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Dr. Karen Creed
Environmental Licencing Programme
Office of Climate, Licencing and Resource Use
Environmental Protection Agency
PO Box 3000
Johnstown Castle Estate
Wexford
21st December 2016
IW-ER-LT0324
Dear Karen,
RE: Clifden Waste Water Discharge Licence - Technical Amendment Application
D0198-01
The Agency issued a Wastewater Discharge Licence for the Clifden Agglomeration (D0198-01)
on the 19th December 2011. Irish Water now requests a Technical Amendment under Section
33 (1) of the Waste Water Discharge (Authorisation) Regulations 2007, to amend Schedule A.3
Storm Water Overflows, to include an additional stormwater overflow as follows:-
Licence
Code
SWO
Discharge
Location
Storm Water
Overflow Location
Name of
Receiving
Water
WFD Code Receiving
Water
SW005 065282E;
250136N
WWTP Storm Tank
Overflow
Clifden Bay IE_WE_270_0100
The stormwater overflow, which is not currently included by the Licence, is the overflow from
the storm tank at the wastewater treatment plant and discharges to the same location as the
Primary Discharge Point.
Irish Water has had regard to the EPA’s publication EPA Guidance for Irish Water on Requests
for Alterations to a Waste Water Discharge Licence or Certificate of Authorisation in compiling
this submission for a Technical Amendment.
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Appendix 1. Map of Stormwater Overflow Location
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Drawn By:Checked By:Approved By:
Drawing No.:Scale @ A3:
Drawn DateChecked Date:Approved Date:
1:7,244
Coordinate System: TM65 Irish GridProjection: Transverse Mercator
0 90 18045Meters
MBS
IW-AGG-2016-457
13/12/201613/12/201612/12/2016
FLRS
COY
Q
ClifdenWWTP
© Ordnance Survey Ireland
±1. No part of this drawing may be reproduced or transmitted in any form or stored in any retrieval system of any nature without the written permission of Irish Water as copyright holder except as agreed for use onthe project for which the document was originally issued.2. Whilst every care has been taken in its compilation, Irish Water gives this information as to the position of its underground network as a general guide only on the strict understanding that it is based on the bestavailable information provided by each Local Authority in Ireland to Irish Water. Irish Water can assume no responsibility for and give no guarantees, undertakings or warranties concerning the accuracy, completeness or up to date nature of the information provided and does not accept any liability whatsoever arising from any errors or omissions.This information should not be relied upon in the event of excavations or any other works being carried out in the vicinity of the Irish Water underground network. The onus is on the parties carry ing out excavations or any other works to ensure the exact location of the Irish Water underground network is identified prior to excavations or any other works being carried out. Service connection pipes are not generally shown but their presence should be anticipated.© Copyright Irish WaterReproduced from the Ordnance Survey Of Ireland by Permission of the Government. License No. 3-3-34 Map Template Design: kcarroll@water.ie
Location of Storm Water Overflow SW005 - Clifden
SW001 Primary DischargeSW005 Stormwater OverflowLocation: 065282 E; 250136 N
LegendQ WWTP
COY
Storm WaterOverflow
Cork
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Uisce Éireann Irish Water
Appendix 2. Appropriate Assessment Screening
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Irish Water
Report
Appropriate Assessment Screening as part of the Clifden Waste
Water Discharge Licence Technical Amendment
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2 | Irish Water AA Screening – Clifden Overflow
Contents
Introduction 3
Legislative Context 3
Methodology 5
Guidance Followed 5
Stages Involved in the Appropriate Assessment Process 6
Stage 1: Screening / Test of Significance 7
Screening 8
Description of the Project 8
Description of the Receiving Environment and Monitoring Results 9
Brief Description of the Natura 2000 Sites 10
Possible Effects of the Stormwater Tank Overflow on Natura 2000 Sites 16
Direct, Indirect or Secondary Impacts 16
Possible Cumulative Impacts with other Plans and Projects in the Area 17
Screening Assessment 18
Likely Changes to the Natura 2000 Site(s) 21
Elements of the Project where the Impacts are Likely to be Significant 21
Screening Conclusions and Statement 22
Finding of No Significant Effects Report Matrix 23
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3 | Irish Water AA Screening – Clifden Overflow
Introduction
This report provides an Appropriate Assessment (AA) Screening of a stormwater tank overflow
from the existing Waste Water Treatment Plant (WwTP) at Clifden, Co Galway, for the purposes
of the Waste Water Discharge (Authorisation) Regulations, 2007 (S.I. No. 684 of 2007), as
amended. It assesses whether the on-going operation of the overflow, alone or in combination
with other plans and projects, is likely to have significant effects on a Natura 2000 Site(s) in view
of best scientific knowledge and the conservation objectives of the site(s). Natura 2000 Sites are
those identified as sites of European Community importance designated as Special Areas of
Conservation under the Habitats Directive or as Special Protection Areas under the Birds
Directive.
This report follows the guidance for AA published by the Environmental Protection Agency’s
(EPA) ‘Note on Appropriate Assessments for the purposes of the Waste Water Discharge
(Authorisation) Regulations, 2007 (S.I. No. 684 of 2007)’ (EPA, 2009); and takes account of the
Department of the Environment, Heritage and Local Government’s guidelines ‘Appropriate
Assessment of Plans and Projects in Ireland. Guidance for Planning Authorities’ (DoEHLG, 2009)
and Circular L8/08 ‘Water Services Investment and Rural Water Programmes – Protection of
Natural Heritage and National Monuments’ (DoEHLG, 2008).
This report was written by a qualified ecologist working for Irish Water.
Legislative Context The Council Directive 92/43/EEC on the Conservation of Natural Habitats and of Wild Fauna and
Flora, better known as “The Habitats Directive”, provides legal protection for habitats and species
of European importance. Articles 3 to 9 provide the legislative means to protect habitats and
species of Community interest through the establishment and conservation of an EU-wide
network of sites known as Natura 2000. These are Special Areas of Conservation (SACs)
designated under the Habitats Directive and Special Protection Areas (SPAs) designated under
the Conservation of Wild Birds Directive (79/409/ECC) as codified by Directive 2009/147/EC.
Articles 6(3) and 6(4) of the Habitats Directive set out the decision-making tests for plans and
projects likely to affect Natura 2000 sites (Annex 1.1). Article 6(3) establishes the requirement for
Appropriate Assessment (AA):
Any plan or project not directly connected with or necessary to the management of the
[Natura 2000] site but likely to have a significant effect thereon, either individually or in
combination with other plans or projects, shall be subjected to appropriate assessment
of its implications for the site in view of the site’s conservation objectives. In light of the
conclusions of the assessment of the implications for the site and subject to the
provisions of paragraph 4, the competent national authorities shall agree to the plan or
project only after having ascertained that it will not adversely affect the integrity of the
site concerned and, if appropriate, after having obtained the opinion of the general
public.
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4 | Irish Water AA Screening – Clifden Overflow
Article 6(4) states:
If, in spite of a negative assessment of the implications for the [Natura 2000] site and in
the absence of alternative solutions, a plan or project must nevertheless be carried out
for imperative reasons of overriding public interest, including those of a social or
economic nature, Member States shall take all compensatory measures necessary to
ensure that the overall coherence of Natura 2000 is protected. It shall inform the
Commission of the compensatory measures adopted.
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5 | Irish Water AA Screening – Clifden Overflow
Methodology
Guidance Followed Both EU and national guidance exists in relation to Member States fulfilling their requirements
under the EU Habitats Directive, with particular reference to Article 6(3) and 6(4) of that Directive.
The methodology followed in relation to this AA Screening has had regard to the following
guidance:
Note on Appropriate Assessments for the purposes of the Waste Water Discharge
(Authorisation) Regulations, 2007 (S.I. No. 684 of 2007). Environmental Protection
Agency, (EPA, 2009).
Appropriate Assessment of Plans and Projects in Ireland: Guidance for Planning
Authorities. Department of Environment, Heritage and Local Government, (DoEHLG,
2010).
Circular L8/08 – Water Services Investment and Rural Water Programmes – Protection
of Natural Heritage and National Monuments. Department of Environment, Heritage and
Local Government, (DoEHLG, 2008).
Communication from the Commission on the Precautionary Principle. Office for Official
Publications of the European Communities, Luxembourg, (EC, 2000a).
Managing Natura 2000 Sites: the provisions of Article 6 of the ‘Habitats’ Directive
92/43/EEC, Office for Official Publications of the European Communities, Luxembourg,
(EC, 2000b).
Assessment of plans and projects 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).
Guidance document on Article 6(4) of the ‘Habitats Directive’ 92/43/EEC – Clarification
of the concepts of: alternative solutions, imperative reasons of overriding public interest,
compensatory measures, overall coherence, opinion of the Commission. Office for
Official Publications of the European Communities, Luxembourg, (EC, 2007).
Nature and biodiversity cases: Ruling of the European Court of Justice. Office for Official
Publications of the European Communities, Luxembourg (EC, 2006).
Marine Natura Impact Statements in Irish Special Areas of Conservation: A working
document, National Parks and Wildlife Service, Dublin (NPWS, 2012).
European Communities (Birds and Natural Habitats) Regulations, 2011 (S.I. No.477 of
2011).
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6 | Irish Water AA Screening – Clifden Overflow
Interpretation Manual of European Union Habitats. Version EUR 28. European
Commission (EC, 2013).
Stages Involved in the Appropriate Assessment Process
Stage 1: Screening / Test of Significance
This process identifies whether the stormwater tank overflow is directly connected to or
necessary for the management of a Natura 2000 Site(s); and identifies whether the overflow is
likely to have significant impacts upon a Natura 2000 Site(s) either alone or in combination with
other projects or plans.
The output from this stage is a determination for each Natura 2000 Site(s) of not significant,
significant, potentially significant, or uncertain effects. The latter three determinations will cause
that site to be brought forward to Stage 2.
Stage 2: Appropriate Assessment
This stage considers the impact of the stormwater tank overflow on the integrity of a Natura 2000
Site(s), either alone or in combination with other projects or plans, with respect to (1) the site’s
conservation objectives; and (2) the site’s structure and function and its overall integrity.
Additionally, where there are adverse impacts, an assessment of the potential mitigation of those
impacts
The output from this stage is a Natura Impact Statement (NIS). This document must include
sufficient information for the EPA to carry out the appropriate assessment. If the assessment is
negative, i.e. adverse effects on the integrity of a site cannot be excluded, then the process must
consider alternatives (Stage 3) or proceed to Stage 4.
Stage 3: Assessment of Alternatives
This process examines alternative ways of achieving the objectives of the project or plan that
avoid adverse impacts on the integrity of the Natura 2000 Site. This assessment may be carried
out concurrently with Stage 2 in order to find the most appropriate solution. If no alternatives
exist or all alternatives would result in negative impacts to the integrity of the Natura 2000 Sites
then the process either moves to Stage 4 or the project is abandoned.
Stage 4: Assessment Where Adverse Impacts Remain
An assessment of compensatory measures where, in the light of an assessment of Imperative
Reasons of Overriding Public Interest (IROPI), it is deemed that the project or plan should
proceed.
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7 | Irish Water AA Screening – Clifden Overflow
Stage 1: Screening / Test of Significance In complying with the obligations under Article 6(3) and following the appropriate guidelines, this
AA Screening has been structured as a stage by stage approach as follows:
Description of the project;
Identification of Natura 2000 sites potentially affected;
Identification and description of individual and cumulative impacts likely to result;
Assessment of the likely significance of the effects on the Natura 2000 site;
Exclusion of sites where it can be objectively concluded that there will be no significant
effects; and
Screening conclusion.
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8 | Irish Water AA Screening – Clifden Overflow
Screening
Description of the Project
Clifden is a town located 55 miles west of Galway City. The town is a market centre for the
surrounding agricultural area and has traditionally been a centre for tourism and angling in
Connemara. There is no significant industrial activity at present in the town.
The new Clifden WwTP was commissioned in 2015. The new plant discharges via a long-sea
outfall into the marine environment in the Owenglin estuary channel. The discharge location is to
a transitional water body (IE_WE_270_0100).
The agglomeration is served by a wastewater treatment plant with a Plant Capacity PE of 6,000.
The treatment process includes the following:-
preliminary treatment (including screening / grit removal)
secondary treatment -. SBR
chemical dosing for phosphorus removal
tertiary treatment – UV treatment
This assessment relates to an overflow from the stormwater tank which connects to the main
outfall discharge pipe downstream of the UV installation. The tank provides sufficient stormwater
storage (>2hrs at 3DWF), however in 2016 the number of overflows exceeded the requirement
for bathing waters. Options for reducing the frequency of these overflows are currently being
investigated.
The current population equivalent for the agglomeration is 3114 (2015 AER). Emission Limit
Values (ELV’s) set by Schedule A of EPA licence (as amended) for the primary discharge point
are 25mg/l BOD, 125mg/l COD, 35mg/l TSS and 2mg/l Total P. Effluent data for the primary
discharge from 2016 is presented in Table 1.0 together with the ELVs. The effluent discharge
meets the ELV’s for all relevant parameters.
Table 1.0: Clifden WwTP Effluent Monitoring Data
Date BOD COD SS Total Phosphorus
25mg/l 125mg/l 35mg/l 2mg/l
12/01/2016 2 10 2 0.56
09/02/2016 2 10 2 0.27
14/03/2016 2 15 2 0.88
04/04/2016 2 20 2 0.91
04/05/2016 2 31 11 0.35
08/06/2016 2 35 9 0.6
26/07/2016 2 32 7 0.88
02/08/2016 2 27 2 0.88
06/09/2016 2 23 2 0.34
10/10/2016 2 20 2 0.95
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9 | Irish Water AA Screening – Clifden Overflow
Description of the Receiving Environment and Monitoring Results
Monitoring data from a ‘downstream’ location by Galway County Council is provided below in
Table 2.0. The sample taken on 20/3/2015 is the only sample that was taken prior to the new
plant being commissioned. The grid reference for all of the ambient samples is East 65251 North
250155 and this location is shown on Figure 1.
Table 2.0: Clifden Bay Monitoring Data
Date BOD
mg/l
Total
Nitrogen
mg/l
Total
Phosphorus
mg/l
Ammonia
mg/l
DO
mg/l
Faecal
Coliforms
MPN/100ml
E.coli MPN
MPN/100ml
Intestinal
Enterococci
Cfu/100ml
20/03/15 <1 0.72 <0.05 0.35 10.9 380000 380000 5600
22/07/15 <1 0.69 <0.05 0.25 10.1 6300 6300 13
15/10/15 <1 0.69 <0.05 0.29 10.2 315 315 104
08/12/15 <1 <0.5 <0.05 0.08 9.9 140 140 15
21/03/16 <1 <0.5 <0.05 0.079 10 8500 8500 3700
26/07/16 <1 1.04 <0.05 0.015 10.3 7300 7300 3000
10/10/2016 <1 0.989 <0.05 0.03 9.5 1800 1800 3000
BOD measured is below the Surface Water Regulations EQS value for this parameter. There
are no Surface Water Regulations EQS values for Total Nitrogen and Total Phosphorus,
however given these parameters would be higher than DIN and MRP respectively, the results
obtained suggest they would meet the relevant EQS’s for Good status for mixed salinity waters.
Clifden Bay is a designated Shellfish Water and a classified production area. Clifden Bay inner
is Class A for clams and B for mussels, while Clifden Bay outer is Class A for clams. The Sea
Fisheries Protection Authority (SFPA) and Marine Institute (MI) monitor these waters for
compliance with the relevant water quality and shellfish flesh quality standards for designated
areas/production areas. A Shellfish Impact Assessment was submitted to the EPA with the 2014
AER as referenced in Section 5.2 of the 2015 AER which considered the SFPA/MI data. The
report identified that Clifden WwTP (pre-upgrade) was not impacting on the microbiological
quality of Shellfish. A review is proposed once the new plant has been operational for 1 year.
In terms of Water Framework Directive Status1, the transitional and coastal waterbodies of
Clifden Bay are currently unassinged. The EPA water quality status (2010-2012) is Unpolluted
for both the Clifden Bay transitional waterbody and the Western Atlantic Seaboard coastal
waterbody.
Bathing water quality at Clifden Beach is noted as ‘Changes –classification not yet possible’
while the effect of the new WwTP is monitored. Water quality results for this site have varied in
2016 with some Poor results still being recorded2.
1 http://gis.epa.ie/Envision/
2 http://splash.epa.ie/#idbw/IEWEBWT270_0100_0100
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10 | Irish Water AA Screening – Clifden Overflow
Brief Description of the Natura 2000 Sites
This section of the screening process describes the Natura 2000 sites within a 15km radius of
the stormwater tank overflow location. A 15km buffer zone has been chosen as a precautionary
measure, to ensure that all potentially affected Natura 2000 sites are included in the screening
process, which is in line with Appropriate Assessment of Plans and Projects in Ireland –
Guidance for Planning Authorities produced by the Department of the Environment, Heritage and
Local Government.
Table 3.0 lists the SACs and Table 4.0 lists the SPAs that are within 15km of the WwTP
discharge location, and Figure 1.0 shows their location in relation to the Clifden WwTP
discharge. The qualifying interests of each of the identified Natura 2000 Sites is also provided.
Table 3.0: SACs located within 15km from Clifden WwTP stormwater overflow
Site
Code
Site Name Qualifying Habitats Qualify Species
002031 Twelve Bens/Garraun
Complex SAC
Oligotrophic waters containing very
few minerals of sandy plains
(Littorelletalia uniflorae) [3110]
Oligotrophic to mesotrophic standing
waters with vegetation of the
Littorelletea uniflorae and/or Isoeto-
Nanojuncetea [3130]
Alpine and Boreal heaths [4060]
Blanket bogs (* if active bog) [7130]
Depressions on peat substrates of
the Rhynchosporion [7150]
Siliceous scree of the montane to
snow levels (Androsacetalia alpinae
and Galeopsietalia ladani) [8110]
Calcareous rocky slopes with
chasmophytic vegetation [8210]
Siliceous rocky slopes with
chasmophytic vegetation [8220]
Old sessile oak woods with Ilex and
Blechnum in the British Isles [91A0]
Margaritifera margaritifera
(Freshwater Pearl Mussel)
[1029]
Salmo salar (Salmon)
[1106]
Lutra lutra (Otter) [1355]
Najas flexilis (Slender
Naiad) [1833]
002034 Connemara Bog Complex
SAC
Coastal lagoons [1150]
Reefs [1170]
Oligotrophic waters containing very
few minerals of sandy plains
(Littorelletalia uniflorae) [3110]
Oligotrophic to mesotrophic standing
waters with vegetation of the
Euphydryas aurinia (Marsh
Fritillary) [1065]
Salmo salar (Salmon)
[1106]
Lutra lutra (Otter) [1355]
Najas flexilis (Slender
Naiad) [1833]
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11 | Irish Water AA Screening – Clifden Overflow
Site
Code
Site Name Qualifying Habitats Qualify Species
Littorelletea uniflorae and/or Isoeto-
Nanojuncetea [3130]
Natural dystrophic lakes and ponds
[3160]
Water courses of plain to montane
levels with the Ranunculion fluitantis
and Callitricho-Batrachion
vegetation [3260]
Northern Atlantic wet heaths with
Erica tetralix [4010]
European dry heaths [4030]
Molinia meadows on calcareous,
peaty or clayey-silt-laden soils
(Molinion caeruleae) [6410]
Blanket bogs (* if active bog) [7130]
Transition mires and quaking bogs
[7140]
Depressions on peat substrates of
the Rhynchosporion [7150]
Alkaline fens [7230]
Old sessile oak woods with Ilex and
Blechnum in the British Isles [91A0]
002074 Slyne Head Peninsula
SAC
Coastal lagoons [1150]
Large shallow inlets and bays [1160]
Reefs [1170]
Annual vegetation of drift lines
[1210]
Perennial vegetation of stony banks
[1220]
Atlantic salt meadows (Glauco-
Puccinellietalia maritimae) [1330]
Mediterranean salt meadows
(Juncetalia maritimi) [1410]
Embryonic shifting dunes [2110]
Shifting dunes along the shoreline
with Ammophila arenaria (white
dunes) [2120]
Machairs (* in Ireland) [21A0]
Oligotrophic waters containing very
few minerals of sandy plains
(Littorelletalia uniflorae) [3110]
Oligotrophic to mesotrophic standing
waters with vegetation of the
Petalophyllum ralfsii
(Petalwort) [1395]
Najas flexilis (Slender
Naiad) [1833]
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12 | Irish Water AA Screening – Clifden Overflow
Site
Code
Site Name Qualifying Habitats Qualify Species
Littorelletea uniflorae and/or Isoeto-
Nanojuncetea [3130]
Hard oligo-mesotrophic waters with
benthic vegetation of Chara spp.
[3140]
European dry heaths [4030]
Juniperus communis formations on
heaths or calcareous grasslands
[5130]
Semi-natural dry grasslands and
scrubland facies on calcareous
substrates (Festuco-Brometalia) (*
important orchid sites) [6210]
Molinia meadows on calcareous,
peaty or clayey-silt-laden soils
(Molinion caeruleae) [6410]
Lowland hay meadows (Alopecurus
pratensis, Sanguisorba officinalis)
[6510]
Alkaline fens [7230]
002265 Kingstown Bay SAC Large shallow inlets and bays [1160]
000330 Tully Mountain SAC European dry heaths [4030]
Alpine and Boreal heaths [4060]
002130 Tully Lough SAC Oligotrophic to mesotrophic standing
waters with vegetation of the
Littorelletea uniflorae and/or Isoeto-
Nanojuncetea [3130]
Najas flexilis (Slender
Naiad) [1833]
000328 Slyne Head Islands SAC Reefs [1170]
Halichoerus grypus (Grey
Seal) [1364]
0002998 West Connacht Coast
SAC
Tursiops truncatus
(Common Bottlenose
Dolphin) [1349]
002129 Murvey Machair SAC Machairs (* in Ireland) [21A0]
Petalophyllum ralfsii
(Petalwort) [1395]
001257 Dogs Bay SAC Annual vegetation of drift lines
[1210]
Embryonic shifting dunes [2110]
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13 | Irish Water AA Screening – Clifden Overflow
Site
Code
Site Name Qualifying Habitats Qualify Species
Shifting dunes along the shoreline
with Ammophila arenaria (white
dunes) [2120]
Fixed coastal dunes with
herbaceous vegetation (grey dunes)
[2130]
European dry heaths [4030]
001251 Cregduff Lough SAC Transition mires and quaking bogs
[7140]
Najas flexilis (Slender
Naiad) [1833]
000324 Rosroe Bog SAC Blanket bogs (* if active bog) [7130]
Depressions on peat substrates of
the Rhynchosporion [7150]
001311 Rusheenduff Lough Oligotrophic to mesotrophic standing
waters with vegetation of the
Littorelletea uniflorae and/or Isoeto-
Nanojuncetea [3130]
Najas flexilis (Slender
Naiad) [1833]
001228 Aughrusbeg Machair and
lake
Oligotrophic waters containing very
few minerals of sandy plains
(Littorelletalia uniflorae) [3110]
Northern Atlantic wet heaths with
Erica tetralix [4010]
001309 Omey Island Machair Machairs (* in Ireland) [21A0]
Hard oligo-mesotrophic waters with
benthic vegetation of Chara spp.
[3140]
Petalophyllum ralfsii
(Petalwort) [1395]
002118 Barnahallia Lough Oligotrophic to mesotrophic standing
waters with vegetation of the
Littorelletea uniflorae and/or Isoeto-
Nanojuncetea [3130]
Najas flexilis (Slender
Naiad) [1833]
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14 | Irish Water AA Screening – Clifden Overflow
Table 4.0: SPAs located within 15km of Clifden WwTP
Site Code Site Name Special Conservation Interests
004159 Slyne Head to Ardmore
Point Islands SPA
Barnacle Goose (Branta leucopsis) [A045]
Sandwich Tern (Sterna sandvicensis) [A191]
Arctic Tern (Sterna paradisaea) [A194]
Little Tern (Sterna albifrons) [A195]
004231 Inishbofin, Omey Island and
Turbot Island SPA
Corncrake (Crex crex) [A122]
004221 Illaunnanoon SPA Sandwich Tern (Sterna sandvicensis) [A191]
004170 Cruagh Island SPA Manx Shearwater (Puffinus puffinus) [A013]
Barnacle Goose (Branta leucopsis) [A045]
004181 Connemara Bog Complex
SPA
Cormorant (Phalacrocorax carbo) [A017]
Merlin (Falco columbarius) [A098]
Golden Plover (Pluvialis apricaria) [A140]
Common Gull (Larus canus) [A182]
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15 | Irish Water AA Screening – Clifden Overflow
Figure 1.0: Natura 2000 Sites
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16 | Irish Water AA Screening – Clifden Overflow
Possible Effects of the Stormwater Tank Overflow on Natura 2000 Sites
The purpose of this section of the screening is to examine the possibility that the stormwater tank
outfall, either individually or in combination with other plans and projects, may result in significant
negative effects on the Conservation Objectives and the integrity of the Natura 2000 Sites
identified.
The most apparent potential risk to a Natura 2000 Site(s) from a WwTP overflow is to the water
quality of the receiving environment, and if the receiving environments water quality has the
potential to interact with the qualifying interests of the Natura 2000 Sites identified. Using the
source-pathway-receptor model, the qualifying interests of two Natura 2000 sites have
connectivity with the overflow discharge:
Twelve Bens/Garraun Complex SAC
West Connacht Coast SAC
The Conservation Objectives of these sites were reviewed as part of this Screening Assessment:
NPWS (2016) Conservation objectives for The Twelve Bens/Garraun Complex SAC
[002031]. Generic Version 5.0. Department of Arts, Heritage, Regional, Rural and
Gaeltacht Affairs.
NPWS (2015) Conservation Objectives: West Connacht Coast SAC 002998. Version 1.
National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.
The Clifden WwTP and associated overflows is not directly connected with or necessary to the
management of the site for nature conservation.
Direct, Indirect or Secondary Impacts
The stormwater tank outfall discharges into the primary outfall pipe. As such existing ambient
monitoring is likely to detect any significant changes in water quality. It is noted that the
transitional and coastal waters of Clifden Bay are classed as Unpolluted by the EPA and meet
relevant Surface Water Regulations standards for Good status. They are also monitoring by the
SFPA and Marine Institute and maintain the water quality and shellfish flesh standards required
for a classified production area for shellfish. Bathing water quality has failed to meet the required
standards on a number of occasions in 2016 and there is the possibility that this has
corresponded with times when the overflow has been operational. In the context, the relevant
qualifying interests are identified below, and the likely impact of the overflow on their
conservation status is considered.
Salmon and Otter are qualifying interest of Twelve Bens/Garraun complex, and would be
associated with the Owenglin river which is designated as part of this SAC and is located ca.
600m to the east of the outfall. Salmon associated with the SAC would pass through the Clifden
Bay area on migration to and from the Owenglin River. Otter associated with the SAC may
forage in Clifden Bay. Bottlenose Dolphin are the qualifying interest of West Connacht coast
SAC ca. 4.7km to the west of the main outfall pipe and there is the possibility that they may
occasionally enter Clifden Bay.
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17 | Irish Water AA Screening – Clifden Overflow
The risk to these mobile species from the overflow is considered negligible. Ambient water
quality monitoring indicates there has been no overall water quality deterioration in the bay.
Given the stormwater overflow would only operate in times of heavy rain, any effluent released
would be extremely diluted. Its discharge via the main outfall pipe also provides significant
dispersal and dilution for any overflow discharge. While there may be a plume of reduced-
quality water at times when the overflow is operational, salmon would pass quickly through the
area. The overflow therefore is unlikely to impact any migrating salmon that would be moving
through the area should their movements through the bay happen to coincide with a time when
the overflow is operational. While otter associated with the SAC may rely to some extent on fish
stocks in the Clifden Bay area, it is not expected that the operation of the overflow would have
any impact on the diversity, abundance or biomass of fish species and no direct/indirect impacts
to otter are predicted. While their conservation status is not defined for this SAC, they are at
favourable conservation status nationally. Similarly, bottlenose dolphin may rely to some extent
on fish stocks in the area. This species is at favourable conservation status in the SAC and the
designated area and core population is located ca. 4.7km west of the overflow/primary outfall.
Given the dilution and dispersal available for any effluent in intervening coastal waters, no impact
to the population is predicted. Any occasional movement through the Clifden Bay area in the
vicinity of a diluted overflow discharge is not expected to affect the conservation status of this
species.
In accordance with the Waste Water Discharge (Authorisation) Regulations 2007 (S.I. No. 684 of
2007) the waste water discharged from the Clifden stormwater tank overflow does not have the
potential to impact the relevant qualifying interests identified, and therefore will no affect the
conservation objectives of the Twelve Bens/Garraun Complex SAC or West Connacht Coast
SAC. No significant adverse impacts on the Annex II species are anticipated as a result of the
stormwater overflow from Clifden WwTP.
No significant adverse impacts on the qualifying interests of the remaining Natura 2000 Sites
identified within 15km of the overflow discharge location is considered likely due to lack of
hydrological connection between the discharge and the relevant terrestrial SACs and SPAs, or
the dilution and dispersion provided by intervening coastal waters for remote coastal/marine
SACs and SPA sites.
Possible Cumulative Impacts with other Plans and Projects in the Area
As part of Stage 1 Screening, in addition to the stormwater overflow, other relevant projects and
plans in the relevant region must also be considered. This step aims to identify at this early stage
any possible significant effects on the Natura 2000 Sites from the waste water discharge in-
combination or cumulative with other plans and projects. Existing plans which have been
examined include:
Galway County Development Plan 2015-2021;
West Galway Management Unit Action Plan3; and
Clifden Tidy Towns Biodiversity Plan 2014-2018.
3 http://wfdireland.ie/docs/1_River%20Basin%20Management%20Plans%202009%20-
%202015/WRBD%20RBMP%202010/Water%20Management%20Unit%20Action%20Plans/West%20Galway%20WMU_190310.pdf
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18 | Irish Water AA Screening – Clifden Overflow
The above plans have been assessed in accordance with Article 6(3) of the Habitats Directive
and Part XAB of the Planning and Development Act, 2000, and are not envisaged to result in
significant effects on the integrity of the Natura 2000 network.
The potential cumulative/in-combination impacts with the existing Clifden WwTP and wastewater
network were also considered. The primary discharge is now compliant with the licence ELV’s
and the requirements of the UWWT Directive. Appropriate Assessment was carried out for the
new scheme and, once operated within the terms of its licence, it was concluded there would be
no adverse effects on any Natura 2000 site. The overflow has no potential to contribute to
cumulative impacts with the existing wastewater infrastructure at Clifden.
Galway County Council online planning maps were reviewed for any significant developments
that have the potential to contribute to cumulative impacts. A school development was granted
permission in 2015 (Planning Ref 15671). The development was subject to Appropriate
Assessment with no significant effects predicted for any Natura 2000 site. A packaged
Envirocare sewage treatment system will be installed as part of the development.
Screening Assessment Table 5.0 provides a summary of the likely significant impact of the current overflow discharge on
the conservation objectives of the Natura 2000 sites potentially linked to the Clifden WwTP
stormwater tank overflow as identified in Tables 3.0 and 4.0.
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19 | Irish Water AA Screening – Clifden Overflow
Table 5.0: Potential Significant Impacts on Natura 2000 sites from the Clifden Overflow Discharge
Site Name Direct Impacts
Indirect/ Secondary
Resource Requirements (Drinking Water Abstraction Etc.)
Emissions (Disposal to Land, Water or Air)
Excavation Requirements
Transportation Requirements
Duration of Construction, Operation, Decommissioning
Twelve Bens/Garraun
Complex SAC
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
Connemara Bog Complex
SAC
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
Slyne Head Peninsula
SAC
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
Kingstown Bay SAC No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
Tully Mountain SAC No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
Tully Lough SAC No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
Slyne Head Islands SAC No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
West Connacht Coast
SAC
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
Murvey Machair SAC No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
Dogs Bay SAC No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
Cregduff Lough SAC No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
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20 | Irish Water AA Screening – Clifden Overflow
Site Name Direct Impacts
Indirect/ Secondary
Resource Requirements (Drinking Water Abstraction Etc.)
Emissions (Disposal to Land, Water or Air)
Excavation Requirements
Transportation Requirements
Duration of Construction, Operation, Decommissioning
Rosroe Bog SAC No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
Rusheenduff Lough No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
Aughrusbeg Machair and
lake
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
Omey Island Machair No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
Barnahallia Lough No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
Slyne Head to Ardmore
Point Islands SPA
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
Inishbofin, Omey Island
and Turbot Island SPA
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
Illaunnanoon SPA No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
Cruagh Island SPA No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
Connemara Bog Complex
SPA
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
No impact on qualifying interest
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21 | Irish Water AA Screening – Clifden Overflow
Likely Changes to the Natura 2000 Site(s)
The likely changes that will arise from the Clifden overflow discharge have been examined in the
context of a number of factors that could potentially affect the integrity of the identified Natura
2000 Sites. Overall, it has been found that the current overflow discharge will not affect the
integrity of the identified Natura 2000 Sites, alone or in-combination with other plans or projects.
Table 6.0: Likely Affect on Natura 2000 Sites
Site Name Reduction
of Habitat
Area
Disturbanc
e to Key
Species
Habitat or
Species
Fragmentation
Reductio
n in
Species
Density
Changes in
Key Indicators
of
Conservation
Value (Water
Quality Etc.)
Climate
Change
Twelve Bens/Garraun
Complex SAC
None None None None None None
Connemara Bog
Complex SAC
None None None None None None
Slyne Head Peninsula
SAC
None None None None None None
Kingstown Bay SAC None None None None None None
Tully Mountain SAC None None None None None None
Tully Lough SAC None None None None None None
Slyne Head Islands SAC None None None None None None
West Connacht Coast
SAC
None None None None None None
Murvey Machair SAC None None None None None None
Dogs Bay SAC None None None None None None
Cregduff Lough SAC None None None None None None
Rosroe Bog SAC None None None None None None
Rusheenduff Lough None None None None None None
Aughrusbeg Machair
and lake
None None None None None None
Omey Island Machair None None None None None None
Barnahallia Lough None None None None None None
Slyne Head to Ardmore
Point Islands SPA
None None None None None None
Inishbofin, Omey Island
and Turbot Island SPA
None None None None None None
Illaunnanoon SPA None None None None None None
Cruagh Island SPA None None None None None None
Connemara Bog
Complex SPA
None None None None None None
Elements of the Project where the Impacts are Likely to be Significant
No elements of the current overflow discharge are likely to cause significant impacts on NATURA
2000 Sites.
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22 | Irish Water AA Screening – Clifden Overflow
Screening Conclusions and
Statement
The likely impacts that will arise from the current stormwater overflow discharge have been
examined in the context of a number of factors that could potentially affect the integrity of the
Natura 2000 network. None of the sites within 15km of the discharge location will be adversely
affected. A finding of No Significant Effects Matrix has been completed and is presented in next
section of this Screening Statement.
On the basis of the findings of this Screening for Appropriate Assessment of Natura 2000 Sites, it
is concluded that the current overflow discharge from the Clifden overflow will not have a
significant effect on the Natura 2000 network and a Stage 2 Appropriate Assessment is not
required.
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23 | Irish Water AA Screening – Clifden Overflow
Finding of No Significant Effects
Report Matrix
Name of project or plan
Name and location of Natura 2000 site Twelve Bens/Garraun Complex SAC
West Connacht Coast SAC
Description of the project or plan The new Clifden WwTP was commissioned in 2015. The
new plant discharges via a long-sea outfall into the
marine environment in the Owenglin estuary channel.
The discharge location is to a transitional water body
(IE_WE_270_0100).
The agglomeration is served by a wastewater treatment
plant with a Plant Capacity PE of 6,000. The treatment
process includes the following:-
preliminary treatment (including screening / grit
removal)
secondary treatment -. SBR
chemical dosing for phosphorus removal
tertiary treatment – UV treatment
This assessment relates to an overflow from the
stormwater tank which connects to the main outfall
discharge pipe downstream of the UV installation. The
tank provides sufficient stormwater storage (>2hrs at
3DWF), however in 2016 the number of overflows
exceeded the requirement for bathing waters. Options
for reducing the frequency of these overflows are
currently being investigated.
Is the project or plan directly
connected with or necessary to the
management of the site?
No.
Are there other projects or plans that
together with the project or plan being
assessed could affect the site?
No.
The Assessment of Significance of Effects
Describe how the project or plan
(alone or in combination) is likely to
affect the European Site(s).
The stormwater tank outfall discharges into the primary
outfall pipe. As such existing ambient monitoring is likely
to detect any significant changes in water quality. It is
noted that the transitional and coastal waters of Clifden
Bay are classed as Unpolluted by the EPA and meet
relevant Surface Water Regulations standards for Good
status. They are also monitoring by the SFPA and
Marine Institute and maintain the water quality and
shellfish flesh standards required for a classified
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24 | Irish Water AA Screening – Clifden Overflow
production area for shellfish. Bathing water quality has
failed to meet the required standards on a number of
occasions in 2016 and there is the possibility that this has
corresponded with times when the overflow has been
operational. In the context, the relevant qualifying
interests are identified below, and the likely impact of the
overflow on their conservation status is considered.
Salmon and Otter are qualifying interest of Twelve
Bens/Garraun complex, and would be associated with
the Owenglin river which is designated as part of this
SAC and is located ca. 600m to the east of the outfall.
Salmon associated with the SAC would pass through the
Clifden Bay area on migration to and from the Owenglin
River. Otter associated with the SAC may forage in
Clifden Bay. Bottlenose Dolphin are the qualifying
interest of West Connacht coast SAC ca. 4.7km to the
west of the main outfall pipe and there is the possibility
that they may occasionally enter Clifden Bay.
Explain why these effects are not
considered significant. The risk to these mobile species from the overflow is
considered negligible. Ambient water quality monitoring
indicates there has been no overall water quality
deterioration in the bay. Given the stormwater overflow
would only operate in times of heavy rain, any effluent
released would be extremely diluted. Its discharge via
the main outfall pipe also provides significant dispersal
and dilution for any overflow discharge. While there may
be a plume of reduced-quality water at times when the
overflow is operational, salmon would pass quickly
through the area. The overflow therefore is unlikely to
impact any migrating salmon that would be moving
through the area should their movements through the bay
happen to coincide with a time when the overflow is
operational. While otter associated with the SAC may
rely to some extent on fish stocks in the Clifden Bay area,
it is not expected that the operation of the overflow would
have any impact on the diversity, abundance or biomass
of fish species and no direct/indirect impacts to otter are
predicted. While their conservation status is not defined
for this SAC, they are at favourable conservation status
nationally. Similarly, bottlenose dolphin may rely to some
extent on fish stocks in the area. This species is at
favourable conservation status in the SAC and the
designated area and core population is located ca. 4.7km
west of the overflow/primary outfall. Given the dilution
and dispersal available for any effluent in intervening
coastal waters, no impact to the population is predicted.
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25 | Irish Water AA Screening – Clifden Overflow
Any occasional movement through the Clifden Bay area
in the vicinity of a diluted overflow discharge is not
expected to affect the conservation status of this species.
In accordance with the Waste Water Discharge
(Authorisation) Regulations 2007 (S.I. No. 684 of 2007)
the waste water discharged from the Clifden stormwater
tank overflow does not have the potential to impact the
relevant qualifying interests identified, and therefore will
no affect the conservation objectives of the Twelve
Bens/Garraun Complex SAC or West Connacht Coast
SAC. No significant adverse impacts on the Annex II
species are anticipated as a result of the stormwater
overflow from Clifden WwTP.
List of agencies consulted: provide
contact name and telephone or e-mail
address.
N/A
Response to consultation. N/A
Data Collected to Carry Out the Assessment
Who carried out the assessment? Qualified Ecologist, Irish Water
Sources of data NPWS database;
EPA database;
WFD Ireland database; and
Information from Irish Water.
Level of assessment completed Desktop survey
Where can the full results of the
assessment be accessed and viewed?
EPA
Overall Conclusion Stage 1 Screening indicates that the Clifden WwTP
stormwater overflow discharge will not have a significant
negative impact on the Natura 2000 network. Therefore, a
Stage 2 'Appropriate Assessment' under Article 6(3) of the
Habitats Directive 92/43/EEC is not required.
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