. The same assessment is made in relation to angling, while an imperceptible potential negative impact is expected in relation to trout and salmon spawning. The report predicts no impact on Arctic Char with mitigation measures.
Section 4.2.2 deals with the operational phase and states that the impacts on fish migration and fisheries, including angling are potentially substantial.With the mitigation measures proposed which include modern a fish pass, compensation flows and controlled water releases or freshets, together with no winter regulation, the impacts are predicted to be slight negative. With
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mitigation, no impact is expected in relation to salmonid spawning. It states that reduced water supplies in rivers can have significant hydro-ecological impacts, but with mitigation, the impacts are expected to be reduced to slight negative impact.
The report points outs that in extreme drought conditions, the provision of a guaranteed compensation flow would have a slight positive impact. Impacts on out-migrating fish or kelts are predicted to be imperceptible negative and the impact on Char in the lake is predicted to be imperceptible.
Section 4.3 deals with flora and habitats and the impacts arising from the project. The report deals with the regulating weir and access roadway, treatment plant, reservoirs, landscaping and watermains. The impacts predicted are between imperceptible and slight negative following mitigation. In dealing with the impacts during operation, the report deals with river and lake regulations and the operation of the treatment plant and reservoirs. It also refers to impacts arising from maintenance of the various aspects of the works.
Section 4.5 relates to a do-minimum impact. It refers to the impacts from peat cutting, over-grazing, afforestation and drainage and reclamation of land. It notes that as the national and regional population is expanding, open space along rural roads in the study area are under development pressure and segments of habitats along road corridors could be lost to future development.
Section 5 of the report deals with mitigation measures and relates in the first instance to designated areas. It outlines controls required for construction operations and also the levels within which lake regulation is to be kept, namely 25.56 mOD and 27.35 mOD. It states the current abstraction order would ensure that lake levels are maintained within the band of 25.75 to 26.35 mOD, which is a narrower band than that described as the existing natural fluctuations. It states that the mitigation measures would protect shoreline ecology, the Arctic Char, lake-spawning sea trout and rod fisheries.
The protection of water quality on the Cashla River is achieved by lake regulation which provides for increased compensation flow when natural flows are in excess of 0.5 m3/second. It states that the mitigation measures would also include monitoring using a fish surveillance system for a period of three years following the commissioning of the scheme. The report states that the mitigation measures would also protect aquatic and riparian ecology, salmonid spawning and rod fisheries, as well as eels and eel migration.
Section 5.3 deals with flora and habitats. It states that all areas within the SAC borders and comprising blanket bog or heath and scrub habitats need to be limited to the minimal space required and the use of low ground pressure machinery is required. It notes that backfilling should be with locally excavated materials to repair damaged areas. In relation to the regulating weir, it notes a suitable environmental management system would be used to control sediments during works. The access road to the regulating weir is to follow the driest and/or currently more disturbed area bog as mapped by the ecologist. In relation to treatment plant at Cashla, this is stated to be on semi-
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improved fields adjoining an industrial estate. The reservoir at Rosmuc is to be located east of the original proposed site to avoid juniper heath. In relation to landscaping and reinstatement, the use of local materials is proposed and at Screebe and Glenmore, wooded areas are stated to be in the vicinity of the reservoir sites. It states that tree planting of native species can be used to screen the reservoirs in these locations. It notes that the restoration of peat areas would be covered by a method statement to be agreed in advance with NPWS. In relation to birds, it states that a further survey would be undertaken at pre-construction stage and no removal of scrub or other semi-natural habitats should be undertaken during the bird-breeding season.
Section 6 on Page 82 deals with predicted impacts and this section are in summary form and is generally as per the main text of the EIS. Impacts at construction stage are assessed from none to slight negative. Further impacts during the operational phase are similarly assessed for fisheries and aquatic ecology. Section 6.3 deals with flora habitats, residual impacts and the range of impacts are from imperceptible negative to moderate which is in the case of the flora and habitats at the proposed weir site. It states that for terrestrial fauna, the impact on birds would be imperceptible negative.
Section 7 proposes monitoring to be agreed with the NPWS, DCMNR and the WRFB. These would cover the following: -
· Monitoring water quality.
· Monitoring of mitigation measures.
· Ongoing monitoring of Char populations during construction and following commissioning of the scheme.
· Ongoing monitoring of upstream fish movements at the proposed regulating weir using a fish counting system.
· Ongoing visual monitoring of downstream movements of fish path.
· Ongoing monitoring of the compensation flow.
· Monitoring of the habitat restoration measures for a period of three years post development.
It states that the scale and duration of artificial flood events would be modified as necessary, following the results obtained from monitoring. It also states that alternative approaches to habitat restoration would be undertaken if necessary. In relation to reinstatement, it states a landscaping plan for all affected areas has been drawn up.
Pages 86 – 92 contain references.
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Appendix 3A of this report is on Page 93 and gives criteria for assessing ecological importance, criteria for assessing impact type and criteria for assessing impact magnitude. Appendix 3A/2 gives the site codes for the Connemara Bog Complex and the Kilkieran Bay and Islands.
Appendix 3B gives the Costelloe Habitat Maps which indicates the habitats at Glenmore Reservoir, Lettermore Reservoir, regulating weir, Rosmuc Reservoir and the proposed treatment works.
APPENDIX 4 – SURVEY OF ARCTIC CHAR IN GLENICMURRIN LOUGH
The summary is given at the beginning of the report and states that the only previous record of Arctic Char for Glenicmurrin Lough was a specimen lodged in 1937 and the British National History Museum. It states that in 2004, a single Char was captured in the tidal reaches of the Cashla River during sea trout monitoring work. It notes a gill net survey was carried out on the 16th and 17th June 2006 and a total of 10 Arctic Char and 15 brown trout were recorded. It states that Arctic Char were taken in both the floating pelagic net and the benthic nets in numbers which suggested that the population of Arctic Char in Glenicmurrin Lough is substantial.
The summary concludes by saying that a monitoring programme including identification and monitoring of char spawning areas and recruitment in the lake is proposed.
Page 3 and 4 of the report covers introduction and a description of water abstraction impacts on fish communities, together with a photograph of the Arctic Char captured in 2004. Page 5 sets out the methodology involved in gill netting and on Pages 6, 7 and 8, the results of the survey of 2006 are given which includes a photograph of an Arctic Char alongside a Brown Trout. Table 2 compares the catch per unit effort and Figures 1 and 2 give the length of the fish taken in the pelagic and benthic nets which ranges between 160 and 200 millimetres for the Arctic Char and from 120 –200 millimetres for the Brown Trout.
The conclusion of the report was that the sea trout avoidance strategy required a netting effort reduced by factor of three and this was successful in that no adult sea trout were killed. It states the survey achieved its objective which was the confirmation of the presence of Arctic Char in the lough. It states that the lough is clearly a nationally important site for Arctic Char and more detailed conclusions would require more sampling.
The recommendations of the report are that the spawning areas used by Char need to be identified, characterised and digitally mapped prior to construction taking place. It states that the lough level would not be allowed to drop below that to which the Char spawn during the period of October to May.
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APPENDIX 5 – CYRPTOSPORIDIUM RISK ASSESSMENTS
This appendix is two parts, namely Appendix 5A which is the risk assessment of 2004 carried out on the existing schemes and Appendix 5B which is stated to be the risk assessment on the proposed scheme.
The report has five pages of text and sets out the approach taken. It states that the Scottish Methodology in the new 2003 Directions are chosen which involve a relatively simple quantative scoring system and relate also to the frequency of sampling of both raw water and treated water at the treatment works. It lists 11 factors which might affect the occurrence of a water-borne outbreak of a cyrptosporidiosis. It states that the higher the score from the risk assessment, the higher the potential risk. It notes that the population- weighting factor is 0.4 multiplied by the log 10 of the population served by the supply. It states the final weighted surface water risk assessment is the final surface water risk assessment multiplied by the population-weighting factor. It states that a very high risk is a score of over 100 and low risk is less than 50.
It states that the water supply classification for the proposed scheme is low risk and the final risk assessment score is 26. Appendix 1 of this report lists the impacts of animals within the catchment and gives a score for the proposed works of 16 and when the risk factors from slurry spreading, septic tanks, the use of an upland reservoir, frequency of catchment inspections and the raw water intake management provisions, a surface water catchment risk score of 42 is arrived at. The methodology adds the impact of treatment and the figure of minus 26 is given to this factor. It gives the net surface water risk assessment score of 16 and a population of 9,870 gives a weighting factor of 1.6 which is how the final weight of surface water risk assessment score of 26 is arrived at. Appendix 5B is listed as the risk assessment for the proposed Costelloe RWSS, but in actual fact, it gives the risk assessment for some of the existing works. The final risk assessment score for Carraroe supply is given as 125, for Rosmuc and 73 and for Tir an Fhia 64.
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APPENDIX 6 – CULTERAL HERITAGE
This appendix is divided into four parts, namely 6A which is the record of monuments and places, 6B the topographical finds, 6C the protected structures and 6D which are the photographs.
Appendix 6A gives details of 59 sites listed on the record of monuments and places throughout the overall study area.
Appendix 6B notes three finds recorded from the area.
Appendix 6C – protected structures.
This appendix gives details of 10 protected structures throughout the study area.
Appendix 6D – photographs.
This appendix indicates 43 different photographs of views, monuments, RMP sites and includes a number of photographs of the abstraction point at Glenicmurrin Lough.
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