prepared for: lawlor, burns & associatescanalbanklimerick.com/.../natura-impact-statement... ·...

NATURA IMPACT STATEMENT

Canal Bank Development, Limerick

Developer: Revington Developments Ltd.

Prepared for: Lawlor, Burns & Associates

SLR Ref: 501.00672.00002

Version No: 1

December 2019

Client Name: Lawlor, Burns & Associates

Report Title: Canal Bank Development, Limerick - Natura Impact Statement

Filename: 501.00672.00002_CanalBank-NIS_10122019_A1 Final

SLR Ref No: 501.00672.00001

December 2019

.

Document Control

Document Properties

Organisation SLR Consulting

Project Name Canal Bank, Limerick

Report Title Natura Impact Statement

Author(s) Ida Bailey and Elaine Dromey

Draft version/final Final

Document reference 501.00672.00002_CanalBank-NIS_10122019_A1

DATE Revision

No

Prepared

by

Reviewed

by

Approved by Status Comments

18/12/20

19

1 Ida Bailey

Elaine

Dromey

Bob

Edmonds

Draft For internal review and

amendments.

19/12/20

19

1 Ida Bailey Tim Paul Bob

Edmonds

FINAL For issue to client.

BASIS OF REPORT

This document has been prepared by SLR Consulting with reasonable skill, care and diligence, and taking account of the manpower,

timescales and resources devoted to it by agreement with Lawlor, Burns & Associates (the Client) as part or all of the services it has been

appointed by the Client to carry out. It is subject to the terms and conditions of that appointment. SLR shall not be liable for the use of or

reliance on any information, advice, recommendations and opinions in this document for any purpose by any person other than the

Client. Reliance may be granted to a third party only in the event that SLR and the third party have executed a reliance agreement or

collateral warranty. Information reported herein may be based on the interpretation of public domain data collected by SLR, and/or

information supplied by the Client and/or its other advisors and associates. These data have been accepted in good faith as being accurate

and valid. The copyright and intellectual property in all drawings, reports, specifications, bills of quantities, calculations and other

information set out in this report remain vested in SLR unless the terms of appointment state otherwise. This document may contain

information of a specialised and/or highly technical nature and the Client is advised to seek clarification on any elements which may be

unclear to it. Information, advice, recommendations and opinions in this document should only be relied upon in the context of the whole

document and any documents referenced explicitly herein and should then only be used within the context of the appointment.




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CONTENTS

INTRODUCTION ............................................................................................................... 1

1.1 General Description of the Site ................................................................................................. 1

1.2 Brief Project Description ........................................................................................................... 1

1.3 Aim of the Report...................................................................................................................... 1

1.4 Objectives of Appropriate Assessment ..................................................................................... 2

1.5 Evidence of Technical Competence and Experience ................................................................. 2

RELEVANT LEGISLATION ................................................................................................... 3

2.1 European Nature Directives (Habitats and Birds) ..................................................................... 3

2.2 EC (Birds and Natural Habitats) Regulations 2011 .................................................................... 3

METHODS ....................................................................................................................... 5

3.1 Desk Study ................................................................................................................................ 5

3.2 Potential Zone of Influence ....................................................................................................... 5

3.3 Natura Impact Statement ......................................................................................................... 5

DETAILED DESCRIPTION OF THE DEVELOPMENT ............................................................... 7

NATURA IMPACT STATEMENT .......................................................................................... 9

5.1 Screening Assessment (Stage 1)................................................................................................ 9

5.2 Assessment of the effects of the project or plan on the integrity of Natura 2000 Sites ......... 10

CONSIDERATION OF FINDINGS ....................................................................................... 18

REFERENCES .................................................................................................................. 19

DOCUMENT REFERENCES

TABLES

Table 5-1: Qualifying features of the Lower River Shannon SAC and River Shannon and River Fergus

Estuaries SPA....................................................................................................................................... 10

DRAWINGS

Drawing 1: Canal Bank Development, Limerick City - Natura Impact Statement: Natura 2000 Sites




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Introduction

SLR Consulting Ireland (SLR) was commissioned by Lawlor, Burns & Associates, in November 2019, on behalf of

Revington Developments Ltd., to prepare a Natura Impact Statement for the proposed Canal Bank Development

in Limerick City.

1.11.11.11.1 General Description ofGeneral Description ofGeneral Description ofGeneral Description of the Sitethe Sitethe Sitethe Site The project site is located within Limerick City. It is bounded to the south by Pa Healy Road and to the east by

Park Rd. The Park Canal is located to the north of the site. It is dominated by recolonising bare ground habitat,

with areas of immature Salix woodland and spoil material particularly in the east and north. The recent historic

use included facilitating storage of building materials and construction machinery.

To the north, the site is adjacent to the Lower River Shannon SAC, in the form of the Park Canal 30m from the

site boundary and a large area of wetland habitat to the north of the canal. The canal is raised in relation to the

site, and groundwater from the therefore passes underneath it as it moves north-west. In addition, there is a

deep drain at the base of the canal embankment, separating surface water from the site from the canal and no

connection has been recorded on site between the drain and the canal to the north (Verde, 2019). Between the

drain and the canal is a tow-path that is in frequent use by pedestrians.

The next waterbodies north-west, in the path of the groundwater flow direction, are the wetland to the north of

the Park Canal and the River Abbey 580m away. The Abbey River flows in a southerly direction joining the River

Shannon lower approximately 1.1km to the west of the site.

The Park Canal connects the Abbey River to the River Shannon flowing in an easterly direction. The canal supports

qualifying habitats of the SAC including: The rare and nationally protected Groenlandia densa community of

“Watercourses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation”.

The area surrounding the site to the south, east and west is largely urban, dominated by buildings and artificial

surfaces with small areas of amenity grassland and landscaping.

1.21.21.21.2 Brief Project DescriptionBrief Project DescriptionBrief Project DescriptionBrief Project Description The site is proposed for a mixed use, principally residential, public space and car parking. Development comprises

apartment buildings (six and seven storeys) including approximately: c. 61 student apartments and c. 363

residential apartments; a Creche/cafe building (three storeys) and retail units.

All surface water generated during the construction phase will be contained within the site or will drain to the

existing combined sewer network, through which it will be conveyed to the municipal wastewater treatment

plant (WWTP) for treatment prior to discharge.

Surface water run-off from the completed development will be collected in a piped system (with manholes

containing silt traps) and passed through a hydrocarbon interceptor before being discharged to Park Canal. The

discharge volume will be restricted to pre-development run-off volumes and there is attenuation storage

incorporated into the design through the two retention basins shown on PHM Consulting Drawing No. 201 –

Drainage General Arrangement for the scheme. All wastewater from the development will be directed to the

existing sewerage network and will be conveyed to the WWTP for treatment prior to discharge.

1.31.31.31.3 Aim of the ReportAim of the ReportAim of the ReportAim of the Report This aim of this report is to provide supporting information to assist the competent authority to carry out

appropriate assessment of the proposed development at Canal Bank, Limerick, under the Habitats Directive. This

report includes a screening for likely significant effects on Natura 2000 sites (Stage 1 Assessment) and

information to inform an appropriate assessment to determine if there will be an adverse effect on the integrity

of Natura 2000 sites as a result of the proposed development (Stage 2 Assessment).




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1.41.41.41.4 Objectives of Appropriate AssessmentObjectives of Appropriate AssessmentObjectives of Appropriate AssessmentObjectives of Appropriate Assessment The Habitats Directive promotes a hierarchy of avoidance, mitigation and compensatory measures to be

addressed in the AA process as follows:

• Firstly, a plan / project should aim to avoid any negative impacts on Natura 2000 sites by identifying

possible impacts early and designing the project / plan to avoid such impacts.

• Secondly, mitigation measures should be applied during the Appropriate Assessment (after Stage 1

screening stage) process to the point where no adverse impacts on the site(s) remain.

• Thirdly a plan / project may have to undergo an assessment of alternative solutions. Under this stage of

the assessment, compensatory measures are required for any remaining adverse effects, but they are

permitted only if (a) there are no alternative solutions and (b) the plan / project is required for imperative

reasons of overriding public interest (the ‘IROPI test’). European case law highlights that consideration

must be given to alternatives outside the plan / project boundary area in carrying out the IROPI test.

1.51.51.51.5 Evidence of Technical Competence and Experience Evidence of Technical Competence and Experience Evidence of Technical Competence and Experience Evidence of Technical Competence and Experience This Natura Impact Statement (NIS) was prepared by Ida Bailey ACIEEM. Bob Edmonds MCIEEM CEnv carried out

the technical review of the NIS.

Bob Edmonds is a Technical Director at SLR Consulting Ltd and has 20 years professional experience working as

a consultant ecologist. Bob is a full member of the Chartered Institute of Ecology and Environmental

Management and a Chartered Environmentalist. Bob has prepared AA screening reports and Natura Impact

Statements (NIS) in the UK and Ireland for a range of different projects.

Ida Bailey holds a PhD from the University of Edinburgh. She is an Associate member of the Chartered Institute

of Ecology and Environmental Management and an active member of the Society for Ecological Restoration (SER).

Ida has prepared ecological reports including Appropriate Assessment (AA) screening reports for a range of

sectors including for renewable energy, grid, quarries and landfill projects.




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Relevant Legislation

2.12.12.12.1 European Nature Directives (Habitats and Birds)European Nature Directives (Habitats and Birds)European Nature Directives (Habitats and Birds)European Nature Directives (Habitats and Birds) The Habitats Directive (Council Directive 92/43/EEC on the Conservation of Natural Habitats and of Wild Fauna

and Flora) forms the basis for the designation of Special Areas of Conservation. Similarly, Special Protection Areas

are classified under the Birds Directive (Council Directive 2009/147/EEC on the Conservation of Wild Birds).

Collectively, Special Areas of Conservation (SAC) and Special Protection Areas (SPA) are referred to as the Natura

2000 network. In general terms, they are considered to be of exceptional importance for rare, endangered or

vulnerable habitats and species within the European Community.

Under Article 6(3) of the Habitats Directive an Appropriate Assessment must be undertaken for any plan or

project that is likely to have a significant effect on the conservation objectives of a Natura 2000 site. An

Appropriate Assessment is an evaluation of the potential impacts of a plan or project on the conservation

objectives of a Natura 2000 site, and the development, where necessary, of mitigation or avoidance measures

to preclude negative effects.

Article 6, paragraph 3 of the EC Habitats Directive 92/43/EEC (“the Habitats Directive”) states that:

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

have a significant effect thereon, either individually or in combination with other plans or projects, shall

be subject to appropriate assessment of its implications 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”.

2.22.22.22.2 EC (Birds and Natural Habitats) Regulations 2011EC (Birds and Natural Habitats) Regulations 2011EC (Birds and Natural Habitats) Regulations 2011EC (Birds and Natural Habitats) Regulations 2011 Part 5 of the EC (Birds and Natural Habitats) Regulations 2011 sets out the circumstances under which an

‘appropriate assessment’ is required. Section 42(1) requires that ‘a screening for Appropriate Assessment of a

plan or project for which an application for consent is received, or which a public authority wishes to undertake

or adopt, and which is not directly connected with or necessary to the management of the site as a European Site,

shall be carried out by the public authority to assess, in view of best scientific knowledge and in view of the

conservation objectives of the site, if that plan or project, individually or in combination with other plans or

projects is likely to have a significant effect on the European site.’

Section 42(2) expands on this, stipulating that a public authority must carry out a screening for Appropriate

Assessment before consent for a plan or project is given, or a decision to undertake or adopt a plan or project is

taken. To assist a public authority to discharge its duty in this respect, Section 42(3)(a) gives them the authority

to direct a third party to provide a Natura Impact Statement and Section 42(3)(b) allows them to request any

additional information that is considered necessary for the purposes of undertaking a screening assessment. A

Natura Impact Statement has to include such information or data as the public authority considers necessary to

enable it to ascertain if the plan or project will affect the integrity of a Natura 2000 site. Where appropriate, a

Natura Impact Statement also needs to include:

I. the alternative solutions that have been considered and the reasons why they have not been

adopted,

II. the imperative reasons of overriding public interest that are being relied upon to indicate that

the plan or project should proceed notwithstanding that it may adversely affect the integrity of

a European site,

III. the compensatory measures that are being proposed.




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Section 42(6) requires that ‘the public authority shall determine that an Appropriate Assessment of a plan or

project is required where the plan or project is not directly connected with or necessary to the management of

the site as a European Site and if it cannot be excluded, on the basis of objective scientific information following

screening under this Regulation, that the plan or project, individually or in combination with other plans or

projects, will have a significant effect on a European site’.




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Methods

3.13.13.13.1 Desk SDesk SDesk SDesk Studytudytudytudy A desk study was carried out to support the preparation of the NIS. Information available on Natura 2000

sites within the potential zone of influence of the proposed works was collated. The National Parks and

Wildlife Service (NPWS) website1 was accessed for information on Natura 2000 sites. Environmental

Protection Agency (EPA) Maps2 was accessed for other environmental information relevant to preparation

of this report.

The documents reviewed to assist the preparation of this NIS include: the environmental due diligence report

(Verde, 2019), for the development; A Construction Environmental and Waste Management Plan (CEMP)

(PHM Consulting, 2019) and design drawings and project information supplied by the client.

3.23.23.23.2 Potential Zone of InfluencePotential Zone of InfluencePotential Zone of InfluencePotential Zone of Influence The ‘zone of influence’ for a project is the area over which ecological features may be affected by biophysical

changes as a result of the proposed project and associated activities. This is likely to extend beyond the

project site, for example where there are ecological or hydrological links beyond the site boundaries. The

zone of influence will vary for different ecological features depending on their sensitivity to an environmental

change (CIEEM, 2018).

A distance of 15 km is currently recommended in the case of plans, as a potential zone of influence, and this

distance is derived from UK guidance (Scott Wilson and Levett-Therivel, 2006). For projects, the distance

could be much less than 15 km, and in some cases less than 100 m. National Parks and Wildlife Service

guidance advises that this must be evaluated on a case-by-case basis with reference to the nature, size and

location of the project, the sensitivities of the ecological receptors, and the potential for in-combination

effects.

The Natura 2000 sites that lie within 15km of the site are the River Shannon and River Fergus Estuaries SPA

approximately 2km away and Lower River Shannon SAC c. 30m away (Drawing 1). These two sites are

considered to be within the Zone of Influence of the project site.

3.33.33.33.3 Natura Impact StatementNatura Impact StatementNatura Impact StatementNatura Impact Statement The report prepared to support an Appropriate Assessment of the project sets out information required for

appropriate assessment as follows:

• Set out information on the Natura 2000 sites identified within the zone of influence of the project.

• Undertake a screening stage assessment and present the conclusion on the likelihood of a significant

effect.

• Describe the elements of the project or plan (alone or in combination with other projects or plans)

that are likely to give rise to significant effects on the environment.

• Set out the conservation objectives of the Natura 2000 sites.

• Describe how the project or plan will affect key species and key habitats. Acknowledge uncertainties

and gaps in information.

• Describe how the integrity of the site (determined by structure and function and conservation

objectives) is likely to be affected by the project or plan (e.g. loss of habitat, disturbance, disruption,

______________________

1 https://www.npws.ie/protected-sites (last accessed 04 December 2019) 2 http://gis.epa.ie/(last accessed 04 December 2019)




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chemical changes, hydrological changes and geological changes, etc.). Acknowledge also

uncertainties and any gaps in information.

It is the role of the competent authority to undertake an appropriate assessment, which should be informed

by the information contained within this NIS3. Where considered necessary, the competent authority may

request additional information to support their assessment.

The approach taken in preparing the NIS is based on standard methods and guidance, as listed in the

references section of this report.

______________________

3 Page 28 https://www.npws.ie/sites/default/files/publications/pdf/NPWS_2009_AA_Guidance.pdf




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Detailed Description of the Development

The detailed description of the development has been taken from the site Construction Environmental and

Waste Management Plan (PHM Consulting, 2019).

The planning application comprises of a mixed use development on a circa 4 ha site with vehicular access

points from Pa Healy Road. The development will consist of:

(A) Demolition of existing 800m2 warehouse building on site.

(B) Block 1 – Student accommodation building of 8,238m2 stepped from three to six storeys, with ground

floor café of 144.60m2 and 3 no. retail units facing onto Pa Healy road of 86.59m2 each, with 9 no. two

bedroom, 37 no. three bedroom, and 15 no. four bedroom student apartments, totalling 189 bed spaces,

ancillary laundry, refuse and enclosed communal courtyard with landscaping and bicycle storage;

(C) Block 2 - A residential apartment building of 6,013.25m2 with nine storeys and two penthouse storeys,

total eleven storeys containing 10 no. studio, 1 no. one bedroom and 52 no. two-bedroom apartments;

(D) Block 3 – A residential apartment building of 8,107.10m2 with six storeys and two penthouse storeys,

total eight storeys containing 16 no. studio, 9 no. one bedroom, and 63 no. two-bedroom apartments;

(E) Block 4 – A residential apartment building of 3,869.18m2 with six storeys and one penthouse storey, total

seven storeys containing 7 no. studio, 13 no. one bedroom and 25 no. two-bedroom apartments;

(F) Block 5 – A residential apartment building of 5,849.40m2 with six storey and one penthouse storey total


(G) Block 6 a residential apartment building of 3,869.18m2 with six storeys and one penthouse storey, total


(H) Block 7 a residential apartment building of 4,962m2 with five storeys and one penthouse storey, total six

storeys containing 12 no. studio, 13 no. one bedroom and 31 no. two-bedroom apartments;

(I) Community facilities building of 1,336.90m2 and three storeys with creche, café, management offices and

common accommodation for use by apartment dwellers;

The scheme does not include any excavations for basements. In addition, it likely that redevelopment of the

site will involve importing soils to raise levels on the site.

To address concerns raised following site investigations relating to contaminated ground, the following

working methods have been advised (Verde, 2019):

• To minimise the potential risks posed by contaminated soil by removal of the source of

contamination, including soil: excavation, storage and transportation of in the areas of identified and

quantified contamination;

• Material excavation, segregation and removal should be managed and supervised by a competent

person to ensure correct procedures are followed and that wastes are appropriately logged and

tracked according to waste management requirements and legislation.

• Encapsulation of contaminated soils by the importation of suitable clean fill material onto the site;

• Backfilling the service trenches with material considered to be clean and not contaminated;

• Where off-site disposal of contaminated soils (waste) is required, all lorry loads will be sheeted once

loaded and before leaving site to reduce dust generation;

• Any stock piles containing contaminated soils will be placed on an impermeable surface while

awaiting the results of validation testing. The stockpiles will be sheeted to minimise dust emissions

and also to minimise the potential for leaching rainwater and run off contaminating clean areas;




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• Adequate precautions will be taken during site works to prevent surface water run-off from the site

affecting the local surface waters and drainage network; and

• Dust monitoring and dust suppression will be carried out during any remedial works. As a minimum

this will include visual inspections to identify dust generating activities and damping down such

sources as when required.

A construction environmental and waste management plan (PHM Consulting, 2019) has been developed and

will be implemented prior to the redevelopment of the site. The CEMP seeks to:

1. Provide a basis for achieving and implementing the construction related mitigation measures

identified in the Natura Impact Statement (NIS).

2. Comply with all relevant conditions attached to the Planning Permission.

3. Promote best environmental on-site practices for the duration of the construction phase.

As stated in Section 1.2 above surface water run-off from the completed development will be collected in a

piped system (with manholes containing silt traps) and passed through a hydrocarbon interceptor before

being discharged to the canal. The discharge volume will be restricted to pre-development run-off volumes

and there is attenuation storage incorporated into the design through the two retention basins shown on

PHM Consulting Drawing No. 201 – Drainage General Arrangement for the scheme. All wastewater from the

development will be directed to the existing sewerage network and will be conveyed to the WWTP for

treatment prior to discharge.




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Natura Impact Statement

We have considered the following Natura 2000 sites, which are considered to be within the zone of influence

of the project:

• The River Shannon and River Fergus Estuaries SPA (004077).

• The Lower River Shannon SAC (002165).

This report uses the headings within the appropriate assessment report template provided in the European

Commission (2001) guidance document ‘Assessment of plans and projects significantly affecting Natura 2000

sites’4 have been to provide a basis to examine the potential effects on Natura 2000 sites as a result of the

proposed housing development at Canal Park, Limerick.

5.15.15.15.1 Screening Assessment (Stage 1)Screening Assessment (Stage 1)Screening Assessment (Stage 1)Screening Assessment (Stage 1) The project site is not currently considered to be hydrologically connected any Natura 2000 sites via the

surface water environment as:

• There are no watercourse on site;

• There are no drainage channels/ ditches on site connecting to watercourses;

• The canal is raised relative to the site and is an engineered feature lined with impermeable barrier

to prevent escape of the water and is buffered from the site by a deep drainage ditch. The site and

canal are therefore not considered to be hydrologically connected (Verde, 2019, Section 5.5.3);

Surface water run-off from the completed development will be collected in a piped system (with manholes

containing silt traps) and passed through a hydrocarbon interceptor before being discharged to the

canal. The discharge volume will be restricted to pre-development run-off volumes and there is attenuation

storage incorporated into the design through the two retention basins shown on PHM Consulting Drawing

No. 201 – Drainage General Arrangement for the scheme. All wastewater from the development will be

directed to the existing sewerage network and will be conveyed to the WWTP for treatment prior to

discharge.

The detailed site investigation has concluded that there is a ‘very low risk from leaching of contamination

[including Barium contamination] from the contaminated soils to the limestone aquifer’ (Verde 2019).

Therefore, there is potential for groundwater flows resulting from construction activities during this project

to connect into Natura 2000 sites, i.e. a wetland area north of the site and River Abbey, both of which are

part of the Lower River Shannon SAC and hydrologically contiguous with the River Shannon and River Fergus

Estuaries SPA.

In addition to groundwater connectivity, otter (Lutra lutra) are a qualifying feature of Lower River Shannon

SAC which are known to be sensitive to disturbance, including human disturbance. Disturbance may occur

during the construction or the operation/occupation of the site. There is a separation distance of 30m from

the Park Canal, part of the Lower River Shannon SAC, at its closest point to the project site.

Due to the risk of groundwater contamination during construction, a likely significant effect upon the River

Shannon and River Fergus Estuaries SPA cannot be screened out.

Due to the risk of groundwater contamination, and a risk of contaminated surface water run-off from the

development entering the Lower River Shannon SAC, and the risk of disturbance impacts to otters, a likely

significant effect upon the Lower River Shannon SAC cannot be screened out.

______________________

4 http://ec.europa.eu/environment/nature/natura2000/management/docs/art6/natura_2000_assess_en.pdf




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5.25.25.25.2 Assessment of the effects of the project or plan on the integrity of Natura Assessment of the effects of the project or plan on the integrity of Natura Assessment of the effects of the project or plan on the integrity of Natura Assessment of the effects of the project or plan on the integrity of Natura

2000 Sites2000 Sites2000 Sites2000 Sites This section of the report sets out the potential effects of the proposed works (either alone or in combination

with other projects or plans) on the integrity the River Shannon and River Fergus Estuaries SPA and Lower

River Shannon SAC with respect to the conservation objectives of the sites and to their structure and function.

The focus is on demonstrating, with supporting evidence, that there will be no adverse effects on the integrity

of the River Shannon and River Fergus Estuaries SPA and Lower River Shannon SAC. Where this is not the

case, adverse effects must be assumed.

5.2.1 Description of European (Natura 2000) Sites

The proposed development site is within 30 metres of the Lower River Shannon SAC5 and within 2km of the

River Shannon and River Fergus Estuaries SPA. Qualifying features of these sites are listed in Table 5-1.

Table 5-1: Qualifying features of the Lower River Shannon SAC and River Shannon and River Fergus

Estuaries SPA

Lower River Shannon SAC

Freshwater Pearl Mussel Margaritifera margaritifera.

Sea Lamprey Petromyzon marinus.

Brook Lamprey Lampetra planeri.

River Lamprey Lampetra fluviatilis.

Atlantic Salmon Salmo salar (only in fresh water).

Sandbanks which are slightly covered by sea water all the time.

Estuaries.

Mudflats and sandflats not covered by seawater at low tide.

Coastal lagoons.

Large shallow inlets and bays.

Reefs.

Perennial vegetation of stony banks.

Vegetated sea cliffs of the Atlantic and Baltic coasts.

Salicornia and other annuals colonizing mud and sand.

Atlantic salt meadows (Glauco-Puccinellietalia maritimae).

Bottlenose Dolphin Tursiops truncates.

Otter Lutra lutra.

Mediterranean salt meadows (Juncetalia maritimi).

______________________

5 https://www.npws.ie/sites/default/files/protected-sites/natura2000/NF002165.pdf




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Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-

Batrachion vegetation.

Molinia meadows on calcareous, peaty or clayey-silt-laden soils (Molinion caeruleae).

Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-Padion, Alnion incanae, Salicion

albae).

River Shannon and River Fergus Estuaries SPA

Cormorant Phalacrocorax carbo - breeding + wintering.

Whooper Swan Cygnus cygnus - wintering.

Light-bellied Brent Goose Branta bernicla hrota - wintering.

Shelduck Tadorna tadorna - wintering.

Wigeon Anas penelope - wintering.

Teal Anas crecca - wintering.

Pintail Anas acuta - wintering.

Shoveler Anas clypeata - wintering.

Scaup Aythya marila - wintering.

Ringed Plover Charadrius hiaticula - wintering.

Golden Plover Pluvialis apricaria - wintering.

Grey Plover Pluvialis squatarola - wintering.

Lapwing Vanellus vanellus - wintering.

Knot Calidris canutus - wintering.

Dunlin Calidris alpina - wintering.

Black-tailed Godwit Limosa limosa - wintering.

Bar-tailed Godwit Limosa lapponica - wintering.

Curlew Numenius arquata - wintering.

Redshank Tringa totanus - wintering.

Greenshank Tringa nebularia - wintering.

Black-headed Gull Chroicocephalus ridibundus - wintering.

Wetlands.




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The following Natura 2000 site descriptions are summarised from information within the sites Natura 2000

Standard Data Forms and Site synopses available on the NPWS website6.

The Lower River Shannon SAC5

“The Lower River Shannon SAC is large, long site approximately 14 km wide and 120 km long,

encompassing: the drained river valley which forms the River Shannon estuary; the broader River

Fergus estuary, plus a number of smaller estuaries e.g. Poulnasherry Bay; the freshwater lower

reaches of the Shannon River, between Killaloe and Limerick, plus the freshwater stretches of much

of the Feale and Mulkear catchments; a marine area at the mouth of the Shannon estuary with high

rocky cliffs to the north and south; ericaceous heath on Kerry Head and Loop Head; and several

lagoons. The underlying geology ranges from Carboniferous limestone (east of Foynes) to Namurian

shales and flagstones (west of Foynes) to Old Red Sandstone (at Kerry Head). The salinity of the

system varies daily with the ebb and flood of the tide and with annual rainfall fluctuations seasonally.

The site contains many Annexed habitats, including the most extensive area of estuarine habitat in

Ireland. A good range of Annexed species are also present, including the only known resident

population of Tursiops truncatus in Ireland, all three Irish species of lamprey, and a good population

of Salmo salar. A number of birds listed on the EU Birds Directive either winter or breed in the site.

The site is internationally important for waterfowl with more than 50,000 individuals occurring in

winter. Several species listed in the Irish Red Data Book are present, perhaps most notably the only

known Irish populations of Scirpus triqueter.”

The River Shannon and River Fergus Estuaries SPA7

“The River Shannon and River Fergus Estuaries form the largest estuarine complex in Ireland. The site

comprises all of the estuarine habitat west from Limerick City and south from Ennis, extending west

as far as Killadysert and Foynes on the north and south shores of the Shannon respectively (a distance

of some 25 km from east to west). Also included are several areas in the outer Shannon estuary,

notably Clonderalaw Bay and Poulnasherry Bay. The site has vast expanses of intertidal flats. The

main macro-invertebrate community is a Macoma-Scrobicularia-Nereis community which provides a

rich food resource for the wintering birds. Eelgrass (Zostera spp.) is present in places. The intertidal

flats are often fringed with salt marsh vegetation, areas which provide important high tide roost sites

for the birds. In the innermost parts of the estuaries, the tidal channels or creeks are fringed with

species such as Phragmites australis and Scirpus spp. Spartina anglica is frequent in parts.

This is the most important coastal wetland site in the country and regularly supports in excess of

50,000 wintering waterfowl. It has internationally important populations of Calidris alpina, Limosa

limosa and Tringa totanus. A further 16 species have populations of national importance. The site is

particularly significant for Calidris alpina (11% of national total), Pluvialis squatarola (7.5% of total),

Vanellus vanellus (6.5% of total), Tringa totanus (6.1% of total) and Tadorna tadorna (6.0% of total).

It has Cygnus cygnus, Pluvialis apricaria and Limosa lapponica in significant numbers. The site

provides both feeding and roosting areas for the wintering birds and habitat quality for most of the

estuarine habitats is good.”

5.2.2 Describe the elements of the project or plan (alone or in combination with other projects

or plans) that are likely to give rise to significant effects on the environment.

The elements of the project identified as having potential to affect Natura sites via the potential release of

contaminants into the groundwater environment and disturbance to qualifying species are as follows:

• Excavation – implications on groundwater quality.

______________________

6 https://www.npws.ie/protected-sites 7 https://www.npws.ie/sites/default/files/protected-sites/natura2000/NF004077.pdf




SLR Ref No: 501.00672.00001

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• Treatment of contaminated material from the site – implications on groundwater quality.

• Construction activity, human habitation and site lighting within the site – implications for disturbance

of otters.

• Following completion of the development an increase in recreational use of the tow path along the

Park Canal due to site residents and their pets (in particular dogs) – implications for disturbance of

otters.

• Risks of contaminated surface waters entering the Park Canal and therefore the aquatic systems of

either River Shannon and River Fergus Estuaries SPA and Lower River Shannon SAC.

Site investigation completed in 2018 revealed that the site was infilled with imported materials comprising

mainly demolition waste (Verde, 2019). Hydrocarbon, PAHs, lead and beryllium contamination was detected

within the soils. Groundwater beneath the site is considered of good quality although concentrations of

Barium contamination (between 104µg/l in and 1,215µg/l) do exceed Environmental Protection Agency

Interim Guidance Values, the Barium is considered to be naturally occurring and therefore not a potential

source of pollution from the development site.

There is considered to be a Very Low risk from leaching of contamination from the contaminated soils to the

limestone aquifer and groundwater quality data indicates no current impact (Verde, 2019). The groundwater

flow follows the regional and local topography an in a north-westerly direction (See Figure 3 of the due

diligence report (Verde, 2019).

5.2.3 Set out the conservation objectives of the site

The conservation objectives for the River Shannon and River Fergus Estuaries SPA and Lower River Shannon

SAC, and the list of specific attributes and targets defining the conservation objectives for each feature of

interest (Section 5.2.1, Table 5-1), are listed within the supporting information accessed through NPWS

website. These were reviewed and considered for the features of interest likely to be affected.


The conservation objectives of this site are set out in full here:

https://www.npws.ie/sites/default/files/protected-sites/conservation_objectives/CO002165.pdf

In summary the conservation objective for the SAC is to maintain or restore the favourable conservation

condition of the habitat(s) and species for which the SAC has been selected.


The conservation objectives of this site are set out in full here:

https://www.npws.ie/sites/default/files/protected-sites/conservation_objectives/CO004077.pdf

In summary, the conservation objective is to maintain or restore the favourable conservation condition of

the bird species and wetlands listed as Special Conservation Interests for this SPA.

5.2.4 Describe how the project or plan will affect key species and key habitats. Acknowledge

uncertainties and gaps in information


The project involves the limited excavation of potentially contaminated soil during the construction of the

proposed development at Canal Bank, Limerick. These works would take place at a distance of c. 2km from

the River Shannon and River Fergus Estuaries SPA. The potential route to effects on this Natura 2000 site is

transmission of contaminants via groundwater and surface water.

The project site and SPA boundaries do not overlap so there is no risk that the project could cause direct

impacts, such as habitat loss or fragmentation, resulting in effects on the habitats listed as feature of interest

for the River Shannon and River Fergus Estuaries SPA.




SLR Ref No: 501.00672.00001

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It is considered that there is a very low risk of contamination of ground water on site due to the nature of

the contamination, the presence of silty clays restricting any migration of contamination from the Made

Ground (as evidenced by the analysis of groundwater presence in the bedrock aquifer which shows no impact

from contaminated soils on site to the bedrock aquifer, Verde, 2019), and the distance (2km) from the River

Shannon and River Fergus Estuaries SPA.

The CEMP defines the approach to environmental management at the site during the construction phase,

including protection of both ground and surface waters from contamination. Compliance with the CEMP, the

procedures, work practices and controls will be mandatory and must be adhered to by all personnel and

contractors employed on the construction phase of the project. Due to the separation distance, and the

implementation of the CEMP, it is considered highly unlikely that there will be any indirect effects on key

species or habitats listed as features of interest of the SPA as a result of the degradation of water quality due

to the risk of potential discharge of contaminated groundwater or contaminated surface water from the

project site during construction.

Surface water run-off from the completed development will be collected in a piped system with silt traps and

a hydrocarbon interceptor before discharged to the Park Canal. Discharge volume will be restricted and the

development incorporates attenuation storage basins (PHM Consulting Drawing No. 201 – Drainage General

Arrangement). All wastewater will be directed to the existing sewerage network and conveyed to WWTP

prior to discharge.

It is considered that these design measures and standard construction management and protection measures

included, any adverse impacts upon the interest features of River Shannon and River Fergus Estuaries SPA

would be avoided.


The project involves the excavation of contaminated soil during the construction of the proposed

development at Canal Bank, Limerick. These works would take place at a distance of 30m from the Lower

River Shannon SAC. The potential route to effects on this Natura 2000 sites is transmission of contaminants

via groundwater, surface waters and disturbance of a qualifying species (otter).

The terrestrial key habitats and species of the Lower River Shannon SAC, such as perennial vegetation of

stony banks and Molinia meadows on calcareous, peaty or clayey-silt-laden soils, will not be affected by the

proposed project as they lack any hydrogeological (groundwater or surface water) or ecological connectivity8

with the project.

The Site and SAC boundaries do not overlap so there is no risk that the project could cause direct impacts,

such as habitat loss or fragmentation, resulting in effects on the habitats listed as feature of interest for the

Lower River Shannon SAC.

It is considered that there is a very low risk of contamination of ground water on site. The CEMP defines the

approach to environmental management at the site during the construction phase. Compliance with the

CEMP, the procedures, work practices and controls will be mandatory and must be adhered to by all

personnel and contractors employed on the construction phase of the project. Through the implementation

of the CEMP, it is considered highly unlikely that there will be any indirect effects on key species or habitats

listed as features of interest of the SAC as a result of the degradation of water quality due to the risk of

potential discharge of contaminated groundwater or surface water from the Site to Lower River Shannon

SAC.

The Lower River Shannon SAC is close enough to the development for disturbance of otters (a species listed

as feature of interest of the SAC) to either enter the project site and be impacted there or to be disturbed by

______________________

8 Ecological Connectivity is defined by Chartered Institute of Ecology and Environmental Management (CIEEM) as “A

measure of the functional availability of the habitats needed for a particular species to move through a given area.

Examples include the flight lines used by bats to travel between roosts and foraging areas or the corridors of appropriate

habitat needed by some slow colonising species if they are to spread.” (CIEEM, 2018).




SLR Ref No: 501.00672.00001

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Page 15

activities within the project site whilst active within the SAC, e.g. otters resting, foraging or commuting along

the Park Canal or the adjacent marshland. There is a risk of disturbance during construction, resulting from

construction activities and people working on site. There is also a risk of disturbance to otters from residents’

recreational activities, including dog walking, following completion of the development.

Otter is a crepuscular mammal, and principally active at night and dawn or dusk. Therefore, the risk of

individuals of this species being directly disturbed during daytime construction activities are low. Working

hours presented in the CEMP are envisaged to be 0700 – 1900 (Mon – Fri) and 0700 – 1400 (Sat) (PHM

Consulting, 2019).

The risk of adverse effects upon resting otters within the SAC site boundary, e.g. whilst using resting couches

or holts in marshland areas, during construction would be avoided (or mitigated, where required) through

pre-construction surveys and implementation of an otter protection plan, as set out in Section 5.2.6 below.

The area of the marsh is approximately 3.8ha with a maximum of 2.6ha of reeds and tall vegetation where

otter could rest up. The SAC site details do not estimate the total extent of potential couching habitat in the

SAC, although they do indicate that the total area of terrestrial habitat within 10m of freshwater is 958ha.

The marsh therefore contributes c. 0.3% of the terrestrial habitat within the SAC adjacent to freshwater.

However, riversides often lack the appropriate cover for otters to lie up during the day (Mammal Society, a)

so the area available for otters to rest up undisturbed within the SAC is likely smaller than 958ha. However,

using a precautionary approach, it is still considered that disturbance of the marshland area would, as a

worst-case, only result in disturbance of <1% of the total suitable potential couching/resting habitat within

the SAC, and only for a temporary period during construction.

Following construction, disturbance impacts are principally predicted to be associated with recreational

activities of the occupants of the residences and their pets, e.g. dogs. Otters are likely to be mainly active

along the Park Canal and within the marshland at dusk/ dawn when human activity within the project site

and towpath are likely to be comparatively low. The towpaths are already well-used recreational resources,

although there is predicted to be an increase in use resulting from the project.

The marshland provides potential day-time resting habitat that could be used both by adult otters and their

young. Marshes can be a very important habitat, for raising young and as a source of frogs (Mammal Society,

a). Direct disturbance by people is considered unlikely as this marsh area is separated from established

recreational areas, e.g. towpaths and football training areas, and appears wet and therefore unlikely to be

an important informal recreational resource. It is predicted that the most likely threat to otter is the presence

of dogs, especially at breeding sites where natal dens are in above-ground cover such as scrub and reed beds

(Liles, 2003). Breeding sites vary in size, from 2 ha to 50 ha, and where otters are giving birth above ground

in wetland areas even low levels of disturbance may prevent breeding at the site (Liles, 2003). It is not clear

to what extent otter use the marsh area near the proposed development or if disturbance levels are already

too high for them to couch/ raise young there. Domestic dogs are known to both chase and on occasion kill

otters/ their cubs, and there is no apparent barrier to prevent dogs from entering the marsh. Therefore, dogs

from the development could case direct harm to otter, disturbance of otter and exclusion of otter via

disturbance from the marsh.

The development comprises principally apartment buildings, which are predicted to support fewer dog

owners than typical residential housing development, such as the existing housing that is located in the

vicinity of the marsh. The development project also provides green space within the project area, including

areas for formal and informal recreation. A single exit point from the development is proposed onto the

towpath on the southside of Park Canal. This exit would not provide direct access to the path adjacent to the

marshland, which can only be accessed via the footbridge at Park Road or Lock Quay Bridge. It is therefore

predicted that most recreational activities would take place on the path south of the marshland and therefore

not directly connect with this marshland.

The area of the marsh that may be subject to recreational disturbance is approximately 3.8ha of which

roughly 1.2ha is open water leaving 2.6ha of reeds and tall vegetation where otter could rest up. As states

above, this is considered to be <1% of the suitable resting up area for otter within the SAC.




SLR Ref No: 501.00672.00001

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5.2.5 Describe how the integrity of the site (determined by structure and function and

conservation objectives) is likely to be affected by the project or plan (e.g. loss of habitat,

disturbance, disruption, chemical changes, hydrological changes and geological changes,

etc.). Acknowledge also uncertainties and any gaps in information.

The terrestrial habitats and species for which the River Shannon and River Fergus Estuaries SPA are

designated are not predicted to be affected by the proposed project as there is no ecological or

hydrogeological connectivity between this SPA and the project site. Control, avoidance and mitigation

measures, e.g. the provisions included within the CEMP, will ensure that the risks of contamination and other

adverse effects are negligible. The effective implementation of these measures is considered to be

sufficiently certain that no impacts upon the integrity of this site are predicted.

The terrestrial habitats and species for which the Lower River Shannon SAC are designated are not predicted

to be significantly adversely affected by the proposed project during construction. Control, avoidance and

mitigation measures, e.g. the provisions included within the CEMP and outlined in Section 5.2.6 below, will

ensure that the risks of contamination, disturbance or other adverse effects during construction are

negligible. The effective implementation of these measures are considered to be sufficiently certain that no

impacts upon the integrity of this site during construction are predicted.

There is currently only limited information on the use of the marshland area and other habitats adjacent to

the project site by the local otter population. A precautionary assessment is therefore required. It is

predicted that any disturbance impact to otters by the residential population associated with this new

development alone is not significant, as the site is predicted to have a lower than average number of dogs

per household than developments of a similar scale, the development includes new green space for

recreation and amenity uses, and only links to the Park Canal directly on its south bank, which is some

distance by foot to the SAC-designated marshland areas likely to be most suitable for resting otters. However,

in the light of the predicted cumulative increase of the population of Limerick (increasing by c. 3% between

2011 and 2016 9) a contribution to cumulative disturbance impacts to the local population of otter cannot be

completely dismissed.

The significance of this potential for cumulative disturbance to otter cannot be fully assessed in the absence

of recent otter survey data. For example, surveys that allow determination of the importance of the marsh

land for this species. It is therefore proposed to increase certainty in the assessment of no effect on the

integrity of the SAC by conducting pre-construction and post-construction surveys for otter in the project site

and adjacent marshland area.

5.2.6 Describe what mitigation measures are to be introduced to avoid, reduce or remedy the

adverse effects on the integrity of the site. Acknowledge uncertainties and any gaps in

information.

Otter

The implementation of mitigation measures during construction will be the responsibility of the Project

Ecologist and controlled by the CEMP. The Project Ecologist will report to the Environmental Officer and will

be available to respond to any issues arising that relate to biodiversity protection or impact.

The Project Ecologist would undertake pre-construction surveys for the presence of otters, in particular

focussed on the location and usage of any holts or resting places that may be in the vicinity of the

development. If holts are present, then standard good practice measures to avoid disturbance to otters

would be enacted by the Project Ecologist and related to the Construction Management Team. If required,

an otter protection plan would be drawn up, and would include the following:

• details of how the construction operations are likely to affect otters;

______________________

9 https://www.citypopulation.de/en/ireland/towns/LK__limerick/




SLR Ref No: 501.00672.00001

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• detail of any specific mitigation and avoidance measures to be employed to avoid any offence and

minimise impacts on individual otters;

• summary of any residual impacts once mitigation measures have been taken into account.

Typical mitigation measures would include the following (the final detail of any otter protection plan would

be based upon the predicted risk of impact):

• avoiding otter habitat where possible and avoiding creating any obstructions to established otter

paths/access to open water;

• avoiding working in the vicinity of otter habitat during the hours of darkness and within 2 hours after

sunrise and 2 hours before sunset. This can be reduced to one hour between November to February

(inclusive) because of the limited daylight;

• marking exclusion zones around any holts and shelters. If otters are known or suspected to be

breeding, the exclusion zone should normally be 150m radius. However, it could be reduced to 30m

depending on the nature of the holt (i.e. non-breeding holts), the type and duration of works

proposed. Exclusion zones will require judgement from the Project Ecologist on a case-by-case basis.;

• screen fencing to reduce noise and visual disturbance;

• capping any exposed pipe systems when contractors are off site, and providing exit ramps from any

exposed trenches or holes (to prevent otters entering and becoming trapped).

Further information relating to the protection of otters during construction can be derived from guidance,

for example (NRA, 2008).

On completion of the development signage will be put in place at the egress point of the proposed

development to the towpath requesting that dogs are kept on leads at all times.

Other

While no other adverse effects on the integrity of the SPA/SAC are anticipated as a result of the proposed

project the mitigation measures outlined in Section 4.0 and Section 5.2.6 above are included. These measures

provide increased certainty that the SAC and SPA will not be affected by the proposal to construct residential

properties and associated amenities at Canal Bank, Limerick.

Further details of the mitigation proposed for the construction phase can be found in the Construction and

Environmental Waste Management Plan (PHM Consulting, 2019).




SLR Ref No: 501.00672.00001

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Consideration of Findings

Following implementation of appropriate mitigation for otter (Section 4 and 5.2.6) the project is not

predicted to give rise to adverse effects on the integrity of the River Shannon and River Fergus

Estuaries SPA and Lower River Shannon SAC either alone or in-combination with other projects or

plans. The mitigation measures set out increase certainty that the SAC and SPA will not be affected by

the proposed development at Canal Bank, Limerick.

It is considered that there will be no adverse effects on the integrity of River Shannon and River Fergus

Estuaries SPA and Lower River Shannon SAC as a result of the proposed development at Canal Bank,

Limerick.

Based on the information set out in this report and associated documents, we submit that the

competent authority has sufficient information to allow them to determine that the proposed project,

individually or in combination with other plans or projects, will not have an adverse effect on the

integrity of any European (Natura 2000) sites.




SLR Ref No: 501.00672.00001

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Page 19

References

CIEEM (2018) Guidelines for Ecological Impact Assessment in the UK and Ireland: Terrestrial,

Freshwater, Coastal and Marine. Chartered Institute of Ecology and Environmental Management,

Winchester. Version 1.1 - Updated September 2019

European Commission (2001). 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.

European Commission (2018). Managing Natura 2000 Sites: The Provisions of Article 6 of the ‘Habitats

Directive’ 92/43/EEC.

European Union Habitats Directive, (1992). Council Directives 92/43/EEC of 21 May 1992 on the

conservation of natural habitats and of wild fauna and flora.

Scott Wilson and Levett-Therivel, (2006). Appropriate Assessment of Plans. Scott Wilson, Levett-

Therivel Sustainability Consultants, Treweek Environmental Consultants and Land Use Consultants.

Tyldesley. D., and Chapman, C., (2013) The Habitat Regulations Assessment Handbook, February 2019

Edition UK: DTA Publications Ltd.

Liles, G. (2003). Otter breeding sites: Conservation and management. Conserving Natura 2000 Rivers

Conservation Techniques Series No. 5. Retrieved 12 17, 2019, from

https://www.nature.scot/sites/default/files/2019-10/Otter%20Breeding%20Sites%20-

%20Conserving%20Natura%202000%20Rivers%20Series.pdf

Mammal Society. (a). Species Factsheet: Otter (Lutra lutra). Retrieved 12 17, 2019, from

http://mammal.org.uk/sites/default/files/factsheets/otter_complete.pdf

PHM Consulting. (2019). Mixed Use Development, Pa Healy Road, Limerick: Construction

Environmental and Waste Management Plan.

Scott Wilson and Levett-Therivel. (2006). Appropriate Assessment of Plans. Scott Wilson, Levett-

Therivel Sustainability Consultants, Treweek Environmental Consultants and Land Use Consultants.

Verde. (2019). Phase 2 Environmental Due Diligence Report: Canal Bank Project, Pa Healy Road,

Limerick City. Ref: 52187.

https://www.tii.ie/tii-library/environment/construction-guidelines/Guidelines-for-the-Treatment-of-

Otters-prior-to-the-Construction-of-National-Road-Schemes.pdf

Websites

https://www.npws.ie/protected-sites (last accessed 12/12/2019)

http://gis.epa.ie/ (last accessed 12/12/2019)

Page 28 https://www.npws.ie/sites/default/files/publications/pdf/NPWS_2009_AA_Guidance.pdf

http://ec.europa.eu/environment/nature/natura2000/management/docs/art6/natura_2000_assess

_en.pdf (last accessed 12/12/2019)

https://www.npws.ie/sites/default/files/protected-sites/natura2000/NF002165.pdf (last accessed

12/12/2019)




SLR Ref No: 501.00672.00001

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https://www.npws.ie/sites/default/files/protected-sites/natura2000/NF004077.pdf (last accessed

12/12/2019)

https://www.nature.scot/sites/default/files/2018-09/Species%20Planning%20Advice%20-

%20otter.pdf

FIGURES

Figure 1: Natura Impact Statement: Natura 2000 Sites

Lower RiverShannon SAC




River Shannonand River Fergus

Estuaries SPA

MarshLand

Park Canal

Abbey River

556000 557000 558000 559000 560000 56100065

6000

6570

0065

8000

6590

00

APPLICATION BOUNDARYAPPLICATION BOUNDARY 2kmBUFFERSPECIAL AREA OF CONSERVATION

SPECIAL PROTECTION AREA¯

LEGEND

DRAWING 1DECEMBER 2019

DateScale @ A31:17,500

NATURA 2000 SITES

4/5 LOCHSIDE VIEWEDINBURGH PARK

EDINBURGHEH12 9DH

T: +44 (0)131 335 6830www.slrconsulting.com

CANAL BANK DEVELOPMENTLIMERICK CITY

NATURA IMPACT STATEMENT

Service Layer Credits: (c) OpenStreetMap and contributors, Creative Commons-Share Alike License (CC-BY-SA) © This drawing and its content are the copyright of SLR Consulting Ltd and may not be reproduced or amended except by prior written permission. SLR Consulting Ltd accepts no liability for any amendments made by other persons.

0 0.5 1 1.5 2

Kilometers

501.0

0672

.0000

2.27.1

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