Dixon.Brosnan environmental consultants

Project Natura Impact Statement (NIS) for a proposed sub-surface mains sewer

facility at Spital Cross, , Co. .

Project ref Report no Client ref -

DixonBrosnan 12 Steam Packet House, Railway Street, , Co. Cork Tel 086 851 1437| [email protected] | www.dixonbrosnan.com

Date Rev Status Prepared by 06/11/18 0 Issue to client Carl Dixon MSc. Sorcha Sheehy PhD Ian McDermott MSc.

This report and its contents are For copyright inspection of DixonBrosnan. purposes only. It may not be reproduced without permission. The reportConsent is to beof usedcopyright only for owner its intended required purpose. for any The other report use. is confidential to the client, and is personal and non-assignable. No liability is admitted to third parties.

v180907

EPA Export 01-05-2019:04:23:33 Contents 1. Introduction 1.1 Background 1.2 Aim of this report 2. Regulatory Context and the Appropriate Assessment Procedure 2.1. Regulatory Context 2.2. Appropriate Assessment Procedure 2.3 Description of Proposed Development 3. Potential impact of pipeline construction and outfall 3.1 Potential impacts from loss of habitat. 3.2 Potential impacts from noise and disturbance during construction 3.3 Potential impacts on Water Quality during construction 3.4 Potential impacts from the spread of Invasive Species and Biosecurity Risks 3.5 Potential impacts on water quality during operation 3.6 Potential cumulative Impacts 4. Description of receiving environment 4.1 Natura 2000 sites 4.2 Annex I habitats 4.3 Annex II species 4.3.1 NPWS Winter bird survey 4.3.2 DixonBrosnan Winter bird survey 4.3.2.2 Shelduck (Tadorna tadorna) [A048] For inspection purposes only. 4.3.2.3 Wigeon (Anas PenelopeConsent of copyright) [A050] owner required for any other use.

4.3.2.4 Red-breasted Merganser (Mergus serrator) [A069] 4.3.2.5 Golden Plover (Pluvialis apricaria) [A140] 4.3.2.6 Lapwing (Vanellus vanellus) [A142] 4.3.2.7 Dunlin (Calidris alpina) [A149] 4.3.2.8 Black-tailed Godwit (Limosa limosa) [A156] 4.3.2.9 Bar-tailed Godwit (Limosa lapponica) [A157] 4.3.2.10 Curlew (Numenius arquata) [A160] 4.3.2.11 Black-headed Gull (Chroicocephalus ridibundus) [A179] 4.3.2.12 Common Gull (Larus canus) [A182] 5. Stage 1 Appropriate Assessment Screening 5.1 Identification of Relevant Natura 2000 Sites and Qualifying Interests/Special Conservation Interests 5.2 Screening Assessment

EPA Export 01-05-2019:04:23:33 5.3 Screening statement 6. Stage 2: Appropriate Assessment Natura Impact Statement 6.1 Characteristics of Relevant Site 6.1.1 Courtmacsherry Estuary SAC 6.1.2 Courtmacsherry Bay SPA 6.2 Impact Assessment 6.2.1 Potential impacts on Water Quality during construction 6.2.3 Potential impacts from the spread of Invasive Species and Biosecurity Risks 6.2.4 Potential impacts from noise and disturbance during construction 6.2.5 Potential cumulative Impacts 7. Conclusions

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 01-05-2019:04:23:33 1. Introduction 1.1 Background

The information in this report has been compiled by DixonBrosnan Environmental Consultants, on behalf of the applicant. It provides information on and assesses the potential for the proposed development at Timoleague, Co. Cork to impact on any Natura 2000 sites within its zone of influence. The information in this report forms part of and should be read in conjunction with the planning application documentation being submitted to Cork County Council in connection with the proposed development. The Birds Directive (2009/147/EC) and the Habitats Directive (92/42/EEC) put an obligation on EU Member States to establish the Natura 2000 network of sites of highest biodiversity importance for rare and threatened habitats and species across the EU. In , the Natura 2000 network of European sites comprises Special Areas of Conservation (SACs, including candidate SACs) and Special Protection Areas (SPAs, including proposed SPAs). SACs are selected for the conservation of Annex I habitats (including priority types which are in danger of disappearance) and Annex II species (other than birds). SPAs are selected for the conservation of Annex I birds and other regularly occurring migratory birds and their habitats. The annexed habitats and species for which each site is selected correspond to the qualifying interests of the sites and from these the conservation objectives of the site are derived. The Birds and Habitats Directives set out various procedures and obligations in relation to nature conservation management in Member States in general, and of the Natura 2000 sites and their habitats and species in particular. A key protection mechanism is the requirement to consider the possible nature conservation implications of any plan or project on the Natura 2000 site network before any decision is made to allow that plan or project to proceed. Not only is every new plan or project captured by this requirement but each plan or project, when being considered for approval at any stage, must take into consideration the possible effects it may have in combination For inspection purposes with only. other plans and projects when going Consent of copyright owner required for any other use. through the process known as Appropriate Assessment (AA). The obligation to undertake Appropriate Assessment (AA) derives from Article 6(3) and 6(4) of the Habitats Directive, and both involve a number of steps and tests that need to be applied in sequential order. Article 6(3) is concerned with the strict protection of sites, while Article 6(4) is the procedure for allowing derogation from this strict protection in certain restricted circumstances. As set out in Section 177U of the Planning and Development Act 2000 as amended, a screening for appropriate assessment of an application for consent for the proposed development must be carried out by the competent authority to assess, in view of best scientific knowledge, if the proposed development, individually or in combination with another plan or project is likely to have a significant effect on any European site. Each step in the assessment process precedes and provides a basis for other steps. The results at each step must be documented and recorded carefully so there is full traceability and transparency of the decisions made. The discharge point for the proposed mains sewer will be located in the Courtmacsherry Estuary SAC (site code 001230) and Courtmacsherry Bay SPA (site code 004219). For this reason, it is regarded as necessary that the proposal should

EPA Export 01-05-2019:04:23:33 be subject to the AA process. This document represents Stages 1 and 2 (Screening and Natura Impact Statement) of the Appropriate Assessment process.

1.2 Aim of this report

The purpose of this report is to inform the AA process as required under the Habitats Directive (92/43/EEC) in instances where a plan or project may give rise to significant impacts on a Natura 2000 site. This report aims to inform the Appropriate Assessment process in determining whether the proposed pipeline and discharge, both alone and in combination with other plans or projects, are likely to have a significant impact on the Natura 2000 sites in the study area, in the context of their conservation objectives and specifically on the habitats and species for which the sites have been designated. Documentation/guidelines of relevance to this NIS include the following:

significantly affecting Natura 2000 sites: 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);

the Precautionary Principle., Office for Official Publications of the European Communities, Luxembourg (EC, 2000a);

Directive 92/43/EEC (Draft) Office for Official Publications of the European Communities, Luxembourg (EC, 2015);

Directive 92/43/EEC (EC, 2000)

For inspection purposes only. Consent of copyright owner required for any other use. Clarification of the concepts of: alternative solutions, imperative reasons of overriding public interest, compensatory measures, overall coherence, opinion of the commission; (EC, 2007);

Planning Authorities. Department of the Environment, Heritage and Local Government, Dublin (DEHLG, 2010a);

1/10 and PSSP 2/10 on Appropriate Assessment under Article 6 of the

European Commission (EC, 2013);

as amended (Appropriate Assessment): Guidelines for Local Authorities.

This report provides the relevant ecological information on the proposed project to assist the relevant authorities to determine if an Appropriate Assessment is required

EPA Export 01-05-2019:04:23:33 and ultimately to make a determination in relation to the likely impact on Natura 2000 sites. This report was prepared by Carl Dixon MSc. (Ecological Monitoring), Sorcha Sheehy PhD (Ecology) and Ian McDermott MSc. (Ecological Monitoring). All three including assessments of aquatic impacts.

2. Regulatory Context and the Appropriate Assessment Procedure 2.1 Regulatory 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; 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 SACs and SPAs, and also candidate sites, which form the Natura 2000 network. Article 6(3) of Council Directive 92/43/EEC of 21 May 1992 on the Conservation of Natural Habitats and of Wild Fauna and Flora to the management of a designated 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 For havinginspection purposes determined only. that it will not adversely affect Consent of copyright owner required for any other use. the integrity of the site concerned. generated the need for an appropriate assessment to be carried out by the competent authority for the purposes of Article 6(3). A Stage Two Appropriate Assessment is required if it cannot be excluded, on the basis of objective information, that the proposed development, individually or in combination with other plans or projects, will have a significant effect on a European site. The first (Screening) Stage for appropriate assessment operates merely to determine whether a (Stage Two) Appropriate Assessment must be undertaken on the implications of the plan or project for the conservation objectives of relevant European sites. 2.2 Appropriate Assessment Procedure

The assessment requirements of Article 6(3) establish a stage-by-stage approach. This assessment follows the stages outlined in the 2001 European Commission sites: methodological guidance on the provisions of Articles 6(3) and 6(4) of the

EPA Export 01-05-2019:04:23:33 Publications of the European Communities, Luxembourg (EC, 2015);

The stages are as follows: a Natura 2000 site of a project or plan, either alone or in combination with other projects or plans, and considers whether these impacts are likely to be significant; integrity of the Natura 2000 site of the project or plan, either alone or in combination conservation objectives. Additionally, where there are adverse impacts, an assessment of the potential mitigation of those impacts; Stage Three: Assessment of alternative solutions: The process which examines alternative ways of achieving the objectives of the project or plan that avoid adverse impacts on the integrity of the Natura 2000 site. It is confirmed that no reliance is placed by the developer on Stage Three in the context of this application for development consent;

Stage Four: Assessment where For no inspection alternative purposes only. solutions exist and where adverse Consent of copyright owner required for any other use. an assessment of imperative reasons of overriding public interest (IROPI), it is deemed that the project or plan should proceed (it is important to note that this guidance does not deal with the assessment of imperative reasons of overriding public interest). Again, for the avoidance of doubt, it is confirmed that no reliance is placed by the developer on Stage Four in the context of this application for development consent. It is the responsibility of the competent authority, in this instance Cork County Council, to make a decision on whether or not the proposed development should be approved, taking into consideration any potential impact upon any Natura 2000 site within its zone of influence. 2.3 Description of Proposed Development

The Staunton Foods Ltd. facility occupies a 2.2 ha rectangular plot, with the longer axis running in a north-south direction and is located approximately 1.1 km from Timoleague village. A local primary road (L4021) forms the western boundary of the site. The northern boundary is formed by a local secondary road which meets the

EPA Export 01-05-2019:04:23:33 L4021 at Spital Cross. The eastern boundary is formed by Spital Stream, a large stream which drains much of the Barryroe area, running northwards to meet the estuary at Timoleague. The majority of the site is covered by the main building complex and associated hard-standing areas, including a parking and loading areas, roadways as well as a pig unloading and weighbridge area, A lower zone near the eastern boundary is occupied by several ancillary structures, including the onsite waste water treatment plant (WWTP), utilities building, and fuel and liquid tanks. Historically wastewater arising at the Staunton Foods facility was treated at an onsite WWTP before discharging to the adjacent Spital Stream. The stream meets the Argideen Estuary, at the head of Courtmacsherry Bay, 1000 m northeast of the SF site. Recent planning permission has been granted to construct a new WWTP at number 17162). The new WWTP was commissioned in summer 2018, and is now fully operational. In due course, the existing WWTP will be decommissioned. At present, the new WWTP does not discharge to Spital Stream, and treated wastewater is being trucked offsite as an interim measure. A summary of the new WWTP process is provided in the EIAR and an overview of the newly commissioned WWTP is provided in Appendix 1 of this report. In order to ensure compliance with relevant emission limit values, and to allow for terminate the outfall to Spital Stream, and to instead redirect the treated wastewater to the Argideen Estuary. To this end, it is proposed to installed a sub-surface mains sewer which will connect the new WWTP to the existing Irish Water outfall at Timoleague. The proposed mains will run underneath SF land, third party land and the public road over a total distance of 1550 m. This proposal is subject to permission agreements with the local authority and Irish Water. An application for planning permission will be submitted to Cork County Council in relation to the proposed mains. The sewer will consist of a 150 mm diameter HDPE pipeline. The pipe will be For inspection purposes only. installed with an invert levelConsent of of approximately copyright owner required 800for any other mm use. below the field and road surface. The excavations will be approximately 1m deep and 0.4m wide and construction of the sewer and the connections at each end is expected to take several weeks. The proposed sewer route is show in Figure 1. The sewer route is as follows:

northern boundary of the WWTP zone.

corner of the site.

adjacent field, to the northwest corner of the field.

sewer will be buried underneath the road over a distance of approximately 1080 m to the existing Irish Water manhole at Timoleague. From the manhole, an existing outfall runs to the estuary. The 1550 m length of the sewer may be broken down approximately as follows:

EPA Export 01-05-2019:04:23:33 For inspection purposes only. Consent of copyright owner required for any other use.

Figure 2. Proposed pipeline route N The sewer will consist of a 150 mm diameter HDPE pipeline. The pipe will be installed with an invert level of approximately 750 mm below the field and road surface. Construction of the sewer and its connections is expected to take several weeks. The proposed construction method is as follows:

EPA Export 01-05-2019:04:23:33 using a hand-held circular saw.

wheeled excavator, or by backhoe loader.

line.

an adjacent truck for removal to an approved facility.

backhoe.

backfilled with the stored soil on the field segment, with topsoil placed over subsoil.The finished topsoil will be levelled to be consistent with the surrounding field, and grass seeded with a mix to be agreed with the landowner.

material. This material will be imported from a suitable quarry by truck.

be agreed with the local authority. The trench width required is 400 mm. The working width is 3 m along the road segment, required to allow operation of an excavator or backhoe, with sufficient swing room where necessary to tip excavated spoil. The working width in the field segment will be approximately 8 m to allow for machinery passage and soil temporary storage. For inspection purposes only. Consent of copyright owner required for any other use. With an expected progression rate of 100 m per day, the sewer installation works are expected to last several weeks. The works will be undertaken in stages, and are expected to commence following approval from the local authority, Irish Water and the EPA. A staging area will be provided immediately north of the WWTP plot. The installation contractor has not yet been selected. The contractor will be required to carry out integrity testing of the sewer mains following the completion of all works. An Environmental Management Plan has been prepared and is presented in Appendix 2 of this NIS. It is noted that new WWTP will allow the applicant to better meet the requirements of discharge limits. Wastewater discharge licence limits have been designed to ensure that water quality in the estuary is protected. The construction of the modern plant on a larger site will allow for greater control over the wastewater treatment process. All contaminated water from the facility is directed to the WWTP. The WWTP is managed directly by the full time onsite Environmental Manager. An emergency response procedure has been prepared to provide for plant breakdown or structural failure. The structural integrity of WWTP tanks, channels and sumps has been confirmed by an independent engineering firm.

EPA Export 01-05-2019:04:23:33 The proposed pipeline route from the new plant will be subsequently connected to an existing municipal outfall and the discharge point, which will remain underwater at low water on a spring tide. This site south of Church Bridge has favourable dilutions

WWTP has a daily capacity of 400 m3. This is equivalent to an average flow of 4.6 l/s. The Staunton Foods facility is regulated by the EPA through IED licence P0947-01 which specifies the limits and volumes of treated wastewater applicable to the site. These limits are based on the assimilative capacity for the bay and are designed to minimise impacts on estuarine ecology and designated sites.

3. Potential impact of pipeline construction and outfall

This section of the Screening determines whether Appropriate Assessment is necessary. It does this by: I. Confirming in this instance that the proposed project is not directly connected with or necessary to, the conservation management of any of the European sites; II. Describing the details of the project/plan proposals and other plans or projects that may cumulatively affect any European sites. Potential Impacts that could arise from this project are listed below.

3.1 Potential impacts from loss of habitat.

Any habitat loss of Natura 2000 sites or deterioration in habitat quality would decrease the viability of and increase the pressure on existing habitats and may result in further deterioration. It would also reduce the extent of habitat available for species. For inspection purposes only. Consent of copyright owner required for any other use. The proposed pipeline route will not be located within a designated site and the habitats recorded within the proposed development boundary do not correspond to habitats listed on Annex 1 of the Habitats Directive or qualifying habitats for the Courtmacsherry Estuary SAC. The habitats to be affected are considered of low value at a local level and are relatively common in the surrounding landscape. Full details on the habitats recorded in the proposed development site are available in the Ecology Chapter (11) of the EIAR. No significant loss of habitat within Natura 2000 sites is predicted to occur. No qualifying habitats within the Courtmacsherry Bay SAC or Courtmacsherry Bay SPA will be lost as result of the new pipeline construction.

EPA Export 01-05-2019:04:23:33 3.2 Potential impacts from noise and disturbance during construction

Disturbance of important qualifying bird species could potentially occur during the construction phase of the project although predicting potential impacts on birds from disturbance can be problematic. Although there are many instances where waterfowl and people appear to co-exist on estuaries, there are widespread examples where effects and impacts of varying severity have been described. Optimal foraging theory is a useful basis from which to understand likely effects of disturbance on feeding. Many studies have shown that birds concentrate where feeding is best. If birds are forced temporarily or permanently to leave these places, then there is an increased risk that their foraging ability will suffer. However, the severity of this type of situation and the way is which birds respond, vary in a very complex way (Stillman et al. 2007; Cayford 1993). Burger (1981), in a study of a coastal bay, found that birds were present 42% of the time when people were present, but birds were present 72% of the time when people were absent. It is known that human recreational disturbance can negatively impact upon the foraging ability of wading birds and that this causes a reduction in fitness (Cayford 1993; Goss-Custard et al. 2005). Foraging effort can also be reduced if birds are forced to move from a site of preference. This can occur through birds being forced to feed at higher densities at other sites, this has been found to reduce individual food intake in certain wader species (Goss-Custard, 1980; Cayford, 1993; Smit & Visser, 1993). A reduced fitness can cause serious problems in many chance of mortality through starvation but also it can impede its ability to handle climatic changes, especially those relating to cold and windy weather (Durell et al. 2001). Winter weather impacts upon the energy requirements of wading birds and therefore requires them to feed sufficiently to avoid starvation.

For inspection purposes only. The potential effects and impactsConsent of copyright of disturbance owner required for any have other use. been widely recognised in wildlife conservation legislation, as has the need to develop conservation measures disturbances affecting the birds, in so far as these would be significant having regard to the objectives of this Article concerning Annex I species. Construction stage works have the potential to generate noise and vibrations. Potentially increased noise and disturbance associated with the site works could cause displacement of Annex II wading birds and wildfowl, which are listed as qualifying species for the Courtmacsherry Bay SPA. If of sufficient severity, this could affect the overall numbers of birds which the SPA can support.

EPA Export 01-05-2019:04:23:33 3.3 Potential impacts on Water Quality during construction

Surface water emissions associated with the construction phase of the proposed development could impact on aquatic habitats via increased silt levels in surface water run-off and resuspension of riverbed sediments and inadvertent spillages of hydrocarbons from fuel and hydraulic fluid. Inadvertent spillages of hydrocarbon and/or other chemical substances during construction could introduce toxic chemicals into the aquatic environment via direct means, surface water run-off or groundwater contamination. High levels of silt can impact on fish and invertebrate species. Changes in sediment composition, an increase in turbidity and chemical changes in the water column are the main stress factors to invertebrates after a discharge (Essink 1995). Aquatic plant communities may also be affected by increased siltation. Fish and invertebrate species are an important food source for the qualifying species within the Courtmacsherry Bay SPA. Therefore, surface water emissions have the potential to affect qualifying habitats and species in European sites in the vicinity of the proposed mains sewer. 3.4 Potential impacts from the spread of Invasive Species and Biosecurity Risks

Non-native plants are defined as those plants which have been introduced outside of their native range by humans and their activities, either purposefully or accidentally. Invasive non-native species are so-called as they typically display one or more of the following characteristics or features: (1) prolific reproduction through seed dispersal and/or re-growth from plant fragments; (2) rapid growth patterns; and, (3) resistance to standard weed control methods. Where a non-native species displays invasive qualities, and is not managed it can potentially: (1) out compete native vegetation, affecting plant community structure For inspection purposes only. and habitat for wildlife;Consent (2) causeof copyright owner damage required for to any other infrastructure use. including road carriageways, footpaths, walls and foundations; and, (3) have an adverse effect on landscape quality. There is a statutory obligation under S.I. 477 of 2011 of the European Communities (Birds and Natural Habitats) Regulations 2011 to address invasive species in Ireland. With relation to this particular project the high-risk invasive species Japanese knotweed (Fallopia japonica) is of particular concern. This species is listed under the

Regulations 49 & 50 Prohibition on introduction and dispersal Prohibition on dealing with and keeping certain species a transitional provision in relation to Regulation 49 and 50. The Wildlife (Amendment) Act 2000 states that anyone who plants or otherwise causes to grow in a wild state in any place in the State any species of (exotic) flora, or the flowers, roots, seeds or spores of (exotic) flora shall be guilty of an offence. The proposed development lies within Ordnance Survey National Grid 10km square W44. The National Parks and Wildlife Service (NPWS) notes a number of both

EPA Export 01-05-2019:04:23:33 aquatic and terrestrial high impact invasive species which have been recorded within grid square W44 (Table 1). The non-native invasive species Japanese Knotweed (Fallopia japonica) was

WWTP). Whilst noted to be occurring outside the scope of the proposed pipeline treatment and within front garden of cottage at junction of the L4021 with the Spital road) there may be the risk of contaminating the site from inadvertent contact with the plants from passing construction machinery gaining access to the site. Japanese initiative by the Northern Ireland Environment Agency and NPWS. Japanese Knotweed is also included in the NRA Guidelines on the Management of Noxious Weeds and Non-native Species on National Roads (NRA, 2010) as this species has been shown to have an adverse impact on landscape quality, native biodiversity or infrastructure; and is likely to be encountered during road schemes.

Table 1: NBDC list of high impact invasive species.

Common Name Latin Name

Japanese Knotweed Fallopia japonica

Rhododendron Rhododendron ponticum

Hybrid Knotweed Fallopia japonica x sachalinensis = F. x bohemica

Canadian Waterweed Elodea canadensis

Common Cord-grass Spartina anglica

American Mink Mustela vison

Canada Goose Branta canadensis

For inspection purposes only. Consent of copyright owner required for any other use. Japanese knotweed is a highly invasive, non-native species which was originally introduced as an ornamental plant but has since spread along transport routes and rivers to become a serious problem. From an ecological viewpoint, it out-competes native species by forming dense stands which suppresses growth of other species. It grows extremely vigorously and can penetrate through small faults in tarmac and concrete and thus can damage footpaths, roads and flood defence structures. As it can survive in poor quality soils, including spoil, it often thrives in brownfield sites and in urban areas. There is potential during the construction phase of the proposed works for invasive species to be spread within Courtmacsherry Bay SAC and SPA, and negatively impact native species or habitats causing a decline or loss; or species that could impact either/both Natura 2000 sites.

EPA Export 01-05-2019:04:23:33 3.5 Potential impacts on water quality during operation

The proposed new mains sewer will carry treated wastewater from the existing time. Wastewater discharge licence limits have been designed to ensure that water quality in the estuary is protected. This provision of a modern plant on a larger site will allow for greater control over the wastewater treatment process. All contaminated water from the facility will be directed to the WWTP. The WWTP will be managed directly by the full time onsite Environmental Manager. An emergency response procedure will be prepared to provide for plant breakdown or structural failure. The site comprises of an activity in relation to which an Industrial Emission Directive Licence (formerly IPPC Licence) has been granted (Licence P0947-01). Accordingly, all details relating to emissions and operating conditions thereto are a matter for the EPA. While there will be no changes in the level of discharge, the discharge location is moving to a site within the Courtmacsherry Bay SAC/SPA. Therefore, the impacts of this need to be assessed. 3.6 Potential cumulative Impacts

Cumulative impacts refer to a series of individual impacts that may, in combination, produce a significant impact. The underlying intention of this in combination provision is to take account of cumulative impacts from existing or proposed plans and projects and these will often only occur over time. Pressures identified for the Courtmacsherry Estuary SAC and Courtmacsherry Bay SPA (NPWS,) include agricultural, nautical sports and other outdoor leisure activities and disposal of human waste. Agriculture remains the dominant land use and intensive agriculture in particular can have significant impacts on aquatic ecology by increasing nutrients and sediment loads. Wastewater is also discharged from other settlements (Timoleague and Courtmacsherry) For and inspection local purposes industry. only. Consent of copyright owner required for any other use. Changes to the wastewater treatment system for Timoleague, which will result in treated waste being discharged at Courtmacsherry, will reduce the net volume of nutrients reaching the inner bay. Whilst this may have a net positive impact on local prey availability. The populations dynamics of feeding birds within the estuary are positive impact on bird populations by contributing nutrients which increase prey availability in estuarine muds. his positive benefit may become more pronounced as inputs of nutrients from Timoleague and agricultural sources are further reduced in the future. It is noted that levels of sea lettuce within the bay have significantly declined in recent years (Ian McDermott Pers. Obs). This may have consequences for foraging waders if reductions in organic nutrients entering the site as a result of improvements to the WWTP (aimed at meeting objectives of the Urban Waste Water Treatment Regulations (e.g. S. I. 48 of 2010) and the Water Framework Directive (2000/20/EC as transposed by the European Communities) (Water Policy) (Amendment) Regulations, 2010)) leads to reductions in the macroinvertebrate prey base.

EPA Export 01-05-2019:04:23:33 4. Description of receiving environment 4.1 Natura 2000 sites

In accordance with the European Commission Methodological Guidance (EC2001), a list of Natura 2000 Sites that can be potentially affected by the proposed project radius of the proposed development have been identified at Table 2. It is noted that use of a 15km radius is a precautionary measure, as impacts at this distance from the proposed development are highly unlikely in the absence of significant aqueous emissions. The Courtmacsherry Estuary SAC (site code 001230) and Courtmacsherry Bay SPA (Site code 004219) overlap adjacent to the site of the new pipeline and the proposed sewer outfall of the new WWTP discharges directly into these designated areas, as shown in Figure 3. Full site synopses for these Natura 2000 sites are included below.

Table 2. European sites within 15km. Site Code Distance at closest point SAC Courtmacsherry Estuary SAC 001230 Outfall discharges into designated site Bay SAC 000091 5.9km SW SPA Courtmacsherry Bay SPA 004219 Outfall discharges into designated site Seven heads SPA 004191 4.7km S Clonakilty Bay SPA 004081 5.9km SW Galley Head to Duneen Point 004190 9.3km SSW

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 01-05-2019:04:23:33 Figure 3. Location of Natura 2000 sites within 15km of proposed development site. Inset proposed mains sewer route (in yellow)

For inspection purposes only. 4.2 Annex I habitats Consent of copyright owner required for any other use. A site inspection was carried out on the 30th of August 2017 and July 2018. Further details this ecological assessment is provided in Chapter 11 of the EIAR. The terrestrial and aquatic habitats within or adjacent to the proposed development site were classified using the classification scheme outlined in the Heritage council publication A Guide to Habitats in Ireland (Fossitt, 2000) and cross referenced with Annex 1 Habitats where required. No rare species were noted, nor are they expected to occur given that the habitats within the study area are common. The survey results are representative of the habitats within the application site and include the dominant and characteristic species of flora. None of the habitats recorded along the proposed development site, correspond to qualifying habitats for the Courtmacsherry Estuary SAC. Therefore, there will be no direct impacts on qualifying habitats within Courtmacsherry Bay SAC. 4.3 Annex II species 4.3.1 NPWS Winter bird survey

The 2010/11 waterbird survey programme was designed to investigate how waterbirds are distributed across coastal wetland sites during the low tide period.

EPA Export 01-05-2019:04:23:33 The surveys ran alongside and are complementary to the Irish Wetland Bird Survey (I-WeBS) which is a nationwide survey undertaken primarily on a rising tide or at high tide. At Courtmacsherry Bay, a standard survey programme of four low tide counts (October, November and December 2010 and February 2011) and one high tide counts (January 2011) were undertaken. Waterbirds were counted within a series of 17 count subsites. It should be noted that the count subsite boundaries and SPA boundaries are not coincident. A total of 48 waterbird species were recorded during the 2010/11 survey programme at Courtmacsherry Bay. The average proportion of subsites in which a species occurred during low tide counts, ranged from 65% (Black-headed Gull) to just 6% (Golden Plover). Only three species (Black-headed Gull, Curlew and Black-tailed Godwit) were distributed across more than half of the count subsites.

Friary (0L446). The current WWTP outfall discharges into subsite Creggane (0L445) while it is proposed the that new discharge point will be into the Friary (0L446) subsite. During low tide surveys, eight subsites supported, on average ten or more species. Average subsite species richness ranged from 1 to 19 species. The average species richness recorded for both relevant subsites can be seen below in Table 3. Table 3: Average species richness for the Creggane and Friary Subsites. Subsite Code Subsite Name HT Survey Peak Overall LT Survey (H/L) 0L445 Creggane 7(6) 12 13(L) 0L446 Friary 14(4) 8 18(L)

As can be seen from the survey results, the proposed outfall site (Friary) contains, on average a higher number of species during the low tide cycle. This combined with the approximate size of each subsite, Creggane 20ha and the Friary 17ha means For inspection purposes only. that the Friary on averageConsent contains of copyright a owner greater required for numberany other use. of species per hectare. Average percentage area occupancy is defined as the average proportion of the whole site area that a species occurred in during low tide counts. Although this is a broad calculation across all habitat zones it presents some indication of the range of a species across the site as a whole. In line with the very low use of subsites, the Golden Plover was only recorded from 10% of the survey area. Most widespread was the Black-headed Gull and this was the only species to distribute across more than half of the survey area. Nine SCI species, on average, were recorded from less than 40% of the survey area. Whole site species richness (total number of species) ranged between 28 species to 37 species during low tide surveys and 36 species were recorded during the high tide survey. The location north of Timoleague Bridge, within the Friary subsite, is known to be the most important area for birds in the estuary as it is the most extensive high tide roost for winter waders (Natura, 2005). Of the species listed as special conservation interests for the Courtmacsherry Bay SPA, 10 were recorded in the estuary in the vicinity of the proposed pipeline route, namely; Curlew, Lapwing, Black-tailed Godwit, Bar-tailed Godwit, Dunlin, Black-headed Gull, Common Gull, Golden Plover, Red-breasted Merganser and Wigeon.

EPA Export 01-05-2019:04:23:33 4.3.2 DixonBrosnan Winter bird survey

A winter bird survey was undertaken by DixonBrosnan Environmental Consultants on three separate occasions; 28th of November and the 5th & 22nd of December 2017. The survey methodology was based on that used by the British Trust for Ornithology (BTO), Wetland Bird Survey (WeBS) and also that for the Irish Wetland Bird Survey (I-WeBS), as outlined in Gilbert et al. (1998). Where possible the survey covered a radius of approximately 300m from the proposed construction site, with particular emphasis on areas designated under European legislation i.e. Courtmacsherry Bay SPA. A radius of 300m was used based on information gathered by Borgmann (2011), stating that establishing set-back distances of 250m from waterfowl, diving ducks, wading birds, and shorebirds may lessen the impacts to the most sensitive species. In addition, in most instances, a visual stimulus will create a disturbance effect before any associated noise starts to have an effect e.g. a flight response might be expected by many species if approached to within c. 100- 150m across a mudflat (Cutts et. al. 2013). A map of the survey area as well as the vantage point locations for the winter bird counts are shown in Figure 4. The results of this survey are outline in Table 4.

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 01-05-2019:04:23:33 Figure 4: Vantage point locations for the winter bird counts in relation to the proposed pipeline route.

Table 4. Species recorded during the 2017 winter bird surveys and abundance

Survey Site 1 Survey Site 2 Survey Site 3

Species surveys surveys surveys surveys

Black-headed Gull 238 176 28 0

Common Gull 36 59 3 0

Lesser Black-backed Gull 45 326 3 0

Herring Gull 7 7 3 0

Great Black-backed Gull 4 7 1 0

Grey Heron 3 5 1 0

Little Egret 1 3 2 0

Cormorant 9 5 1 0

Shag 1 0 0 0

Mute Swan 0 2 2 2

Curlew 23 47 66 14

Oystercatcher 9 14 7 0

Black-tailed Godwit 92 90 38 0

Bar-tailed Godwit 16 4 1 0

Lapwing 36 43 198 0

Greenshank 0 0 0 1

Redshank19 For inspection purposes 32 only. 14 7 Consent of copyright owner required for any other use. Snipe 9 0 3 3

Dunlin 2 14 23 0

Wigeon 23 35 76 12

Teal 0 4 0 0

Mallard 0 1 5 35

Golden Plover 0 0 8 0

Ruff 0 0 1 0

Common Sandpiper 0 1 0 0

Notes

Increased numbers during high tide surveys over low tide surveys, with particular reference to Survey Site 1, maybe due to areas of exposed mudflat remaining thus attracting birds from other sections of the Estuary as tide levels rise. This is in particular regard to waders.

During all site visits the water levels recorded within Survey Site 2 were low resembling that of low tide events, even during periods of high tide further out in the estuary. Thus, no results are available for high water levels/tide.

EPA Export 01-05-2019:04:23:33 Two surveys were conducted at Survey Site 3, both during low tide events. Of all three sites, Survey Site 3 is the least ecologically important with regards to wintering waterbirds due to the limited availability of mudflat habitat within the site.

4.3.2.1 Northern Diver (Gavia immer) [A003] Great Northern Divers are primarily fish-eaters, although a variety of other prey items can be taken including molluscs and crustaceans. They tend, therefore to forage in deeper waters of between 4-10m when foraging (BWPi, 2004). NPWS records show Great Northern Divers prefer to forage in the deeper waters of the SPA, near Courtmacsherry Harbour and Broadstrand. Roosting sites are located nearby within the same SPA subsites. Great Northern Divers were not recorded during DixonBrosnan 2017 winter bird surveys carried out as part of the EIAR for the proposed development. Construction works could potentially disturb waterbirds foraging in the intertidal areas adjacent to the site works. However, as Great Northern Diver forage several kilometres away, there is unlikely to be any impact, either direct or indirect on this species, as a result of the proposed development. 4.3.2.2 Shelduck (Tadorna tadorna) [A048] The Shelduck has five known populations which breed across temperate Eurasia. The northwest Europe population breeds and winters along coasts of Britain, Ireland, Scandinavia, the Baltic and continental Europe. Although a breeding species in Ireland, Shelducks undertake a moult migration each autumn. Winter bird surveys carried out during November and December 2017, found no records of Shelduck on or near the proposed development site. NPWS data from 2010 and 2011 found that Shelduck have a localised distribution with high site fidelity. This data also showed that they were found in the intertidal habitats at the centre of the SPA and not near the proposed development site. Therefore, due to the foraging preferences of Shelduck there is unlikely to be any impact either direct or For inspection purposes only. indirect on this species as aConsent result of ofcopyright the owner proposed required for works.any other use.

4.3.2.3 Wigeon (Anas Penelope) [A050] Wigeon have a widespread breeding distribution across northern Europe and Asia, from Iceland and northern Britain across Scandinavia, and northern Russia to the Bering Sea coast (Wernham et al. 2002). The species is highly migratory. Five main wintering groups are known; birds breeding in northwest and northeast Europe and west Siberia spend winter in northwest Europe. The Wigeon diet is almost entirely vegetarian and a major part of the diet comprises seagrass and algae species which are taken by grazing or dabbling in shallow water. Wigeon also forage within grasslands and agricultural crops for seeds, stems and rhizomes. A gregarious bird, they are rarely seen far from water. DixonBrosan 2017 winter surveys recorded Wigeon both foraging and roosting within sections of the estuary in proximity to the proposed mains sewer route and outfall location. NPWS (2014) surveys also recorded Wigeon foraging in the Creggane subsite. Therefore, disturbance during the construction phase as well as potential impacts on feeding grounds at the proposed new outfall location could impact on Wigeon within Courtmacsherry Bay SPA.

EPA Export 01-05-2019:04:23:33 4.3.2.4 Red-breasted Merganser (Mergus serrator) [A069] Red-breasted Mergansers have a wide breeding range which spans northern Europe, Russia, Siberia and North America. The Irish breeding population is thought to be sedentary. Large flocks of moulting birds congregate at several sites in Ireland and numbers remain relatively stable throughout the wintering season apart from some peaks possibly reflecting passage populations or cold weather movements (Crowe, 2005). Red-breasted Mergansers are sea ducks that feed on fish, obtained

(BWPi, 2004). All records of Red-breasted Mergansers were of foraging individuals. Six subsites were used overall within the Courtmacsherry Bay SPA, including the Friary subsite where the proposed outfall site is located. Therefore, disturbance during the construction phase as well as potential impacts on feeding grounds at the proposed new outfall location could impact on Red-Breasted Merganser within Courtmacsherry Bay SPA. 4.3.2.5 Golden Plover (Pluvialis apricaria) [A140] The Eurasian Golden Plover is a Palearctic species, occurring mainly at higher latitudes of Western Europe to north-central Siberia and wintering south in Europe, north Africa and parts of Asia. During winter, Golden Plovers feed primarily within agricultural grassland and arable land. Tidal flats are used more as a roosting/resting habitat and the birds tend to favour large, open tidal flats. As a consequence, Golden Plovers tend to be in large aggregations when observed upon tidal flats. Intertidal feeding is observed to a greater degree during cold weather periods when grassland feeding areas are frozen over. Although Golden Plovers eat a wide range of invertebrate species, relatively little is known about their intertidal feeding patterns (Gillings et al. 2006). During the NPWS survey (2010), Golden Plover were present in two low tide surveys, but neither count exceeded the threshold for all-Ireland importance. The absence of the species in later surveys may be attributed to the cold weather spell For inspection purposes only. experienced in December 2010.Consent of Fifty-eight copyright owner individualsrequired for any other were use. recorded roosting within the Friary subsite during November 2010 (NPWS 2014). Therefore disturbance during the construction phase as well as potential impacts on feeding grounds at the proposed new outfall location could impact on Golden Plover within Courtmacsherry Bay SPA. 4.3.2.6 Lapwing (Vanellus vanellus) [A142] The Lapwing is a monotypic species and has a wide Palearctic breeding distribution from Britain and Ireland in the west to Eastern and southern Siberia in the east with a southern limit extending into Spain (Delaney et al. 2009). Birds breeding in Britain and Ireland are partial migrants with some residing over winter and some migrating south. The wintering population is enhanced by Lapwings moving in from continental Europe and northern and western Britain (Wernham et al. 2002). Cold weather

across a wide variety of habitats, principally using lowland farmland and freshwater wetlands (e.g. turloughs and callows) but also coastal wetlands where they feed on a variety of soil and surface living invertebrates. They are opportunistic and mobile birds and will readily exploit temporary food sources such as newly-ploughed fields.

EPA Export 01-05-2019:04:23:33 Estuaries are typically used as roosting areas where large flocks may be observed roosting upon the tidal flats but coastal areas will also be used to a greater degree during cold weather events when farmland and freshwater habitats freeze over. DixonBrosnan 2017 winter bird surveys recorded Lapwing roosting and foraging estuarine areas adjacent to the proposed mains sewer route. NPWS (2014) surveys also found peak numbers of Lapwing within the Creggane and Friary subsites. Therefore disturbance during the construction phase as well as potential impacts on feeding grounds at the proposed new outfall location could impact on Lapwing within Courtmacsherry Bay SPA. 4.3.2.7 Dunlin (Calidris alpina) [A149] The Dunlin is a Holarctic and highly migratory wader, breeding widely in Arctic zones across Europe, Asia and North America. The majority of Dunlin wintering in Ireland are C. a. alpina that originate from the western part of their breeding range and moult mainly in the Wadden Sea before starting to arrive in Ireland during October (Crowe, 2005). The Dunlin diet is relatively wide and although this versatile species often shows a preference for muddier areas within sites (Hill et al. 1993; Santos et al. 2005), their distribution can often be widespread with no clear patterns. DixonBrosnan winter bird surveys recorded Dunlin both foraging and roosting in close proximity to the proposed sewer route. Dunlin were recorded foraging within both the Creggane and Friary subsites, with a peak intertidal foraging density of 7 Dunlin ha-1recorded for Creggane (NPWS 2014). During NPWS high-tide surveys, 135 individuals roosted intertidally across three subsites with the majority (89%) in Friary. During the February roost survey, Creggane held a flock of 11 Dunlin roosting supratidally on saltmarsh. (NPWS 2014). Therefore, disturbance during the construction phase as well as potential impacts on feeding grounds at the proposed new outfall location could impact on Dunlin within Courtmacsherry Bay SPA. 4.3.2.8 Black-tailed Godwit (Limosa limosa) [A156] Black-tailed Godwits have a widespread Palearctic breeding distribution. Black-tailed Godwits are relatively large long-billed For inspection wading purposes birdsonly. that forage within intertidal flats Consent of copyright owner required for any other use. for their preferred prey of bivalves such as Macoma balthica, Scrobicularia plana and Mya arenaria. At some sites, polychaete worms form a larger proportion of the diet and the species is relatively adaptable, utilising other habitats for foraging where available, such as terrestrial grassland, coastal marshes or freshwater callows. Black-tailed Godwit was recorded within both Creggane and Friary subsites in proximity to the proposed development site (NPWS 2014). Low tide surveys carried out at Courtmacsherry Bay in the winter 2011/12 (surveys by NPWS Regional Staff) recorded peak numbers of foraging Black-tailed Godwits in the Creggane subsite. Surveys the following winter (2012/13) recorded peak numbers in Friary subsite. DixonBrosan winter surveys recorded Black-tailed Godwit in surveys sites 1 and 2. Moderate numbers of Black-tailed Godwits were recorded roosting intertidally during low tide surveys across Courtmacsherry Bay with Creggane and the Friary holding joint peak numbers on 10/10/10 of 114 individuals. During the November roost survey, the NPWS recorded roosting Black-tailed Godwits in three subsites, with the largest single roost of 208 individuals being recorded in Friary at just over an hour before high water, with the birds positioned intertidally along the bend in the river channel. Low tide surveys carried out at Courtmacsherry Bay in the winter 2011/12 (surveys by NPWS Regional Staff) recorded peak numbers of roosting Black-tailed

EPA Export 01-05-2019:04:23:33 Godwits in the Friary subsite. Therefore, disturbance during the construction phase as well as potential impacts on feeding grounds at the proposed new outfall location could impact on Black-tailed Godwit within Courtmacsherry Bay SPA. 4.3.2.9 Bar-tailed Godwit (Limosa lapponica) [A157] The Bar-tailed Godwit has a widespread breeding distribution across the sub-arctic and low Arctic zones of the Palearctic and extending into western Alaska (Delaney et al. 2009). The nominate subspecies L. l. lapponica breeds in northern Fennoscandia and Northern European Russia, east to the Kanin Peninsula, and winters mainly in Western Europe, including Ireland. Bar-tailed godwits are a wader species considered characteristic of coastal wetland sites dominated by sand. The birds forage by probing within intertidal sediment for invertebrate species, predominantly large polychaete worms such as Arenicola marina and Nepthys sp. The species is characteristic of sites with sandy substrates (Hill et al. 1993). Bar-tailed Godwits were recorded both foraging and roosting in close proximity to the proposed pipeline route. During low tide surveys carried out at Courtmacsherry Bay in the winter 2011/12 (surveys by NPWS Regional Staff) recorded peak numbers of foraging Bar-tailed Godwits in three subsites including the Creggane subsite. Surveys the following winter (2012/13) recorded peak numbers in the Friary subsite along with two other subsites not in proximity to the proposed development site. During DixonBrosnan 2017 winter bird surveys, Bar-tailed Godwits were recorded during both high- and low-tide and at survey site 1 and site 2. Therefore, disturbance during the construction phase as well as potential impacts on feeding grounds at the proposed new outfall location could impact on Black-tailed Godwit within Courtmacsherry Bay SPA. 4.3.2.10 Curlew (Numenius arquata) [A160] The Curlew has a widespread breeding range across temperate latitudes of the Palearctic region, occurring across Europe and Asia from Ireland in the west to northern China in the east (Delaney et al. 2009). The nominate subspecies breeds across Europe and winters in Europe. Ireland supports a small and declining For inspection purposes only. population of breeding Curlew.Consent Irish of copyright breeding owner required Curlew for any other are use. thought to make only short migrations and be mainly resident during winter. Wintering numbers are enhanced by birds moving in from breeding grounds in Fennoscandia, the Baltic and northwest Russia (Delaney et al. 2009) and Britain (Wernham et al. 2002). Curlews are the largest intertidal wader to spend the non-breeding season within Ireland. Within intertidal areas they seek out larger prey items such as crabs, large worms and bivalves. Their de-curved bill is ideally suited to extracting deep-living worms such as Lugworms (Arenicola marina). Curlews are also known to heavily utilise agricultural grassland as foraging sites especially during periods of high tide. Curlews rely on large prey that takes more time to handle in contrast to many other wader species that swallow prey relatively quickly upon finding it. As a consequence, Curlews are territorial foragers and tend to occur widely spaced from each other to avoid competitive conflicts. Curlew are usually well dispersed across the estuary while feeding, but generally roost communally, usually along salt marshes and sand banks. During the February roost survey, the largest flock (75 Curlews) was recorded in the Creggane subsite, these birds were noted roosting on saltmarsh just upstream of Timoleague Bridge (NPWS 2014). Curlews were also recorded during DixonBrosnan 2017 winter bird surveys. They were present in both high- and low- tide surveys at all three survey sites. Therefore, disturbance during the construction

EPA Export 01-05-2019:04:23:33 phase as well as potential impacts on feeding grounds at the proposed new outfall location could impact on Curlew within Courtmacsherry Bay SPA. 4.3.2.11 Black-headed Gull (Chroicocephalus ridibundus) [A179] Black-headed Gulls breed widely throughout the middle latitudes of the Palearctic and in north-eastern North America (Mitchell et al. 2004). It is the most widespread breeding seabird within Ireland, breeding both inland and on the coast. Winter numbers are boosted by birds arriving from northern and eastern Europe (Wernham et al. 2004). There is some evidence that gulls from Iceland also move into Ireland for the winter (BWPi, 2004). Black-headed Gulls were recorded terrestrial roosting in close proximity to the proposed development site. The Friary also held peak numbers on two separate surveys, with numbers during the high tide survey ranked as second highest. Creggane held peak numbers on 10/10/10 during a low tide survey and good numbers (ranked in top three) in three other surveys (NPWS 2014). Black-headed gulls were also recorded during DixonBrosnan winter bird surveys. The species was present during high- and low-tide counts in survey site 1 and survey site 2, with peak low tide numbers of 238 individuals. Therefore, disturbance during the construction phase as well as potential impacts on feeding grounds at the proposed new outfall location could impact on Black-headed Gull within Courtmacsherry Bay SPA. 4.3.2.12 Common Gull (Larus canus) [A182] The Common Gull breeds widely across the Palearctic and in North America (Mitchell et al. 2004). In Ireland, the species is most widely seen during winter when wintering birds arrive from Scotland and continental Europe (Wernham et al. 2004). Common Gull were noted to be wide spread across Courtmacsherry Bay. The Friary held peak numbers of roosting birds twice and numbers ranked as second highest on another low tide survey occasion. Just four individuals were recorded roosting intertidally during the high tide survey and they were within the Creggane subsite (NPWS 2014). DixonBrosnan winter bird counts recorded Common Gull in survey site 1 and survey site 2. For inspection purposes only. Consent of copyright owner required for any other use. Therefore, disturbance during the construction phase as well as potential impacts on feeding grounds at the proposed new outfall location could impact on Common Gull within Courtmacsherry Bay SPA. 4.3.2.13 Wetlands and waterbirds The wetlands of northwest Europe are a vital resource for millions of northern and boreal nesting waterbird species that overwinter on these wetlands or visit them when migrating further south. To acknowledge the importance of Ireland's wetlands to wintering waterbirds the term Wetland & Waterbirds can be included as a Special Conservation Interest for a Special Protection Area that has been designated for wintering waterbirds, and is or contains a wetland site of significant importance to one or more of the species of Special Conservation Interest. 4.4 Water quality The South Western River Basin District (WRBD) River Basin Management Plan

(2000/60/EEC) for the south-west coast of Ireland and covers Courtmacsherry Bay and its inflowing rivers and streams. The current water quality status of

EPA Export 01-05-2019:04:23:33 Transitional and Coastal Waters Action Programme (SWRBD,2010); this sub- standard status linked to below standard recorded levels of dissolved oxygen and fish in the estuary, and for the extensive growth of macroalgae. The pressures upon the system are listed as point source pollutants (WWTP), combined sewer overflows and treatment plant overflows. The Environmental Protection Agency (EPA) monitors the status of estuarine and coastal water bodies using their Trophic Status Assessment Scheme (TSAS), a requirement under the Urban Waste Water Treatment Directive (UWWT) (91/271/EEC)20 and Nitrates Directive (91/676/EEC). Following assessment, waterbodies are classified as eutrophic, potentially eutrophic, intermediate, or et al. 2010). Results for the period 2007-2009 reveal that the et al. 2010). In addition to nutrient enrichment, other pressures such as hazardous substances and morphological alterations can impact on the quality of aquatic systems. Biological indicators are used to assess the ecological status of transitional and coastal waters. Classification schemes have been developed that use the characteristics of different biological communities, together with information on the physico-chemical environment to define ecological status. Ecological status for the period 2007-2009 et al. 2010). Therefore any deterioration in water quality as a result of the proposed development, may impact negatively on Wetland and Waterbirds within Courtmacsherry Bay SPA.

5. Stage 1 Appropriate Assessment Screening 5.1 Identification of Relevant Natura 2000 Sites and Qualifying Interests/Special Conservation Interests

Adopting a precautionary principle, the Natura 2000 sites within 15km of the works were included in this assessment. All are listed in Table 5 and can be seen in Figure 3. Of these, the Natura 2000 sites deemed relevant and screened in for Appropriate Assessment are those which have For Conservationsinspection purposes only. Objectives or Qualifying Interests Consent of copyright owner required for any other use. (QIs)/Special Conservation Interests (SCIs) which may be impacted by the proposed works. The potential impacts are discussed in detail in Section 3 of this report. Those sites or individual qualifying interests that are screened out for Appropriate Assessment and require no further assessment at this stage (primarily as a result of being too great a distance away from the site and having different habitat requirements) are not assessed further. Sites/QIs/SCIs that are screened in for further assessment are highlighted in Table 5.

EPA Export 01-05-2019:04:23:33 Table 5. Identification of relevant Natura 2000 sites. All those screened in for AA are highlighted (in bold).

Natura 2000 site Qualifying Interest Distance Potential impacts Screened from In/Out proposed pipeline route (approx.) Courtmacsherry 0.1km -Surface water emissions during Screened In Bay SAC For inspection purposes only.construction phase may impact on habitat Consent of copyright owner required for any other use. Site Code quality 001230 -Spread of invasive species may affect Estuaries [1130] habitat -quality 0.1km -Surface water emissions during Screened In construction phase may impact on habitat quality Mudflats and sandflats not covered by -Spread of invasive species may affect seawater at low tide [1140] habitat quality Annual vegetation of drift lines [1210] 6.5km No pathway for interaction due to distance Screened Out Perennial vegetation of stony banks [1220] 5.0km No pathway for interaction due to distance Screened Out Salicornia and other annuals colonizing mud and 6.3km No pathway for interaction due to distance Screened Out sand [1310] 6.2km -Surface water emissions during Screened In (potential construction phase may impact on habitat 0.1km) quality Atlantic salt meadows (Glauco- -Spread of invasive species may affect Puccinellietalia maritimae) [1330] habitat quality 6.0km No pathway for interaction due to distance Screened Out Mediterranean salt meadows (Juncetalia (potential maritimi) [1410] 1.7km) Embryonic shifting dunes [2110] 6.0km No pathway for interaction due to distance Screened Out

EPA Export 01-05-2019:04:23:33 Shifting dunes along the shoreline with 6.0km No pathway for interaction due to distance Screened Out Ammophila arenaria (white dunes) [2120] Fixed coastal dunes with herbaceous vegetation 5.9km No pathway for interaction due to distance Screened Out (grey dunes) [2130] Courtmacsherry Great Northern Diver (Gavia immer) [A003] - Noise during the construction phase may Screened Out Bay SPA Shelduck (Tadorna tadorna) [A048] disturb foraging during the winter period Screened Out Site Code Wigeon (Anas penelope) [A050] -Impacts on estuarine habitats in the SAC Screened In 004219 Red-breasted Merganser (Mergus serrator) would similarly be impact of species within Screened In [A069] the SPA Golden Plover (Pluvialis apricaria) [A140] through a temporary loss of and reduced Screened In Lapwing (Vanellus vanellus) [A142] quality these habitats for roosting and Screened In Dunlin (Calidris alpina) [A149] feeding. Screened In Black-tailed Godwit (Limosa limosa) [A156] -A nett reduction in the nutrients entering the Screened In Bar-tailed Godwit (Limosa lapponica) [A157] bay, may impact on the population dynamics For inspection purposes only. Screened In Curlew (Numenius arquata) [A160] Consent of copyright owner required for anyof otherbird use.species Screened In

Black-headed Gull (Chroicocephalus Screened In ridibundus) [A179] Common Gull (Larus canus) [A182] Screened In Wetland and Waterbirds [A999] Screened In Clonakilty Bay Mudflats and sandflats not covered by seawater c. 5.9km No pathway for interaction due to distance Screened Out SAC at low tide [1140] Site code 00091 Annual vegetation of drift lines [1210] No pathway for interaction due to distance Embryonic shifting dunes [2110] No pathway for interaction due to distance Shifting dunes along the shoreline with No pathway for interaction due to distance Ammophila arenaria (white dunes) [2120] Fixed coastal dunes with herbaceous vegetation No pathway for interaction due to distance (grey dunes) [2130] Atlantic decalcified fixed dunes (Calluno- No pathway for interaction due to distance Ulicetea) [2150] Mudflats and sandflats not covered by seawater No pathway for interaction due to distance at low tide [1140] Clonakilty Bay Shelduck (Tadorna tadorna) [A048] c. 5.9km No pathway for interaction due to distance Screened Out SPA Dunlin (Calidris alpina) [A149] No pathway for interaction due to distance Screened Out Site code Black-tailed Godwit (Limosa limosa) [A156] No pathway for interaction due to distance Screened Out 004081 Curlew (Numenius arquata) [A160] No pathway for interaction due to distance Screened Out Wetland and Waterbirds [A999] No pathway for interaction due to distance Screened Out

EPA Export 01-05-2019:04:23:33 Shelduck (Tadorna tadorna) [A048] No pathway for interaction due to distance Screened Out Seven Heads c. 4.7km No pathway for interaction due to distance Screened Out Bay SPA Site Code 004191 Chough (Pyrrhocorax pyrrhocorax) [A346] Galley Head to c. 9.3km No pathway for interaction due to distance Screened Out Duneen Point SPA Site Code 004190 Chough (Pyrrhocorax pyrrhocorax) [A346]

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 01-05-2019:04:23:33 5.2 Screening Assessment

After an initial review of all Natura 2000 sites within 15km of the proposed survey no pathway could impact upon on the following Natura 2000 sites: Clonakilty Bay SAC (site code 000091) Clonakilty Bay SPA (site code 004081) Seven Heads Bay SPA (site code 004191) Galley Head to Duneen Point SPA (site code 004190) Due to distance of these European sites from the proposed development site, there is no potential for any effects on these Natura 2000 sites and they can be screened out for AA. which the proposed development could impact on the following QIs/SCIs within the Courtmacsherry Bay SAC and Courtmacsherry Bay SPA: Annual vegetation of drift lines [1210] (QI Courtmacsherry Bay SAC) Perennial vegetation of stony banks [1220] (QI Courtmacsherry Bay SAC) Salicornia and other annuals colonizing mud and sand [1310] (QI Courtmacsherry Bay SAC) Mediterranean salt meadows (Juncetalia maritimi) [1410] (QI Courtmacsherry Bay SAC) Embryonic shifting dunes [2110] (QI Courtmacsherry Bay SAC) Shifting dunes along the shoreline with Ammophila arenaria (white dunes) [2120] (QI Courtmacsherry Bay SAC) Fixed coastal dunes with herbaceous vegetation (grey dunes) [2130] (QI Courtmacsherry Bay SAC) For inspection purposes only. Due to distance / habitat preferencesConsent of copyright there owner required is no for potentialany other use. for any effects on these QIs/SCIs within the relevant Natura 2000 sites and they can be screened out for AA. However, there are two Natura 2000 sites identified in Table 5, that have been screened in for further assessment, as significant effects cannot be rules out. These Natura 2000 site and their QIs/SCIs which have the potential to be significantly impacted are listed below: Courtmacsherry Bay SAC (Site code 001230) Estuaries [1130], Mudflats and sandflats not covered by seawater at low tide [1140], Atlantic salt meadows (Glauco-Puccinellietalia maritimae) [1330] Courtmacsherry Bay SPA (Site code 004219); Great Northern Diver (Gavia immer) [A003], Shelduck (Tadorna tadorna) [A048], Wigeon (Anas penelope) [A050], Red-breasted Merganser (Mergus serrator) [A069], Golden Plover (Pluvialis apricaria) [A140], Lapwing (Vanellus vanellus) [A142], Dunlin (Calidris alpina) [A149], Black-tailed Godwit (Limosa limosa) [A156], Bar-tailed Godwit (Limosa lapponica) [A157], Curlew (Numenius arquata) [A160], Black-headed Gull

EPA Export 01-05-2019:04:23:33 (Chroicocephalus ridibundus) [A179], Common Gull (Larus canus) [A182], Wetland and Waterbirds [A999]

5.3 Screening statement

Due to the uncertainty of significant impacts on two Natura 2000 sites at this stage, it is recommended that the assessment proceed to Stage 2 Natura Impact Statement for two Natura 2000 sites (Courtmacsherry Bay SAC and Courtmacsherry Bay SPA)

6. Stage 2: Appropriate Assessment Natura Impact Statement 6.1 Characteristics of Relevant Site

The characteristics of the relevant sites are described below. The Conservation Objectives of the sites are discussed in Section 6.2 Impact Assessment in the context of the potential impacts on them. Full site synopses for these European sites are included below. 6.1.1 Courtmacsherry Estuary SAC This site is located in west Cork, some 12 km south of Bandon and immediately east of the village of Timoleague. The estuary consists of the drowned valley of the Argideen River, which is now filled with sediments, resulting in an extensive area of mudflats. The site contains a complex of coastal habitats, including ten which are listed in the E.U. Habitats Directive. The site is a Special Area of Conservation (SAC) selected for the following habitats and/or species listed on Annex I / II of the E.U. Habitats Directive: [1130] Estuaries

[1140] Tidal Mudflats and Sandflats For inspection purposes only. Consent of copyright owner required for any other use. [1210] Annual Vegetation of Drift Lines [1220] Perennial Vegetation of Stony Banks [1310] Salicornia Mud [1330] Atlantic Salt Meadows [1410] Mediterranean Salt Meadows [2110] Embryonic Shifting Dunes [2120] Marram Dunes (White Dunes) [2130] Fixed Dunes (Grey Dunes) The greater part of this estuary site is mudflat and tidal channels, but three rivers flow into the site and areas of fresh- and saltmarsh are found. Most of the mudflat at Courtmacsherry is unvegetated, although in places cord-grass (Spartina sp.) occurs.

EPA Export 01-05-2019:04:23:33 Saltmarsh has developed in a number of areas, with the most abundant species being Sea Club-rush (Scirpus maritimus), Common Scurvygrass (Cochlearia officinalis), Sea Arrowgrass (Triglochin maritima), Sea Plantain (Plantago maritima), Thrift (Armeria maritima) and Saltmarsh Rush (Juncus gerardi). On the outer edges such species as Greater Sea-spurrey (Spergularia media), Lesser Sea-spurrey (S. marina) and Laxflowered Sea-lavender (Limonium humile) occur, while on their landward edge the saltmarshes frequently support Creeping Bent (Agrostis stolonifera), Red Fescue (Festuca rubra), Silverweed (Potentilla anserina), Soft Rush (Juncus effusus), Common Sorrel (Rumex acetosa) and others. A particularly well- developed and intact saltmarsh occurs at Garranefeen Strand. Tideline communities of Sea Rocket (Cakile maritima) and oraches (Atriplex spp.), including Grass-leaved Orache (A. littoralis), are noted from this site. In stony areas east of Courtmacsherry the uncommon Sea-kale (Crambe maritima) occurs, and Yellow Horned-poppy (Glaucium flavum) has also been recorded. Glasswort (Salicornia spp.) communities have been recorded from Garranefeen inlet. The site also supports small but interesting sand dune systems. Embryonic dunes occur in a number of places, including Garranefeen, Flaxford Strand and near Courtmacsherry, and the species Sand Couch (Elymus farctus) occurs. Marram dunes are well developed on the eastern spit at Garranefeen inlet. Species present include Sea Bindweed (Calystegia soldanella), Sea-spurge (Euphorbia paralias) and Sand Couch. Fixed dunes are not particularly well developed at this site, but where present, support species such as Red Fescue, Common Restharrow (Ononis repens), Kidney Vetch (Anthyllis vulneraria), Pyramidal Orchid (Anacamptis pyramidalis Galium verum). The site also includes small areas of sand dune, sandy and shingle beaches, reedbeds of Common Reed (Phragmites australis), scrub, dry grassland, and areas of both wet and dry semi-natural broadleaved woodland, parts of which are dominated by oak (Quercus sp.). For inspection The presence purposes only. of some rare and scarce plant Consent of copyright owner required for any other use. species at the site is noteworthy. The rare Red Data Book species Sea-kale occurs on shingle and the scarce grass, Tor-grass (Brachypodium pinnatum), has been recorded on cliffs between Broadstrand and Wood Point. The site is of ornithological importance for the many waders and wildfowl that feed on the mud- and sandflats. The winter flocks of Golden Plover (2,600) and BlackTailed Godwit (110) constitute nationally important numbers, and at least nine other species occur in numbers which are significant for the region - Wigeon (58), Mallard (69), Red-breasted Merganser (18), Oystercatcher (162), Lapwing (629), Dunlin (215), Bar-tailed Godwit (178), Curlew (731) and Redshank (139). Although these figures are the average peaks of 4 counts between 1984/85 and 1986/87, at times the numbers present far exceed those given. For example, in January 1992, 5,800 Golden Plover, 671 Wigeon, 731 Dunlin and 456 Oystercatchers were present. The spread of cord-grass on parts of the mudflats poses a threat to the quality of the area for feeding birds, and pollution is an ever-present threat in such a wetland. Courtmacsherry Estuary is an important site for the complex of coastal habitats found there, including ten listed on Annex I of the E.U. Habitats Directive, and for the

EPA Export 01-05-2019:04:23:33 large numbers of birds that use the area. The presence of rare and scarce plant species adds further interest and value to the site. 6.1.2 Courtmacsherry Bay SPA Courtmacsherry Bay SPA is located approximately 12 km south of Bandon and immediately east of the village of Timoleague in west Co. Cork. The site, which is largely estuarine in nature, consists of the drowned valley of the Argideen River which is now filled with sediments, resulting in extensive mudflats and areas of saltmarsh. The estuary of the River in the north-east of the site holds an area of well-developed saltmarsh. The seaward boundary for the site stretches from Coolmain Point to Barry Point, and includes Coolmain Bay and Broadstrand Bay. Most of the mudflats are unvegetated, although in places Cord-grass (Spartina anglica) occurs. Saltmarsh has developed in a number of areas, the abundant species mostly being Sea Club-rush (Scirpus maritimus), Common Scurvygrass (Cochlearia officinalis), Sea Arrowgrass (Triglochin maritima), Sea Plantain (Plantago maritima), Thrift (Armeria maritima) and Saltmarsh Rush (Juncus gerardi). The site is a Special Protection Area (SPA) under the E.U. Birds Directive, of special conservation interest for the following species: Great Northern Diver, Shelduck, Wigeon, Red-breasted Merganser, Golden Plover, Lapwing, Dunlin, Black-tailed Godwit, Bar-tailed Godwit, Curlew, Black-headed Gull and Common Gull. 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. The site is of ornithological importance for the wintering waders and wildfowl that feed on the mudflats. It supports internationally important numbers of Black-tailed Godwit (506 - figures given here and below are mean peaks for the five winters in the period 1995/96 to 1999/00), as well as nationally important numbers of a further eleven species, i.e. Great Northern For inspection Diver purposes (27), only. Shelduck (175), Wigeon (934), Red- Consent of copyright owner required for any other use. breasted Merganser (63), Golden Plover (5,759), Lapwing (2,713), Dunlin (1,353), Bar-tailed Godwit (182), Curlew (1,357), Black-headed Gull (2,727) and Common Gull (2,226). Other species which occur include Oystercatcher (610), Redshank (227) and Greenshank (26). Courtmacsherry Bay SPA is an important site for wintering birds. It holds internationally important numbers of Black-tailed Godwit and nationally important numbers of a further eleven species, including three that are listed on Annex I of the E.U. Birds Directive, i.e. Great Northern Diver, Golden Plover and Bar-tailed Godwit.

6.2 Impact Assessment 6.2.1 Potential impacts on Water Quality during construction Potential impacts on aquatic habitats which can arise during the construction phase of a development, include increased silt levels in surface water run-off and inadvertent spillages of hydrocarbons from fuel and hydraulic fluid. This could potentially impact on estuarine habitats adjacent to the proposed sewer route i.e. Estuary [1130], Mudflats and sandflats not covered by seawater at low tide [1140] and Atlantic Salt Meadows [1330].

EPA Export 01-05-2019:04:23:33 High levels of surface water run-off can result in aquatic invertebrates being smothered by excessive deposits of silt from suspended solids. In areas of stony substrate, silt deposits may result in a change in the macro-invertebrate species composition, favouring less diverse assemblages and impacting on sensitive species. Aquatic plant communities may also be affected by increased siltation. Submerged plants may be stunted and photosynthesis may be reduced. Impacts on water quality could also impact on fish stocks which in turn could impact on populations of piscivorous birds (e.g Red-breasted Merganser). This could theoretically result in changes in the ecology of the estuary, if silt in construction run- off was very severe. A range of precautionary measures to minimise impacts on water quality from the sewer construction are provided by the draft Environmental Management Plan which is included as Appendix 2 and EIAR (Environmental Impact Assessment Report, Proposed underground sewer to Timoleague, DixonBrosnan 2018). The

6.2.1.1 Construction mitigation plan A detailed Construction and Environmental Management Plan (CEMP) will be developed by the appointed Contractor in consultation with a suitably qualified ecologist. This will include details all of the construction mitigation measures, which are set out in the AA Screening, NIS Reports, construction methodology reports and conditions of planning. The principal measures which will be set out in the CEMP are summarised below. Construction best practice measures (of relevance in respect of any potential ecological impacts) will be implemented throughout the project, including the preparation and implementation of detailed method statements. The works will incorporate the relevant elements of the guidelines outlined below: NRA (2010) Guidelines for the Management of Noxious Weeds and Non- For inspection purposes only. Native Invasive PlantConsent Species of copyright on owner National required for Roads. any other use. National Roads Authority, Dublin. IW-AMP-SOP-009 Information and Guidance Document on Japanese knotweed Asset Strategy and Sustainability and Invasive Species Ireland Best Practice Management Guidelines for Himalayan Balsam

and Information Association, CIRIA reference C697

Research and Information Association publication C692 (3rd Edition - an update of C650 (2005); (I. Audus, P. Charles and S. Evans) IFI (2016) Guidelines on protection of fisheries during construction Works in and adjacent to waters (IFI, 2016)

Information Association, CIRIA reference C532, January 2001

Construction Industry Research and Information Association (CIRIA) (Connolly S. and Charles P.)

EPA Export 01-05-2019:04:23:33 Murnane, Heap and Swain. (2006) Control of water pollution from linear construction projects. Technical guidance (C648). CIRIA.

All personnel involved with the project will receive an on-site induction relating to operations and the environmentally sensitive nature of Courtmacsherry Bay SAC and SPA and to re-emphasize the precautions that are required as well as the precautionary measures to be implemented. All staff and subcontractors have the responsibility to: Work to agreed plans, methods and procedures to eliminate and minimise environmental impacts, Understand the importance of avoiding pollution on-site, including noise and dust, and how to respond in the event of an incident to avoid or limit environmental impact; Respond in the event of an incident to avoid or limit environmental impact; Report all incidents immediately to their line manager; Monitor the work place for potential environmental risks and alert the immediate line manager if any are observed; and Co-operate as required, with site inspections. Hydrocarbons and Waste Management A construction and demolition waste management plan will be developed and maintained by the main contractor prior to construction works commencing on site. The Plan will meet the requirements of the DoEHLG Best Practice Guidelines on the Preparation of Waste Management Plans for Construction & Demolition Projects. During the construction phase all necessary precautions will be put in place to ensure that there is no run-off to the estuary. All contractors will be made aware that

of the sensitivity of the Courtmacsherry For inspection purposes Estuary only. SAC and the Courtmacsherry Consent of copyright owner required for any other use. Bay SPA, and the necessity of protecting water quality. Careful consideration will be given to the location of any fuel storage facilities. Oil, petrol and other fuel containers will be double-skinned and bunded to be able to contain 110% volume to guard against potential accidental spills or leakages entering local watercourses linked to the European sites. Bund specification will conform to the current best practice for oil storage such as Enterprise Best Practice Guidelines. Construction materials will be stored in a secure compound to prevent the potential for vandalism and theft of material. Dedicated fuel storage areas will be introduced on-site or fuelling should take place offsite. All vehicles and plant will be regularly inspected for fuel, oil and hydraulic fluid leaks. Suitable equipment to deal with spills will be maintained on site. It will be ensured that all staff are trained and follow vehicle cleaning procedures. Post details of the procedures in the work area for easy reference. Use of cleaning chemicals will be minimised. Machinery including hand-tools will never be washed in watercourses or drainage ditches.

EPA Export 01-05-2019:04:23:33 It will be ensured that all areas where liquids are stored or cleaning is carried out are in a designated impermeable area that is isolated from the surrounding area, e.g. by a roll-over bund, raised kerb, ramps or stepped access. Use collection systems to prevent any contaminated drainage entering surface water drains, watercourses or groundwater, or draining onto the land. Wash down and washout of concrete transporting vehicles will not be permitted at the location of construction. Such wash down and washout activities will take place at an appropriate facility offsite or at the location where concrete was sourced. A detailed spillage procedure will be put in place and all will be trained with respect to the relevant procedures to be undertaken in the event of the release of any sediment, hydrocarbons into a watercourse. Spill kits will be maintained on site and relevant staff will be trained in their effective usage. All site personnel will be trained and aware of the appropriate action in the event of an emergency, such as the spillage of potentially polluting substances. In the event of spillage of any polluting substance and/or pollution of a watercourse, Cork County Council, Inland Fisheries Ireland and the NPWS shall be notified. All wastes generated as part of the construction process will be controlled and managed to ensure environmental protection. All site wastes (hazardous and non-hazardous), will be stored in designated areas and taken off site frequently to prevent large quantities accumulating. Careful ordering of materials will be undertaken to minimise quantities present on-site. Wastes which cannot be recycled will be removed from site by a licensed waste contractor to an appropriate licensed landfill facility ensuring adherence to the Environmental Protection (Duty of Care) Regulations 1991. Segregated waste for recycling will be removed from site to an appropriate Materials Recycling Facility for reprocessing.

Stockpiled Material- Mitigation For inspection purposes only. Consent of copyright owner required for any other use. Where feasible, soil excavation will be completed during dry periods and undertaken with excavators and dump trucks. Topsoil and subsoil will not be mixed together. Stockpiles will be graded to a <1:4 profile. Topsoil and subsoils will be stored separately. Stockpiles of mineral soils and peat will be <2m and <1m respectively. Stockpiles will be covered with plastic sheeting during wet weather to prevent run-off of silt and will be located on flat ground where possible. Excavated material will used for backfill where possible. Surplus material will be removed from site.

A dedicated holding tank for storage of construction foul effluent will be constructed, if required, prior to commencement of the main construction activities. The effluent will be regularly disposed of off-site by tanker by a licensed contractor to an approved licensed facility. Storm water will be managed carefully during construction. In general, storm water will be infiltrated to ground via silt traps and managed soakaways.

EPA Export 01-05-2019:04:23:33 To minimise the potential for elevated silt levels in surface water run-off, the working area used during construction will be clearly outlined prior to the commencement of works and will be kept to the minimum area necessary to effectively complete the works. Vegetation should be retained where possible, with particular emphasis on riparian vegetation. Works will be suspended during severe flood events or when such events are forecast. This makes all activities and measures easier to implement and manage and limits the potential for generation of sediment and mobilisation of both sediment and pollutants downstream. The method statement for the crossing of the stream will specifically consider the possibility of material associated with the works such as sandbags being washed downstream and the associated risk of increased siltation. The method statement will provide a set of criteria with respect to predicted rainfall, flood risk and status of the works at that time, to determine if material should be removed from the river prior to a flood event occurring. It is possible that there will be some surface water or minor ground water ingress into the excavations. Any pumping from the works area should discharge to a green vegetated area to allow for settlement of suspended solids or via silt mitigation measures (i.e. Silt settlement tank discharging through a silt sock or settlement lagoon with silt fence) as appropriate where no green area is available. The mitigation measures will be inspected by the supervising ecologist.

The NPWS has given technical clarification in relation to specific conservation objectives and targets for Annex I habitats, to facilitate the appropriate assessment process (NPWS 2014b). In relation to the constituent communities that are structurally important (broad sedimentary communities including Estuary [1130] and Mudflats and Sandflats [1140]) within an Annex I marine habitat, episodic activities such as the construction phase of the proposed development, should be assessed as follows. For inspection purposes only. Consent of copyright owner required for any other use.

Some activities may cause significant disturbance but may not necessarily represent a continuous or ongoing source of disturbance over time and space. This may arise for intermittent or episodic activities for which the receiving environment would have some resilience and may be expected to recover within a reasonable timeframe relative to the six-year reporting cycle (as required under Article 17 of the Directive). This Department is satisfied that such activities could be assessed in a context specific manner giving due consideration to the proposed nature and scale of activities during the reporting cycle and the particular resilience of the receiving habitat in combination with other activities within the designated site. The three habitats listed in Table 6, include a target that permanent habitat area is stable or increasing, subject to natural processes. This target refers to activities or operations that propose to permanently remove habitat from a site, thereby reducing the permanent amount of habitat area. It does not refer to long or short-term disturbance of the biology of a site. Therefore, based on the criteria set out by the NPWS, the proposed work will have no impact on the habitat area or distribution of

EPA Export 01-05-2019:04:23:33 Atlantic Salt Meadow [1330] is a transitional coastal habitat which can be damaged by excessing grazing, the spread of the Cordgrass, infilling (flood relief schemes) and reclamation (mainly agriculture) and sea-level rises. Silting up or accretion is generally assessed as having a positive impact on Atlantic Salt Meadow. Erosion and accretion are natural processes and Atlantic Salt Meadow as a coastal habitat will attempt to adjust or reach equilibrium in response to climatic and local changes (McGorry & Ryle, 2009). Therefore, there will be no impact on Atlantic Salt Meadow [1130] within the Courtmacsherry Bay SAC during the construction phase.

Attribute Measure Target Estuary [1130] Habitat area Hectares Ensure the habitat area of 490ha respectively (NPWS, 2014) remains stable or increasing Community distribution Hectares Conserve the following community types in a natural condition: Sandy mud to mixed sediments with Tubificoides benedii and Hediste diversicolor community complex; Sand to mixed sediment with oligochaetes community complex; Sand with Nephtys cirrosa community complex. Mudflats and sandflat [1140] Habitat area Hectares Ensure the habitat area of 442ha respectively (NPWS, 2014) remains stable or increasing Community distribution Hectares Conserve the following community types in a natural condition: Sandy mud to mixed sediments with Tubificoides benedii and Hediste diversicolor community complex; Sand to mixed sediment with oligochaetes community complex; Sand with Nephtys cirrosa community complex. Atlantic Salt Meadows [1330] Habitat area Hectares Area stable or increasing, subject to natural processes, including erosion and succession. One sub-site was mapped (10.79ha) and additional areas of potential saltmarsh (21.59ha) were identified for an examination of aerial photographs, giving a total estimated area of 32.38ha Habitat distribution Occurrence No decline or change in habitat distribution, subject to natural processes. Physical structure Presence/absence of Maintain natural circulation of sediments and organic physical barriers For inspection purposesmatter, only. without any physical obstructions Consent of copyright owner required for any other use. Physical structure creaks Occurrence Maintain creek and pan structure, subject to natural and pans processes, including erosion and succession Physical structure Hectares flooded; Maintain natural tidal regime flooding regime frequency Vegetation structure Occurrence Maintain range of coastal habitats including transitional zonation zones, subject to natural processes including erosion and succession Vegetation structure: Percentage cover at a Maintain more than 90% area outside creeks vegetated vegetation height representative number of monitoring stops Vegetation Percentage cover at a Maintain range of subcommunities with typical species composition: representative number listed in the saltmarsh monitoring project typical species of monitoring stops and subcommunities Vegetation Hectares No significant expansion of common cordgrass (Spartina structure: anglica), with an annual spread of less than 1% where it is negative indicator known to occur species - Spartina anglica

Both Estuary [1130] and Mudflats & Sandflats [1140] have a target to:

EPA Export 01-05-2019:04:23:33 Conserve the following community types a natural condition: Sandy mud to mixed sediments with Tubificoides benedii and Hediste diversicolor community complex; Sand to mixed sediment with oligochaetes community complex and Sand with Nephtys cirrosa community complex. The estimated areas of these community types within the Estuaries [1130]/Mudflats and Sandflats [1140] are: Sandy mud to mixed sediments with Tubificoides benedii and Hediste diversicolor

422ha (Mudflats & Sandflats) - Sand with Nephtys cirrosa & Sandflats) The NPWS suggests that significant continuous or ongoing disturbance of communities should not exceed an approximate area of 15% of the interpolated area of each community type, at which point an inter-Departmental management review is recommended prior to further licensing of such activities. The area of the SAC/SPA adjacent to the proposed development site is relatively small in the context of the total area of communities of invertebrates described above. Furthermore, the disturbance caused by the construction phase of the proposed development will be short-term and following the implementation of the mitigation measures outlined in the construction management plan, will effectively minimise/prevent impacts from silt and hydrocarbons. The impact on water quality during construction is predicted to be minor at a local level in the short-term and negligible in the long-term. Using the criteria outlined by the NPWS, it can be concluded that there will be no adverse

Courtmacsherry Bay SAC and the conservation objectives of the SAC will be For inspection purposes only. maintained. Consent of copyright owner required for any other use.

6.2.2 Potential impacts on Water Quality during operation According to the NPWS (2014), one of the major pressures upon water quality of the Courtmacsherry Estuary is inadequate waste water treatment. It is proposed to use the existing outfall at Church Bridge for Staunton Foods new WWTP discharge. This will replace the Timoleague Municipal WWTP discharge which is moving to near Courtmacsherry village in Courtmacsherry Bay. The cumulative impacts of this are discussed in Section 6.2.5 (P09947-01) to discharge 120m3/day at a point in the Spital Stream. The assimilative capacity of the Spital Stream is limited and restrictive licence Emission Limit Values existing WWTP is not capable of achieving these values and a new WWTP has received planning permission. This new plant will have a larger capacity (400m3/day) to provide for potential future expansion of the plant. As part of the EIAR for this proposed development, a hydrological study was carried out by Irish Hydrodata Ltd, to examine possible alternative outfall locations within the Argideen Estuary. Subsequently hydrodynamic water quality models were

EPA Export 01-05-2019:04:23:33 constructed to investigate dilutions and to simulate the impacts of the proposed discharge. The full hydrological report is included in Attachment 1 of the EIAR ( Proposed WWTP Investigation of the Impact of Treated Wastewater Discharges to Argideen Estuary; 2017 Irish Hydrodata Limited). Irish Hydrodata Limited undertook an assessment to determine the best location for the outfall from the new WWTP based on the most appropriate location to accommodate the licenced discharge and ensure compliance with all EC and National Regulations. The following regulations were used in the assessment: Water Framework Directive, given effect under SI 254/2001, EC Environmental Objectives (Surface Waters), SI 272/2009, EC Quality of Salmonid Waters Regulations, SI 293/1988, Bathing Water Directive, SI 272/2009 and Habitats Directive, SI 477/2011. The analysis was based on a discharge of 4.6 l/s (400 m3/day).The three sites which were assessed were as follows:

1. The existing outfall at Spital bridge; 2. An outfall at Abbey bridge (1250m from the WWTP); 3. An outfall to the Argideen river channel (1550m from the WWTP).

On the basis of this initial evaluation it is evident that option 3 (outfall to the Argideen river channel 1550m from the WWTP) is the more preferable site as it provides use of the existing municipal outfall and the discharge point which remains underwater on a low water spring tide. The discharge will be subject to tidal control, with a likely discharge window of three hours during each tidal cycle.

The 95th percentile river flow here is 0.59m3/s with additional significant upstream tidal volumes. A minimum fully mixed dilution of about 128 is thus available. This increases to 676 when tidal volumes are included. The existing discharge location at the Spital Stream affords only a 6-fold dilution. th The 95 percentile tidal water depth For inspection at the purposes proposed only. Church Bridge outfall location is Consent of copyright owner required for any other use. 0.9m excluding river flows. The proposed discharge point is an existing municipal outfall. The available initial dilution will be about 20. Thus, by the time the plume has surfaced contaminant concentrations will be approaching target Environmental Quality Standards (EQS). Only PO4 and DIN will remain elevated, the predicted un- ionised ammonia concentration will be below the desirable target of 0.021 mg/l almost immediately. As the plume moves upstream or downstream from the outflow point, additional dilution will be achieved. The mixing zone for PO4 is calculated to extend 80m and from the diffuser and reach a maximum width of 6m at the 95th percentile tidal water level. Outside of this zone the PO4 concentrations will have reached EQS level. Tidal simulations of the estuary show that the proposed outfall will have a minor impact on the overall estuary water quality. The average PO4 level will rise by 0.002mg/l and the DIN by 0.02mg/l. et al. 2010) and the current

Western River Basin Transitional and Coastal Waters Action Programme (SWRBD 2010). The pressures upon the system are listed as point source pollutants (WWTP), combined sewer overflows and treatment plant overflows. The proposed relocation

EPA Export 01-05-2019:04:23:33 improve water quality within the Argideen Estuary and Courtmacsherry Bay SAC/SPA. Improvements in WWTP treatment are aimed at meeting objectives of the Urban Waste Water Treatment Regulations (EU Council Directive 91/271/EEC, as transposed by S.I. No. 254 of 2001 as amended by S.I. 48 of 2010) and the Water Framework Directive (2000/20/EC as transposed by the European Communities (Water Policy) (Amendment) Regulations, 2010)). Therefore, as the proposed within Courtmacherry Bay SAC and SPA as a result of changes in water quality during the operational phase of this development. 6.2.3 Potential impacts from the spread of Invasive Species and Biosecurity Risks Measures to prevent the spread of invasive species during the construction phase of the development include: To prevent Japanese Knotweed from outside the site being inadvertently being brought in to the site, the contractor will be required to inspect vehicles before using them on site and will pay particular attention to caterpillar tracks and where trucks and dumpers are stowed. The supplier of fill will be required to provide a guarantee that the fill to be imported does not contain knotweed. In addition, the fill will be inspected for signs of knotweed, prior to inspection of topsoil brought into the site, should be carried out using the guidance in

Specification for Topsoil. A buffer zone of at least seven metres should be out in place in respect to the stand of Japanese Knotweed. This zone should be clearly marked and no works will proceed within these buffer zones. For inspection purposes only. Consent of copyright owner required for any other use. As the works will not impact on existing stands of Japanese Knotweed or other invasive species no impact from the spread of invasive species will occur. 6.2.4 Potential impacts from noise and disturbance during construction

The activities associated with construction of the pipeline will be confined to the proposed development site and undertaken primarily from October to March, when the wintering waterfowl and wader populations are on summer breeding grounds and are not in the vicinity of the proposed sewer route. A resident breeding population of Shelduck tend to be more widely dispersed during the summer period. It is noted that the proposed development site is located within Timoleague and its outskirts, and is subject to noise disturbance from traffic and the local population and industry. Noise levels associated with construction activities are not expected to be significantly elevated over typical background levels associated with the area as mixed urban and agricultural environment. The EIAR submitted with the planning application noted the following in relation to noise:

EPA Export 01-05-2019:04:23:33 Noise emissions from the existing SF facility are satisfactory and in compliance with limits specified in licence P0947-01. The proposed development will not result in the introduction of any new sources, other than those associated with temporary construction works. Construction works emissions will be clearly audible locally, but will comply with recommendations set out in British Standard BS 5228:2009+A1:2014 Code of practice for noise and vibration control on construction and open sites Part 1: Noise (2014). Following commissioning, SF emissions will continue to comply with noise limits set out in licence P0947-01. No residual impacts are expected, and noise emissions at receptors will be similar to those currently arising. Impacts will therefore be neutral. No secondary or indirect impacts are expected. Cumulative impacts attributable to the proposed development are not expected. During the construction stage, there may be short-term increases in disturbance but it will not be significant in the context of existing noise levels. Given the short-term nature of the works, the tolerance of local birds to the existing background noise levels and the proposed mitigation measures, there should be no significant works. 6.2.5 Potential cumulative Impacts

Construction of a new sewerage scheme for Timoleague and Courtmacsherry is currently underway (Licence Reg: D0294-02). The existing WWTP in Courtmacsherry consists of two septic tanks and is designed to cater for 500 population equivalent (PE). This septic tank is grossly overloaded. The second septic tank is located at the western end of the village and currently serves 15 houses. The Timoleague area has a very old wastewater collection system and no form of WWTP in place. The collection system discharges For inspection purposes untreated only. waste water directly into the Consent of copyright owner required for any other use. Argideen Estuary via five outfalls. The existing PE being served by the agglomeration is 1,490. It is proposed to construct a new secondary WWTP for the Courtmacsherry Timoleague agglomeration. This WWTP will be designed to cater for 2,500 PE. The licence requires that the new WWTP will be fully constructed and operational by 31/12/2019. 3/day at a point in the Spittal River. The hydraulic loading (IDWF) at Timoleague WWTP was 133 m3/day in 2005 and is estimated to reach 429m3/day by 2020. It is proposed to

Courtmacsherry Bay at this location. The changes in the wastewater treatment regimes, both within the agglomeration of Timoleague and Courtmacsherry and quality within Courtmacsherry Bay SPA and SAC. However, a reduction in organic and nutrient loading to an estuary may have various consequences for the ecology of the estuarine system. For example, there could be

EPA Export 01-05-2019:04:23:33 a reduction in the abundance of benthic invertebrate prey species (Burton et al. 2002) particularly those invertebrates that thrive in organically-enriched sediments. This could have subsequent knock-on effects upon waterbird foraging distribution, prey intake rates, and ultimately upon survival and fitness. Given that sustained high levels of macroalgal growth is linked to organic enrichment, there is a potential for a reduction in macroalgal abundance as a result of improvements to sewage discharges. While exerting many influences upon the estuarine system, algal mats can have both negative and positive effects upon waterbird foraging ecology. Some waterbird species avoid them or may be negatively affected by lowered invertebrate abundances beneath them (Lewis & Kelly, 2001; Lopes et al. 2006) while on the other hand, herbivores such as Light-bellied Brent Geese and Wigeon benefit from the algae being a source of food. The populations dynamics of feeding birds within an estuary are complex and it is possible that the removal of the Timoleague municipal discharge from the inner part availability in estuarine muds and subsequently the distribution or density of wading birds within the European site. Lewis and Kelly (2012) have shown that the enrichment attributed to the Clonakilty WWTP within Clonakilty Bay SPA, coincided with particularly high abundances of the Ragworm Hediste diversicolor. This worm is a potential prey species for Black-tailed and Bar-tailed Godwit, Redshank, Curlew and Dunlin. Such implications have been noted previously (Burton et al. 2002) as have a reduction in bird numbers (Essink 1998 in Van der Kam et al. 2004). Alves et al. (2011) explored the effects of untreated sewage discharges on the distribution and abundance of foraging black tailed godwits Limosa limosa and their main benthic prey (bivalves and polychaetes) on the Tejo estuary in Portugal, a major European Special Protection Area with ongoing wastewater improvements. Patches of mudflat in close proximity to sewage streams (<30m) can support polychaete densities and biomass For that inspection are purposes an orderonly. of magnitude higher than more Consent of copyright owner required for any other use. distant sites (>70m), and godwits foraging in these areas can attain the highest intake rates recorded for the estuary. However, they also found that high intake rates can also be attained on bivalve prey, and bivalve biomass and density increase slightly with distance from sewage streams. They concluded that as the organic input from sewage outfalls influences invertebrate abundance and godwit foraging rates over relatively small areas, the ongoing implementation of a sewage treatment network on the estuary seemed likely to have only a limited impact on the wintering godwit population. The localized effect of untreated sewage discharges on benthic communities suggests that the implications for predatory birds are relatively minor where alternative prey are available, but may be more severe in locations with more depauperate, polychaete dominated invertebrate communities. Such cumulative impacts are complex and may operate over the long-term. Further research is needed to conclude that cumulative impacts such as these will not have a long-term impact on feeding birds within Courtmacsherry Bay SPA. However, this

EPA Export 01-05-2019:04:23:33 Urban Waste Water Treatment Regulations and the Water Framework Directive.

7. Conclusions

The only Natura 2000 sites for which potential significant impacts have been identified are Courtmacsherry Bay SAC and Courtmacsherry Bay SPA, which are both located adjacent to the proposed development site. Impacts which were considered to have the potential to impact Courtmacsherry Bay SAC/SPA relate primarily to impacts on water quality, increased noise and disturbance, invasive species and loss of habitat. Potential cumulative impacts were also considered. A range of mitigation measures have been incorporated into the project design, and other mitigation measures have been developed and proposed, with the purpose of avoiding or minimising impacts on the qualifying interests and conservation objectives of the Courtmacsherry Bay SAC/SPA.

whole area, or the habitats, complex of habitats and / or population of species for The draft documents Managing Natura 2000 (EC, 2015) states that the integrity of the site can be usefully defined as the coherent sum area, which enables it to sustain the habitats, complex of habitats and/or populations

Following a comprehensive evaluation of the potential direct, indirect and cumulative For inspection purposes only. impacts on the qualifyingConsent interests of copyright owner and required conservationfor any other use. objectives for the Courtmacsherry Bay SAC/SPA, it has been concluded that the proposed development will not have an adverse effect on the integrity of the Courtmacsherry Bay SAC/SPA or any other Natura 2000 sites.

EPA Export 01-05-2019:04:23:33 References

Borgmann, K.L. (2011) A review of human disturbance impacts on waterbirds. Tiburon, California: National Audubon Society- Report on Human Impacts to Birds, 1-23. Burger, J. 1981b. Effects of human disturbance on colonial species, particularly Gulls. Colonial Waterbirds 4:28-36. Burton, N.H.K., Paipai, E., Armitage, M.J.S., Maskell, J.M., Jones, E.T., Struve, J., Hutchings, C.J. and Rehfisch, M.M. (2002) Effects of reductions in organic and nutrient loading on bird populations in estuaries and coastal waters of England and Wales. Phase 1 Report. BTO Research Report, No. 267 to English Nature, the Countryside Council for Wales and the Environment Agency. BTO. Thetford, UK. BWPi (2004) Birds of the Western Palearctic Interactive. BirdGuides Ltd. 2004. Cayford, J. T. 1993. Wader disturbance: a theoretical overview. Wader Study Group Bull. 68: 3-5. Crowe, O. (2005) . BirdWatch Ireland. Cutts, N., Hemingway, K. and Spencer, J. (2013) Waterbird Disturbance Migration Toolkit. Informing Estuarine Planning and Construction Projects (version 3.2). University of Hull, Hull. Delaney, S., Scott, D., Dodman, T. & Stroud, D. (2009) (eds) An atlas of wader populations in Africa and Western Eurasia. Wetlands International, Wageningen. The Netherlands For inspection purposes only. Durell, S.E.A. le V. dit., Goss-Custard,Consent of copyright owner J.D., required Stillman, for any other R.A., use. West, A.D., 2001. The effect of weather and density-dependence on Oystercatcher Haematopus ostralegus winter mortality. Ibis. 143 Essink K (1995) Ecological effects of dredging and dumping of dredge spoil. Waddensea News 1 Gilbert, G., Gibbons, D.W. & Evans, J. (1998) Techniques for Key UK Species. RSPB: Sandy. Gillings, S., Austin, G. E., Fuller, R. J., & Sutherland, W. J. (2006) Distribution shifts in wintering Golden Plover Pluvialis apricaria and Lapwing Vanellus vanellus in Britain. Bird Study 53, 274-284. Goss-Custard, J.D., 1980. Competition for food and interference among waders. Ardea 68 Goss-Custard, J.D., Triplet, P., Sueur, F., West, A.D., 2005. Critical thresholds of disturbance by people and raptors in foraging wading birds. Biological Conservation. 127

EPA Export 01-05-2019:04:23:33 Hill, D., Rushton, S. P., Clark, N., Green, P & Prys-Jones, R. (1993) Shorebird communities on British estuaries: factors affecting community composition. Journal of Applied Ecology 30, 220-234 IFI (2016). Guidelines on protection of fisheries during construction Works in and adjacent to waters. Inland Fisheries Ireland. Lewis, L.J. and Kelly, T.C. (2001) A short-term study of the effects of algal mats on the distribution and behavioural ecology of estuarine birds. Bird Study 48, 354-360. of macroalgal mats on abundance and distribution of Dunlin Calidris alpina in estuaries: A long-term approach. Marine Ecology Progress Series 323, 11-20. McCorry, M. and Ryle, T. (2009). Saltmarsh Monitoring Project 2007-2008 Contract reference D/C/227 A Report for Research Branch, National Parks and Wildlife Service. Department of Arts, Heritage and the Gaeltacht. Mitchell,I.P., Ratcliffe, N., Newton, S, & Dunn, T.E. (2004) Seabird Populations of Britain and Ireland. T & AD Poyser, NPWS (2014) Courtmacsherry Bay SPA (004219) Conservation objectives supporting document (Version 1) National Parks and Wildlife Service. Department of Arts, Heritage and the Gaeltacht. NPWS (2014) Courtmacsherry Estuary SAC (site code: 1230) Conservation objectives supporting document - Marine Habitats Version 1. National Parks and Wildlife Service. Department of Arts, Heritage and the Gaeltacht. Quality of estuarine and coastal waters

For inspection purposes only. Santos, C.D., Grandareiro,Consent J.P of and copyright Palmeirim, owner required for J.Many other (2005). use. Feeding Ecology of

Dunlin Calidris alpina in a Southern European Estuary. Ardeola 52(2), 2005, 235-252 Smit, C .J. & Visser,G .J.M. 1993. Effects of disturbance on shorebirds: a summary of existing knowledge from the Dutch Wadden Sea and Delta area. Wader Study Group Bull. 68 Stillman, R.A., West, A. D., Caldow, R.W.G. and Lev. Dit Durrell, S.E.A. (2007) Predicting the effect of disturbance on coastal birds. Ibis, 149 SWRBD (2010) South Western River Basin Transitional and Coastal Waters Action Programme. www.wfdireland.ie Van der Kam, J., Ens, B., Piersma, T. and Zwarts, L. 2004. Shorebirds: an illustrated behavioural ecology. KNNV Publishers, Netherlands. Wernham, V. V., Toms, M. P., Marchant, J. H., Clark, J. A., Siriwardena, G. M. & Baillie, S. R. (eds) (2002) The Migration Atlas: movements of birds of Britain and Ireland. T & A D Poyser. London.

EPA Export 01-05-2019:04:23:34 For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 01-05-2019:04:23:34 Appendix 2 Environmental Management Plan

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 01-05-2019:04:23:34 ______

For inspection purposes only. Consent of copyright owner required for any other use.

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TABLE OF CONTENTS

Page No.

1.0 Introduction 3

2.0 Proposed Construction Methodology and likely Raw Material Usage 5

2.1 - Securing the Site & Site Mobilisation 5 2.2 - Scheduling of Works 5 2.3 - Working Hours 7 2.4 - Construction Compound 7 2.5 - Waste Arising

3.0 Proposals for Minimisation, Reuse, Recycling and Management of C&D Waste 8

3.1 - Waste Handling 8

4.0 Assignment of Responsibilities 11

5.0 Waste Records 12

For inspection purposes only. Consent of copyright owner required for any other use.

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1.0 Introduction

This outline Mythology and Construction Management Plan has been prepared to ensure that the construction phase and all associated wastes arising from the project are dealt with from generation to disposal in a systematic way and in accordance with the governing legislation i.e. The Waste Management Act, 1996 and subsequent amendments.

OLS Consulting Engineers were commissioned by Staunton Foods Ltd to prepare and submit a planning application for a proposed development at their existing Pork Processing Plant

The proposed development comprises of the following:-

The laying of a 150mm fusion welded HDPE pipeline from the newly constructed wWTP to an existing Irish Water outfall pipe located to the southern fringes of Timoleague village.

All Associated Siteworks

The proposed development pertains to proposed works both within the lands under the applicants ownership, lands under the ownership of a 3rd parties and to the public roadway.

Pipeline The overall length of the pipeline from initial outfall from the wWTP to the existing Irish Water outfall id 1546 m, of which

253 m runs within the applicants ownership. 198 m runs within lands under the ownership of Colin Bateman. 1095 m runs on the Public Road - under the stewardship of Cork County Council

For inspection purposes only. The boundary with the R600 RegionalConsent of copyright Road owner comprises required for any partially other use. of a low concrete wall with landscaped area behind the wall east of the site entrance and an existing sod and stone ditch to the west of the entrance. The boundary with the local road on the south-eastern boundary is also an existing sod and stone ditch. The boundaries with the agricultural lands to the northeast and southwest comprise of concrete post and wire fencing with intermittent mature hardwood and softwood trees. All existing boundaries will be undisturbed by this planned development.

A more detailed and quantitative Waste Management Plan for the Project will be produced in advance of Project Commencement when the detailed design has been completed and a contractor appointed.

This Outline Demolition and Construction Management Plan has been prepared for the provision of waste management for the construction phase of the proposed scheme taking account of the many guidance documents on the management and minimisation of construction and demolition waste including:-

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Best Practice Guidelines on the Preparation of Waste Management Plans for Construction and Demolition Projects(Department of Environment, Heritage and Local Government, July 2006).

CIRIA Document 133 Waste Minimisation in Construction.

There has been no consultation to date with waste disposal sites with regard to the acceptance of waste arising from the Project, however, final arrangements for the disposal of all waste will be subject to commercial considerations and the possession of each site/facility of the necessary regulatory permissions to accept the particular waste type.

For inspection purposes only. Consent of copyright owner required for any other use.

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2.0 Proposed Construction Methodology and likely Raw Material Usage

The planned development will require a variety of construction methodologies. It is anticipated that the works associated with the outfall pipeline shall be completed be completed in sequence as set out on the Pipeline Construction Mythology Layout as enclosed as part of this submission.

2.1 Securing the Site and Site Mobilisation

The development area of the site will be segregated from the remainder of the site which will remain in operation during the planned works.

The boundaries of the compound shall be secured off with preparatory fencing.

2.2 Scheduling of the Works.

Pipeline.

It is envisaged that the laying of the pipeline shall be completed in elemental sections to minimise disruption, in summary works shall be completed as follows.

a) Section 1 - The proposed outfall pipeline shall be laid in an open cut trench within the confines of the lands under the ownership of the applicant and 3rd party Colin Batemen, this shall consist of a 400mm wide by 1200mm deep trench, all associated arising shall be used to backfill the excavation any extra over material in the form of subsoil shall be redistributed locally over the excavation. No significant impact is envisaged - Envisaged Duration for this section of the works 1 week.

b) Section 2 - The proposed pipeline shall then exit the agricultural field onto the public road, the pipeline shall run to Forthe inspection eastern purposes side only. of the road at this location, the road Consent of copyright owner required for any other use. shall be excavated 300mm wide and 850mm deep, all associated arising will be disposed of to a licensed facility. The excavated material shall be backfilled and compacted with certified crushed stone with the road finish being reinstated with 60mm of blacktop. A "Stop and Go" traffic management system where one road carriage way will remain open for this phase of the works - Envisaged Duration for this section of the works 1 week.

c) Section 3 - The proposed pipeline shall run to the northern side of the road at this location, the road shall be excavated 300mm wide and 850mm deep, all associated arising`s will be disposed off site to a licensed facility. The excavation shall be backfilled and compacted with certified crushed stone with the road finish being reinstated with 60mm of blacktop. At the western side of this section there is a piped culvert transverseing the road. We shall maintain the integrity of the piped culvert and dig locally under same, thus it is proposed to run the rising main under the existing culvert. A temporary road closure shall be applied for to the local authority for this phase of the works - Envisaged Duration for this section of the works 2 weeks.

d) Section 4 - The proposed pipeline shall run along the public road, the pipeline shall run to the northern side of the road at this location, the road shall be excavated

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300mm wide and 850mm deep, all associated arising will be disposed off site to a licensed facility. It is envisaged that a minimum separation of 1200mm shall be provided between the proposed outfall pipeline and Irish Waters pipeline serving the Timoleague - Courtmacsherry wWTP The excavated material shall be backfilled and compacted with certified crushed stone with the road finish being reinstated with 60mm of blacktop. A "Stop and Go" traffic management system where one road carriage way will remain open for this phase of the works - Envisaged Duration for this section of the works 2 weeks.

e) Vale Chamber at the outfall connection point - It is proposed to install a precast concrete manhole / valve chamber to the green / soft landscaped area between the public road and the quay wall. It is intended to pick up the existing Irish Water outfall pipe at this location. No works are proposed to the harbour side of the quay wall. The said valve chamber will be a "dry chamber" where access to the pipeline will be provided for both inspection, integrity testing of the line and direct drain off to a tanker where required.

2.3 Working Hours

Normal Site Working Hours will be 8.00am to 6.00pm Monday to Friday and 8.00am to 1.00pm on Saturday. It is envisaged that project will take 6 months to complete.

For inspection purposes only. Consent of copyright owner required for any other use.

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2.4 Construction Compound

A construction compound will be created for the duration of the construction phase for the storage of materials, plant and equipment and for site offices. The compound area will consist of a crushed stone working platform, utilities, offices, welfare facilities and stores. It shall be located within the agricultural field under the ownership of Staunton Foods.

Following completion of the works; all construction materials will be removed from the compound, all temporary services decommissioned and disconnected and the area will be reinstated with finishes consistent with the existing hard & soft landscaping finishes on the site.

2.5 Waste Arising

Given the nature of the Project and the construction methodologies outlined above; it is anticipated that the main waste types generated during the construction phase of the project will be from sub soil arising and bitumen road materials. There will also be some waste materials generated in the clearing and stripping of the site to formation level.

Quantities of general construction waste such as packaging, metals, plastics, canteen waste, some hazardous wastes (e.g. oils, adhesives), site clearance and residual wastes will be generated during the construction phase.

Whilst it is difficult to predict at this stage precise tonnages of these wastes, estimation of the composition of waste materials generated by a typical Irish Construction Site from the EPA National Database Report are presented by Table 2.2 below. A more detailed estimate of the anticipated quantities of these materials will be provided in the detailed waste management plan following completion of the detailed design and the appointment of a contractor to execute the works.

TABLE 2.2 C&D COMPOSITION FROM ForT inspectionYPICAL purposesIRISH only.CONSTRUCTION SITE (EPA 2004) Consent of copyright owner required for any other use.

Waste Type % Soil and Stones 71.0 Concrete, Ceramics. 3 Asphalt, Tar and Tar Products 20 Metals 1.0 Other Wastes 5.0 Total Wastes 100.0

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3.0 Proposals for Minimisation, Reuse, Recycling and Management of C&D Waste

3.1 Waste Handling

The primary aim of this Plan is to ensure that the wastes generated in the course of the project are managed in a systematic manner in accordance with the governing Waste Management Legislation and the principles of the Waste Management Hierarchy i.e. prevention, minimisation, reuse , recovery and recycling.

Wastes generated on the construction site must be identified and segregated in accordance to their category as described by the European Waste Catalogue (EWC). In order to effect this, designated Waste Storage Areas will be created in the construction site compound or other suitable location on site for the storage of segregated wastes prior to their transport for recovery/disposal at suitably licensed/permitted facilities. The designated waste storage area shall be located within the confines of the site compound.

Suitably sized containers/skips will be provided for each waste stream and will be supervised by the Contractor appointee who will be responsible for the management of wastes during the entire project. Source segregation of wastes will result in cost savings to the Project as well as providing an environmentally sound route for the management of all C&D wastes.

Under the Waste Management (Collection Permit) Regulations 2007 a waste collection permit, for the appropriate EWC Code(s) and destinations is required by a waste haulier to transport waste from one site to another. Compliance with the Waste Management (Movement of Hazardous Waste) Regulations, 1998 is also required for the transportation of hazardous waste by road. The export of waste from Ireland is subject to the requirements of the Waste Management (Shipment of Waste) Regulations 2007. The Contractor will ensure that the transport and movement of all wastes are carried out in compliance with these requirements. For inspection purposes only. Consent of copyright owner required for any other use.

Waste may only be treated or disposed at facilities that are licensed to carry out that specific activity, (e.g. chemical treatment, landfill, incineration, etc.) for a specific waste type. Records of all waste movements and associated documentation should be held on site.

It is planned that the only waste activities to be undertaken at the site will comprise of source segregation, storage and collection and therefore, no waste licensable and waste permissible activity will be undertaken at the site.

In order to prevent and minimise the generation of wastes; the Contractor will be required to ensure raw materials are ordered so that the timing of the delivery, the quantity delivered and the storage is not conducive to the creation of unnecessary waste.

It is essential that the construction work planning is carried out closely with the waste management contractors in order to determine the best techniques for managing waste and to ensure a high level of recovery of materials for recycling. The Contractor will be required to continuously seek to improve the waste management process on site during all stage of the project. Construction Waste Management should also be included as an agenda Item at the

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An overview of the methods to manage the primary waste streams is presented below.

Excavated Clay, Soil and Stones

Topsoil will be stockpiled on site for reuse in soft landscaping. Sub soil arising generated during the excavation of the pipeline within the confines of the agricultural field, shall be reused in the filling of the trench, any extra over material will be levelled within the works location. Arising generated during the excavation of the road will be loaded directly to vehicles for removal from site for off-site disposal.

Concrete

It is anticipated that there will be a limited amount of waste concrete arise during the works. it is anticipated that it will be limited to the removal of a bund wall to the existing wWTP, the waste concrete will be loaded directly to vehicles for off-site disposal.

Metals

It is anticipated that there will be a limited amount Metal wastes, the primary source of metal waste is rebar. Wastage of rebar will be reduced by ordering made to measure rebar from the manufacturer and detailing rebar schedules for all reinforced concrete structural elements.

When the waste metal storage containers are full; they will be removed by the waste storage contractor and sent to a metals recycling facility.

Packaging & Plastic For inspection purposes only. Consent of copyright owner required for any other use.

Packaging waste can become a major problem on a construction site. Double handing will be avoided by segregating packaging immediately after unwrapping. Many suppliers are now prepared to collect their packaging for recycling and this will also be investigates prior to works commencing. Waste packaging will be segregated and stored in separate containers, preferably covered, in the Site Compound Area for collection and distribution to packaging recycling facilities.

Blocks, Bricks & Tiles

The careful storage of these raw materials will significantly reduce the volume of this waste arising on site. The most likely wastes produced will be off-cuts, trimmings and wastes from breakages. Every effort will be made to use broken bricks and off-cuts.

Hazardous Wastes

Hazardous liquid waste arisings from the construction process will require careful handling. Oil, paints, adhesives and chemicals will be kept in a separate contained storage area which will be locked when not in use. Lids will be kept on containers in order to avoid spillage or ______9

EPA Export 01-05-2019:04:23:34 Stanton Foods Timoleague - Mythology & Construction Management Plan August 2018 - Revision A waste by evaporation. Waste oils, paints and chemicals will require careful handling and disposal. This includes the containers and will be stored in a containment tray. A small number of suitably licensed private contractors/facilities are present in the for the disposal of these wastes as they arise.

Fuels and chemicals will be stored in double skinned containers or within a bund which must have capacity to contain 110% of the volume of the largest tank stored within it. All containers are to be carefully labelled.

Canteen Wastes

Staff Canteens have the potential to generate food waste and packaging waste. Designated receptacles for food waste, dry recyclables and residual waste. Separate receptacles for the recyclable fractions may be provided such as plastics, metals and glass.

Other Wastes

Waste materials other than those outlined above can constitute a significant proportion of the total waste generated by a construction site. This waste is normally made up of residual non recyclable waste such as soiled paper, cloth, cardboard or plastics as well as canteen waste to include food as above. Other wastes which might be generated are fibreglass, polystyrene insulation and plasterboard.

For inspection purposes only. Consent of copyright owner required for any other use.

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4.0 Assignment of Responsibilities

A Waste Management Co-ordinator will be appointed who will have overall responsibility for waste management on the site. The appointed person in addition to the site personnel must be in a position to:-

Distinguish reusable materials from materials suitable for recycling.

Ensure maximum segregation at source.

Co-operate with site management on best locations for stockpiling reusable materials.

Separate materials for recovery.

Identify and liaise with operators of recovery outlets.

5.0 Waste Records

When establishing the systems for managing the details of all arisings, movement and treatment of C&D Waste in the Waste Management Plan, the use of electronic tools should be considered to provide for convenient recording of information in a useful format.

The Contractor will be required to arrange full details of all arisings, movements and construction and demolition waste discards to be recorded during all stages of the project.

Each consignment of C&D waste removed from the site will be documented in the form of a Waste Movement Record form which will ensure full traceability of the material to its final destination. The Contractor will also receive printed documents/records form waste disposal companies employed quantifying the exact amount of waste materials removed from site. All such records will be retainedin the Site For inspection Office. purposes only. Consent of copyright owner required for any other use.

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