Cork County Council An Bord Pleanála Inspector’s Report Board Reference: 04.YA0005 Proposed Development: Proposed Wastewater Treatment Plant at Shanbally, County Cork Local Authority: Cork County Council Inspector: Daniel O’Connor PL04.YA0005 An Bord Pleanála Page 1 of 77 Cork County Council PROPOSED WASTEWATER TREATMENT PLANT AT SHANBALLY, CARRIGALINE , COUNTY CORK CONTENTS 1.0 STATUTORY REQUIRMENTS p03 2.0 DESCRIPTION OF PROPOSED DEVELOPMENT p05 3.0 IMPACTS IDENTIFIED p06 4.0 SUBMISSIONS AND OBSERVATIONS p11 5.0 ASSESSMENT p16 6.0 CONCLUSION p22 7.0 RECOMMENDATION p23 Appendix I: Summary of Environmental Impact Statement p25 PL04.YA0005 An Bord Pleanála Page 2 of 77 Cork County Council 1.0 STATUTORY REQUIREMENTS Cork County Council, by letter of 7 th march 2008, applied to An Bord Pleanála for approval to the proposed Wastewater Treatment Plant in the townland of Shanbally, Co. Cork. The proposed Wastewater Treatment Plant is to cater for Cobh, Passage West, Monkstown, Ringaskiddy, Crosshaven and Carrigaline. The application included 3 copies of the Environmental Impact Statement which is in 3 volumes. The application is stated to be made under Section 175(3) and 226 of the Planning and Development Act 2000 and in accordance with Art 118 in part 10 of the Planning and Development Regulations 2001. A copy of the notice published in the Irish Examiner on 29 th February 2008 was also enclosed. Prescribed bodies were notified and the a copy of the letter of notification is enclosed. This states that the EIS has been issued to the prescribed bodies and was issued on 6 th March 2008. The prescribed bodies notified are given as follows: • An Chomhairle Ealaíon • Fáilte Ireland • An Taisce The National Trust for Ireland • Minister for Environment, Heritage and Local Government • Heritage Council • Cobh Town Council • Passage West Town Council • South Western Regional Fisheries Board (SWRFB) • Córas Iompar Éireann • EPA Headquarters • HSE Head Office • Minister for Communications, energy and Natural Resources • Minister for Agriculture Fisheries and Food • Railway Safety Commission The requirements of Article 121 of the Planning and Development Regulations (SI 600 of 2001) appear to have been complied with in relation to the notification of the Prescribed Bodies. 1.1 Responses / Submissions from Prescribed Bodies The prescribed bodies which responded were The Railway Safety Commission (RSC), the South Western Regional Fisheries Board (SWRFB), HSE-Southern Region, the Development Applications Unit of DEHLG and the Department of Agriculture, Fisheries and Food (Coastal Zone Management Section). Submissions were also received from 3 rd parties namely Mr Kevin Loftus and Mr Michael Barry. The submissions are described in Chapter 4.0 below. 1.2 Additional Information By letter of 25 th August 2008 the Board requested additional information form the Local Authority in relation to the following: • Extent of combined and separate sewerage systems in Cobh • Residence time of sewage in rising mains PL04.YA0005 An Bord Pleanála Page 3 of 77 Cork County Council • Robustness of cost comparisons in light of rising energy costs • Locations of existing outfalls and discharges • Consultation with River Basin District group • Water Quality data clarification. The Local Authority submitted the information by letter dated 12 th September 2008 and the responses are dealt with in paragraphs 4.9 to 4.15 below. 1.3 As the provisions of Regulation No 44 of the Wastewater Discharge (Authorisation) Regulations apply in this instance, the views of the EPA were sought by the Board in relation to the development by letter of 11 th December 2008. The EPA responded by letter of 17 th December 2008 and noted that pursuant to WWDA Regulations 2007, Cork County Council had submitted applications in respect of the following (existing) discharges: • D0057-01 Ringaskiddy / Carrigaline • D0129-01 Passsage West / Monkstown • D0140-01 Cork North • D0054-01 Cobh The EPA letter stated that the above applications were being assessed and that no application had been made in respect of the (proposed) Shanbally development. The views of the EPA in relation to the efficacy of the proposals as far as storm overflows is concerned is therefore not available at this time. 1.4 Cork County Council submitted Volumes 1, 2 and 5 of the Preliminary Report for the Cork Harbour Main Drainage Scheme as additional information as requested by the Board by letter of 19 th January 2009. The request for this documentation was to have clarity in relation to the proposals of the Local Authority in relation to stormwater discharges and on separation of foul and storm water within the sewer network. The assessment of this information is under Section 4.16 below. 1.5 I carried out a site inspection on 11 th August 2008. PL04.YA0005 An Bord Pleanála Page 4 of 77 Cork County Council 2.0 PROPOSED DEVELOPMENT The proposal is to construct a Wastewater Treatment Plant at Shanbally, approximately 2 kilometres west of Ringaskiddy on locally elevated ground. The proposed design capacity is for a plant of 80,000 p.e. and the proposal is to use an existing IDA outfall off Ringaskiddy towards Carlisle Fort on the east side of the outer harbour mouth. It is proposed to use the Design / Build / Operate form of procurement. The proposal also includes 4 No. major pumping stations at West Beach (Cobh) Carrigaloe, Monkstown and Rafeen operating effectively in series together with the diversion of the rising main from the existing Carrigaline (Church Road ) pumping station to the proposed WWTW. It also includes construction of a number of new smaller pumping stations and the incorporation of others into the network discharging to the proposed WWTW. In total there would be over 20 small and 5 large pumping stations in the expanded network. Stormwater tanks would be provided at individual pumping stations and the proposal is to pump forward 6-7 times dry weather flow from each pumping station with excess flows being held in storm tanks during heavy rainfall events. Emergency overflows are planned at pumping stations to allow for power outages etc. The proposed method of procurement of the project is by DBO and the EIS is not in a position to give details of actual proposed layout or systems. There are two different indicative layouts described in the text and outlined in figures 2.5 – 2.8 of the EIS. The estimation is that construction would take 2 years and there is a commitment that the maximum height of any building would be 12 metres above existing ground level. The location of the high voltage overhead power lines dictate the general layout of the plant and it is noted that there are less buildings and structures involved in the Sequencing Batch Reactor type layout. Control mechanisms to be provided are a Construction Environmental Management Plan, an Operational Environmental Management Plan and an Energy Management Plan. The provision of an extensive surface water system which would remove surface water from combined sewers is referred to in the EIS but is not detailed. PL04.YA0005 An Bord Pleanála Page 5 of 77 Cork County Council 3.0 IMPACTS IDENTIFIED 3.1 The EIS describes the impacts under 8 main headings as follows: • Human Beings • Terrestrial and Marine Ecology • Water Quality • Soils, Geology and Hydrogeology • Material Assets • Air Quality, Odour and Climate • Noise and Vibration • Cultural Heritage • Landscape and Visual impacts. The EIS also describes interactions . 3.2 Human Beings Land uses adjacent to the proposed WWTP site include a site with permission for residential development, the proposed realigned N28 and tourism and recreational uses. The harbour uses also include tourism and recreational uses. Construction activities identified include excavation, pipe-laying construction of the WWTP and pumphouses and a proposed Marine Crossing. The EIS states that the loss of 7.36 hectares of agricultural land for the WWTP would not be a significant impact. Raffeen and West Beach pumping stations would be built on reclaimed land. The prediction in the EIS is that there would be positive impacts for future development arising from the construction and operation of the WWTP. Traffic impacts are anticipated to be slight in the operational phase. The 2006 census figures are given as 32,411 for the catchment to be served and the plant design is for 80,000 p.e. The EIS states that the plant would facilitate increased residential and commercial development in the environs of the Lower Harbour. 3.3 Terrestrial and Marine Ecology Cork harbour is described as being connected to the Atlantic Ocean by a narrow inlet between Roches Point and Crosshaven and that inter-tidal flats are often muddy in character. The proposed Plant is located within 2 kilometres of the Great Island Channel SAC which stretches from Little Island to Middleton. Habitats are described in the EIS and are mainly rated as of local importance. However the habitat types “Estuaries and sea inlets and bays” , “Infralittoral gravels and sands” , “Mud Shore” and “mixed sediment shore” are rated of international importance. It is noted that the location of emergency storm outfalls is not determined. PL04.YA0005 An Bord Pleanála Page 6 of 77 Cork County Council The EIS notes that Cork Harbour is an area of international importance for wintering waterfowl and sections of the harbour are designated SPA, SAC and NHA. Near the proposed WWTP there is reference to a badger sett and mitigation is proposed. The harbour is stated to be an important nursery ground for juvenile fish before they return to sea. Adult mullet are noted grazing on algal films and the impact of the proposed WWTP is stated to be likely to impact on mullet. The EIS describes the impact on mullet arising from the removal of sewage outfalls as neutral.