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CYJ-JBAI-XX-XX-RP-BD-0001-A4-C01_NIS_Clondalkin_Metal_Processors i

Clondalkin

Metal Processors Ltd.

Natura Impact Statement

July 2020

www.jbaconsulting.com

Metal Processors Ltd Station Rd,

Clondalkin Industrial Estate,

Ballymanaggin, Dublin 22,

D22 T102

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CYJ-JBAI-XX-XX-RP-BD-0001-A4-C01_NIS_Clondalkin_Metal_Processors i

JBA Project Manager

Niamh Burke

8 Greenogue Business Plaza

Greenogue Business Park

Rathcoole

Co. Dublin

Revision History

Revision Ref/Date Amendments Issued to

26/06/2020 Draft Report Metal Processors Ltd.

02/07/2020 Final Report Metal Processors Ltd.

Contract

This report describes work commissioned by Environmental Efficiency, on behalf of Metal

Processors Ltd., by a JBA acceptance form dated 5 February 2020. Environmental

Efficiency’s representative for the contract was Richard Deeney. Joe Freijser and William

Mulville of JBA Consulting carried out this work.

Prepared by .................................. William Mulville BSc (Hons), MSc, ACIEEM

Assistant Ecologist

.................................................... Joe Freijser BA MSc

Ecologist

Reviewed by .................................. Niamh Burke BSc (Hons), PhD, CEnv, MCIEEM

Principal Ecologist

Purpose

This document has been prepared as a Final Report for Environmental Efficiency. JBA

Consulting accepts no responsibility or liability for any use that is made of this document

other than by the Client for the purposes for which it was originally commissioned and

prepared.

JBA Consulting has no liability regarding the use of this report except to Environmental

Efficiency.

Copyright

© Jeremy Benn Associates Limited 2020.

Carbon Footprint

A printed copy of the main text in this document will result in a carbon footprint of 58g if

100% post-consumer recycled paper is used and 73g if primary-source paper is used. These

figures assume the report is printed in black and white on A4 paper and in duplex.

JBA is aiming to reduce its per capita carbon emissions.

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CYJ-JBAI-XX-XX-RP-BD-0001-A4-C01_NIS_Clondalkin_Metal_Processors ii

Contents

1 Introduction 1 1.1 Background 1 1.2 Summary of the Screening Assessment 1 1.3 Legislative Context 1 1.4 Appropriate Assessment Process 2 1.4.1 Stage 1 - Screening for AA 2 1.4.2 Stage 2 – AA 2 1.4.3 Stage 3- Alternative Solutions 3 1.4.4 Stage 4 – IROPI 3 1.5 Methodology 3 1.6 Desktop Survey 3 1.7 Competent Persons 4 1.7.1 Limitations and Constraints 4 2 Project Description 5 2.1 The 'Project' 5 2.2 Site Location 5 2.3 Proposed Project 6 2.3.1 Background 6 2.3.2 Development of a Dual Flow Drainage System 6 2.4 Project Zone of Influence 7 2.5 Project Summary 7 3 Screening Assessment 9 3.1 Natura 2000 Sites 9 3.1.1 Screened-out Qualifying Interests 9 4 Environmental Baseline 27 4.1 Site survey 27 4.1.1 Methodology 27 4.2 Habitats 27 4.2.1 Buildings and artificial surfaces (BL3) 28 4.2.2 Amenity grassland (improved) (GA2) 28 4.2.3 Treelines (WL2) 28 4.2.4 Ornamental/non-native shrub (WS3) 28 4.3 Invasive Non-native Species 28 4.4 Waterbodies within the Vicinity of the Proposed Site 28 4.4.1 Water Quality 29 4.4.2 Water Sampling Results (JBA,2020) 29 4.4.3 Qualifying Interests present within the ZoI 31 4.4.4 Non-Qualifying Interest, Protected Species within the ZoI 32 5 Other Relevant Plans and Projects 35 5.1 Cumulative effects 35 5.1.1 South Dublin County Council Development Plan (2016-2022) 35 5.1.2 River Basin Management Plan for Ireland 2018-2021 35 5.1.3 Other Projects 35 5.1.4 Summary 36 6 Appropriate Assessment 37 6.1 Introduction 37 6.2 Potential Sources of Impact via Surface Water Pathways 37 6.2.1 Construction Phase - Direct impacts 37 6.2.2 Construction Phase – Indirect impacts 49

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CYJ-JBAI-XX-XX-RP-BD-0001-A4-C01_NIS_Clondalkin_Metal_Processors iii

6.2.3 Operational Impacts 54 6.2.3.1 Air & Dust 54 6.2.3.2 Surface water & Groundwater 54 6.2.4 Do Nothing Impact 54 6.2.5 Significance of Cumulative and In-combination Impacts 55 6.3 Mitigation Measures 55 6.3.1 Adherence to Best Practice Guidance 55 6.3.2 Water Quality 55 6.3.3 Pollution Control and Spill Prevention 56 6.3.4 General storage, site-cleaning and air/dust-based mitigations 57 6.3.5 Post-Installation Monitoring programme 58 6.4 Residual Impacts 58 6.4.1 Additional Note on Non-QI, Protected Species potentially present within the

ZoI 83 7 Conclusions 84 A Site Drainage Layout (including Dual Flow Drainage System) I

B Dual Flow System II

C Habitat Map III

List of Figures

Figure 1-1: The Appropriate Assessment Process (from: Appropriate Assessment of

Plans and Projects in Ireland - Guidance for Planning Authorities, DoEHLG, 2009) 2 Figure 2-1 Site location of Metal Processors Ltd. 5 Figure 3-1: Natura 2000 site and site location. 9 Figure 4-1: Habitat Map. 27 Figure 4-2: Rivers, canals and surface water catchment within the vicinity of the

proposed site; and hydrologically connected to the River Liffey (Dublin Bay). 29

List of Tables

Table 2-1: Summary of project elements relevant to ecology of the Natura 2000 sites

within the ZoI. 7 Table 3-1: Natura 2000 sites within the ZoI and their respective site briefs. 10 Table 3-2: Natura 2000 sites within the ZoI and their respective qualifying interests

and conservation objectives. 11 Table 3-3: Natura 2000 sites within the ZoI with their respective site threats and

pressures of relevance to the proposed development’s construction and operation. 26 Table 4-1: Habitats recorded on the site visit (Fossitt classifications). 28 Table 4-2: Water chemistry sampling results from Gallanstown Stream 30 Table 4-3: Non-QI, Protected Species potentially present within the ZoI. 32 Table 5-1: Projects granted planning permission within vicinity of the proposed site

and local watercourse. 35 Table 6-1: Potential direct impacts on the attributes of the designated features of the

North Dublin Bay SAC within the ZoI of the proposed project. 38 Table 6-2: Potential direct impacts on the attributes of the designated features of the

South Dublin Bay SAC within the ZoI of the proposed project. 42 Table 6-3: Potential direct impacts on the attributes of the designated features of the

North Bull Island SPA within the ZoI of the proposed project. 45

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CYJ-JBAI-XX-XX-RP-BD-0001-A4-C01_NIS_Clondalkin_Metal_Processors iv

Table 6-4: Potential direct impacts on the attributes of the designated features of the

South Dublin Bay and River Tolka Estuary SPA within the ZoI of the proposed project. 46 Table 6-5: Potential indirect impacts on the attributes of the designated features of

North Bull Islands SPA within the ZoI of the proposed project. 49 Table 6-6: Potential indirect impacts on the attributes of the designated features of

South Dublin Bay and River Tolka Estuary SPA within the ZoI of the proposed project. 51 Table 6-7: Pathways of impact on the attributes of the designated QIs of the Dublin

Bay Natura 2000 sites. 59

Abbreviations

AA Appropriate Assessment

DoEHLG Department of Environment, Heritage and Local Government

EC European Communities

EPA Environmental Protection Agency

EU European Union

GIS Geographical Information Systems

IROPI Imperative Reasons of Over-riding Public Interest

NBDC National Biodiversity Data Centre

NIS Natura Impact Statement

NOx Nitrogen oxides

NPWS National Parks and Wildlife Service

PM Particulate matter

QI Qualifying Interest

RBMP River Basin Management Plan

SAC Special Area of Conservation

SPA Special Protection Area

WFD Water Framework Directive

ZoI Zone of Influence

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CYJ-JBAI-XX-XX-RP-BD-0001-A4-C01_NIS_Clondalkin_Metal_Processors

1

1 Introduction

1.1 Background

JBA Consulting was appointed by Environmental Efficiency to undertake a Natura Impact

Assessment in relation to an Industrial Emissions License Review Application on behalf of

Metal Processors Ltd.

1.2 Summary of the Screening Assessment

Following an initial Screening carried out by Environmental Efficiency (2019), where it was

concluded that significant adverse impacts were unlikely. However, the Planning Authority

(the Competent Authority) disagreed with this conclusion and subsequently JBA Consulting

was asked to carry out a full (stage 2 AA) Natura Impact Statement. Because there is an

unrestricted surface water connection with Dublin Bay, and it concerns heavy metal

pollution, it is concluded that there are likely significant effects from the project on the

Natura 2000 sites in Dublin Bay.

Given the Planning Authority’s focus on potential impact to the Dublin Bay Natura 2000

sites, this NIS report will solely examine these Natura 2000 sites in respect to the potential

impacts derived from the construction and operations of this development.

1.3 Legislative Context

Directive 92/43/EEC on the Conservation of Natural Habitats and Wild Fauna and Flora,

known as the ‘Habitats Directive’ - provides legal protection for habitats and species of

European importance. Article 2 of the Directive requires the maintenance or restoration of

habitats and species of European Community interest, at a favourable conservation status.

Articles 3 - 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 sites. Natura 2000 sites 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 / EEC).

Articles 6(3) and 6(4) of the Habitats Directive set out the decision-making tests for plans

or projects affecting Natura 2000 sites. Article 6(3) establishes the requirement for

Appropriate Assessment:

“Any plan or project not directly connected with or necessary to the management of the

site but likely to have a significant effect thereon, either individually or in combination with

other plans or projects, shall be subject to appropriate assessment of its implications for

the site in view of the site's conservation objectives. In the 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.”

Article 6(4) deals with the steps that should be taken when it is determined, as a result of

Appropriate Assessment, that a plan/project will adversely affect a Natura 2000 site.

Issues dealing with alternative solutions, imperative reasons of overriding public interest

and compensatory measures need to be addressed in this case.

Article 6(4) states:

“If, in spite of a negative assessment of the implications for the 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, the

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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Where the site concerned hosts a priority natural habitat type and / or a priority species,

the only considerations which may be raised are those relating to human health or public

safety, to beneficial consequences of primary importance for the environment or, further to

an opinion from the Commission, to other imperative reasons of overriding public interest.”

The requirements of Articles 6(3) and 6(4) of the Habitats Directive have been transposed

into Irish legislation by means of the Habitats Regulations, 1997 (S.I. No. 94 of 1997) and

the European Communities (Birds and Natural Habitats) Regulations 2011 (S.I. No. 477 /

2011).

1.4 Appropriate Assessment Process

Guidance on the Appropriate Assessment (AA) process was produced by the European

Commission in 2002, which was subsequently developed into guidance specifically for

Ireland by the Department of Environment, Heritage and Local Government (DoEHLG)

(2009). These guidance documents identify a staged approach to conducting an AA, as

shown in Figure 1-1.

Figure 1-1: The Appropriate Assessment Process (from: Appropriate Assessment of Plans

and Projects in Ireland - Guidance for Planning Authorities, DoEHLG, 2009)

1.4.1 Stage 1 - Screening for AA

The initial, screening stage of the Appropriate Assessment is to determine:

a. whether the proposed plan or project is directly connected with or necessary for the

management of the Natura 2000 site for nature conservation

b. if it is likely to have a significant adverse effect on the Natura 2000 site, either

individually or in combination with other plans or projects

For those sites where potential adverse impacts are identified, either alone or in

combination with other plans or projects, further assessment is necessary to determine if

the proposals will have an adverse impact on the integrity of a Natura 2000 site, in view of

the sites conservation objectives (i.e. the process proceeds to Stage 2).

1.4.2 Stage 2 – AA

This stage requires a more in-depth evaluation of the plan or project, and the potential

direct and indirect impacts of them on the integrity and interest features of the European

designated site(s), alone and in-combination with other plans and projects, taking into

account the site's structure, function and conservation objectives. Where required,

mitigation or avoidance measures will be suggested.

The competent authority can only agree to the plan or project after having ascertained that

it will not adversely affect the integrity of the site(s) concerned. If this cannot be

determined, and where mitigation cannot be achieved, then alternative solutions will need

to be considered (i.e. the process proceeds to Stage 3).

Screening for

AA

Stage 2

AA

Stage 4

IROPI

Stage 3

Alternative

Solutions

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1.4.3 Stage 3- Alternative Solutions

Where adverse impacts on the integrity of Natura 2000 sites are identified, and mitigation

cannot be satisfactorily implemented, alternative ways of achieving the objectives of the

plan or project that avoid adverse impacts need to be considered. If none can be found, the

process proceeds to Stage 4.

1.4.4 Stage 4 – IROPI

Where adverse impacts of a plan or project on the integrity of Natura 2000 sites are

identified and no alternative solutions exist, the plan will only be allowed to progress if

imperative reasons of overriding public interest can be demonstrated. In this case

compensatory measures will be required.

The process only proceeds through each of the four stages for certain plans or projects. For

example, for a plan or project, not connected with management of a site, but where no

likely significant impacts are identified, the process stops at stage 1. Throughout the

process, the precautionary principle must be applied, so that any uncertainties do not result

in adverse impacts on a site.

This report is in support of a Stage 1 Screening for Appropriate Assessment.

1.5 Methodology

The Screening for Appropriate Assessment has been carried out with reference to the

following documents:

• DoEHLG (2009 rev 2010) Appropriate Assessment of Plans and Projects in

Ireland Guidance for Planning Authorities. Department of the Environment,

Heritage and Local Government (DoEHLG 2009).

• European Communities (EC) (2000) Managing Natura 2000 Sites: the provisions

of Article 6 of the ‘Habitats’ Directive 92/43/EEC, Office for Official Publications

of the European Communities, Luxembourg. European Commission (European

Commission and Office for Official Publications of the European Communities

2000).

• EC (2002) Assessment of Plans and Projects Significantly Affecting Natura 2000

Sites: Methodological guidance on the provisions of Article 6(3) and (4) of the

Habitats Directive 92/43/EEC, Office for Official Publications of the European

Communities, Luxembourg. European Commission (EC 2002).

• EC (2007) Guidance document on Article 6(4) of the 'Habitats Directive'

92/43/EEC – Clarification of the concepts of: alternative solutions, imperative

reasons of overriding public interest, compensatory measures, overall coherence,

opinion of the commission. European Commission (EC 2007).

• CIEEM (2018) Guidelines for Ecological Impact Assessment for the UK and

Ireland: Terrestrial, Freshwater, Coastal and Marine.

• Fossitt, J. (2000). A Guide to Habitats in Ireland. The Heritage Council, Kilkenny

A site visit was completed by JBA in March 2020 and is discussed in this report.

1.6 Desktop Survey

A desktop survey was conducted of available published and unpublished information, along

with a review of data available on the NPWS and National Biodiversity Data Centre web-

based databases, in order to identify key habitats and species that may be present within

relevant 2km grid squares, in particular those protected by European and national

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legislation. The data sources this assessment has been collected in a range of formats,

from a range of sources, including;

• NPWS website (NPWS 2020) where site synopses, Natura 2000 data forms and

conservation objectives were obtained.

• National Biodiversity Data Centre (NBDC 2020)

• Environmental Protection Agency (EPA 2020)

• River Basin Management Plans (RBMP) (www.wfdireland.ie)

• The National Planning website (DoHPLG 2020)

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

versions used, available at the time of issue.

1.7 Competent Persons

The assessment has been carried out by Joe Freijser and William Mulville. They are both

ecologists with JBA and have undertaken numerous Appropriate Assessment screenings and

NIS assessments. The assessment has been reviewed by Dr Niamh Burke, a Principal

ecologist with over 11 years' experience in undertaking assessments under the Habitats

Directive.

1.7.1 Limitations and Constraints

The NIS assessment necessarily relies on some assumptions and it was inevitably subject

to some limitations. These would not affect the conclusion, but the following points are

recorded in order to ensure the basis of the assessment is clear:

• The levels of heavy metals measured in water samples taken at different times

under different circumstances may not show the entire picture of heavy metal

effluent from the site. However, every measure was taken to ensure high quality

results were obtained by using the same sampling locations and procedures.

• The ecological surveys were carried adjacent to site and along Gallanstown

Stream on the 04/03/2020.

• Information on the works and conditions on site are based on current knowledge

at the time of writing. Changes to the site since surveys were undertaken cannot

be accounted for.

• Some slight variation in the works methodology may occur, but these will only

be minor changes. Where changes to methodology could impact on ecological

features, an ecologist will be consulted to determine if the project needs

reassessment.

• Adverse weather can cause delays to the schedule and alter the timing of works.

This has been accounted for using a worst-case scenario where necessary.

• The NIS addresses issues around designated sites and does not exempt works

from responsibilities related to habitats and species covered under separate

national legislation.

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2 Project Description

2.1 The 'Project'

The proposed development meets the criteria of a 'Project' as defined in the Habitats

Directive and is not directly connected with or necessary to the management of any Natura

2000 site. Therefore, the Project is subject to the requirements of the Appropriate

Assessment process.

2.2 Site Location

The site is located on Station Road (L10006), Clondalkin, Dublin 22. It is situated in

Clondalkin Industrial Estate and is immediately surrounded by commercial and industrial

facilities in all directions. The site itself comprises of a number of industrial and

administrative buildings surrounded by large areas of yard. It is bordered to the north by

the Dublin to Cork Railway Line. Ronanstown lies to the north of the site and Clondalkin lies

to the south and west. The M50 motorway runs to the east of the site.

The nearest residential dwellings are houses situated in James Connolly Park housing estate

which is approximately 100 m to the south-west of the site. In addition, residential

dwellings are located on Station Road to the south west of the site, Ballymanaggin Lane to

the south of the site and in Raheen to the north west of the site.

The Grand Canal Greenway is situated approximately 300 meters south of the site. The

Gallanstown Stream, which runs alongside the canal is situated approximately 280 meters

to the south of the site and the River Camac, which the Gallanstown eventually flows into,

is situated approximately 760 meters to the south-east of the site.

An aerial photo showing the site and its surroundings is shown in Figure 2-1 below. A Site

Location Map for the facility is shown in Appendix A.

Figure 2-1 Site location of Metal Processors Ltd.

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2.3 Proposed Project

2.3.1 Background

Metal Processors Ltd are a subsidiary of the Calder Group and are involved in the

manufacture of sheet lead for roof flashing. The company employs 25 people and occupies

an industrial site in Clondalkin Industrial Estate, Dublin 22.

Metal Processors Ltd. hold an existing Industrial Emissions License (License Reference:

P0401-01) administered and enforced by the Environmental Protection Agency (EPA). The

licensable activity occurring at their facility, in accordance with the EPA Act, as amended, is

as follows:

3.4.1(b) The melting, including the alloyage, of non-ferrous metals, including recovered

products and operation of non-ferrous metal foundries, with a melting capacity exceeding 4

tonnes per day for lead and cadmium or 20 tonnes per day for all other metals.

Metal Processors Ltd. has the intention to initiate a Review of their existing Industrial

Emissions License Application in accordance with the EPA Act, as amended, for the

purposes of:

1. Revising the License to ensure conformance with the Industrial Emissions Directive

(2010/75/EU), namely, to ensure compliance with new Best Available Techniques

Conclusions (BAT-C) for the non-ferrous metal industry for preventing or minimising

emissions and impacts on the environment. (Commission Implementing Decision (EU)

2016/1032) and;

2. Regularizing and accommodating a proposed site modification involving the development

of a Dual Flow Drainage System. This will involve the redirection of ‘first flush’ stormwater

run-off from yard/roof areas, occasionally containing elevated concentrations of lead, to

public foul sewer. This will create a new emission point, thereby causing a material change

in the nature of emission emanating from the site.

2.3.2 Development of a Dual Flow Drainage System

The proposed activity involves alterations to the existing drainage system, namely the

development of a Dual Flow Drainage System on-site. This will involve the construction of a

retention tank system and the connection of this system to existing public foul and storm

sewer systems. The Dual Flow Drainage System will ensure that First Flush stormwater

run-off is directed to foul sewer and subsequent stormwater run-off, occurring during a

prolonged or intense rainfall, is directed to public storm sewer.

The principle of the dual flow system is to allow for the discharge to the surface water in

the event of a 1:100-year storm. Normal non exceptional rainfall can also be handled by

the system. The system is designed to store and discharge normal rainfall at a controlled

rate to the fowl sewer and above normal rainfall, after initial flush. During a prolonged or

intense rainfall stormwater run-off will eventually fill the retention tank before by-passing

the tank and being directed to the public stormwater sewer and then onto the Gallanstown

Stream. This by-pass stormwater un-off will contain negligible concentrations of lead due to

the occurrence of the ‘first flush’ effect.

The retention tank will be situated in the south eastern corner of the site. A Site Layout

Plan and design specifications showing the location, layout and detailed design of the Dual

Flow Drainage System can be found in Appendix A and Appendix B. These drawings also

show the land use requirement associated with the retention tank and connecting pipelines.

It is expected that the construction of this drainage system will take place over short term

period and will involve the following construction processes:

• The breaking and excavation of concrete yard and its removal from the site.

• The excavation and trenching of soils to required depths.

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• The temporary storage of soil in skips prior to backfilling or removal from the

site

• The laying of a concrete base for the retention tank.

• The construction of a GRP over ground tank and a concrete underground tank.

• The construction of manholes and inspection chambers.

• The laying and connection of drainage pipework

• Backfilling, compaction and grading of soils

• Laying of new impermeable concrete yard to restore the yard area.

Construction operations shall only be carried out during designated construction operating

hours, which are proposed to be as follows:

• Monday to Friday: 8 a.m. to 7 p.m.

• Saturdays: 8 a.m. to 2 p.m.

In addition to the above, it is proposed to install two oil interceptors before the outlets of

the existing surface water and proposed foul drainage systems in order to prevent the

discharge of hydrocarbons from the site going forward. Further to this, it is proposed to

install kerbing of 30 cm in height along the southern boundary of the site, and the south

eastern and south western boundaries of the site. At the same time, it is also proposed to

repair cracking that occurs in a small number of locations on-site. This will convert the

southern portion of the site into a firewater containment area. (The yard area slopes gently

from north to south with the highest point on the yard being at the northern site boundary

at 55.043 OD and the lowest point on-site being at the southern boundary at 54.282 OD).

This will provide a substantial amount of additional retention capacity on-site. It is

anticipated that this will provide sufficient firewater retention capabilities for any major fire

that may occur on-site.

2.4 Project Zone of Influence

Because the impacts of pollution from Metal Processors Ltd. can be dispersed over a wide

area by air and surface water the zone of influence is 15km downstream of the site

including the Natura 2000 sites in the Dublin Bay area.

2.5 Project Summary

Table 2-1 in overleaf presents a summary of the elements of the Project that are relevant

for ecology- (derived from the Screening for Appropriate Assessment report [Environmental

Efficiency, 2019]).

Table 2-1: Summary of project elements relevant to ecology of the Natura 2000

sites within the ZoI.

Project Elements Comment

Land-take The proposed project does not involve any land take or

construction impacting upon a Natura 2000 site.

Distance from Natura

2000 site or key

features of the site

The industrial activity is not adjacent, bordering or within a Natura

site. The nearest Natura site is Rye Water Valley/Carton Special Area

of Conservation (001398) which is 7.1 km north west of Metal

Processors facility. Therefore, there will be no direct impact on any

protected sites in the form of noise or fugitive dust emissions.

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Project Elements Comment

*Nearest Natura 2000 sites following Planning Authority focus

on Dublin Bay Natura 2000 sites:

- North Bull Island SPA (11.3km east) – nearest

- South Dublin Bay SAC (11.9km east)

- South Dublin and River Tolka Estuary SPA (12.0km east)

- North Dublin Bay SAC (14.4km east)

Resource requirements

(water abstraction etc.)

It does not involve the use of any natural resources relating

to or connected to a Natura 2000 site.

Emissions (disposal to

land, water or air)

Industrial operations within the facility do not give rise to emissions

to air of any significance. Past air emission monitoring at the one main

emission point on-site (A1-1, baghouse filter exhaust) shows that

emission levels for Particulate Matter and Heavy Metals do not exceed

applicable Best Available Technique Emission Limit Values.

Excavation requirements

The proposed project does not involve any excavation or construction

impacting upon a Natura 2000 site.

Duration of construction,

operation,

decommissioning etc.

Duration of construction – 6 weeks.

There is a decommissioning and closure plan in place for the site

should the need arise.

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3 Screening Assessment

3.1 Natura 2000 Sites

This section provides baseline information on the Natura 2000 sites within the Zone of

Influence of the proposed works. A short description of the Natura 2000 site is provided,

along with details of the qualifying interest/special conservation interests, conservation

objectives, the attributes used to define favourable conservation status and site

vulnerabilities.

The Natura 2000 sites identified as occurring within the Zone of Influence (Figure 3-1) of

the proposed development are:

• North Dublin Bay SAC (14.4km east)

• South Dublin Bay SAC (11.9km east)

• North Bull Island SPA (11.3km east)

• South Dublin and River Tolka Estuary SPA (12.0km east)

Figure 3-1: Natura 2000 site and site location.

3.1.1 Screened-out Qualifying Interests

Qualifying interests (QI) screened-out of the project’s ZoI include the North Dublin Bay SAC

QIs:

• Humid dune slacks [2190]

• Petalwort (Petalophyllum ralfsii) [1395]

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Table 3-1: Natura 2000 sites within the ZoI and their respective site briefs.

Natura 2000 Site Site Brief

North Dublin Bay SAC

[000206]

The North Bull Island sand spit is a relatively recent depositional feature, formed as a result of improvements to Dublin Port during the 18th and 19th centuries. It is almost 5km long and 1km wide and runs parallel to the coast between Clontarf and Sutton. The North Bull Island dune system is one of the most important systems on the east coast and is one of the few in Ireland that is actively accreting. It possesses extensive and mostly good quality examples of embryonic, shifting marram and fixed dunes, as well as excellent examples of humid dune slacks. Both Atlantic and Mediterranean salt marshes are well represented, and a particularly good marsh zonation is shown. The salt marshes grade into mudflats and sandflats, some of which are dominated by

annual Salicornia species. Petalwort (Petalophyllum ralfsii) occurs at its only known station away from the western seaboard (NPWS, 2018a).

South Dublin Bay SAC

[000210]

This intertidal site extends from the South Wall at Dublin Port to the West Pier at Dun Laoghaire, a distance of c. 5 km. At their widest, the intertidal flats extend for almost 3 km. The seaward boundary is marked by the low tide mark, while the landward boundary is now almost entirely artificially embanked. A small sandy beach occurs at Merrion Gates, while some bedrock shore occurs near Dun Laoghaire. The proximity of the site to Dublin City results in it being a very popular recreational area. It is also important for educational and research purposes. Site possesses a fine and fairly extensive example of intertidal flats. Sediment type is predominantly sand, with muddy sands in the more sheltered areas. A typical macro-invertebrate fauna exists. Has the largest stand of Zostera on the east coast. Supports part of the important wintering waterfowl populations of Dublin Bay. Regularly has an internationally population of Branta bernicila horta, plus nationally important numbers of at least a further 6 species,

including Limosa lapponica. Regular autumn roosting ground for significant numbers of Sterna terns, including S. dougallii (NPWS, 2018b).

North Bull Island SPA

[004006]

The site is among the top ten sites for wintering waterfowl in the country. It supports internationally important populations of

Branta bernicila hrota and Limosa lapponica and is the top site in the country for both of these species. A further 14 species have populations of national importance, with particular notable numbers of Tadorna tadorna (8.5% of national total), Anas acuta (11.6% of national total), Pluvialis squatarola (6.9% of national total), Calidris canutus (10.5% of national total). North Bull Island SPA is a regular site for passage waders such as Philomachus pugnax, Calidris ferruginea and Tringa erythropus. The site supports Asio flammeus in winter. Formerly the site had an important colony of Sterna albifrons but breeding has not occurred in recent years. The site provides both feeding and roosting areas for the waterfowl species (NPWS, 2018c).

South Dublin Bay and

River Tolka Estuary

SPA [004024]

This site comprises a substantial part of Dublin Bay. It includes virtually all of the intertidal area in the south bay, as well as much of the Tolka Estuary to the north of the River Liffey. A portion of the shallow bay waters is also included. The site possesses extensive intertidal flats which support wintering waterfowl which are part of the overall Dublin Bay population. It regularly has an internationally important population of Branta bernicla hrota, which feeds on Zostera noltii in the autumn. It has nationally

important numbers of a further 6 species: Haematopus ostralegus, Charadrius hiaticula, Calidris canutus, Calidris alba, Calidris alpina and Limosa lapponica. It is an important site for wintering gulls, especially Larus ridibundus and Larus canus. South Dublin Bay is the premier site in Ireland for Larus melanocephalus, with up to 20 birds present at times. Is a regular autumn roosting ground for significant numbers of terns, including Sterna dougallii, S. hirundo and S. paradisaea (NPWS, 2018d).

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Table 3-2: Natura 2000 sites within the ZoI and their respective qualifying interests and conservation objectives.

Natura 2000 Site

Qualifying Interest Attribute Measure Target

North

Dublin

Bay SAC

[000206]

Mudflats and sandflats

not covered by

seawater at low tide

[1140]

Conservation Objectives: To maintain favourable

conditions

(NPWS, 2013a)

Habitat area Hectares The permanent habitat area is stable or increasing, subject to natural processes.

Community extent Hectares Maintain the extent of the Mytilus edulis-dominated community, subject to natural processes.

Community structure: Mytilus edulis density

Individuals/m² Conserve the high quality of the Mytilus edulis-dominated community, subject to natural processes.

Community distribution Hectares Conserve the following community types in a natural condition: Fine sand to sandy mud with Pygospio elegans and Crangon crangon community complex; Fine sand with Spio martinensis community complex

Annual vegetation of

drift lines [1210]

Conservation Objectives: To restore favourable conditions

(NPWS, 2013a)

Habitat area Hectares Area increasing, subject to natural processes, including erosion and succession. Total area mapped: South Bull - 0.11ha.

Habitat distribution Occurrence No decline, or change in habitat distribution, subject to natural processes.

Physical structure: functionality

and sediment supply

Presence/ absence of

physical barriers

Maintain the natural circulation of sediment and organic

matter, without any physical obstructions.

Vegetation structure: zonation Occurrence Maintain the range of coastal habitats including transitional zones, subject to natural processes

including erosion and succession.

Vegetation composition: typical species and subcommunities

Percentage cover at a representative number

of monitoring stops

Maintain the presence of species-poor communities with typical species: sea rocket (Cakile maritima), sea

sandwort (Honckenya peploides), prickly saltwort (Salsola kali) and oraches (Atriplex spp.)

Vegetation composition: negative indicator species

Percentage cover Negative indicator species (including non-natives) to represent less than 5% cover.

Salicornia and other

annuals colonising mud

and sand [1310]

Habitat area Hectares Area stable or increasing, subject to natural processes, including erosion and succession. For sub-site mapped: North Bull Island - 29.10ha.


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Conservation Objectives:

To restore favourable conditions

(NPWS, 2013a)

Physical structure: sediment

supply


physical barriers

Maintain, or where necessary restore, natural

circulation of sediments and organic matter, without

any physical obstructions.

Physical structure: creeks and pans

Occurrence Maintain creek and pan structure, subject to natural processes, including erosion and succession.

Physical structure: flooding regime

Hectares flooded; frequency

Maintain natural tidal regime.

Vegetation structure: zonation Occurrence Maintain the range of coastal habitats including transitional zones, subject to natural processes including erosion and succession.

Vegetation structure:

vegetation height

Centimetres Maintain structural variation within sward.

Vegetation structure: vegetation cover

Percentage cover at a representative number of monitoring stops

Maintain more than 90% of area outside creeks vegetated.


Percentage cover Maintain the presence of species-poor communities listed in SMP.

Vegetation structure: negative indicator species - Spartina

anglica

Hectares No significant expansion of common cordgrass (Spartina anglica), with an annual spread of less than

1%.

Atlantic salt meadows

(Glauco-Puccinellietalia

maritimae) [1330]

Conservation Objectives: To maintain favourable conditions

(NPWS, 2013a)

Habitat area Hectares Area stable or increasing, subject to natural processes, including erosion and succession. For sub-site mapped:

North Bull Island - 81.84ha.

Habitat distribution Occurrence No decline or change in habitat distribution, subject to natural processes.

Physical structure: sediment supply

Presence/ absence of physical barriers

Maintain natural circulation of sediments and organic matter, without any physical obstructions.






Vegetation structure: zonation Occurrence Maintain range of coastal habitats including transitional zones, subject to natural processes including erosion and succession.

Vegetation structure: Centimetres Maintain structural variation within sward.

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vegetation height



of monitoring stops

Maintain more than 90% area outside creeks vegetated.


Percentage cover Maintain range of subcommunities with typical species listed in SMP.

Vegetation structure: negative indicator species - Spartina anglica

Hectares No significant expansion of common cordgrass (Spartina anglica), with an annual spread of less than 1%

Mediterranean salt

meadows (Juncetalia

maritimi) [1410]


To maintain favourable conditions

(NPWS, 2013a)

Habitat area Hectares Area stable or increasing, subject to natural processes, including erosion and succession. For sub-site mapped:

North Bull Island - 7.98ha.




Maintain natural circulation of sediments and organic matter, without any physical obstructions.






Vegetation structure: zonation Occurrence Maintain range of coastal habitats including transitional zones, subject to natural processes including erosion and succession.

Vegetation structure: vegetation height




Maintain more than 90% area outside creeks vegetated.

Vegetation composition: typical

species and subcommunities

Percentage cover Maintain range of subcommunities with typical species

listed in SMP.


Hectares No significant expansion of common cordgrass (Spartina anglica), with an annual spread of less than 1%

Embryonic shifting

dunes [2110]

Habitat area Hectares Area stable or increasing, subject to natural processes, including erosion and succession. For sub-sites mapped: North Bull - 2.64ha; South Bull - 3.43ha.

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(NPWS, 2013a)

Habitat distribution Occurrence No decline or change in habitat distribution, subject to

natural processes.

Physical structure: functionality and sediment supply

Presence/absence of physical barriers

Maintain the natural circulation of sediment and organic matter, without any physical obstructions.


Vegetation composition: plant health of foredune grasses

Percentage cover More than 95% of sand couch (Elytrigia juncea) and/or lyme-grass (Leymus arenarius) should be healthy (i.e. green plant parts above ground and flowering heads present).



Maintain the presence of species-poor communities with typical species: sand couch (Elytrigia juncea) and/or lyme-grass (Leymus arenarius)


Percentage cover Negative indicator species (including non-native species) to represent less than 5% cover.

Shifting dunes along

the shoreline with

Ammophila arenaria

(white dunes) [2120]



(NPWS, 2013a)

Habitat area Hectares Area stable or increasing, subject to natural processes including erosion and succession. North Bull - 2.20ha; South Bull - 0.97ha.

Habitat distribution Occurrence No decline, or change in habitat distribution, subject to

natural processes.






Vegetation composition: plant health of dune grasses

Percentage cover 95% of marram grass (Ammophila arenaria) and/or lyme-grass (Leymus arenarius) should be healthy (i.e. green plant parts above ground and flowering heads

present).



of monitoring stops

Maintain the presence of species-poor communities dominated by marram grass (Ammophila arenaria)

and/or lymegrass (Leymus arenarius).



Fixed coastal dunes Habitat area Hectares Area stable or increasing, subject to natural processes

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with herbaceous

vegetation (grey

dunes) [2130]


(NPWS, 2013a)

including erosion and succession. For subsites mapped:

North Bull - 40.29ha; South Bull - 64.56ha.






Vegetation structure: bare ground

Percentage cover Bare ground should not exceed 10% of fixed dune habitat, subject to natural processes.

Vegetation structure: sward height




Maintain range of subcommunities with typical species listed in Delaney et al. (2013).

Vegetation composition: negative indicator species (including Hippophae rhamnoides)


Vegetation composition: scrub/trees

Percentage cover No more than 5% cover or under control.

South

Dublin

Bay SAC

[000210]

Mudflats and sandflats

not covered by

seawater at low tide

[1140]


conditions

(NPWS, 2013b)

Habitat area Hectares The permanent habitat area is stable or increasing, subject to natural processes.

Community extent Hectares Maintain the extent of the Zostera-dominated community, subject to natural processes.


Individuals/m² Conserve the high quality of the Zostera-dominated community, subject to natural processes.

Community distribution Hectares Conserve the following community type in a natural condition: Fine sands with Angulus tenuis community complex.

Annual vegetation of Habitat area Hectares Area increasing, subject to natural processes, including erosion and succession.

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drift lines [1210]

Taken from North Dublin

Bay SAC Conservation Objectives as not detailed in South Dublin Bay SAC Conservation Objectives.


(NPWS, 2013a)

Habitat distribution Occurrence No decline, or change in habitat distribution, subject to

natural processes.







Maintain the presence of species-poor communities with typical species: sea rocket (Cakile maritima), sea sandwort (Honckenya peploides), prickly saltwort (Salsola kali) and oraches (Atriplex spp.)




annuals colonising mud

and sand [1310]

Taken from North Dublin Bay SAC Conservation Objectives as not detailed

in South Dublin Bay SAC Conservation Objectives.



(NPWS, 2013a)

Habitat area Hectares Area stable or increasing, subject to natural processes, including erosion and succession. For sub-site mapped: North Bull Island - 29.10ha.




Maintain, or where necessary restore, natural circulation of sediments and organic matter, without

any physical obstructions.











Maintain more than 90% of area outside creeks vegetated.


Percentage cover Maintain the presence of species-poor communities listed in SMP.

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Vegetation structure: negative

indicator species - Spartina

anglica

Hectares No significant expansion of common cordgrass

(Spartina anglica), with an annual spread of less than

1%.

Embryonic shifting

dunes [2110]

Taken from North Dublin

Bay SAC Conservation Objectives as not detailed in South Dublin Bay SAC Conservation Objectives.


(NPWS, 2013a)

Habitat area Hectares Area stable or increasing, subject to natural processes, including erosion and succession.








Percentage cover More than 95% of sand couch (Elytrigia juncea) and/or lyme-grass (Leymus arenarius) should be healthy (i.e. green plant parts above ground and flowering heads present).



Maintain the presence of species-poor communities with typical species: sand couch (Elytrigia juncea) and/or lyme-grass (Leymus arenarius)

Vegetation composition:

negative indicator species

Percentage cover Negative indicator species (including non-native

species) to represent less than 5% cover.

North Bull

Island SPA

[004006]

Light-bellied Brent

Goose (Branta bernicla

hrota) [A046]


(NPWS, 2015a)

Population trend Percentage change Long term population trend stable or increasing.

Distribution Range, timing and intensity of use of areas

No significant decrease in the range, timing or intensity of use of areas by Light-bellied Brent goose, other than

that occurring from natural patterns of variation.

Shelduck (Tadorna

tadorna) [A048]



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To maintain favourable

conditions

(NPWS, 2015a)

Distribution Range, timing and

intensity of use of areas

No significant decrease in the range, timing or intensity

of use of areas by Shelduck, other than that occurring

from natural patterns of variation.

Teal (Anas crecca)

[A052]


(NPWS, 2015a)



No significant decrease in the range, timing or intensity of use of areas by Teal, other than that occurring from natural patterns of variation.

Pintail (Anas acuta)

[A054]


(NPWS, 2015a)



No significant decrease in the range, timing or intensity of use of areas by Pintail, other than that occurring from natural patterns of variation.

Shoveler (Anas

clypeata) [A056]


(NPWS, 2015a)



No significant decrease in the range, timing or intensity of use of areas by Shoveler, other than that occurring from natural patterns of variation.

Oystercatcher

(Haematopus

ostralegus) [A130]



(NPWS, 2015a)



No significant decrease in the range, timing or intensity of use of areas by Oystercatcher, other than that

occurring from natural patterns of variation.

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Golden Plover (Pluvialis

apricaria) [A140]



(NPWS, 2015a)



No significant decrease in the range, timing or intensity of use of areas by Golden Plover, other than that occurring from natural patterns of variation.

Grey Plover (Pluvialis

squatarola) [A141]


(NPWS, 2015a)



No significant decrease in the range, timing or intensity of use of areas by Grey Plover, other than that occurring from natural patterns of variation.

Knot (Calidris canutus)

[A143]



(NPWS, 2015a)



No significant decrease in the range, timing or intensity of use of areas by Knot, other than that occurring from natural patterns of variation.

Sanderling (Calidris

alba) [A144]


(NPWS, 2015a)





of use of areas by Sanderling, other than that occurring from natural patterns of variation.

Dunlin (Calidris alpina)

[A149]



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conditions

(NPWS, 2015a)




of use of areas by Dunlin, other than that occurring from

natural patterns of variation.

Black-tailed Godwit

(Limosa limosa)

[A156]


(NPWS, 2015a)



No significant decrease in the range, timing or intensity of use of areas by Black-tailed Godwit, other than that occurring from natural patterns of variation.

Bar-tailed Godwit

(Limosa lapponica)

[A157]


(NPWS, 2015a)



No significant decrease in the range, timing or intensity of use of areas by Bar-tailed Godwit, other than that occurring from natural patterns of variation.

Curlew (Numenius

arquata) [A160]


(NPWS, 2015a)



No significant decrease in the range, timing or intensity of use of areas by Curlew, other than that occurring

from natural patterns of variation.

Redshank (Tringa

totanus) [A162]


conditions

(NPWS, 2015a)



No significant decrease in the range, timing or intensity of use of areas by Redshank, other than that occurring from natural patterns of variation.

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Turnstone (Arenaria

interpres) [A169]



(NPWS, 2015a)



No significant decrease in the range, timing or intensity of use of areas by Turnstone, other than that occurring from natural patterns of variation.

Black-headed Gull

(Chroicocephalus

ridibundus) [A179]


(NPWS, 2015a)



No significant decrease in the range, timing or intensity of use of areas by Curlew, other than that occurring from natural patterns of variation.

Wetland and

Waterbirds [A999]


(NPWS, 2015a)

Habitat area Hectares The permanent area occupied by the wetland habitat should be stable and not significantly less than the area of 1,713 hectares, other than that occurring from natural patterns of variation.

South

Dublin

Bay and

River

Tolka

Estuary

SPA

[004024]

Light-bellied Brent

Goose (Branta bernicla

hrota) [A046]


(NPWS, 2015b)



No significant decrease in the range, timing or intensity of use of areas by Light-bellied Brent Goose, other than that occurring from natural patterns of variation.

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Oystercatcher

(Haematopus

ostralegus) [A130]


(NPWS, 2015b)



No significant decrease in the range, timing or intensity of use of areas by Oystercatcher, other than that occurring from natural patterns of variation.

Ringed Plover

(Charadrius hiaticula)

[A137]


(NPWS, 2015b)



No significant decrease in the range, timing or intensity of use of areas by Ringed Plover, other than that occurring from natural patterns of variation.

Grey Plover (Pluvialis

squatarola) [A141]

(NPWS, 2015b)

Grey Plover is proposed for removal from the list of Special Conservation Interests for South Dublin Bay and River Tolka Estuary SPA. As a result, a site-specific conservation objective has not been set for this species.

Knot (Calidris canutus)

[A143]


(NPWS, 2015b)



No significant decrease in the range, timing or intensity of use of areas by Knot, other than that occurring from natural patterns of variation.


alba) [A144]


(NPWS, 2015b)



No significant decrease in the range, timing or intensity of use of areas by Sanderling, other than that occurring from natural patterns of variation.

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Dunlin (Calidris alpina)

[A149]



(NPWS, 2015b)



No significant decrease in the range, timing or intensity of use of areas by Dunlin, other than that occurring from natural patterns of variation.

Bar-tailed Godwit

(Limosa lapponica)

[A157]


(NPWS, 2015b)



No significant decrease in the range, timing or intensity of use of areas by Bar-tailed Godwit, other than that occurring from natural patterns of variation.

Redshank (Tringa

totanus) [A162]


conditions

(NPWS, 2015b)





of use of areas by Redshank, other than that occurring from natural patterns of variation.

Black-headed Gull

(Chroicocephalus

ridibundus) [A179]


(NPWS, 2015b)



No significant decrease in the range, timing or intensity of use of areas by Black-headed Gull, other than that occurring from natural patterns of variation.

Roseate Tern (Sterna

dougallii) [A192]


Passage population: individuals Number No significant decline.

Distribution: roosting areas Number; location; area (hectares)

No significant decline.

Prey biomass available Kilogrammes No significant decline.

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conditions

(NPWS, 2015b)

Barriers to connectivity Number; location;

shape; area (hectares) No significant increase.

Disturbance at roosting site Level of impact Human activities should occur at levels that do not adversely affect the numbers of roseate tern among the post-breeding aggregation of terns.

Common Tern (Sterna

hirundo) [A193]


(NPWS, 2015b)

Breeding population abundance: apparently occupied nests (AONs)

Number No significant decline.

Productivity rate: fledged young per breeding pair

Mean number No significant decline.


Distribution: breeding colonies Number; location; shape; area (hectares)


Distribution: roosting areas Number; location; shape; area (hectares)



Barriers to connectivity Number; location; shape; area (hectares)

No significant increase.

Disturbance at breeding site Level of impact

Disturbance at roosting site Level of impact Human activities should occur at levels that do not adversely affect the numbers of common tern among the post-breeding aggregation of terns.

Arctic Tern (Sterna

paradisaea) [A194]


(NPWS, 2015b)


Distribution: roosting areas Number; location; area (hectares)




shape; area (hectares)

No significant increase.

Disturbance at roosting site Level of impact Human activities should occur at levels that do not adversely affect the numbers of Arctic tern among the post-breeding aggregation of terns.

Wetland and

Waterbirds [A999]

Habitat area Hectares The permanent area occupied by the wetland habitat should be stable and not significantly less than the area

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(NPWS, 2015b)

of 2,192 hectares, other than that occurring from

natural patterns of variation.

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Table 3-3: Natura 2000 sites within the ZoI with their respective site threats and pressures of relevance to the

proposed development’s construction and operation.

Natura 2000 Site Development relevant Threats and Pressures

(NPWS, 2017a, b, c, d)

Impact Rank:

High (H)

Moderate(M)

Low (L)

Impact Source:

Inside (i)

Outside (o)

Both (b)

North Dublin Bay SAC

[000206]

Diffuse pollution to surface waters due to other sources not listed M i

Discharges H i

Industrial or commercial areas H o

Other point source pollution to surface water M i

South Dublin Bay SAC

[000210]


Marine water pollution M b

Discharges M b

North Bull Island SPA

[004006]

Discharges M b

Industrial or commercial areas M o

South Dublin Bay and

River Tolka Estuary SPA

[004024]


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4 Environmental Baseline

4.1 Site survey

Baseline conditions are based on an ecological walkover survey carried out by Ecologist

William Mulville of JBA Consulting during February 2020.

The site is currently being utilised for the manufacturing and distribution of lead, roofing

materials and related ancillary prodcts.

4.1.1 Methodology

Habitats were surveyed following standard methodology (Heritage Council, 2011), and were

classified under the national habitat classification system of Fossitt (2000). Nomenclature

for higher plants principally follows Parnell and Curtis (2012). Habitat boundaries were

recorded with the aid of aerial images of the site while in the field.

4.2 Habitats

The survey results outlined in this section are illustrated as a habitat map in Figure 4-1 and

Appendix C. Habitats recorded in the area are listed in Table 4-1.

Figure 4-1: Habitat Map.

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Table 4-1: Habitats recorded on the site visit (Fossitt classifications).

Habitat Fossitt Code

Buildings and artificial surfaces BL3

Amenity grassland (improved) GA2

Treelines WL2

Ornamental/non-native shrub WS3

4.2.1 Buildings and artificial surfaces (BL3)

The vast majority of the site is comprised of artificial concrete surfaces, tarmacadam road

surfaces and industrial buildings.

4.2.2 Amenity grassland (improved) (GA2)

A small linear strip of amenity grassland, with some ornamental shrubbery and scattered

trees, are present on the west side of the site access road at the Clondalkin Industrial

Estate Road junction. The grassland is dominated by Perennial Ryegrass (Lolium perenne)

and the trees species present include Lime (Tilia sp.) and Silver Birch (Betula pendula).

4.2.3 Treelines (WL2)

A mature Poplar (Populus sp.) treeline runs along the southern boundary of the site, with

some more Silver Birch along the eastern most point, adjacent to the site entrance.

4.2.4 Ornamental/non-native shrub (WS3)

A small patch of ornamental/non-native shrubbery is present along the right side of the site

access road at the Clondalkin Industrial Estate Road junction.

4.3 Invasive Non-native Species

No invasive non-native species were recorded within the boundaries of the proposed site.

4.4 Waterbodies within the Vicinity of the Proposed Site

The site lies within the Water Framework Directive (WFD) sub-catchment of Liffey_SC_090

(EPA, 2020a). Figure 4-2 in overleaf outlines the watercourses close to the proposed

development. Gallanstown Stream and the Grand Canal are located to south of the site,

though only Gallanstown Stream has a hydrological connection with the site. Gallanstown

Stream joins with the River Camac several kilometres east of the site, with the River Camac

ultimately flowing into the River Liffey several hundred metres east of Phoenix Park.

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Figure 4-2: Rivers, canals and surface water catchment within the vicinity of the

proposed site; and hydrologically connected to the River Liffey (Dublin Bay).

4.4.1 Water Quality

At present, Gallanstown Stream is not monitored in by the EPA under the Water Framework

Directive and as such has no biological (invertebrate) or supporting water chemistry data or

status. The nearest monitored river section is the River Camac (CAMAC_040), where

Gallanstown Stream flows into the River Camac in the Bluebell area. Currently CAMAC_040

has a ‘Poor’ WFD status (2013-2018) and is considered to be ‘At Risk’ (EPA, 2020). This

‘Poor’ WFD status was based on the Invertebrate Status or Potential (Poor) and Supporting

Chemistry Conditions (Pass), though with only ‘Moderate’ Phosphate Conditions. The

weighing of Invertebrate Status or Potential ultimately leading to an overall ‘Poor’ status

(Catchments, 2020).

4.4.2 Water Sampling Results (JBA,2020)

During February 2020, JBA Ecologists conducted water grab sampling along select points of

Gallanstown Stream, upstream and downstream of the development’s outlet pipe. This

sampling was timed to coincide with the first flush of potential contaminants draining off

the site of proposed development and out into the Gallanstown Stream. The sampling

points were located directly upstream and downstream of the outlet drainage pipe, with

additional samples being taken 100m upstream and downstream. Once the samples were

taken, they were immediately transported to The Water Lab, Celbridge for processing. The

results of the samples, with the environmental quality standards (EQS) of the chemical

parameters are displayed below in Table 4-2. The first sample taken was from the 100m

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downstream sample point, from their surveys continue upstream sampling the other 3

sample points.

Table 4-2: Water chemistry sampling results from Gallanstown Stream

Parameter 100m Upstream

5m Upstream

5m Downstream

100m Downstream

SW AA/MAC-EQS, Inland Surface Waters (2009,

2015, 2019)

Cadmium

(µg/l)

<0.3 <0.3 <0.3 <0.3 0.45 (MAC)

Lead (Subcon)

(µg/l)

10.1 <0.9 21.6 28.7 1.2 (AA) / 14 (MAC)

Mercury

(µg/l)

<0.06 <0.06 <0.06 <0.06 0.07 (MAC)

Arsenic

(µg/l)

2.3 <1.0 1.1 1.3 25 (AA)

Zinc

(µg/l)

68 25 260 280 100 (AA) 1

Selenium

(µg/l)

<3.0 <3.0 <3.0 <3.0 -

Mineral Oils

(µg/l) <0.2 <0.2 <0.2 <0.2 -

Nickel

(µg/l)

6.6 4.0 5.6 7.3 4 (AA) / 34 (MAC)

Copper

(µg/l)

0.011 <0.003 0.010 0.010 30 (AA) 2

Chromium

(µg/l)

<3.0 <3.0 <3.0 <3.0 3.4 (AA) 3

Total Suspended

Solids (mg/l) 48 9 10 20 <25 4

AA = Annual average

MAC = Maximum allowable concentration 1 = Limit is 100 µg/l given the water hardness levels in the region are greater than 100mg/l 2 = Limit is 30 µg/l given the water hardness levels in the region are greater than 100mg/l 3 = SW EQS pertaining to Chromium VI. 4 = previous guidance from DIRECTIVE 2006/44/EC regarding water quality standards for freshwater fish,

which outlines exceedance of limits of <25mg/l for both Salmonid and Cyprinid waters.

Of the 11 parameters, 4 parameters, namely Lead, Zinc, Total Suspended Solids and

Nickel, were recorded as exceeding their EQSs / EU guidance in regard to annual average

and/or maximum allowable concentration limits. As Total Suspended Solids only exceeds

the limits upstream from the development’s outlet pipe, it will not be examined in any

further detail. Nickel was seen to exceed the average annual limit at both points

downstream but not its maximum allowable concentration limit. Lead and Zinc were the

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most notable exceedances, with both parameters displaying levels more than doubling their

respective maximum allowable concentrations.

The data also highlights that Lead, Zinc and Nickel increase further downstream, where one

would expect a decrease as a result of dilution, similar to what occurs between the two

upstream sites. The most likely explanation for this occurrence is the chronological order of

sampling. As the furthest downstream point was sampled first, it is possible it picked up the

peak of the first flush of contaminants draining from the site, with the second sample

further upstream recording the post-peak contaminant levels minutes later.

4.4.3 Qualifying Interests present within the ZoI

There are 30 QIs that have been mapped by NPWS as being present within the ZoI, which

is comprised of the Dublin Bay area. They are as follows:

• Mudflats and sandflats not covered by seawater at low tide [1140]

• Annual vegetation of drift lines [1210]

• Salicornia and other annuals colonising mud and sand [1310]

• 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]

• Fixed coastal dunes with herbaceous vegetation (grey dunes) [2130]

• Light-bellied Brent Goose (Branta bernicla hrota) [A046]

• Shelduck (Tadorna tadorna) [A048]

• Teal (Anas crecca) [A052]

• Pintail (Anas acuta) [A054]

• Shoveler (Anas clypeata) [A056]

• Oystercatcher (Haematopus ostralegus) [A130]

• Ringed Plover (Charadrius hiaticula) [A137]

• Golden Plover (Pluvialis apricaria) [A140]

• Grey Plover (Pluvialis squatarola) [A141]

• Knot (Calidris canutus) [A143]

• Sanderling (Calidris alba) [A144]

• Dunlin (Calidris alpina) [A149]

• Black-tailed Godwit (Limosa limosa) [A156]

• Bar-tailed Godwit (Limosa lapponica) [A157]

• Curlew (Numenius arquata) [A160]

• Redshank (Tringa totanus) [A162]

• Turnstone (Arenaria interpres) [A169]

• Black-headed Gull (Chroicocephalus ridibundus) [A179]

• Roseate Tern (Sterna dougallii) [A192]

• Common Tern (Sterna hirundo) [A193]

• Arctic Tern (Sterna paradisaea) [A194]

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• Wetland and Waterbirds [A999]

4.4.4 Non-Qualifying Interest, Protected Species within the ZoI

There are numerous internationally protected species which have the potential to be

present within the proposed project’s ZoI but are not QIs of the four Natura 2000 sites. See

Table 4-3 in overleaf for a list of potential non-QI protected species within the ZoI which

have been recorded within the last 10 years. Given the specificity of the project’s potential

impact pathways, the ZoI will be is restricted to species with access to watercourses

downstream of the site, and downwind of the south-westerly prevailing wind, within an

overall 10km buffer zone for airborne impacts and 15km buffer zone for surface water.

Table 4-3: Non-QI, Protected Species potentially present within the ZoI.

Species Protective Designation

European Badger (Meles meles) WA

Eurasian Otter (Lutra lutra) WA; Annex II and IV HD

European Hedgehog (Erinaceus europaeus) WA

Red Squirrel (Sciurus vulgaris) WA

Irish Stoat (Mustela erminea subsp. hibernica) WA

Irish Hare (Lepus timidus subsp. hibernicus) WA; Annex V HD, WA

Pygmy Shrew (Sorex minutus) WA

Daubenton's Bat (Myotis daubentoni) WA; Annex IV HD, WA

Leisler’s Bat (Nyctalus leisleri) WA; Annex IV HD, WA

Common Pipistrelle (Pipistrellus pipistrellus) WA; Annex IV HD, WA

Soprano Pipistrelle (Pipistrellus pygmaeus) WA; Annex IV HD, WA

Nathusius's Pipistrelle (Pipistrellus nathusii) WA; Annex IV HD, WA

Brown Long-eared Bat (Plecotus auritus) WA; Annex IV HD, WA

Fallow Deer (Dama dama) WA

Common Seal (Phoca vitulina) WA, Annex II and V HD

Grey Seal (Halichoerus grypus) WA, Annex II and V HD

Common Porpoise (Phocoena phocoena) WA, Annex II and IV HD

Barn Owl (Tyto alba) WA; Red List

Barn Swallow (Hirundo rustica) WA; Amber List

Common Pheasant (Phasianus colchicus) WA, Annex II and III BD

Yellowhammer (Emberiza citrinella) WA; Red List

Coot (Fulica atra) WA, Annex II and III BD;

Amber List

Mallard (Anas platyrhynchos) WA, Annex II BD; AEWA

Kingfisher (Alcedo atthis) WA, Annex I BD; Amber List

Lapwing (Vanellus vanellus) WA, Annex II BD; Red List;

AEWA

Snipe (Gallinago gallinago) WA, Annex II BD; Amber List;

AEWA

Mute Swan (Cygnus olor) AEWA, WA, Amber List

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Lesser Black-backed Gull (Larus fuscus) WA; Amber List; AEWA

Wood Pigeon (Columba palumbus) WA; Annex II and III BD

Wigeon (Anas penelope) WA; Annex II and III BD;

Amber List; AEWA

Little Egret (Egretta garzetta) WA; Annex I BD; AEWA

Cormorant (Phalacrocorax carbo) WA; Amber List; AEWA

Peregrine Falcon (Falco peregrinus) WA; Annex I BD

Rock Pigeon (Columba livia) WA; Annex II BD

Sand Martin (Riparia riparia) WA; Amber List

Skylark (Alauda arvensis) WA; Amber List

Spotted Flycatcher (Muscicapa striata) WA; Amber List

Tufted Duck (Aythya fuligula) WA; Annex II and III BD;

Amber List; AEWA

Water Rail (Rallus aquaticus) WA; Amber List

Whooper Swan (Cygnus cygnus) WA; Annex I BD; Amber List;

AEWA

Grey Wagtail (Motacilla cinerea) WA; Red List

Herring Gull (Larus argentatus) WA; Red List

Meadow Pipit (Anthus pratensis) WA; Red List

Starling (Sturnus vulgaris) WA; Amber List

Robin (Erithacus rubecula) WA; Amber List

Stonechat (Saxicola rubicola) WA; Amber List

Common Kestrel (Falco tinnunculus) WA; Amber List

Razorbill (Alca torda) WA; Amber List; AEWA

Black Guillemot (Cepphus grylle) WA; Amber List; AEWA

Common Guillemot (Uria aalge) WA; Amber List; AEWA

Gadwall (Anas strepera) WA; Annex II BD; Amber List;

AEWA

Common Pochard (Aythya ferina) WA; Annex II & III BD; Red

List; AEWA

Greater Scaup (Aythya marila) WA; Annex II & III BD; Amber

List; AEWA

Barnacle Goose (Branta leucopsis) WA; Amber List; AEWA

Common Goldeneye (Bucephala clangula) WA; Annex II BD; Red List;

AEWA

Long-tailed Duck (Clangula hyemalis) WA; Annex II BD; Red List;

AEWA

Common Scoter (Melanitta nigra) WA; Annex II & III BD; Red

List; AEWA

Smew (Mergellus albellus) WA; Amber List; AEWA

Goosander (Mergus merganser) WA; Annex II BD; Amber List;

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AEWA

Red-breasted Merganser (Mergus serrator) WA; Annex II BD; AEWA

Grey Heron (Ardea cinerea) WA; AEWA

Merlin (Falco columbarius) WA; Annex I BD; Amber List

Twite (Carduelis flavirostris) WA; Red List

Common Linnet (Carduelis cannabina) WA; Amber List

Common Frog (Rana temporaria) WA; Annex V HD

Smooth Newt (Lissotriton vulgaris) WA

European Eel (Anguilla anguilla) IUCN Red Status – Critically

Endangered; OSPAR

AEWA = African-Eurasian Migratory Waterbird Agreement

HD = Habitats Directive

WA = Wildlife Act (Amendment 2000)

BD = Birds Directive

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5 Other Relevant Plans and Projects

5.1 Cumulative effects

5.1.1 South Dublin County Council Development Plan (2016-2022)

The South Dublin County Council (SDCC) Development Plan sets out an overall strategy for

the proper planning and sustainable development of the County. The objectives include a

target of increased population and continuing the consolidation of established urban areas,

support and facilitate economic activity, promote the ease of movement by sustainable

modes (walking, cycling and public transport). The Plan also aims to protect and enhance

surface water quality, to support, improve and protect Natura 2000 sites, and to develop an

integrated Green Infrastructure network to enhance biodiversity, provide accessible parks,

open spaces and recreational facilities (SDCC, 2016).

The plan also states that work will be in conjunction with Irish Water to protect existing

water and drainage infrastructure, to promote investments aiming to support

environmental protection and facilitate the sustainable growth of the county (SDCC, 2016).

5.1.2 River Basin Management Plan for Ireland 2018-2021

The River Basin Management Plan for Ireland 2018-2021 sets out the actions that Ireland

will take to improve water quality and achieve ‘good’ ecological status in water bodies

(rivers, lakes, estuaries and coastal waters) by 2021 (DoHPLG, 2018). Changes from

previous River Basin Management Plans is that all River Basin Districts are merged as one

national River Basin District. The Plan provides a more coordinated framework for

improving the quality of our waters — to protect public health, the environment, water

amenities and to sustain water-intensive industries, including agri-food and tourism,

particularly in rural Ireland.

It is important to note that Gallanstown Stream is not monitored in by the EPA under the

Water Framework Directive and as such has no biological (invertebrate) or supporting

water chemistry data or status. The nearest monitored river section is the River Camac

(CAMAC_040), where Gallanstown Stream flows into the River Camac in the Bluebell area.

Currently CAMAC_040 has a ‘Poor’ WFD status (2013-2018) and is considered to be ‘At

Risk’ (EPA, 2020). The potential effects arising from this development may lead to

degradation of these river bodies, and as such will be considered in the Appropriate

Assessment.

5.1.3 Other Projects

As of January 2017 there are no planning applications which are not retention applications,

home extensions and/or internal alterations, that have been granted planning permission in

the Clondalkin area, or adjacent to the Gallanstown Stream (NPAD, 2020).

Table 5-1: Projects granted planning permission within vicinity of the proposed site

and local watercourse.

Planning

Application

Ref.

Address Decision

- date

Proposed Development

SD17A/0397 Cloverhill

Road,

Raheen,

Dublin 22.

Granted -

10/05/2018

Residential development of 85 dwellings consisting

of: 65 houses and 20 apartments comprised of 4

no. 2 bed, 2 storey terraced houses, 1 no. 4 bed,

2 storey semi-detached house, 17 no. 3 bed, 2

storey semi-detached houses, 43 no. 3 bed, 2

storey townhouses in 10 terrace blocks, 1 no. 4

storey apartment block accommodating 12 no. 2

bedroom apartments and 1 no. 2 storey apartment

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Planning

Application

Ref.

Address Decision

- date

Proposed Development

block accommodating 8 no. 2 bedroom

apartments, all on a site area of 2.91 ha. The

proposal also provides for a single storey crèche

(207.11 sq.m) and all associated site development

and infrastructural works, car parking, open

spaces and landscaping. Proposed access to the

development will be via permitted access (Ref.

SD15A/0192) off Cloverhill Road.

SD18A/0299 Unit 20 &

Unit 21,

Weatherwell

Industrial

Estate,

Clondalkin,

Dublin 22

Granted -

18/10/2018

New industrial unit for storage space facility,

98sq.m and 8.2m in height and all associated site

works.

SD19A/0255 Unit 3-4,

Crag Avenue

Business

Park,

Clondalkin

Industrial

Estate,

Dublin 22

Granted –

07/10/2019

Permission for: (i) ground floor lobby and wc's; (ii)

extension of first floor mezzanine to provide open

plan office and storage area.

SD19A/0023 Unit 18/1,

Clondalkin

Industrial

Estate,

Dublin 22

Granted –

19/08/2019

370sq.m side & rear extension & new entrance.

SD18A/0024 Unit 15, Crag

Crescent,

Clondalkin

Industrial

Estate,

Clondalkin,

Dublin 22

Granted –

23/03/2018

A 347sq.m extension being single storey to the

rear and 2-storey to the side containing light

industrial storage and fabrication space.

5.1.4 Summary

The County Development Plan, RBMP and projects near the proposed project are

considered in combination with the currently proposed project in the Screening Assessment

section below.

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6 Appropriate Assessment

6.1 Introduction

This section presents a detailed assessment of the potential impact of the proposed project

on the qualifying interests of the Dublin Bay Natura 2000 sites. The screening report

identified surface water pollution as the potential impacts on qualifying interests of the

Natura 2000 sites.

Section 6.2 assesses the screened-in Natura 2000 sites in more detail and examines where

potentially adverse impacts may arise from the sources of impact identified (i.e. surface

water, land and air, or groundwater pathways). Where potentially adverse impacts are

identified, avoidance and mitigation measures are proposed. These are discussed in Section

6.3.

6.2 Potential Sources of Impact via Surface Water Pathways

The AA screening determined that pathway of impact existed between the proposed site

and the relevant Natura 2000 sites. This section further examines the source > pathway >

receptor chains that could potentially result in adverse impacts arising within the Dublin

Bay Natura 2000 sites.

Habitats and species, and their attributes, likely to be impacted by surface water pollution

are listed in Table 6-1.

6.2.1 Construction Phase - Direct impacts

Spill or leakage incidents may lead to pollutant materials entering the Dublin Bay Natura

2000 sites. There is potential for impacts on the water-dependent qualifying interests to

occur during the construction phase of the proposed project.

The construction phase of the project will comprise of the installation of a new dual-flow

drainage and balancing system within the development’s existing drainage network.

The possible accidental entry of pollutants, such as diesel, oil, solvents, cleaners; leaking

into the surface water network on-site during works has the potential to degrade the

surface water quality. This degradation of surface water can in turn impact the Natura 2000

site’s QIs via surface run-off into the Gallanstown Stream, Rivers Camac and Liffey, and

ultimately Dublin Bay. These pollutants may cause effects such as increased turbidity;

changes in pH levels; and introduction or increase in toxic chemicals. These potential

effects may impact on the floral communities of the Annex I habitats present within the

Natura 2000 sites, potentially resulting in decreased distribution of these communities, and

ultimately resulting in a percentage loss of the designated habitats. Additionally, these

pollutants could directly impact the bird QI species of the SPAs through contact with the

feathers, which will ultimately degrade the physical condition of these biological features.

Furthermore, these pollutants may be ingested through the grooming the affected feathers,

or while feeding within the aquatic environment. The potential direct impacts on QIs of the

Dublin Bay Natura 2000 sites from the construction phase are outlined in Table 6-1.

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Table 6-1: Potential direct impacts on the attributes of the designated features of the North Dublin Bay SAC within

the ZoI of the proposed project.

Qualifying

Interest

Attribute Measure Potential Impacts

Mudflats and

sandflats not

covered by seawater

at low tide [1140]

Habitat area Hectares N/A

Community extent Hectares Potential pollutants may negatively impact on the Mytilus edulis-dominated community and its extent.


Individuals/m² Potential pollutants may negatively impact on the Mytilus edulis density.

Community distribution Hectares Potential pollutants may negatively impact on the Pygospio elegans, Crangon crangon and Spio martinensis community complexes.


drift lines [1210]

Habitat area Hectares Potential pollutants may negatively impact on the total habitat area of annual drift line vegetation.

Habitat distribution Occurrence Potential pollutants may negatively impact on the overall distribution of annual drift line vegetation.

Physical structure: functionality and

sediment supply


N/A

Vegetation structure: zonation

Occurrence N/A



Potential pollutants may negatively impact on the species-poor communities with typical species: sea rocket (Cakile maritima), sea sandwort (Honckenya peploides), prickly saltwort (Salsola kali) and oraches (Atriplex spp.).


Percentage cover Potential pollutants may negatively impact on the positive indicator species, reducing their density and subsequently allowing the establishment of non-native invasive species.


annuals colonising

mud and sand

[1310]

Habitat area Hectares Potential pollutants may negatively impact on the total habitat area of Salicornia and other colonising annual vegetation.

Habitat distribution Occurrence Potential pollutants may negatively impact on the overall distribution of Salicornia and other colonising annual vegetation.

Physical structure: Presence/ absence of N/A

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Qualifying

Interest


sediment supply physical barriers


Occurrence N/A



N/A


Occurrence N/A


vegetation height

Centimetres Potential pollutants may negatively impact and alter the sward heights

of the Salicornia and other colonising annual vegetation.



Potential pollutants may negatively impact and subsequently reduce the total vegetation cover (outside of creeks).


Percentage cover Potential pollutants may negatively impact on the typical species and subcommunities.

Vegetation structure: negative indicator species - Spartina

anglica

Hectares Potential pollutants may negatively impact on the positive indicator species, reducing their density and subsequently allowing the establishment of non-native invasive species, such as Spartina anglica.

Atlantic salt

meadows (Glauco-

Puccinellietalia

maritimae) [1330]

Habitat area Hectares Potential pollutants may negatively impact on the total habitat area of Atlantic salt meadows.

Habitat distribution Occurrence Potential pollutants may negatively impact on the overall distribution of Atlantic salt meadows.



N/A

Physical structure:

creeks and pans

Occurrence N/A



N/A


Occurrence N/A

Vegetation structure: Centimetres Potential pollutants may negatively impact and alter the sward heights

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vegetation height of the Atlantic salt meadow vegetation.



of monitoring stops


Vegetation composition: typical species and

subcommunities

Percentage cover Potential pollutants may negatively impact on the typical species and subcommunities of Atlantic salt meadows.

Vegetation structure: negative indicator

species - Spartina anglica

Hectares Potential pollutants may negatively impact on the positive indicator species, reducing their density and subsequently allowing the

establishment of non-native invasive species, such as Spartina anglica.

Mediterranean salt

meadows (Juncetalia

maritimi) [1410]

Habitat area Hectares Potential pollutants may negatively impact on the total habitat area of Mediterranean salt meadows.

Habitat distribution Occurrence Potential pollutants may negatively impact on the overall distribution of Mediterranean salt meadows.



N/A


Occurrence N/A



N/A


Occurrence N/A


Centimetres Potential pollutants may negatively impact and alter the sward heights of the Mediterranean salt meadow vegetation.


vegetation cover

Percentage cover at a

representative number of monitoring stops

Potential pollutants may negatively impact and subsequently reduce the

total vegetation cover (outside of creeks).


Percentage cover Potential pollutants may negatively impact on the typical species and subcommunities of Mediterranean salt meadows.


Hectares Potential pollutants may negatively impact on the positive indicator species, reducing their density and subsequently allowing the

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species - Spartina anglica

establishment of non-native invasive species, such as Spartina anglica.

Embryonic shifting

dunes [2110]

Habitat area Hectares Potential pollutants may negatively impact on the total habitat area of Embryonic shifting dune vegetation.

Habitat distribution Occurrence Potential pollutants may negatively impact on the overall distribution of Embryonic shifting dune vegetation.

Physical structure:

functionality and sediment supply

Presence/absence of

physical barriers

N/A


Occurrence N/A


Percentage cover Potential pollutants may negatively impact on the health of foredune grass vegetation.



Potential pollutants may negatively impact on the typical species and subcommunities of Embryonic shifting dunes.



Shifting dunes along

the shoreline with

Ammophila arenaria

(white dunes)

[2120]

Habitat area Hectares Potential pollutants may negatively impact on the total habitat area of shifting dunes with Ammophila arenaria.

Habitat distribution Occurrence Potential pollutants may negatively impact on the overall distribution of shifting dunes with Ammophila arenaria.

Physical structure:

functionality and sediment supply


physical barriers

N/A


Occurrence N/A

Vegetation composition: plant health of dune

grasses

Percentage cover Potential pollutants may negatively impact on the health of dune grass vegetation.

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subcommunities


of monitoring stops

Potential pollutants may negatively impact on the typical species and subcommunities of shifting dunes with Ammophila arenaria.

Vegetation composition: negative indicator

species

Percentage cover Potential pollutants may negatively impact on the positive indicator species, reducing their density and subsequently allowing the

establishment of non-native invasive species.

Fixed coastal dunes

with herbaceous

vegetation (grey

dunes) [2130]

Habitat area Hectares Potential pollutants may negatively impact on the total habitat area of

Fixed coastal dunes with herbaceous vegetation.

Habitat distribution Occurrence Potential pollutants may negatively impact on the overall distribution of Fixed coastal dunes with herbaceous vegetation.



N/A


Occurrence N/A


Percentage cover Potential pollutants may negatively impact on the herbaceous vegetation reducing total cover, and thus increasing total bare ground

cover.


Centimetres Potential pollutants may negatively impact and alter the sward heights of the Fixed coastal dunes with herbaceous vegetation.



Potential pollutants may negatively impact on the typical species and subcommunities of Fixed coastal dunes with herbaceous vegetation.

Vegetation composition: negative indicator species (including Hippophae rhamnoides)



Percentage cover Potential pollutants may negatively impact on the herbaceous vegetation reducing total cover and allowing the encroachment of scrub.

Table 6-2: Potential direct impacts on the attributes of the designated features of the South Dublin Bay SAC within


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Mudflats and

sandflats not

covered by seawater

at low tide [1140]


Community extent Hectares Potential pollutants may negatively impact on the Zostera-dominated community and its extent.

Community structure: Zostera density

Individuals/m² Potential pollutants may negatively impact on the Zostera density.

Community distribution Hectares Potential pollutants may negatively impact on the Angulus tenuis community complex.


drift lines [1210]

Habitat area Hectares Potential pollutants may negatively impact on the total habitat area of annual drift line vegetation.

Habitat distribution Occurrence Potential pollutants may negatively impact on the overall distribution of annual drift line vegetation.



N/A


Occurrence N/A



Potential pollutants may negatively impact on the species-poor communities with typical species: sea rocket (Cakile maritima), sea sandwort (Honckenya peploides), prickly saltwort (Salsola kali) and oraches (Atriplex spp.).




annuals colonising

mud and sand

[1310]

Habitat area Hectares Potential pollutants may negatively impact on the total habitat area of Salicornia and other colonising annual vegetation.

Habitat distribution Occurrence Potential pollutants may negatively impact on the overall distribution of Salicornia and other colonising annual vegetation.



N/A


Occurrence N/A

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N/A


Occurrence N/A


Centimetres Potential pollutants may negatively impact and alter the sward heights of the Salicornia and other colonising annual vegetation.



of monitoring stops



Percentage cover Potential pollutants may negatively impact on the typical species and subcommunities.


Hectares Potential pollutants may negatively impact on the positive indicator species, reducing their density and subsequently allowing the establishment of non-native invasive species, such as Spartina anglica.

Embryonic shifting

dunes [2110]


Embryonic shifting dune vegetation.

Habitat distribution Occurrence Potential pollutants may negatively impact on the overall distribution of Embryonic shifting dune vegetation.



N/A


Occurrence N/A


plant health of foredune grasses

Percentage cover Potential pollutants may negatively impact on the health of foredune

grass vegetation.





Percentage cover Potential pollutants may negatively impact on the positive indicator species, reducing their density and subsequently allowing the

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species establishment of non-native invasive species.

Table 6-3: Potential direct impacts on the attributes of the designated features of the North Bull Island SPA within


Qualifying

Interest


Light-bellied Brent

Goose (Branta

bernicla hrota)

[A046]

Shelduck (Tadorna

tadorna) [A048]

Teal (Anas crecca)

[A052]


[A054]

Shoveler (Anas

clypeata) [A056]

Oystercatcher

(Haematopus

ostralegus) [A130]

Golden Plover

(Pluvialis apricaria)

[A140]

Grey Plover

(Pluvialis squatarola)

[A141]

Knot (Calidris

canutus) [A143]


alba) [A144]

Dunlin (Calidris

Population trend Percentage change Potential pollutants may negatively impact on the overall health of the

population resulting in decreased fecundity, ultimately leading to a decrease in population for the following QI bird species:

- Light-bellied Brent Goose

- Shelduck

- Teal

- Pintail

- Shoveler

- Oystercatcher

- Golden Plover

- Grey Plover

- Knot

- Sanderling

- Dunlin

- Black-tailed Godwit

- Bar-tailed Godwit

- Curlew

- Redshank

- Turnstone

- Black-headed Gull


Potential pollutants may negatively impact on the range, timing and intensity of use of areas within the SPA by the following QI bird species:


- Shelduck

- Teal

- Pintail

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alpina) [A149]

Black-tailed Godwit

(Limosa limosa)

[A156]

Bar-tailed Godwit

(Limosa lapponica)

[A157]

Curlew (Numenius

arquata) [A160]

Redshank (Tringa

totanus) [A162]

Turnstone (Arenaria

interpres) [A169]

Black-headed Gull

(Chroicocephalus

ridibundus) [A179]

- Shoveler

- Oystercatcher

- Golden Plover

- Grey Plover

- Knot

- Sanderling

- Dunlin


- Bar-tailed Godwit

- Curlew

- Redshank

- Turnstone

- Black-headed Gull

Wetland and

Waterbirds [A999]

Habitat area Hectares Potential pollutants may negatively impact on the wetland vegetation, resulting in a decrease of total wetland habitat.

Table 6-4: Potential direct impacts on the attributes of the designated features of the South Dublin Bay and River

Tolka Estuary SPA within the ZoI of the proposed project.

Qualifying

Interest


Light-bellied Brent

Goose (Branta

bernicla hrota)

[A046]

Oystercatcher

(Haematopus

ostralegus) [A130]

Population trend Percentage change Potential pollutants may negatively impact on the overall health of the

population resulting in decreased fecundity, ultimately leading to a decrease in population for the following QI bird species:


- Oystercatcher

- Ringed Plover

- Grey Plover

- Knot

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Ringed Plover

(Charadrius

hiaticula) [A137]

Grey Plover


[A141]

Knot (Calidris

canutus) [A143]


alba) [A144]

Dunlin (Calidris

alpina) [A149]

Bar-tailed Godwit

(Limosa lapponica)

[A157]

Redshank (Tringa

totanus) [A162]

Black-headed Gull

(Chroicocephalus

ridibundus) [A179]

- Sanderling

- Dunlin

- Bar-tailed Godwit

- Redshank

- Black-headed Gull


Potential pollutants may negatively impact on the range, timing and intensity of use of areas within the SPA by the following QI bird species:


- Oystercatcher

- Ringed Plover

- Grey Plover

- Knot

- Sanderling

- Dunlin

- Bar-tailed Godwit

- Redshank

- Black-headed Gull

Roseate Tern

(Sterna dougallii)

[A192]

Passage population: individuals

Number Potential pollutants may negatively impact on the overall health of individuals within the passage population, resulting in potential population decline.

Distribution: roosting areas

Number; location; area (hectares)

N/A

Prey biomass available Kilogrammes Potential pollutants may negatively impact on prey biomass as prey species

may reduce in quantity / quality, which in turn reduces prey biomass available for the Roseate Tern population.


N/A

Disturbance at roosting site

Level of impact N/A

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Common Tern

(Sterna hirundo)

[A193]

Breeding population abundance: apparently occupied nests (AONs)

Number Potential pollutants may negatively impact on the overall health of individuals within the breeding population, resulting in potential population / occupied nest decline.


Mean number Potential pollutants may negatively impact on the overall health of individuals within the breeding population, resulting in reducing fecundity and a decrease in fledged young per breeding pair.

Passage population:

individuals

Number Potential pollutants may negatively impact on the overall health of

individuals within the passage population, resulting in potential population decline.

Distribution: breeding colonies

Number; location; shape; area (hectares)

N/A



N/A

Prey biomass available Kilogrammes Potential pollutants may negatively impact on prey biomass as prey species may reduce in quantity / quality, which in turn reduces prey biomass available for the Common Tern population.


shape; area (hectares)

N/A

Disturbance at breeding site

Level of impact N/A


Level of impact N/A

Arctic Tern (Sterna

paradisaea) [A194]


Number Potential pollutants may negatively impact on the overall health of individuals within the passage population, resulting in potential population decline.



N/A

Prey biomass available Kilogrammes Potential pollutants may negatively impact on prey biomass as prey species may reduce in quantity / quality, which in turn reduces prey biomass available for the Artic Tern population.


N/A

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Level of impact N/A

Wetland and

Waterbirds [A999]


6.2.2 Construction Phase – Indirect impacts

Impacts to the Natura 2000 sites could impact the food chain for QI bird species, i.e. fish, macro-invertebrates and flora species

(also within the supporting habitat of the Natura 2000 site), which the faunal QI species of Natura 2000 site depend upon.

The potential indirect impacts on QIs from the construction phase are outlined in Table 6-5.

Table 6-5: Potential indirect impacts on the attributes of the designated features of North Bull Islands SPA within


Qualifying

Interest


Light-bellied Brent

Goose (Branta

bernicla hrota)

[A046]

Shelduck (Tadorna

tadorna) [A048]

Teal (Anas crecca)

[A052]


[A054]

Shoveler (Anas

clypeata) [A056]

Oystercatcher

(Haematopus

ostralegus) [A130]

Population trend Percentage change Potential pollutants may indirectly impact on QI bird species through reduction in food availability and quality (contaminated), which may negatively affect the overall health of the population resulting in decreased fecundity, ultimately leading to a decrease in population for the following QI bird species:


- Shelduck

- Teal

- Pintail

- Shoveler

- Oystercatcher

- Golden Plover

- Grey Plover

- Knot

- Sanderling

- Dunlin

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Interest


Golden Plover

(Pluvialis apricaria)

[A140]

Grey Plover


[A141]

Knot (Calidris

canutus) [A143]


alba) [A144]

Dunlin (Calidris

alpina) [A149]

Black-tailed Godwit

(Limosa limosa)

[A156]

Bar-tailed Godwit

(Limosa lapponica)

[A157]

Curlew (Numenius

arquata) [A160]

Redshank (Tringa

totanus) [A162]

Turnstone (Arenaria

interpres) [A169]

Black-headed Gull

(Chroicocephalus

ridibundus) [A179]


- Bar-tailed Godwit

- Curlew

- Redshank

- Turnstone

- Black-headed Gull


Potential pollutants may indirectly impact on QI bird species through reduction in food availability and quality (contaminated), which may

negatively impact on the range, timing and intensity of use of areas within the SPA by the following QI bird species:


- Shelduck

- Teal

- Pintail

- Shoveler

- Oystercatcher

- Golden Plover

- Grey Plover

- Knot

- Sanderling

- Dunlin


- Bar-tailed Godwit

- Curlew

- Redshank

- Turnstone

- Black-headed Gull

Wetland and

Waterbirds [A999]


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Table 6-6: Potential indirect impacts on the attributes of the designated features of South Dublin Bay and River

Tolka Estuary SPA within the ZoI of the proposed project.

Qualifying

Interest


Light-bellied Brent

Goose (Branta

bernicla hrota)

[A046]

Oystercatcher

(Haematopus

ostralegus) [A130]

Ringed Plover

(Charadrius

hiaticula) [A137]

Grey Plover


[A141]

Knot (Calidris

canutus) [A143]


alba) [A144]

Dunlin (Calidris

alpina) [A149]

Bar-tailed Godwit

(Limosa lapponica)

[A157]

Redshank (Tringa

totanus) [A162]

Black-headed Gull

(Chroicocephalus

ridibundus) [A179]

Population trend Percentage change Potential pollutants may indirectly impact on QI bird species through reduction in food availability and quality (contaminated), which may

negatively affect the overall health of the population resulting in decreased fecundity, ultimately leading to a decrease in population for the following QI bird species:


- Oystercatcher

- Ringed Plover

- Grey Plover

- Knot

- Sanderling

- Dunlin

- Bar-tailed Godwit

- Redshank

- Black-headed Gull


Potential pollutants may indirectly impact on QI bird species through reduction in food availability and quality (contaminated), which may negatively impact on the range, timing and intensity of use of areas within the SPA by the following QI bird species:


- Oystercatcher

- Ringed Plover

- Grey Plover

- Knot

- Sanderling

- Dunlin

- Bar-tailed Godwit

- Redshank

- Black-headed Gull

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Roseate Tern

(Sterna dougallii)

[A192]


Number Potential pollutants may indirectly impact on QI bird species through reduction in food availability and quality (contaminated), which may

negatively impact on the overall health of individuals within the passage population, resulting in potential population decline.



N/A

Prey biomass available Kilogrammes Potential pollutants may indirectly impact on QI bird species through reduction in food availability and quality (contaminated), which may

negatively impact on prey biomass as prey species may reduce in quantity

/ quality, which in turn reduces prey biomass available for the Roseate Tern population.


N/A


Level of impact N/A

Common Tern

(Sterna hirundo)

[A193]

Breeding population abundance: apparently

occupied nests (AONs)

Number Potential pollutants may indirectly impact on QI bird species through reduction in food availability and quality (contaminated), which may

negatively impact on the overall health of individuals within the breeding population, resulting in potential population / occupied nest decline.


Mean number Potential pollutants may indirectly impact on QI bird species through reduction in food availability and quality (contaminated), which may negatively impact on the overall health of individuals within the breeding population, resulting in reducing fecundity and a decrease in fledged young per breeding pair.


Number Potential pollutants may indirectly impact on QI bird species through reduction in food availability and quality (contaminated), which may negatively impact on the overall health of individuals within the passage

population, resulting in potential population decline.

Distribution: breeding colonies


N/A



N/A


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negatively impact on prey biomass as prey species may reduce in quantity / quality, which in turn reduces prey biomass available for the Common Tern population.


N/A

Disturbance at breeding site

Level of impact N/A


Level of impact N/A

Arctic Tern (Sterna

paradisaea) [A194]


Number Potential pollutants may indirectly impact on QI bird species through reduction in food availability and quality (contaminated), which may negatively impact on the overall health of individuals within the passage population, resulting in potential population decline.



N/A


negatively impact on prey biomass as prey species may reduce in quantity / quality, which in turn reduces prey biomass available for the Artic Tern population.


N/A


Level of impact N/A

Wetland and

Waterbirds [A999]


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6.2.3 Operational Impacts

6.2.3.1 Air & Dust

The proposed operational activities have the potential to have impacts upon local habitats

and species due to fugitive dust emissions and noise emissions. The impacts of operational

noise at the facility have been detailed in Section 10 of the EIAR (Environmental Efficiency,

2019). It has been determined that the operational noise emanating from the facility will

have no significant impact upon the surrounding environment.

Fugitive dust arises on-site due to the storage, handling and processing of lead. An

assessment of fugitive dust emissions detailed in Section 9 of the EIAR has concluded that

fugitive dust impacts will not be significant given the existing (and those in mitigation

section below) mitigation measures in place on-site (Environmental Efficiency, 2019).

Therefore, there is no anticipated operational impacts to the Natura 2000 sites and their

respective QIs, in regard to air quality.

6.2.3.2 Surface water & Groundwater

Prior to the installation of the Dual Flow Drainage System, the site’s operational surface

water drainage, under first-flush conditions, would contain toxic levels of metals (Lead, Zinc

and Nickel) which will likely result in impacts to the local aquatic environment (Gallanstown

Stream), as well as potentially the Dublin Bay Natura 2000 sites and their respective QIs.

Under the Dual Flow Proposal, ‘first flush’ stormwater, containing elevated lead

concentrations, will be discharged to a retention tank before gradually draining to foul

sewer. ‘First flush’ stormwater run-off which is directed to foul sewer will be treated at the

Ringsend WWTP before being discharged to the environment. During a prolonged or intense

rainfall stormwater run-off will eventually fill the retention tank before by-passing the tank

and being directed to the public stormwater sewer and then onto the Gallanstown Stream.

This by-pass stormwater un-off will contain negligible concentrations of lead due to the

occurrence of the ‘first flush’ effect. An Assimilative Capacity Assessment has been

undertaken demonstrating that the anticipated stormwater discharges to the Gallanstown

Stream will not result in an exceedance of the Environmental Quality Standard for Lead in

surface waters of 1.2 μg/l, as defined in the Surface Water Regulations.

As such, anticipated stormwater discharges to receiving surface waters are not expected to

have a significant, adverse impact upon the water quality of the Gallanstown Stream;

Rivers Camac and Liffey; and Dublin Bay.

Additionally, hazardous liquids stored and in use on-site (e.g. hydrocarbons), have the

potential to spill or leak and subsequently cause pollution affecting the aquatic environment

of Gallanstown Stream and the waterbodies downstream. Mitigation measures in the form

of hazardous material bunding and emergency spill response procedures/equipment are

detailed in following mitigation measures section (Section 6.3).

Furthermore, in the event of a fire on-site, hazardous substances could be released and

contaminate the run-off firewater. In the absence of any mitigation measures, this

contaminated run-off could potentially impact the local watercourse, as well as the

waterbodies downstream, including the Dublin Bay Natura 2000 sites. However, there is a

number of control systems in place on-site for this potential occurrence, the details of

which are listed in the mitigations section (Section 6.3)

Therefore, there is no anticipated operational impacts to the Natura 2000 sites, in regard to

surface water or groundwater quality.

6.2.4 Do Nothing Impact

If the proposed project does not go ahead there is the potential for a continuous impact

from the operations of the current development on the Dublin Bay Natura 2000 sites.

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6.2.5 Significance of Cumulative and In-combination Impacts

There are a number of other project developments planned for the Clondalkin area (Section

5). As the development’s overall waste outputs will not increase as a result of these

installation (construction) and operational works, there will be no in-combination

cumulative effects on the QI habitats and species designated for the Natura 2000 sites.

6.3 Mitigation Measures

6.3.1 Adherence to Best Practice Guidance

The activities of the project for the construction phase shall remain within the boundary of

the proposed site. Within this area, the mitigation measures outlined below shall be

implemented.

• A Construction and Environment Management Plan (CEMP) will be submitted to

South Dublin County Council for agreement prior to site works commencing. This

CEMP will incorporate the mitigation measures listed here.

• The CEMP will also strictly adhere to best practice environmental guidance

including but not limited to the following:

• CIRIA Guidance C532 Control of water pollution from construction sites.

Guidance for consultants and contractors. (CIRIA, 2019 - www.ciria.org);

• CIRIA Guidance C741: Environmental good practice on site guide (Charles &

Edwards, 2015; CIRIA, 2019 - www.ciria.org);

• CIRIA Guidance C750D: Groundwater control: design and practice (Preene et al.,

2016; CIRIA, 2019 - www.ciria.org);

• Inland Fisheries Ireland 2016 Guidance on Protection of Fisheries During

Construction Works In and Adjacent to Waters;

• Construction method statements will be submitted to South Dublin County

Council for agreement prior to site works commencing.

6.3.2 Water Quality

Relevant legislation and best practice guidance that have been considered includes but not

limited to the following:

• CIRIA C532 Control of water pollution from construction sites. Guidance for

consultants and contractors (CIRIA, 2019 - www.ciria.org)

• CIRIA C515 Groundwater control – design and practice, 2nd ed. (CIRIA, 2019 -

www.ciria.org)

• CIRIA Guidance C741: Environmental good practice on site guide (Charles &

Edwards, 2015; CIRIA, 2019 - www.ciria.org)

• Inland Fisheries Ireland 2016 Guidance on Protection of Fisheries During

Construction Works In and Adjacent to Waters

• Adoption of a surface water / groundwater plan including appropriate barrier

controls to prevent any seepage of potentially polluted surface water from the

site into the groundwater table below (e.g. geotextile barriers).

• Oil booms and oil soakage pads should be maintained on-site to enable a rapid

and effective response to any accidental spillage or discharge. These shall be

disposed of correctly and records will be maintained by the environmental

manager of the used booms and pads taken off site for disposal.

• Fail-safe site drainage and bunding through drip trays on plant and machinery

will be provided to prevent discharge of chemical spillage from the sites to

surface water.

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6.3.3 Pollution Control and Spill Prevention

Spill kits containing absorbent pads, granules and booms will be stored in the site

compound with easy access for delivery to site in the case of an emergency. A

minimum stock of spill kits will be maintained at all times and site foremen’s

vehicles will carry large spill kits at all times. Absorbent material will be used with

pumps and generators at all times and used material disposed of in accordance with

the Waste Management Plan. All used spill materials e.g. Absorbent pads will be

placed in a bunded container in the contractor's compound. The material will be

disposed of by a licenced waste contractor at a licenced facility. Records will be

maintained by the environmental site manager.

Regular inspections and maintenance of plant and machinery checking for leaks, damage or

vandalism will be made on all plant and equipment.

In the event of a spill the Contractor will ensure that the following procedure are in place:

• Emergency response awareness training for all Project personnel on-site works.

• Appropriate and sufficient spill control materials will be installed at strategic

locations within the site. Spills kits for immediate use will be kept in the cab of

mobile equipment.

• Spill kits will be stored in the site compound with easy access for delivery to site

in the case of an emergency. A minimum stock of spill kits will be maintained at

all times and site vehicles will carry spill kits at all times. Spill kits must include

suitable spill control materials to deal with the type of spillage that may occur

and where it may occur. Typical contents of an on-site spill kit will include the

following as a minimum;

• Absorbent granules;

• Absorbent mats/cushions;

• Absorbent booms

• Spill kits will contain gloves to handle contaminated materials and sealable

disposal sacks.

• Track-mats, geotextile material and drain covers.

• All potentially polluting substances such as oils and chemicals used during

construction will be stored in containers clearly labelled and stored with suitable

precautionary measures such as bunding within the site compound.

• All tank and drum storage areas on the site will, as a minimum, be bunded to a

volume not less than the following;

• 110% of the capacity of the largest tank or drum within the bunded area, or

• 25% of the total volume of substances which could be stored within the bunded

area.

• The site compound fuel storage areas and cleaning areas will be rendered

impervious and will be constructed to ensure no discharges will cause pollution

to surface or ground waters.

• Designated locations for refuelling are within Site Compound and 50m away from

dual flow system installation area.

• Potentially contaminated run off from plant and machinery maintenance areas

will be managed within the site compound surface water collection system.

• Damaged or leaking containers will be removed from use and replaced

immediately.

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• The construction of a Dual Flow Drainage System to ensure that stormwater

containing elevated concentration of lead will be directed to foul sewer rather

than towards the Gallanstown Stream.

• Fire prevention and control systems are in place on-site in order to ensure the

prevention of a major fire scenario which could result in the release of

contaminated firewater to the environment. These are listed below:

- A programme of inspection and preventative maintenance for equipment that

poses a risk such as gas burners and melting kettles has been established and

will be implemented on an ongoing basis at the facility.

- Standard Operating Procedures to ensure the effective and safe operation and

control of processes have been established for working activities at the facility

that pose risk.

- Flammable liquids are stored on-site in designated bunded storage areas away

from heat sources.

- Sodium hydroxide, Calcium hydroxide and Sodium nitrate (which poses an

explosive hazard) are stored in a cool, dry place in a segregated, contained

storage area in Building D and are protected from heat sources and mechanical

impact. Sodium nitrate is stored in accordance with national explosives

legislation. The facility is a licensed factory/magazine with the Department of

Justice under this legislation.

- In a fire scenario shut off valves will be shut at the existing storm sewer and

proposed foul sewer outlets. Initially, the underground tanks and the water

retention tank, which will be constructed on-site as part of the Dual Flow

Drainage System proposal, will be capable of retaining 112 and 202 m3 of

potentially contaminated firewater which may arise during a fire scenario on-site

respectively. In a fire scenario firewater will make its way to these tanks by way

of the drainage network on-site.

- Further firewater retention facilities will be provided on-site in the unlikely

event the capacity of the above-mentioned tanks is exceeded by the volume of

contaminated firewater generated in a fire scenario. Overspill from the tank will

flow into the sites watertight drainage system, which will be sealed through the

use of the aforementioned shut off valves, before overflowing to the sites

concreted, yard area. As part of this proposal, it is proposed to install kerbing of

30 cm in height along the southern boundary of the site, and the south eastern

and south western boundaries of the site in order to convert the southern portion

of the site into a firewater containment area. This will provide a substantial

amount of additional retention capacity on-site. It is anticipated that this will

provide sufficient firewater retention capabilities for any major fire that may

occur on-site.

• Underground tanks, a water retention tank, the stormwater drainage system and

the kerbed, southern section of the yard will provide retention capabilities on-

site ensuring any contaminated firewater generated during a fire scenario would

not be discharged to the receiving environment.

6.3.4 General storage, site-cleaning and air/dust-based mitigations

The following Mitigation Measures will be implemented on-site to prevent and minimize the

potential for adverse environmental impacts upon sensitive ecological receptors in the

surrounding area:

• The storage, handling and processing of materials will take place indoors to

minimize noise and dust emissions emanating off-site which may impact upon

ecology in the local area.

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• Road sweeping of the yard will take place on a weekly basis to minimize the

levels of fugitive dust contained in the yard area.

• An air pollution abatement system comprising an air cyclone and a baghouse

filter will reduce hazardous air emissions from smelting/refining processes that

may contribute to reduced ambient air quality affecting local ecology (existing).

6.3.5 Post-Installation Monitoring programme

Post Dual Flow Drainage System monitoring to be conducted for the first 5 first-flush

scenarios, where rainfall exceeds the retention capacity of the tank, in order to establish

suitable functionality.

6.4 Residual Impacts

Table 6-7 in overleaf summaries the potential impacts on the attributes of the designated

QIs of the Dublin Bay Natura 2000 sites along with the mitigation measures and residual

impacts.

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59

Table 6-7: Pathways of impact on the attributes of the designated QIs of the Dublin Bay Natura 2000 sites.

Natura

2000 sites

Qualifying

Interest

Attribute Measure Potential Impacts Cumulative Impacts

Mitigation Measures Residual Impact

North

Dublin Bay

SAC

[000206]

Mudflats and sandflats not covered by seawater at low tide [1140]

Community extent

Hectares Potential pollutants may negatively impact on the Mytilus edulis-dominated community and its extent.

Impacts on habitats, species and water quality from surface

water run-off from the industrial park and surrounding area to local watercourses.

Strict adherence to:

- The CEMP and all the best

practice guidance therewith.

- Site compound layout instructions, ensuring that potential sources of pollution

(chemical storage and machinery) are kept at minimum of 50m away from the dual flow system installation area.

- Water quality controls,

including the firewater run-off prevention and control protocols.

- Pollution control and spill prevention methods, detailing suitable spill kit equipment and management on site.

- General house-keeping

mitigations, i.e. suitable storage of materials, weekly vacuum sweeping of the site’s

hardstanding surface; and maintaining the efficiency of the air cyclone and a baghouse filter.

No adverse effects

Community structure:

Mytilus edulis density

Individuals/m² Potential pollutants may negatively impact on the

Mytilus edulis density.

No adverse

effects

Community distribution

Hectares Potential pollutants may negatively impact on the

Pygospio elegans, Crangon crangon and Spio martinensis

community complexes.

No adverse

effects

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60

Natura

2000 sites

Qualifying

Interest



- Post Dual Flow Drainage

System monitoring to be conducted for the first 5 first-flush scenarios, where rainfall exceeds the retention capacity of the tank, in order to establish suitable

functionality.

Annual vegetation of drift lines

[1210]


annual drift line vegetation.

Impacts on habitats, species and

water quality from surface water run-off from the industrial park and

surrounding

area to local watercourses.


- The CEMP and all the best practice guidance therewith.

- Site compound layout instructions, ensuring that potential sources of pollution (chemical storage and

machinery) are kept at minimum of 50m away from

the dual flow system installation area.

- Water quality controls, including the firewater run-off

prevention and control protocols.

- Pollution control and spill

prevention methods, detailing suitable spill kit equipment and management on site.


mitigations, i.e. suitable storage of materials, weekly

No adverse effects

Habitat distribution

Occurrence Potential pollutants may negatively impact on the overall distribution of annual drift line

vegetation.

No adverse effects



Potential pollutants may negatively impact on the species-poor communities with typical species: sea rocket (Cakile maritima), sea sandwort (Honckenya

peploides), prickly saltwort (Salsola kali) and oraches (Atriplex spp.).

No adverse effects


Percentage cover

Potential pollutants may negatively impact on the positive indicator species, reducing their density and subsequently allowing the

establishment of non-

No adverse effects

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61

Natura

2000 sites

Qualifying

Interest



native invasive species. vacuum sweeping of the site’s



System monitoring to be conducted for the first 5 first-flush scenarios, where rainfall exceeds the retention capacity of the tank, in order to

establish suitable functionality.

Salicornia and other annuals colonising mud

and sand [1310]


Salicornia and other colonising annual vegetation.


water quality from surface water run-off from the industrial park

and surrounding area to local watercourses.




- Site compound layout instructions, ensuring that potential sources of pollution (chemical storage and machinery) are kept at

minimum of 50m away from the dual flow system installation area.

- Water quality controls, including the firewater run-off prevention and control protocols.


No adverse effects


Occurrence Potential pollutants may negatively impact on the overall distribution of Salicornia and other colonising annual

vegetation.

No adverse effects


vegetation height

Centimetres Potential pollutants may negatively impact and

alter the sward heights of the Salicornia and other colonising annual vegetation.

No adverse

effects

Vegetation structure: vegetation

Percentage cover at a representative


No adverse effects

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62

Natura

2000 sites

Qualifying

Interest



cover number of

monitoring stops

total vegetation cover

(outside of creeks).

prevention methods, detailing

suitable spill kit equipment and management on site.



vacuum sweeping of the site’s hardstanding surface; and maintaining the efficiency of the air cyclone and a baghouse filter.

- Post Dual Flow Drainage System monitoring to be conducted for the first 5 first-

flush scenarios, where rainfall

exceeds the retention capacity of the tank, in order to establish suitable functionality.


subcommunities

Percentage cover

Potential pollutants may negatively impact on the typical species and subcommunities.

No adverse effects

Vegetation structure: negative indicator species -

Spartina anglica

Hectares Potential pollutants may negatively impact on the positive indicator species, reducing their density and subsequently

allowing the establishment of non-native invasive species,

such as Spartina anglica.

No adverse effects

Atlantic salt meadows (Glauco-Puccinellietalia maritimae)

[1330

Habitat area Hectares Potential pollutants may negatively impact on the total habitat area of Atlantic salt meadows.


water run-off from the

industrial park and surrounding area to local watercourses.




- Site compound layout

instructions, ensuring that

potential sources of pollution (chemical storage and machinery) are kept at minimum of 50m away from the dual flow system installation area.

No adverse effects


Occurrence Potential pollutants may negatively impact on the

overall distribution of Atlantic salt meadows.

No adverse

effects


vegetation height

Centimetres Potential pollutants may negatively impact and

alter the sward heights of the Atlantic salt meadow vegetation.

No adverse

effects

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63

Natura

2000 sites

Qualifying

Interest




cover

Percentage cover at a representative

number of monitoring stops


total vegetation cover (outside of creeks).






mitigations, i.e. suitable storage of materials, weekly vacuum sweeping of the site’s hardstanding surface; and maintaining the efficiency of

the air cyclone and a

baghouse filter.


flush scenarios, where rainfall exceeds the retention capacity of the tank, in order to establish suitable functionality.

No adverse effects

Vegetation

composition: typical species and subcommunities

Percentage

cover

Potential pollutants may

negatively impact on the typical species and subcommunities of Atlantic salt meadows.

No

adverse effects


species -

Spartina anglica

Hectares Potential pollutants may negatively impact on the positive indicator species, reducing their density

and subsequently

allowing the establishment of non-native invasive species, such as Spartina anglica.

No adverse effects

Mediterranean salt meadows (Juncetalia maritimi) [1410]

Habitat area Hectares Potential pollutants may negatively impact on the total habitat area of Mediterranean salt meadows.


water run-off from the





No adverse effects



No adverse

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64

Natura

2000 sites

Qualifying

Interest



overall distribution of

Mediterranean salt meadows.

industrial park



potential sources of pollution (chemical storage and machinery) are kept at minimum of 50m away from the dual flow system installation area.


- Pollution control and spill prevention methods, detailing suitable spill kit equipment

and management on site.

- General house-keeping mitigations, i.e. suitable storage of materials, weekly



System monitoring to be conducted for the first 5 first-flush scenarios, where rainfall exceeds the retention capacity

of the tank, in order to establish suitable functionality.

effects


Centimetres Potential pollutants may negatively impact and alter the sward heights of the Mediterranean salt

meadow vegetation.

No adverse effects




No adverse effects

Vegetation composition: typical

species and subcommunities

Percentage cover

Potential pollutants may negatively impact on the typical species and

subcommunities of Mediterranean salt meadows.

No adverse effects


Hectares Potential pollutants may negatively impact on the positive indicator species, reducing their density and subsequently allowing the establishment of non-

native invasive species,

such as Spartina anglica.

No adverse effects

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65

Natura

2000 sites

Qualifying

Interest



Embryonic shifting dunes [2110]


Embryonic shifting dune vegetation.


water quality from surface water run-off from the

industrial park and

surrounding area to local watercourses.




instructions, ensuring that potential sources of pollution (chemical storage and machinery) are kept at minimum of 50m away from the dual flow system

installation area.


prevention and control

protocols.

- Pollution control and spill prevention methods, detailing





- Post Dual Flow Drainage System monitoring to be

No adverse effects



overall distribution of Embryonic shifting dune vegetation.

No adverse

effects


Percentage cover

Potential pollutants may negatively impact on the health of foredune grass vegetation.

No adverse effects


typical species and

subcommunities

Percentage cover at a

representative number of

monitoring stops

Potential pollutants may negatively impact on the

typical species and subcommunities of

Embryonic shifting dunes.

No adverse

effects


negative indicator species

Percentage cover


positive indicator species, reducing their density and subsequently allowing the


No adverse

effects

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66

Natura

2000 sites

Qualifying

Interest



conducted for the first 5 first-


Shifting dunes

along the shoreline with Ammophila arenaria (white

dunes) [2120]

Habitat area Hectares Potential pollutants may

negatively impact on the total habitat area of shifting dunes with Ammophila arenaria.

Impacts on

habitats, species and water quality from surface

water run-off from the industrial park and surrounding area to local

watercourses.



- Site compound layout instructions, ensuring that

potential sources of pollution (chemical storage and machinery) are kept at minimum of 50m away from




suitable spill kit equipment



vacuum sweeping of the site’s hardstanding surface; and

No

adverse effects


Occurrence Potential pollutants may negatively impact on the overall distribution of

shifting dunes with Ammophila arenaria.

No adverse effects

Vegetation

composition: plant health of dune grasses

Percentage

cover


negatively impact on the health of dune grass vegetation.

No

adverse effects



Potential pollutants may negatively impact on the typical species and subcommunities of shifting dunes with Ammophila arenaria.

No adverse effects


species

Percentage cover

Potential pollutants may negatively impact on the positive indicator species, reducing their density

and subsequently allowing the establishment of non-native invasive species.

No adverse effects

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67

Natura

2000 sites

Qualifying

Interest



maintaining the efficiency of

the air cyclone and a baghouse filter.


System monitoring to be conducted for the first 5 first-


Fixed coastal dunes with herbaceous

vegetation (grey dunes) [2130]

Habitat area Hectares Potential pollutants may negatively impact on the total habitat area of Fixed

coastal dunes with herbaceous vegetation.


water quality from surface

water run-off from the industrial park and surrounding




- Site compound layout instructions, ensuring that potential sources of pollution (chemical storage and machinery) are kept at minimum of 50m away from the dual flow system

installation area.


including the firewater run-off




No adverse effects


Occurrence Potential pollutants may negatively impact on the overall distribution of Fixed coastal dunes with herbaceous vegetation.

No adverse effects


Percentage cover

Potential pollutants may negatively impact on the herbaceous vegetation reducing total cover, and thus increasing total bare ground cover.

No adverse effects


Centimetres Potential pollutants may negatively impact and alter the sward heights of the Fixed coastal dunes

with herbaceous vegetation.

No adverse effects

Vegetation Percentage Potential pollutants may No

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68

Natura

2000 sites

Qualifying

Interest



composition:

typical species and subcommunities

cover at a

representative number of monitoring stops

negatively impact on the

typical species and subcommunities of Fixed coastal dunes with herbaceous vegetation.

- General house-keeping mitigations, i.e. suitable

storage of materials, weekly vacuum sweeping of the site’s hardstanding surface; and maintaining the efficiency of


- Post Dual Flow Drainage System monitoring to be conducted for the first 5 first-flush scenarios, where rainfall


adverse

effects


negative indicator species (including

Hippophae rhamnoides)

Percentage cover




No adverse

effects


Percentage cover

Potential pollutants may negatively impact on the herbaceous vegetation reducing total cover and

allowing the encroachment of scrub.

No adverse effects

South

Dublin Bay

SAC

(000210)

Mudflats and sandflats not covered by

seawater at low tide [1140]

Community extent

Hectares Potential pollutants may negatively impact on the Zostera-dominated

community and its extent.



industrial park and





instructions, ensuring that potential sources of pollution (chemical storage and machinery) are kept at minimum of 50m away from the dual flow system

installation area.

No adverse effects

Community

structure: Zostera density

Individuals/m² Potential pollutants may

negatively impact on the Zostera density.

No

adverse effects

Community distribution

Hectares Potential pollutants may negatively impact on the Angulus tenuis

community complex.

No adverse effects

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69

Natura

2000 sites

Qualifying

Interest




including the firewater run-off prevention and control protocols.



- General house-keeping mitigations, i.e. suitable storage of materials, weekly vacuum sweeping of the site’s hardstanding surface; and maintaining the efficiency of


baghouse filter.


conducted for the first 5 first-flush scenarios, where rainfall exceeds the retention capacity of the tank, in order to establish suitable functionality.

Annual

vegetation of drift lines [1210]

Habitat area Hectares Potential pollutants may

negatively impact on the total habitat area of annual drift line

vegetation.

Impacts on

habitats, species and water quality

from surface water run-off from the industrial park





No

adverse effects



overall distribution of

No adverse

effects

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70

Natura

2000 sites

Qualifying

Interest



annual drift line

vegetation.

and


potential sources of pollution




- General house-keeping mitigations, i.e. suitable storage of materials, weekly vacuum sweeping of the site’s



conducted for the first 5 first-flush scenarios, where rainfall exceeds the retention capacity of the tank, in order to


Habitat area Hectares Potential pollutants may negatively impact on the

total habitat area of annual drift line vegetation.

No adverse

effects


Occurrence Potential pollutants may negatively impact on the overall distribution of annual drift line vegetation.

No adverse effects

Salicornia and Habitat area Hectares Potential pollutants may Impacts on Strict adherence to: No

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71

Natura

2000 sites

Qualifying

Interest



other annuals

colonising mud and sand [1310]

negatively impact on the

total habitat area of Salicornia and other colonising annual vegetation.

habitats,

species and water quality from surface water run-off from the industrial park








hardstanding surface; and

maintaining the efficiency of the air cyclone and a baghouse filter.


adverse

effects



overall distribution of Salicornia and other colonising annual vegetation.

No adverse

effects


height

Centimetres Potential pollutants may negatively impact and alter the sward heights of

the Salicornia and other colonising annual vegetation.

No adverse effects




No adverse effects


subcommunit

ies

Percentage cover

Potential pollutants may negatively impact on the typical species and subcommunities.

No adverse effects


negative indicator species - Spartina

Hectares Potential pollutants may negatively impact on the


No adverse

effects

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72

Natura

2000 sites

Qualifying

Interest



anglica establishment of non-

native invasive species, such as Spartina anglica.

flush scenarios, where rainfall


Embryonic shifting dunes

[2110]

Habitat area Hectares Potential pollutants may negatively impact on the

total habitat area of Embryonic shifting dune vegetation.

Impacts on habitats,

species and water quality from surface water run-off

from the industrial park and surrounding area to local watercourses.





(chemical storage and machinery) are kept at minimum of 50m away from the dual flow system

installation area.


- Pollution control and spill prevention methods, detailing suitable spill kit equipment



hardstanding surface; and maintaining the efficiency of

No adverse

effects


Occurrence Potential pollutants may negatively impact on the overall distribution of Embryonic shifting dune

vegetation.

No adverse effects


plant health of foredune grasses

Percentage cover


health of foredune grass vegetation.

No adverse

effects




No adverse effects

Vegetation

composition: negative indicator species

Percentage

cover


negatively impact on the positive indicator species, reducing their density and subsequently

allowing the establishment of non-native invasive species.

No

adverse effects

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73

Natura

2000 sites

Qualifying

Interest




baghouse filter.


conducted for the first 5 first-flush scenarios, where rainfall


North Bull

Island SPA

[004006]

Light-bellied Brent Goose (Branta bernicla

hrota) [A046]

Shelduck

(Tadorna tadorna) [A048]

Teal (Anas crecca) [A052]

Pintail (Anas

acuta) [A054]

Shoveler (Anas

clypeata) [A056]

Oystercatcher (Haematopus ostralegus) [A130]

Golden Plover (Pluvialis apricaria) [A140]

Population trend

Percentage change

Potential pollutants may:

- negatively impact on the overall health of the population resulting in

decreased fecundity;

- indirectly impact on QI bird species through reduction in food availability and quality

(contaminated), which may negatively affect the overall health of the population resulting in decreased fecundity

ultimately leading to a decrease in population for the following QI bird species:

Light-bellied Brent Goose

Shelduck


water quality

from surface water run-off from the industrial park and surrounding




- Site compound layout instructions, ensuring that potential sources of pollution (chemical storage and machinery) are kept at minimum of 50m away from the dual flow system

installation area.




suitable spill kit equipment

No adverse effects

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Natura

2000 sites

Qualifying

Interest



Grey Plover

(Pluvialis squatarola) [A141]

Knot (Calidris canutus) [A143]

Sanderling

(Calidris alba) [A144]

Dunlin (Calidris alpina) [A149]

Black-tailed Godwit (Limosa limosa) [A156]

Bar-tailed Godwit (Limosa lapponica)

[A157]

Curlew (Numenius arquata) [A160]

Redshank (Tringa totanus)

[A162]

Turnstone

(Arenaria interpres) [A169]

Black-headed Gull (Chroicocephalus ridibundus) [A179]

Teal

Pintail

Shoveler

Oystercatcher

Golden Plover

Grey Plover

Knot

Sanderling

Dunlin

Black-tailed Godwit

Bar-tailed Godwit

Curlew

Redshank

Turnstone

Black-headed Gull



vacuum sweeping of the site’s hardstanding surface; and

maintaining the efficiency of the air cyclone and a baghouse filter.

- Post Dual Flow Drainage System monitoring to be conducted for the first 5 first-flush scenarios, where rainfall exceeds the retention capacity

of the tank, in order to




- negatively impact on

the overall health of the population resulting in decreased fecundity;

- indirectly impact on QI

bird species through reduction in food availability and quality (contaminated), which

may negatively affect the overall health of the

population resulting in decreased fecundity

, which may in turn negatively impact on the

No adverse effects

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75

Natura

2000 sites

Qualifying

Interest



range, timing and

intensity of use of areas within the SPA by the following QI bird species:


Shelduck

Teal

Pintail

Shoveler

Oystercatcher

Golden Plover

Grey Plover

Knot

Sanderling

Dunlin

Black-tailed Godwit

Bar-tailed Godwit

Curlew

Redshank

Turnstone

Black-headed Gull

Wetland and Waterbirds [A999]


No adverse effects

South

Dublin Bay

and River

Light-bellied Brent Goose (Branta bernicla hrota) [A046]

Population trend

Percentage change



the overall health of the population resulting in

Impacts on habitats, species and water quality



No adverse effects

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76

Natura

2000 sites

Qualifying

Interest



Tolka

Estuary SPA

[004024]

Oystercatcher

(Haematopus ostralegus) [A130]

Ringed Plover (Charadrius hiaticula)

[A137]

Grey Plover (Pluvialis squatarola) [A141]

Knot (Calidris canutus) [A143]

Sanderling (Calidris alba)

[A144]

Dunlin (Calidris

alpina) [A149]

Bar-tailed Godwit (Limosa

lapponica) [A157]

Redshank (Tringa totanus) [A162]

Black-headed Gull

(Chroicocephalus ridibundus) [A179]

decreased fecundity;

- indirectly impact on QI bird species through reduction in food

availability and quality (contaminated), which

may negatively affect the overall health of the population resulting in decreased fecundity

ultimately leading to a decrease in population for the following QI bird species:


Oystercatcher

Ringed Plover

Grey Plover

Knot

Sanderling

Dunlin

Bar-tailed Godwit

Redshank

Black-headed Gull

from surface


watercourses.



(chemical storage and machinery) are kept at






hardstanding surface; and maintaining the efficiency of the air cyclone and a

baghouse filter.

- Post Dual Flow Drainage System monitoring to be conducted for the first 5 first-flush scenarios, where rainfall exceeds the retention capacity

Distribution Range, timing and intensity

of use of areas


- negatively impact on the overall health of the population resulting in decreased fecundity;

- indirectly impact on QI bird species through

No adverse

effects

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77

Natura

2000 sites

Qualifying

Interest



reduction in food

availability and quality (contaminated), which may negatively affect the overall health of the population resulting in decreased fecundity

, which may in turn negatively impact on the range, timing and intensity of use of areas

within the SPA by the following QI bird species:


Oystercatcher

Ringed Plover

Grey Plover

Knot

Sanderling

Dunlin

Bar-tailed Godwit

Redshank

Black-headed Gull

of the tank, in order to


Roseate Tern (Sterna dougallii)

[A192]


Number Potential pollutants may:


the overall health of individuals within the passage population, resulting in potential population decline.

- indirectly impact on QI bird species through



industrial park and surrounding



- Site compound layout instructions, ensuring that potential sources of pollution (chemical storage and

No adverse effects

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78

Natura

2000 sites

Qualifying

Interest



reduction in food

availability and quality (contaminated), which may negatively impact on the overall health of individuals within the passage population,

resulting in potential population decline.

area to local

watercourses.

machinery) are kept at





- General house-keeping mitigations, i.e. suitable

storage of materials, weekly vacuum sweeping of the site’s hardstanding surface; and maintaining the efficiency of



System monitoring to be conducted for the first 5 first-flush scenarios, where rainfall


Prey biomass available

Kilogrammes Potential pollutants may:

- negatively impact on prey biomass as prey species may reduce in

quantity / quality, which in turn reduces prey biomass available for the Roseate Tern population.

- indirectly impact on QI bird species through reduction in food availability and quality (contaminated), which

may negatively impact on prey biomass as prey species may reduce in quantity / quality, which in turn reduces prey biomass available for the

Roseate Tern population.

No adverse

effects

Common Tern (Sterna hirundo) [A193]

Breeding population abundance:


- negatively impact on the overall health of



No adverse effects

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79

Natura

2000 sites

Qualifying

Interest



apparently

occupied nests (AONs)

individuals within the

breeding population, resulting in potential population / occupied nest decline;


bird species through reduction in food availability and quality (contaminated), which may negatively impact on

the overall health of individuals within the breeding population, resulting in potential population / occupied nest decline.

water quality

from surface water run-off from the industrial park and surrounding



practice guidance therein.


potential sources of pollution (chemical storage and

machinery) are kept at minimum of 50m away from the dual flow system installation area.




vacuum sweeping of the site’s hardstanding surface; and maintaining the efficiency of


- Post Dual Flow Drainage System monitoring to be conducted for the first 5 first-flush scenarios, where rainfall


Mean number Potential pollutants may:

- negatively impact on the overall health of individuals within the breeding population, resulting in reducing

fecundity and a decrease in fledged young per breeding pair;

- indirectly impact on QI bird species through reduction in food availability and quality (contaminated), which may negatively impact on the overall health of

individuals within the

No adverse effects

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80

Natura

2000 sites

Qualifying

Interest



breeding population,

resulting in reducing fecundity and a decrease in fledged young per breeding pair.

exceeds the retention capacity

of the tank, in order to establish suitable functionality.

Passage population:

individuals



the overall health of individuals within the passage population, resulting in potential population decline;

- indirectly impact on QI bird species through reduction in food availability and quality

(contaminated), which may negatively impact on the overall health of individuals within the passage population, resulting in potential population decline.

No adverse

effects



- negatively impact on prey biomass as prey species may reduce in

quantity / quality, which

in turn reduces prey biomass available for the Common Tern population;


No adverse effects

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81

Natura

2000 sites

Qualifying

Interest



bird species through

reduction in food availability and quality (contaminated), which may negatively impact on prey biomass as prey species may reduce in

quantity / quality, which in turn reduces prey biomass available for the Common Tern population.

Arctic Tern (Sterna paradisaea) [A194]




the overall health of individuals within the passage population, resulting in potential population decline;

- indirectly impact on QI bird species through reduction in food availability and quality (contaminated), which

may negatively impact on prey biomass as prey species may reduce in quantity / quality, which

in turn reduces prey biomass available for the Artic Tern population.

Impacts on habitats, species and water quality from surface water run-off

from the

industrial park and surrounding area to local watercourses.




instructions, ensuring that potential sources of pollution


- Water quality controls, including the firewater run-off prevention and control

protocols.


No adverse effects



- negatively impact on prey biomass as prey species may reduce in quantity / quality, which

No adverse effects

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82

Natura

2000 sites

Qualifying

Interest



in turn reduces prey

biomass available for the Artic Tern population;


bird species through reduction in food

availability and quality (contaminated), which may negatively impact on prey biomass as prey species may reduce in

quantity / quality, which in turn reduces prey biomass available for the Artic Tern population.


mitigations, i.e. suitable storage of materials, weekly vacuum sweeping of the site’s hardstanding surface; and maintaining the efficiency of the air cyclone and a

baghouse filter.



Wetland and Waterbirds [A999]




watercourses




potential sources of pollution (chemical storage and machinery) are kept at minimum of 50m away from



No adverse effects

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83

Natura

2000 sites

Qualifying

Interest






mitigations, i.e. suitable storage of materials, weekly vacuum sweeping of the site’s hardstanding surface; and maintaining the efficiency of the air cyclone and a baghouse filter.


conducted for the first 5 first-


6.4.1 Additional Note on Non-QI, Protected Species potentially present within the ZoI

The mitigation measures outlined in the above sections and tables will also ensure that none of the nationally and

internationally protected species (listed in Table 4-3) potentially present in the ZoI will experience any adverse impacts, either

direct or indirect, as a result of the works carried during the construction or operational phases of the proposed project.

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84

7 Conclusions

JBA Consulting Ireland Ltd. was commissioned by Environmental Efficiency, on behalf of

Metal Processors Ltd. to undertake a Natura Impact Assessment (NIS) in relation to the

proposed installation of the Dual Flow Drainage System at their site in Clondalkin Industrial

Estate, Co. Dublin.

The proposed project is identified as occurring within the Zone of Influence of the following

Natura 2000 sites:

• North Dublin Bay SAC

• South Dublin Bay SAC

• North Bull Island SPA

• South Dublin and River Tolka Estuary SPA

The proposed site is connected to the Natura 2000 sites via the surface water pathway,

from Gallanstown Stream to the Rivers Camac and Liffey; and onwards to Dublin Bay.

The qualifying interests within the Zone of Influence are:

• Mudflats and sandflats not covered by seawater at low tide [1140]

• Annual vegetation of drift lines [1210]

• Salicornia and other annuals colonising mud and sand [1310]

• 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]

• Fixed coastal dunes with herbaceous vegetation (grey dunes) [2130]

• Light-bellied Brent Goose (Branta bernicla hrota) [A046]

• Shelduck (Tadorna tadorna) [A048]

• Teal (Anas crecca) [A052]

• Pintail (Anas acuta) [A054]

• Shoveler (Anas clypeata) [A056]

• Oystercatcher (Haematopus ostralegus) [A130]

• Ringed Plover (Charadrius hiaticula) [A137]

• Golden Plover (Pluvialis apricaria) [A140]

• Grey Plover (Pluvialis squatarola) [A141]

• Knot (Calidris canutus) [A143]

• Sanderling (Calidris alba) [A144]

• Dunlin (Calidris alpina) [A149]

• Black-tailed Godwit (Limosa limosa) [A156]

• Bar-tailed Godwit (Limosa lapponica) [A157]

• Curlew (Numenius arquata) [A160]

• Redshank (Tringa totanus) [A162]

• Turnstone (Arenaria interpres) [A169]

• Black-headed Gull (Chroicocephalus ridibundus) [A179]

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85

• Roseate Tern (Sterna dougallii) [A192]

• Common Tern (Sterna hirundo) [A193]

• Arctic Tern (Sterna paradisaea) [A194]

• Wetland and Waterbirds [A999]

The potential impact from the proposed project is posed during construction and relates to

potential pollution of surface water caused by the operational emissions of metals in

surface water network and accidental spillage of pollutants, such as diesel and oil, which

could impact on the designated QI habitats and species.

Mitigation measures have been proposed for the area of the proposed site and for inclusion

in surface water pollution and disturbance control measures, ensuring that no adverse

effects in relation to surface water pollution or physical land-based disturbance occur.

It is concluded that provided that the mitigation measures outlined are strictly

adhered to, adverse effects are not likely to occur from the works involved with the

proposed installation of the Dual Flow Drainage System at their site in Clondalkin Industrial

Estate, Co. Dublin; in-combination with other projects and plans on the following Natura

2000 sites:

• North Dublin Bay SAC

• South Dublin Bay SAC

• North Bull Island SPA

• South Dublin and River Tolka Estuary SPA

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I

Appendices

A Site Drainage Layout (including Dual Flow Drainage System)

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II

B Dual Flow System

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III

C Habitat Map

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References

DEHLG, 2009. Appropriate Assessment of Plans and Projects in Ireland. Guidance for Planning

Authorities, available:

https://www.npws.ie/sites/default/files/publications/pdf/NPWS_2009_AA_Guidance.pdf

DoHPLG, 2020. ‘National Planning website’, available: https://myplan.ie/national-planning-

application-map-viewer/.

EC, 2002. Assessment of Plans and Projects Significantly Affecting Natura 2000 Sites:

Methodological Guidance on the Provisions of Article 6(3) and (4) of the Habitats Directive

92/43/EEC, EUR-OP: Luxembourg.

EC, 2007. Guidance Document on Article 6(4) of the ‘Habitats Directive’ 92/43/EEC. Clarification of

the Concepts of: Alternative Solutions, Imperative Reasons of Overriding Public Interest,

Compensatory Measures, Overall Coherence, Opinion of the Commission, available:

http://ec.europa.eu/environment/nature/natura2000/management/docs/art6/guidance_art6_4_en.

pdf

EPA, 2020. EPA Maps [online], Next Generation EPA Maps, available: https://gis.epa.ie/EPAMaps/

European Commission, Office for Official Publications of the European Communities (Eds.) (2000)

Managing Natura 2000 Sites: The Provisions of Article 6 of the ‘Habitats’ Directive 92/43/EEC, Office

for Official Publications of the European Communities: Luxembourg.

NBDC, 2020. Biodiversity Maps - Map Viewer [online], National Biodiversity Data Centre Biodiversity

Maps, available: http://maps.biodiversityireland.ie/#/Map.

NPAD, 2020. National Planning Application Database – Map Viewer [website]. Available online at:

https://housinggovie.maps.arcgis.com/apps/webappviewer/index.html?id=9cf2a09799d74d8e9316a

3d3a4d3a8de

NPWS, 2013a. Conservation Objectives: North Dublin Bay SAC 000206. Version 1. National Parks

and Wildlife Service, Department of Arts, Heritage and the Gaeltacht. Available online at:

https://www.npws.ie/sites/default/files/protected-sites/conservation_objectives/CO000206.pdf

NPWS, 2013b. Conservation Objectives: South Dublin Bay SAC 000210. Version 1. National Parks



NPWS, 2015a. Conservation Objectives: North Bull Island SPA 004006. Version 1. National Parks



NPWS, 2015b. Conservation Objectives: South Dublin Bay and River Tolka Estuary SPA 004024.

Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.

Available online at: https://www.npws.ie/sites/default/files/protected-

sites/conservation_objectives/CO004024.pdf

NPWS, 2018a. Natura 2000 – Standard Data Form: North Dublin Bay SAC. National Parks and

Wildlife Service, Department of Arts, Heritage and the Gaeltacht. Available online at:

https://www.npws.ie/sites/default/files/protected-sites/natura2000/NF000206.pdf

NPWS, 2018b. Natura 2000 – Standard Data Form: South Dublin Bay SAC. National Parks and



NPWS, 2018c. Natura 2000 – Standard Data Form: North Bull Island SPA. National Parks and



NPWS, 2018d. Natura 2000 – Standard Data Form: South Dublin Bay and River Tolka Estuary SPA.

National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht. Available online

at: https://www.npws.ie/sites/default/files/protected-sites/natura2000/NF004024.pdf

NPWS, 2020. ‘National Parks & Wildlife Service Website’, available: https://www.npws.ie/.

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https://housinggovie.maps.arcgis.com/apps/webappviewer/index.html?id=9cf2a09799d74d8e9316a3d3a4d3a8de

https://housinggovie.maps.arcgis.com/apps/webappviewer/index.html?id=9cf2a09799d74d8e9316a3d3a4d3a8de








SSCC, 2016. ‘South Dublin County Council Development Plan 2016-2022’. Available online at:

https://www.southdublindevplan.ie/sites/default/files/documents/CDP%202016-

2022%20(lower%20res).pdf

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Offices at

Coleshill Doncaster Dublin Edinburgh Exeter Glasgow Haywards Heath Isle of Man Limerick Newcastle upon Tyne Newport Peterborough Saltaire Skipton Tadcaster Thirsk Wallingford Warrington Registered Office 1 Broughton Park Old Lane North Broughton SKIPTON North Yorkshire BD23 3FD United Kingdom +44(0)1756 799919 [email protected] www.jbaconsulting.com Follow us: Jeremy Benn Associates Limited Registered in England 3246693 JBA Group Ltd is certified to: ISO 9001:2015

ISO 14001:2015 OHSAS 18001:2007

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mailto:[email protected]

http://www.jbaconsulting.com/

https://www.linkedin.com/company/jba-consulting-ltd-jeremy-benn-/

https://twitter.com/JBAConsulting

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jba consulting report template 2015

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