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Takeda Ireland Limited
(Grange Castle)
IPPCL P0693-01
Request for a TA in Relation to
Schedule 1 (ii)
Appropiate Assessment Screening
Report
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1 | P a g e
Table of Contents
1. Introduction...................................................................................................................... 2
2. Metholodgy ....................................................................................................................... 2
3. Overview of the Technical Amendment in relation to the Receiving Environment ........................ 5
4. Analysis of European Sites within 15km................................................................................ 7
5. Screening Assessment ..................................................................................................... 11
6. Conclusion of the Screening Assessment ............................................................................ 12
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1. Introduction
The information in this report forms part of, and should be read in conjunction with the
documentation accompanying the application for a Technical Amendment in relation to Schedule
1.1 of IEL P0693-01. This report, which contains information required for the competent authority
(in this instance the Environmental Protection Agency) to undertake a screening exercise for
Appropriate Assessment (AA), was prepared by Takeda. It provides information on and assesses
the potential for the proposed works to significantly affect Natura 2000 sites (hereafter “European
sites”1).
It is necessary that the proposal has regard to Article 6 of the Council Directive 92/43/EEC of 21
May 1992 on the Conservation of Natural Habitats and of Wild Fauna and Flora (as amended)
(hereafter “the Habitats Directive”). This is transposed in Ireland primarily by the European
Communities (Birds and Natural Habitats) Regulations 2011 (S.I. No. 477/2011) (hereafter the
Birds and Habitats Regulations) and the Planning and Development (Amendment) Act, 2010
(hereafter the Planning Act) as amended.
An AA is required if likely significant effects on European sites arising from a proposed
development cannot be ruled out at the screening stage, either alone or in combination with other
plans or projects.
Following the preparation of this screening report it may be objectively concluded that there is no
likelihood of any significant effects on any European sites arising from the proposed works, either
alone or in combination with other plans or projects. Therefore it was in Takeda’s view that an
Appropriate Assessment is not required in this instance. The information in the tables below
provide a summary of the information gathered for this screening exercise and the conclusions
made.
2. Metholodgy
This Screening Statement for Appropriate Assessment was prepared with regard to the following
guidance documents, where relevant:
Appropriate Assessment of Plans and Projects in Ireland - Guidance for Planning
Authorities. (Department of Environment, Heritage and Local Government, 2010 revision).
Appropriate Assessment under Article 6 of the Habitats Directive: Guidance for Planning
Authorities. Circular NPW 1/10 & PSSP 2/10.
Assessment of Plans and Projects Significantly Affecting Natura 2000 sites: Methodological
Guidance on the Provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC
(European Commission Environment Directorate-General, 2001); hereafter referred to as
the EC Article 6 Guidance Document. The guidance within this document provides a non-
mandatory methodology for carrying out assessments required under Article 6(3) and (4)
of the Habitats Directive.
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Compensatory Measures, Overall Coherence. Opinion of the European Commission
(European Commission, January 2007).
Guidelines for Good Practice Appropriate Assessment of Plans under Article 6(3) Habitats
Directive. Findings of an international workshop on Appropriate Assessment in Oxford,
December 20092.
Communication from the Commission on the precautionary principle. European
Commission (2000b).
The above referenced guidance sets out a staged process for carrying out Appropriate Assessment.
To determine if Appropriate Assessment is required, documented screening is required. Screening
identifies the likely effects on European Sites, if any, which would arise from a proposed plan or
project, either alone or in combination with other plans and projects.
If the conclusions at the end of screening are that there is no likelihood of significant effects
occurring on any European Sites, as a result of the proposed plan or project, either alone or in
combination with other plans and projects, then there would be no requirement to undertake
Appropriate Assessment.
However, even if screening makes a finding of no significant effects, and therefore concludes that
Appropriate Assessment is not required, these findings must be clearly documented in order to
provide transparency of decision-making, and to ensure the application of the ‘precautionary
principle’.
Screening for Appropriate Assessment involves the following:
Determining whether a project or plan is directly connected with or necessary to the
conservation management of any European Sites;
Describing the details of the project/plan proposals and other plans or projects that may
cumulatively affect any European sites (see Table 1);
Describing the characteristics of relevant European Sites (Table 2); and,
Assessing the likelihood and significance of effects on relevant European Sites (see Table
2).
The information that was collected to allow the competent authority to screen the proposal was
based on a desktop study carried out on 05th December 2017. Information relied upon included
the following information sources, which included maps, ecological and water quality data:
Ordnance Survey of Ireland mapping and aerial photography available from www.osi.ie ;
Online data available on European Sites as held by the National Parks and Wildlife
Service(NPWS) from www.npws.ie ;
Information on land-use zoning from the online mapping of the Department of the
Environment, Community and Local Government http://www.myplan.ie/en/index.html ;
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Information on water quality in the area available from www.epa.ie ;
Information on the Eastern River Basin District from www.wfdireland.ie ;
Information on soils, geology and hydrogeology in the area available from www.gsi.ie ;
Information on the location, nature and design of the proposed Technical Amendment;
Managing Natura 2000 Sites: The Provisions of Article 6 of the Habitat’s Directive
92/43/EEC (EC Environment Directorate-General, updated April 2015); hereafter referred
to as MN2000.
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,
Information on the status of EU protected habitats and species in Ireland (National Parks &
Wildlife Service, 2013a & 2013b);
Information on the conservation status of birds in Ireland (Colhoun & Cummins, 2014).
The following planning and policy documents were relevant to the subject lands, in particular
with regard to the assessment of other plans and projects with potential for cumulative
effects:
National Biodiversity Plan 2011 – 2016 (Department of Arts, Heritage and the
Gaeltacht, 2011);
South Dublin County Development Plan 2016 – 2022 (South Dublin County Council,
2016);
South Dublin County Heritage Plan 2010 – 2015; and,
Eastern River Basin District, River Basin Management Plan 2009-2015.
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3. Overview of the Technical Amendment in relation to the Receiving Environment
Brief
Description of
the site
The subject lands are located on the Takeda premises in Grange Castle Business Park (Grid Reference: O 03234 31973), Dublin 22.
Lands surrounding Grange Castle Business Park are predominantly agricultural to the west and residential to the east.
Features of the
Surrounding
Environment
The desktop study found no records of any species or habitats for which European sites listed in Table 2 are designated within the subject
lands or environs. Peregrine Falcon (Falco peregrinus) was recorded within 2km of the TILGC’s site (Bird Atlas 2007 – 2011).
The TILGC site is located within the Liffey river catchment. The Ballymakaily stream is culverted beneath TILGC’s site. It emerges at the
eastern boundary of the site and flows north along the hedgerow. It converges with the river Grifeen at the north-eastern boundary of the
site. The river Griffeen converges with the river Liffey c. 4km downstream of TILGC’s site. The river Liffey discharges into a complex of
marine and intertidal European Sites in Dublin Bay.
According to EPA online Envision Maps, the water quality of the surface, transitional and coastal water is as follows:
The River Liffey is classified as of ‘Moderate’ water quality status c.4.7km downstream of TILGC’s site;
The Upper Liffey Estuary is classified as ‘Eutrophic’ transitional water;
The Lower Liffey Estuary is classified as ‘Unpolluted’ transitional water; and,
Dublin Bay is classified as ‘Unpolluted’ coastal water.
The Liffey is classified as “at risk of not achieving good status” under the Water Framework Directive (WFD) risk scoring system.
The groundwater body at TILGC is within the ‘Dublin Urban’ ground waterbody and is described as ‘Poorly productive bedrock’ and is
‘Expected to achieve good status’. According to the GSI Map Viewer, the level of vulnerability to groundwater contamination from human
activities in the immediate area is deemed to be ‘Extreme’ and the site is located on an area of “rock at or near the surface or karst”. It is
also described as ‘Locally Important Aquifer – Bedrock which is moderately productive only in local zones’.
Foul effluent generated from TILGC is discharged to the existing sewer and is treated at Ringsend Wastewater Treatment Works (WWTW)
prior to discharge into Dublin Bay. Surface water runoff is discharged into the river Grifeen which joins the river Liffey and ultimately
leads to Dublin Bay. According to the EPA Envision Map Viewer Dublin Bay’s coastal waters are “Unpolluted”. Under the “Trophic Status
Assessment Scheme” classification of the EPA, “Unpolluted” means there have been no breaches of the EPA’s threshold values for
nutrient enrichment, accelerated plant growth, or disturbance of the level of dissolved oxygen normally present (EPA, 2015). The most
recently available water quality data for the Irish Sea indicates that it is of ‘Unpolluted’ status. Description of
Proposed
Technical
Amendment
Full details of the proposed Technical Amendment are contained in the application report. In brief the proposal to to change TILGC’s
existing abatement system at EP-P1-03 from a water scrubber to disposable carbon beds to ensure ongoing compliance with the licence
without any negative environmental or human health impact.
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Defining the
Zone of
Influence of the
Proposed
Works
The Zone of Influence (ZoI) is a distance within which the proposed Technical Amendment could potentially affect the conservation
condition of QI habitats or species. There is no set recommended distance for which European sites are considered as being relevant (i.e.
within the ZoI of proposed works) for AA. Available guidance (NPWS, 2010) recommends that “the distance should be evaluated on a
case-by-case basis with reference to the nature, size and location of the project, and the sensitivities of the ecological receptors, and the
potential for in combination effects”. As a general rule of thumb, it is often considered appropriate to examine all European sites within
15km as a starting point. In some instances where there are far reaching hydrological/hydrogeological connections, a whole river
catchment or a groundwater aquifer may need to be included in determining the ZoI. All European sites within 15km of the proposed
works are listed in Table 2 and illustrated on Figure 1. In this case, the distance of 15km exceeds the potential zone of influence of the
proposed works and any likelihood of significant effects in relation to European Sites beyond 15km can be ruled out.
Other existing
or proposed
plans or
projects nearby
which may lead
to cumulative
effects on
European sites.
Existing habitat loss pressures
TILGC’s lands do not physically overlap with any European Sites. The nearest European Site is more than 5km away. There are no
habitats listed under Annex I of the Habitats Directive within the site boundary. These habitats are not indirectly connected with any
habitats within European Sites (e.g. by groundwater). No mobile fauna species for which nearby European Sites are designated are known
(or are likely) to use the habitats within the TILGC sie. There is therefore no potential for cumulative effects relating to habitat loss or
direct impacts on species.
Existing pressures on water quality within European Sites in proximity to the site
Several intertidal habitats for which European sites in Dublin Bay are designated are failing to meet favourable conservation status. For
some of these, water pollution is considered a threat ranked as being of “high importance”5 (NPWS, 2013).
Pressures from surface waters
There will be no impact from the proposed Technical Amendment on Surface Wate. Therefore there will be no impact on designated sites
within Dublin Bay as the proposed site is located approx. 15km east of the European site at its closest point.
Pressures from foul waters
There will be no foul water generated as a result of the proppsed Technical Amendment. Foul waste from TILGC is discharged to the
existing foul water drainage network at Citywest Business Campus. From here foul waters is transferred to Ringsend WWTP for treatment
prior to discharge into the Liffey Estuary/Dublin Bay. Ringsend WWTP currently operates above its capacity of 1.64 million P.E., however
there will be no additional loading resulting from the proposed Technical Amendment and it will not result in significant effects on
European sites within Dublin Bay for the following reasons:
The coastal waters in Dublin Bay are classed as “Unpolluted” by the EPA;
There remained at the time of writing no proven link between Ringsend WWTP discharges and nutrient enrichment of sediments in
Dublin Bay based on previous analyses of dissolved and particulate Nitrogen signatures (Wilson and Jackson, 2011); and
Enriched water entering Dublin Bay has been shown to rapidly mix and become diluted such that the plume is often
indistinguishable from the rest of bay water (O'Higgins and Wilson, 2005).
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4. Analysis of European Sites within 15km
Site name and
code
Distance from
TILGC’s Site (approximate)
Reasons for designation6 (*=
Priority Habitat)
Relevant source-pathway-receptor links between TILGC’s site and
European site? No sites are “Relevant” to the Proposed Development.
(European sites are “Relevant” where a relevant source-
Rye Valley/Carton
SAC (001398)
Located c. 5km north-west of TILGC’s site
Conservation Objectives Generic Version 5.0
(15/08/16) Annex I Habitats:
Petrifying springs with tufa formation (Cratoneurion)* [7220]
Annex II Species :
Narrow-mouthed Whorl Snail Vertigo angustior [1014]
Desmoulin's Whorl Snail Vertigo moulinsiana [1016]
This SAC site lies c. 4.5km upstream of the TILGC site. In addition, it is within a separate river sub basin to the proposed development. Therefore
it is not possible that the proposed Technical Amendment would impact upon this SAC in any way.
Glenasmole
Valley SAC (001209)
Located c.10km south
of TILGC’s site
Conservation Objectives
Generic Version 5.0 (15/08/16)
Annex I Habitats: Semi-natural dry grasslands
and scrubland facies on calcareous substrates
(Festuco-Brometalia) (* important orchid sites)* [6210]
Molinia meadows on calcareous, peaty or clayey-
silt-laden soils (Molinion caeruleae) [6410]
Petrifying springs with tufa formation (Cratoneurion)*
No, due to the distance between the TILGC site and the European site
and the absence of a hydrological linkage between the two.
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Wicklow
Mountains SAC (002122)
Located c. 12km south
of TILGC’s site.
Conservation Objectives
Version 1.0 (31/07/2017) Annex I Habitats:
Oligotrophic waters containing very few minerals of sandy
plains (Littorelletea uniflorae) [3110]
Natural dystrophic lakes and ponds [3160]
Northern Atlantic wet heaths
with Erica tetralix [4010] European dry heaths [4030]
Alpine and Boreal heaths [4060]
Species-rich Nardus grasslands, on siliceous
substrates in mountain areas (and submountain areas, in
Continental Europe)* [6230] Blanket bogs (* if active bog)
[7130] Siliceous scree of the montane
to snow levels (Androsacetalia alpinae and Galeopsietalia
ladani) [8110] Calcareous rocky slopes with
chasmophytic vegetation [8210]
Siliceous rocky slopes with chasmophytic vegetation
[8220] Old sessile oak woods with Ilex
and Blechnum in the British
Isles [91A0] Annex II Species:
Lutra lutra (Otter) [1355]
No, due to the distance between the TILGC site and the European site
and the absence of a hydrological linkage between the two.
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South Dublin
Bay SAC (000210)
Located c. 15 km east
of of TILGC’s site.
Conservation Objectives
Version 1.0 (22/08/13) Annex I Habitats:
[1140] Mudflats and sandflats not covered by seawater at low tide
[1210] Annual vegetation of drift lines
[1310] Salicornia and other annuals colonising mud and sand [2110] Embryonic shifting dunes
Whilst there is a linkage between the TILGC Site and the European site
through discharges of surface water and foul waters treated at Ringsend WWTP and discharged in Dublin Bay, there is no possibility any effects
resulting from the proposed Technical Amendment and the proposal will not result in the generation of any additional surface or wastewater.
Surface Water Discharges
TILGC’s site is located approx. 14km west of the European site; surface waters will not be impacted as a result of this Technical Amendment . Surface water currently generated on the site could carry silt, oils, or
other chemicals into the local surface water sewer network at Citywest Business Campus which may indirectly be discharged to Dublin Bay.
There is no possibility of significant effects on the reasons for designation of the European site in view of the relevant conservation objectives for
the following reasons: Distance between the subject lands and European site and potential
for dilution in the drainage network; Any pollution event is likely to be short in duration (i.e. confined to
storm events) and The qualifying interest habitats within the European site by nature
have existing heavy silt loading
Foul Water Discharges There will be no foul water generated as a result of the Technical
Amendment. Foul waters generated at TILGC are ultimately treated at Ringsend WWTP and discharged into Dublin Bay within the European site.
No significant effects were predicted for the following reasons: The coastal waters in Dublin Bay are classed as
“Unpolluted” by the EPA; There remained at the time of writing no proven link between
Ringsend WWTP discharges and nutrient enrichment of sediments in Dublin Bay based on previous analyses of dissolved and particulate Nitrogen signatures (Wilson and Jackson, 2011);
Enriched water entering Dublin Bay has been shown to rapidly mix and become diluted such that the plume is often indistinguishable
from the rest of bay water (O'Higgins and Wilson, 2005); The Ringsend WWTP extension is likely to be completed in the short-
medium term to ensure statutory compliance with the Water
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Framework Directive. This is likely to maintain the “Unpolluted” water
quality status of coastal waters despite potential pressures from future development; and
Marine modelling for Ringsend WWTP indicates that discharged effluent is rapidly mixed and dispersed to low levels via tidal mixing
within a short distance of the outfall pipe (Dowly & Bedri 2007).
Wicklow
Mountains SPA (004040)
Located c. 15 km south
of of TILGC’s site.
Generic Conservation
Objectives Version 5.0 (15/08/16) Merlin Falco columbarius
[A098] Peregrine Falco peregrinus
[A103]
No, due to the distance between TILGC’s site and the European site and
the absence of a hydrological linkage between the
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5. Screening Assessment
The following screening assessment is carried OL in accordance with EU Guidance (EC, 2001) and
using the standardscreening assessment form provided in Annex 2 of the EU Guidance
document.Implicit in the Habitats Directive is the application of the precautionary principal, which is
used (i) where there ispotential for negative effects and (ii) where due to inconclusive or insufficient
data it is not possible to determine withsufficient certainty the risk in question (EC, 2000b).
Assessment Criteria
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.
Change of abatement system from a water
scrubber to disposable carbon beds.
Describe any likely direct, indirect or secondary
impacts of the project (either alone or in
combination with other plans or projects) on the
Natura 2000 site by virtue of: Size and scale;
Land-take;
Resource requirements;
Emissions;
Excavation requirements;
Transportation requirements;
Distance from Natura 2000 site or key
features of the site
Duration of construction, operation etc
Others.
The emission of THF may have the effect of
impairing individual plants and species within
the designated sites and thereby having an
impact at a habitat or species level. At the
levels proposed and as predicted by the air
screening model the magnitude of this impact is
imperceptible.
Describe any likely changes to the site arising
as a result of:
Reduction of habitat area;
Disturbance of key species;
Habitat or species fragmentation; .
Reduction in species density;
Changes in key indicators of
conservation value;
Climate change.
No changes to any European Site are likely
to occur as a result of the proposed amendment
to the IEL for TILGC
At concentrations predicted by the worst case
model its effect on climate change will be
imperceptlble.
Describe any likely impacts on the Natura 2000
site 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 impacts to any European Site are likely to
occur as a result of the proposed amendment to
the IEL
Describe from the above those elements of the
project or plan, or combination of elements,
where the above impacts are likely to be
significant or where the scale of magnitude of
impacts is not known
not known.
None.
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6. Conclusion of the Screening Assessment
Following an examination, analysis and evaluation of the relevant information, including in
particular, the nature of the proposed Technical Amendment and their potential relationship with
European sites, as well as considering other plans and projects, and applying the precautionary
principle, it is Takeda’s opinion that it is possible to rule out likely significant effects on all European
sites.
The AA screening process has identified that a number of European sites lie within the potential
zone of influence of surface and foul effluent discharges from TILGC’s site. However for the reasons
outlined below no European sites are deemed to be at risk of likely significant effects from the
proposed Technical Amendment.
Surface Water
The proposed Technical Amendment will not impact on the site’s existing surface water drainage
system. The existing surface water system drains to Dublin Bay via the River Griffeen and River Liffey
and the discharge of treated effluent from the foul drainage network are potential pathways
between TILGC’s site and Dublin Bay. No significant adverse effects are predicted due to the
following:
The significant distance, approx. 15km, between the site and Dublin Bay and potential for
mixing of pollution in the drainage network;
Lack of hydrological linkage between the proposed site and other European sites within
15km.
Foul Water
The proposed Technical Amendment will not generate foul wastwaters. Foul waters from the
existing site are treated at Ringsend WWTW before being discharged into Dublin Bay. The WWTP
currently operates above its capacity of 1.64 million P.E. at 1.9 million P.E. Any existing or proposed
projects discharging to the plant have the potential to act cumulatively to reduce water quality in
Dublin Bay, affecting European sites therein. Despite Ringsend WWTP historically operating at or
above capacity, no significant effects from discharge arising from TILGC’s site are predicted due to
the following:
There was no proven link between WWTP discharges and nutrient enrichment of sediments
in Dublin Bay based on analyses of dissolved and particulate Nitrogen signatures (Wilson and
Jackson, 2011);
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Enriched water entering Dublin Bay has been shown to rapidly mix and become diluted such
that the plume is often indistinguishable from the rest of bay water (O'Higgins and Wilson,
2005);
Marine modelling for Ringsend WWTP indicates that discharged effluent is rapidly mixed and
dispersed to low levels via tidal mixing within a short distance of the outfall pipe (Dowly &
Bedri 2007).
The NPWS standard data form for North Dublin Bay SAC states that there had been no apparent
impacts to the associated flora and fauna from polluted water; and,
A commitment by Irish Water to upgrade the plant from its current capacity of 1.64 million
P.E. to meet EU standards and expand the facility to deal with the equivalent expansion as
previously planned by Dublin City Council.
For these reasons, it is Takeda’s opinion that the application for the the Technical Amendment in
relation to Schedule 1.1 does not require an Appropriate Assessment.
However, Takeda acknowledge that it is for Environmental Protection Agency, as the competent
authority, to carry out a screening for AA and to reach one of the following determinations:
a) AA of the proposed Technical Amendment is required if it cannot be excluded, on the
basis of objective information, that the proposed Technical Amendment, individually or in
combination with other plans or projects, will have a significant effect on any European
sites;
b) AA of the proposed Technical Amendment is not required if it can be excluded, on the
basis of objective information, that the Technical Amendment, individually or in combination
with other plans or projects, will have a significant effect on any European sites.
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