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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 For inspection purposes only. Consent of copyright owner required for any other use. EPA Export 14-03-2018:03:27:03

CR04552 - Request for a TA in relation to Schedule 1 (ii ... · Request for a TA in Relation to Schedule 1 (ii) Appropiate Assessment Screening Report ... In brief the proposal to

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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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IPPCL P0693-01

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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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