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Statement of Screening for AA for proposed floating pontoon at Inishgowla February 2016

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Non-technical summary This screening statement for appropriate assessment has been undertaken to accompany a foreshore license application for the installation of a floating boat jetty/pontoon on Inishgowla island near Westport, Co. Mayo. Inishgowla is an island located within the inner Clew Bay island complex, approximately 5 linear km west-northwest of Westport harbour. The proposed boat jetty is to be located on the northeast shore of the island, adjacent to a longstanding residential property. The jetty has dimensions of c. 30. metres length and 2.4 metres width and comprises a surface layer of wooden planks overlaying rectangular buoyant pontoons which will be tethered small ship’s chain to 6 mooring blocks, each of which are 1.2 metres wide and 0.6 metres deep(See accompanying planning application drawings for layout of the proposed jetty) . The proposed development location lies within the Clew Bay Complex SAC which is the sole designated site of relevance to this assessment.This screening exercise included a detailed consideration of the potential impacts arising from the proposed development on Clew Bay Complex SAC. Given the small size and scale of the proposed project, it is considered that viable pathways for significant impacts to accrue on constituent habitats and species within the SAC do not exist. The location of the proposed development comprises a mixed sediment shore which is not considered to be of significant conservation value. The proposed installation of the jetty will not precipitate a significant increase in boat traffic to the island; The boat traffic associated with the proposed installation of the jetty is considered to be negligible and in line with the levels currently visiting the island ie. boat traffic associated with the installed jetty does not pose a disturbance related threat to seal populations or other protected wildlife species. Given the small size and scale of the proposed project and absence of habitats of conservation interest within the development footprint, it is considered that viable pathways for significant impacts to accrue on constituent habitats and species within the SAC do not exist. It is the conclusion of this Screening for Appropriate Assessment Statement that the proposed project is compatible with the Conservation Objectives for the qualifying interests of Clew Bay Complex SAC ie. significant effects accruing from the proposed development on these Natura 2000 sites do not have potential to occur. Therefore it is the recommendation of this Screening for Appropriate Assessment Statement that further phases of the Habitats Directive Assessment Process will not be required for the proposed development.


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Table of Contents Part A: Overview of process 1.0 Introduction

1.1 Background

1.2 Natura 2000 Sites

1.3 The purpose of Habitats Directive Assessment (HDA)

1.4 Overview of Habitats Directive Assessment Process

1.5 Guidance Documents

2.0 Statement of Qualification

3.0 Methodology

Part B: Screening Report

4.0 Connectivity of the development to the management of Natura 2000 sites

5.0 Relevant Natura 2000 Sites – qualifying criteria and conservation objectives

6.0 Description of project

7.0 Existing environment in vicinity of application site

8.0 Assessment of Significance of Potential Impacts – Screening Matrix 8.1 Finding of No Significant Effects Matrix

9.0 Screening Conclusions

10.0 References Appendix A: NPWS Site synopsis for Clew Bay Complex SAC Appendix B: Photographs of proposed development location


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1.0 Introduction 1.1 Background This screening statement for appropriate assessment has been undertaken to accompany a foreshore license application for the installation of a floating boat jetty on Inishgowla island near Westport, Co. Mayo. Inishgowla is a small island located approximately 5 km west/northwest of Westport harbour. The proposed boat jetty is to be located on the northeast shore of the island, adjoining a longstanding residential property which overlooks the shoreline. The jetty will facilitate small boats landing at the island. The proposed development location lies within the Clew Bay Complex SAC. A more detailed description of the proposed development is contained in Section 6 of this document. This screening report includes a consideration of the existing local environment in the vicinity of the application site and the potential impacts arising from the proposed development on Clew Bay Complex SAC. 1.2 Natura 2000 Sites Natura 2000 sites are also known as European Sites and include Special Protection Areas (SPAs) designated under the EU Birds Directive and Special Aras of Conservation (SACs) designated under the EU Habitats Directive. Natura 2000 is an EU wide network of nature protection areas, the aim of which is to ensure the long-term survival of Europe’s most valuable and threatened species and habitats. 1.3 The purpose of Habitats Directive Assessment (HDA) Habitats Directive Assessment (HDA) is an evaluation of the potential impacts of a plan or project on the conservation objectives of a Natura 2000 site(s), and the development, where necessary, of mitigation or avoidance measures to preclude negative effects. Principally, the purpose of AA is to identify the possible effects of implementing a Plan or Project on the conservation status of designated Natura 2000 sites within the Plan or Project area. Directive 92/43/EEC on the conservation of Natural Habitats and Wild Flora and Fauna – 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 interest to the EU in a favourable condition. Article 6(3) of the Habitats Directive states “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 light of the conclusions of the assessment of the implications for the site and 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) 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 social or economical nature, the Member State shall take all compensatory measures necessary to ensure that the overall coherence of the Natura 2000 is protected. It shall inform the Commission of the compensatory measures adopted’. 1.4 Overview of Habitats Directive Assessment Process The European Commission, as well as the Department of Environment, Community and Local Government


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have both published methodological guidance, both of which recommend a four stage approach in carrying out the entire Habitats Directive Assessment process as follows: Stage 1 – Screening: Determines whether a project or plan, either alone or in combination with other plans or projects, is likely to have an impact on a Natura 2000 site, and considers whether these impacts are likely to be significant; Stage 2 – Appropriate Assessment (AA): Considers the impact on the integrity of the Natura 2000 sites of the project or plan, either alone or in combination with other plans or projects, with respect to the site’s structure and function and its conservation objectives. Additionally, where there are adverse impacts, it assesses the potential mitigation of those impacts; Stage 3 – Assessment of Alternative Solutions: Examines alternative ways of achieving the objectives of the project or plan that avoid adverse impacts on the integrity of the Natura 2000 site; Stage 4 – Imperative Reasons of Overriding Public Interest: Assess compensatory measures where in the light of an assessment of imperative reasons of overriding public interest (IROPI) it is deemed that the plan or project should proceed. Each stage determines whether the next stage in the process is required. If, for example, it is concluded at the end of Stage 1 that there will be no significant impacts on the Natura 2000 site, there is no requirement to proceed further. However if it is concluded after Stage 1 that significant impacts are likely or unknown then Stage 2 – Appropriate Assessment is required. 1.5 Guidance Documents In preparing this Screening report the following guidance documents were consulted (both documents are issued by Department of Environment, Heritage and Local Government):

'Circular NPW 1/10 & PSSP 2/10 (March 2010)'

'Appropriate Assessment of Plans and Projects in Ireland – Guidance for Planning Authorities (2009),'

In addition, the following European Union published documents were consulted (See Section ?? for a full list of references) :

European Commision (2000). Managing Natura Sites: The provisions of Article 6 of the Habitats Directive 92/43/EEC. Office for Official Publications for the EuropeanCommunities, Luxembourg.

European Commision (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 for the European Communities, Luxembourg.

European Commission (2007). Guidance Document on Article 6(4) of the Habitats Directive 92/43/EEC: Clarification of the concepts of: alternative solutions, imperative reasons of over-riding public interest, compensatory measures, overall coherence, opinion of the Commission.

European Commission (2006). Nature and Biodiversity Cases: Ruling of the European Court of Justice. Office for Official Publications for the European Communities, Luxembourg.

In keeping with the guidelines outlined in the above documents, the aims of this report are to produce a Screening for Appropriate Assessment report through following the procedure outlined for Appropriate Assessment. The aims of this report can therefore be summarised as follows :


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Determining whether the project or plan is directly connected with or necessary to the management of the Natura 2000 site.

Describing the project or plan and the description and characterisation of other projects or plans that in combination have the potential for having significant effects on the Natura 2000 site(s).

Characteristics of the Natura 2000 site – identification of the relevant Natura 2000 sites and compiling of information on their qualifying interests and conservation objectives.

Identification of possible impacts caused by the development to the Natura 2000 site

Assessment of the significance of potential impacts – To assess the potential for significant direct, indirect and combined impacts on Natura 2000 sites caused by the site development.

2.0 Statement of Qualification I hold an MSc in Ecological Assessment and a BSc in Marine Science. I have 5 years experience in ecological surveying in the west of Ireland, in a variety of upland, lowland and aquatic habitats. I have extensive experience in the preparation of appropriate assessment and ecological impact assessment related reports. 3.0 Methodology Desktop Review This report is based on an assessment of the potential for the proposed development to cause significant impacts to the integrity of Clew Bay Complex SAC, with particular reference to the qualifying criteria of the SAC and the associated conservation objectives. A desktop survey was conducted to ascertain the site's proximity to Natura 2000 sites and to compile information on qualifying interests and conservation objectives of relevant Natura 2000 sites along with their likely ecological connectivity to the proposed site development. Clew Bay Complex SAC (Site code 001482) was found to be the sole Natura 2000 site of relevance to this assessment. Owing to the confined scale of the project, it was considered that potential impacts on designated sites other than Clew Bay Complex SAC could be readily screened out. Site specific conservation objectives and associated backing documents for the Clew Bay Complex SAC have been contemporaneously prepared by NPWS; the information contained in these documents was used to inform the assessment, along with the observations made during the site visit Site Visit In order to verify the composition of the habitats at the proposed development location, a site visit was conducted on 25/02/16 to coincide with a low tide at circa 13:30. The vicinity of the proposed development was walked over and the constituent habitats were noted. Photographs of the proposed location were taken and some of these photographs are included as Appendix D to this report. Report Format Sections 4 to 7 outline the relevant Natura 2000 sites – in this case Clew Bay Complex SAC - and the existing environment in the vicinity of the proposed project location. Section 8 comprises the screening matrix for this assessment which follows the template recommended in the guidance literature. A ‘Finding of no significant effects’ matrix is contained in Section 8.1. Section 9.0 comprises screening conclusions.


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4.0 Connectivity of the development to the management of Natura 2000 sites The proposed development is not connected with the management of Natura 2000 sites. 5.0 Relevant Natura 2000 Sites – qualifying criteria and conservation objectives

The application site is located in the southern section of the Clew Bay complex SAC. Other Natura 2000 sites located within a 15km radius of the application site include:

Brackloon Wood SAC (Site code 000471)

Old Head Wood SAC (Site code 000532)

Mweelrea Sheefrey Erriff Complex SAC (Site code 001932)

West Connacht Coast SAC (Site code 000471)

The nearest of the above Natura 2000 sites is Brackloon Wood SAC which is located c. 6 km to the southeast of the application site. Owing to the confined size and scale of the proposed development, it is considered that pathways for impacts to accrue on these Natura 2000 sites do not exist and therefore potential impacts on these Natura 2000 sites can be readily discounted. Therefore this assessment will focus solely on assessing the potential for impacts to accrue on Clew Bay Complex SAC. Figure 1 shows the position of the application site within Clew Bay Complex SAC.

Map of proposed development location within Clew Bay Complex SAC

Figure 1: Map of proposed development location (Circled) within Clew Bay Complex SAC. Cross hatch shading denotes extent of SAC coverage. The qualifying attributes and conservation objectives of Clew Bay Complex SAC are outlined in Table 1. A full site synopsis for the SAC is included as Appendix A to this report.


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Table 1: Site details for Clew Bay Complex SAC

Site Name and Location

Clew Bay Complex SAC (001482) – located in the direct vicinity of the application site

Site Description Clew Bay is a wide, west-facing bay on the west coast of Co. Mayo. It is open to the westerly swells and winds from the Atlantic with Clare Island giving only a small amount of protection. The drumlin landscape was formed during the last glacial period when sediments were laid down and smoothed over by advancing ice - the sea has subsequently inundated this area, creating a multitude of islands. The geomorphology of the bay has resulted in a complex series of interlocking bays creating a wide variety of marine and terrestrial habitats, including several listed on Annex I of the E.U. Habitats Directive: large shallow bay, lagoon, Atlantic saltmeadows,drift lines, perennial vegetation of stony banks, embryonic shifting dunes,Marram dunes and dune slacks.

Qualifying Interests of the Site

The site is designated for three Annex II species and eight Annex I habitats, all of which are listed below.

[1355]Otter Lutra lutra

[1365]Common seal Phoca vitulina

[1013]Geyer's whorl snail Vertigo geyeri

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

[1150]* Coastal lagoons (*Priority habitat)

[1160]Large shallow inlets and bays

[1210]Annual vegetation of drift lines

[1220]Perennial vegetation of stony banks

[1330]Atlantic salt meadows (Glauco‐Puccinellietalia maritimae)

[2110]Embryonic shifting dunes

[2120]Shifting dunes along the shoreline with Ammophila arenaria ("white dunes")

Conservation Objectives for Clew Bay Complex SAC

The conservation objectives for Clew Bay Complex SAC can be summarised as ‘To maintain or restore the favourable conservation condition of the Annex I Habitats and Annex II species for which the SAC has been selected’ Site-specific conservation objectives have been prepared for the site. These objectives include specific conservation targets for each of the qualifying criteria for which Clew Bay Complex SAC is designated. Maps showing the distribution of habitats and features of interest for designated species within the site have also been prepared by NPWS for inclusion in the Conservation Objectives document. Although not included in the main qualifying criteria for the SAC designation, it is important to note that Clew Bay provides habitat for several species of gull, wader and waterfowl, all of which are protected under the EU Wild Birds Directive. Several of these species are listed in the Natura 2000 form for the site.

Current information on the location, form and function of the designated habitats and species (With the exception of Otter and Geyer's whorl snail*) is also contained in the following additional backing documents for the SAC’s conservation objectives (*Geyer's whorl snail's inclusion in the qualifying criteria of the SAC is currently under review. This species' habitat is confined to small sections of freshwater fen macro-habitats. Such habitats are not ecologically connected with the locality of the proposed development; mainly occurring in the northern fringes of the SAC therefore potential impacts on the species can be discounted):


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Clew Bay Complex SAC (001482): Conservation objectives supporting document - coastal habitats [Version 1, 2011]

Clew Bay Complex SAC (001482): Conservation objectives supporting document - marine habitats and species [Version 1, 2011] Maps of the main littoral and sub-littoral habitats within the SAC are contained in the various conservation objectives documents. These documents also provide additional information on the site-specific conservation objectives for all of the qualifying criteria for the SAC. Based on the distribution of habitats as shown in these documents and my own personal ecological knowledge of the local area, it is considered that the qualifying habitats and species of primary relevance to this assessment therefore include the following: • 1160 Large shallow inlets and bays • 1140 Mudflats and sandflats not covered by seawater at low tide • 1365 Common seal Phoca vitulina • 1355 Otter Lutra lutra. The mapped distribution of Otter within the SAC is shown to be ubiquitous along all sections of coastline within the SAC (including the coastlines of islands). Maps abstracted from the SAC conservation objectives documents showing the distribution of the above (with the exception of Otter) are included as Appendix B to this report. Given the small scale and confined size of the proposed project, it is considered that the other qualifying habitats and species for which the SAC is designated are located at a sufficient distance from the proposed project location (in terms of their current and potential distribution) such that no impacts on them are likely to arise from the proposed project.

6.0 Description of project The proposed development comprises the installation of a pre-assembled floating jetty on the shore adjoining a long standing single house on Inishgowla island near Westport. The jetty will enable house residents to embark and disembark safely from boats when travelling to and from the island. The jetty has dimensions of c. 30.4 metres length and 2.4 metres width and comprises a surface layer of wooden planks overlaying 9 rectangular pontoons . The jetty will be tethered by small ship’s chain to 6 mooring blocks, each of which are 1.2 metres wide and 0.6 metres deep(See accompanying planning application drawings for layout of the proposed jetty). The proposed jetty location has historically been the main landing point for boat traffic accessing the house; Boat traffic visiting the island is currently obliged to land directly on the beach which can be an arduous process with associated health and safety risks. The installation of the jetty is anticipated to significantly improve the ease and safety of this process while also reducing and confining any potential impacts of boat hulls compacting the underlying beach substrate. (although it should be noted that the impacts of boat hulls on the shore substrate are currently likely to be minor in any case).


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7.0 Existing Environment in vicinity of application site

Location and Setting (See Appendix B for photographs of proposed location)

The application site is located on the northeast shoreline of Inishgowla, an island located in the inner section of Clew Bay, c. 5 km west/northwest of Westport. Inishgowla is a flooded drumlin island with a shape and profile characteristic of the numerous ‘whale backed’ islands which occupy the inner section of Clew Bay. The island is comprised of two main sections, both of which are elongated in an east to west direction and are linked by a narrow strip of land. The western sections of the island are fringed by boulder clay cliffs while the eastern portion of the island tapers gently to the shoreline. Virtually the entirety of the terrestrial environment on the island is comprised of pasture grassland on a boulder clay substrate. The likely Fossit category for the grassland which dominates the terrestrial section of the island is ‘Dry calcareous and neutral grassland GS1’. The location of the proposed jetty is adjacent to a longstanding house and small garden which overlooks the shoreline. The garden has a simple layout, largely consisting of a maintained grass lawn. A dry stone retaining wall abuts the seaward border of the garden and denotes the boundary between the shore and the garden. Various other sections of dry stone retaining walls occur denote shore/land boundary in this part of the island. A moderate sized stone shed and ruins are located to the northwest of the property . A moderate sized stone shed is also located to the southwest of the property. A modern outhouse building is located in the southern section of the property. Within the footprint and immediate vicinity of the proposed jetty location, the shore largely comprises a mixed substrate of pebbles, gravel and muddy sand (See Appendix B). ‘Mixed sediment shores LS5’ is the likely appropriate Fossit category for this habitat. The shore here has a moderate slope profile in the mid to upper littoral zone with a more gentle gradient occurring in the lower littoral zone. Seaweed growth here is much reduced in comparison with the majority of the surrounding shoreline and comprises small quantities of fucoid (Wrack) species and abundant filamentous brown algae. This habitat grades into a muddy sand sediment along the lower littoral margins. The littoral zone of the remainder of the island is typical of that fringing the numerous islands in Clew Bay, comprising a moderately sloped substrate of mixed stones and boulders covered by a mat of fucoid seaweeds including Bladder Wrack Fucus vesiculosis and Spiral Wrack Fucus spiralis in the mid to upper zone and Egg Wrack Ascophyllum nodosum in the mid to lower shore. ‘Sheltered rocky shores LR3’ is the likely appropriate category for this habitat type under Fossit (2000). This habitat typically grades into muddy sand and mixed sediment in the lower littoral and sub-littoral zones. Several small islands and small skerries are located in close proximity to the section of Inishgowla on which the proposed jetty is to be located; These islands and skerries denote the channel by which the proposed location is accessed. Two small ribbon islands extend in a in a south easterly direction from the shore just to the east of the proposed jetty location and several small tidal rocky skerries extend in a ribbon from northwest to southeast, commencing approximately 20 metres east of the the base of the shoreline.


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Aerial photo of proposed jetty location

Figure 2: Aerial photo showing proposed jetty location (Circled) Ecological Assessment of Application Site The Annex I habitat ‘1160 Large shallow inlets and Bays’ is a large physiographic feature that may wholly or partly incorporate other Annex I habitats (including mudflats and sandflats) and benthic habitats of particular conservation interest including seagrass (Zostera) and maerl beds within its area. In the site specific conservation objectives backing document (marine habitats) for the SAC, the proposed jetty location is classified as ‘Reef’ , as is the entirety of the boulder shore of Inishgowla and the adjacent islands and skerries. However this document’s portrayal of the shore habitat at the application site is misleading as Reef habitat does not occur within the vicinity of the proposed jetty footprint. ‘Mixed sediment shores LS5’ is instead the most appropriate Fossit (2000) category for the habitat occurring at the application site. This habitat type is not considered to be of high ecological value and does not correlate with any specific habitat types that are annexed under the EU Habitats Directive. The shore here has a moderate slope profile in the mid to upper littoral zone with a more gentle gradient occurring in the lower littoral zone. Seaweed growth here is much reduced in comparison with the majority of the surrounding shoreline and comprises small quantities of fucoid (Wrack) species and abundant filamentous brown algae. This habitat is clearly shown in the photographs of the application site in Appendix B.This habitat grades into a muddy sand sediment along the lower littoral margins. The form of the habitat which occurs at the application site is not considered to be of significant conservation value as it has diminished cover of epifauna and flora and low numbers of infauna. The proposed jetty location has been the longstanding boat landing location on the island as the shore surface here is smooth – if a boulder shore (i.e. Reef habitat) did in fact occur here, boat landing would not be possible at this location. The proposed location is not considered to be within the potential zone of influence of Maërl dominated communities, the closest of which occurs to the south of the southern section of Inishgowla.


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The closest section of seagrass dominated habitat occurs in the main sub littoral channel to the north of the application site at a minimum distance of circa 120 metres - this is also considered to be beyond the zone of influence of the confined development footprint Owing to the depth at which the sub-littoral Seagrass and Maërl communites occur, no direct threat is posed to the habitat by boat traffic passing through the waters above the habitat. The proposed jetty footprint is not considered to be of particular value for protected wildlife species. The site footprint does not contain any terrain suitable for construction of Otter holts and there is an abundance of similar or better quality habitat for the species in the local and wider vicinity. Various haul out locations for Harbour Seals occur within the Westport Bay section of the SAC. The nearest recorded haul out location occurs on the southern section of Inishgowla (minimum distance 300 metres) and on a small unhabitated island to the east of the proposed development (minimum distance 400 metres) (See Marine Habitats Conservation Objectives backing document for maps of seal haul-outs) . However seal numbers occurring at these locations are generally very low and the haul out location of primary importance in the Westport Bay area occurs at Green Island (personal observation) at a distance of over 2km east of the proposed location. The shore in the vicinity of the proposed jetty location is not known to be used as a regular haul-out by seals and the proposed location is not in direct line of visual sight from either of the nearest haul-out locations. The proposed installation of the jetty will not precipitate a significant increase in boat traffic to the island; Therefore the boat traffic associated with the proposed installation of the jetty is considered to be negligible ie. boat traffic associated with the installed jetty does not pose a disturbance related threat to seal populations or other protected wildlife species. 8.0 Assessment of Significance of Potential Impacts

Screening Matrix for Assessment of Significance of Potential Impacts

Describe the individual elements of the project (either alone or in combination with other plans or projects) likely to give rise to impacts on the Natura 2000 Sites

Owing to the extremely small scale and size of the proposed project, the potential for direct impacts arising from the proposed project is considered to be very limited. Direct impacts solely pertain to damage to the substrate underlying the jetty structure. Indirect and in -combination impacts pertain to disturbance arising from boat traffic. The potential for these impacts to be significant is considered further in the following sections below and overleaf with the conclusion being that no significant impacts are predicted.

Assessment of likely direct, indirect or secondary impacts of the project (either alone or in combination with other plans or projects) on the Natura 2000 sites

Size and scale; Likely Impacts: None. Given the extremely small scale and size of the proposed structure, no negative impacts are predicted in this regard. Land-take; Likely Impacts: None. The shore substrate has a paucity of emergent or sessile fauna, therefore the potential impacts of structures being placed on the substrate are reduced. The footprint of the structure is small with a total area occupied of less than 100 m2 (Including mooring blocks). The structure will be afloat from mid to high tide and will rest on the shore during mid to low tide. The weight of the jetty is considered to be sufficiently spread across the 9 rectangular pontoons such that the underlying substrate will not be significantly compressed during the lower part of the tide. The overall effect of the structure’s installation is likely to constitute a net minor positive impact by eliminating the requirement for boats to land directly on the beach. Distance from the Natura 2000 site or key features of the site; Likely Impacts: None. The location is within the SAC but does not comprise a key


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feature of the SAC. Resource requirements (water abstraction etc); Likely Impacts: None. The structure will be pre-fabricated at an industrial location remote from Natura 2000 sites, therefore no resources from within the SAC will be required. Emissions (disposal to land, water or air); Likely Impacts: None. Excavation requirements; Likely Impacts: None. The jetty is a free-floating structure which will be tethered to mooring blocks using light to moderate chains Transportation requirements; Likely Impacts: None. The proposed installation of the jetty will not precipitate a significant increase in boat traffic to the island; The boat traffic associated with the proposed installation of the jetty is considered to be negligible and in line with the levels currently visiting the island ie. boat traffic associated with the installed jetty does not pose a disturbance related threat to seal populations or other protected wildlife species. Duration of construction, operation, decommissioning; Likely Impacts: None. The structure will be pre-fabricated at a location remote from the Natura 2000 site. Noise and Light Pollution; Likely Impacts: None. The sole noise impacts associated with the structure pertain to boat traffic which will not increase significantly above existing levels. Potential In-combination impacts; Likely Impacts: None. Given the location’s proximity to the main navigation channel for access to Westport harbour, it is considered that the small craft boat traffic associated with the installation of the structure is so minor such that no in-combination impacts associated with existing boat traffic in the Westport bay section of the SAC will occur.

Likely changes to the Natura 2000 sites arising from the development as a result of:

Reduction of habitat area; Owing to the tiny footprint of the jetty on a category of inter-tidal habitat (Mixed sediment shores LS5) that that is not considered to be of significant conservation value (in the context of the SAC or otherwise), no changes are predicted in this regard. Disturbance to key species; The application site is not of significant value for constituent annexed or protected species of the SAC, therefore the potential for direct disturbance arising from the development is considered to be negligible. While the SAC conservation documents do indeed show a point location on the southeast section of the island (c. 300 linear metres from the application site) to be a moulting location for the species, the numbers of seals that haul-out at this location during the moulting season are very low. Seals are often entirely absent from this location during the moulting seasons and if present, generally only


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occur in numbers of one to several individuals (personal observation). The primary locations of importance for hauled out Harbour Seals occur to the east at skerries and islands in the vicinity of Green Island which are well beyond the potential zone of influence of the proposed development In any event the number of seals occurring at the marked moulting location is somewhat moot given the distance of the application site from the marked location and also given that the location is not directly visible from the application site. A recent review of international literature on seal disturbance conducted by Dr Susan Wilson for the Seal Conservation Society (Date unspecified) found that the flushing distances for hauled out seals which are unacclimatised to boat traffic was in the range of 150 to 200 metres ie. unacclimatised seals remain in situ at distances greater than 200 metres. Harbour Seals occurring in Westport Bay are undoubtedly acclimatised to a certain level of boat traffic. Given that the haul-out location is not directly visible from the application site and is at a distance well in excess of 200 m from the application site, it is my professional opinion that no significant impacts on seal species should arise from this development. It should also be noted that the primary direction of boat movement to and from the island is in the direction of Rosmoney and Carrowholly (both of which lie to the north and northeast of the island), ie. in a different direction from the marked haul-out. In conclusion, it is reiterated that the proposed development will not significantly impact Harbour Seal populations occurring within the Clew Bay Complex SAC. Habitat or species fragmentation; No changes are predicted. Reduction in species density; No changes are predicted. Changes in key indicators of conservation value (water quality etc.); It is considered that pathways for impacts on water, air, soils etc within the SACs do not exist. Climate change; No changes are predicted.

Likely impacts on the Natura 2000 sites as a whole in terms of:

Interference with the key relationships that define the structure of the site;

Interference with key relationships that define the function of the site; No significant impacts arising from the development on key relationships that define the structure or function of Clew Bay Complex SAC are foreseen


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Indicators of significance as a result of the identification of effects set out above in terms of:

Loss;

Fragmentation;

Disruption;

Disturbance;

Change to key elements of the site (e.g. water quality etc.). Indicators of significance in the context of Clew Bay Complex would entail significant impacts (particularly with regards to disturbance) to the qualifying habitats and species of the SAC. However no such impacts are predicted.

Elements of the project or plan, or combination of elements, where the above impacts are likely to be significant or where the scale or magnitude of impacts is not known.

None - there are no such elements of the project where the above impacts are likely to be significant or where the scale or magnitude of impacts is not known.

8.1 Finding of No Significant Effects Matrix

Name of Project or Plan Installation of a jetty for small craft at Inishgowla island near Westport, Co. Mayo

Names and locations of relevant Natura 2000 sites

Clew Bay Complex SAC (001482) – the proposed project is to be located within the southern section of the SAC.

Description of the project or plan

The proposed development comprises the installation of a floating jetty on the north east shore of Inishgowla Island c. 5 km west of Westport in Clew Bay. The purpose of the jetty is provide a safe berthing facility for small craft landing at the island. The jetty has dimensions of c. 30.4 metres length and 2.4 metres width and comprises a surface layer of wooden planks overlaying rectangular pontoons.

Is the project or plan directly connected with or necessary to the management of the site (provide details)?

No

Are there other projects or plans that together with the project or plan being assessed could affect the site (provide details)?

No

The assessment of significance of effects

Describe how the project or plan (alone or in combination) is likely to affect the Natura 2000 site.

It is the conclusion arising from the foregoing assessment that significant effects are not likely to arise from the proposed project. Potential effects considered include damage to shore


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substrate and disturbance arising from associated boat traffic.

Explain why these effects are not considered significant.

The projected small volume of associated boat traffic will not have a significant effect owing to the significant levels of existing boat traffic in the adjacent navigation channel and the absence of features of interest for designated species of interest in the immediate vicinity of the proposed location. The mixed sediment habitat composition of the shore at the proposed location is not considered to be of any significant conservation value. The footprint of the jetty is very small at less than 100m2 and the load of the jetty is evenly distributed across attached underlying pontoons – therefore the substrate should not be significantly compressed. The jetty will also help to confine and reduce the footprint of small craft which currently have to land directly on the shore.

List of agencies consulted: provide contact name and telephone or e-mail address.

N/A

Response to consultation. N/A

Data collected to carry out the assessment

Who carried out the assessment?

Sources of data Level of Assessment Where can the full results of the completed assessment be accessed and viewed?

Conor Ryan MSc

1. NPWS Site Synopses, Conservation Objectives and backing documents and NATURA 2000 Forms for relevant Natura 2000 sites 2. Personal observations made during site visit previous recreational visits to the site vicinity 3. Drawings of the proposed development to be submitted with the planning application

Site Visit conducted on 25/02/16 and Desktop Assessment

This document will be submitted as part of a planning application to the relevant planning authority. Therefore the submitted document should be available for public viewing from Mayo County Council.

9.0 Screening Conclusions This screening exercise included a detailed consideration of the potential impacts arising from the proposed development on Clew Bay Complex SAC. Given the small size and scale of the proposed project and absence of habitats of conservation interest within the development footprint, it is considered that viable pathways for significant impacts to accrue on


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constituent habitats and species within the SAC do not exist. It is the conclusion of this Screening for Appropriate Assessment Statement that the proposed project is compatible with the Conservation Objectives for the qualifying interests of Clew Bay Complex SAC ie. significant effects accruing from the proposed development on these Natura 2000 sites do not have potential to occur. Therefore it is the recommendation of this Screening for Appropriate Assessment Statement that further phases of the Habitats Directive Assessment Process will not be required for the proposed development. 10.0 References Department of Environment, Heritage and Local Government (2010): Appropriate Assessment of Plans and Projects in Ireland – Guidance for Planning Authorities. Environmental Protection Agency website and map-viewer www.epa.ie EUNIS Natura 2000 Site Information Forms - European Environment Agency http://eunis.eea.eu European Union Habitats Directive 1992 European Commision (2000). Managing Natura Sites: The provisions of Article 6 of the Habitats Directive 92/43/EEC. Office for Official Publications for the European Communities, Luxembourg. European Commision (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 for the European Communities, Luxembourg. European Commission (2007). Guidance Document on Article 6(4) of the Habitats Directive 92/43/EEC: Clarification of the concepts of: alternative solutions, imperative reasons of over-riding public interest, compensatory measures, overall coherence, opinion of the Commission. European Commission (2006). Nature and Biodiversity Cases: Ruling of the European Court of Justice. Office for Official Publications for the European Communities, Luxembourg. Fairley, J (1984) An Irish Beast Book: A Natural history of Ireland's Furred Wildlife. Blackstaff Press Fossitt, J.A. (2000) A Guide to Habitats in Ireland. The Heritage Council Geological Survey of Ireland. Website and map-viewer www.gsi.ie NPWS (2011) Conservation objectives and associated backing documents for Clew Bay Complex SAC (001482) Version 1.0. Department of Arts, Heritage & the Gaeltacht. National Biodiversity Data Centre website 2016 – Online atlas of national species distribution www.biodiversityireland.ie Wilson, S (Date Unknown). The impact of human disturbance at seal haul-out sites. A literature review for the Seal Conservation Society.

http://www.biodiversityireland.ie/


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Appendix A: NPWS Site synopsis for Clew Bay Complex SAC SITE NAME: Clew Bay Complex SAC SITE CODE: 001482

Clew Bay is a wide, west-facing bay on the west coast of Co. Mayo. It is open to the westerly swells and winds from the Atlantic with Clare Island giving only a small amount of protection. The drumlin landscape was formed during the last glacial period when sediments were laid down and smoothed over by advancing ice - the sea has subsequently inundated this area, creating a multitude of islands. The geomorphology of the bay has resulted in a complex series of interlocking bays creating a wide variety of marine and terrestrial habitats. The site is a Special Area of Conservation (SAC) selected for the following habitats and/or species listed on Annex I / II of the E.U. Habitats Directive (* = priority; numbers in brackets are Natura 2000 codes):

[1355]Otter Lutra lutra

[1365]Common seal Phoca vitulina

[1013]Geyer's whorl snail Vertigo geyeri

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

[1150]* Coastal lagoons (*Priority habitat)

[1160]Large shallow inlets and bays

[1210]Annual vegetation of drift lines

[1220]Perennial vegetation of stony banks

[1330]Atlantic salt meadows (Glauco‐Puccinellietalia maritimae)

[2110]Embryonic shifting dunes

[2120]Shifting dunes along the shoreline with Ammophila arenaria ("white dunes") Within the shallow bay, subtidal sediments are characterised by typical bivalve communities in fine sand (Chamelea striatula and Ensis sp.), and by the polychaete worm Euclymene and the bivalve Thyasira flexuosa in muddy sand. The intertidal sediment communities are characterised by polychaetes and bivalves in the mid-shore and by the sand mason worm Lanice conchilega in the low shore. In areas where there is maerl debris with small amounts of live maerl the infaunal community has a mixture of species characteristic of coarse sand (e.g. the bivalves Timoclea ovata, Spisula sp., and the polychaetes Nepthys cirrosa and Glycera lapidum) and medium sand (e.g., the bivalve Ensis sp. and the polychaetes Lanice conchilega, Scoloplos armiger and Sthenelais boa). The bivalves Timoclea ovata, Tapes rhomboides and the polychaetes Branchiomma bombyx and Glycera lapidum are typical of gravels and medium sands, whereas the bivalves Abra alba, Corbula gibba, Thyasira flexuosa and Mysella bidentata and the polychaete Euclymene are characteristic of muddy sands. Beds of live maerl of Lithothamnion corallioides are also present in a number of areas. Around the edges of the inner part of the bay are shores of mixed boulders, cobbles, gravel with some sand and mud. They have a typical zonation of intertidal communities found on sheltered shores of mixed substratum. The shore at Murrisk is unusual as a distinct zone characterised by archiannelids occurs above the sandhopper zone in the upper shore under the boulders and cobbles. This is an unusual habitat. In sheltered areas of shallow water with little sand scour a well developed community of hydroids, sponges and solitary sea squirts is present. Where the sediments includes gravel and mud the species richness in the area can be exceptionally high (180 species). A number of marine species that are rarely recorded are found in Clew Bay: the stalked jellyfish Lucernariopsis cruxmelitensis; the polycheates Anitides rosea, Clymenura clypeata, Pterosyllis formosa and Pionosylis sp. and the snail Clypterea chinensis. Clew Bay is considered to have the most significant shingle reserves in the country, and has (on the islands) the only examples of incipient gravel barriers in Ireland. Associated with the shingle (and dunes) are good examples of annual vegetation of drift lines. Characteristic species found in these habitats include: Spear-leaved Orache (Atriplex prostrata), Red Fescue (Festuca rubra), Sea Sandwort (Honkenya peploides), Thrift


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(Armeria maritima), Common Scurvygrass (Cochlearia officinalis), Sea Mayweed (Matricaria maritima) and Sea Campion (Silene vulgaris subsp. maritima). Lough Furnace is located at the north-eastern corner of Clew Bay. The lough is a good example of a deep, stratified, saline lake lagoon in a very natural state. Salinity levels can vary considerably here depending on rainfall and tides. The lake is one of the very few permanently stratified lakes known in Ireland and Britain. The lake is ringed by Common Reed (Phragmites australis) and Common Club-rush (Scirpus lacustris), with small patches of Great Fen-sedge (Cladium mariscus) and Bottle Sedge (Carex rostrata). Lough Furnace supports a relatively high faunal diversity (41 taxa recorded in the 1996 survey) including a number of important invertebrate species. The relict mysid species Neomysis integer, the isopods Jaera albifrons, J. ischiosetosa and J. nordmanni, and two rare amphipods (Lembos longipes and Leptocheirus pilosus) have all been recorded from the lake. Both Irish species of tasselweed (Ruppia maritima and R. cirrhosa) occur in the lagoon. Eel, Flounder and Mullet also occur in the lake waters. Mallard nest around the lough, while Saint’s Island contains nesting Black-headed Gull. At the north-western end of Lough Furnace lie two associated lakes, Lough Napransky and Lough Navroony. A stream drains from the latter into the main lake. The area contains flush and quaking-mire vegetation, which is of interest as Irish Heath (Erica erigena) is found there, with Bog Moss (Sphagnum spp.), Black Bog-rush (Schoenus nigricans), Bog Asphodel (Narthecium ossifragum), Common Cottongrass (Eriophorum angustifolium) and Round-leaved Sundew (Drosera rotundifolia). Bog Orchid (Hammarbya paludosa), a species listed in the Irish Red Data Book is also found in this area. Beyond the wet area there is a Hazel (Corylus avellana) dominated woodland growing over abandoned fields. Birch (Betula pubescens), Hawthorn (Crataegus monogyna) and Holly (Ilex aquifolium) are common, with occasional Oak (Quercus petraea). The ground flora contains such species as Bluebell (Hyacinthoides non-scripta), Sanicle (Sanicula europaea) and Wood-sorrel (Oxalis acetosella). The Rosmurrevagh area in the north of Clew Bay displays a high diversity of habitats, from seashore to dunes and coastal grassland, as well as saltmarsh, bog and fen. The sandy beach on the seaward side grades into dunes of Marram (Ammophila arenaria). Adjacent to this, the saltmarsh vegetation, which is approximately 5 m wide, comprises Thrift, Common Scurvygrass, Common Saltmarsh-grass (Puccinellia maritima) and ‘turf fucoids’ (diminutive forms of brown algae). These plant species are typical of Atlantic salt meadows. Similar saltmarshes occur scattered around the entire shoreline of the bay. Next to the saltmarsh at Rosmurrevagh is an area of coastal grassland with species such as Daisy (Bellis perennis), Ribwort Plantain (Plantago lanceolata), Dandelion (Taraxacum officinale), Heath Wood-rush (Luzula multiflora), Common Ragwort (Senecio jacobaea) and Yarrow (Achillea millefolium). Flushes introduce a species-rich bog/fen type vegetation. Yellow Iris (Iris pseudacorus), Soft Rush (Juncus effusus), Irish Heath, Bog Mosses, sedges, Water Mint (Mentha aquatica), Bog-myrtle (Myrica gale), Bog Asphodel and Cuckooflower (Cardamine pratensis) are found. A further dune system occurs at Bartraw in the south-west of the site. Here Marram and embryonic dunes occur along a shingle ridge which links a small island where dunes also occur. Embryonic dunes, characterised by the presence of Sand Couch (Elymus farctus), also occur on some of the islands in the bay. Important populations of Otter and Common Seal are found in Clew Bay. Both of these species are listed on Annex II of the E.U. Habitats Directive. The Clew Bay Complex supports a good diversity of wintering waterfowl, with nationally important numbers of Red-breasted Merganser (average maximum of 70 in the winters 1995/96-1999/00) and Ringed Plover (average maximum of 142 in the winters 1995/96-1999/00). A population of Barnacle Geese (between 100 and 200 birds) frequents the islands during winter. Other species which occur in significant numbers include Great Northern Diver (14), Brent Goose (118), Shelduck (74), Wigeon (112), Teal (127), Mallard (64), Oystercatcher 250), Dunlin (450), Bar-tailed Godwit (73), Curlew (373), Redshank (172), Greenshank (10) and Turnstone (27) (all figures are average maxima for the winters 1995/95-1999/00). Species which breed in important numbers include Cormorant (115 pairs in 1985), Common Tern (20+ pairs in 2000/01), Arctic Tern (100+ pairs in 2000/01) and Little Tern (9 pairs in 2000). The various tern species, as well as Barnacle Goose, Great Northern Diver and Bartailed Godwit, are listed on Annex I of the E.U. Birds Directive. The juxtaposition within Clew Bay of a wide variety of habitats, including seven listed on Annex I of the E.U.


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Habitats Directive, and the combination of important flora and fauna, including one Red Data Book plant and two mammals listed on Annex II of the E.U. Habitats Directive, make this a site of considerable national and international importance.


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Appendix B: Photographs of proposed development location

Plate 1: View looking southwest from lower section of shore showing proposed jetty footprint

Plate 2: View looking northeast from edge of applicant’s garden over the proposed jetty location


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Plate 3: View looking southwest of middle and upper section of the shore at the proposed jetty

location


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