Office of Public Works Arterial Drainage Maintenance Works - Creegh Arterial Drainage Scheme

2018 - 2022

Stage 2: Natura Impact Statement

July 2018

Office of Public Works Main Street Headford Co Galway Ireland

JBA Project Manager Tom Sampson 24 Grove Island Corbally Limerick Ireland Revision History Revision Ref / Date Issued Amendments Issued to v1.0 / July 2018 Tony Brew

Contract This report describes work commissioned by the Office of Public Works by a letter dated 31/08/17. The Office of Public Work’s representative for the contract was Tony Brew. Tanya Slattery, Fiona Byrne and Laura Thomas of JBA Consulting carried out this work.

Prepared by ...... Tanya Slattery BSc MSc MSc (Res) Ecologist

...... Niamh Burke BSc PhD CEnv MCIEEM Senior Ecologist

Reviewed by ...... Tom Sampson BSc MSc FRGS C.WEM MCIWEM Principal Analyst

Purpose This document has been prepared as a Draft Report for the OPW. JBA Consulting accepts no responsibility or liability for any use that is made of this document other than by the Client for the purposes for which it was originally commissioned and prepared. JBA Consulting has no liability regarding the use of this report except to the OPW. Copyright © Jeremy Benn Associates Limited 2018 Carbon Footprint A printed copy of the main text in this document will result in a carbon footprint of 264g if 100% post- consumer recycled paper is used and 336g if primary-source paper is used. These figures assume the report is printed in black and white on A4 paper and in duplex. JBA is aiming to reduce its per capita carbon emissions.

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Contents

1 Introduction ...... 1 1.1 Background ...... 1 1.2 Legislative context ...... 1 1.3 Appropriate Assessment Process ...... 1 1.4 Methodology...... 3 2 Project Description ...... 6 2.1 Arterial Drainage Maintenance ...... 6 2.2 Drainage Maintenance Activities ...... 6 2.3 The Creegh Arterial Drainage Maintenance Scheme and Proposed Works ...... 11 3 Screening Assessment Results ...... 14 4 Existing Environment ...... 20 4.1 General ecology of the site ...... 20 4.2 Description of habitats present ...... 20 5 Natura 2000 sites within the Zone of Influence of the works/scheme ...... 23 5.1 Introduction ...... 23 5.2 Carrowmore Dunes SAC (002250) ...... 23 5.3 Mid-Clare Coast SPA (004182) ...... 30 6 Appropriate Assessment...... 34 6.1 Introduction ...... 34 6.2 Identification of Potential Sources of Impact ...... 34 6.3 Impact Assessment ...... 38 6.4 Impact Evaluation ...... 39 7 Avoidance and Mitigation Measures ...... 47 8 Conclusions ...... 48 References...... I A Appendices ...... III

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List of Figures Figure 1-1: The Appropriate Assessment Process (from: Appropriate Assessment of Plans and Projects in Ireland - Guidance for Planning Authorities, DoEHLG, 2009).. 2 Figure 1-2: Screening assessment process ...... 4 Figure 2-1 Extent of Creegh Arterial Drainage Scheme ...... 12 Figure 3-1 Channels and embankments with potential impacts via surface water pathways ...... 14 Figure 3-2 Channels and embankments with potential impacts via land and air pathways ...... 16 Table 3-2 Summary results of QIs / FOIs with potential land and air connectivity, resulting in a potential for impact from the proposed works through land and air pathways ...... 17 Figure 3-3 Channels and embankments with potential impacts via groundwater pathways ...... 18

List of Tables Table 2-1: OPW Drainage Maintenance Subcategories ...... 6 Table 2-2: OPW Drainage Maintenance Types ...... 6 Table 2-3 Channels at Creegh, planned works and frequency of maintenance ...... 12 Table 3-3 Summary of Natura 2000 habitats potentially present in the zone of influence of the works that may potentially be significantly impacted by the proposed works ...... 18 Table 3-4. Screening conclusions ...... 19 Table 4-1 Main habitats present at the Scheme ...... 20 Table 5-1: Qualifying Interests of the Carrowmore Dunes SAC (002250) ...... 23 Table 5-2: Conservation Objectives of Carrowmore Dunes SAC (002250) ...... 24 Table 5-2 List of pressures and threats to Carrowmore Dunes SAC ...... 30 Table 5-3: Qualifying Interests of the Mid-Clare Coast SPA (004182) ...... 30 Table 5-4. Conservation Objectives of Mid-Clare Coast SPA (004182) ...... 30 Table 5-5 List of pressures and threats to Mid-Clare Coast SPA (004182) ...... 33 Table 6-1 Impact evaluation table ...... 41 Table 7-1 Specific mitigation measures for Creegh Arterial Drainage Scheme ...... 47 Table 8-1 Integrity of Natura 2000 site checklist (DoEHLG 2009) ...... 48

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Abbreviations AA ...... Appropriate Assessment CA ...... Competent Authority COs ...... Conservation Objectives DoEHLG ...... Department of Environment, Heritage and Local Government EDM ...... Environmental Drainage Maintenance EPA ...... Environmental Protection Agency EREP ...... Environmental River Enhancement Programme FOI ...... Features of Interest GIS ...... Geographical Information Services GWD ...... Ground Water Dependant HDPE ...... High-density polyethylene IFI ...... Inland Fisheries Ireland IRB ...... International River Basin IROPI ...... Imperative Reasons of Over-riding Public Interest I-WeBS ...... Irish Wetland Bird Survey MAC ...... Machine Access Channel NIS ...... Natura Impact Statement NBDC ...... National Biodiversity Date Centre NPWS ...... National Parks and Wildlife Service OPW ...... Office of Public Works PVC ...... Polyvinyl chloride RBMP ...... River Basin Management Plan SAC ...... Special Area of Conservation SOP ...... Standard Operating Procedure SPA ...... Special Protection Area SWD ...... Surface Water Dependant QI ...... Qualifying Interests WFD ...... Water Framework Directive WMU ...... Water Management Unit ZOI ...... Zone of Influence

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1 Introduction

1.1 Background JBA has been appointed by the Office of Public Works (OPW) to provide environmental consultancy services in relation to statutory arterial drainage maintenance activities for 2018 - 2022 at Creegh in County Clare. This includes preparing a Natura Impact Statement (NIS) report to present required information to the relevant Competent Authority (CA) to undertake Appropriate Assessment. Appropriate Assessment is required at this location due to the presence of Carrowmore Dunes Special Area of Conservation (SAC) and Mid Clare Coast Special Protection Area (SPA) in County Clare within the Creegh Arterial Drainage Maintenance Scheme.

An initial screening assessment was undertaken at this location for the purposes of Appropriate Assessment by JBA in 2014 (JBA 2014a). This screening report defined the zone of influence of the works, screened Natura 2000 sites within this zone of influence for potential to be significantly impacted by the proposed works and identified the potential for the proposed works to have significant impact upon Carrowmore Dunes SAC and Mid-Clare Coast SPA in accordance with Article 6(3) of the Habitats Directive (Council Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora). Due to the identification of potentially significant effects in relation to the proposed works at this location, this NIS has been prepared to further assess the impacts on the integrity of the relevant Natura 2000 site and devise appropriate avoidance and mitigation measures where necessary.

1.2 Legislative context The Habitats Directive (Council Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora) aims to maintain or restore the favourable conservation status of habitats and species of community interest across Europe. The requirements of these directives are transposed into Irish law through the European Communities (Birds and Natural Habitats) Regulations) 2011 (S.I. No. 477 of 2011). Under the Directive a network of sites of nature conservation importance have been identified by each Member State as containing specified habitats or species requiring to be maintained or returned to favourable conservation status. In Ireland the network consists of Special Areas of Conservation (SACs) and SPAs, and also candidate sites, which form the Natura 2000 network. Article 6(3) of the Habitats Directive requires that, in relation to European designated sites (i.e. SACs and SPAs that form the Natura 2000 network), "any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subject to appropriate assessment of its implications for the site in view of the site's conservation objectives". A competent authority (e.g. the OPW or Local Authority) can only agree to a plan or project after having determined that it will not adversely affect the integrity of the site concerned. Under article 6(4) of the Directive, if adverse impacts are likely, and in the absence of alternative options, a plan or project must nevertheless proceed for imperative reasons of overriding public interest (IROPI), including social or economic reasons, a Member State is required to take all compensatory measures necessary to ensure the overall integrity of the Natura 2000 site. The European Commission have to be informed of any compensatory measures adopted, unless a priority habitat type or species is present and in which case an opinion from the European Commission is required beforehand (unless for human health or public safety reasons, or of benefit to the environment).

1.3 Appropriate Assessment Process Guidance on the Appropriate Assessment (AA) process was produced by the European Commission in 2002, which was subsequently developed into guidance specifically for Ireland by the Department of Environment, Heritage and Local Government (DoEHLG) (2009). These guidance documents identify a staged approach to conducting an AA, as shown Figure 1-1.

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Stage 1 Stage 2 Stage 3 Stage 4

Screening for AA AA Alternative Solutions IROPI

Figure 1-1: The Appropriate Assessment Process (from: Appropriate Assessment of Plans and Projects in Ireland - Guidance for Planning Authorities, DoEHLG, 2009)

1.3.1 Stage 1 - Screening for AA The initial, screening stage of the Appropriate Assessment is to determine: a. whether the proposed plan or project is directly connected with or necessary for the management of the European designated site for nature conservation b. if it is likely to have a significant adverse effect on the European designated site, either individually or in combination with other plans or projects For those sites where potential adverse impacts are identified, either alone or in combination with other plans or projects, further assessment is necessary to determine if the proposals will have an adverse impact on the integrity of a European designated site, in view of the sites conservation objectives (i.e. the process proceeds to Stage 2).

1.3.2 Stage 2 - AA This stage requires a more in-depth evaluation of the plan or project, and the potential direct and indirect impacts of them on the integrity and interest features of the European designated site(s), alone and in-combination with other plans and projects, taking into account the site's structure, function and conservation objectives. Where required, mitigation or avoidance measures will be suggested. The competent authority can only agree to the plan or project after having ascertained that it will not adversely affect the integrity of the site(s) concerned. If this cannot be determined, and where mitigation cannot be achieved, then alternative solutions will need to be considered (i.e. the process proceeds to Stage 3).

1.3.3 Stage 3 - Alternative Solutions Where adverse impacts on the integrity of Natura 2000 sites are identified, and mitigation cannot be satisfactorily implemented, alternative ways of achieving the objectives of the plan or project that avoid adverse impacts need to be considered. If none can be found, the process proceeds to Stage 4.

1.3.4 Stage 4 - IROPI Where adverse impacts of a plan or project on the integrity of Natura 2000 sites are identified and no alternative solutions exist, the plan will only be allowed to progress if imperative reasons of overriding public interest (IROPI) can be demonstrated. In this case compensatory measures will be required.

The process only proceeds through each of the four stages for certain plans or projects. For example, for a plan or project, not connected with management of a site, but where no likely significant impacts are identified, the process stops at stage 1. Throughout the process, the precautionary principle must be applied, so that any uncertainties do not result in adverse impacts on a site.

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1.4 Methodology Data to be used in this assessment has been collected in a range of formats, from a range of sources, including: • A comprehensive desktop survey (Section 1.4.1) • The 2014 Creegh Arterial Drainage Maintenance Screening Assessment (JBA 2014a) (Section 1.4.2) • A number of ecological surveys (Section 1.4.3) • National Parks and Wildlife Service (NPWS) website (http://www.npws.ie/) where site synopses, Natura 2000 data forms, GIS data and conservation objectives were obtained. • The Irish Wetland Bird Survey (BirdWatch Ireland 2017) • National Biodiversity Data Centre (NBDC 2017)

1.4.1 Desktop This NIS has been prepared with regard to the following documents: • DoEHLG (2009 rev 2010) Appropriate Assessment of Plans and Projects in Ireland Guidance for Planning Authorities. Department of the Environment, Heritage and Local Government (DoEHLG 2009). • European Communities (EC) (2000) Managing Natura 2000 Sites: the provisions of Article 6 of the ‘Habitats’ Directive 92/43/EEC, Office for Official Publications of the European Communities, Luxembourg. European Commission (European Commission and Office for Official Publications of the European Communities 2000). • EC (2002) Assessment of Plans and Projects Significantly Affecting Natura 2000 Sites: Methodological guidance on the provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC, Office for Official Publications of the European Communities, Luxembourg. European Commission (EC 2002). • EC (2007) Guidance document on Article 6(4) of the 'Habitats Directive' 92/43/EEC – Clarification of the concepts of: alternative solutions, imperative reasons of overriding public interest, compensatory measures, overall coherence, opinion of the commission. European Commission (EC 2007). • EC (2013) Interpretation Manual of European Union Habitats. Version EUR 28. European Commission (EC 2013). • Fossitt, J., (2000). A Guide to Habitats in Ireland. The Heritage Council, Kilkenny (Fossitt 2000). • NPWS (2008). The Status of EU Protected Habitats and Species in Ireland. National Parks and Wildlife Service, Department of the Environment, Heritage and Local Government, Dublin, Ireland (NPWS 2008). • NPWS (2014). The Status of EU Protected Habitats and Species in Ireland. Habitats Assessment Volume 2. National Parks and Wildlife Service, Department of the Environment, Heritage and Local Government, Dublin, Ireland (NPWS 2013a). • NPWS (2014). The Status of EU Protected Habitats and Species in Ireland. Species Assessment Volume 3. Habitats Assessment Volume 2. National Parks and Wildlife Service, Department of the Environment, Heritage and Local Government, Dublin, Ireland (NPWS 2013b).

This report has been produced on currently available information, with the most up-to-date versions used.

1.4.2 Screening The screening assessment conducted for these works has been undertaken in line with recommended guidance including that specifically produced for the OPW in 2014 (Ryan Hanley 2014b, 2014a). This methodology is based on source > pathway > receptor chain principles and involves assessing likely significant effects on Natura 2000 sites within the zone of influence of the proposed drainage maintenance in relation to three pathways:

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1. Surface water 2. Land & air 3. Groundwater The screening assessment involves assessing the impacts of drainage maintenance operations within the arterial drainage scheme, and its zone of influence, in relation to each of the three pathways individually. The results of each pathway are then combined in a concluding section to identify if/where likely significant effects may arise.

Figure 1-2: Screening assessment process

Surface water Land & Air Groundwater Pathway present Pathway present Pathway present connecting connecting connecting potential potential impacts potential impacts impacts to relevant to relevant Natura to relevant Natura Natura 2000 sites 2000 sites 2000 sites

Source > Pathway > Receptor Chain Receptor > Pathway > Source

Further assessment required

The screening process uses a combination of GIS analysis and qualitative assessment to identify which drainage maintenance activities, on which specific watercourses, are likely to have significant effects on the integrity of Natura 2000 sites. The screening report, conducted by JBA ecologists in 2014, has been reviewed and updated as necessary for the production of this NIS.

1.4.3 Ecological surveys To inform the Appropriate Assessment process, a number of assessments and ecological surveys have been conducted, including: • An ecological desk-based assessment to collate information on designated sites and protected and notable species, including bird survey data from the waterbird survey programme and the Irish Wetland Bird Survey (I-WeBS). • An ecological walkover survey of channel C1 (from 100m upstream of Mountrivers Bridge to the outfall to the sea, backdrains D1, D2, D3 and D4 and embankments E1, E2, E3 & E4, including habitat survey, conducted on 25th and 26th of September 2017. • A further ecological walkover survey was conducted on 17th and 18th May 2018 on channels C2, C2/1, C2/2, C2/3, C2/4. C2/4/1 and C5. This survey also focussed on potential habitat and presence of Whorl Snail.

The ecological walkover survey was carried out in general accordance with the methods outlined in the following documents; • Heritage Council (2011). Best Practice Guidance for Habitat Survey and Mapping (Smith et al. 2011).

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• Phase 1 Habitat Survey methodology (Joint Nature Conservation Committee (JNCC), 1990, revised 2003). • Ecological Surveying Techniques for Protected Flora and Fauna during the Planning of National Road Schemes (NRA 2009). • Fossitt, J. (2000). A Guide to Habitats in Ireland. The Heritage Council, Kilkenny (Fossitt 2000). Moorkens, E.A. & Killeen, I.J. (2011) Monitoring and Condition Assessment of Populations of Vertigo geyeri, Vertigo angustior and Vertigo moulinsiana in Ireland. Irish Wildlife Manuals, No. 55. National Parks and Wildlife Service, Department of Arts, Heritage and Gaeltacht, Dublin, Ireland. Aerial photographs and site maps assisted the habitat survey. Protected species, including mammals (e.g. Otter, Badger) and birds, were surveyed based upon sightings and signs of activity during the habitat survey and also by the identification of potentially suitable habitats. This included a preliminary assessment of features with suitability for roosting bats and recording of any non- native invasive species found. All evidence of protected habitats and species was recorded on a tablet using the bespoke JBA GISmapp application where relevant, and all information gathered was provided to the OPW on a separate GIS database. The results of these surveys have informed this NIS where relevant.

1.4.4 Consultation (if relevant) The findings of this assessment will be subject to consultation with the NPWS. This report has been produced on currently available information, with the most up-to-date versions used. Where new, or updated, information becomes available the OPW will consider and review the findings of this assessment, if necessary.

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2 Project Description

2.1 Arterial Drainage Maintenance Between 1945 and 1995, under the Arterial Drainage Act (1945), the OPW completed 34 Arterial Drainage Schemes on river catchments, along with five estuarine embankment schemes (over 11,500km of channel and 730km of embankments). The OPW is statutorily obligated to maintain arterial drainage channels under the 1945 Arterial Drainage Act, and since their completion, maintenance of these Arterial Drainage Schemes has been ongoing, with the majority of channels maintained every five years. However, larger channels tend to be only maintained every ten years, on average.

2.2 Drainage Maintenance Activities Arterial Drainage Maintenance includes a range of operations such as silt and vegetation management, mowing and structure maintenance, as detailed in Table 2-1, and listed as channel, embankment or structure maintenance in Table 2-2 below. It is required to retain the arterial drainage scheme design capacity. Table 2-1: OPW Drainage Maintenance Subcategories

Drainage Maintenance Subcategories A Silt and vegetation management B Aquatic vegetation cutting C Bank protection D Bush cutting/Branch trimming E Tree cutting F Mulching G Mowing H Gate installation I Sluice maintenance J Bridge maintenance K Other

Table 2-2: OPW Drainage Maintenance Types Category Maintenance Type Code

Silt and vegetation management A Aquatic vegetation cutting B Bank protection C Channel Maintenance Bush cutting/Branch trimming D Tree cutting E Other K Bush cutting/Branch trimming D Tree cutting E Embankment Mulching F Maintenance Mowing G Gate installation H Sluice maintenance I Bridge maintenance J Structural Maintenance Bank protection C Bush cutting/Branch trimming D Tree cutting E

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The following sections, taken from Ryan Hanley (2014a) and OPW (2011a), provide further details on the types and nature of arterial drainage maintenance operations undertaken by the OPW.

2.2.1 Channel Maintenance Activities The majority of drainage maintenance activities are focused on channel maintenance. While the frequency of maintenance on an individual channel may vary, with some channels requiring maintenance annually and others only requiring maintenance every twenty years, the average channel requires maintenance every four to six years. In this regard, approximately 2,000km of channels are maintained annually and nearly all of the 11,500km of channels across Irelands Arterial Drainage Schemes will have been maintained at least once over a period of five years. Channel maintenance is organised on a regional basis, with OPW Arterial Drainage Maintenance Regional Offices in Limerick, Headford, Co. Galway and Trim, Co. Meath. Scheme Design Standards Arterial Drainage Schemes constructed under the Arterial Drainage Act, 1945 were designed to provide an outfall for drainage of agricultural lands, and generally provided protection for a 3-year flood event. Where the creation of an outfall dictated the design bed levels, greater protection than the 3-year flood event was achieved as a consequence. In the case of modern flood relief schemes, flood protection for a 100-year flood event would be the design objective. The original Scheme designs, including the outfall datum for each of the Arterial Drainage Schemes, are available in the relevant OPW Arterial Drainage Maintenance Regional Office. This includes the mapped Scheme design, and the associated long sections and cross sections. These designs are used to inform channel maintenance. Types of Channel Requiring Maintenance In the years following the construction of a drainage scheme there is a tendency for the channel capacity to be progressively reduced due mainly to the transportation and deposition of bed materials, the accumulation of silt and the growth of in-channel vegetation. The resultant channel maintenance consists of repetitive works of a cyclical nature, to restore the Schemes design levels i.e. outfall datum in order to maintain the channel's designed capacity to convey water. Channels are prioritised for maintenance based on the rate of deterioration and the risk arising. The selection takes account of requests from the general public and potential flooding risk to roads, properties, urban areas and sewage works (OPW 2011a). Plane Bed to Low Gradient Channels Some 60 – 70% of maintained channels are of gentle longitudinal gradient and subject to relatively rapid deposition of silt, especially those that are subject to prolific growth of in-channel vegetation. The majority of maintenance works are therefore located on smaller lower-lying channels, with 90% of works in channels with a base width of <3m (OPW 2011a). In such channels silt and in-channel vegetation may cause the low flow level to rise by 50-300mm above the Scheme design level. In such circumstances maintenance is focused on restoring both low-flow and flood-flow water levels to original Scheme design. Medium to High Gradient Channels A smaller proportion of channels are steep and fast flowing and are subject to flash floods, bank erosion and rapid movement of bed gravel. The steeper sections of channel normally require relatively little and infrequent maintenance works (OPW 2011a) as opposed to channels of low gradient which are subject to rapid accumulation of silt and proliferation of vegetation. These channels will have a greater requirement for bank protection works. Periods and Cycles of Maintenance The average channel requires silt and vegetation management every four to six years. However, channels with prolific weed growth may require maintenance annually, particularly where downstream bridges are at risk of being blocked due to a flow of decaying vegetation in autumn. Conversely, some channels may only require in-stream maintenance every twenty years due to the self-cleaning characteristics e.g. high gradient channels. Where the period between previous channel maintenance works has been exceptionally long, dense scrub and woody vegetation can establish along the channel and within the maintenance access corridor. In such circumstances, drainage maintenance works will include the removal of scrub/transitional woodland (code WS1 in the Fossitt Classification, 2000) that has developed along

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the banksides via bush cutting/branch trimming, tree cutting or mulching. This is undertaken between the 1st September and 28th February to avoid the residential bird nesting season (from the 1st March to 31st August as per the Wildlife Act (1976). In contrast, in-stream works for silt and vegetation management are carried out outside of the salmonid spawning season (May to September) and the times that early life stages of salmonid fish will be present as per Section 173 of the Fisheries (Consolidation) Act (1959) on channels with salmonid spawning habitat. Any works required during this period are carried out in consultation with IFI. As a result, there may be a two stage approach to the works, with silt and in-stream vegetation management carried out during the open season (i.e. summer months), while woody vegetation removal is carried out in the winter months. Other restrictions on works may also apply in relation to the presence/absence of other protected species such as White-clawed Crayfish and Sea, River and Brook Lamprey which will influence the timing of works.

2.2.2 Embankment Maintenance Activities A total of 5 No. Estuarine Embankment Schemes were constructed under the 1945 Act. In addition, a number of the Arterial Drainage Schemes have embanked sections. Embankments are present within the Creegh Arterial Drainage Scheme. Scheme Design Standards As above for the Arterial Drainage Schemes, Estuarine Embankment Schemes constructed under the Arterial Drainage Act 1945 were designed to provide an outfall for drainage of agricultural lands, and generally provided protection for a 3-year flood event. Where the creation of an outfall dictated the design bed levels, greater protection than the 3-year flood event was achieved as a consequence. In the case of modern flood relief schemes, flood protection for a 100-year flood event would be the design objective. The original Scheme designs are available in the relevant OPW Arterial Drainage Maintenance Regional Office. This includes the mapped Scheme design, and the associated long sections and cross sections. Types of Embankments Requiring Maintenance All embankments and associated sluice structures (see section 2.2.3) are inspected annually for signs of disrepair. Regular inspections are carried out on sections of embankments, which are known from experience to be at risk, together with additional inspections after a storm surge at sea or a high tidal/flood event. Maintenance of embankments includes removal of vegetation to allow for inspection of the embankment, and in some cases the replacement of existing fencing with gates to allow for future access during maintenance.

2.2.3 Structural Maintenance Activities Structural Design Standards During the construction of the Arterial Drainage Schemes under the 1945 Act, some 18,500 No. accommodation bridges were identified and modified, or replaced as required. These bridges provide farmers owning land on both sides of a channels with farm vehicular and/or foot access from one side to the other. The type of bridge provided depended on the width, depth and required flow capacity of the channel, and ranged from concrete piped culverts to relatively large structures formed on concrete or masonry abutments spanned by structural steel beams, or lattice girders together with concrete or timber decking. During the Estuarine Embankment Schemes under the 1945 Act, existing sluice structures were identified and modified, or replaced as required. Additional sluice structures were constructed as required bringing the total number to approximately 750. The function of these sluice structures is to allow water from the floodplain behind the embankments to discharge to the main river or estuary. Types of Structures Requiring Maintenance In general, as channel maintenance proceeds, the bridges are examined by the supervisory industrial staff and if required, repairs/replacements are scheduled. The type of bridge structures, which are most likely to have fallen into a critical state of disrepair, are those with timber decking supported on steel beams, and those in which abutment foundations are being undercut. There is

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a standard type of design for the replacement of these structures, which consists essentially of mass concrete abutments with reinforced cast in-situ decking. This type of structure is simple to construct and under normal circumstances, it will last for many years with little or no maintenance. On many occasions, it is not necessary to totally replace a bridge, and repairs such as underpinning the foundation or replacement of wing-walls, parapets or sections of the deck may be all that is required to extend the useful life of the structure. All embankments and associated structures are inspected annually for disrepair. Due to the time elapsed since scheme completion, some of these sluice structures have reached their design life and have started to fail. In this instance, full replacement is required. Typically, this involves the installation of pre-cast headwalls and back walls, and the replacement of existing corrugated galvanised steel pipes with PVC plastic pipes. Sluice doors are the most frequent part of the sluice structure that are required to be repaired or replaced. Repairs to a sluice door consist of replacing the arms/hinges on the existing cast iron door. On occasion, the existing cast iron door would be replaced with a high-density polyethylene (HDPE) door. Blockages often occur at the doors of the sluices due to silt build up. These blockages are removed using along reach excavator working from the bank of the channel. There is no maintenance planned on structures, including bridges and sluice doors, as part of the Creegh Scheme. Further details on this are provided in Section 2.3.

2.2.4 Plant and Machinery The types of machinery typically utilised during maintenance works would include 3600 hydraulic excavators (from 15-20 tonne excavators), mini-diggers, tractors and trailers, tipper lorries, hydraulic shears, hydraulic secateurs, chainsaws, mulchers and mowers; the machinery used is dependent on the maintenance activity being conducted. The removal of dense in-stream silt and vegetation requires the use of a hydraulic excavator with a 1.5m wide (approximate) bucket (capacity approximate 500ltrs). For standard excavators, works progress at a rate of 700m to 900m per week. In relation to long-reach excavators, works progress at a slower rate of between 200m and 350m per week. Rates may change due to channel width or ground conditions.

2.2.5 Maintenance Access Corridors (MAC) and Working Zone Maintenance sites are generally accessed via the public road and through farmland. A maintenance access corridor is utilised along one side of a channel for maintenance purposes. These established routes are used to track the hydraulic excavators for maintenance and for the disposal of spoil (see section 2.2.7). The same route is generally followed every maintenance cycle. This approach avoids disturbance of habitats on the opposite bank during works. Where grasslands are present within the maintenance access corridor, the impact is predominantly temporary as the grasslands are trampled by machinery and can recolonise following completion of the maintenance activities. Within woodland and scrub habitats a linear path more typical of disturbed vegetation i.e. scrub/transitional woodland (WS1) will be evident along the maintenance access corridor due to regular machine access. In this regard, the disturbance regime associated with the tracking of plant machinery along the maintenance access corridors on the channel bank arrests succession to mature woodland such that scrub/transitional woodland (WS1) dominates. Where mature trees are present these are generally avoided by plant machinery. Structures are generally accessed through farmland from the public road above. Plant machinery will utilise the same maintenance access corridor used for channel maintenance to gain access to the structure. Where individual trees, woodland and scrub habitats are present at the location of the structure, these may be removed to facilitate bridge inspection and works. Where mature trees are present these are generally avoided by plant machinery. The location of drainage maintenance works is generally accessed via public roads and through farmland, with the siting of mobile short-term staff welfare facilities, plant storage and car parking agreed with local landowners. There is no requirement for temporary site lighting. There is a requirement for water supply and disposal of wastewater from the welfare facilities (see section 2.2.7 in relation to waste disposal).

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2.2.6 Site Compounds (Welfare Facilities), Access Routes and Haul Roads Haul roads are generally not required to facilitate drainage maintenance activities. Where access is required in soft ground conditions, plant equipment will be brought in on tracks or temporary matting will be laid to provide a corridor for machinery access. Where matting is utilised, it will be completely removed post completion of works to allow vegetation to recolonise. All plant and machinery is confined to one defined access route to minimise disturbance. All plant and machinery are regularly maintained and serviced to minimise release of hydrocarbons. All hydraulic excavators and other plant machinery use long life engine oil and biodegradable hydraulic oil. Fuelling and lubrication are conducted a minimum of 50m away from all channels. Spill kits are present in all plant used in maintenance activities. Integrated submersible pumps are also deployed in the event of structural maintenance and the requirement for dewatering of excavations.

2.2.7 Waste Output/Disposal The material removed from a channel during silt and vegetation management is normally spread thinly along the bank or on top of existing spoil heaps where present within the access corridor. All dead wood material is left on site to decompose or is removed off site and utilised as firewood under local landowner agreements. Where mulchers or mowers are deployed, the arisings are left on site to decompose or the mulched material is buried. Construction and demolition waste from structures includes broken concrete and stone. Steel railings are returned to the depot for recycling. Used engine oil and hydraulic oil is disposed of by a licensed waste handler. Toilet facilities are maintained by a licensed waste handler. Any waste generated on site is returned to the depot for segregation and disposal by a licensed waste handler.

2.2.8 Working Hours All maintenance activities are undertaken during daylight hours. Standard working hours are 8.00am to 4.30pm, with lunch and tea breaks, Monday to Friday. There is no requirement for temporary site lighting to facilitate works. Machines are powered down when not in use.

2.2.9 Environmental Training Environmental training of all staff involved in drainage maintenance is an ongoing process. Technical and Operational Staff have completed formal training in Environmental Drainage Maintenance (EDM) in 2004. This training course was revised and expanded under the OPW’s Environmental River Enhancement Programme (EREP) and was delivered to all staff in 2010. The training programme delivered included presentations in river corridor ecology, the Environmental Drainage Maintenance Guidance Notes (Ten Steps to Environmentally Friendly Maintenance), maintenance strategies involving both ‘enhanced maintenance’ and ‘capital enhancement’, and OPW’s Environmental Management Protocols and Standard Operating Procedures (SOPs) (see section 2.2.11 for more details). Both sets of training were developed and delivered by Inland Fisheries Ireland (IFI). The formal approach to EDM Training is complimented with on-site training. Regular site visits from IFI and OPW’s Environment Section provide further guidance and advice to operational staff. Auditing of operational staff on the implementation of the Environmental Drainage Maintenance Guidance Notes (Ten Steps to Environmentally Friendly Maintenance (OPW 2011b) is also carried out by both IFI and OPW’s Environment Section. In addition, other environmental training takes place as deemed beneficial, e.g. in 2008, the majority of the technical and operational staff were trained in Otter Awareness. This course, provided by the Department of Zoology, Trinity College Dublin, included presentations on Otter ecology, and on-site identification of Otter signs and suitable habitat. In 2017 an environmental training course was designed and provided by JBA to all OPW staff. It was given in three different stages. Management were given a more detailed 2 day course in Environmental and Ecological training. Ground staff were given 1.5 days of training in the environment and ecology. Modules were designed to assist staff in understanding the relevant legislation, recognising ecologically sensitive habitats and species, non-native invasive species identification and general environmental and ecological training relevant to their work. This included a half day practical session where ecologists demonstrated the identification of the elements taught in the classroom, in the field.

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2.2.10 Environmental Audits A portion of operational crews are audited annually by the OPW Environment Section and IFI for the implementation of the Environmental Drainage Maintenance Guidance Notes (Ten Steps to Environmentally Friendly Maintenance) and the OPW’s Environmental Management Protocol and SOPs (Appendix A.4). Auditing is carried out separately by both IFI and OPW Environment Section on a rotational basis to ensure all operational crews are audited at least once every three years. All audit results are forwarded to the relevant Engineer for that Scheme within two working weeks. In the event of an audit showing elements of unreasonable non-compliance with procedures, the relevant Engineer will be notified within one working day. Audit results are also forwarded to OPW Systems Manager for inclusion in monthly regional benchmarking reports.

2.2.11 Environmental Management Protocol and Standard Operating Procedures (SOPs) The OPW’s Environmental Management Protocols set out how regional management staff manage a range of environmental aspects, including programming of works to accommodate certain environmental windows or restrictions on timing of works, and recording of data. A total of 7 No. Standard Operating Procedures (SOPs) are applied during operational works. These SOPs set out actions designed to eliminate, or substantially reduce likely impacts to identified species and their associated habitats. These include: • Environmental Drainage Maintenance Guidance Notes (10 Steps to Environmentally Friendly Maintenance) • Lamprey SOP • Crayfish SOP • Otter SOP • Mussel SOP • Invasive Species SOP • Zebra Mussel SOP Appendix A.4 contains the OPWs Environmental Management Protocols and Standard Operating Procedures (OPW 2011b). This document can also be downloaded from http://www.opw.ie/en/media/OPW%20Environmental%20Management%20Protocols%20&%20SO Ps%20April%202011.pdf A draft Environmental Risk Assessment process has been developed by the OPW which will be filled in by the program producer for >3m base width main channels where maintenance has not occurred for 15 years and embankment works where maintenance has not occurred for 15 years. The Environmental Risk Assessment form for this process is in Appendix A.3.

2.3 The Creegh Arterial Drainage Maintenance Scheme and Proposed Works The Creegh Arterial Drainage Scheme is located in County Clare. It includes 31.5km of watercourse and 3.8km of embankment (Figure 2-1). The location and OPW channel name of the relevant channels and embankments are provided in Appendix A.1.

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Figure 2-1 Extent of Creegh Arterial Drainage Scheme

Within the Creegh Arterial Drainage Scheme the exact location and type of required maintenance activity varies over time. For the purposes of this NIS not all activities will occur on all Scheme channels, structures and embankments and only the following are planned for the Creegh Scheme: • A - Silt and vegetation management (Channel Maintenance) • D - Bush cutting/branch trimming (Channel Maintenance) • F - Mulching (Embankment Maintenance)

Channels and embankments subject to planned works within the Creegh scheme, are shown in Table 2-3. The location of each of these OPW channels and embankments are in Appendix A.1. Table 2-3 Channels at Creegh, planned works and frequency of maintenance

Ref: Frequency of Year of Last Season Type of Notes Maintenance Maintenance Maintenance A D F

C1 1 10/05/2017 S X Shoals of gravel removed at the outfall of C1 C1 10 11/05/2017 S X

C1 10 12/05/2017 S X

C1 10 13/05/2017 S X

C2 2 08/07/2015 S X X

C2 2 09/07/2015 S X X

C2/1 2 19/08/2015 S X X

C2/2 2 19/08/2015 S X X

C2/3 2 08/07/2015 S X X

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Ref: Frequency of Year of Last Season Type of Notes Maintenance Maintenance Maintenance A D F

C2/4 2 15/07/2015 S X X

C2/4/ 2 15/07/2015 S X X 1 C3 2 24/02/2016 S X X

C3/1 2 28/09/2011 S X X

C4 2 21/06/2017 S X X

C5 2 19/08/2015 S X X

D1 2 17/06/2015 S X X

D2 2 17/06/2015 S X X

D3 2 17/06/2015 S X X

D4 2 05/10/2011 S X X

D5 2 05/10/2011 S X X

E1 5 W X Mulching of undergrowth on embankment E1 W Mulching of undergrowth on embankment E1 W Mulching of undergrowth on embankment E2 W Inspection

E2 W Inspection

E3 W Inspection

E4 W Inspection Note: Ref: C = Channel, E = Embankment S / W = Summer / Winter

In terms of structural maintenance, no operations are planned as part of these works in 2018 - 2022. Therefore, any structural maintenance works on bridges and associated structures on those watercourses screened into the assessment (JBA 2014a) via each of the pathways are not included in this assessment.

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3 Screening Assessment Results An Appropriate Assessment screening assessment, addressing Stage 1 of the AA process, has already been completed for the Creegh Arterial Drainage Scheme (JBA 2014b). This identified that likely significant effects on a Natura 2000 site may occur as a result of the proposed maintenance activities and therefore a Stage 2 Appropriate Assessment is necessary. The Stage 1 Screening Assessment was conducted in line with guidance produced for the OPW in 2014 (Ryan Hanley 2014b, 2014a). This methodology is based on source > pathway > receptor chain principles and involves assessing likely significant effects on Natura 2000 sites within the zone of influence of the proposed drainage maintenance in relation to three pathways: 1. Surface water 2. Land & air 3. Groundwater The screening assessment involved assessing the impacts of drainage maintenance operations within the arterial drainage scheme, and its zone of influence, in relation to each of the three pathways individually. Conclusions were then drawn to identify if maintenance works upon the channels and embankments within the scheme, could impact upon Natura 2000 sites. Sites that had the potential to be impacted by the maintenance works were determined to be within the ZOI and these sites require further assessment. This included Carrowmore Dunes SAC (site code: 002250) and Mid-Clare Coast SPA (site code: 004182).

3.1.1 Surface Water Pathways As a result of the screening assessment (JBA 2014b) maintenance activities on those watercourses shown in Figure 3-1 including the Creegh River, were identified as potentially resulting in significant adverse impacts on Carrowmore Dunes SAC and Mid-Clare Coast SPA via surface water pathways.

Figure 3-1 Channels and embankments with potential impacts via surface water pathways This assessment was determined based on presence of surface water connectivity between the Natura 2000 sites and the Creegh Arterial Drainage Scheme, and considering a variety of factors. Relevant factors considered in the assessment included the "At Risk" status (Under the Water

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Framework Directive (WFD)) of all surface waterbodies within the area of works, the potential for impact, the significance of potential impacts and the relevance of any threats and pressures within the Natura 2000 site. Significance was determined based on the nature of the surface water dependant (SWD) qualifying interests that may be present and the nature of the scheme based on the hydrological setting within the catchment. Pre-determined distances and typologies (Ryan Hanley 2014b) were used to define the zone of influence of the works and determine potential and significance of impacts. Using the precautionary principle, during the screening assessment, SWD habitats and species that may be present were assessed as if present, based on information available in the Conservation Objectives, Natura 2000 Data Form and the Site Synopsis. These potentially present Qualifying Interests / Features of Interest were then assessed for the potential to be significantly impacted by the proposed works if present. The results of this assessment are in Table 3-1. Table 3-1 Summary results of SWD QIs / FOIs with potential surface water pathways, potential Annex I habitats present and potential for significant impact

EU SWD Qualifying Desktop Study Comment Conclusion Code Interest/Special Conservation Interest Carrowmore Dunes SAC (002250) 1016 Narrow-mouthed Whorl Located <5km upstream and some Potential for Likely Snail Vertigo angustior overlap. NPWS (2014a) state that Significant Effect within the SAC Narrow-mouthed Whorl snail are located in grid squares Q9969, Q9968 and Q9967; scheme watercourses are also located in these grid squares and consequently adverse impacts may arise.

SWD Annex I Special Desktop Study Conclusion habitats Habitat Conservatio Comment present n Interest likely to occur Mid-Clare Coast SPA (004182) Marine open This habitat is not of No potential effect water and value for any of the habitats (e.g. None SPAs special N/A reefs, conservation interests. islands) [MW1] No detailed information <5km upstream, on the distribution of 0km overlap - Sand Shores Mudflats and this habitat type within Potential for Likely and small sand flats not Ringed the SPA is available. Significant Effect dunes [LS2, covered by Plover Drainage maintenance CD1, CD2, seawater at activities are proposed CD3] low tide (1140) a short distance upstream of the SPA boundary. No detailed information <5km upstream, on the distribution of 0km overlap - this habitat type within Potential for Likely Exposed Sanderling the SPA is available. Significant Effect Rocky Reefs (1170) Drainage maintenance Shores [LR1, Ruddy activities are proposed LR2, LR3] Turnstone a short distance upstream of the SPA boundary.

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3.1.2 Land and Air Pathways As a result of the screening assessment (JBA 2014b) maintenance activities on those watercourses shown in Figure 3-2, including Creegh River, were identified as potentially resulting in significant adverse impacts on Carrowmore Dunes SAC and Mid-Clare Coast SPA via Land and Air pathways.

Figure 3-2 Channels and embankments with potential impacts via land and air pathways

This assessment was determined based on the location of the relevant Natura 2000 site and the Creegh Arterial Drainage Scheme, and considering a variety of factors. Factors considered include the nature of the relevant site, the location of the pathways and any other site specific factors such as topographic features that might influence the magnitude of potential impacts from each potential pathway. Each qualifying interest of the SAC and SPA were then assessed individually for potential to be impacted and the overall assessment included a review of the potential for cumulative and/or in-combination impacts as a result of the identified pressures and threats identified in the Natura 2000 form (NPWS 2015). Pre-determined distances and typologies (Ryan Hanley 2014b) were used to define the zone of influence of the works and determine potential and significance of impacts. Where no detailed information was available on the location of qualifying interests, the precautionary principle was used during the screening assessment. Species that may be present were assessed as if present throughout based on information available in the Conservation Objectives, Natura 2000 Data Form and the Site Synopsis. These potentially present QIs / FOIs were then assessed for potential to be significantly impacted by the proposed works if present. The results of this assessment are in Table 3-2.

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Table 3-2 Summary results of QIs / FOIs with potential land and air connectivity, resulting in a potential for impact from the proposed works through land and air pathways

EU Species/Habitats Maintenance Location Result Code activity of Impact location relative to Natura 2000 site boundary Mid-Clare Coast SPA (004182) Cormorant Phalacrocorax 100m A017 carbo 0km/Overlap (breeding Potential Effect and winter) Ringed Plover Charadrius 100m A137 0km/Overlap Potential Effect hiaticula (winter) Sanderling Calidris alba 100m A144 0km/Overlap Potential Effect (winter) Purple Sandpiper Calidris 50m A148 0km/Overlap Potential Effect maritima (winter) Dunlin Calidris alpina 100m A149 0km/Overlap Potential Effect (winter) Turnstone Arenaria 50m A169 0km/Overlap Potential Effect interpres (winter) Barnacle Goose Branta 300m A396 0km/Overlap Potential Effect leucopsis (winter) Wetlands & Waterbirds 0.01km/ A999 0km/Overlap Potential Effect overlap Carrowmore Dunes SAC (002250) 2110 Embryonic shifting dunes 0m/Overlap 10m Potential Effect Shifting dunes along the 0m/Overlap 2120 shoreline with Ammophila 10m Potential Effect arenaria (white dunes) Fixed coastal dunes with 0m/Overlap 2130 herbaceous vegetation 10m Potential Effect (grey dunes) Narrow-mouthed Whorl 1014 0m/Overlap MAC Potential Effect Snail Vertigo angustior Notes: MAC = Maintenance Access Corridor BR = Bridge INST = Instream

3.1.3 Groundwater Pathways As a result of the screening assessment (JBA 2014b) maintenance activities on those watercourses, including the Creegh River, shown in Figure 3-3 were identified as potentially resulting in significant adverse impacts on Carrowmore Dunes SAC and Mid-Clare Coast SPA via groundwater pathways.

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Figure 3-3 Channels and embankments with potential impacts via groundwater pathways This assessment was determined based on the location of the relevant Natura 2000 site within the same groundwater body as the Creegh Arterial Drainage Scheme (Miltown Malbay (IE_SH_G_167), and considering a variety of factors. Relevant factors considered in assessing the potential for the Natura 2000 site to be impacted through groundwater pathways also included the presence of Groundwater Dependant (GWD) QIs / FOIs, the risk status under the WFD of each site and the potential and significance of impact, should one occur. Each qualifying interest of the screened in Natura 2000 site, at this stage Carrowmore Dunes SAC, was then assessed individually for potential to be impacted and the overall assessment included a review of the potential for cumulative and/or in-combination impacts as a result of the identified pressures and threats identified in the Natura 2000 form (NPWS 2015). The location of the drainage maintenance activity works relative to the Natura 2000 site and features of interest were considered to determine relevance at this stage, along with GWD habitat typology. The Miltown Malbay GWB is considered to be poorly productive bedrock and is not at risk (WFD /EPA 2016). Pre-determined distances and typologies (Ryan Hanley 2014b) were used to define the zone of influence of the works and determine potential and significance of impacts. As no detailed information was available on the location of qualifying interests, the precautionary principle was used during the screening assessment. Species that may be present were assessed as if present throughout based on information available in the Conservation Objectives, Natura 2000 Data Form and the Site Synopsis. These potentially present QIs / FOIs were then assessed for potential to be significantly impacted by the proposed works if present. The results of this assessment are in Table 3-3. Table 3-3 Summary of Natura 2000 habitats potentially present in the zone of influence of the works that may potentially be significantly impacted by the proposed works

GWD Qualifying Interest GWB Habitat Drainage maintenance Result Habitats Typology activity location relevant to Natura 2000 site Carrowmore Dunes SAC (002250) Narrow-mouthed Whorl Snail A (for both 2190 Up and down gradient Potential for Vertigo angustior [1014] – and 6430) significant assumed to be present in dune

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GWD Qualifying Interest GWB Habitat Drainage maintenance Result Habitats Typology activity location relevant to Natura 2000 site slack habitats [2190] and tall- effect herb swamp [6430] habitats Note: GWD Habitat Typology after Table 5.1 Kilroy et al (2008) in Ryan Hanley (2014a) A = Type A, Groundwater Discharge Zone Wetlands

3.1.4 Summary of screening results The Screening Assessment (JBA, 2014) identified that the Carrowmore Dunes SAC (002250) and Mid-Clare Coast SPA (004182) was likely to be significantly affected by drainage maintenance operations undertaken within the Creegh Arterial Drainage Scheme, due to the presence of Surface Water, Land and Air and Groundwater pathways. This conclusion is through following the methodology described in the Screening Methodology Report (Ryan Hanley, 2014a). These conclusions are based on the assumption that all drainage maintenance activities are to be undertaken on all watercourses, embankments and structures during the life of the plan (2018- 2022). From this screening exercise it has been determined that significant likely effects may occur within the Carrowmore Dunes SAC (002250) and Mid-Clare Coast SPA (004182), and that habitats could be vulnerable to maintenance works which may reach the site via surface water pathways. Table 3-4. Screening conclusions

Pathway of Impact Comment Site Surface Land Ground Water and Air water No significant impacts, via any of the Ballyteige (Clare) three pathways, have been identified as SAC (000994) part of this assessment. The Narrow-mouthed Whorl Snail for which this site is designated are at risk Carrowmore Dunes from drainage maintenance activities via

SAC (002250) all three pathways. Other qualifying interests within the site are not at risk via any of the three pathways. Carrowmore Point to No significant impacts, via any of the Spanish Point and three pathways, have been identified as Islands SAC (001021) part of this assessment. Inagh River Estuary

SAC (000036) Kilkee Reefs SAC

(002264) Tullaher Lough and

Bog SAC (002343) Cliffs of Moher SPA

(004005) All bird species within the SPA are at risk from drainage maintenance activities via land and air pathways, and those species which rely on surface water dependent Mid-Clare Coast SPA habitats are also potentially at risk via (004182) surface water pathways. No adverse impacts via groundwater pathways were identified as the habitats within the site are not groundwater dependent. Note: Red = likely significant effect Green = no likely significant effect

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4 Existing Environment This section summarises the findings of the ecological walkover surveys of the embankments and channels of the Creegh River relative to the proposed 2018 - 2020 works for the Creegh Arterial Drainage Maintenance Scheme. Habitats were identified to Fossitt level as per Fossitt (2000). Photographs of the embankments and habitats are included where appropriate. The Creegh river waterbody is classified as "Good" River waterbody status during the 2010-2015 assessment cycle1.

4.1 General ecology of the site An ecological walkover survey was conducted on 25th and 26th September 2017 and 17th and 18th May 2018 of the proposed works area. The September survey of 2017 was carried out by JBA ecology Tanya Slattery and involved a baseline ecology walkover survey which noted the riparian ecology of each of the channels, noting key habitats (following Fossitt 2000), plant species and any animal signs or sightings. The May 2018 survey was a specialist ecology survey examining Narrow- mouthed whorl snail (Vertigo angustior) habitat, and was carried out by consultant ecologist, Rory Dalton. A brief summary of the specialist survey results are outlined in section 4.1.1 below. In terms of general ecology, the channel banks (C1) were heavily vegetated in in the upper reaches with dense brambles, nettles and thistles. Occasional willow also occurring bankside throughout, especially towards the mid-to lower channel reaches of C1. Within the channel, bulrush was the dominant marginal vegetation in the upper reaches of this channel. Further downstream, stands of Phragmites become dominant within the channel and the bordering embankment dominated by grasses, brambles and Phragmites. The channel increasingly becomes choked with vegetation with distance downstream. Bordering land use is generally semi-natural grassland and pasture. In the lowermost reaches, toward the golf links, reedbeds dominate the channel banks, with low lying bramble covering the embankments. Evidence of mammals and observations of birds were noted along main channel among which were meadow pippets displaying mating behaviour. Badger signs were noted throughout the main C1 channel. Specific locations of mammal and bird sighting are shown in the habitat map (Appendix A).

4.1.1 Whorl snail and dune slacks. A specialist survey for the Annex 1 species the Narrow-mouthed whorl snail (Vertigo angustior) was carried out during May 2018. The channel areas which bordered the SAC (channels C2/1, C2/2, C5) were examined for evidence of whorl snail as these areas were seen to consist of habitat which may be suitable for the species. 9 separate sampling points were chosen within the defined area along C2, C2/1, C2/2 and C5. The points sampled on C2 and C2/1 showed the most promising whorl snail habitat with intact areas of dune slack habitat (CD5) in the upper reaches of C2, representing optimal whorl snail habitat. Other sampling points exhibited CD5 habitat though with some levels of impact, representing suboptimal whorl snail habitat. The presence of Vertigo angustior was not observed during the survey, although other whorl snail species were found. Nonetheless, the precautionary approach should apply when carrying out maintenance works on this potential habitat on the channels described.

4.2 Description of habitats present Habitats recorded included during the ecological walkover surveys include: Table 4-1 Main habitats present at the Scheme Habitat Name Fossitt Code Building and artificial surfaces BL3 Shingle and gravel banks CB1 Marram dunes CD2 Fixed dunes CD3

1 http://gis.epa.ie/geoserver/ows?service=WMS&request=GetLegendGraphic&format=image%2Fpng&width=20&height=20&layer=EP A%3AWFD_RWBStatus_20102015

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Habitat Name Fossitt Code Dune slacks CD5 Recolonising bare ground ED3 Reed and large sedge swamps FS1 Drainage ditches FW4 Improved agricultural grassland GA1 Amenity grassland GA2 Marsh GM1 Grassy verge GS2 Wet Grassland GS4 Scrub WS1

Building and artificial surfaces (BL3) A small area of hard standing occurred within the survey area along channel C2 at the entrance to the golf links. The surface in this area is of tarmacadam and bears no important habitat potential for plant or animal species. Shingle and gravel banks (CB1) A small shingle and gravel bank runs along the foreshore on the western side of the Creegh estuary (C1). The extent of the gravel/shingle continues for approximately 500m along the shoreline and is within both the Mid Clare Coast SPA and Carrowmore Dunes SAC boundaries. Marram dunes (CD2) A small area of Marram Dunes (CD2) habitat was noted as within the survey area at the seaward end of the C1 channel, on the eastern side of the estuary. Species noted include Common Scurvygrass (Cochlearia officinalis) and Colt’s-foot (Tussilago farfara) on the seaward side and Red Fescue, Common Ragwort (Senecio jacobaea), White Clover and Cat’s-ear (Hypochoeris radicata) further inland. Fixed dunes (CD3) Fixed dunes were observed at the extreme end of the estuary directly behind the marram dune habitat as noted above. The extent of the habitat within survey area was small at some 100m2 approximately and within of very close to the SAC boundary line. Dune slacks (CD5) Dune slack habitat was noted within the survey area on Channel C2 and C2/1, C2/2, C2/3 and C2/4. This habitat, consisting of short herbs and groundwater-dependent species covers both optimal and suboptimal habitat for the Narrow Mouthed Whorl Snail and as such will need to be considered as protected for the purposes of this assessment. Recolonising bare ground (ED3) A small area of recolonising ground was noted at the northern extent of the study area. This habitat of pioneer species including nettle (Urtica dioica), dandelion (Taraxacum spp.), willow-herb (Epilobium sp.). The area of bare ground pertains to some disturbed land associated with prior roadworks adjacent to a roundabout which serves the Doonbeg golf club. Reed and large sedge swamps (FS1) A small area of reed and large sedge swamp was recorded at the extreme eastern end of channel C5. This swamp habitat is adjacent and surrounded by fields of improved agricultural grassland. Drainage ditches (FW4) Several drainage ditches were recorded and surveyed in the study area. These pertain to ditches draining farmland which ran directly adjacent to or into the main surveyed channels C1, C2, C2/1, C2/4 and C5. Refer to habitat map for visualization of drainage ditches and connection points. Improved agricultural grassland (GA1)

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Improved agricultural grassland was the dominant habitat type bounding the surveyed channels. This consisted of cattle and sheep pasture and was species poor grassland which had undergone some level of fertilisation. Amenity grassland (GA2) A small area of amenity grassland was recorded at the downstream end of channel C1 within the the grounds of the Doonbeg golf links complex. This area will have limited habitat value due its limited species diversity and human traffic. Marsh (GM1) Freshwater Marsh habitat was recorded in the middle reaches of channel C1 along the left hand bankside. Its bordering habitat is wet grassland which grades into the area of marsh. Species present included a variety of rushes (Juncus spp.), sedges (Carex spp.) although these did not dominate. Also present were Meadowsweet (Filipendula ulmaria). Grasses such as Creeping Bent (Agrostis stolonifera), Tall Fescue (Festuca arundinacea). Broadleaved herbs such as Mint (Mentha aquatica), Ragged-robin (Lychnis flos-cuculi), Purpleloosestrife (Lythrum salicaria), horsetails (Equisetum spp.), and Yellow Iris (Iris pseudacorus) were also present. Grassy verge (GS2) Grassy verges were recorded along channel C2 and northward along the road side to the roundabout at the entrance to the Doonbeg complex. A thin strip of this habitat marks the boundary between road and agricultural land further back. Species present included False Oat-grass (Arrhenatherum elatius), nettlle (Urtica dioeca), Pignut (Conopodium majus), Creeping Cinquefoil (Potentilla reptans) and clovers (Trifolium spp.). Wet Grassland (GS4) Two areas of wet grassland were recorded - the first towards the lower reaches of the C1 channel just upstream of the Doonbeg complex, and the second mid-way along the C5 channel. Both in include wet grassland with rushes, meadowsweet, thistles and nettles among the grasses. Scrub (WS1) Extensive swathes of scrub were recorded particularly along the channel C5 where much bramble and gorse lined the riparian zone. This type of dense scrub habitat bordering the channels would have good potential for breeding birds and refuge opportunities for other terrestrial species.

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5 Natura 2000 sites within the Zone of Influence of the works/scheme

5.1 Introduction This chapter provides baseline information on the Natura 2000 site within the Zone of Influence (ZOI) of the drainage maintenance activities (i.e. that screened into the assessment as detailed in Table 3-4). A description of the site is provided, along with details of the qualifying interests and conservation objectives and site vulnerabilities.

5.2 Carrowmore Dunes SAC (002250) The Carrowmore Dunes are situated on the south-western coast of Co. Clare, roughly midway between Milltown Malbay and Kilkee, and extend from Carrowmore Point in the north to Doonbeg Bay in the south. Fine sandy beach merges into a cobble beach on the seaward side of a sand dune system. Exposed bedrock marks the northern and southern boundaries of the site. Seaward, the site extends for 500 m from the shore to include shallow marine waters. The geology of the site comprises Upper Carboniferous sandstone and shale. Pure sand dominates the soils on the seaward side, with increasing organic content further inland. Fixed dune habitat with herbaceous vegetation is the largest habitat present within the site. Typically, the high dunes have an abundant Marram (Ammophila arenaria) cover and in places attain a height of up to 25 m. At the landward side, in the drier sheltered hollows a closed grassy community Marram dunes occur on the steeper, seaward slopes of the dunes above the beach and at the edges of blow-outs. Typically, the cover of Marram is high and there is little ground vegetation over bare sand. Common Scurvygrass (Cochlearia officinalis) and Colt’s-foot (Tussilago farfara) occur occasionally amongst the Marram on the seaward side, with Red Fescue, Common Ragwort (Senecio jacobaea), White Clover and Cat’s-ear (Hypochoeris radicata) increasing inland. Due to the exposure and high levels of coastal erosion at this site, the embryonic shifting, or fore dunes are not significantly developed, Intertidal reefs occur on the seaward side of the site and are particularly well developed about Magrath’s Point at the southern end of the site. This site contains a relatively small area of intertidal sandflats, comprised of fine to course sand. The site supports a population of the rare snail Vertigo angustior, a species that is listed on Annex II of the E.U. Habitats Directive. Towards the back of the dune system there are two wetland areas that serve as important refuges for V. angustior, particularly in drier summers. The vegetation can reach heights in excess of 2 m, and is dominated by reeds, sedges (Carex spp.) and Yellow Iris (Iris pseudacorus), with an understorey of Great Willowherb (Epilobium hirsutum), Meadowsweet (Filipendula ulmaria), Water Horsetail (Equisetum fluviatile), Creeping Bent (Agrostis stolonifera) and the moss Calliergon cuspidatum. Common Reed (Phragmites australis) is dominant in the wettest areas. The site is used by a number of bird species, including Chough (a species that is listed on Annex I of the E.U. Birds Directive), Curlew, Dunlin, Oystercatcher, Ringed Plover, Lapwing, Wigeon, Black- headed Gull and Common Gull. A number of other species are intermittent visitors. The Carrowmore Dunes site is of considerable conservation significance, supporting good examples of four habitats that are listed on Annex I of the E.U. Habitats Directive, as well as a population of the rare Annex II snail, Vertigo angustior.

5.2.1 Qualifying Interests The site is a Special Area of Conservation (SAC) selected for the habitats and/or species listed on Annex I / II of the E.U. Habitats Directive (* = priority; numbers in brackets are Natura 2000 codes), as detailed in Table 5-1. Table 5-1: Qualifying Interests of the Carrowmore Dunes SAC (002250)

Code Qualifying Interest 1014 Narrow-mouthed Whorl Snail Vertigo angustior 1170 Reefs

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Code Qualifying Interest 2110 Embryonic shifting dunes 2120 Shifting dunes along the shoreline with Ammophila arenaria (white dunes) 2130 Fixed coastal dunes with herbaceous vegetation (grey dunes)*

5.2.2 Conservation Objectives The Conservation Objective for the Carrowmore Dunes SAC (002250) is to maintain or restore the favourable conservation condition of the Annex I habitat(s) and/or the Annex II species for which the SAC has been selected (NPWS, 2014). Qualifying interests and their attributes for Carrowmore Dunes SAC, which may be present in the area and have the potential to be impacted by the proposed maintenance works are listed in Table 5-2. Five dune habitats were recorded by Ryle et al. (2009) for Carrowmore Dunes SAC. These habitats include mobile areas at the front, as well as more stabilised parts of dune systems. Humid dune slacks and annual vegetation of driftlines were also recorded at the Whitestrand sub-site in the NPWS site synopsis but not included as Qualifying Interests. Areas of humid dune slacks have been identified outside of the Natura 2000 site boundary, with some modified by the Golf Course development.(NPWS 2014c). Table 5-2: Conservation Objectives of Carrowmore Dunes SAC (002250)

1170 Reefs To maintain the favourable conservation condition of Reefs in Carrowmore Dunes SAC, which is defined by the following list of attributes and targets: Attribute Measure Target Notes Habitat area Hectares The permanent habitat area Habitat area estimated as is stable or increasing, 211ha from a 1996 BioMar subject to natural survey (Picton and Costello, processes. See map 3 1997) and 2011 and 2012 intertidal and subtidal reef surveys (MERC, 2012, 2013). See marine supporting document for further details Distribution Occurrence The distribution of reefs is Based on information from a stable or increasing, 1996 BioMar survey (Picton subject to natural and Costello, 1997) and 2011 processes. See map 3 and 2012 intertidal and subtidal reef surveys (MERC, 2012, 2013). See marine supporting document for further details Community Biological Conserve the following Reef mapping based on structure composition community types in a information from a 1996 BioMar natural condition: Intertidal survey (Picton and Costello, reef community complex; 1997) and 2011 and 2012 Laminaria-dominated intertidal and subtidal reef community complex. See surveys (MERC, 2012, 2013). map 4 See marine supporting document for further details from the Conservation Objectives for Carrowmore Dunes SAC 002250 (NPWS 2014b)

2210 Embryonic shifting dunes To restore the favourable conservation condition of Embryonic shifting dunes in Carrowmore Dunes SAC, which is defined by the following list of attributes and targets: Attribute Measure Target Notes Habitat area Hectares Area increasing, Based on data from the Coastal subject to natural Monitoring Project (CMP) (Ryle et al., processes, 2009). Habitat is very difficult to including erosion measure in view of its dynamic nature. and succession. See coastal habitats supporting For sub-site document for further details mapped: White Strand 0.19ha.

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2210 Embryonic shifting dunes To restore the favourable conservation condition of Embryonic shifting dunes in Carrowmore Dunes SAC, which is defined by the following list of attributes and targets: (refer to map 5 of NPWS, 2014b. Habitat Occurrence No decline, subject Based on data from Ryle et al. (2009). distribution to natural Embryonic dunes are present along the processes. See seaward side of the dune system at the map 5 for known foot of tall marram dunes. Due to the distribution high exposure and retreating conditions of the west coast, typically the fore dunes are poorly developed. See coastal habitats supporting document for further details Physical Presence/ Maintain the Dunes are naturally dynamic systems structure: absence of natural circulation that require continuous supply and functionality and physical of sediment and circulation of sand. Physical barriers can sediment supply barriers organic matter, lead to fossilisation or over-stabilisation without any of dunes, as well as beach starvation physical resulting in increased rates of erosion. obstructions Soft erosion protection measure have been installed to protect eroding areas of the golf course since 2001. These measures are absent from areas fronting the high dune sections within the SAC. See coastal habitats supporting document for further details Vegetation Occurrence Maintain the range Based on data Ryle et al. (2009). structure: of coastal habitats Carrowmore dunes support a range of zonation including other dune habitats including marram transitional zones, dunes, fixed dunes, dune slacks, annual subject to natural vegetation of driftlines and perennial processes vegetation of stony banks. The dunes including erosion are also connected to a significant and succession wetland area known as Carrowmore Marsh. See coastal habitats supporting document for further details Vegetation Percentage More than 95% of Based on data from Ryle et al. (2009). composition: cover sand couch See coastal habitats supporting plant health of (Elytrigia juncea) document for further details dune grasses and/or lyme-grass (Leymus arenarius) should be healthy (i.e. green plant parts above ground and flowering heads present) Vegetation Percentage Maintain the Based on data from Ryle et al. (2009). composition: cover at a presence of See coastal habitats supporting typical species representative species-poor document for further details and number of communities with subcommunities monitoring typical species: stops sand couch (Elytrigia juncea) and/or lyme-grass (Leymus arenarius) Vegetation Percentage Negative indicator Based on data from Ryle et al. (2009). composition: cover species (including Negative indicators include non-native negative non-native species) species, species indicative of changes in indicator to represent less nutrient status and species not species than 5% cover considered characteristic of the habitat. Seabuckthorn (Hippophae rhamnoides) should be absent or effectively controlled. This species has not been recorded at this site. See coastal habitats supporting document for further

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2210 Embryonic shifting dunes To restore the favourable conservation condition of Embryonic shifting dunes in Carrowmore Dunes SAC, which is defined by the following list of attributes and targets: details from the Conservation Objectives for Carrowmore Dunes SAC 002250 (NPWS 2014b)

2120 Shifting dunes along the shoreline with Ammophila arenaria (white dunes) To restore the favourable conservation condition of Shifting dunes along the shoreline with Ammophila arenaria ('white dunes') in Carrowmore Dunes SAC, which is defined by the following list of attributes and targets: Attribute Measure Target Notes Habitat area Hectares Area stable or increasing, Based on data from the Coastal subject to natural processes Monitoring Project (CMP) (Ryle including erosion and et al. 2009). Habitat mapped at succession. For subsite one sub-site to give a total mapped: White Strand- estimated area of 2.15ha. 2.15ha. (refer to map 5 of Habitat is very difficult to NPWS, 2014b. measure in view of its dynamic nature. See coastal habitats supporting document for further details Habitat Occurrence No decline, or change in Shifting dunes along the distribution habitat distribution, subject shoreline with Ammophila to natural processes. See arenaria, or marram dunes, map 5 for known distribution occur on the seaward steeper slopes of the dunes above the beach and at the edges of blowouts. See coastal habitats supporting document for further details Physical Presence/ Maintain the natural Dunes are naturally dynamic structure: absence of circulation of sediment and systems that require continuous functionality and physical organic matter, without any supply and circulation of sand. sediment supply barriers physical obstructions Marram grass (Ammophila arenaria) reproduces vegetatively and requires constant accretion of fresh sand to maintain active growth. Soft coastal protection measures have been installed since 2001 to protect eroding parts of the golf course. These measures are absent from the front of the north and south high dune sections within the SAC. See coastal habitats supporting document for further details Vegetation Occurrence Maintain the range of Based on data from Gaynor structure: coastal habitats including (2008) and Ryle et al. (2009). zonation transitional zones, subject Carrowmore dunes support a to natural processes range of other dune habitats including erosion and including embryonic dunes, succession fixed dunes, dune slacks, annual vegetation of driftlines and perennial vegetation of stony banks. The dunes are also connected to a significant wetland area known as Carrowmore Marsh. See coastal habitats supporting document for further details Vegetation Percentage More than 95% of marram Based on data from Ryle et al. composition: cover grass (Ammophila arenaria) (2009). See coastal habitats plant health of and/or lymegrass (Leymus supporting document for further dune grasses arenarius) should be details

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2120 Shifting dunes along the shoreline with Ammophila arenaria (white dunes) To restore the favourable conservation condition of Shifting dunes along the shoreline with Ammophila arenaria ('white dunes') in Carrowmore Dunes SAC, which is defined by the following list of attributes and targets: healthy (i.e. green plant parts above ground and flowering heads present) Vegetation Percentage Maintain the presence of Based on data from Ryle et al. composition: cover at a species-poor communities (2009). See coastal habitats typical species representative dominated by marram grass supporting document for further and number of (Ammophila arenaria) details subcommunities monitoring and/or lymegrass (Leymus stops arenarius). Vegetation Percentage Negative indicator species Based on data from Ryle et al. composition: cover (including non-native (2009). Negative indicators negative species) to represent less include non-native species; indicator than 5% cover species indicative of changes in species nutrient status and species not considered characteristic of the habitat. Seabuckthorn (Hippophae rhamnoides) should be absent or effectively controlled. This species has not been recorded at this site. See coastal habitats supporting document for further details from the Conservation Objectives for Carrowmore Dunes SAC 002250 (NPWS 2014b)

2130 Fixed coastal dunes with herbaceous vegetation (grey dunes) To restore the favourable conservation condition of Fixed coastal dunes with herbaceous vegetation ('grey dunes') in Carrowmore Dunes SAC, which is defined by the following list of attributes and targets: Attribute Measure Target Notes Habitat area Hectares Area stable or increasing, Based on data from Coastal subject to natural processes Monitoring Project (CMP) (Ryle including erosion and et al., 2009). One sub-site was succession. For subsite mapped, giving a total mapped: White Strand- estimated area of 10.46ha. See 10.46ha. See map 5 coastal habitats supporting document for further details Habitat Occurrence No decline, or change in Based on data from Ryle et al. distribution habitat distribution, subject (2009). Fixed dunes represent to natural processes. See the largest dune habitat present map 5 for known distribution within the SAC. See coastal habitats supporting document for further details Physical Presence/ Maintain the natural Physical barriers can lead to structure: absence of circulation of sediment and fossilisation or overstabilisation functionality and physical organic matter, without any of dunes, as well as beach sediment supply barriers physical obstructions starvation resulting in increased rates of erosion. Soft coastal protection measures have been installed since 2001 to protect eroding parts of the golf course. These measures are absent from the front of the north and south high dune sections within the SAC. See coastal habitats supporting document for further details Vegetation Occurrence Maintain the range of Based on data from Ryle et al. structure: coastal habitats including (2009). Carrowmore dunes zonation transitional zones, subject support a range of other dune to natural processes habitats including embryonic

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2130 Fixed coastal dunes with herbaceous vegetation (grey dunes) To restore the favourable conservation condition of Fixed coastal dunes with herbaceous vegetation ('grey dunes') in Carrowmore Dunes SAC, which is defined by the following list of attributes and targets: including erosion and dunes, marram dunes, dune succession slacks, annual vegetation of drift lines and perennial vegetation of stony banks. The dunes are also connected to a significant wetland area known as Carrowmore Marsh. See coastal habitats supporting document for further details Vegetation Percentage Bare ground should not Based on data from Gaynor structure: bare cover exceed 10% of fixed dune (2008) and Ryle et al. (2009). ground habitat, subject to natural See coastal habitats supporting processes document for further details Vegetation Centimetres Maintain structural variation Based on data from Gaynor structure: sward within sward (2008) and Ryle et al. (2009). height The dunes are moderately grazed as part of an agreed management plan. See coastal habitats supporting document for further details Vegetation Percentage Maintain range of Based on data from Gaynor composition: cover at a subcommunities with typical (2008) and Ryle et al. (2009). typical species representative species listed in Ryle et al. Mountain pansy (Viola lutea) is and number of (2009) considered an indicator of local subcommunities monitoring distinctiveness. See coastal stops habitats supporting document for further details. Vegetation Percentage Negative indicator species Based on data from Ryle et al. composition: cover (including non-natives) to (2009). Negative indicators negative represent less than 5% include non-native species, indicator cover species indicative of changes in species nutrient status and species not (including considered characteristic of the Hippophae habitat. Seabuckthorn rhamnoides) (Hippophae rhamnoides) should be absent or effectively controlled. This species has not been recorded at this site. See coastal habitats supporting document for further details Vegetation Percentage No more than 5% cover or Based on data from CMP (Ryle composition: cover under control et al. 2009). See coastal scrub/trees habitats supporting document for further details from the Conservation Objectives for Carrowmore Dunes SAC 002250 (NPWS 2014b)

1010 Narrow-mouthed Whorl Snail Vertigo angustior To maintain the favourable conservation condition of Narrow-mouthed Whorl Snail in Carrowmore Dunes SAC, which is defined by the following list of attributes and targets: Attribute Measure Target Notes Distribution occupied sites Number No decline. There are four known terrestrial sub-sites for this species in this SAC, which overlap three 1km squares. See map 6 From Moorkens and Killeen (2011) (site code Va CAM18), Moorkens (2004-2011); Moorkens and Browne (2003); and Moorkens and Gaynor (2000- 2002)

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1010 Narrow-mouthed Whorl Snail Vertigo angustior To maintain the favourable conservation condition of Narrow-mouthed Whorl Snail in Carrowmore Dunes SAC, which is defined by the following list of attributes and targets: Presence on Occurrence Adult or sub-adult snails are Transect established as part of transect present in at least four of condition assessment the six maritime grassland monitoring at this site zones on the transect (Moorkens and Killeen, 2011). where optimal or sub- See habitat extent target below optimal habitat occurs for definition of optimal and sub-optimal habitat Abundance on Number per At least two samples on the From Moorkens and Killeen transect sample transect should have more (2011) than 20 V. angustior individuals Transect habitat Metres At least 75m of habitat of From Moorkens and Killeen quality the transect is classed as (2011). See habitat extent optimal or sub-optimal, with target below for definition of at least 40m classed as optimal and sub-optimal habitat optimal Transect Metres Soils, at time of sampling, From Moorkens and Killeen optimal wetness are damp (optimal wetness) (2011) and covered with a layer of humid thatch for at least 40m along the transect Habitat extent Hectares A minimum of 19ha of the From Moorkens and Killeen SAC is in optimal/ (2011). Note, there are suboptimal condition, additional areas of optimal and subject to natural sub-optimal habitat beyond the processes. Optimal habitat SAC boundary (Moorkens, is defined as fixed dune 2004-2011; Moorkens and vegetation of species-rich Browne, 2003; Moorkens and grassland dominated by red Gaynor, 2000-2002). See also fescue (Festuca rubra), with the conservation objective for sparse marram grass fixed dunes (2130) (Ammophila arenaria), lady’s bedstraw (Galium verum) and other low growing herbs, with height of 10-30cm, growing on damp, friable soil covered with a layer of humid, open structured thatch. Sub- optimal habitat is as optimal habitat but either vegetation height is less than 10cm or is between 30 and 50cm; or the soil is dry and sandy; or the thatch is wetter with a denser structure. Also included in this definition are the wetland areas with yellow iris (Iris pseudacorus) and taller sedge species from the Conservation Objectives for Carrowmore Dunes SAC 002250 (NPWS 2014b)

5.2.3 Site Vulnerabilities Negative pressures or threats identified in the Standard Natura 2000 form for this site are listed in Table 5-2.

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Table 5-2 List of pressures and threats to Carrowmore Dunes SAC

Threat or pressure Rank Sand and gravel extraction (C01.01) - outside Medium Hunting, fishing or collecting activities (F06) - inside Low Stock feeding - (A05.02) - outside High Stock feeding (A05.02) - inside Low Nautical sports (G01.01) - inside Medium Grazing (A04) - inside Medium Erosion (K01.01) - inside High Fertilisation (A08) - outside Medium Grazing (A04) - outside High

5.3 Mid-Clare Coast SPA (004182) The Mid-Clare Coast SPA site extends along the Co. Clare coastline in a south-south-westerly direction from Spanish Point (3 km west of Milltown Malbay) to just west of Doonbeg Bay, a distance of some 14 km. The mainland shoreline is mostly rocky or stony, though there are several sandy beaches and areas of intertidal flats. Shingle or stony banks are found at the base of cliffs and at the head of bays. The site is a Special Protection Area (SPA) under the E.U. Birds Directive, of special conservation interest for the following species: Cormorant, Barnacle Goose, Ringed Plover, Sanderling, Purple Sandpiper, Dunlin and Turnstone. The E.U. Birds Directive pays particular attention to wetlands, and as these form part of this SPA, the site and its associated waterbirds are of special conservation interest for Wetland & Waterbirds.

5.3.1 Qualifying Interests The site is a Special Protection Area (SPA) selected for the habitats and/or species listed on Annex I / II of the E.U. Habitats Directive (* = priority; numbers in brackets are Natura 2000 codes), as detailed in Table 5-1. Table 5-3: Qualifying Interests of the Mid-Clare Coast SPA (004182)

Code Qualifying Interest A017 Cormorant Phalacrocorax carbo A045 Barnacle Goose Branta leucopsis A137 Ringed Plover Charadrius hiaticula A144 Sanderling Calidris alba A148 Purple Sandpiper Calidris maritima A149 Dunlin Calidris alpina alpina A169 Turnstone Arenaria interpres A999 Wetlands

5.3.2 Conservation Objectives The Conservation Objective for the Mid-Clare Coast SPA (004182) is to maintain or restore the favourable conservation condition of the Annex I habitat(s) and/or the Annex II species for which the SAC has been selected (NPWS, 2014). Qualifying interests and their attributes for Mid-Clare Coast SPA, which may be present in the area and have the potential to be impacted by the proposed maintenance works are listed in Table 5-4. Table 5-4. Conservation Objectives of Mid-Clare Coast SPA (004182)

A045 Barnacle Goose Branta leucopsis To maintain the favourable conservation condition of Barnacle Goose in Mid-Clare Coast SPA, which is defined by the following list of attributes and targets: Attribute Measure Target Notes Population Percentage Long term population trend Population trends are trend change stable or increasing presented in part four of the

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A045 Barnacle Goose Branta leucopsis To maintain the favourable conservation condition of Barnacle Goose in Mid-Clare Coast SPA, which is defined by the following list of attributes and targets: conservation objectives supporting document Distribution Range, timing No significant decrease in Waterbird distribution from the and intensity the range, timing or 2010/2011 waterbird survey of use of intensity of use of areas by programme is discussed in part areas barnacle goose other than five of the conservation that occurring from natural objectives supporting document patterns of variation from the Conservation Objectives for Mid-Clare Coast SPA 004182 (NPWS 2014)

A017 Cormorant Phalacrocorax carbo To maintain the favourable conservation condition of Cormorant in Mid-Clare Coast SPA, which is defined by the following list of attributes and targets: Attribute Measure Target Notes Breeding Number No significant decline Measure based on standard population survey methods (see Walsh et abundance: al., 1995). The Seabird apparently Monitoring Programme (SMP) occupied nests online database (JNCC, 2014) (AONs) provides population data for this species Productivity rate Mean number No significant decline Measure based on standard survey methods (see Walsh et al., 1995). The Seabird Monitoring Programme (SMP) online database (JNCC, 2014) provides population data for this species Distribution: Number; No significant decline Cormorant colonies are usually breeding location; area sited on flat or rocky islets or colonies sea stack tops, less often on cliffs (Walsh et al., 1995). Mattle Island is a traditional breeding colony in this SPA Prey biomass Kilogrammes No significant decline Key prey items: fish (mostly available benthic), some crustaceans. Key habitats: populations use sandy areas as well as rocky and vegetated substrates. Foraging range: max. 50km, mean max. 31.67km, mean 8.46km (BirdLife International Seabird Database (Birdlife International, 2014)) Barriers to Number; No significant increase Seabird species make connectivity location; extensive use of the marine shape; area waters adjacent to their breeding colonies. Foraging range: max. 50km, mean max. 31.67km, mean 8.46km (BirdLife International Seabird Database (Birdlife International, 2014)) Disturbance at Level of Human activities should Cormorant colonies are usually the breeding impact occur at levels that do not sited on flat or rocky islets or site adversely affect the stack stops, less often on cliffs breeding cormorant (Walsh et al., 1995). Mattle population Island is a traditional breeding site from the Conservation Objectives for Mid-Clare Coast SPA 004182 (NPWS 2014)

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A137 Ringed Plover Charadrius hiaticula To maintain the favourable conservation condition of Ringed Plover in Mid-Clare Coast SPA, which is defined by the following list of attributes and targets: Attribute Measure Target Notes Population Percentage Long term population trend Population trends are trend change stable or increasing presented in part four of the conservation objectives supporting document Distribution Range, timing No significant decrease in Waterbird distribution from the and intensity the range, timing or 2010/2011 waterbird survey of use of intensity of use of areas by programme is discussed in part areas ringed plover, other than five of conservation objectives that occurring from natural supporting document patterns of variation from the Conservation Objectives for Mid-Clare Coast SPA 004182 004182 (NPWS 2014)

A144 Sanderling Calidris alba To maintain the favourable conservation condition of Sanderling in Mid-Clare Coast SPA, which is defined by the following list of attributes and targets: Attribute Measure Target Notes Population Percentage Long term population trend Population trends are trend change stable or increasing presented in part four of the conservation objectives supporting document Distribution Range, timing No significant decrease in Waterbird distribution from the and intensity the range, timing or 2010/2011 waterbird survey of use of intensity of use of areas by programme is discussed in part areas ringed plover, other than five of conservation objectives that occurring from natural supporting document patterns of variation from the Conservation Objectives for Mid-Clare Coast SPA 004182 (NPWS 2014)

A148 Purple Sandpiper Calidris maritima To maintain the favourable conservation condition of Purple Sandpiper in Mid-Clare Coast SPA, which is defined by the following list of attributes and targets: Attribute Measure Target Notes Population Percentage Long term population trend Population trends are trend change stable or increasing presented in part four of the conservation objectives supporting document Distribution Range, timing No significant decrease in Waterbird distribution from the and intensity the range, timing or 2010/2011 waterbird survey of use of intensity of use of areas by programme is discussed in part areas ringed plover, other than five of conservation objectives that occurring from natural supporting document patterns of variation from the Conservation Objectives for Mid-Clare Coast SPA 004182 (NPWS 2011)

A149 Dunlin Calidris alpina alpina To maintain the favourable conservation condition of Dunlin in Mid-Clare Coast SPA, which is defined by the following list of attributes and targets: Attribute Measure Target Notes Population Percentage Long term population trend Population trends are trend change stable or increasing presented in part four of the conservation objectives supporting document Distribution Range, timing No significant decrease in Waterbird distribution from the

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A149 Dunlin Calidris alpina alpina To maintain the favourable conservation condition of Dunlin in Mid-Clare Coast SPA, which is defined by the following list of attributes and targets: and intensity the range, timing or 2010/2011 waterbird survey of use of intensity of use of areas by programme is discussed in part areas ringed plover, other than five of conservation objectives that occurring from natural supporting document patterns of variation from the Conservation Objectives for Mid-Clare Coast SPA 004182 (NPWS 2014)

A169 Turnstone Arenaria interpres To maintain the favourable conservation condition of Turnstone in Mid-Clare Coast SPA, which is defined by the following list of attributes and targets: Attribute Measure Target Notes Population Percentage Long term population trend Population trends are trend change stable or increasing presented in part four of the conservation objectives supporting document Distribution Range, timing No significant decrease in Waterbird distribution from the and intensity the range, timing or 2010/2011 waterbird survey of use of intensity of use of areas by programme is discussed in part areas ringed plover, other than five of conservation objectives that occurring from natural supporting document patterns of variation from the Conservation Objectives for Mid-Clare Coast SPA 004182 (NPWS 2014)

A999 Wetlands To maintain the favourable conservation condition of the wetland habitat in Mid-Clare Coast SPA as a resource for the regularly occurring migratory waterbirds that utilise it. This is defined by the following attribute and target: Attribute Measure Target Notes Habitat area Hectares The permanent area The wetland habitat area was occupied by the wetland estimated as 4,641ha using OSi habitat should be stable and data and relevant not significantly less than orthophotographs. For further the area of 4,641 hectares, information see part three of the other than that occurring conservation objectives from natural patterns of supporting document variation from the Conservation Objectives for Mid-Clare Coast SPA 004182 (NPWS 2014)

5.3.3 Site Vulnerabilities Negative pressures or threats identified in the Standard Natura 2000 form for this site are listed in Table 5-2. Table 5-5 List of pressures and threats to Mid-Clare Coast SPA (004182)

Threat or pressure Rank Leisure fishing (F02.03) - inside Medium Walking, horseriding and non-motorised vehicles (G01.02) - inside Medium Grazing (A04) - inside Medium Nautical sports (G01.01) - inside Medium Grazing (A04) - outside Medium

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6 Appropriate Assessment

6.1 Introduction The following chapter assesses the screened in Natura 2000 site in more detail using the additional information provided and examines where adverse impacts may arise from the sources of impact identified in Section 5. The full impact assessment on these features is found in Section 6.4. The screened in Natura 2000 sites are:

• Carrowmore Dunes SAC • Mid-Clare Coast SPA

The Screening Assessment (JBA, 2014) identified that the above sites Carrowmore Dunes SAC (002250) and Mid-Clare Coast SPA (004182) as likely to be significantly affected by drainage maintenance operations undertaken within the Creegh Arterial Drainage Scheme, due to the presence of Surface Water, Land and Air and Groundwater pathways. These conclusions are based on the assumption that all drainage maintenance activities are to be undertaken on all watercourses, embankments and structures during the life of the plan (2018-2022). As reported in the Appropriate Assessment screening report, it was established that only certain QI of the Carrowmore Dunes SAC were at risk of being affected by the proposed maintenance operations. Specifically, the Narrow mouthed whorl snail (Vertigo angustior). This risk applied to all three pathways - Surface water, Groundwater, Land and Air categories. The Mid Clare Coast SPA was cited as at risk and all bird species within the SPA found to be at risk from drainage maintenance activities via land and air pathways, and those species which rely on surface water dependent habitats are also potentially at risk via surface water pathways. No adverse impacts via groundwater pathways were identified as the habitats within the SPA site are not groundwater dependent. The following sections examine the individual sources of impact for each of the Qualifying Interests which are at risk of impact, for each of the Natura 2000 sites.

6.2 Identification of Potential Sources of Impact This section further examines the source > pathway > receptor chains that could potentially result in adverse impacts arising on the Carrowmore Dunes SAC and Mid-Clare Coast SPA.

6.2.1 Surface Water Natura 2000 Site (Site Code) Qualifying Interests/ Special Conservation Interests likely to be affected by drainage maintenance activities via Land and Air Pathways Carrowmore Dunes SAC (002250) Narrow Mouthed Whorl Snail (Vertigo angustior) [1014] – assumed to be present in dune slack habitats [2190] and tall-herb swamp [6430] habitats surveyed Mid Clare Coast SPA (004182) Cormorant Phalacrocorax carbo [A017] Barnacle Goose Branta leucopsis [A045] Ringed Plover Charadrius hiaticula [A137] Sanderling Calidris alba [A144] Purple Sandpiper Calidris maritima [A148] Dunlin Calidris alpina alpina [A149] Turnstone Arenaria interpres [A169] Wetland and Waterbirds [A999]

The Narrow-mouthed Whorl Snail for which the Carrowmore Dunes SAC site is designated are at risk from drainage maintenance activities. Changes in water levels/channel morphology can arise from a variety of activities, including removal of in-stream silt and vegetation and bush cutting/ branch trimming. It can occur from maintenance activities that deepen and widen the channel back to the original design level. This can impact on surface water dependent habitats indirectly through increased capacity and flow in the channel leading to hydrological impacts.

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Additionally, those bird species which rely on surface water dependent habitats within the Mid-Clare Coast SPA are potentially at risk via surface water pathways. A number of potential deleterious sources of impact could affect the bird species for which the SPA is designated. Drainage maintenance activities could impact on these habitats through the release of nutrients, suspended solids and pollution incidents which could potentially result in reduced water quality, eutrophication and increased turbidity, which could impact upon the wetland habitats and potentially the food supply (i.e. macroinvertebrates and fish) of the waterbirds, Additionally, the physical changes to the channel hydromorphology could impact on surface water flows and water table levels. This could then have adverse impacts on those habitats and distribution of the waterbirds they support. The following sources of impact from proposed works are identified as potentially affecting the above Natura 2000 sites through surface water pathways: • Release of suspended solids - this can arise from a variety of drainage maintenance activities, including removal of in-stream silt and vegetation, and bush cutting/ branch trimming. It can impact on surface water dependent habitats indirectly through increased turbidity, which can reduce photosynthesis levels. It can also impact indirectly on waterbirds of special conservation interest by affecting food chains from reduced water clarity and reduced photosynthesis which can affect aquatic invertebrate diversity (i.e. the food source of the waterbirds) • Release or changes in nutrient levels/pollutants - this can arise from a variety of drainage maintenance activities, including removal of in-stream silt and vegetation, and bush cutting/ branch trimming, and also through spillages or leaks of contaminative material. It can impact on surface water dependent habitats indirectly through causing eutrophication and reducing water quality and ability to support Annex II species. There is also the potential for pollutants (e.g. fuel) to be released from construction activities with machinery working in or near water as a result of pollution incidents, fuel spillages or poorly maintained machinery. It can also impact indirectly on waterbirds of special conservation interest by affecting food chains through increased algal growth and decreased invertebrate and algal diversity (i.e. the food source of the waterbirds). • Changes in water levels/channel morphology - this can arise from a variety of drainage maintenance activities, including removal of in-stream silt and vegetation and bush cutting/ branch trimming. It can occur from maintenance activities that deepen and widen the channel back to the original design level. This can impact on surface water dependent habitats indirectly through increased capacity and flow in the channel leading to hydrological impacts.

6.2.2 Groundwater The Narrow-mouthed Whorl Snail for which this site is designated are at risk from drainage maintenance activities. Vertigo angustior is a groundwater-dependant species. Groundwater levels if affected, could impact on the dune slack habitat (CD5). The physical changes to channel hydromorphology could impact on water table levels and thus affect the moisture levels within the dune and riparian habitat.

Natura 2000 Site (Site Qualifying Interests/ Special Conservation Interests likely to be Code) affected by drainage maintenance activities via Groundwater Pathways Carrowmore Dunes SAC Narrow Mouthed Whorl Snail (Vertigo angustior) [1014] – assumed to be (002250) present in dune slack habitats [2190] and tall-herb swamp [6430] habitats

Figures 6.1 and 6.2 show example of the nature of the dune slack habitat (CD5) found on site - chiefly on channels C2, C2/2 C2/3 and C2/4.

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Figure 6-1 Example of CD5 Dune Slack habitat (on channel C2/2)

Figure 6-2 Close up of Dune Slack vegetation

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The following sources of impact in particular have been identified as potentially deleterious: • Changes in water levels/channel morphology - this can arise from a variety of drainage maintenance activities, including removal of in-stream silt and vegetation and bush cutting/ branch trimming. It can occur from maintenance activities that deepen and widen the channel back to the original design level. This can impact on groundwater dependent habitats indirectly through increased capacity and flow in the channel leading to hydrological impacts.

6.2.3 Land and Air The Narrow-mouthed Whorl Snail for which this site is designated are at risk from drainage maintenance activities and although none were identified during the 2017 survey, they are assumed to be present within the dune slack and tall herb swamp Annex 1 habitats. In terms of the corresponding favourable Fossit habitats for this species found during the walkover survey (though not specifically Annex 1), the Fossit code CD5 applies. Areas where this habitat occurs is highlighted on the habitat map (appendix A) and mitigation approaches are proposed in sections 6.4 and 7.0 below. Additionally, all bird species within the SPA are at risk from drainage maintenance activities via land and air pathways as a result of the proposed maintenance activities.

Natura 2000 Site (Site Qualifying Interests/ Special Conservation Interests likely to be Code) affected by drainage maintenance activities via Land and Air Pathways Carrowmore Dunes SAC Narrow Mouthed Whorl Snail (Vertigo angustior) [1014] – assumed to be (002250) present in dune slack habitats [2190] and tall-herb swamp [6430] habitats Mid Clare Coast SPA Cormorant Phalacrocorax carbo [A017] (004182) Barnacle Goose Branta leucopsis [A045] Ringed Plover Charadrius hiaticula [A137] Sanderling Calidris alba [A144] Purple Sandpiper Calidris maritima [A148] Dunlin Calidris alpina alpina [A149] Turnstone Arenaria interpres [A169] Wetland and Waterbirds [A999]

The following sources of impact in particular have been identified as potentially deleterious: • Physical disturbance of habitats - this can arise from a variety of drainage maintenance activities, including removal of in-stream silt and vegetation and bush cutting/ branch trimming. It can impact on habitats directly, although temporarily, as a result of machines tracking along the bankside and as a result of the deposition of spoil on the bankside. This can result in a loss of habitat from in-stream/bankside areas and maintenance access corridors, direct mortalities or the displacement of sensitive species. Machines tracking along the bankside, reducing vegetation as a food source and a refuge. Where the sensitive whorl snail can exist within thin margins of suitable habitat (less than 5m across) these actions can impact upon the population status and site integrity as a whole. • Noise and visual disturbance - this can arise from a variety of drainage maintenance activities, including removal of in-stream silt and vegetation and bush cutting/ branch trimming. It can occur as a result of noise emissions and visual disturbance from machinery and the presence of machine drivers and other OPW staff. It can result in the flight and displacement of sensitive species from suitable habitat locations. It is not considered relevant in relation to designated habitat types, although it is relevant for the species which these habitats support. • Spread of non-native invasive species - Maintenance activities in areas infested with non-native invasive species can result in their spread if inappropriate working methods are followed and no biosecurity or management measures are put in place. This could then adversely impact upon Natura 2000 sites by reducing the diversity and extent of native species. For certain aquatic species, their spread can result in changes to water chemistry parameters, light penetration and nutrient levels which could then impact upon the species for which SACs and SPAs are designated.

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6.3 Impact Assessment

6.3.1 Do nothing impact Should the Creegh Arterial Drainage Scheme works not be carried out at this site, it is likely that natural succession would occur throughout the location. This is likely to include increased sedimentation in the channels over time, and increased vegetation growth along channel edges. Reduction in channel width, and retention of water in flood plain areas, may slow the flow of water and cause flooding in susceptible areas during periods of high rainfall.

6.3.2 Cumulative and in-combination impacts Projects and Plans that have the potential to contribute in-combination impacts and cumulative impacts upon Natura 2000 designated sites are considered in this section, as described in the Guidelines for the Assessment of Indirect and Cumulative Impacts, as well as Impact Interactions (Walker and Johnston 1999). Key points to consider when assessing cumulative and in-combination impacts include the nature and scale of the potential impacts including their potential magnitude and significance, the availability and quality of data and the impacts that may have occurred with similar projects in the area, where available or observed. Potential sources of in-combination effects identified as part of this assessment include:

6.3.2.1 Development planning applications Various planning permissions have been granted to projects in the nearby area, most of which involve small scale renovation or single dwelling builds. The following applications which may have a significant impact on the SAC, SPA and other ecological receptors are currently in the planning process and as yet unresolved.

Application Date: 19/11/2018 Application Number: 18930 Applicant: TIGL Ireland Enterprises Ltd for Trump International Golf Links and Hotel Doonbeg, Co. Clare Development Description: development including the construction of Ballroom/Function Room building; Leisure Facility building including restaurant; 53 no dwellings to be used for short term tourist accommodation; minor alterations to Doughmore house; a gatehouse; additional car parking and cycle parking. The development will also provide for the dismantling and removal of the existing Marquee structure, all associated ground works, ancillary works and enabling works and connection to existing services and facilities. The proposal will be developed on undeveloped lands previously part of planning permission P03/937 and associated permissions which have been part implemented, which provided for the construction of the existing Trump International Golf Links and Hotel and associated facilities. The development will be on a site of approx. 9.76 Ha (Circa 10Ha).

Application Date: 23/02/2016 Application Number: 16124 Applicant: TIGL Ireland Enterprises Ltd for Trump International Golf Links and Hotel Doonbeg, Co. Clare Development Decsription: coastal erosion management works at and adjacent Carrowmore Dunes, White Strand, Doughmore Bay and Trump International Golf Links and Hotel, Doonbeg. Planning permission for any works related to the above applications have not been granted and are not likely to commence in the immediate future. There are thus no likely significant cumulative and in-combination effects anticipated in the context of these planned maintenance works

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6.3.2.2 Agricultural activities: Farmers and landowners may also undertake general agricultural operations in areas adjacent to the Creegh River, which could potentially give rise to impacts of a similar nature to those arising from the planned OPW works. This could potentially result in additional periods of disturbance and a risk to water quality. Many agricultural operations are periodic, not continuous in nature, and qualify as a Notifiable Action that requires consultation with NPWS in advance of the works e.g. reclamation, infilling or land drainage within 30m of the river, removal of trees or any aquatic vegetation within 30m of the river, and harvesting or burning of reed or willow (NPWS 2018). Agricultural operations must also comply with the EC (Environmental Impact Assessment) (Agriculture) Regulations 2011 and amendment 2017 S.I. No. 456/2011 and 407/2017 in relation to activities covered by the regulations; • restructuring of rural land holdings, • commencing use of uncultivated land or semi-natural areas for intensive, • land drainage works on lands used for agriculture. A NIS is required under Regulation 9 if it is likely to have a significant effect on a Natura 2000 site. The drainage or reclamation of wetlands is controlled under the Planning and Development (Amendment) (No. 2) Regulations 2011 and the European Communities (Amendment to Planning and Development) Regulations 2011.

Lastly, no additional maintenance works are currently planned in the vicinity of the Creegh maintenance scheme.

Therefore, the in-combination effects of the proposed works and agricultural operations is not likely to be significant.

6.4 Impact Evaluation

The Impact evaluation of the proposed works on the Qualifying Interests/ Special Conservation Interests of the SAC/ SPA in question was carried with respect to the specific attributes and targets listed within the site-specific Conservation objectives for each of the sites (Mid Clare Coast SPA, NPWS 2014 and Carrowmore Dunes SAC, 2014). The overall Conservation Objective for bother the SPA and the SAC is to Maintain the favourable Conservation Status of all species concerned.

6.4.1 Carrowmore Dunes SAC - Impact Evaluation and proposed Mitigation The chief risks to the SAC as highlighted above are to the integrity of the Narrow-Mouthed Whorl Snail habitat which has been outlined as three separate 1km grid squares in the Specific Conservation Objectives for the site (NPWS 2014). One of the grid squares (Q9967) as shown in Map 6 of the Conservation Objectives overlaps with an area due for channel maintenance works. This is area which was found more recently to contain suitable habitat (CD5 Dune Slack) during a 2018 specialist survey, although no Narrow-Mouthed Whorl Snails were found in the area at the time of survey. The impact assessment and mitigation approaches for the SAC are thus centred around this species and its relevant attributes and targets. In brief, these include specific methodologies applied to the areas of channel adjacent to Dune slack habitat (Channels C2/1 and C2/2, C2/3 and C2/4). Specific Methodologies include the appropriate use of mini diggers and bog mats to minimise disturbance to sensitive habitat and vegetation. No work in in sensitive CD5 area during wet conditions (only when ground conditions are solid). An on-site ecological presence (ECoW) is proposed during the works to ensure any optimal habitat is avoided by works traffic and to guide the methodology of operatives when undertaking the work.

6.4.2 Mid-Clare Coast SPA - Impact Evaluation and proposed Mitigation The impact assessment for the Mid Clare Coast SPA bird species involve ensuring that none of the potential impacts highlighted above - release of sediment or nutrients, hydrological changes or disturbance (either physical or noise) manifest as 'significant' due to the proposed works.

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The mitigation approaches encompass avoidance of all works within the Spa boundary and demarcation of a buffer zone of 300m for the SPA species during the winter months to minimise disturbance during the key overwintering period for the designated species. Table 6-1 below more fully evaluates the screened in Natura 2000 sites and potential impacts as discussed in Section in more specific detail and examines where potentially adverse impacts may arise from the sources identified above. Where potentially significant adverse impacts are identified, avoidance and mitigation measures are proposed to offset these impacts.

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Table 6-1 Impact evaluation table

Site Name Qualifying Interests/ Potential Source Pathway Impact on Attribute and Target Prior to Avoidance / Mitigation Residual (site code) Special Conservation of Impact Mitigation / Avoidance Measures Impact Interests and Relevant attributes and Targets Carrowmore Narrowmouthed Whorl Changes in water Surface Water The dune slack habitats which favour Vertigo Follow protocols and SOPs in OPW Not Dunes SAC Snail (Vertigo Angustior) levels/ channel & Groundwater angustior are dependent on specific physical (2011b) - specifically points 2.1 and significant (002250) morphology flow regime attributes, including the flooding 2.2, of the Environmental Drainage As stated in section 5.2 regime. Maintenance Guidance SOP. above, the conservation This snail is known as a groundwater Ensure no actions are taken which objective for this species dependent species (IUCN 2012). may alter the hydrology of the site is to maintain the Drainage maintenance activities, such as silt beyond the original scheme design. favourable conservation and vegetation management can result in the This will include any activities which status of Narrow-mouthed deepening and widening of channels which result in channel widening or whorl snail within this could impact on surface water flows. This could deepening beyond the original SAC. Relevant attributes have adverse impacts on these habitats and a scheme design. and targets would be the number of attributes, including habitat area, An on-site ecological presence maintenance of transect habitat distribution and vegetation composition. (ECoW) is proposed during works to habitat quality and of However, significant changes to the ensure that any optimal habitat is optimal wetness of the hydrological regime are unlikely as the works avoided by works traffic and to guide transects used for will restore the system to the design standard the methodology of operatives when condition assessments. only. undertaking work on the most sensitive channels channels (C2/1 Transect habitat quality: and C2/2, C2/3 and C2/4). At least 75m of habitat of Implementing this strategy will help ensure that future condition the transect is classed as assessment of transects achieve the optimal or suboptimal relevant conservation targets. In this Transect optimal case, this specifically relates to: wetness: Soils within the survey transect are damp Transect habitat quality: At least 75m of habitat of the transect is and covered with layer of humid thatch for a length classed as optimal or suboptimal of at least 40m along the Transect optimal wetness: Soils transect. within the survey transect are damp and covered with layer of humid thatch for a length of at least 40m along the transect.

Narrowmouthed Whorl Release or changes Drainage maintenance activities such as silt Follow protocols and SOPs in OPW Not Snail (Vertigo Angustior) in nutrient levels/ management could impact on water quality in (2011b) - specifically point 2.1 and significant pollutants this habitat type through the release of 2.2 of Environmental Drainage

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Site Name Qualifying Interests/ Potential Source Pathway Impact on Attribute and Target Prior to Avoidance / Mitigation Residual (site code) Special Conservation of Impact Mitigation / Avoidance Measures Impact Interests and Relevant attributes and Targets Relevant attributes and nutrients and/ or pollution incidents which could Maintenance Guidance SOP. targets for this potential potentially result in reduced water quality, See Table 7-1 for details of impact would be the increased turbidity and eutrophication, which additional pollution prevention and maintenance of could then result in algal blooms, through sediment control measures required. population distribution aquifer recharge. This could then impact on a

and abundance and of range of vegetation structure attributes and the total habitat extent for potentially result in the increase in growth of Works on all channels will be the species. negative indicator species, or species which do undertaken in accordance with the not favour the whorl snail Vertigo angustior. Scheme's design standard, in order to prevent any new widening or deepening. Narrowmouthed Whorl Physical Land and air Where fixed dunes have the correct habitat Follow protocols and SOPs in OPW Not Snail (Vertigo Angustior) disturbance of conditions, Vertigo angustior may cover a large (2011b) - specifically point 1.1, 1.2, significant habitats area of occupancy. Otherwise, it can be found 1.3, 2.3, 4.1, 4.2, 4.3, 4.4, 5.1 of in an often narrow transition zone between Environmental Drainage Relevant attributes and saltmarsh and dune, and in transition zones Maintenance Guidance SOP to targets for this potential impact would be the between grassland and wetland with short minimise the impacts of physical herbs, mosses and Iris. disturbance. maintenance of population distribution Areas of dune slack habitat and transitions Works within the SAC boundary and abundance and of from wet grassland to dune habitat in this should be avoided as should any the total habitat extent for scheme, represent optimal habitat for this access and disturbance dune the species. species and the risks to disturbance to this habitat. habitat are high. This could be through disturbance via access tracks or from direct Works will need to be limited near removal of vegetation within the maintenance areas of CD5 habitat which occurs access corridor. Unmitigated actions could adjacent to the channels C2/1 and impact on a range of attributes including total C2/2, C2/3 and C2/4. This is to habitat area and vegetation composition, ensure that no degradation of structure and function, which would impact on transitional (grassland to dune slack) the population of the snail in this area. narrow-mouthed whorl snail habitat occurs. Mini diggers are to be used Given that maintenance activities are where appropriate to ensure the conducted along the watercourses, there will smallest footprint of works on the be a working corridor along the channels and habitat. Larger machinery should consequently the potential for adverse impacts only access these works areas on the Vertigo angustior habitat is high. during dry ground conditions to avoid damage to the sensitive dune slack/ whorl snail habitat. The use of bog mats where appropriate is

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Site Name Qualifying Interests/ Potential Source Pathway Impact on Attribute and Target Prior to Avoidance / Mitigation Residual (site code) Special Conservation of Impact Mitigation / Avoidance Measures Impact Interests and Relevant attributes and Targets recommended. No spoil should be spread on areas of CD5 habitat. Spoil from the channels should be disposed of on nearby agricultural land or the berm/embankments themselves. The presence of an on-site Ecological Clerk of Works during this stage of channel management is proposed. This will help ensure that the appropriate level of care is taken in sensitive areas, and that avoidance measures are defined by this suitably qualified Ecologist. Narrowmouthed Whorl Spread of non- Land, Air and Due to the presence of Montbretia along the Stringent biosecurity measures must Not Snail (Vertigo Angustior) native alien Water Creegh River, drainage maintenance works be implemented throughout the significant invasive species have the potential to cause further spread of works following OPW’s Invasive this invasive non-native species within the river Species SOP (2011) and the Check, Relevant attributes and system and off site via personnel, equipment Clean, Dry principles of the Non- targets for this potential impact would be the and machinery. Dispersal can occur via Native Species Secretariat (NNSS, machinery vectors (i.e. tyres, tracks and 2017) to ensure invasive non-native maintenance of the total habitat extent for the buckets) as well as by water. species are not introduced into areas species. This has the potential to spread to Annex I of the SAC. habitat downstream, where it could alter

community structure and function. The Ecological Clerk of Works can

act to inform staff of safe system of work where biosecurity is concerned and provide toolbox talks prior to works commencement.

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Site Name Qualifying Interests/ Potential Source Pathway Impact on Attribute and Target Prior to Avoidance / Mitigation Residual (site code) Special Conservation of Impact Mitigation / Avoidance Measures Impact Interests and Relevant attributes and Targets Mid Clare Cormorant Phalacrocorax Release of Surface Water The wetlands and waterbird populations and Follow protocols and SOPs in OPW Not Coast SPA carbo [A017] suspended solids most of the designated species of this SPA are (2011b) - specifically points 2.1, 2.2, significant (004182) Barnacle Goose Branta dependent on a number of habitats with 3.1 and 3.2 of Environmental leucopsis [A045] Release or changes connectivity to surface waters within the site, Drainage Maintenance Guidance Ringed Plover Charadrius in nutrient levels/ including estuaries, mudflats, sandflats and SOP. saltmarsh. Drainage maintenance activities hiaticula [A137] pollutants could impact on these habitats through the Sanderling Calidris alba See Table 7.1 for additional release of nutrients, suspended solids and mitigation measures. [A144] pollution incidents which could potentially result Purple Sandpiper Calidris in reduced water quality, eutrophication and maritima [A148] increased turbidity, which could impact upon Works undertaken on the channel C1 Dunlin Calidris alpina the wetland habitats and potentially the food in the area closest to the sea alpina [A149] supply (i.e. macroinvertebrates and fish) of the (Confluence of C1 with C2) should Turnstone Arenaria waterbirds, possibly affecting the distribution of be carried out at low tide, when there is minimal risk of sediment delivery interpres [A169] species within the Mid Clare coast SPA and long-term population trends. to the SPA Wetland and Waterbirds [A999] Any works undertaken in the most downstream reach must avoid encroaching onto Dune habitat (see The Conservation habitat map). Objective for the Mid- Clare Coast SPA is to Changes in water The birds for which this SPA is designated Follow protocols and SOPs in OPW Not maintain the favourable levels/ channel have specific conservation objectives which (2011b) - specifically point 2.1 and significant conservation status of the morphology are to maintain favourable conservation status 2.2 of Environmental Drainage above species. of the species concerned. These species are Maintenance Guidance SOP also dependent on a number of habitats with connectivity to surface waters within the site, See Table 7.1 for additional including estuaries, mudflats, sandflats and mitigation measures. saltmarsh.

Drainage maintenance activities, such as silt and vegetation management can result in the deepening and widening of channels which could impact on surface water flows and water table levels. This could then have adverse impacts on those habitats and distribution of the waterbirds they support. However, significant changes to the hydrological regime are unlikely as the works will restore the system to the design standard

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Site Name Qualifying Interests/ Potential Source Pathway Impact on Attribute and Target Prior to Avoidance / Mitigation Residual (site code) Special Conservation of Impact Mitigation / Avoidance Measures Impact Interests and Relevant attributes and Targets only and there are no works planned to widen or deepen the channel within the SAC boundary. The drainage maintenance activities are therefore unlikely to impact significantly on attributes used to define conservation status. Cormorant Phalacrocorax Physical Land and air The bird species for which the SPA is Follow protocols and SOPs in OPW Not carbo [A017] disturbance of designated were identified by Ryan Hanley (2011b) - specifically points 1.1 and significant Barnacle Goose Branta habitat (2014a) as being vulnerable to drainage 1.2 of Environmental Drainage leucopsis [A045] maintenance activities via land and air Maintenance Guidance SOP. Ringed Plover Charadrius pathways. The habitats that support these species are likely to be vulnerable to physical hiaticula [A137] Works within the SPA boundary disturbance arising from drainage maintenance should be avoided at all times Sanderling Calidris alba activities, such as silt and vegetation [A144] management. Purple Sandpiper Calidris This could be through disturbance via access See Table 7.1 for additional maritima [A148] tracks or from direct removal of vegetation mitigation measures Dunlin Calidris alpina within the maintenance access corridor. This alpina [A149] could impact on a range of attributes including Turnstone Arenaria habitat area and vegetation composition, interpres [A169] structure and function, as well as the Wetland and Waterbirds modification of roosting/ feedings sites. [A999] Noise and visual The bird species for which the SPA is Follow protocols and SOPs in OPW Not disturbance designated were identified by JBA (2014) as (2011b) - specifically points 1.1 and significant being vulnerable to drainage maintenance 1.2 of Environmental Drainage activities via land and air pathways. Maintenance Guidance SOP. These species will be sensitive to disturbance No maintenance work will be from machinery and workforces conducting conducted downstream of the drainage maintenance operations during the junction of C1 with the N67 road at over-wintering period (November - March). Mountrivers bridge between This disturbance could cause displacement of November and March. This allows populations which can require significant for a buffer of 300m for the SPA energy expenditure for the birds, which, if species in the winter months and undertaken during the cold winter months minimise disturbance during the key when birds are already stressed by recent overwintering period. migrations and difficulties in finding food, could have an adverse impact on population trend See Table 7.1 for additional and distribution. mitigation measures.

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7 Avoidance and Mitigation Measures Table 7-1 Specific mitigation measures for Creegh Arterial Drainage Scheme Potential Specific Avoidance and Mitigation Measures Impact Release of Refuelling will not be undertaken within 20m of a watercourse. suspended Biodegradable oils and fuels will be used where possible. solids Drip trays will be placed underneath any standing machinery to prevent pollution by oil/fuel leaks. Release or Operators will check their vehicles on a daily basis before starting work to confirm the absence of changes in leakages. Any leakages will be reported immediately. nutrient levels/ pollutants Emergency spill kits will be available on site and staff trained in their use. During all works the weather forecast will be monitored and a contingency plan developed to prevent damage or pollution during extreme weather and high flow events. The release of suspended solids will be minimised during works and appropriate sediment control measures will be employed as follows; - Vehicles shall not expose significant area of soil as track marks in the vicinity of watercourses that may result in soil entering the watercourse via surface water runoff. If channels need to be accessed by vehicles over soft/wet ground and there is a risk that significant areas of soil may be exposed, bog mats or sleepers shall be laid. - Works shall retain vegetation along the riparian zone of the riverbank, providing a natural buffer strip as described in OPW SOP, to protect from bank erosion and reduce the release of suspended solids to the waterbody. - When removing aquatic vegetation instream, maximise the use of weed-cutting bucket where possible to minimise the amount of silt being disturbed/suspended into the water column from the river substrate or bank - All aquatic vegetation or brash cuttings shall be removed from the channel and its bank and placed in an area where they cannot re-enter the water. Changes in water Works on all channels shall be undertaken in accordance with the Scheme's design standard, in order levels/ channel to prevent any new widening or deepening of a channel. morphology Works will need to be limited near areas of CD5 habitat which occurs adjacent to the channels C2/1 and C2/2, C2/3 and C2/4 (see habitat map for habitat area detail). This is to ensure that no degradation of transitional (grassland to dune slack) narrow-mouthed whorl snail habitat occurs. It is proposed that Mini diggers are to be used where appropriate to ensure the smallest footprint of works on the habitat. Larger machinery should only access these works areas during dry ground conditions to avoid damage to the sensitive dune slack/ whorl snail habitat. The use of bog mats where appropriate is recommended. Avoid activities that can lower water levels, beyond the original scheme design. This will include any activities which result in channel widening or deepening. An on-site ecological presence (ECoW) is proposed during works to ensure that any optimal habitat is avoided by works traffic and to guide the methodology of operatives when undertaking work on the most sensitive channels channels (C2/1 and C2/2, C2/3 and C2/4). Implementing this strategy will help ensure that future condition assessment of transects achieve the relevant conservation targets.

Physical Works within the SAC boundary should be avoided entirely including access to dune habitat on the disturbance of western side of the C1 estuary. habitats Works will need to be limited near areas of CD5 habitat which occurs adjacent to the channels C2/1 and C2/2, C2/3 and C2/4 (see habitat map for habitat area detail). This is to ensure that no Noise and visual degradation of transitional (grassland to dune slack) narrow-mouthed whorl snail habitat occurs. It is disturbance proposed that Mini diggers are to be used where appropriate to ensure the smallest footprint of works on the habitat. Larger machinery should only access these works areas during dry ground conditions to avoid damage to the sensitive dune slack/ whorl snail habitat. The use of bog mats where Spread of non- appropriate is recommended. Avoid activities that can lower water levels, beyond the original scheme native invasive design. This will include any activities which result in channel widening or deepening. species An on-site ecological presence (ECoW) is proposed during works to ensure that any optimal habitat is avoided by works traffic and to guide the methodology of operatives when undertaking work on the most sensitive channels channels (C2/1 and C2/2, C2/3 and C2/4). Implementing this strategy will help ensure that future condition assessment of transects achieve the relevant conservation targets.

No maintenance work will be conducted within 300m of the Mid Clare Coast SPA boundary between November and March. Stringent biosecurity measures will be implemented throughout the works following the OPW's Invasive Species Procedures (Appendix A.4)

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8 Conclusions This NIS details the findings of the Stage 2 Appropriate Assessment conducted to further examine the potential direct and indirect impacts of proposed drainage maintenance works in the Creegh Arterial Drainage Scheme on the following Natura 2000 sites: • Carrowmore Dunes SAC (002250) • Mid Clare Coast SPA (004182)

The above sites were identified by a screening exercise (JBA, 2014) that determined likely significant effects in relation to the above sites. This screening exercise was conducted following the methodology outlined in Ryan Hanley (2014a), which examines three source > pathway > receptor chains; surface water, land and air, and groundwater pathways. The Appropriate Assessment investigated the potential direct and indirect impacts of the proposed works on the integrity and interest features of the above Natura 2000 sites, alone and in-combination with other plans and projects, taking into account the sites' structure, function and conservation objectives. Where potentially significant adverse impacts were identified, a range of mitigation and avoidance measures have been suggested to help offset them. As a result of this Appropriate Assessment it has been concluded, on adherence with the avoidance and mitigation measures suggested, the proposed drainage maintenance operations in the Creegh Arterial Drainage Scheme will not have a significant adverse impact on the above Natura 2000 sites. To confirm this conclusion, a checklist taken from DoEHLG 2009, has been completed in Table 8-1. Table 8-1 Integrity of Natura 2000 site checklist (DoEHLG 2009)

Conservation objectives: does the project Y/N or plan have the potential to: Cause delays in progress towards N - Following mitigation, no significant adverse achieving the conservation objectives of residual impacts have been identified that will prevent the sites? achievement of the conservation objectives of the assessed sites. Interrupt progress towards achieving the N - Following mitigation, no significant adverse conservation objectives of the sites? residual impacts have been identified that will prevent achievement of the conservation objectives of the assessed site. Disrupt those factors that help to maintain N - Potential adverse impacts via surface water; land the favourable conditions of the site? and air; and groundwater pathways identified during the screening and AA process can be mitigated against. Interfere with the balance, distribution and N - Potential adverse impacts on the habitats and density of key species that are the species of the one SAC and two SPAs are not indicators of the favourable condition of expected as impacts can be avoided by implementing the site? the mitigation and avoidance measures detailed. Other objectives: does the project or plan have the potential to: Cause changes to the vital defining N - Potential adverse impacts from suspended solid aspects (e.g. nutrient balance) that and nutrient release are not expected as measures determine how the site functions as a can be included within working protocols to ensure habitat or ecosystem? potential impacts are effectively mitigated. Change the dynamics of the relationships N - Potential adverse impacts relating to hydrological (between, for example, soil and water or status and water quality have been identified which plants and animals) that define the could impact on the functioning and dynamics of the structure and/or function of the site? site, however, these are not expected to be significant given the mitigation measures detailed to ensure potential impacts are effectively mitigated. Interfere with predicted or expected N - Potential adverse impacts from changes to the natural changes to the site (such as water hydrological regime and suspended dynamics or chemical composition)? solid/nutrient/pollutant release are not expected as measures can be included within working protocols to

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Conservation objectives: does the project Y/N or plan have the potential to: ensure potential impacts are effectively mitigated. Reduce the area of key habitats? N - Potential adverse impacts on the habitats of the SAC and SPA are not expected given the mitigation measures that have been detailed. Reduce the population of key species? N - Potential impacts to the Narrow-mouthed whorl snail for which the SAC is designated can be avoided provided the works adhere to the mitigation proposed and no-go zones and specific high impact maintenance techniques are avoided in the sensitive areas defined above. N - Potential impacts to the bird species for which the Mid Clare Coast SPA designated, are not expected as impacts can be avoided by implementing the mitigation measures detailed. Change the balance between key N - Potential impacts to the species for which species? Carrowmore Dunes SAC and Mid Clare Coast SPA are designated, are not expected as impacts can be avoided by implementing the mitigation measures detailed. Reduce diversity of the site? N - The identified mitigation measures to protect designated habitats and species will ensure that the current diversity of the sites is maintained. Result in disturbance that could affect N - Potential impacts to the species for which population size or density or the balance Carrowmore Dunes SAC and Mid Clare Coast SPA between key species? are designated are not expected as impacts can be avoided by implementing the mitigation measures detailed. Result in fragmentation N - The proposed works will be undertaken along existing maintenance access corridors and therefore no fragmentation of habitats will occur. Result in loss or reduction of key features N - Potential adverse impacts on SAC and SPA (e.g. tree cover, tidal exposure, annual habitats are not expected as impacts can be avoided flooding etc.)? by implementing the mitigation measures detailed so there will be no loss of, or reduction of, key features.

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References DEHLG (2009) Appropriate Assessment of Plans and Projects in Ireland. Guidance for Planning Authorities, available: https://www.npws.ie/sites/default/files/publications/pdf/NPWS_2009_AA_Guidance.pdf [accessed 31 Aug 2016]. DoEHLG (2009) Appropriate Assessment of Plans and Projects in Ireland Guidance for Planning Authorities., Department of the Environment, Heritage and Local Government, available: http://www.wicklow.ie/sites/default/files/Manager’s%20report%20on%20submissions%20to%20th e%20Proposed%20Amendments.pdf [accessed 12 Mar 2017]. EC (2002) Assessment of Plans and Projects Significantly Affecting Natura 2000 Sites: Methodological Guidance on the Provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC, EUR-OP: Luxembourg. EC (2007) Guidance Document on Article 6(4) of the ‘Habitats Directive’ 92/43/EEC. Clarification of the Concepts of: Alternative Solutions, Imperative Reasons of Overriding Public Interest, Compensatory Measures, Overall Coherence, Opinion of the Commission, available: http://ec.europa.eu/environment/nature/natura2000/management/docs/art6/guidance_art6_4_en.p df [accessed 31 Aug 2016]. EC (2013) Interpretation Manual of European Union Habitats, Version EUR 28, available: http://eunis.eea.europa.eu/references/2435. EPA (2017) EPA Envision Map Viewer [online], available: http://gis.epa.ie/Envision [accessed 9 Mar 2017]. European Commission, Office for Official Publications of the European Communities (Eds.) (2000) Managing Natura 2000 Sites: The Provisions of Article 6 of the ‘Habitats’ Directive 92/43/EEC, Office for Official Publications of the European Communities: Luxembourg. Fossitt, J.A. (2000) A Guide to Habitats in Ireland, Heritage Council of Ireland series, Heritage Council/Chomhairle Oidhreachta: Kilkenny. IFI (2010) ‘IFI Biosecurity Protocol for Field Survey Work’. JBA (2014) Appropriate Assessment Screening for Creegh Arterial Drainage Maintenance Scheme, AA Screening, Office of Public Works. Moorkens, E. & Killeen, I. (2011). Vertigo angustior. The IUCN Red List of Threatened Species. Version 2014.2. . < www.iucnredlist.org> Downloaded on 18 September 2014. Moorkens, E.A.& Killeen,I.J (2011a) Monitoring and Condition Assessment of Populations of Vertigo geyeri,Vertigo angustiorandVertigo moulinsiana in Ireland.Irish Wildlife Manuals,No.55.National Parks and Wildlife Service,Department of Arts,Heritage and Gaeltacht, Dublin, Ireland. Moorkens, E. & Browne, K. (2003) Annual conservation report for the development and maintenance of the golf links at Doonbeg,. Co. Clare Moorkens, E. & Gaynor, K. (2000 - 2002) Annual conservation reports for the development and maintenance of the golf links at Doonbeg,. Co. Clare NBDC (2017) Biodiversity Maps - Map Viewer [online], National Biodiversity Data Centre Biodiversity Maps, available: http://maps.biodiversityireland.ie/#/Map [accessed 10 Apr 2018]. NNSS (2017) Check, Clean, Dry - GB Non-Native Species Secretariat [online], GB Non-native species secretariat, available: http://www.nonnativespecies.org/checkcleandry/ [accessed 16 Nov 2017]. NPWS (2008) The Status of EU Protected Habitats and Species in Ireland, • National Parks and Wildlife Service (NPWS) (2008). The Status of EU Protected Habitats and Species in Ireland. National Parks and Wildlife Service, Department of the Environment, Heritage and Local Government, Dublin, Ireland., available: https://www.npws.ie/sites/default/files/publications/pdf/NPWS_2007_Conservation_Status_Report .pdf [accessed 17 Apr 2018]. NPWS (2013a) The Status of EU Protected Habitats and Species in Ireland 2013 Habitat Assessments Volume 2, National Parks & Wildlife Services. Department of Arts, Heritage and the

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Gaeltacht, Dublin, Ireland., available: https://www.npws.ie/sites/default/files/publications/pdf/Article_17_Print_Vol_2_report_habitats_v1 _1_0.pdf [accessed 31 Mar 2018]. NPWS (2013b) The Status of EU Protected Habitats and Species in Ireland Species Assessments Volume 3, National Parks & Wildlife Services. Department of Arts, Heritage and the Gaeltacht, Dublin, Ireland., available: https://www.npws.ie/sites/default/files/publications/pdf/Article_17_Print_Vol_3_report_species_v1 _1_0.pdf [accessed 31 Mar 2018]. NPWS (2014) Conservation Objectives: Mid Clare Coast SPA 004182 ]. NPWS (2014b) Conservation Objectives: Carrowmore Dunes SAC 002070 NPWS (2014c) Carrowmore Dunes SAC (002250) Conservation objectives supporting document - Coastal habitats [Version 1]. NRA (2009) Ecological Surveying Techniques for Protected Flora and Fauna during the Planning of National Road Schemes, National Roads Authority, available: http://www.tii.ie/technical- services/environment/planning/Ecological-Surveying-Techniques-for-Protected-Flora-and-Fauna- during-the-Planning-of-National-Road-Schemes.pdf [accessed 29 Nov 2017]. OPW (2011a) Arterial Drainage Maintenance & High Risk Channel Designation Programme 2011- 2015 Habitats Directive Assessment, Office of Public Works, available: https://www.opw.ie/media/Arterial%20Drainage%20Maintenance%20&%20High%20Risk%20Cha nnel%20Designation%20HDA%202011-2015.pdf [accessed 17 Nov 2017]. OPW (2011b) ‘The Office of Public WorksArterial Drainage Maintenance Service Environmental Management Protocols & Standard Operating Procedures’. Ryan Hanley (2012) Creegh Arterial Drainage Scheme 2012-2016 - Natura Impact Statement Ryan Hanley (2014a) Office of Public Works Arterial Drainage Maintenance Environmental Services 2013. Stage 1: Appropriate Assessment Screening Methodology for the Maintenance of Arterial Drainage Schemes. Methodology. Unpublished Report. Ryan Hanley (2014b) Office of Public Works Arterial Drainage Maintenance Environmental Services 2013. Stage 1: Appropriate Assessment Screening Methodology for the Maintenance of Arterial Drainage Schemes. Moy Validation Report. Unpublished Report. Ryan Hanley (2014c) Office of Public Works Arterial Drainage Maintenance Service 2014-2018. Source > Pathway > Receptor Chains for Appropriate Assessment. Unpublished Report. Ryle,T. Murray,A. Connolly,K. Swann, M. (2009).Coastal Monitoring Project 2004-2006. Smith, G.F., O’Donoghue, P., O’Hora, K., Delaney, E. (2011) ‘Best practice guidance for habitat survey and mapping’, The Heritage Council: Ireland. Walker, L.J., Johnston, J. (1999) Guidelines for the Assessment of Indirect and Cumulative Impacts as Well as Impact Interactions, Office for Official Publications of the European Communities, Brussels, available: http://edz.bib.uni-mannheim.de/www-edz/pdf/1999/guideassess.pdf [accessed 18 Apr 2017]. Waterways Ireland (2017) Marine Notices: CRAYFISH PLAGUE Notice Number 94 of 2017 [online], Waterways Ireland | News Centre | Marine Notices, available: https://www.waterwaysireland.org/news-centre/marine-notices/689/crayfish-plague [accessed 16 Nov 2017]. WFD /EPA (2016) WFD Ground Waterbody Approved Risk [online], EPA Ireland Catalogue, available: https://gis.epa.ie/geonetwork/srv/eng/catalog.search#/metadata/94b1067c-22d0-469a- 913b-2f08b94ab461 [accessed 16 Nov 2017].

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A Appendices

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A.1 Channel layout relative to Natura 2000 sites

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A.2 Habitat map

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A.3 Waterways Ireland Marine Notice Number 94 of 2017

Posted: 26/09/2017 CRAYFISH PLAGUE Notice Number 94 of 2017 Preventative Measures for Crayfish Plague

ALERT: CRAYFISH PLAGUE CONFIRMED ON THE RIVER BARROW AND LORRHA RIVER (Near Lough Derg): Water users urged to take immediate bio security precautions "Crayfish Plague" is a condition which only affects, but is fatal to our native populations of Freshwater White-Clawed Crayfish (All native crayfish that become infected will die) Crayfish Plague is easily transmitted in water or via contaminated equipment (eg canoes, waders or nets, wetsuits), machinery and potentially even by animals/pets coming into contact with water from infected areas (crayfish plague only affects crayfish and not other animals) Crayfish plague may also have entered into other rivers. Emergency disease containment measures are therefore needed to help ensure its containment and prevent its spread.

Commencing immediately ALL recreational, commercial, private and public body water users (boaters, walkers, swimmers, kayakers, rowers, machine operators etc) are being urged to take immediate biosecurity precautions to stop the spread of crayfish plague and are asked to operate a temporary ban on moving water sports/angling equipment and other equipment/machinery that comes in contact with the water, out of, or into the affected catchments/Rivers.

If movements are essential, all recreational equipment including clothing etc should be thoroughly dried out and the following biosecurity measures followed:

Water sports, angling and other equipment currently in use in these catchments may continue to be used there in a limit capacity; but boats, angling/water sports equipment and machinery should not be transferred in or out of the affected catchments. Users operating within the affected areas are also requested to limit their activity to the immediate river sections where they normally operate, avoid moving around the catchment and follow biosecurity protocols – "Check, Clean, Dry" - which should be adopted as standard practice in all freshwaters. All equipment that comes in contact with water should be checked for any silt or mud, plant material or animals. Before and after use all equipment should then be cleaned (Disinfectant or hot water {over 60 Degrees Celsius} should be used to clean all equipment) and finally fully dried. Drying is especially important, including removing of all water from inside a boat and disposing of it on grass.

Further information on Crayfish/Crayfish Plague

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The kill only infects species of crayfish but causes 100% mortality in our native White Clawed crayfish. Farm animals, pets and other freshwater animals and fish are not affected.

The crayfish plague organism can be carried on wet equipment (boats, kayaks, fishing equipment, wetsuits, machinery etc) to new sites. Containment of the outbreak is essential to prevent spread to other as yet unaffected populations in Ireland and further along the Barrow and Shannon Rivers and their tributaries.

People are also asked to alert the authorities (National Parks and wildlife, Local Council Env Section, Inland Fisheries Ireland or Waterways Ireland Environment Section) of any mass mortality of crayfish or sightings of unusual crayfish that might be non-native species (e.g. crayfish with red claws, large size).

The White-clawed Crayfish is a globally threatened species and Ireland holds one of the largest surviving populations in Europe. Found in lakes, rivers and streams over much of the island it is the only freshwater crayfish species in Ireland. Throughout its European range, this species has been decimated by the impact of Crayfish Plague which spread to Europe with the introduction of North American species of crayfish. Until 2015, Ireland was considered free of the disease and it remains the only European country without any established non-native crayfish species.

Further information: http://www.biodiversityireland.ie/crayfish-plague-2017

Source: Interagency personnel from National Parks and Wildlife Service, Inland Fisheries Ireland, Environmental Protection Agency, Tipperary, Carlow, Waterford County and City Councils, Sports Partnerships including Tipperary, Marine Institute, Local Authority Water and Communities Offices, Waterways Ireland and National Biodiversity Data Centre

Shane Anderson Assistant Inspector of Navigation 13 Sept 2017

Tel: 353 90 6494232 Fax: 353 90 6494147

From: https://www.waterwaysireland.org/ 22/11/2017

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A.4 OPW Environmental Management Protocols and Standard Operating Procedures

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Offices at Dublin Limerick

Registered Office 24 Grove Island Corbally Limerick Ireland

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