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EPA Export 27-01-2016:00:36:09 Irish Water Report
Natura Impact Statement as part of the Portrane WwTP Discharge License Review D0114-02
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Contents
Introduction 4 Legislative Context 4
Methodology 6 Guidance Followed 6 Stages Involved in the Appropriate Assessment Process 7 Stage 1: Screening / Test of Significance 8 Field Walkover Surveys 8 Consultation 8
Screening 9
Stage 2: Appropriate Assessment 11 Description of the Project 11 Process Description 12 Description of the Receiving Environment and Monitoring Results 14 Field Walkover Survey 15 Description of the Natura 2000 Sites Affected 17 Rockabill to Dalkey Island SAC 20 Description of the Qualifying Interests of the SAC 21 For inspection purposes only. Rogerstown Estuary SAC Consent of copyright owner required for any other use. 22
Description of the Qualifying Interests of the SAC 22 Rogerstown Estuary SPA 23 Description of the Conservation Interests of the SPA 24 Conservation Objectives 27 Rockabill to Dalkey Island SAC 27 Rogerstown Estuary SAC 28 Rogerstown Estuary SPA 30 Impact Prediction 31 Impacts on Annex I Habitats 32 Impacts on Annex II Species 33 Impacts on designated features of the SPA 34 Mitigation Measures 35 Stage 2 Appropriate Assessment Conclusion Statement 36
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EPA Export 27-01-2016:00:36:09 Introduction
This report provides an Appropriate Assessment (AA) of the existing Waste Water Treatment Plant (WwTP) at Portrane, Co Dublin, for the purposes of the Waste Water Discharge (Authorisation) Regulations, 2007 (S.I. No. 684 of 2007), as amended. This plant serves the Portrane, Donabate, Rush and Lusk agglomeration. It assesses whether the on-going operation of the plant, alone or in combination with other plans and projects, is likely to have significant effects on a Natura 2000 Site(s) in view of best scientific knowledge and the conservation objectives of the site(s). Natura 2000 Sites are those identified as sites of European Community importance designated as Special Areas of Conservation under the Habitats Directive or as Special Protection Areas under the Birds Directive.
This report follows the guidance for AA published by the Environmental Protection Agency’s (EPA) ‘Note on Appropriate Assessments for the purposes of the Waste Water Discharge (Authorisation) Regulations, 2007 (S.I. No. 684 of 2007)’ (EPA, 2009); and takes account of the Department of the Environment, Heritage and Local Government’s guidelines ‘Appropriate Assessment of Plans and Projects in Ireland. Guidance for Planning Authorities’ (DoEHLG, 2009) and Circular L8/08 ‘Water Services Investment and Rural Water Programmes – Protection of Natural Heritage and National Monuments’ (DoEHLG, 2008).
Legislative Context The Council Directive 92/43/EEC on the Conservation of Natural Habitats and of Wild Fauna and Flora, better known as “The Habitats Directive”, provides legal protection for habitats and species of European importance. Articles 3 to 9 provide the legislative means to protect habitats and species of Community interest through the establishment and conservation of an EU-wide network of sites known as Natura 2000. These are Special Areas of Conservation (SACs) designated under the Habitats Directive and Special Protection Areas (SPAs) designated under the Conservation of Wild Birds Directive For (79/409/ECC)inspection purposes only.as codified by Directive 2009/147/EC. Consent of copyright owner required for any other use.
Articles 6(3) and 6(4) of the Habitats Directive set out the decision-making tests for plans and projects likely to affect Natura 2000 sites (Annex 1.1). Article 6(3) establishes the requirement for Appropriate Assessment (AA):
Any plan or project not directly connected with or necessary to the management of the [Natura 2000] site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subjected to appropriate assessment of its implications for the site in view of the site’s conservation objectives. In light of the conclusions of the assessment of the implications for the site and subject to the provisions of paragraph 4, the competent national authorities shall agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the site concerned and, if appropriate, after having obtained the opinion of the general public.
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Article 6(4) states:
If, in spite of a negative assessment of the implications for the [Natura 2000] site and in the absence of alternative solutions, a plan or project must nevertheless be carried out for imperative reasons of overriding public interest, including those of a social or economic nature, Member States shall take all compensatory measures necessary to ensure that the overall coherence of Natura 2000 is protected. It shall inform the Commission of the compensatory measures adopted.
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Methodology
Guidance Followed Both EU and national guidance exists in relation to Member States fulfilling their requirements under the EU Habitats Directive, with particular reference to Article 6(3) and 6(4) of that Directive. The methodology followed in relation to this AA Screening has had regard to the following guidance:
Note on Appropriate Assessments for the purposes of the Waste Water Discharge (Authorisation) Regulations, 2007 (S.I. No. 684 of 2007). Environmental Protection Agency, (EPA, 2009).
Appropriate Assessment of Plans and Projects in Ireland: Guidance for Planning Authorities. Department of Environment, Heritage and Local Government, (DoEHLG, 2010).
Circular L8/08 – Water Services Investment and Rural Water Programmes – Protection of Natural Heritage and National Monuments. Department of Environment, Heritage and Local Government, (DoEHLG, 2008).
Communication from the Commission on the Precautionary Principle. Office for Official Publications of the European Communities, Luxembourg, (EC, 2000a).
Managing Natura 2000 Sites: the provisions of Article 6 of the ‘Habitats’ Directive 92/43/EEC, Office for Official Publications of the European Communities, Luxembourg, (EC, 2000b).
Assessment of plans and projects For inspection significantly purposes only. affecting Natura 2000 sites: Consent of copyright owner required for any other use. Methodological guidance on the provisions of Articles 6(3) and (4) of the Habitats Directive 92/43/EEC. Office for Official Publications of the European Communities, Brussels (EC, 2001).
Guidance document on Article 6(4) of the ‘Habitats Directive’ 92/43/EEC – Clarification of the concepts of: alternative solutions, imperative reasons of overriding public interest, compensatory measures, overall coherence, opinion of the Commission. Office for Official Publications of the European Communities, Luxembourg, (EC, 2007).
Nature and biodiversity cases: Ruling of the European Court of Justice. Office for Official Publications of the European Communities, Luxembourg (EC, 2006).
Marine Natura Impact Statements in Irish Special Areas of Conservation: A working document, National Parks and Wildlife Service, Dublin (NPWS, 2012).
European Communities (Birds and Natural Habitats) Regulations, 2011 (S.I. No.477 of 2011).
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Interpretation Manual of European Union Habitats. Version EUR 28. European Commission (EC, 2013).
Stages Involved in the Appropriate Assessment Process
Stage 1: Screening / Test of Significance This process identifies whether the WwTP discharge is directly connected to or necessary for the management of a Natura 2000 Site(s); and identifies whether the discharge is likely to have significant impacts upon a Natura 2000 Site(s) either alone or in combination with other projects or plans.
The output from this stage is a determination for each Natura 2000 Site(s) of not significant, significant, potentially significant, or uncertain effects. The latter three determinations will cause that site to be brought forward to Stage 2.
Stage 2: Appropriate Assessment This stage considers the impact of the WwTP discharge on the integrity of a Natura 2000 Site(s), either alone or in combination with other projects or plans, with respect to (1) the site’s conservation objectives; and (2) the site’s structure and function and its overall integrity. Additionally, where there are adverse impacts, an assessment of the potential mitigation of those impacts
The output from this stage is a Natura Impact Statement (NIS). This document must include sufficient information for the EPA to carry out the appropriate assessment. If the assessment is negative, i.e. adverse effects on the integrity of a site cannot be excluded, then the process must consider alternatives (Stage 3) or proceed to Stage 4.
Stage 3: Assessment of Alternatives For inspection purposes only. Consent of copyright owner required for any other use. This process examines alternative ways of achieving the objectives of the project or plan that avoid adverse impacts on the integrity of the Natura 2000 Site. This assessment may be carried out concurrently with Stage 2 in order to find the most appropriate solution. If no alternatives exist or all alternatives would result in negative impacts to the integrity of the Natura 2000 Sites then the process either moves to Stage 4 or the project is abandoned.
Stage 4: Assessment Where Adverse Impacts Remain An assessment of compensatory measures where, in the light of an assessment of Imperative Reasons of Overriding Public Interest (IROPI), it is deemed that the project or plan should proceed.
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Stage 1: Screening / Test of Significance In complying with the obligations under Article 6(3) and following the appropriate guidelines, this AA Screening has been structured as a stage by stage approach as follows:
Description of the project;
Identification of Natura 2000 sites potentially affected;
Identification and description of individual and cumulative impacts likely to result;
Assessment of the significance of the impacts identified above on site integrity;
Exclusion of sites where it can be objectively concluded that there will be no significant effects; and
Screening conclusion.
Field Walkover Surveys Field walkover surveys were undertaken on 17th of December 2015 to identify the potential for qualifying species and habitats in the surrounding environs of the current WwTP discharges at Portrane and Rush. The field surveys and reporting were completed by a qualified ecologist.
Consultation The EPA, as the competent authority, will seek NPWS advice as may be required in reaching their decision on a WwTP discharge. The NPWS can only communicate with the applicant (i.e. Irish Water) on request from the competent authority, when the formal application process to the competent authority has already commenced.
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Screening
Screening for Appropriate Assessment was undertaken by the Environmental Protection Agency who determined that an Appropriate Assessment of the existing discharge from the Portrane, Donabate, Rush and Lusk Agglomeration is required due to the potential adverse impact on the qualifying interests of Rockabill to Dalkey SAC, Rogerstown Estuary SAC, Malahide Estuary SAC, Baldoyle Bay SAC, Howth Head SAC, Lambay Island SAC, Rogerstown Estuary SPA, Lambay Island SPA, Rockabill SPA, Skerries Islands SPA, Broadmeadow/Swords Estuary SPA, Baldoyle SPA, Irelands Eye SPA and Howth Head Coast SPA. This determination was based on the following:
The discharge of untreated effluent to the Northwestern Irish Sea, the proximity of the primary and secondary discharges to the named European Sites and the potential for impacts on the qualifying interests.
Therefore, applying the Precautionary Principle and in accordance with Article 6(3) of the Habitats Directive, the current WwTP discharge at Portrane will be brought forward for a Stage 2 Appropriate Assessment.
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Stage 2: Appropriate Assessment
The Natura 2000 sites, which have been determined as requiring AA, are described and all the potential impacts resulting from the Portrane WwTP discharge are discussed in relation to the conservation objectives of these designated sites.
Description of the Project Donabate, Portrane, Rush and Lusk are villages/towns located in North County Dublin that have seen significant population growth in recent years. The settlements were originally licensed separately by the EPA as Donabate/Portrane (D0114-01), Rush (D0119-01-01) and Lusk (D0122-01).
A single wastewater treatment plant in Portrane and an associated sewer network has recently been constructed to treat the wastewater generated in the four areas. The network also includes a pump station at Whitestown to transfer wastewater from the northside of the Rogerstown Estuary (i.e. from Rush and Lusk) to the Portrane plant.
The following infrastructure has been constructed in recent years; Portrane WwTP – opened in 2013 with capacity for 65,000 PE; 600m outfall from the WwTP – for the discharge of treated effluent to the Irish Sea; Whitestown Pump station – to pump flows to the WWTP from Rush and Lusk; Gravity sewer from Lusk to Whitestown – Connection for Lusk to the WwTP; Donabate Pump station and associated rising mains; Portrane Pump station and associated rising mains; Two pipelines across the Rogerstown Estuary – connecting everything north of the Estuary to Portrane; and Channel Road sewer Rush - Connection for Rush to the WwTP.
The Lusk agglomeration has been connected For inspection to purposesthe Portrane only. WwTP, meaning that the discharge Consent of copyright owner required for any other use. from the former septic tank at Lusk to Rogerstown Estuary has ceased. A total of 25% of the load from the Rush agglomeration has been transferred to Portrane WwTP, with the remaining 75% currently discharging untreated to the Irish Sea via a temporary secondary discharge point in Rush. The works to connect the remaining 75% of the Rush agglomeration are currently programmed to commence in Summer 2016 and construction is programmed to be completed in mid 2018.
The treatment process at the Portrane plant includes the following:- Preliminary treatment (including screening / grit removal); Primary treatment; Secondary treatment – SBR; and Tertiary treatment – UV treatment.
The current population equivalent for the agglomeration is 30,404p.e. (residential and non- domestic) and the estimated 2022 load will be 32,363p.e. The estimates include the ca. 10,000p.e. load due to be transferred from Rush by 2018.
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Process Description The new Portrane WwTP consists of an inlet works for screening and degritting, 4 Sequence Batch Reactors (SBRs), a sludge handling building, and UV on the effluent. The sludge is dewatered and the resultant cake is disposed of by private Contractor by landspreading after composting.
The Waste Water Treatment Plant is designed to cater for future expansion on the Portrane/Donabate Peninsula (up to 35,000PE) together with the Rusk/Lusk areas (30,000PE).
The Waste Water Discharge Licence dictates the standards to which the plant must treat effluent: BOD 25mg/l COD 125mg/l SS 35mg/l
The location of the primary discharge to the Irish Sea is N249774, E325900. Effluent data from 2015 is presented in Table 1.0 together with the ELV’s set in the discharge license.
The effluent from the primary discharge meets the Urban Wastewater Treatment Regulations 2001(S.I. No. 254/2001) as amended, and discharge license ELV’s, for all relevant parameters (Table 1.0). The agglomeration does not discharge to any waterbody listed as a Sensitive Area on Schedule 1 of the Urban Waste Water Treatment (Amendment) Regulations 2010 (S.I. No. 48/2010).
The effluent from the temporary secondary discharge is untreated, and as such does not meet the requirements of the Urban Wastewater Treatment Regulations (Table 2.0).
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Table 1.0: Effluent Monitoring Data at Primary Discharge 2015 Dissolved Inorganic Total Total Ortho- Sample BOD COD SS Nitrogen Nitrogen Phosphorous Ammonia Phosphate Date mg/l mg/l mg/l mg/l as N mg/l mg/l mg/l as N mg/l as P License 25 125 35 ELV 08/01/15 3 36 6 16.17 16.9 3.81 1.42 3.53 15/01/15 3 37 7 15.61 17.8 3.29 1.11 3.01 22/01/15 3 44 <5 12.74 15.2 3.38 0.62 3.14 29/01/15 4 37 <5 12.41 15.6 4.34 0.55 4.11 05/02/15 4 39 <5 13.55 16.3 4.02 1.11 3.55 12/02/15 4 44 13 14.84 17.3 4.36 1.38 3.83 19/02/15 4 39 6 13.01 15.2 2.94 0.75 2.36 26/02/15 5 39 <5 12.45 13.9 2.9 0.93 2.51 05/03/15 2 36 <5 12.88 15.5 2.7 0.74 2.38 12/03/15 - 45 5 17.87 18.7 4.17 2.36 3.52 19/03/15 4 39 <5 12.1 15.7 3.94 0.52 3.57 26/03/15 6 38 5 13.17 14.9 3.83 1.69 3.3 02/04/15 4 30 5 10.63 11.7 2.92 0.73 2.6 09/04/15 3 41 <5 11.58 12.4 2.61 0.19 1.86 16/04/15 4 30 5 11.61 12.9 3.63 0.07 3.08 23/04/15 4 37 7 13.7 14.8 4.46 0.23 3.94 30/04/15 5 41 8 16.26 17.6 4.28 0.5 3.06 07/05/15 6 34 11 10.24 11 2.06 0.66 1.5 14/05/15 3 37 <5 12.63 14.4 2.43 0.21 2.09 21/05/15 3 33 <5 12.92 14.5 3.56 0.43 2.57 28/05/15 6 41 <5 12.18 16.8 4.11 0.36 3.11 04/06/15 5 41 11 14.05 15.3 4.1 0.25 3.71 11/06/15 4 42 10 15.31 18.3 5.08 0.3 4.7 18/06/15 4 47 11 16.12 17.4 5.39 0.26 4.97 25/06/15 4 44 7 15.59 17.8 5.35 0.26 4.92 02/07/25 4 40 5 11.93 For inspection13.4 purposes only. 4.33 0.23 4.05 Consent of copyright owner required for any other use. 09/07/15 5 44 8 13.33 15.6 4.1 0.3 3.75 16/07/15 4 37 6 12.15 13.7 4.25 0.17 3.68 23/07/15 4 35 <5 14.67 16.4 4.04 0.19 3.69 30/07/15 4 30 <5 13.93 15.4 4.01 0.39 3.89 06/08/15 4 33 6 14.65 14.8 4.78 0.26 4.62 13/08/15 5 36 8 7.79 14.1 4.81 0.18 2.5 20/08/15 6 54 9 15.22 16.5 4.92 1.01 4.19 27/08/15 4 31 6 11.24 13.1 2.93 0.22 2.59 03/09/15 5 39 8 14 14.9 3.88 0.18 3.52 10/09/15 4 37 8 14.01 14.6 4.43 0.17 3.79 17/09/15 5 41 8 10.22 15.7 3.83 0.15 2.42 24/09/15 4 30 10 13.26 15.5 7.31 0.3 2.87 01/10/15 3 41 6 16.51 17.8 4.6 0.32 4.2 08/10/15 4 43 13 16.4 17.7 4.45 0.22 3.86 15/10/15 5 47 16 11.51 16.5 5.17 0.42 3.57 22/10/15 4 42 7 12.71 14 4.91 0.43 4.37 29/10/15 4 45 9 11.88 12.9 4.68 0.72 4.18 05/11/15 5 45 11 13.77 14.9 4.03 0.45 3.64 12/11/15 3 34 <5 7.84 8.34 2.69 0.25 2.44 19/11/15 4 32 <5 9.77 10.4 2.74 1.29 2.42 26/11/15 3 28 <5 12.8 15.4 4.13 0.83 3.46
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Table 2.0: Effluent Monitoring Data at Secondary Discharge 2015 Sample BOD COD SS Dissolved Total Total Ammonia Ortho- Date mg/l mg/l mg/l Inorganic Nitrogen Phosphorous mg/l as N Phosphate Nitrogen mg/l mg/l mg/l as P mg/l as N
22/01/15 228 431 155 29.07 57.4 5.77 26.58 5.72 05/03/15 239 462 264 58.13 93.2 10.7 55.01 7.09 26/03/15 254 570 171 33.23 52.5 7.26 30.46 4.57 30/04/15 306 593 271 36.89 58 7.03 34.96 4.33 28/05/15 348 1050 258 28.61 42.5 6.25 26.98 3.44 25/06/15 >385 745 299 49.53 62.7 8.66 49.53 4.45 30/07/15 336 627 216 47.24 59.1 7.14 46.86 4.83 03/09/15 279 571 353 43.26 79.4 8.17 43.26 4.69 01/10/15 >385 1003 559 48.38 59.1 12.1 48.38 4.81 29/10/15 30 343 78 23.66 30.9 3.64 22.93 2.47 26/11/15 282 539 208 25.48 39.8 5.44 24.55 2.98
Description of the Receiving Environment and Monitoring Results
The WwTP discharges to the Irish Sea off the Portrane coastline. Data from an EPA monitoring location in the Irish Sea off Portrane (DB750), located approximately 500m from the primary discharge point of Portrane WwTP, is presented below. Water quality at this location (DB750) was compliant with Schedule 5 of the European Communities Environmental Objectives (Surface Water) Regulations 2009 (S.I. No. 272 of 2009) with DIN levels achieving ‘Good status’ on both sampling occasions. Water quality at the Rush ambient sampling (DB770), located ca. 1km south of the secondary discharge point, did not achieve Good status with respect to DIN levels in May 2014.
For inspection purposes only. Table 3.0:Consent of copyrightAmbient owner Water required forMonitoring any other use. Data
ll a ll
pH
BOD
Nitrogen Nitrogen
Ammonia
Parameter
Chlorophy
Total Organic Total Organic
Sampling Date/ Sampling Dissolved Inorganic Inorganic Dissolved mg/l N mg/l mg/l mg/m3 pH Units mg/l
SW EQS ≤0.25 ≤10.0 22/05/14 <10 <2 0.092 8.8 8.2 0.082 DB750 27/11/14 <5 <2 0.199 0.8 8 0.199 22/05/14 52 <2 1.502 9.6 8.2 1.450 DB770 27/11/14 <5 <2 0.184 0.4 8 0.184
Both Portrane (Brook Beach) and Donabate (Balcarrick Beach) achieved ‘Excellent’ bathing water quality in 2014, an improvement from ‘Good’ status in the previous few years. Rush south beach was assigned ‘Poor’ bathing water status in 2014. One of the management measures
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proposed by the EPA (2015)1 includes the connection of the Rush agglomeration into the Portrane/Donabate/Rush/Lusk sewerage scheme.
The EPA classes Rogerstown Estuary transitional water body (IE_EA_050_0100) and Baldoyle Bay (IE_EA_080_0100) as Eutrophic (2010-2012). In terms of WFD (2010-2012) status, Rogerstown Estuary and Broadmeadow water (inner Malahide Bay – not assigned an EPA water quality status) are assigned Poor status, while Baldoyle Estuary is assigned Moderate status. With regard to WFD risk scores Rogerstown Estuary and Broadmeadow water are ‘At risk of not achieving good status’, while Baldoyle Bay is ‘Possibly at risk of not achieving good status’.
Coastal water quality in the Northwestern Irish Sea (IE_EA_020_0000) (into which Portrane and Rush discharge) and the Irish Sea Dublin waterbody to the south (IE_EA_070_0000) are classed as Unpolluted, while that in Malahide Bay (IE_EA_060_0000) is classed as Intermediate. In terms of WFD (2010-2012) status, the Northwestern Irish Sea is assigned High status, the Irish Sea Dublin waterbody is assigned Good status, and Malahide Bay is assigned Moderate status. With regard to WFD risk scores all these coastal waters are considered to be ‘At risk of not achieving good status’.
The coastal waters off Malahide and Skerries are designated shellfish waters under the European Communities (Quality of Shellfish Waters) (Amendment) Regulations 2009 (S.I. 55 of 2009). The Marine Institute carries out ongoing shellfish monitoring for biotoxins in each area at sampling locations DN-ME-ME in the Malahide area, and DN-SS-SS in the Skerries area2 with occasional elevated levels of biotoxins recorded. The Skerries area is a Class B3 mollusc production area for Razor clam meaning the shellfish can not be directly consumed without further treatment, while Malahide is preliminarily classified as a Class A area for the same species4 indicating E coli levels are low enough to allow direct consumption. The primary discharge at Portrane is on the boundary between these two areas, while the temporary secondary discharge at Rush is within the Skerries production area.
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Field Walkover Survey The coastal and intertidal habitats and species in the vicinity of the discharges at Portrane and Rush were surveyed in December 2015. The new outfall at Portrane discharges subtidally 600m offshore. The closest coastal/intertidal habitats to the outfall location are rocky shore, small patches of coastal grassland at the edge of the coastal path, and amenity and agricultural grasslands beyond this. Birds observed in the general area foraging in and around the rocks and shallow coastal waters included herring gull, greater black-backed gull, black-headed gull, redshank, turnstone, oystercatcher, curlew and raven. Other birds noted in the grassland and shrubs adjacent to the coastal paths were starling, greenfinch, stonechat and wren. There was no evidence of pollution observed.
At Rush, the outfall discharges near the low tide mark close to intertidal rocky shore habitats. Flocks of herring gull and black-headed gull were observed foraging at the outfall. The only
1 EPA (2015) Bathing Water Quality in Ireland - A report for the year 2014. 2 http://www.marine.ie/Home/site-area/data-services/interactive-maps/latest-shellfish-safety-data 3 http://www.sfpa.ie/SeafoodSafety/Shellfish/ClassifiedAreas.aspx 4 SFPA (2013) Code of practice for the microbiological monitoring of Bivalve Mollusc Production Areas. Sea Fisheries Protection Authorities. Version 5 – September 2013.
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other bird species noted along the rocky shore was oystercatcher. A carpet of green algae covers the exposed concrete covering of the outfall. The water in the rockpools in the vicinity of the outfall was observed to be cloudy.
The Marine Atlas5 provides habitat data for the Irish Sea. The subtidal area in the coastal waters where the Rush and Portrane outfalls discharge is classed as ‘Shallow sublittoral mixed sediment’, while the habitat in Rogerstown estuary is ‘Shallow sublittoral mud’.
A total of 18 fish species were recorded in Rogerstown Estuary in October 2010 during surveys carried out by IFI (IFI, 2010a). Sand goby was the most abundant species, followed by lesser sand eel and thick-lipped grey mullet. Eels, listed as critically endangered in the Irish Red Data Book (King et al, 2011) were also present. Surveys of the Broadmeadow Estuary in the same year recorded a total of 12 fish species (IFI, 2010b). Sand goby was again the most abundant species recorded, followed by sprat and flounder.
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5 http://atlas.marine.ie/
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Description of the Natura 2000 Sites Affected
A total of 14 Natura 2000 sites were screened in by the EPA. Considering the effluent and water quality data presented above, the possibility of significant effects on each site has been considered in the table below. Currently, the main risk to designated sites relates to the untreated discharge in Rush. The current discharge from the new plant at Portrane, and future predicted discharges within design capacity, do not pose a threat to water quality. Those sites where significant effects are considered possible are then dealt with in more detail.
Table 4.0: Natura 2000 Sites and potential for impact Designated Site Qualifying Interests Potential for Impact Rockabill to Dalkey SAC Reefs [1170] Yes - qualifying features are Site Code: 00300 Phocoena phocoena (Harbour potentially 400m from the Porpoise) [1351] untreated discharge at Rush, with the potential for Harbour porpoise to occur in closer proximity to the untreated discharge. Rogerstown Estuary SAC Estuaries [1130] Yes - sensitive habitats are ca. Site Code 000208 Mudflats and sandflats not covered 900m to the south of the by seawater at low tide [1140] untreated discharge at Rush. Salicornia and other annuals Rogerstown Estuary is classed as colonising mud and sand [1310] Eutrophic and assigned Poor Atlantic salt meadows (Glauco- WFD status indicating it would be Puccinellietalia maritimae) [1330] sensitive to additional nutrients. Mediterranean salt meadows Water quality in the coastal (Juncetalia maritimi) [1410] monitoring site and bathing water
Shifting dunes along the shoreline monitoring site located in the with Ammophila arenaria (white waters between the discharge dunes) [2120] For inspection purposes only. Consent of copyright owner required for any other use.and the SAC do not meet relevant
Fixed coastal dunes with herbaceous standards. vegetation (grey dunes) [2130]
Malahide Estuary SAC Mudflats and sandflats not covered No – while habitats are ca. 1km to by seawater at low tide [1140] Site Code 000205 the south of the primary discharge Salicornia and other annuals point at Portrane, effluent data colonising mud and sand [1310] indicates the plant is operating Spartina swards (Spartinion well and hydrodynamic modelling maritimae) [1320] undertaken for the outfall Atlantic salt meadows (Glauco- indicates the effluent plume would Puccinellietalia maritimae) [1330] only cause water quality Mediterranean salt meadows deterioration in a localised area (Juncetalia maritimi) [1410] around the outfall (Pettit & Co; Shifting dunes along the shoreline 2002). The secondary discharge with Ammophila arenaria (white at Rush is ca. 5km to the north of dunes) [2120] the closest habitat (1140-mudflats Fixed coastal dunes with herbaceous and sandflats) - with the dilution vegetation (grey dunes) [2130] and dispersal available in
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intervening coastal waters, there is no potential for impact. Baldoyle Bay SAC Mudflats and sandflats not covered No – qualifying habitats over 7km by seawater at low tide [1140] Site Code: 000199 from the primary and secondary Salicornia and other annuals discharges. With the dilution and colonising mud and sand [1310] dispersal available in intervening Atlantic salt meadows (Glauco- coastal waters, there is no Puccinellietalia maritimae) [1330] potential for impact. Mediterranean salt meadows (Juncetalia maritimi) [1410]
Howth Head SAC Vegetated sea cliffs of the Atlantic No – qualifying habitats terrestrial and Baltic coasts [1230] Site Code: 000202 with no potential to be impacted European dry heaths [4030] by the agglomeration discharges. Lambay Island SAC Reefs [1170] No – qualifying features over 4km Site Code: 000204 Vegetated sea cliffs of the Atlantic from the primary and secondary and Baltic coasts [1230] discharges. With the dilution and Halichoerus grypus (Grey Seal) dispersal available in intervening [1364] coastal waters, there is no Phoca vitulina (Common Seal) [1365] potential for impact. Rogerstown Estuary SPA Greylag Goose (Anser anser) [A043] Yes - special conservation Site Code: 004015 Light-bellied Brent Goose (Branta interests ca. 900m south of the bernicla hrota) [A046] south of the untreated discharge Shelduck (Tadorna tadorna) [A048] at Rush. Rogerstown Estuary is classed as Eutrophic and Shoveler (Anas clypeata) [A056] assigned Poor WFD status Oystercatcher (Haematopus indicating it would be sensitive to ostralegus) [A130] additional nutrients. Water quality Ringed Plover (Charadrius hiaticula) in the coastal monitoring site and [A137] For inspection purposes only. bathing water monitoring site Consent of copyright owner required for any other use. Grey Plover (Pluvialis squatarola) located in the waters between the [A141] discharge and the SAC do not Knot (Calidris canutus) [A143] meet relevant standards.
Dunlin (Calidris alpina) [A149]
Black-tailed Godwit (Limosa limosa) [A156]
Redshank (Tringa totanus) [A162]
Wetland and Waterbirds [A999]
Lambay Island SPA Fulmar (Fulmarus glacialis) [A009] No - special conservation Site Code: 004069 Cormorant (Phalacrocorax carbo) interests over 4km from the [A017] primary and secondary Shag (Phalacrocorax aristotelis) discharges. With the dilution and [A018] dispersal available in intervening Greylag Goose (Anser anser) [A043] coastal waters, there is no potential for impact. Lesser Black-backed Gull (Larus
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fuscus) [A183]
Herring Gull (Larus argentatus) [A184]
Kittiwake (Rissa tridactyla) [A188]
Guillemot (Uria aalge) [A199]
Razorbill (Alca torda) [A200]
Puffin (Fratercula arctica) [A204]
Rockabill SPA Purple Sandpiper (Calidris maritima) No - special conservation [A148] Site Code: 004014 interests over 5km from the Roseate Tern (Sterna dougallii) primary and secondary [A192] discharges. With the dilution and Common Tern (Sterna hirundo) dispersal available in intervening [A193] coastal waters, there is no Arctic Tern (Sterna paradisaea) potential for impact. [A194] Skerries Islands SPA Cormorant (Phalacrocorax carbo) No - special conservation [A017] Site Code: 004122 interests over 5km from the Shag (Phalacrocorax aristotelis) primary and secondary [A018] discharges. With the dilution and Light-bellied Brent Goose (Branta dispersal available in intervening bernicla hrota) [A046] coastal waters, there is no Purple Sandpiper (Calidris maritima) potential for impact. [A148]
Turnstone (Arenaria interpres) [A169]
Herring Gull (Larus argentatus) [A184] Broadmeadow/Swords Great Crested Grebe (Podiceps No – the SPA boundary is ca. cristatus) [A005] Estuary (Malahide Estuary) For inspection purposes only. 3km to the south of the primary Consent of copyright owner required for any other use. SPA Light-bellied Brent Goose (Branta discharge point. Effluent data bernicla hrota) [A046] Site Code: 004025 indicates the plant is operating Shelduck (Tadorna tadorna) [A048] well and hydrodynamic modelling Pintail (Anas acuta) [A054] undertaken for the outfall indicates the effluent plume would Goldeneye (Bucephala clangula) [A067] only cause water quality deterioration in a localised area Red-breasted Merganser (Mergus serrator) [A069] around the outfall. The secondary discharge at Rush is Oystercatcher (Haematopus ostralegus) [A130] ca. 12km to the north of the boundary. Golden Plover (Pluvialis apricaria) [A140]
Grey Plover (Pluvialis squatarola) [A141]
Knot (Calidris canutus) [A143]
Dunlin (Calidris alpina) [A149]
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Black-tailed Godwit (Limosa limosa) [A156]
Bar-tailed Godwit (Limosa lapponica) [A157]
Redshank (Tringa totanus) [A162]
Wetland and Waterbirds [A999]
Baldoyle Bay SPA Light-bellied Brent Goose (Branta No - special conservation bernicla hrota) [A046] Site Code: 004016 interests over 7km from the Shelduck (Tadorna tadorna) [A048] primary and secondary Ringed Plover (Charadrius hiaticula) discharges. With the dilution and [A137] dispersal available in intervening Golden Plover (Pluvialis apricaria) coastal waters, there is no [A140] potential for impact.
Grey Plover (Pluvialis squatarola) [A141]
Bar-tailed Godwit (Limosa lapponica) [A157]
Wetland and Waterbirds [A999]
Irelands Eye SPA Cormorant (Phalacrocorax carbo) No - special conservation [A017] Site Code: 004117 interests over 8km from the Herring Gull (Larus argentatus) primary and secondary [A184] discharges. With the dilution and Kittiwake (Rissa tridactyla) [A188] dispersal available in intervening Guillemot (Uria aalge) [A199] coastal waters, there is no potential for impact. Razorbill (Alca torda) [A200] Howth Head Coast SPA Kittiwake (Rissa tridactyla) [A188] No - special conservation interest For inspection purposes only. Site Code: 004113 Consent of copyright owner required for any other use.over 11km from the primary and
secondary discharges. With the dilution and dispersal available in intervening coastal waters, there is no potential for impact.
Based on the proximity to the untreated discharge at Rush and evidence of water quality deterioration in connected coastal waters, the following designated sites are considered in more detail: • Rockabill to Dalkey SAC • Rogerstown Estuary SAC • Rogerstown Estuary SPA
Rockabill to Dalkey Island SAC6
6 Information taken from Rockabill to Dalkey Island SAC Site Synopsis (3000). Dated 10.2.2014
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This site includes a range of dynamic inshore and coastal waters in the western Irish Sea. These include sandy and muddy seabed, reefs, sandbanks and islands. This site extends southwards, in a strip approximately 7 km wide and 40 km in length, from Rockabill, running adjacent to Howth Head, and crosses Dublin Bay to Frazer Bank in south Co. Dublin. The site encompasses Dalkey, Muglins and Rockabill islands.
Reef habitat is uncommon along the eastern seaboard of Ireland due to prevailing geology and hydrographical conditions. Expansive surveys of the Irish coast have indicated that the greatest resource of this habitat within the Irish Sea is found fringing offshore islands which are concentrated along the Dublin coast. A detailed survey of selected suitable islands has shown areas with typical biodiversity for this habitat both intertidally and subtidally. These reefs are subject to strong tidal currents with an abundant supply of suspended matter resulting in good representation of filter feeding fauna such as sponges, anemones and echinoderms.
The area selected for designation represents a key habitat for the Annex II species Harbour Porpoise within the Irish Sea. Population survey data show that porpoise occurrence within the site boundary meets suitable reference values for other designated sites in Ireland. The species occurs year-round within the site and comparatively high group sizes have been recorded. The selected site contains a wide array of habitats believed to be important for Harbour Porpoise including inshore shallow sand and mudbanks and rocky reefs scoured by strong current flow.
Description of the Qualifying Interests of the SAC
This site is designated for the following habitats/species: • Reefs [1170] • Phocoena phocoena (Harbour Porpoise) [1351]
A significant area of Reef habitat is present off the Rush Coast in the closest part of the SAC to the discharge at Rush. The habitat is Fordescribed inspection purposesas ‘Subtidal only. Reef Community Complex’ (NPWS, Consent of copyright owner required for any other use. 2013a) and supports a range of species including algae (kelp, red algae), anemones, bryozoans, hydroids, ascidians, barnacles and echinoderms.
Population estimates indicate there is a consistent annual and seasonal occurrence of Harbour porpoise within the SAC and that they are present during the calving/breeding period (NPWS, 2013a). While there are some knowledge gaps with regard to population data, the SAC is considered to be an important coastal site for this species.
Foraging areas for harbour porpoise are often associated with areas of strong tidal current and associated eddies; and therefore the occurrence of porpoises close to shore or adjacent to islands and prominent headlands is commonly reported (NPWS, 2013a). The Ecologist undertaking this AA has observed Harbour porpoise in the Rush area during surveys for other Irish Water projects.
Table 5.0: Qualifying SAC Features along Surveyed Stretch
Site Qualifying Interests Present within potential zone of
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influence of discharge
Rockabill to Dalkey Reefs Yes Island SAC Harbour Porpoise Yes
Rogerstown Estuary SAC7
Rogerstown Estuary is situated about 2 km north of Donabate in Co. Dublin. It is a relatively small, narrow estuary separated from the sea by a sand and shingle bar. The estuary is divided by a causeway and narrow bridge, built in the 1840s to carry the Dublin-Belfast railway line.
The estuary drains almost completely at low tide. The intertidal flats of the outer estuary are mainly of sands, with soft muds in the north-west sector and along the southern shore. Associated with these muds are stands of Common Cordgrass (Spartina anglica).
The area of intertidal flats in the inner estuary is reduced as a result of the local authority refuse tip on the north shore. The sediments are mostly muds, which are very soft in places. In the extreme inner part, the estuary narrows to a tidal river.
The habitat ‘Salicornia mud’ occurs in both the outer and inner estuaries, and S. dolichostachya is the main glasswort species found.
Saltmarsh fringes parts of the estuary, especially the southern shores and parts of the outer sand spit. Salt meadows and wet brackish fields occur along the tidal river. Low sand hills occur on the outer spit, including some small areas of fixed dunes and Marram Grass (Ammophila arenaria) dunes. Fine sandy beaches and intertidal sandflats occur at the outer part of the estuary.
Two plant species which are legally protected For inspection under purposes the only. Flora (Protection) Order, 1999, occur Consent of copyright owner required for any other use. within the site: Hairy Violet (Viola hirta) occurs on the sand spit and Meadow Barley (Hordeum secalinum) occurs in the saline fields of the inner estuary.
Description of the Qualifying Interests of the SAC
This site is designated for the following 7 habitats:
• Estuaries [1130] • Mudflats and sandflats not covered by seawater at low tide [1140] • Salicornia and other annuals colonising mud and sand [1310] • Atlantic salt meadows (Glauco-Puccinellietalia maritimae) [1330] • Mediterranean salt meadows (Juncetalia maritimi) [1410] • Shifting dunes along the shoreline with Ammophila arenaria (white dunes) [2120] • Fixed coastal dunes with herbaceous vegetation (grey dunes) [2130]
7 Information taken from Rogerstown Estuary SAC Site Synopsis (208). Dated 12.8.2013.
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The nearest habitats to the discharge point are the mudflats and sandflats that occur outside the mouth of the estuary along the coast south of Rush. The ‘Estuaries’ habitat occurs inside the main estuary, with some small areas of Salicornia mud/sand around the southern inner edges of the estuary (NPWS, 2013b). The saltmarsh habitats, inundated at high tides, are located mainly along the southern shores and inner edges of the estuary. The dune habitats occur at the outer part of the estuary (NPWS, 2013c). The mudflats and sandflats habitats outside of the estuary include the poor-status Rush South Beach bathing water site, and are therefore assessed as having the potential to be impacted by the secondary discharge at Rush. There is the potential for tidal exchange to allow the flow of diluted effluent into Rogerstown Estuary, potentially contributing to the eutrophication of this waterbody (currently classed as Eutrophic by the EPA) – habitats potentially at risk are Estuaries, Mudflats and Sandflats, and Salicornia and other annuals colonising mud and sand. The saltmarsh habitats, while present within the estuary, are not considered to be at risk as are only periodically covered by water at high tide. Dune habitats are outside the potential zone of influence of the discharge.
Table 6.0: Qualifying SAC Features along Surveyed Stretch
Site Qualifying Interests Present within potential zone of influence of discharge
Rogerstown Estuaries Yes Estuary SAC Mudflats and sandflats not covered by seawater at Yes low tide Salicornia and other annuals colonising mud and Yes sand Atlantic salt meadows Yes Mediterranean salt meadows Yes Shifting dunes along the shoreline with Ammophila No arenaria Fixed coastal dunes with herbaceous vegetation No For inspection purposes only. (grey dunes) Consent of copyright owner required for any other use.
Rogerstown Estuary SPA8
Rogerstown Estuary SPA largely overlaps with the SAC (described above). At low tide extensive intertidal sand and mud flats are exposed and these provide the main food resource for the wintering waterfowl.
Rogerstown Estuary is an important winter waterfowl site and supports a population of Pale- bellied Brent Goose of international importance (1194 - all counts given are average peaks over the five winters 1996/97 – 2000/01). A further 14 species have populations of national importance as follows: Greylag Goose 87, Shelduck 78, Shoveler 72, Oystercatcher 1794, Ringed Plover 188, Grey Plover 343, Knot 2159, Sanderling 89, Dunlin 3128, Redshank 674, Lapwing 2166, Black-tailed Godwit 212, Greenshank 26 and Turnstone 188. The Greylag Geese are part of a larger population which spends most of the winter on Lambay Island. Other species which occur regularly in significant numbers include Wigeon 411, Teal 379, Mallard 267,
8 Information taken from Rogerstown Estuary SPA Site Synopsis (4015). Dated 10.11.2003.
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Redbreasted Merganser 22, Golden Plover 159 and Curlew 245. The numbers of Golden Plover and Lapwing can at times be considerably higher than the averages given above. The presence of Golden Plover is of note as this species is listed on Annex I of the E.U. Birds Directive. Large numbers of gulls, mostly Herring, Great Blackbacked and Black-headed, are attracted to the area, partly due to the presence of an adjacent local authority landfill site.
Some of the wader species also occur on passage, notably Black-tailed Godwit with numbers often exceeding 300 in April. The estuary is a regular staging post for scarce migrants, especially in autumn when Green Sandpiper, Ruff, Little Stint, Curlew Sandpiper and Spotted Redshank may be seen. Shelduck breed within the site.
Description of the Conservation Interests of the SPA
The SPA is designated for the following bird species and the wetlands that support them:
• Greylag Goose (Anser anser) [A043] • Light-bellied Brent Goose (Branta bernicla hrota) [A046] • Shelduck (Tadorna tadorna) [A048] • Shoveler (Anas clypeata) [A056] • Oystercatcher (Haematopus ostralegus) [A130] • Ringed Plover (Charadrius hiaticula) [A137] • Grey Plover (Pluvialis squatarola) [A141] • Knot (Calidris canutus) [A143] • Dunlin (Calidris alpina) [A149] • Black-tailed Godwit (Limosa limosa) [A156] • Redshank (Tringa totanus) [A162] • Wetland and Waterbirds [A999]
The relevant population and distribution data is provided in the Conservation objectives supporting document (NPWS, 2013d)9. For inspection purposes only. Consent of copyright owner required for any other use. Regarding current conservation status:
• 2 species are currently considered as Highly Unfavourable (Greylag Goose & Knot);
• 1 species is considered as Intermediate unfavourable (Grey Plover);
• 8 species are currently considered as Favourable (Light-bellied Brent Goose, Shelduck, Shoveler, Oystercatcher, Ringed Plover, Dunlin, Black-tailed Godwit & Redshank).
Information on populations (where available), requirements and sensitivities of key species are considered in more detail below with data taken from Crowe (2005), Colhoun & Cummins, (2013), BirdWatch Ireland website and iWeBS data10 and NPWS (2013d).
Greylag Geese that occur at Rogerstown Estuary are considered part of the ‘North County Dublin flock’. This flock frequents Rogerstown Estuary, and nearby terrestrial grasslands. They
9 NPWS (2013) Rogerstown Estuary SPA. Conservation Objectives Supporting Document – Version 1 10 www.birdwatchireland.ie iWeBS site summary data for Cork Harbour
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feed mostly on cereal stubble and grassland. They are amber-listed in Ireland as the majority of the population winters at less than ten sites. Numbers peaked in 1995, then declined before gradually increasing again till 2004. Since 2004, number have decreased again. Many iWeBS counts in recent years have been below the nationally important threshold for this species.
Light-bellied Brent Goose The brent geese that winter in Rogerstown Estuary are part of the population that breed in the Canadian Arctic. They feed on Zostera beds, as well as on algae and in adjacent terrestrial fields when these resources become depleted (Robinson et al, 2004). The long-term trend for increasing numbers at Rogerstown Estuary is consistent with the all-Ireland and national trends. Peak counts from iWeBS survey data recorded between winters 2004/2005 and 2013/2014 indicate that internationally important numbers have been recorded in all these years. Results of a low-tide survey indicate that brent geese occasionally use the ‘Rush south beach’ subsite (OUL13).
Shelduck are amber listed in Ireland as the majority of the wintering population occurs at less than ten sites (Colhoun & Cummins, 2013). Their chief source of food is the estuarine snail Hydrobia ulvae, and spatial distribution of Shelduck within estuaries is strongly influenced by the behaviour of this prey, particularly in relation to water depth. iWeBS data indicates that nationally important shelduck numbers have consistently been recorded at Rogerstown.
Small numbers of Shoveler breeding in Ireland are supplemented during winter by migratory birds from northwest and central Europe. The wintering population is relatively small. They are a dabbling duck feeding on a range of items from planktonic crustaceans and small molluscs, to insects, larvae, plant material and seeds. Numbers in Rogerstown have fluctuated greatly between seasons, though they usually exceed national importance.
Oystercatcher winter in all coastal habitats, particularly favouring open sandy coasts. Their diet includes large invertebrates particularly mussels and cockles. They also occasionally feed on For inspection purposes only. grasslands where they prey on Consenttipulid of larve copyright and owner earthwor required forms. any Numbersother use. of Oystercatcher in the
SPA have shown a gradual increase up to the mid 2000’s before declining in recent winters. iWeBS data indicates that nationally important oystercatcher numbers have consistently been recorded at Rogerstown. Results of a low-tide survey indicate that oystercatcher use the subsites north and south of Rush (OU455, OUL12, OUL13).
Ringed Plover numbers have fluctuated widely, though the overall trend highlights increasing numbers up to 2003 that subsequently decreased. The national trend for this species is showing an increase but this contrasts with Northern Ireland and Britain, both of which have shown a long-term decline in numbers. iWeBS data indicates numbers consistently exceed the threshold for national importance at Rogerstown. Results of a low-tide survey indicate that ringed plover use the Rush North Beach subsite (OU455).
Grey Plover are a winter visitor from Siberia. They are amber-listed as the majority of birds winter at less than ten sites. They feed on a variety of burrowing intertidal invertebrates. They winter at coastal sites, mostly along eastern and southern coasts in large muddy estuaries. iWeBS data for Rogerstown indicates that numbers have declined in recent years but still exceed the threshold for national importance.
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Knot winter on the coasts of Ireland, preferring estuarine sites with extensive areas of muddy sands. They feed on bivalve mussels and crustaceans in the upper surface of the sediment. Numbers in the SPA have decreased over time and have been below the threshold for national importance for the last 4 winter periods published on the iWeBS website. Results of a low-tide survey indicate that knot occasionally use the Rush North Beach subsite (OU455).
Dunlin are common along coastal areas in Ireland, especially on tidal mudflats and estuaries. They feed on small invertebrates of estuarine mudflats, particularly polychaete works and small gastropods. They feed in the muddier sections of the estuaries close to the tide edge. In terms of the historical trend in numbers at Rogerstown, a gradual increase in numbers was followed by a decrease from 2004 to 2007. The trend at national level is for decline and a similar downward trend has been observed in Britain and Northern Ireland. Numbers in the last published winter period (2013/2014) for Rogerstown were much lower than previous periods, though all counts exceed the threshold for national importance.
Black-tailed Godwit are a winter visitor from Iceland. They winter in a variety of habitats both inland and coastal and feed on a range of invertebrates. Despite fluctuating greatly at times, numbers have steadily increased since the relatively low numbers recorded during the period 1996-1999. The observed increase is consistent with the national trend. Numbers at Rogerstown consistently exceed the threshold for national importance, and have occasionally exceeded the threshold for international importance.
Redshank winter all around the coast of Ireland, but favour mudflats, large estuaries and inlets. They feed along the upper shore of estuaries and along muddy river channels on Hydrobia sp. (bivalve mollusc), Corophium sp.(amphipod) and nereid worms (polychaete). iWeBS data indicates that numbers in Rogerstown have decreased in recent years but have remained above the threshold for national importance.
For inspection purposes only. Wetlands are also listed as a featureConsent of of copyright the SPA. owner requiredThe nearest for any other sensitive use. wetland habitats to a discharge from the agglomeration are the sandy shores south of Rush.
Table 7.0: Qualifying SPA Features along Surveyed Stretch
Site Qualifying Species Observed or signs of species Suitable habitat present presence within potential within potential zone of zone of influence of influence of discharge discharge
Rogerstown Greylag Goose No No Estuary Brent Goose No Yes SPA Shelduck No No Shoveler No No Oystercatcher Yes Yes Ringed Plover No Yes Grey Plover No No Knot No Yes Dunlin No Yes
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Black-tailed Godwit No No Redshank Yes Yes Wetlands - Yes
Species observed in the vicinity of the discharge, or known to use the intertidal habitats around Rush were listed as potentially sensitive. Species typically confined to the inner estuary are not considered sensitive to the discharges.
Conservation Objectives
Article 6 of the Habitats Directive states that:
Any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subject to appropriate assessment of its implications of the site in view of the site’s conservation objectives.
The importance of a site designated under the Habitats Directive is defined by its qualifying features or interests. Qualifying interests for any Natura 2000 site are listed on a pro forma, called the Natura 2000 standard data form, which forms the basis of the rationale behind designation, and informs the Conservation Management Plan for targeted management and monitoring of key species and habitats.
Favourable conservation status of a habitat is achieved when: Its natural range, and area it covers within that range, are stable or increasing; The specific structure and functions which are necessary for its long-term maintenance exist and are likely to continue to exist for the foreseeable future; and The conservation status of its typical species is favourable. For inspection purposes only. Consent of copyright owner required for any other use.
The favourable conservation status of a species is achieved when: Population dynamics data on the species concerned indicate that it is maintaining itself on a long-term basis as a viable component of its natural habitats; The natural range of the species is neither being reduced nor is likely to be reduced for the foreseeable future; and There is, and will probably continue to be, a sufficiently large habitat to maintain its populations on a long-term basis.
Rockabill to Dalkey Island SAC
The overarching conservation objective (NPWS, 2013e) 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:
Reefs [1170] Phocoena phocoena (Harbour Porpoise) [1351]
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Detailed conservation objectives for the qualifying interests assessed as having the potential to be impacted are as follows:
Reefs To maintain the favourable conservation condition of Reefs in Rockabill to Dalkey Island SAC, which is defined by the following list of attributes and targets: Attribute: Habitat Area; Target: Permanent habitat area stable or increasing subject to natural processes. Attribute: Habitat Distribution; Target: The distribution of reefs remains stable, subject to natural processes. Attribute: Community Structure; Target: Conserve the following community types in a natural condition: Intertidal reef community complex; and subtidal reef community complex.
Harbour porpoise To maintain the favourable conservation condition of Reefs in Rockabill to Dalkey Island SAC, which is defined by the following list of attributes and targets: Attribute: Access to suitable habitat; Target: Species range within the site should not be restricted by artificial barriers to site use. Attribute: Disturbance; Target: Human activities should occur at levels that do not adversely affect the harbour porpoise community at the site.
The latter target for harbour porpoise also relates to proposed activities or operations that may result in the deterioration of key resources (water quality) upon which harbour porpoises depend.
For inspection purposes only. Rogerstown Estuary SAC Consent of copyright owner required for any other use.
The overarching conservation objective (NPWS, 2013f) 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: • Estuaries [1130] • Mudflats and sandflats not covered by seawater at low tide [1140] • Salicornia and other annuals colonising mud and sand [1310] • Atlantic salt meadows (Glauco-Puccinellietalia maritimae) [1330] • Mediterranean salt meadows (Juncetalia maritimi) [1410] • Shifting dunes along the shoreline with Ammophila arenaria (white dunes) [2120] • Fixed coastal dunes with herbaceous vegetation (grey dunes) [2130]
Detailed conservation objectives for the qualifying interests assessed as having the potential to be impacted are as follows:
Estuaries
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To maintain the favourable conservation condition of Estuaries in Rogerstown Estuary SAC, which is defined by the following list of attributes and targets: Attribute: Habitat Area; Target: Permanent habitat area stable or increasing subject to natural processes. Attribute: Community Extent; Target: Maintain the extent of the Zostera-dominated community and the Mytilus edulis- dominated community, subject to natural processes. Attribute: Community Structure – Zostera density; Target: Conserve the high quality of the Zostera-dominated community, subject to natural processes. Attribute: Community Structure – Mytilus edulis density; Target: Conserve the high quality of the Mytilus edulis -dominated community, subject to natural processes. Attribute: Community Distribution; Target: Conserve the following community types in a natural condition – Sand to coarse sediment with Nephtys cirrosa and Scolelepis squamata community complex; Estuarine sandy mud to mixed sediment with Tubificoides benedii, Hediste diversicolor and Peringia ulvae community complex.
Muflats and sandflats not covered by seawater at low tide To maintain the favourable conservation condition of Mudflats and sandflats not covered by seawater at low tide in Rogerstown Estuary SAC, which is defined by the following list of attributes and targets: Attribute: Habitat Area; Target: Permanent habitat area stable or increasing subject to natural processes. Attribute: Community Extent; Target: Maintain the extent of the Zostera-dominated community and the Mytilus edulis- dominated community, subject to natural processes. For inspection purposes only. Attribute: Community StructureConsent of copyright – Zostera owner densityrequired for; any other use.
Target: Conserve the high quality of the Zostera-dominated community, subject to natural processes. Attribute: Community Structure – Mytilus edulis density; Target: Conserve the high quality of the Mytilus edulis -dominated community, subject to natural processes. Attribute: Community Distribution; Target: Conserve the following community types in a natural condition – Sand to coarse sediment with Nephtys cirrosa and Scolelepis squamata community complex; Estuarine sandy mud to mixed sediment with Tubificoides benedii, Hediste diversicolor and Peringia ulvae community complex.
Salicornia and other annuals colonising mud and sand To maintain the favourable conservation condition of Salicornia and other annuals colonising mud and sand in Rogerstown Estuary SAC, which is defined by the following list of attributes and targets: Attribute: Habitat Area;
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Target: Area stable or increasing subject to natural processes, including erosion and succession. Attribute: Habitat Distribution; Target: No decline, or change in habitat distribution, subject to natural processes. Attribute: Physical structure-sediment supply; Target: Maintain, or where necessary restore, natural circulation of sediments and organic matter, without any physical obstructions. Attribute: Physical structure – creeks and pans; Target: Maintain creek and pan structure, subject to natural processes including erosion and succession. Attribute: Physical structure-flooding regime; Target: Maintain natural tidal regime. Attribute: Vegetation structure - zonation; Target: Maintain the range of coastal habitats including transition zones, subject to natural processes including erosion and succession. Attribute: Vegetation structure – vegetation height; Target: Maintain structural vegetation within sward. Attribute: Vegetation structure – vegetation cover; Target: Maintain more than 90% of area outside creeks vegetated. Attribute: Vegetation composition – typical species and sub-communities; Target: Maintain the presence of species-poor communities listed in Saltmarsh Monitoring Project report. Attribute: Vegetation structure – negative indicator species – Spartina anglica; Target: No significant expansion of common cordgrass (Spartina anglica). No new sites of this species and an annual spread of less than 1% where it is already known to occur.
Rogerstown Estuary SPA Site specific conservation objectives are available for this SPA (NPWS, 2013g) and are For inspection purposes only. described below. Consent of copyright owner required for any other use.
Objective 1: To maintain the favourable conservation condition of the non-breeding waterbird Special Conservation Interest species listed for Rogerstown Estuary SPA.
This objective is defined by the following attributes and targets:- To be favourable, the long term population trend for each waterbird Special Conservation Interest species should be stable or increasing. Waterbird populations are deemed to be unfavourable when they have declined by 25% or more, as assessed by the most recent population trend analysis.
To be favourable, there should be no significant decrease in the range, timing or intensity of use of areas by the waterbird species of Special Conservation Interest, other than that occurring from natural patterns of variation.
Objective 2: To maintain the favourable conservation condition of the wetland habitat at Rogerstown Estuary SPA as a resource for the regularly-occurring migratory waterbirds that utilise it.
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This objective is defined by the following attributes and targets:- To be favourable, the permanent area occupied by the wetland habitat should be stable and not significantly less than the area of 646 ha, other than that occurring from natural patterns of variation.
Impact Prediction
Impacts on water quality The waste water discharge locations are not within the boundaries of any SAC or SPA, therefore, no direct impacts will occur through landtake or fragmentation of habitats.
It is important to establish whether the receiving environments water quality has the potential to interact with the qualifying interests of the Natura 2000 Sites identified. The closest connected Natura 2000 sites with the potential to be impacted by the Portrane agglomeration WwTP discharges are Rockabill to Dalkey Island SAC, Rogerstown Estuary SAC and Rogerstown Estuary SPA. As described in Table 4.0, other Natura 2000 sites are not considered to be at risk from the agglomeration discharges due to distance from the site and the dispersion and dilution available for the untreated element of the effluent in coastal waters.
The treated effluent from the primary discharge is not anticipated to impact on water quality in the vicinity of the closest Natura 2000 sites. The closest bathing water and surface water monitoring stations to the primary discharge indicates these waters achieve good-high status. The untreated effluent from the secondary discharge at Rush however, may present a risk to certain habitats and species in closest proximity. The Rush outfall is understood to have affected bathing water quality at Rush South Beach, which lies within the Rogerstown SAC and SPA designation. Furthermore ambient water quality data south of this outfall indicates DIN levels do not meet Surface Waters Regulations standards for Good status. For inspection purposes only. Consent of copyright owner required for any other use. Cumulative impacts in the catchment possibly pose the greatest risk to the conservation objectives. The potential threat(s) of Portrane WwTP on water quality (long term or single event) is increased when taken in combination with other water quality concerns in the catchment.
The Eastern River Basin District – River Basin Management Plan (ERBD, 2010) indicates that the main risks to water quality in the Fingal area are wastewater and industrial discharges, agriculture, unsewered properties and drainage management. The watercourses under most pressure are those feeding into Malahide Estuary. The landfill within Rogerstown Estuary is noted as a key concern from a pollution perspective11.
Other impacts which are likely to act cumulatively and impact on water quality in the catchment result from the following:
Chemical fertiliser application to agricultural lands (the main fertilisers in use supply nitrogen, phosphorus, potassium and sulphur);
11 Rogerstown SAC Natura 2000 Data Form (Dated 2014-09)
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Agricultural practices such as ploughing leads to greater mineralisation and nitrification, and in the case of old grassland, it can result in an increase in the release of nitrogen over a number of years (OECD, 1986); Artificial drainage increases nitrate leaching and reduce the morphological qualities of watercourses, thereby reducing the quality of habitat for flora and fauna; Endocrine disruptors in domestic sewage, including the main active component in the oral contraceptive pill, can interfere with the endocrine system of plants and animals which controls a wide range of processes including metabolism, growth and reproduction. Effects include a high degree of intersexuality downstream of sewage works (Routledge et al. 1998); Forestry may alter water quality indirectly through increased evaporation losses and hence an increase in solute concentrations; and On-site wastewater treatment systems, poorly performing septic tank units and other small effluent systems can be significant sources of nutrients to rivers.
While the untreated discharge from Rush potentially poses a threat to water quality in the vicinity of Natura 2000 sites, particularly in combination with other catchment pressures, works to transfer the load from Rush to Portrane WwTP are expected to commence this year.
Impacts on Annex I Habitats
The magnitude of the impact to intertidal and subtidal habitats will depend on the extent of dilution of the effluent and the nature of its subsequent dispersal.
Dilution factors will be influenced by tide and wind currents, the bathymetry of the seabed, the density of the effluent and the design of the outfall (SEPA, 2013). The initial dilution is the process whereby the discharge from a submerged outfall is entrained by the surrounding waters as a result of turbulent mixing and discharge buoyancy relative to ambient water density. Subsequent dilution with the receiving waters occurs away from the initial dilution in an area For inspection purposes only. defined as the mixing zone. HydrodynamicConsent of copyright modelling owner required was for carriedany other use. out for the Portrane outfall design and indicates that with the outfall located subtidally and 600m offshore, nutrients will only affect water quality within a limited area around the outfall (Pettit & Co, 2002).
Increases in anthropogenic nutrient input can favour fast-growing macroalgae in marine environments altering the structure and composition of algal assemblages however, which can have indirect effects on the structure of the entire community (Aquilino et al, 2009; Worm & Lotze, 2006). There was no obvious effects of the primary discharge in the adjacent intertidal habitats (shingle shore) or on the surface of the water (e.g. foam, discolouration), nor were there any foul odours. Given the quality of the effluent and the dilution and dispersal available in coastal waters, the primary discharge is not expected to impact on ‘Reefs’ habitat in Rockabill to Dalkey Island SAC. The secondary discharge at Rush is located closer to the designated Reefs habitat within this SAC. The potential for minor effects to this habitat is considered very low, but cannot be ruled out with the current untreated nature of the effluent.
The secondary discharge has potential to impact on the sandflats habitat in Rogerstown Estuary SAC in the area closest to the outfall, as Poor bathing water quality in this area has been linked to the untreated effluent discharge which does not achieve sufficient dispersal at its current low-
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tide mark location. While there will be some tidal exchange between coastal waters and Rogerstown estuary, the potential for any diluted effluent from the secondary discharge to reach habitats within the estuary is considered very low, however given the Poor status of the waterbody it is considered that there is a possibility of cumulative effects with other sources of pollution entering the estuary. No impacts to Rogerstown Estuary SAC are predicted from the treated primary discharge.
As described earlier, the remaining proportion of the Rush effluent load is scheduled to be transferred to Portrane WwTP, with the discharge at Rush ceasing. Once the entire final treated effluent is being discharged from the Portrane outfall, there will be no potential for significant effects to the qualifying habitats of Rogerstown Estuary SAC or Dalkey to Rockabill Island SAC.
Table 9.0: Qualifying habitats potentially impacted by the WwTP discharges
Qualifying Habitats Potential Brief Explanation Mitigation Impacts required
Rogerstown Estuary SAC Estuaries Yes The secondary discharge at Rush Yes Mudflats and sandflats not covered may pose a risk to these habitats in- by seawater at low tide combination with other sources of Salicornia and other annuals eutrophication. colonising mud and sand Atlantic salt meadows No Habitats only covered by waters at No Mediterranean salt meadows high tide, given the limited exposure impacts to saltmarsh habitats are not predicted. Shifting dunes along the shoreline No Coastal habitats not exposed to the No with Ammophila arenaria discharges, no potential for impact. Fixed coastal dunes with For inspection purposes only. herbaceous vegetation (grey dunes)Consent of copyright owner required for any other use.
Rockabill to Dalkey Island SAC Reefs Yes Secondary discharge at Rush Yes potentially poses a risk to this habitat
Impacts on Annex II Species The only Annex II species under consideration is the Harbour Porpoise in Dalkey to Rockabill Island SAC. Data suggests there is a healthy population of porpoise in the SAC despite the untreated discharges that enter coastal waters. Any eutrophication effects within the mixing/dilution zones of the primary and secondary discharges are not expected to impact the favourable conservation status of this species. The primary discharge comprises treated effluent and so localised eutrophication effects will be minor, while the worst effects of the secondary discharge will be within intertidal/shallow subtidal waters adjacent to the coast which would not be used by this species.
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Table 10.0: Qualifying species potentially impacted by the WwTP discharges
Qualifying Potential Brief Explanation Mitigation Species Impact Required
Rockabill to Dalkey Island SAC Harbour porpoise No Species not considered highly sensitive to indirect No effects from what is likely to be only low levels of nutrient enrichment. Significant effects on the conservation status of harbour porpoise not predicted.
Impacts on designated features of the SPA
The effects of increased nutrients in estuaries and coastal waters can be complex. Eutrophication causing increased phytoplankton growth could increase the amount of food available for bird species, however it can also lead to an increase algal blooms which may interfere with terns/gulls fishing during their breeding season and cause epiphytic algae to blanket seagrass beds. Eutrophication may also result in a depletion of oxygen in the water column and underlying muds leading to a reduction in foraging habitat and food sources for bird species.
In contrast, eutrophication can increase the amount of food available for bird species, and there is evidence to suggest that reduced primary production (measured as chlorophyll a) due to better For inspection purposes only. water quality can lead to a declineConsent in theof copyright density owner and required biomass for any otherof benthic use. invertebrates, and a consequent reduction in the abundance of diving ducks. This has been the case on Lough Neagh where Pochard, Tufted Duck, Scaup and Goldeneye have all declined in numbers over the last 10 years (Burton et al, 2003; Tom nkov , 2013).
In the case of Rogerstown Estuary SPA, given its current Eutrophic status of the estuary, and the poor surface water results at Rush south beach outside of the main estuary, elevated levels of nutrients in the secondary discharge are of concern particularly when considered with other catchment pressures. The secondary discharge may be temporarily contributing to cumulative impacts which have the potential to adversely affect wetland habitats supporting the Special Conservation Interests. Once the discharge ceases at Rush, there will be no potential for the Portrane agglomeration to contribute to adverse effects to the Special Conservation Interests of Rogerstown Estuary SPA.
The potential for adverse effects on the conservation status of SPA Annex I bird species alone or cumulatively with other catchment pressures cannot be ruled out at present, however the scheduled works at Rush will address this risk and no additional mitigation is required.
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Table 11.0: Qualifying Features of SPA Potentially Impacted by WwTP Discharge
Site Qualifying Species Potential Brief Explanation Mitigation Impacts Required
Rogerstown Greylag Goose Yes The potential for indirect effects via Yes Estuary SPA Brent Goose exposure to polluted waters to species Shelduck using sandflats to the south of the Shoveler secondary discharge is considered very Oystercatcher low and temporary.
Ringed Plover There is also the possibility that the Grey Plover secondary discharge may be Knot contributing to cumulative impacts on the Dublin waterbirds and wetlands associated with Black-tailed Godwit the estuary. Redshank Wetlands
Mitigation Measures
A new wastewater treatment plant and sewer network has been constructed to serve the 4 areas under this license. The remaining element of the works will involve a new sewer network in Rush to enable the transfer of the load from Rush to Portrane WwTP and the cessation of the current temporary secondary discharge at Rush. These works are scheduled to commence in 2016 and be completed in 2018. For inspection purposes only. Consent of copyright owner required for any other use. The Portrane plant is currently operating under capacity, and has been designed to accommodate the load from Rush. Final effluent from the primary discharge is expected to continue to comply with the ELV’s set in the license and the relevant Urban Waste Water Treatment standards.
To ensure continued satisfactory operation of the Portrane plant mitigation measures recommended are as follows:
Ensure that the capacity of the WwTP is not exceeded; and Continuation of monitoring of the discharge, including at the outfall, and the ambient background concentrations, on a consistent and regular basis.
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Stage 2 Appropriate Assessment Conclusion Statement The current Appropriate Assessment has been prepared following the EPA (2009) ‘Note on Appropriate Assessments for the purposes of the Waste Water Discharge (Authorisation) Regulations, 2007 (S.I. No. 684 of 2007)’. The Department of the Environment, Heritage and Local Government guidance ‘Appropriate Assessment of Plans and Projects in Ireland. Guidance for Planning Authorities’ (DoEHLG, 2009) has also been taken into account. The current assessment for the Waste Water Discharge Licence Review investigates the potential adverse effects on the aquatic qualifying interests of the Natura 2000 network arising from the plant discharge, in combination with other plans / projects affecting the aquatic environment. The assessment considers whether the discharge, alone or in combination with other projects or plans, will have adverse effects on the integrity of a Natura 2000 site, and includes any mitigation measures necessary to avoid, reduce or offset negative effects.
When the above mitigation measures are implemented in full, it is envisaged that there will be no significant adverse effects on the integrity of Rockabill to Dalkey Island SAC, Rogerstown Estuary SAC or Rogerstown Estuary SPA, in view of these site’s conservation objectives and that the conservation status of the Annex I habitats, Annex II species and protected bird species will not be compromised by WwTP discharge either directly, indirectly or cumulatively.
It is therefore concluded that the Portrane WwTP discharge, alone or in-combination with other plans and / or projects will not give rise to significant effects on the integrity of Rockabill to Dalkey Island SAC, Rogerstown Estuary SAC or Rogerstown Estuary SPA, as long as the mitigation measures as listed above are implemented in full. Stage 2 concludes the Appropriate Assessment process for the Portrane Waste Water Discharge Licence Review.
For inspection purposes only. Consent of copyright owner required for any other use.
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References
Aquilino, K.M; Bracken, M.E.S; Faubel, M.N; and Stachowicz, J.J (2009) Local-scale nutrient regeneration facilitates seaweed growth on wave-exposed rocky shores in an upwelling system. Limnol.Oceanogr., 54(1) 309-317.
Burton, N.H.K., Paipai, E., Armitage, M.J.S., Maskell, J.M., Jones, E.T., Struve, J., Hutchings, C.J. & Rehfisch, M.M. (2003) Effects of reductions in organic and nutrient loading on bird populations in estuaries and coastal waters of England and Wales. Phase 2 Report. English Nature Research Report No 586. December 2003.
Colhoun, K & Cummins, S.(2013) Birds of Conservation Concern in Ireland 2014-2019. Irish Birds 9: 523-544.
ERBD (2010) Eastern River Basin District – River Basin Management Plan 2009-2015.
IFI (2010a) Sampling Fish for the Water Framework Directive. Transitional Waters 2010. Rogerstown Estuary.
IFI (2010b) Sampling Fish for the Water Framework Directive. Transitional Waters 2010. Broadmeadow Water Estuary.
King, J.J; Marnell, F; Kingston, N; Rosell, R; Boylan, P; Caffrey, J.M; Fitzpatrick, U; Gargan, P.G.; Kelly, F.L; O’Grady, M.F; Poole, R; Roche, W.K and Cassidy, D (2011) Ireland Red List No. 5: Amphibians, Reptiles and Freshwater Fish. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht, Dublin, Ireland.
NPWS (2013a) Rockabill to Dalkey Island SAC. Conservation Objectives Supporting Document – For inspection purposes only. Marine habitats and species. VersionConsent of 1. copyright April owner2013. required for any other use.
NPWS (2013b) Rogerstown Estuary SAC. Conservation Objectives Supporting Document – Marine habitats. Version 1 May 2013.
NPWS (2013c) Rogerstown Estuary SAC. Conservation Objectives Supporting Document – Coastal habitats. Version 1 May 2013.
NPWS (2013d) Rogerstown Estuary SPA. Conservation Objectives Supporting Document. Version 1 May 2013.
NPWS (2013e) Conservation Objectives: Rockabill to Dalkey Island SAC 003000. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.
NPWS (2013f) Conservation Objectives: Rogerstown Estuary SAC 000208. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.
NPWS (2013g) Conservation Objectives: Rogerstown Estuary SPA 004015. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.
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OECD (1986) Water pollution by fertilisers and pesticides. Organisation for Economic Cooperation and Development, Paris, 144 pp.
Pettit & Co (2002) Environmental Impact Statement for Portrane/Donabate Waste Water Treatment Scheme. Fingal County Council, July 2002.
Robinson, JA, K Colhoun, GA Gudmundsson, D Boertmann, OJ Merne, M O’Briain, AA Portig, K Mackie & H Boyd. 2004. Light-bellied Brent Goose Branta bernicla hrota (East Canadian High Arctic population) in Canada, Ireland, Iceland, France, Greenland, Scotland, Wales, England, the Channel Islands and Spain 1960/61 – 1999/2000. Waterbird Review Series, The Wildfowl & Wetlands Trust/Joint Nature Conservation Committee, Slimbridge.
Routledge, E.J., D. Sheahan, C. Desbrow, G. Brighty, M. Waldock, and J.P. Sumpter (1998). Identification of estrogenic chemicals in sewage treatment effluent, 2. In vivo responses in trout and roach, Environment, Science and Technology, 32: 1559-65.
SEPA (2013). Water Use - Supporting Guidance (WAT-SG-11) Modelling Coastal and Transitional Discharges. Scottish Environment Protection Agency. Version v3.0. April 2013.
Tom nkov , I. 2013 The causes of diving duck population declines on Lough Neagh, Northern Ireland. phD Thesis. Queens University Belfast.
Worm & Lotze (2006). Effects of eutrophication, grazing, and algal blooms on rocky shores. Limnol. Oceanogr. 51(1, part 2) 569-579.
For inspection purposes only. Consent of copyright owner required for any other use.
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For inspection purposes only. Consent of copyright owner required for any other use.
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