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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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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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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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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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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.
Habitat distribution Occurrence No decline, or change in habitat distribution, subject to natural processes.
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Conservation Objectives:
To restore favourable conditions
(NPWS, 2013a)
Physical structure: sediment
supply
Presence/ absence of
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.
Vegetation composition: typical species and subcommunities
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.
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 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
Vegetation structure: vegetation cover
Percentage cover at a representative number
of monitoring stops
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.
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]
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 - 7.98ha.
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.
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 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% area outside creeks vegetated.
Vegetation composition: typical
species and subcommunities
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%
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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Conservation Objectives: To restore favourable conditions
(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 structure: zonation Occurrence Maintain the range of coastal habitats including transitional zones, subject to natural processes including erosion and succession.
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).
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: 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.
Shifting dunes along
the shoreline with
Ammophila arenaria
(white dunes) [2120]
Conservation Objectives:
To restore favourable conditions
(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.
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: 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).
Vegetation composition: typical species and subcommunities
Percentage cover at a representative number
of monitoring stops
Maintain the presence of species-poor communities dominated by marram grass (Ammophila arenaria)
and/or lymegrass (Leymus arenarius).
Vegetation composition: negative indicator species
Percentage cover Negative indicator species (including non-natives) to represent less than 5% cover.
Fixed coastal dunes Habitat area Hectares Area stable or increasing, subject to natural processes
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with herbaceous
vegetation (grey
dunes) [2130]
Conservation Objectives: To restore favourable conditions
(NPWS, 2013a)
including erosion and succession. For subsites mapped:
North Bull - 40.29ha; South Bull - 64.56ha.
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 structure: bare ground
Percentage cover Bare ground should not exceed 10% of fixed dune habitat, subject to natural processes.
Vegetation structure: sward height
Centimetres Maintain structural variation within sward.
Vegetation composition: typical species and subcommunities
Percentage cover at a representative number of monitoring stops
Maintain range of subcommunities with typical species listed in Delaney et al. (2013).
Vegetation composition: negative indicator species (including Hippophae rhamnoides)
Percentage cover Negative indicator species (including non-natives) to represent less than 5% cover.
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]
Conservation Objectives: To maintain favourable
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.
Community structure: Mytilus edulis density
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.
Conservation Objectives: To restore favourable conditions
(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 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]
Taken from North Dublin Bay SAC Conservation Objectives as not detailed
in South Dublin Bay SAC Conservation Objectives.
Conservation Objectives:
To restore 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 - 29.10ha.
Habitat distribution Occurrence No decline, or change in habitat distribution, subject to natural processes.
Physical structure: sediment supply
Presence/ absence of 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.
Vegetation composition: typical species and subcommunities
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.
Conservation Objectives: To restore favourable conditions
(NPWS, 2013a)
Habitat area Hectares Area stable or increasing, subject to natural processes, including erosion and succession.
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: 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).
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: 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]
Conservation Objectives: To maintain favourable conditions
(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]
Conservation Objectives:
Population trend Percentage change Long term population trend stable or increasing.
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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]
Conservation Objectives: To maintain favourable conditions
(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 Teal, other than that occurring from natural patterns of variation.
Pintail (Anas acuta)
[A054]
Conservation Objectives: To maintain favourable conditions
(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 Pintail, other than that occurring from natural patterns of variation.
Shoveler (Anas
clypeata) [A056]
Conservation Objectives: To maintain favourable conditions
(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 Shoveler, other than that occurring from natural patterns of variation.
Oystercatcher
(Haematopus
ostralegus) [A130]
Conservation Objectives:
To maintain favourable conditions
(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 Oystercatcher, other than that
occurring from natural patterns of variation.
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Golden Plover (Pluvialis
apricaria) [A140]
Conservation Objectives:
To maintain favourable conditions
(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 Golden Plover, other than that occurring from natural patterns of variation.
Grey Plover (Pluvialis
squatarola) [A141]
Conservation Objectives: To maintain favourable conditions
(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 Grey Plover, other than that occurring from natural patterns of variation.
Knot (Calidris canutus)
[A143]
Conservation Objectives:
To maintain favourable conditions
(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 Knot, other than that occurring from natural patterns of variation.
Sanderling (Calidris
alba) [A144]
Conservation Objectives: To maintain favourable conditions
(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 Sanderling, other than that occurring from natural patterns of variation.
Dunlin (Calidris alpina)
[A149]
Conservation Objectives:
Population trend Percentage change Long term population trend stable or increasing.
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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 Dunlin, other than that occurring from
natural patterns of variation.
Black-tailed Godwit
(Limosa limosa)
[A156]
Conservation Objectives: To maintain favourable conditions
(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 Black-tailed Godwit, other than that occurring from natural patterns of variation.
Bar-tailed Godwit
(Limosa lapponica)
[A157]
Conservation Objectives: To maintain favourable conditions
(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 Bar-tailed Godwit, other than that occurring from natural patterns of variation.
Curlew (Numenius
arquata) [A160]
Conservation Objectives: To maintain favourable conditions
(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 Curlew, other than that occurring
from natural patterns of variation.
Redshank (Tringa
totanus) [A162]
Conservation Objectives: To maintain favourable
conditions
(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 Redshank, other than that occurring from natural patterns of variation.
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Turnstone (Arenaria
interpres) [A169]
Conservation Objectives:
To maintain favourable conditions
(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 Turnstone, other than that occurring from natural patterns of variation.
Black-headed Gull
(Chroicocephalus
ridibundus) [A179]
Conservation Objectives: To maintain favourable conditions
(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 Curlew, other than that occurring from natural patterns of variation.
Wetland and
Waterbirds [A999]
Conservation Objectives: To maintain favourable conditions
(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]
Conservation Objectives: To maintain favourable conditions
(NPWS, 2015b)
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.
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Oystercatcher
(Haematopus
ostralegus) [A130]
Conservation Objectives: To maintain favourable conditions
(NPWS, 2015b)
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 Oystercatcher, other than that occurring from natural patterns of variation.
Ringed Plover
(Charadrius hiaticula)
[A137]
Conservation Objectives: To maintain favourable conditions
(NPWS, 2015b)
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 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]
Conservation Objectives: To maintain favourable conditions
(NPWS, 2015b)
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 Knot, other than that occurring from natural patterns of variation.
Sanderling (Calidris
alba) [A144]
Conservation Objectives: To maintain favourable conditions
(NPWS, 2015b)
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 Sanderling, other than that occurring from natural patterns of variation.
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Dunlin (Calidris alpina)
[A149]
Conservation Objectives:
To maintain favourable conditions
(NPWS, 2015b)
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 Dunlin, other than that occurring from natural patterns of variation.
Bar-tailed Godwit
(Limosa lapponica)
[A157]
Conservation Objectives: To maintain favourable conditions
(NPWS, 2015b)
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 Bar-tailed Godwit, other than that occurring from natural patterns of variation.
Redshank (Tringa
totanus) [A162]
Conservation Objectives: To maintain favourable
conditions
(NPWS, 2015b)
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 Redshank, other than that occurring from natural patterns of variation.
Black-headed Gull
(Chroicocephalus
ridibundus) [A179]
Conservation Objectives: To maintain favourable conditions
(NPWS, 2015b)
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 Black-headed Gull, other than that occurring from natural patterns of variation.
Roseate Tern (Sterna
dougallii) [A192]
Conservation Objectives:
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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To maintain favourable
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]
Conservation Objectives: To maintain favourable conditions
(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.
Passage population: individuals Number No significant decline.
Distribution: breeding colonies Number; location; shape; area (hectares)
No significant decline.
Distribution: roosting areas Number; location; shape; area (hectares)
No significant decline.
Prey biomass available Kilogrammes No significant decline.
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]
Conservation Objectives: To maintain favourable conditions
(NPWS, 2015b)
Passage population: individuals Number No significant decline.
Distribution: roosting areas Number; location; area (hectares)
No significant decline.
Prey biomass available Kilogrammes No significant decline.
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 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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Conservation Objectives: To maintain favourable conditions
(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]
Industrial or commercial areas H o
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]
Industrial or commercial areas H o
Discharges H i
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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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Species Protective Designation
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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Species Protective Designation
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.
Community structure: Mytilus edulis density
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.
Annual vegetation of
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
Presence/ absence of physical barriers
N/A
Vegetation structure: zonation
Occurrence N/A
Vegetation composition: typical species and subcommunities
Percentage cover at a representative number of monitoring stops
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.).
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.
Salicornia and other
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
Attribute Measure Potential Impacts
sediment supply physical barriers
Physical structure: creeks and pans
Occurrence N/A
Physical structure: flooding regime
Hectares flooded; frequency
N/A
Vegetation structure: zonation
Occurrence N/A
Vegetation structure:
vegetation height
Centimetres Potential pollutants may negatively impact and alter the sward heights
of the Salicornia and other colonising annual vegetation.
Vegetation structure: 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).
Vegetation composition: typical species and subcommunities
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.
Physical structure: sediment supply
Presence/ absence of physical barriers
N/A
Physical structure:
creeks and pans
Occurrence N/A
Physical structure: flooding regime
Hectares flooded; frequency
N/A
Vegetation structure: zonation
Occurrence N/A
Vegetation structure: Centimetres Potential pollutants may negatively impact and alter the sward heights
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Qualifying
Interest
Attribute Measure Potential Impacts
vegetation height of the Atlantic salt meadow vegetation.
Vegetation structure: 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).
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.
Physical structure: sediment supply
Presence/ absence of physical barriers
N/A
Physical structure: creeks and pans
Occurrence N/A
Physical structure: flooding regime
Hectares flooded; frequency
N/A
Vegetation structure: zonation
Occurrence N/A
Vegetation structure: vegetation height
Centimetres Potential pollutants may negatively impact and alter the sward heights of the Mediterranean salt meadow vegetation.
Vegetation structure:
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).
Vegetation composition: typical species and subcommunities
Percentage cover Potential pollutants may negatively impact on the typical species and subcommunities of Mediterranean salt meadows.
Vegetation structure: negative indicator
Hectares Potential pollutants may negatively impact on the positive indicator species, reducing their density and subsequently allowing the
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Qualifying
Interest
Attribute Measure Potential Impacts
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
Vegetation structure: zonation
Occurrence N/A
Vegetation composition: plant health of foredune grasses
Percentage cover Potential pollutants may negatively impact on the health of foredune grass vegetation.
Vegetation composition: 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.
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.
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
Presence/ absence of
physical barriers
N/A
Vegetation structure: zonation
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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Qualifying
Interest
Attribute Measure Potential Impacts
Vegetation composition: 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 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.
Physical structure: functionality and sediment supply
Presence/ absence of physical barriers
N/A
Vegetation structure: zonation
Occurrence N/A
Vegetation structure: bare ground
Percentage cover Potential pollutants may negatively impact on the herbaceous vegetation reducing total cover, and thus increasing total bare ground
cover.
Vegetation structure: sward height
Centimetres Potential pollutants may negatively impact and alter the sward heights of the Fixed coastal dunes with herbaceous vegetation.
Vegetation composition: 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 Fixed coastal dunes with herbaceous vegetation.
Vegetation composition: negative indicator species (including Hippophae rhamnoides)
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.
Vegetation composition: scrub/trees
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
the ZoI of the proposed project.
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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 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.
Annual vegetation of
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
Presence/ absence of physical barriers
N/A
Vegetation structure: zonation
Occurrence N/A
Vegetation composition: typical species and subcommunities
Percentage cover at a representative number of monitoring stops
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.).
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.
Salicornia and other
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: sediment supply
Presence/ absence of physical barriers
N/A
Physical structure: creeks and pans
Occurrence N/A
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Qualifying
Interest
Attribute Measure Potential Impacts
Physical structure: flooding regime
Hectares flooded; frequency
N/A
Vegetation structure: zonation
Occurrence N/A
Vegetation structure: vegetation height
Centimetres Potential pollutants may negatively impact and alter the sward heights of the Salicornia and other colonising annual vegetation.
Vegetation structure: 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).
Vegetation composition: typical species and subcommunities
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.
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
Vegetation structure: zonation
Occurrence N/A
Vegetation composition:
plant health of foredune grasses
Percentage cover Potential pollutants may negatively impact on the health of foredune
grass vegetation.
Vegetation composition: 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.
Vegetation composition: negative indicator
Percentage cover Potential pollutants may negatively impact on the positive indicator species, reducing their density and subsequently allowing the
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Qualifying
Interest
Attribute Measure Potential Impacts
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
the ZoI of the proposed project.
Qualifying
Interest
Attribute Measure Potential Impacts
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]
Grey Plover
(Pluvialis squatarola)
[A141]
Knot (Calidris
canutus) [A143]
Sanderling (Calidris
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
Distribution Range, timing and intensity of use of areas
Potential pollutants may negatively impact on the range, timing and intensity of use of areas within the SPA by the following QI bird species:
- Light-bellied Brent Goose
- Shelduck
- Teal
- Pintail
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Qualifying
Interest
Attribute Measure Potential Impacts
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
- Black-tailed Godwit
- 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
Attribute Measure Potential Impacts
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:
- Light-bellied Brent Goose
- Oystercatcher
- Ringed Plover
- Grey Plover
- Knot
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Qualifying
Interest
Attribute Measure Potential Impacts
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]
- Sanderling
- Dunlin
- Bar-tailed Godwit
- Redshank
- Black-headed Gull
Distribution Range, timing and intensity of use of areas
Potential pollutants may negatively impact on the range, timing and intensity of use of areas within the SPA by the following QI bird species:
- Light-bellied Brent Goose
- 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.
Barriers to connectivity Number; location; shape; area (hectares)
N/A
Disturbance at roosting site
Level of impact N/A
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Qualifying
Interest
Attribute Measure Potential Impacts
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.
Productivity rate: fledged young per breeding pair
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
Distribution: roosting areas
Number; location; shape; 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 Common Tern population.
Barriers to connectivity Number; location;
shape; area (hectares)
N/A
Disturbance at breeding site
Level of impact N/A
Disturbance at roosting site
Level of impact N/A
Arctic Tern (Sterna
paradisaea) [A194]
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 Artic Tern population.
Barriers to connectivity Number; location; shape; area (hectares)
N/A
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Qualifying
Interest
Attribute Measure Potential Impacts
Disturbance at roosting site
Level of impact N/A
Wetland and
Waterbirds [A999]
Habitat area Hectares Potential pollutants may negatively impact on the wetland vegetation, resulting in a decrease of total wetland habitat.
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
the ZoI of the proposed project.
Qualifying
Interest
Attribute Measure Potential Impacts
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]
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:
- Light-bellied Brent Goose
- Shelduck
- Teal
- Pintail
- Shoveler
- Oystercatcher
- Golden Plover
- Grey Plover
- Knot
- Sanderling
- Dunlin
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Qualifying
Interest
Attribute Measure Potential Impacts
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]
- Black-tailed Godwit
- Bar-tailed Godwit
- Curlew
- Redshank
- Turnstone
- Black-headed Gull
Distribution Range, timing and intensity of use of areas
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:
- 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
Wetland and
Waterbirds [A999]
Habitat area Hectares N/A
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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
Attribute Measure Potential Impacts
Light-bellied Brent
Goose (Branta
bernicla hrota)
[A046]
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]
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:
- Light-bellied Brent Goose
- Oystercatcher
- Ringed Plover
- Grey Plover
- Knot
- Sanderling
- Dunlin
- Bar-tailed Godwit
- Redshank
- Black-headed Gull
Distribution Range, timing and intensity of use of areas
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:
- Light-bellied Brent Goose
- Oystercatcher
- Ringed Plover
- Grey Plover
- Knot
- Sanderling
- Dunlin
- Bar-tailed Godwit
- Redshank
- Black-headed Gull
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Qualifying
Interest
Attribute Measure Potential Impacts
Roseate Tern
(Sterna dougallii)
[A192]
Passage population: individuals
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: roosting areas
Number; location; area (hectares)
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.
Barriers to connectivity Number; location; shape; area (hectares)
N/A
Disturbance at roosting site
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.
Productivity rate: fledged young per breeding pair
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.
Passage population: individuals
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
Number; location; shape; area (hectares)
N/A
Distribution: roosting areas
Number; location; shape; area (hectares)
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
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Qualifying
Interest
Attribute Measure Potential Impacts
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.
Barriers to connectivity Number; location; shape; area (hectares)
N/A
Disturbance at breeding site
Level of impact N/A
Disturbance at roosting site
Level of impact N/A
Arctic Tern (Sterna
paradisaea) [A194]
Passage population: individuals
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: roosting areas
Number; location; area (hectares)
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 Artic Tern population.
Barriers to connectivity Number; location; shape; area (hectares)
N/A
Disturbance at roosting site
Level of impact N/A
Wetland and
Waterbirds [A999]
Habitat area Hectares N/A
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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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se.
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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
For
insp
ectio
n pur
pose
s only
.
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Natura
2000 sites
Qualifying
Interest
Attribute Measure Potential Impacts Cumulative Impacts
Mitigation Measures Residual Impact
- 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]
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 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
No adverse effects
Habitat distribution
Occurrence Potential pollutants may negatively impact on the overall distribution of annual drift line
vegetation.
No adverse effects
Vegetation composition: typical species and subcommunities
Percentage cover at a representative number of monitoring stops
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
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-
No adverse effects
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
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uired
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se.
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Natura
2000 sites
Qualifying
Interest
Attribute Measure Potential Impacts Cumulative Impacts
Mitigation Measures Residual Impact
native invasive species. 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.
Salicornia and other 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.
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
No adverse effects
Habitat distribution
Occurrence Potential pollutants may negatively impact on the overall distribution of Salicornia and other colonising annual
vegetation.
No adverse effects
Vegetation structure:
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
Potential pollutants may negatively impact and subsequently reduce the
No adverse effects
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
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uired
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Natura
2000 sites
Qualifying
Interest
Attribute Measure Potential Impacts Cumulative Impacts
Mitigation Measures Residual Impact
cover number of
monitoring stops
total vegetation cover
(outside of creeks).
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.
- 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.
Vegetation composition: typical species and
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.
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.
No adverse effects
Habitat distribution
Occurrence Potential pollutants may negatively impact on the
overall distribution of Atlantic salt meadows.
No adverse
effects
Vegetation structure:
vegetation height
Centimetres Potential pollutants may negatively impact and
alter the sward heights of the Atlantic salt meadow vegetation.
No adverse
effects
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
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r req
uired
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se.
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Natura
2000 sites
Qualifying
Interest
Attribute Measure Potential Impacts Cumulative Impacts
Mitigation Measures Residual Impact
Vegetation structure: 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).
- 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.
- 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.
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
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
Mediterranean salt meadows (Juncetalia maritimi) [1410]
Habitat area Hectares Potential pollutants may negatively impact on the total habitat area of Mediterranean salt meadows.
Impacts on habitats, species and water quality from surface
water run-off from the
Strict adherence to:
- The CEMP and all the best
practice guidance therewith.
- Site compound layout
No adverse effects
Habitat distribution
Occurrence Potential pollutants may negatively impact on the
No adverse
For
insp
ectio
n pur
pose
s only
.
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nt of
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Natura
2000 sites
Qualifying
Interest
Attribute Measure Potential Impacts Cumulative Impacts
Mitigation Measures Residual Impact
overall distribution of
Mediterranean salt meadows.
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.
- 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.
- 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.
effects
Vegetation structure: vegetation height
Centimetres Potential pollutants may negatively impact and alter the sward heights of the Mediterranean salt
meadow vegetation.
No adverse effects
Vegetation structure: 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).
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
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
For in
spec
tion p
urpo
ses o
nly.
Conse
nt of
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uired
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Natura
2000 sites
Qualifying
Interest
Attribute Measure Potential Impacts Cumulative Impacts
Mitigation Measures Residual Impact
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.
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.
- Post Dual Flow Drainage System monitoring to be
No adverse effects
Habitat distribution
Occurrence Potential pollutants may negatively impact on the
overall distribution of Embryonic shifting dune vegetation.
No adverse
effects
Vegetation composition: plant health of foredune grasses
Percentage cover
Potential pollutants may negatively impact on the health of foredune grass vegetation.
No adverse effects
Vegetation composition:
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
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.
No adverse
effects
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
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uired
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ny ot
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se.
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Natura
2000 sites
Qualifying
Interest
Attribute Measure Potential Impacts Cumulative Impacts
Mitigation Measures Residual Impact
conducted for the first 5 first-
flush scenarios, where rainfall exceeds the retention capacity of the tank, in order to establish suitable functionality.
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.
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
No
adverse effects
Habitat distribution
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
Potential pollutants may
negatively impact on the health of dune grass vegetation.
No
adverse effects
Vegetation composition: 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 shifting dunes with Ammophila arenaria.
No adverse effects
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.
No adverse effects
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
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r req
uired
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se.
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Natura
2000 sites
Qualifying
Interest
Attribute Measure Potential Impacts Cumulative Impacts
Mitigation Measures Residual Impact
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.
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.
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.
No adverse effects
Habitat distribution
Occurrence Potential pollutants may negatively impact on the overall distribution of Fixed coastal dunes with herbaceous vegetation.
No adverse effects
Vegetation structure: bare ground
Percentage cover
Potential pollutants may negatively impact on the herbaceous vegetation reducing total cover, and thus increasing total bare ground cover.
No adverse effects
Vegetation structure: sward height
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
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
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uired
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Natura
2000 sites
Qualifying
Interest
Attribute Measure Potential Impacts Cumulative Impacts
Mitigation Measures Residual Impact
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
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.
adverse
effects
Vegetation composition:
negative indicator species (including
Hippophae rhamnoides)
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
Vegetation composition: scrub/trees
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.
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.
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
For
insp
ectio
n pur
pose
s only
.
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nt of
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Natura
2000 sites
Qualifying
Interest
Attribute Measure Potential Impacts Cumulative Impacts
Mitigation Measures Residual Impact
- 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.
- 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]
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
Strict adherence to:
- The CEMP and all the best practice guidance therewith.
- Site compound layout
instructions, ensuring that
No
adverse effects
Habitat distribution
Occurrence Potential pollutants may negatively impact on the
overall distribution of
No adverse
effects
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
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uired
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Natura
2000 sites
Qualifying
Interest
Attribute Measure Potential Impacts Cumulative Impacts
Mitigation Measures Residual Impact
annual drift line
vegetation.
and
surrounding area to local watercourses.
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.
- 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.
Habitat area Hectares Potential pollutants may negatively impact on the
total habitat area of annual drift line vegetation.
No adverse
effects
Habitat distribution
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
For
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ectio
n pur
pose
s only
.
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nt of
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71
Natura
2000 sites
Qualifying
Interest
Attribute Measure Potential Impacts Cumulative Impacts
Mitigation Measures Residual Impact
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
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.
- 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.
- Post Dual Flow Drainage System monitoring to be conducted for the first 5 first-
adverse
effects
Habitat distribution
Occurrence Potential pollutants may negatively impact on the
overall distribution of Salicornia and other colonising annual vegetation.
No adverse
effects
Vegetation structure: 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 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).
No adverse effects
Vegetation composition: typical species and
subcommunit
ies
Percentage cover
Potential pollutants may negatively impact on the typical species and subcommunities.
No adverse effects
Vegetation structure:
negative indicator species - Spartina
Hectares Potential pollutants may negatively impact on the
positive indicator species, reducing their density and subsequently allowing the
No adverse
effects
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
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uired
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72
Natura
2000 sites
Qualifying
Interest
Attribute Measure Potential Impacts Cumulative Impacts
Mitigation Measures Residual Impact
anglica establishment of non-
native invasive species, such as Spartina anglica.
flush scenarios, where rainfall
exceeds the retention capacity of the tank, in order to establish suitable functionality.
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.
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
No adverse
effects
Habitat distribution
Occurrence Potential pollutants may negatively impact on the overall distribution of Embryonic shifting dune
vegetation.
No adverse effects
Vegetation composition:
plant health of foredune grasses
Percentage cover
Potential pollutants may negatively impact on the
health of foredune grass vegetation.
No adverse
effects
Vegetation composition: 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
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.
No
adverse effects
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
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right
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Natura
2000 sites
Qualifying
Interest
Attribute Measure Potential Impacts Cumulative Impacts
Mitigation Measures Residual Impact
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.
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
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
No adverse effects
For
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ectio
n pur
pose
s only
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Natura
2000 sites
Qualifying
Interest
Attribute Measure Potential Impacts Cumulative Impacts
Mitigation Measures Residual Impact
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
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.
- 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.
Distribution Range, timing and intensity of use of areas
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
, which may in turn negatively impact on the
No adverse effects
For
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Natura
2000 sites
Qualifying
Interest
Attribute Measure Potential Impacts Cumulative Impacts
Mitigation Measures Residual Impact
range, timing and
intensity of use of areas within the SPA by 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
Wetland and Waterbirds [A999]
Habitat area Hectares Potential pollutants may negatively impact on the wetland vegetation, resulting in a decrease of total wetland habitat.
No adverse effects
South
Dublin Bay
and River
Light-bellied Brent Goose (Branta bernicla hrota) [A046]
Population trend
Percentage change
Potential pollutants may:
- negatively impact on
the overall health of the population resulting in
Impacts on habitats, species and water quality
Strict adherence to:
- The CEMP and all the best
No adverse effects
For
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ectio
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s only
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Natura
2000 sites
Qualifying
Interest
Attribute Measure Potential Impacts Cumulative Impacts
Mitigation Measures Residual Impact
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:
Light-bellied Brent Goose
Oystercatcher
Ringed Plover
Grey Plover
Knot
Sanderling
Dunlin
Bar-tailed Godwit
Redshank
Black-headed Gull
from surface
water run-off from the industrial park and surrounding area to local
watercourses.
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.
- 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
Potential pollutants may:
- 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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Natura
2000 sites
Qualifying
Interest
Attribute Measure Potential Impacts Cumulative Impacts
Mitigation Measures Residual Impact
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:
Light-bellied Brent Goose
Oystercatcher
Ringed Plover
Grey Plover
Knot
Sanderling
Dunlin
Bar-tailed Godwit
Redshank
Black-headed Gull
of the tank, in order to
establish suitable functionality.
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.
- indirectly impact on QI bird species through
Impacts on habitats, species and
water quality from surface water run-off from the
industrial park and surrounding
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
No adverse effects
For
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ectio
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Natura
2000 sites
Qualifying
Interest
Attribute Measure Potential Impacts Cumulative Impacts
Mitigation Measures Residual Impact
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
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.
- 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.
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:
Number Potential pollutants may:
- negatively impact on the overall health of
Impacts on habitats, species and
Strict adherence to:
No adverse effects
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ectio
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Natura
2000 sites
Qualifying
Interest
Attribute Measure Potential Impacts Cumulative Impacts
Mitigation Measures Residual Impact
apparently
occupied nests (AONs)
individuals within the
breeding population, resulting in potential population / occupied nest 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 breeding population, resulting in potential population / occupied nest decline.
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 therein.
- 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.
- Post Dual Flow Drainage System monitoring to be conducted for the first 5 first-flush scenarios, where rainfall
Productivity rate: fledged young per breeding pair
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
For
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ectio
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s only
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Natura
2000 sites
Qualifying
Interest
Attribute Measure Potential Impacts Cumulative Impacts
Mitigation Measures Residual Impact
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
Number Potential pollutants may:
- negatively impact on
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
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;
- indirectly impact on QI
No adverse effects
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Natura
2000 sites
Qualifying
Interest
Attribute Measure Potential Impacts Cumulative Impacts
Mitigation Measures Residual Impact
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]
Passage population: individuals
Number Potential pollutants may:
- negatively impact on
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.
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.
No adverse effects
Prey biomass available
Kilogrammes Potential pollutants may:
- negatively impact on prey biomass as prey species may reduce in quantity / quality, which
No adverse effects
For
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ectio
n pur
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s only
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Natura
2000 sites
Qualifying
Interest
Attribute Measure Potential Impacts Cumulative Impacts
Mitigation Measures Residual Impact
in turn reduces prey
biomass available for the Artic 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 Artic Tern population.
- 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.
- 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.
Wetland and Waterbirds [A999]
Habitat area Hectares Potential pollutants may negatively impact on the wetland vegetation, resulting in a decrease of total wetland habitat.
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.
No adverse effects
For
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ectio
n pur
pose
s only
.
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Natura
2000 sites
Qualifying
Interest
Attribute Measure Potential Impacts Cumulative Impacts
Mitigation Measures Residual Impact
- 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.
- 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.
6.4.1 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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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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• 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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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.
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
and Wildlife Service, Department of Arts, Heritage and the Gaeltacht. Available online at:
https://www.npws.ie/sites/default/files/protected-sites/conservation_objectives/CO000210.pdf
NPWS, 2015a. Conservation Objectives: North Bull Island SPA 004006. 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/CO004006.pdf
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
Wildlife Service, Department of Arts, Heritage and the Gaeltacht. Available online at:
https://www.npws.ie/sites/default/files/protected-sites/natura2000/NF000210.pdf
NPWS, 2018c. Natura 2000 – Standard Data Form: North Bull Island 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/NF004006.pdf
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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SSCC, 2016. ‘South Dublin County Council Development Plan 2016-2022’. Available online at:
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2022%20(lower%20res).pdf
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