Irish Water Report - Environmental Protection Agency · 5 | Irish Water NIS - Riverstown Article 6(4) states: If, in spite of a negative assessment of the implications for the [Natura

Irish Water

Report

Natura Impact Statement as part of the Riverstown Waste Water

Certificate of Authorisation

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2 | Irish Water AA Screening - Riverstown

Contents

Introduction 4

Legislative Context 4

Methodology 6

Guidance Followed 6

Stages Involved in the Appropriate Assessment Process 7

Field Walkover Surveys 7

Consultation 7

Screening 8

Management of the Site 8

Description of the Project 8

Description of the Receiving Environment and Monitoring Results 8

Waste Assimilative Capacity 9

Field Walkover Survey 10

Brief Description of the Natura 2000 Sites 10

Possible Effects of the Waste Water Discharge in the Natura 2000 Sites 14

Direct, Indirect or Secondary Impacts 14

Possible Cumulative Impacts with other Plans and Projects in the Area 14

Screening Assessment 15

Likely Changes to the Natura 2000 Sites 17

Screening Conclusions 17

Stage 2: Appropriate Assessment 18

Description of the Natura 2000 Site Affected 18

Description of the Conservation Interests of the SAC 18

Annex I Habitats 18

Annex II Species 19

Conservation Objectives of the Unshin River SAC 20

Impact Prediction 20

Impacts on Water Quality 20

Impacts on Annex I Habitats 21

Impacts on Annex II Species 22

Mitigation Measures 23

Stage 2 Appropriate Assessment Conclusion Statement 24

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3 | Irish Water AA Screening - Riverstown

References 25

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4 | Irish Water NIS - Riverstown

Introduction

This report provides an Appropriate Assessment (AA) of the existing Waste Water Treatment

Plant (WwTP), located at Riverstown, approximately 15km south east of Sligo Town, for the

purposes of the Waste Water Discharge (Authorisation) Regulations, 2007 (S.I. No. 684 of 2007),

as amended. It assesses whether the on-going operation of the plant, alone or in combination

with other plans and projects, is likely to have significant effects on a European Site(s) in view of

best scientific knowledge and the conservation objectives of the site(s). European Sites are

those identified as sites of European Community importance designated as Special Areas of

Conservation under the Habitats Directive or as Special Protection Areas under the Birds

Directive.

This report follows the guidance for AA published by the Environmental Protection Agency’s

(EPA) ‘Note on Appropriate Assessments for the purposes of the Waste Water Discharge

(Authorisation) Regulations, 2007 (S.I. No. 684 of 2007)’ (EPA, 2009); and takes account of the

Department of the Environment, Heritage and Local Government’s guidelines ‘Appropriate

Assessment of Plans and Projects in Ireland. Guidance for Planning Authorities’ (DoEHLG, 2009)

and Circular L8/08 ‘Water Services Investment and Rural Water Programmes – Protection of

Natural Heritage and National Monuments’ (DoEHLG, 2008).

The AA was completed by a qualified ecologist, and full member of the CIEEM, on behalf of Irish

Water.

Legislative Context The Council Directive 92/43/EEC on the Conservation of Natural Habitats and of Wild Fauna and

Flora, better known as “The Habitats Directive”, provides legal protection for habitats and species

of European importance. Articles 3 to 9 provide the legislative means to protect habitats and

species of Community interest through the establishment and conservation of an EU-wide

network of sites known as Natura 2000. These are Special Areas of Conservation (SACs)

designated under the Habitats Directive and Special Protection Areas (SPAs) designated under

the Conservation of Wild Birds Directive (79/409/ECC) as codified by Directive 2009/147/EC.

Articles 6(3) and 6(4) of the Habitats Directive set out the decision-making tests for plans and

projects likely to affect Natura 2000 sites (Annex 1.1). Article 6(3) establishes the requirement for

Appropriate Assessment (AA):

Any plan or project not directly connected with or necessary to the management of the

[Natura 2000] site but likely to have a significant effect thereon, either individually or in

combination with other plans or projects, shall be subjected 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 subject to the

provisions of paragraph 4, the competent national authorities shall agree to the plan or

project only after having ascertained that it will not adversely affect the integrity of the

site concerned and, if appropriate, after having obtained the opinion of the general

public.

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Article 6(4) states:

If, in spite of a negative assessment of the implications for the [Natura 2000] site and in

the absence of alternative solutions, a plan or project must nevertheless be carried out

for imperative reasons of overriding public interest, including those of a social or

economic nature, Member States shall take all compensatory measures necessary to

ensure that the overall coherence of Natura 2000 is protected. It shall inform the

Commission of the compensatory measures adopted.

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Methodology

Guidance Followed Both EU and national guidance exists in relation to Member States fulfilling their requirements

under the EU Habitats Directive, with particular reference to Article 6(3) and 6(4) of that Directive.

The methodology followed in relation to this AA has had regard to the following guidance:

Note on Appropriate Assessments for the purposes of the Waste Water Discharge

(Authorisation) Regulations, 2007 (S.I. No. 684 of 2007). Environmental Protection

Agency, (EPA, 2009).

Appropriate Assessment of Plans and Projects in Ireland: Guidance for Planning

Authorities. Department of Environment, Heritage and Local Government, (DoEHLG,

2010).

Circular L8/08 – Water Services Investment and Rural Water Programmes – Protection

of Natural Heritage and National Monuments. Department of Environment, Heritage and

Local Government, (DoEHLG, 2008).

Communication from the Commission on the Precautionary Principle. Office for Official

Publications of the European Communities, Luxembourg, (EC, 2000a).

Managing Natura 2000 Sites: the provisions of Article 6 of the ‘Habitats’ Directive

92/43/EEC, Office for Official Publications of the European Communities, Luxembourg,

(EC, 2000b).

Assessment of plans and projects significantly affecting Natura 2000 sites:

Methodological guidance on the provisions of Articles 6(3) and (4) of the Habitats

Directive 92/43/EEC. Office for Official Publications of the European Communities,

Brussels (EC, 2001).

Guidance document on Article 6(4) of the ‘Habitats Directive’ 92/43/EEC – Clarification

of the concepts of: alternative solutions, imperative reasons of overriding public interest,

compensatory measures, overall coherence, opinion of the Commission. Office for

Official Publications of the European Communities, Luxembourg, (EC, 2007).

Nature and biodiversity cases: Ruling of the European Court of Justice. Office for Official

Publications of the European Communities, Luxembourg (EC, 2006).

Marine Natura Impact Statements in Irish Special Areas of Conservation: A working

document, National Parks and Wildlife Service, Dublin (NPWS, 2012).

European Communities (Birds and Natural Habitats) Regulations, 2011 (S.I. No.477 of

2011).

Interpretation Manual of European Union Habitats. Version EUR 28. European

Commission (EC, 2013).

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Stages Involved in the Appropriate Assessment Process

Stage 1: Screening / Test of Significance

This process identifies whether the WwTP discharge is directly connected to or necessary for the

management of a European Site(s); and identifies whether the discharge is likely to have

significant impacts upon a European Site(s) either alone or in combination with other projects or

plans.

The output from this stage is a determination for each European Site(s) of not significant,

significant, potentially significant, or uncertain effects. The latter three determinations will cause

that site to be brought forward to Stage 2.

Stage 2: Appropriate Assessment

This stage considers the impact of the WwTP discharge on the integrity of a European Site(s),

either alone or in combination with other projects or plans, with respect to (1) the site’s

conservation objectives; and (2) the site’s structure and function and its overall integrity.

Additionally, where there are adverse impacts, an assessment of the potential mitigation of those

impacts

The output from this stage is a Natura Impact Statement (NIS). This document must include

sufficient information for the EPA to carry out the appropriate assessment. If the assessment is

negative, i.e. adverse effects on the integrity of a site cannot be excluded, then the process must

consider alternatives (Stage 3) or proceed to Stage 4.

Stage 3: Assessment of Alternatives

This process examines alternative ways of achieving the objectives of the project or plan that

avoid adverse impacts on the integrity of the European Site. This assessment may be carried out

concurrently with Stage 2 in order to find the most appropriate solution. If no alternatives exist or

all alternatives would result in negative impacts to the integrity of the European sites then the

process either moves to Stage 4 or the project is abandoned.

Stage 4: Assessment Where Adverse Impacts Remain

An assessment of compensatory measures where, in the light of an assessment of Imperative

Reasons of Overriding Public Interest (IROPI), it is deemed that the project or plan should

proceed.

Field Walkover Surveys Field walkover surveys were undertaken during 13

th of May 2014 to identify the potential for

qualifying species and habitats in the surrounding environs of the WwTP discharge.

Consultation Consultation was undertaken with the Divisional Ecologist Northern Region of the National Parks

and Wildlife Service, Mr. William Macoran, in relation to the existing discharge from the

Riverstown WwTP. Concerns were identified regarding the existing plants discharge into the

Unshin River SAC.

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Screening

Management of the Site The Riverstown WwTP is not directly connected with or necessary to the management of the site

for nature conservation.

Description of the Project Riverstown is located about 15km South East of Sligo Town. The current population equivalent

(residential & non domestic) served by the WwTW is approximately 462 p.e. The projected p.e.

for 2021 is 468.

Currently sewage from the village is conveyed via a combined collection network to the Waste

Water Treatment Plant which is located to the west of the town. The plant is an extended

aeration treatment plant and has a design p.e. of 600. The Riverstown agglomeration discharges

in the Unshin River Special Area of Conservation (SAC).

The WwTP consists of an inlet works, a primary settlement tank, aeration and clarifier, effluent

outlet and a control room. There is a facility for Emergency Overflow prior to the inlet works. In

the case of emergency (mechanical breakdown/power failure) this overflow is to the Unshin River

at NGR 173834E, 320222N.

Based on a p.e. of 462, the daily flow from the WwTP based on a 95% flow is 104m3/d. The

daily flows within the receiving waters of the Unshin River based on the 95% flow is 12,096m3/d.

This provides a significant dilution factor of 116.3:1 within the receiving watercourse.

Description of the Receiving Environment and Monitoring Results

The WwTP discharges to the Unshin River. Monitoring data from 2012/2013 from both upstream

and downstream of the discharge locations demonstrates that the water quality within the Unshin

River is in compliance with Schedule 5 of the European Communities Environmental Objectives

(Surface Water) Regulations 2009 (S.I. No. 272 of 2009).

Table 1.0: Monitoring Data both Upstream and Downstream of WwTP Discharge**

Parameter EQS* Upstream Downstream

BOD ≤2.6 1.5 1.5

Ammonia (as NH3 – N) ≤0.14 0.041 0.040

Orthophosphate ≤0.075 0.01 0.01

*European Communities Environmental Objectives (Surface Waters) Regulations 2009, S.I. No. 272 of 2009

(95%ile standards presented).

** Data from 2012/2013 monitoring (averaged measured from 3 sampling occasions)

In addition, the 2012 EPA Biological Water Quality monitoring data upstream of the discharge at

Riverstown Bridge (Station 0200) was Q4 and the nearest monitoring point downstream (approx.

5.5 km) at Lisconny Bridge (Station 0400) was Q4. Further downstream at Ballygrania Bridge

(Station 0500) the Q value was 4-5. This 2012 data indicates Good Status water both upstream

and downstream of the WwTP discharge.

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Waste Assimilative Capacity

Table 2.0a summaries the assimilative capacity calculations which are based on the 2021

estimated loading of 468p.e., 95%ile river flow and water quality standards in the European

Communities Environmental Objectives (Surface Water) Regulations, 2009 (S.I. No. 272 of

2009). Assimilative capacity calculations have been carried out for the actual background

concentrations and the ‘notionally clean river’ approach and the WWTP effluent design

standards.

Table 2.0a: Assimilative capacity calculations at estimated 2021 loadings of 468p.e.

for actual background concentrations and for a notionally clean river

using effluent design standards.

Parameter Background

(mg/l)

Predicted

downstream

quality (mg/l)

EQS* (mg/l)

BOD Actual Background 1.0 1.72 ≤2.6

Notionally Clean 0.260 0.48

Ammonia Actual Background 0.036 0.257 ≤0.14


Orthophosphate Actual Background 0.010 0.027 ≤0.075


*European Communities Environmental Objectives (Surface Waters) Regulations 2009, S.I. No. 272 of 2009 (95%ile standards presented).

Assuming notionally clean water in the Unshin River, the receiving water does not have

adequate waste assimilative capacity for the Riverstown WwTP, specifically, for Ammonia.

The WAC was also carried out using the mean discharge concentration for Ammonia for 2015

(i.e. current situation). This mean value is based on 10 sampling dates. Based on this calculation

it would suggest that the Unshin River has available assimilative capacity to accommodate the

WwTP discharge in terms of Ammonia using both the actually background concentration and the

EPA notionally clean river concentration (see Table 2.0b).

Table 2.0b: Assimilative capacity calculations at estimated 2021 loadings of 468p.e.

for the actual background concentration and for a notionally clean river

using the 2015 mean effluent concentration for Ammonia (based on 10

sampling dates).

Parameter Background

(mg/l)

Predicted

downstream

quality (mg/l)

EQS* (mg/l)

Ammonia Actual Background 0.036 0.077 ≤0.14


*European Communities Environmental Objectives (Surface Waters) Regulations 2009, S.I. No. 272 of 2009 (95%ile standards presented).

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It appears that the current operation of the Riverstown WwTP and associated discharge to the

Unshin River is not noticeably affecting biological water quality. Likewise, the impact of the

current discharge on the chemical water quality is not considered to be significant.

Field Walkover Survey

At the existing discharge location the Unshin River contained a riffle / glide / pool habitat type,

with a greater proportion of the riffle habitat upstream of the discharge location. It has a good

flow with a substratum type of boulders, cobbles, gravel and sand. Water depth 0.2 – 1m+. In-

stream vegetation consisted of a good distribution of Water-crowfoot (Ranunculus spp.) both

upstream and downstream of the discharge location.

Immediately downstream of the discharge location emergent macrophytes (e.g. Typha latifolia,

Phalaris arundinaceae) were evident, together with filamentus algae (Cladophora spp.), which

are indicative of nutrient enrichment.

Field examination, including both upstream and downstream of the discharge location, revealed

the presence of the Annex I habitat:

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

Batrachion vegetation [3260].

And the Annex II Species:

Salmon (Salmo salar) [1106]; and

Otter (Lutra lutra) [1355].

The Unshin and its tributaries is the most important salmon producing river in Co. Sligo. The

system also supports a good population of trout. Suitable spawning ground was located along

this stretch, both upstream and downstream of the discharge location. There was a greater

proportion of spawning grounds upstream of the discharge location, however, suitable spawning

and resting pools were also recorded downstream of the discharge location.

In addition, juvenile salmonids were observed throughout the downstream section, approximately

500m below the discharge location, together with suitable nursery and adult habitats.

Otter are widespread throughout the Unshin River catchment, and otter signs were also recorded

downstream of the discharge location. This watercourse was the subject of recent flooding, and

so further signs of otters (e.g. spraints, feeding remains, paths/slides) could have been recently

washed away.

Brief Description of the Natura 2000 Sites

This section of the screening process describes the Natura 2000 sites within a 15km radius of

the WwTP discharge location. A 15km buffer zone has been chosen as a precautionary

measure, to ensure that all potentially affected Natura 2000 sites are included in the screening

process, which is in line with Appropriate Assessment of Plans and Projects in Ireland –

Guidance for Planning Authorities produced by the Department of the Environment, Heritage and

Local Government.

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Table 3.0 list the SACs and Table 4.0 lists the SPAs that are within 15km of the WwTP discharge

location, and Figure 1.0 shows their location in relation to the Riverstown WwTP discharge. The

qualifying interests of each of the identified Natura 2000 Sites is also provided.

Table 3.0: SACs located within 15km from Riverstown WwTP discharge

Site

Code

Site Name Qualifying Habitats Qualify Species

000636 Templehouse and

Cloonacleigha

Loughs SAC

Hard oligo-mesotrophic waters with

benthic vegetation of Chara spp. [3140];

and

Water courses of plain to montane

levels with the Ranunculion fluitantis

and Callitricho-Batrachion vegetation

[3260].

-

001656 Bricklieve Mountains

& Keishcorran SAC

Turloughs [3180];

Semi-natural dry grasslands and

scrubland facies on calcareous

substrates (Festuco

Brometalia)(*important orchid sites)

[6210];

Lowland hay meadows (Alopecurus

pratensis, Sanguisorba officinalis)

[6510]; and

Calcareous and calcshist screes of the

montane to alpine levels (Thlaspietea

rotundifolii) [8120].

Marsh fritillary (Euphydryas

aurinia) [1065]; and

White-clawed crayfish

(Austropotamobius pallipes)

[1092].

001673 Lough Arrow SAC Hard oligo-mesotrophic waters with

benthic vegetation of Chara spp. [3140].

-

001898 Unshin River SAC Water courses of plain to montane

levels with the Ranunculion fluitantis

and Callitricho-Batrachion vegetation

[3260]; and

Alluvial forests with Alnus glutinosa and

Fraxinus excelsior (Alno-Padion, Alnion

incanae, Salicion albae) [91E0].

Salmon (Salmo salar) [1106];

and


000622 Ballysadare Bay

SAC

Estuaries [1130];

Mudflats and sandflats not covered by

seawater at low tide [1140];

Embryonic shifting dunes [2110];

Shifting dunes along the shoreline with

Ammophila arenaria (white dunes)

[2120];

Fixed coastal dunes with herbaceous

vegetation (grey dunes) [2130]; and

Humid dune slacks [2190].

Marsh Snail (Vertigo

angustior) [1014]; and

Harbour seal (Phoca vitulina)

[1365].

001976 Lough Gill SAC Natural euthrophic lakes with White-clawed crayfish

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Site

Code

Site Name Qualifying Habitats Qualify Species

Magnopotamion or Hydrocharition-type

vegetation [3150];

Old sessile oak woods with Ilex and

Blechnum in British Isles [91A0]; and

Alluvial forests with Alnus glutinosa and

Fraxinus excelsior (Alno-Padion, Alnion


(Austropotamobius pallipes)

[1092];

Sea lamprey (Petromyzon

marinus) [1095];

Brook lamprey (Lampetra

planeri) [1096];

River lamprey (Lampetra

fluviatilis) [1099];


and


000638 Union Wood SAC Old sessile oak woods with Ilex and

Blechnum in British Isles [91A0].

-

Table 4.0: SPAs located within 15km from Riverstown WwTP discharge

Site Code Site Name Qualifying Features – Annex I Species

004129 Ballysadare Bay SPA Light-bellied Brent Goose (Branta bernicla hrota) [A046];

Grey Plover (Pluvialis squatarola) [A141];

Dunlin (Calidris alpina) [A149];

Bar-tailed Godwit (Limosa lapponica) [A157];

Redshank (Tringa totanus) [A162]; and

Wetlands & Waterbirds [A999].

004050 Lough Arrow SPA Little Grebe (Tachybaptus ruficollis) [A004];

Tufted Duck (Aythya fuligula) [A061]; and

Wetlands & Waterbirds [A999].

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Possible Effects of the Waste Water Discharge in the Natura 2000 Sites

The purpose of this section of the screening is to examine the possibility that the waste water

discharge, either individually or in combination with other plans and projects, may result in

significant negative effects on the Conservation Objectives and the integrity of the Natura 2000

Sites identified.

The most apparent potential risk to a Natura 2000 Site(s) from a WwTP discharge is to the water

quality of the receiving environment, and if the receiving environments water quality has the

potential to interact with the qualifying interests of the Natura 2000 Sites identified.

The WwTP discharges to the Unshin River, which is itself designated as part of the Unshin River

SAC.

Direct, Indirect or Secondary Impacts

The Riverstown WwTP discharges directly to the Unshin River SAC. The receiving waters of the

SAC does not have sufficient assimilative capacity for the effluent in terms of Ammonia, based

on the effluent design standard for Ammonia. However, based on the 2015 mean effluent

concentration (based on 10 samples), the receiving water has sufficient assimilative capacity for

the effluent in terms of Ammonia.

The upstream and downstream monitoring results demonstrate that the Unshin River water

quality is in compliance with Schedule 5 of the Surface Water Regulations and does not appear

to be impacted by the WwTP discharge. Likewise, the 2012 EPA Biological Water Quality data

shows that the current biological water quality both upstream (immediately upstream of the

discharge location at Station Riverstown Bridge) and downstream at Station Lisconny Bridge is Q

4, which indicates Good Status water both upstream and downstream of the WwTP discharge.

However, immediately downstream of the discharge location emergent macrophytes (e.g. Typha

latifolia, Phalaris arundinaceae) were evident, together with filamentus algae (Cladophora spp.),

which are indicative of nutrient enrichment. Elevated nutrient levels in the Unshin River is

considered to be a significant threat to the integrity and favourable conservation status of the

SAC and the Annex II species for which it is designated.

Possible Cumulative Impacts with other Plans and Projects in the Area

As part of Stage 1 Screening, in addition to the proposed waste water discharge, other relevant

projects and plans in the relevant region must also be considered. This step aims to identify at

this early stage any possible significant effects on the Natura 2000 Sites from the waste water

discharge in-combination or cumulative with other plans and projects. Existing plans and projects

which have been examined include:

Sligo County Development Plan 2011-2017;

Western River Basin Management Plan 2009-2015;

Owenmore Water Management Unit Action Plan;

Biodiversity Action Plan 2010 – 2015; and

Existing Riverstown Wastewater Treatment Plant.

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The above plans have been assessed in accordance with Article 6(3) of the Habitats Directive

and Part XAB of the Planning and Development Act, 2000, and are not envisaged to result in

significant effects on the integrity of the Natura 2000 network.

The upstream and downstream monitoring results indicates that the Unshin River is already

being impacted prior to the WwTP discharge. The likely source of this impact is diffuse pollution

from agricultural runoff. The discharge from Riverstown WwTP exceeds the maximum

assimilation capacity for Ammonia at 95%ile flows based on the design effluent standard for

Ammonia. However, using the mean concentration for 2015 it would suggest that there is

assimilative capacity in Unshin River for Ammonia.

Despite the above as noted previously downstream of the discharge location emergent

macrophytes (e.g. Typha latifolia, Phalaris arundinaceae) were evident, together with

filamentus algae (Cladophora spp.), which are indicative of nutrient enrichment. Elevated

nutrient levels in the Unshin River is considered to be a significant threat to the integrity and

favourable conservation status of the SAC and the Annex II species for which it is designated.

Therefore, based on this assessment and taking the pre-cautionary principle approach it must be

considered that the discharge is potentially causing significant cumulative effects on the water

dependent qualifying interests of the Unshin River SAC.

In accordance with the Waste Water Discharge (Authorisation) Regulations 2007 (S.I. No. 684 of

2007) the waste water discharged from Riverstown WwTP is potentially impacting on the water

quality of the Unshin River, and therefore, is potentially impacting on the conservation objectives

of the Unshin River SAC. Potentially significant adverse impacts on the water dependent

qualifying habitats (Water courses of plain to montane levels with the Ranunculion fluitantis and

Callitricho-Batrachion vegetation) and species (Salmon (Salmo salar) and Otter (Lutra lutra)) of

the Unshin River SAC are anticipated as a result of the waste water discharge from Riverstown

WwTP.

No significant adverse impacts on the qualifying interests of the remaining Natura 2000 Sites

identified within 15km of the discharge location is considered likely due to the distance between

the discharge location and the relevant SACs or SPAs.

Screening Assessment Table 5.0 provides a summary of the likely significant impact of the waste water discharge on the

conservation objectives of the identified Natura 2000 site in Tables 3.0 and 4.0.

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Table 5.0: Potential Significant Impacts on Natura 2000 sites from the Riverstown Waste Water Discharge

Site Name Direct Impacts Indirect/ Secondary

Resource Requirements (Drinking Water Abstraction Etc.)

Emissions (Disposal to Land, Water or Air)

Excavation Requirements

Transportation Requirements

Duration of Construction, Operation, Decommissioning

Templehouse and Cloonacleigha Loughs SAC

No impact on qualifying interest







Bricklieve Mountains & Keishcorran SAC








Lough Arrow SAC No impact on qualifying interest







Unshin River SAC Potential impact on the water quality of the Unshin River as a result of the WwTP discharge

Potential impact on the water quality of the Unshin River as a result of the WwTP discharge


Potential impact on the water quality of the Unshin River as a result of the WwTP discharge




Ballysadare Bay SAC No impact on qualifying interest







Lough Gill SAC No impact on qualifying interest







Union Wood SAC No impact on qualifying interest







Ballysadare Bay SPA No impact on qualifying interest







Lough Arrow SPA No impact on qualifying interest







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Likely Changes to the Natura 2000 Sites

The likely changes that will arise from the Riverstown WwTP discharge have been examined in

the context of a number of factors that could potentially affect the integrity of the identified Natura

2000 sites (see Table 6.0).

Table 6.0: Potential Significant Impacts on Natura 2000 sites from the Riverstown Waste

Water Discharge

Site Name Reduction of Habitat

Area

Disturbance to Key

Species

Habitat or Species

Fragmentation

Reduction in Species

Density

Changes in Key Indicators

of Conservation Value (Water Quality Etc.)

Climate Change

Templehouse and Cloonacleigha Loughs SAC

None None None None None None

Bricklieve Mountains & Keishcorran SAC


Lough Arrow SAC None None None None None None

Unshin River SAC Potential negative impact

Potential negative impact




None

Ballysadare Bay SAC


Lough Gill SAC None None None None None None

Union Wood SAC None None None None None None

Ballysadare Bay SPA


Lough Arrow SPA None None None None None None

Screening Conclusions

From the current screening assessment, taking account of supporting documentation, there is

the potential for on-going significant cumulative impacts affecting the Unshin River SAC arising

from the operation of the Riverstown WwTP. From the examination of the information available it

is considered that the discharge has the potential to result in significant impacts to the Natura

2000 network, specifically in relation to direct and cumulative impacts affecting the conservation

interests of the Unshin River SAC. On the basis of the findings of this Screening for Appropriate

Assessment, it is concluded that the current Riverstown WwTP discharge to the Unshin River:

(i) is not directly connected with or necessary to the management of a Natura

2000 site; and

(ii) may have significant effects on a Natura 2000 site, the Unshin River SAC.

Therefore, applying the Precautionary Principle and in accordance with Article 6(3) of the

Habitats Directive, the current WwTP discharge at Riverstown will be brought forward for a Stage

2 Appropriate Assessment.

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Stage 2: Appropriate Assessment

In this section, the Unshin River SAC, which has been determined as requiring AA, is described

and all the potential impacts resulting from the Riverstown WwTP discharge are discussed in

relation to the conservation objectives of this designated site.

Description of the Natura 2000 Site Affected The Unshin River runs from Lough Arrow north to Ballysadare Bay, Co. Sligo. This site consists

of a pristine unmanaged, undrained river and its marginal vegetation. Other rivers included within

the site are the Owenboy/Owenbeg and a number of smaller tributaries.

The site is a candidate SAC selected for alluvial wet woodlands, a priority habitat on Annex I of

the E.U. Habitats Directive, and for floating river vegetation, also listed on Annex I of the E.U.

Habitats Directive. The site is also selected for the following species listed on Annex II of the

same directive – Atlantic Salmon and Otter.

The Unshin River flows across a number of geological boundaries between sandstone, shales

and limestone. This results in unusual physio-chemical qualities which in turn are reflected in the

rich and varied plant and animal populations. The diversity of aquatic macrophytes is exceptional

and to an extent the unusual combinations and richness of species can be accounted for by the

good quality water being discharged from Lough Arrow upstream.

The Unshin and its tributaries form a very important system for Atlantic Salmon, a species that is

listed on Annex II of the E.U. Habitats Directive. The Owenboy/Owenbeg River is the principle

spawning and nursery tributary for the system’s salmon fishery. The Unshin and its tributaries is

the most important salmon producing river in Co. Sligo. The system also supports a good

population of trout.

Two notable bird species which occur along the river are Whooper Swan, which feeds in the wet

grasslands that flank the river, and Kingfisher. Both are listed on Annex I of the E.U. Birds

Directive.

The trophic status of the river increases downstream indicating that some enrichment is taking

place, however, the quality of the Unshin River and particularly its aquatic macrophyte

communities make it rare in both an Irish and European context.

Description of the Conservation Interests of the SAC

Annex I Habitats

The Unshin River SAC contains two Annex I habitats:

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

incanae, Salicion albae) [91E0]; a priority habitat; and


Batrachion vegetation [3260].

Of these habitats, the Riverstown WwTP discharge is assessed as having the potential to impact

on floating river vegetation (Water courses of plain to montane levels with the Ranunculion

fluitantis and Callitricho-Batrachion vegetation) only, as this habitat is dependent on water

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quality. Water quality does not threaten alluvial forests to the same degree, with little/no potential

for adverse effects, and no changes to the conservation status of this habitat.


Batrachion vegetation (3260) (floating river vegetation) is characterised by the abundance of

water-crowfoots Ranunculus spp. Floating mats of these white-flowered species are

characteristic of river channels in early to mid-summer. They may modify water flow, promote

fine sediment deposition, and provide shelter and food for fish and invertebrate animals.

The habitat type 'Water courses of plain to montane levels with the Ranunculion fluitantis and

Callitricho-Batrachion vegetation' is present along the stretch of the Unshin River into which the

Riverstown WwTP discharges.

Annex II Species

The Unshin River SAC is very important for the presence of a number of scarce and specialised

Annex II animal species, with particularly important population of Atlantic Salmon (Salmo salar).

Atlantic Salmon (1106)


Owenboy/Owenbeg river is the principle spawning and nursery tributary for the system’s salmon

fishery. The system also supports a good population of trout.

Suitable physical habitat for salmon spawning and early life stages of salmon occurs in the

Unshin River both upstream and downstream of the WwTP outfall with the occurrence of glides,

riffled and pool habitats present.

The conservation status of salmon in the Unshin River is dependent on good water quality

status; as this species requires clean water (Q4) for spawning and early life stages. This species

is evaluated as being of overall 'Bad' conservation status nationally (NPWS 2013b).

Otter (1355)

Otter is widespread in the Unshin River SAC. Otters have two basic requirements: aquatic prey

and safe refuges where they can rest. This species is dependent on fish stocks which are

ultimately dependent on water quality. Otter is likely to occur in the Unshin River at Riverstown.

One otter holt was recorded during the current survey.

The overall assessment of the conservation status of otter is 'Favourable' (NPWS, 2013b).

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Conservation Objectives of the Unshin River SAC

Article 6 of the Habitats Directive states that:

Any plan or project not directly connected with or necessary to the management of the

site but likely to have a significant effect thereon, either individually or in combination

with other plans or projects, shall be subject to appropriate assessment of its

implications of the site in view of the site’s conservation objectives.

The importance of a site designated under the Habitats Directive is defined by its qualifying

features or interests. Qualifying interests for any Natura 2000 site are listed on a pro forma,

called the Natura 2000 standard data form, which forms the basis of the rationale behind

designation, and informs the Conservation Management Plan for targeted management and

monitoring of key species and habitats.

The conservations objectives for the Unshin River SAC are set out below:

1. To maintain or restore the favourable conservation condition of the Annex I habitats

and/or Annex II species for which the SAC has been selected:


Otter (Lutra lutra) [1355];

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

Callitricho-Batrachion vegetation [3260]; and

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


Impact Prediction

Impacts on Water Quality

The aquatic conservation interests of the Unshin River SAC are directly dependant on the

aquatic environment and as the Riverstown WwTP discharges to the Unshin River within the

SAC designation, there is a connection between this facility and the ecological receptors in the

Unshin River.

Elevated nutrient levels in the Unshin River, specifically Ammonia, Nitrates, Orthophosphates,

and also Suspended Solids are considered to be the most significant threats to the integrity and

favourable conservation status of the SAC and the Annex II species for which it is designated.

The 2012 EPA Biological Water Quality data shows that the current biological water quality both

upstream (immediately upstream of the discharge location at Station Riverstown Bridge) and

downstream (approximately 5.2km) at Station Lisconny Bridge) is Q 4, which indicates Good

Status water both upstream and downstream of the WwTP discharge.

The 2012/13 upstream and downstream monitoring results demonstrate that the Unshin River

water quality is in compliance with Schedule 5 of the Surface Water Regulations and does not

appear to be impacted by the WwTP discharge.

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Assuming notional clean water in the Unshin River, the receiving water does not have adequate

waste assimilative capacity based on the design standard for Ammonia.

However, the Unshin River has available assimilative capacity to accommodate the WwTP

discharge in terms of the current mean Ammonia concentration (based on 10 samples in 2015)

using both the actually background concentration and the EPA notionally clean river

concentration.

It appears that the operation of the Riverstown WwTP and associated discharge to the Unshin

River is not noticeably affecting biological water quality. Likewise, the impact of the discharge on

chemical water quality is not considered to be significant.

Cumulative impacts in the catchment possibly pose the greatest risk to the conservation

objectives. The potential threat(s) of the Riverstown WwTP on water quality (long term or single

event) is greatly increased when taken in combination with other water quality concerns in the

catchment. For example the Collooney WwTP which discharges to the Unshin River also affects

water quality. Other impacts which are likely to act cumulatively and impact on the SAC result

from the following:

Chemical fertiliser application to agricultural lands (the main fertilisers in use supply

nitrogen, phosphorus, potassium and sulphur);

Agricultural practices such as ploughing leads to greater mineralisation and nitrification,

and in the case of old grassland, it can result in an increase in the release of nitrogen

over a number of years (OECD, 1986);

Artificial drainage increases nitrate leaching and reduce the morphological qualities of

watercourses, thereby reducing the quality of habitat for flora and fauna;

Endocrine disruptors in domestic sewage, including the main active component in the

oral contraceptive pill, can interfere with the endocrine system of plants and animals

which controls a wide range of processes including metabolism, growth and

reproduction. Effects include a high degree of intersexuality downstream of sewage

works (Routledge et al. 1998);

Forestry may alter water quality indirectly through increased evaporation losses and

hence an increase in solute concentrations;

On-site wastewater treatment systems, poorly performing septic tank units and other

small effluent systems can be significant sources of nutrients to rivers;

Water abstraction from rivers can cause low flows, which can be directly damaging due

to reducing flows and assimilation capacity;

Point pressures including Section 4 licenced facilities and IPPC licenced facilities;

Quarries - there are 3 quarries in the Owenmore WMU.

Impacts on Annex I Habitats


Batrachion vegetation [3260]

Water quality (particularly phosphorus and nitrates) strongly influences the species composition,

extent and condition of riverine plant communities. The key parameters include alkalinity, pH,

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nitrate, phosphate, potassium and suspended solids. Eutrophication is regarded as the major

water quality issue currently affecting plant communities in British rivers (Environment Agency

2000). The process of eutrophication and its impact on macrophyte communities varies,

depending upon river type and catchment. The effects of eutrophication on aquatic macrophytes

are documented (Haslam 1978; Spink et al. 1993; Mainstone et al. 2000) as usually causing a

shift in community composition and increased biomass. Increasing nutrient supply will lead to an

overall reduction in the number of species, with a loss of Ranunculus spp. and an increase in

pollution-tolerant species such as Potamogeton pectinatus, Myriophyllum spicatum, Sparganium

emersum, Schoenoplectus lacustris and filamentous algae. More extreme nutrient increases lead

to an overall impoverishment of the plant community, with algae dominating.

It is considered that the ongoing operation of the Riverstown WwTP plant is contributing to

background quality pressures in the Unshin River. The Unshin River is particularly vulnerable to

water pollution, that is derived from domestic sources and from agricultural activities posing the

greatest threat.

According to NPWS (2008), discharges, fertilisation and water pollution are identified as the main

pressures affecting floating river vegetation habitat. This has implications for the existing WwTP

at Riverstown, which is contributing to cumulative impacts on background water quality in the

Unshin River. It is considered however that the ongoing operation of the Riverstown plant would

have imperceptible localised impacts in this habitat.

Impacts on Annex II Species

Atlantic Salmon (1106)

Poor water quality will affect the conservation status of salmon in the Unshin River, as this

species requires clean water (Q4) for spawning and early life stages. The Riverstown WwTP is

considered to be contributing to water quality problems in the Unshin River, but the cumulative

effect of the discharge on water quality is considered insignificant. In this light, the Riverstown

WwTP is affecting the potential of the Unshin River as a salmon producing watercourse at a

limited localised level at most. Overall, the conservation status of salmon in the Unshin River

SAC is not thought to be affected by the Riverstown plant discharge as this species has a wide

range in the catchment and impacts from the plant would be localised only.


Owenboy/Owenbeg River is the principle spawning and nursery tributary for the system’s salmon

fishery.

Suitable physical habitat for salmon spawning and early life stages of salmon occurs in the

Unshin River downstream of the WwTP outfall with the occurrence of glides, riffled and pool

habitats present.

The conservation status of salmon in the Unshin River is dependent on good water quality

status; as this species requires clean water (Q4) for spawning and early life stages. This species

is evaluated as being of overall 'Bad' conservation status nationally (NPWS 2013b).

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Otter (1355)

Reduced water quality and ecological status downstream of the discharge of the Riverstown

WwTP could be potentially having indirect effects on otters; as a result of reduced food supply

i.e. reduced macroinvertebrate and fisheries production. The otter is dependent on fish stocks,

which are ultimately dependent on water quality. However, there is no indication that the ongoing

operation of this plant is having an adverse effect on otters within the Unshin River SAC as a

whole.

Mitigation Measures

The current population equivalent (2015) served by the WwTP is approximately 362 p.e., and the

design of the plant is 600 p.e.

Assuming notionally clean water in the Unshin River the receiving water does not have adequate

waste assimilative capacity for the WWTP design standard for Ammonia. However based on the

current situation (mean 2015 concentration), it would suggest that the Unshin River has available

assimilative capacity to accommodate the WwTP discharge in terms of Ammonia using both the

actually background concentrations and the EPA notionally clean river concentration. However,

immediately downstream of the discharge location emergent macrophytes (e.g. Typha latifolia,

Phalaris arundinaceae) were evident during a walkover survey, together with filamentus algae

(Cladophora spp.), which are indicative of nutrient enrichment.

However, based on the impact assessment above it is considered that current operation of the

Riverstown plant is having imperceptible localised impacts on the SACs qualifying habitats and

that the conservation status of qualifying species in the Unshin River SAC are not thought to be

affected by the Riverstown plant discharge.

For the above situation to continue it is recommended that the following mitigation measures are

implemented:

Implementation of an appropriate performance management system for the plant in

accordance with the Owenmore Water Management Unit Action Plan; and

Continuation of monitoring of the discharge, both upstream and downstream of the

plant. Annual biological water quality monitoring should also be undertaken upstream

and downstream of the WwTP outfall. Any biological monitoring should be carried out

during the summer / autumn periods.

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Stage 2 Appropriate Assessment Conclusion Statement The current Appropriate Assessment has been prepared following the EPA (2009) ‘Note on

Appropriate Assessments for the purposes of the Waste Water Discharge (Authorisation)

Regulations, 2007 (S.I. No. 684 of 2007)’. The Department of the Environment, Heritage and

Local Government guidance ‘Appropriate Assessment of Plans and Projects in Ireland. Guidance

for Planning Authorities’ (DoEHLG, 2009a) has also been taken into account. Therefore, the

current assessment for the Waste Water Certificate of Authorisation investigates the potential

adverse effects on the aquatic qualifying interests of the Natura 2000 network arising from the

plant discharge, in combination with other plans / projects affecting the aquatic environment. The

assessment considers whether the discharge, alone or in combination with other projects or

plans, will have adverse effects on the integrity of a Natura 2000 site, and includes any mitigation

measures necessary to avoid, reduce or offset negative effects.

When the above mitigation measures are implemented in full it is envisaged that there will be no

significant adverse effects on the integrity of the Unshin River SAC in view of the site’s

conservation objectives and that the conservation status of the Annex I habitats and Annex II

species will not be compromised by the Riverstown WwTP discharge either directly, indirectly or

cumulatively.

It is therefore concluded that the Riverstown WwTP discharge, alone or in-combination with other

plans and / or projects will not give rise to significant effects on the integrity of the Unshin River

SAC, as long as the mitigation measures as listed above are implemented in full. Stage 2

concludes the Appropriate Assessment process of the Riverstown Waste Water Certificate of

Authorisation.

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References

DoEHLG (2008). Circular L8/08 Water Services Investment and Rural Water Programmes –

Protection of Natural Heritage and National Monuments. Department of the Environment,

Heritage and Local Government.

DoEHLG (2009). ‘Appropriate Assessment of Plans and Projects in Ireland. Guidance for

Planning Authorities’. Department of the Environment, Heritage and Local Government.

Environment Agency (2000). Aquatic Eutrophication in England & Wales: A Management

Strategy. Environment Agency, Bristol.

European Commission (2000a). Communication from the Commission on the Precautionary

Principle., Office for Official Publications of the European Communities, Luxembourg.

European Commission (2000b). Managing Natura 2000 Sites: the provisions of Article 6 of the

‘Habitats’ Directive 92/43/EEC, Office for Official Publications of the European Communities,

Luxembourg.

European Commission (2001). Assessment of plans and projects significantly affecting Natura

2000 sites: Methodological guidance on the provisions of Articles 6(3) and (4) of the Habitats

Directive 92/43/EEC. Office for Official Publications of the European Communities, Brussels.

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Justice. Office for Official Publications of the European Communities, Luxembourg.

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overriding public interest, compensatory measures, overall coherence, opinion of the

commission.

European Commission (2013). Interpretation Manual of European Union Habitats. Version EUR

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Regulations, 2007 (S.I. No. 684 of 2007) Environmental Protection Agency, Co. Wexford.

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Haslam SM (1978). River Plants. Cambridge University Press, Cambridge.

Mainstone CP, Parr W & Day M. (2000). Phosphorus and River Ecology – tackling sewage

inputs. English Nature/Environment Agency, Peterborough.

NPWS (2008). The Status of EU Protected Habitats and Species in Ireland. National Parks and

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Assessments Volume 3, Version 1.0. Unpublished Report, National Parks & Wildlife Services.

Department of Arts, Heritage and the Gaeltacht, Dublin, Ireland.

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Department of Arts, Heritage and the Gaeltacht, Dublin, Ireland.

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Routledge, E.J., D. Sheahan, C. Desbrow, G. Brighty, M. Waldock, and J.P. Sumpter (1998).

Identification of estrogenic chemicals in sewage treatment effluent, 2. In vivo responses in torut

and roach, Environment, Science and Technology, 32: 1559-65.

WRBD (2010) Western River Basin Management Plan – Owenmore Upper Water Management

Unit: http://www.wfdireland.ie/docs/1_River%20Basin%20Management%20Plans%202009%20-

%202015/WRBD%20RBMP%202010/Water%20Management%20Unit%20Action%20Plans/Owe

nmore%20WMU_190310.pdf

Spink AJ, Murphy KJ, Smith SM & Westlake DF (1993). Effects of eutrophication on Ranunculus

and Potamogeton. Journal of Aquatic Plant Management 31, 113–117.

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http://www.wfdireland.ie/docs/1_River%20Basin%20Management%20Plans%202009%20-%202015/WRBD%20RBMP%202010/Water%20Management%20Unit%20Action%20Plans/Owenmore%20WMU_190310.pdf



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