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Natura Impact Statement Shannon Airport Embankments Refurbishment, Shannon, Co. Clare

Shannon Airport Embankments Refurbishment, …...negative impact on the features of interest of the Natura 2000 site i.e. habitats and species. This assessment identifies the environmental

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Page 1: Shannon Airport Embankments Refurbishment, …...negative impact on the features of interest of the Natura 2000 site i.e. habitats and species. This assessment identifies the environmental

Natura Impact Statement

Shannon Airport Embankments Refurbishment,

Shannon, Co. Clare

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19986-6002-B Natura Impact Statement December 2019

i

ISSUE FORM

Project number 19986

Document number 6002

Document revision B (18.12.2019)

Document title Natura Impact Statement: Shannon Airport Embankments

Refurbishment, Shannon, Co. Clare

Document status Final

Document prepared by CH, HD

Document checked by GH

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Table of contents

1 SUMMARY OF FINDINGS ............................................................................................ 7

2 INTRODUCTION ......................................................................................................... 8

3 METHODOLOGY ......................................................................................................... 8

3.1 Appropriate Assessment Guidance .................................................................................... 8

3.2 Consultation ..................................................................................................................... 9

3.3 Desk Study ........................................................................................................................ 9

3.4 Field Surveys ..................................................................................................................... 9

3.4.1 Site Walkover/Habitats ......................................................................................................................... 9

3.4.2 Flora .................................................................................................................................................... 10

3.4.3 Otter .................................................................................................................................................... 10

3.5 Wave Modelling .............................................................................................................. 10

3.6 Assessment of Potentially Significant Effects ................................................................... 10

3.7 Brief Overview of Screening for Appropriate Assessment ................................................. 11

3.8 Conclusions of the Screening for Appropriate Assessment ............................................... 11

3.9 Reasons for Assessment .................................................................................................. 11

4 DESCRIPTION OF THE PROJECT ................................................................................. 12

4.1 Brief Project Description ................................................................................................. 12

4.2 Purpose of the Project..................................................................................................... 12

4.3 Site Location and Context ................................................................................................ 14

4.4 Characteristics of the Project ........................................................................................... 16

5 DESCRIPTION OF THE RECEIVING ENVIRONMENT ..................................................... 19

5.1 Geology/land Use ........................................................................................................... 19

5.2 Hydrogeology ................................................................................................................. 20

5.3 Intertidal Processes ......................................................................................................... 20

5.4 Surface Water ................................................................................................................. 20

5.5 Human Population and Land Use ..................................................................................... 22

5.6 Habitats and Flora ........................................................................................................... 22

5.7 Fauna ............................................................................................................................. 28

5.7.1 Otter .................................................................................................................................................... 28

5.7.2 Avifauna .............................................................................................................................................. 28

5.7.3 Fish ...................................................................................................................................................... 29

6 IDENTIFICATION OF OTHER PROJECTS, PLANS AND ACTIVITIES ................................. 30

6.1 Wastewater Treatment Plant .......................................................................................... 30

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6.2 Licensed Sites ................................................................................................................. 31

6.3 Plans .............................................................................................................................. 31

6.4 Planning Applications ...................................................................................................... 32

6.5 Ongoing Activities ........................................................................................................... 35

6.6 Shannon Airport ............................................................................................................. 35

6.6.1 Bird Strike ............................................................................................................................................ 35

6.6.2 Airport Activities ................................................................................................................................. 36

7 IDENTIFICATION OF NATURA 2000 SITES .................................................................. 37

7.1 Lower River Shannon cSAC (002165) ................................................................................ 37

7.1.1 Description of the Natura 2000 Site .................................................................................................... 37

7.1.2 Identification of Potential for Significant Impacts to Qualifying Features .......................................... 40

7.1.3 Qualifying Features Selected for Further Assessment ........................................................................ 48

7.2 River Shannon and River Fergus Estuaries SPA (004077) ................................................... 59

7.2.1 Description of the Natura 2000 Site .................................................................................................... 59

7.2.2 Identification of Potential for Significant Impacts to Qualifying Features .......................................... 62

7.2.3 Qualifying Features Selected for Further Assessment ........................................................................ 68

8 ASSESSMENT OF POTENTIALLY SIGNIFICANT EFFECTS ............................................... 74

8.1 Water Quality ................................................................................................................. 74

8.1.1 Construction Phase ............................................................................................................................. 74

8.1.2 Operational Phase ............................................................................................................................... 75

8.2 Habitat loss/Alteration.................................................................................................... 75

8.2.1 Lower River Shannon cSAC.................................................................................................................. 75

8.2.2 River Shannon and River Fergus Estuaries SPA (004077) .................................................................... 79

8.3 Disturbance and/or Displacement of Species ................................................................... 80

8.4 Habitat or Species Fragmentation .................................................................................... 80

8.5 Assessment of Significance of Potential Impacts .............................................................. 81

8.5.1 Habitat Loss and Alteration ................................................................................................................. 81

8.5.2 Habitat or Species Fragmentation....................................................................................................... 82

8.5.3 Disturbance and/or Displacement of Species ..................................................................................... 82

8.5.4 Water Quality ...................................................................................................................................... 83

8.6 Assessment of Effect on Conservation Objectives ............................................................ 83

8.6.1 Lower River Shannon cSAC.................................................................................................................. 84

8.6.2 River Shannon and River Fergus Estuaries SPA ................................................................................... 89

8.7 Assessment of Potentially Significant Cumulative Effects ............................................... 106

9 MITIGATION .......................................................................................................... 107

9.1.1 Method statements .......................................................................................................................... 108

9.1.2 Protection of Habitats ....................................................................................................................... 108

9.1.3 Project ecologist ................................................................................................................................ 109

9.1.4 Temporary Construction Compound(s) ............................................................................................ 109

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9.1.5 Excavation and Embankment Works ................................................................................................ 110

9.1.6 Storage and Stockpiles of Excavated Material .................................................................................. 110

9.1.7 Timing of works ................................................................................................................................. 111

9.1.8 Hydrocarbon Control......................................................................................................................... 111

9.1.9 Storage .............................................................................................................................................. 111

9.1.10 Waste management ..................................................................................................................... 112

9.1.11 Otters ............................................................................................................................................ 112

9.1.12 Invasive Species Control ............................................................................................................... 112

9.2 Residual Impacts ........................................................................................................... 113

9.3 Conclusion .................................................................................................................... 113

10 REFERENCES ....................................................................................................... 114

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Table of tables

Table 1 Natura 2000 sites within 15km radius of the proposal site ..................................................... 11

Table 2 Habitats identified within the study area ................................................................................ 25

Table 3 Waterbird species recorded during surveys at Sub-sites 0H510 and 0H512 at low and high

tides across all behaviours and habitats (2010/2011 Waterbird Survey Programme) ......................... 29

Table 4 List of planning permissions granted by Clare County Council in surrounding townlands for

the period 2014-2019 ........................................................................................................................... 32

Table 5 Impacts and activities with high effect on the Lower River Shannon cSAC (Adapted from the

Natura 2000 Standard Data Form) ........................................................................................................ 35

Table 6 Key Points extrapolated from DAA Sustainability Report 2011 on Shannon Airport .............. 36

Table 7 Identification of potential for significant impacts to qualifying features of the Lower River

Shannon cSAC ....................................................................................................................................... 41

Table 8. Attributes and targets for ‘Estuaries’ within the Lower Shannon SAC (NPWS, 2012a) .......... 48

Table 9 Attributes and targets for ‘Mudflats and sand flats not covered by sea water at low tide’

within the Lower River Shannon cSAC (NPWS, 2012a) ......................................................................... 50

Table 10 ‘Coastal Lagoons’ within the Lower River Shannon cSAC (NPWS, 2012a) ............................. 52

Table 11 Attributes and targets for ‘Coastal lagoons’ within the Lower River Shannon cSAC (NPWS,

2012a) ................................................................................................................................................... 53

Table 12 Attributes and targets for ‘Atlantic salt meadows’ within the Lower River Shannon cSAC

(NPWS, 2012a) ...................................................................................................................................... 54

Table 13 Attributes and targets for ‘Vegetation of flowing waters’ within the Lower River Shannon

cSAC (NPWS, 2012a) ............................................................................................................................. 56

Table 14 Attributes and targets of otter within the Lower River Shannon cSAC (NPWS, 2012a) ........ 58

Table 15 Ecological Characteristics, requirements and specialities of non-breeding waterbird SCI

species for River Shannon and River Fergus Estuaries SPA .................................................................. 61

Table 16 Identification of potential for significant impacts to qualifying features of the River Shannon

& Fergus River Estuaries SPA ................................................................................................................ 62

Table 17 Attributes and targets of cormorant in the River Shannon and River Fergus estuaries SPA

(NPWS, 2012b) ...................................................................................................................................... 68

Table 18 Attributes and targets for relevant SCIs in the River Shannon and River Fergus estuaries SPA

(NPWS, 2012b) ...................................................................................................................................... 72

Table 19 Attributes and targets for wetlands in the River Shannon and River Fergus Estuaries SPA

(NPWS, 2012b) ...................................................................................................................................... 72

Table 20 Assessment of potential impacts of the project on ‘wetlands’. ............................................ 79

Table 21 Assessment of potential impacts of the project on estuaries................................................ 84

Table 22 Assessment of potential impacts of the project on mudflats ................................................ 84

Table 23 Assessment of potential impacts of the project on coastal lagoons ..................................... 85

Table 24 Assessment of potential impacts of the project on Atlantic salt meadows........................... 86

Table 25 Assessment of potential impacts of the project on ‘Vegetation of flowing waters’ ............. 87

Table 26 Assessment of conservation objectives and potential impact for Cormorant [A017] ........... 89

Table 27 Assessment of conservation objectives and potential impacts for Whooper Swan [A038] .. 92

Table 28 Assessment of conservation objectives and potential impacts for Light-bellied Brent Geese

[A046] .................................................................................................................................................... 92

Table 29 Assessment of conservation objectives and potential impacts for Shelduck [A048] ............ 93

Table 30 Assessment of conservation objectives and potential impacts for Wigeon [A050] .............. 94

Table 31 Assessment of conservation objectives and potential impacts for Teal [A052] .................... 94

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Table 32 Assessment of conservation objectives and potential impacts for Pintail [A054] ................. 95

Table 33 Assessment of conservation objectives and potential impacts for Shoveler [A056] ............. 96

Table 34 Assessment of conservation objectives and potential impacts for Scaup [A062] ................. 96

Table 35 Assessment of conservation objectives and potential impacts for Ringed Plover [A137] ..... 97

Table 36 Assessment of conservation objectives and potential impacts for Golden Plover [A140] .... 97

Table 37 Assessment of conservation objectives and potential impacts for Grey Plover [A141] ........ 98

Table 38 Assessment of conservation objectives and potential impacts for Lapwing [A142] ............. 99

Table 39 Assessment of conservation objectives and potential impacts for Knot [A143] ................. 100

Table 40 Assessment of conservation objectives and potential impacts for Dunlin [A149] .............. 100

Table 41 Assessment of conservation objectives and potential impacts for Black-tailed Godwit [A156]

............................................................................................................................................................ 101

Table 42 Assessment of conservation objectives and potential impacts for Bar-tailed Godwit [A157]

............................................................................................................................................................ 102

Table 43 Assessment of conservation objectives and potential impacts for Curlew [A160].............. 102

Table 44 Assessment of conservation objectives and potential impacts for Redshank [A162] ......... 103

Table 45 Assessment of conservation objectives and potential impacts Greenshank [A164] ........... 104

Table 46 Assessment of conservation objectives and potential impacts for Black-headed Gull [A179]

............................................................................................................................................................ 104

Table 47 Assessment of conservation objectives and potential impacts to wetlands [A999] ........... 105

Table of figures Figure 1 Indicative proposed embankments work extent, Shannon Airport, Co. Clare. ...................... 14

Figure 2 Habitats at the western embankment .................................................................................... 23

Figure 3 Habitats at the eastern embankment ..................................................................................... 24

Figure 4 Count sub-site boundaries for the 2010/11 Waterbird Survey Programme (Source NPWS,

2012b) ................................................................................................................................................... 28

Figure 5 Distribution of estuaries within the Lower River Shannon cSAC (NPWS, 2012a) ................... 49

Figure 6 Distribution of mudflats and sandflats within the Lower River Shannon cSAC (NPWS, 2012a)

.............................................................................................................................................................. 50

Figure 7 Distribution of marine community types within the inner Shannon Estuary (NPWS, 2012a) 51

Figure 8 Shannon Airport Lagoon (NPWS, 2012a) ................................................................................ 52

Figure 9 Distribution of saltmarsh habitats within the Lower River Shannon cSAC (NPWS, 2012a) .... 55

Figure 10 Distribution of floating river vegetation within the Lower River Shannon cSAC (NPWS,

2012a) ................................................................................................................................................... 57

Figure 11 Extent of mapped ‘commuting buffer’ for otter within the Lower River Shannon cSAC

(NPWS, 2012a) ...................................................................................................................................... 59

Appendices Appendix 1 Screening for Appropriate Assessment

Appendix 2 Shannon Embankment Modelling

Appendix 3 Environmental Commitments

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1 SUMMARY OF FINDINGS

Project Title Shannon Airport Embankments Refurbishment

Project Proponent Shannon Airport Authority

Project Location Shannon Airport Embankments, Shannon, Co. Clare

Natura Impact

Statement

In cases where an Appropriate Assessment is required a Natura Impact

Statement (NIS) is prepared. This is a report based on a scientific examination of

evidence and data, carried out by competent persons with the aim of identifying

and classifying any implications of a proposal, either individually, or in

combination with other plans or projects, on Natura 2000 sites in view of the

conservation objectives of the sites.

Summary of Mitigation Mitigation measures have been outlined primarily in relation to maintaining

existing water quality.

Conclusion

In conclusion, provided the recommended mitigation measures are

implemented in full it is not expected that the proposed Shannon Embankments

refurbishment will result in any significant adverse residual impacts on the

Natura 2000 sites considered in this NIS, namely:

• Lower River Shannon cSAC (002165)

• River Shannon and River Fergus Estuaries SPA (004077)

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2 INTRODUCTION

Appropriate Assessment is the consideration of the impact on the integrity of the Natura 2000 site of

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

ecological structure and function, and conservation objectives. Additionally, mitigation of these

impacts can be considered. A Screening for Appropriate Assessment was completed and determined

the need for full Appropriate Assessment (Appendix 1).

In cases where an Appropriate Assessment is required a Natura Impact Statement (NIS) shall be

prepared and shall include a report of a scientific examination of evidence and data, carried out by

competent persons to identify and classify any implications for Natura 2000 sites in view of the

conservation objectives of the site. The aim of the assessment is to provide a sufficient level of

information to the competent authority on which to base their appropriate assessment of the plan

or project. The plan or project should be fully described, particularly in relation to the aspects that

could interact with the surrounding environment. The proposed Shannon Embankments

refurbishment works are described in Section 4 below.

The focus of the assessment is to determine whether the proposed refurbishment works at the

existing Shannon Embankments at Shannon Airport, Shannon, County Clare, will have a significant

negative impact on the features of interest of the Natura 2000 site i.e. habitats and species. This

assessment identifies the environmental aspects of the project that will interact with the ecological

requirements or sensitivities of the habitats and species, and in this case these relate mainly to loss

of loss/alteration of estuarine habitat and potential impacts to water quality during the construction

phase of the project, as well as potential cumulative/in-combination effects throughout the

undertaking of the project.

The ‘test’ of the assessment is whether the plan or project will have an adverse effect on the

integrity of the Natura 2000 site. Where potentially significant effects are identified proven,

mitigation measures will be recommended. This Natura Impact Statement has been completed by

staff ecologists with Malachy Walsh and Partners, Engineering and Environmental Consultants.

Concerns in relation to potential impacts on coastal processes at the east embankment have been

dealt with in a coastal processes modelling report.

3 METHODOLOGY

3.1 APPROPRIATE ASSESSMENT GUIDANCE

This Natura Impact Statement, Stage 2, has been undertaken in accordance with the European

Commission Methodological Guidance on the provision of Article 6(3) and 6(4) of the ‘Habitats’

Directive 92/43/EEC (EC, 2001) and the European Commission Guidance ‘Managing Natura 2000

sites’ (EC, 2000) and guidance prepared by the NPWS (DoEHLG, 2009).

The aim of the assessment is to provide a sufficient level of information to the competent authority

on which to base their appropriate assessment of the plan or project.

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3.2 CONSULTATION

Consultation was undertaken with the Development Applications Unit of the Department of Culture,

Heritage & The Gaeltacht.

3.3 DESK STUDY

In order to complete the Natura Impact Statement certain information on the existing environment

is required. A desk study was carried out to collate available information on the subject site’s natural

environment. This comprised a review of the following publications, data and datasets:

• OSI Aerial photography and 1:50000 mapping, and other mapping sources (online)

• National Parks and Wildlife Service (NPWS) (online) including:

o Conservation Objectives

o Site data

o Article 17 reports for habitats and species

• National Biodiversity Data Centre (NBDC) (online)

• BirdWatch Ireland

• Teagasc soil area maps (NBDC website)

• Geological Survey Ireland (GSI) area maps (online)

• Environmental Protection Agency (EPA)(online) including:

o EPA maps

o Licence reports

• Shannon River Basin District (ShIRBD) datasets (Water Framework Directive) (online)

• IFI WFD Fish Survey Map

• Clare County Development Plan 2017 – 20231

• Shannon Town and Environs Local Area Plan 2012 – 2018 (amendment 1)2

• Other information sources and reports footnoted or referenced in the course of the report.

Shape files downloaded from the websites of the NPWS and EPA were used to generate maps on a

Geographic Information System (GIS) platform. This mapping was used to illustrate information,

including SAC boundaries, and display important habitats and species of conservation interest in the

study area.

3.4 FIELD SURVEYS

3.4.1 Site Walkover/Habitats

An ecological field survey was conducted by staff ecologists with Malachy Walsh and Partners

Environmental Consultants on February 24th and April 2nd 2019. The aim of these surveys was to

characterise the site and environs and establish the ecological features and resources at the site,

particularly in relation to the conservation interests of the Lower River Shannon cSAC.

Aerial photography was used together with GPS to accurately enable field navigation. Notes were

made on all habitats encountered, including notes on dominant and indicative vegetation. A

qualitative assessment was made of plant species diversity, vegetation structure, topography and

1 http://www.clarecoco.ie/services/planning/publications/clare-county-development-plan-2017-2023-volume-3a-ennis-municipal-district-

written-statement-and-maps-24146.pdf [accessed 10/07/2019] 2 http://www.clarecoco.ie/services/planning/local-area-plans/shannon-town-and-environs-local-area-plan%202012-2018/ [accessed

10/07/2019]

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drainage, disturbance and management. Habitats were categorised according to the Heritage

Council’s A Guide to Habitats in Ireland (Fossitt, 2000). The presence of invasive plant species was

noted.

The survey included an aquatic habitat assessment of the surface water features adjacent to the site.

Physical characteristics were noted and evaluated in cognisance of the leaflet ‘The Evaluation of

habitat for Salmon and Trout’ (DANI, 1995) and the publication ‘Ecology of the Atlantic Salmon’

(Hendry and Cragg-Hine, 2003) to assess habitat suitability for salmonids. An evaluation of lamprey

nursery habitat was also carried out based on the habitat requirements of juvenile lampreys as

outlined in Maitland (2003).

3.4.2 Flora

A dedicated botanical survey was undertaken on August 8th by Michelle O’Neill of Cluain Ecology.

3.4.3 Otter

Searches for signs of otter including tracks, spraints, slides, hauling-out sites and holts were carried

out. The otter survey was conducted according to methodology described in Animal Tracks and Signs

(Bang and Dahlstrom, 2001), and The Mammal Detective (Strachan, 1995).

3.5 WAVE MODELLING

In order to allay possible concerns regarding the potential impact such refurbishment works might

have on coastal processes in the vicinity of the works modelling of a number of wave, tide and

sediment transport conditions have been undertaken for the existing situation and following

refurbishment works. Modelling was undertaken of the combined wave and water level conditions

and the resulting sediment transport of the intertidal muds (silt sized material) for the existing case

and with the works in place.

The modelling examined the case of a neap tide, a spring tide and a surge tide with a joint wave

water level probability of 0.05% selected for maximum wave height at the embankment, obtained

from the OPW's Irish Coastal Wave and Water Level Study modelling results for the more exposed

area of the east embankment. A reflection wave assessment was carried out, based on equation

5.72 and Table 5.14 of the CIRIA guide , C683, the Rock Manual (CIRIA et al, 2007). The modelling

report is provided (See Appendix 2).

3.6 ASSESSMENT OF POTENTIALLY SIGNIFICANT EFFECTS

As set out in the NPWS guidance, the task of establishing whether a plan or project is likely to have

an effect on a Natura 2000 site(s) is based on a preliminary impact assessment using available

information and data, including that outlined above, and other available environmental information,

supplemented as necessary by local site information and ecological surveys. This is followed by a

determination of whether there is a risk that the effects identified could be significant. The

precautionary principle approach is required.

Once the potential impacts that may arise from the proposal are identified the significance of these

is assessed through the use of key indicators in the screening process:

• Habitat loss

• Habitat alteration

• Habitat or species fragmentation

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• Disturbance and/or displacement of species

• Water quality and resource.

3.7 BRIEF OVERVIEW OF SCREENING FOR APPROPRIATE ASSESSMENT

A screening for Appropriate Assessment was carried out for the proposal. The full screening for

Appropriate Assessment report is available in Appendix 1. The test for the screening for Appropriate

Assessment is to assess, in view of best scientific knowledge, if the proposal, individually or in

combination with other plans/projects is likely to have a significant affect on a Natura 2000 site. If

there are any significant, potentially significant, or uncertain effects, it will be necessary to proceed

to Appropriate Assessment and submit an NIS. Adopting the precautionary principle in identifying

potentially affected European sites, all SACs and SPAs within a 15km radius of the proposal site were

included. Designated SAC and SPA sites within 15km of the proposal including their proximity are

shown in Table 1 below.

Table 1 Natura 2000 sites within 15km radius of the proposal site

No. Designated Sites Site

Code

Proximity of subject site to nearest point of designated

site

1 Lower River Shannon cSAC 002165 Within and adjacent to the proposal site

2 River Shannon and River Fergus

Estuaries SPA

004077 Within and adjacent to the proposal site

3 Askeaton Fen Complex SAC 002279 5.5km to the south of the proposal site

4 Lough Gash Turlough SAC 000051 6.3km to the north of the proposal site

5 Curraghchase Woods SAC 000174 7.5km to the south-east of the proposal site

6 Ratty River Cave SAC 002316 11km to the north-east of the proposal site

7 Barrigone SAC 000432 11km to the south-west of the proposal site

8 Knockanira House SAC 002318 13km to the north-west of the proposal site

9 Newhall and Edenvale Complex

SAC

002091 13.3km to the north-west of the proposal site

10 Poulnagordon Cave (Quin) SAC 000064 13.3km to the north-east of the proposal site

11 Kilkishen House SAC 002319 14.9km to north-east of the proposal site

3.8 CONCLUSIONS OF THE SCREENING FOR APPROPRIATE ASSESSMENT

Potential impacts on nine of the eleven Natura 2000 sites which occur within the zone of potential

impact influence have been screened out due to a lack of credible or tangible source-pathway-

receptor links between these sites and the proposal site. The comprehensive reasoning for this

conclusion is available in the Screening for Appropriate Assessment appended to this report

(Appendix 1). Site synopses for the Natura sites considered in this NIS are appended to the

Screening report.

The screening assessment concluded that water quality, habitat loss and alteration, species

disturbance and/or displacement impacts, habitat and species fragmentation, and potential

cumulative/in-combinations effects could not be ruled out for the Lower River Shannon cSAC

(002165) and the River Shannon and River Fergus Estuaries SPA (004077) and therefore further

assessment is required for these Natura 2000 sites.

3.9 REASONS FOR ASSESSMENT

The focus of this NIS is to determine whether the proposed development will have a significant

negative impact on the qualifying features (i.e. features of interest of the Natura 2000 site or reason

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for designation) of the Lower River Shannon cSAC and the River Shannon and River Fergus Estuaries

SPA, as outlined in Table 1 above.

This NIS identifies the environmental aspects of the project which may lead to significant impacts,

and which may interact with the ecological requirements or sensitivities of the qualifying features of

the Natura 2000 sites listed in Section 3.7 above. These aspects are primarily related to water quality

and habitat loss/alteration associated with the dredging phase of the project. The test of the

assessment is whether the project will have ‘an adverse effect on the integrity of the site’. Where

potentially significant effects are identified, proven mitigation measures will be recommended.

4 DESCRIPTION OF THE PROJECT

4.1 BRIEF PROJECT DESCRIPTION

Shannon Airport was constructed in the late 1930’s and 1940’s. As significant areas of the site lie

below High Tide Level, a series of flood defence measures were included in the original design of the

airport. These measures, installed to protect the site from high tides, included the construction of

sea walls from the mainland to Dernish Island (now lying at the south-east tip of the Shannon Airport

Drainage Lagoon) and the provision of a number of drainage systems for the airport.

It is proposed to carry out refurbishment works to existing coastal defence structures, namely the

East Embankment and West Embankment at Shannon Airport (see Plate 1 and Plate 2 below). The

proposed works at the East embankment consist of the placement of rock armour on the front slope

of the embankment. The crest of this embankment will also be strengthened using either small rock

armour or a gravel filled geotextile. There will be a short (approx 100m) section of the east

embankment where the armouring of the front face will be undertaken using an alternative method

(armorflex or similar mattressing) within the existing profile in order not to disturb the salt marsh

habitat fronting this area. The proposed works to the West Embankment consist of the armouring of

the crest and back slope using either small rock armour or a gravel filled geo-synthetic cellular

confinement system. See planning drawings for details.

4.2 PURPOSE OF THE PROJECT

The purpose of the project is to refurbish the existing West and East Embankments following the

winter storms of 2013/2014. The embankments are essential to the protection of the airport from

flooding from the River Shannon Estuary. The existing embankments and drainage system are

essential to the airport for the following reasons:

• To facilitate the proper drainage of the aerodrome to provide a safe aviation environment;

• To ensure that critical infrastructure and equipment including navigational aids and

pavements are not undermined through flooding;

• To ensure that water levels in the Shannon Airport Drainage Lagoon are maintained at a

level that minimises swan presence and usage of the lagoon;

• To ensure that bird activity within the airfield is minimised and that there are no other

unavoidable areas of standing water at the airport that could give rise to bird hazard (e.g.

flooding of the airfield).

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Plate 1 View of eastern embankment

Plate 2 View of western embankment

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4.3 SITE LOCATION AND CONTEXT

The subject embankments are located at two locations along the shoreline to the south of Shannon

Airport in County Clare as shown in Figure 1 below.

The proposed development areas form part of the boundary with and lie directly adjacent to the

Shannon Estuary. The Shannon Estuary and some areas on the landward side of the West

Embankment are designated as a Special Area of Conservation (Lower River Shannon cSAC 002165)

and a Special Protection Area (River Shannon and River Fergus Estuaries SPA 004077).

Figure 1 Indicative proposed embankments work extent, Shannon Airport, Co. Clare.

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4.4 CHARACTERISTICS OF THE PROJECT

The proposal is described below and has been confirmed with the project engineer.

Size, scale, area, land-take

It is proposed to carry out refurbishment works on the East Embankment and

West Embankment at Shannon Airport.

The East Embankment is:

• Approximately 1.3km long;

• Has an average crest level of approximately +4.20mODM to

+5.20mODM (varies);

• An average crest width of approximately 1.5m to 5m (varies greatly);

• An average seaward toe level of approximately +0.40mODM to

+1.80mODM (varies);

• An average landward toe level of approximately +0.5mODM to

+2.00mODM (varies);

• The embankment has a plan area of approximately 23,985m2.

The proposed works are to the front face and crest of the east embankment.

The works to the front will extend for much of the length some 5m seawards of

the existing embankment toe. There are two areas where this will not occur:

firstly, along an approximately 150m section that has in the past been faced

with rock armour; and, secondly a length some 100m long immediately north

east of this rock armour.

The West Embankment is:

• Approximately 1.6km long;

• Has an average crest level of approximately +4.80mODM to

+5.50mODM (varies);

• An average crest width of approximately 1.5m to 3m (varies);

• An average seaward toe level of approximately -0.50mODM to

+1.60mODM (varies);

• An average landward toe level of approximately +2.00mODM to

+3.40mODM (varies);

• The embankment has a plan area of approximately 22,320m2.

The proposed works are to the crest and backslope of the west embankment.

There will be no works on the seaward side of this embankment.

There is spatial overlap between the proposed areas of work and both the

Lower River Shannon cSAC (002165) and River Shannon and River Fergus

Estuaries SPA (004077). There will be land-take within both the SAC and SPA as

a result of the proposal.

Details of physical changes that will take place during the various stages of implementing the proposal

East Embankment

In summary the works are to consist of the placement of rock armour on the

front slope of the east embankment and the strengthening of the crest of this

embankment using either small rock armour or a gravel filled geotextile. This

will result in an increase in the width of the east embankment (the footprint

will extend seawards by 5m from the existing toe - except where there is

existing rock armour in place and a length some 100m just north east of this

armour).

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The following works to the East Embankment are proposed:

• Material will be excavated to approximately -1.0mODM for foundation

pocket of proposed rock armour to the seaward face;

• The excavator will be located either on the crest of the existing

embankment or on the partly completed rock armour immediately

adjacent. Plant movement will be restricted to the embankment and

the footprint of the works.

• Gravel will be placed to blind the face of existing pitched stone on

seaward face of the section of embankment being worked on – this

gravel blinding will have a layer thickness of 100mm perpendicular to

the slope face;

• Geotextile will be placed on the gravel blinding layer;

• 2 layers of 1.3T rock armour will be placed on the geotextile;

• Turf and top soil layer will be removed from the section of

embankment being worked on (estimated length of sections to be

worked on at a time approx. 50m) to facilitate the formation of crest

protection;

• Geotextile will be placed on the prepared crest;

• Required rock armour/geosynthetic cellular confinement system will

be placed on the crest, over the geotextile;

• Gravel will be placed to blind face of armouring works on crest of

embankment – this gravel blinding will have a layer thickness of

100mm ;

• Turf and topsoil will be reinstated to complete the works.

• In the case of the 100m section north east of the existing armour it is

proposed to widen the embankment landwards by some 1m in this

area; to place a layer of proprietary protection (armorflex or similar)

within the existing front face; and to provide protection to the crest

and backface of the widened embankment. Prior to the placing of

protection (rock armour or proprietary armouring) turf and topsoil will

have been removed from the existing embankment, stored and

replaced on the newly armoured crest and backslope.

West Embankment

The works to the West Embankment are to consist of the armouring of the crest

and back slope using either small rock armour or a gravel filled geo-synthetic

cellular confinement system.

The following works to the West Embankment are proposed:

• There are no proposed works to the seaward slope of the

embankment;

• Turf and top soil layer will be removed to form crest and landward

slope protection;

• Landward slope protection will extend a minimum of 1m beyond the

embankment toe;

• Geotextile will be placed on the prepared crest and landward slope;

• Required rock armour/geo-synthetic cellular confinement system will

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be placed on the crest and landward slope, over the geotextile;

• Gravel will be placed to blind face of armouring works on crest of

embankment – this gravel blinding will have a layer thickness of

100mm;

• Turf and topsoil will be reinstated to complete the works.

In general, machinery required for the works will track along the access path

east of the west embankment. Plant and vehicle movement will be precluded

on the adjacent shoreline due to ground conditions.

Several (perhaps 3) ramps will be constructed along the access road of both

embankments. These ramps will be used primarily to bring materials to the top

of the embankments, and potentially for future maintenance works.

Description of resource requirements for the construction/operation and decommissioning of the proposal (water resources, construction material, human presence etc)

The equipment and resources required for the works will include:

• Rock armour, gravel (Imported material will be clean and will be

sourced from a licensed establishment)

• Geo-textile membrane

• Geo-synthetic cellular confinement system

• Excavator for lifting rock armour and geo-synthetic materials into place

• Trucks for transport of rock armour/geo-synthetic materials

• Total number of excavators could range from 1 to 3 on each

embankment. Personnel on each embankment 2 to 6 plus truck

drivers.

• Welfare facilities, potable water, power source, secure site compound

Description of timescale for the various activities that will take place as a result of implementation (including likely start and finish date)

• Duration of approximately 6-9 months between January 2020 and

December 2020.

• Works will be undertaken at each embankment in a staged manner (at

a number of locations (2 to 3) on each embankment at the same time).

This will be governed by access and storage space limitations.

Key Quantities

East Embankment:

• 1.3T Rock armour to front face: 22,000m3

• Geotextile: 24,000m2

• Gravel: 1,400m3

• Proprietary armour (armorflex or similar):1,000m3

• 75kg rock armour to crest: 1,900m3

Or:

• Geo-synthetic cellular confinement system: 6,500 m2

• Geo-synthetic cellular confinement system fill: 1,000m3

West Embankment

• 75kg Rock armour: 5,300m3

• Geotextile: 18,000m2

Or:

• Geo-synthetic cellular confinement system: 18,000m2

• Geo-synthetic cellular confinement system fill: 2,700m3

Description of wastes arising and other residues (including quantities) and their disposal

• Turf and top layer spoil generated by works will be inert and will be

stockpiled at locations adjacent to the works until reinstatement. All

turf and top-soil is to be reinstated on-site prior to completion of the

works at each section.

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• Fuels/oil/lubricants associated with plant and machinery

• Effluent from temporary on-site welfare facilities will be transported to

a suitably licensed facility for treatment

• No hazardous waste material will be generated.

Identification of wastes arising and other residues (including quantities) that may be of particular concern in the context of the Natura 2000 network

• Turf and top layer spoil generated by works will be inert and will be

reinstated on-site prior to completion of the works.

• Fuels/oil/lubricants associated with plant and machinery

• Fuels/oils etc will be stored within a bunded area in the enclosed

compound along with tools, materials etc. All plant is to be refuelled in

this compound and a drip tray fitted to any stationary plant working in

proximity to the watercourse.

Description of any additional services required to implement the project or plan, their location and means of construction

• A site compound will be required for the successful contractor to

undertake the works. This will be situated at either end of the

embankment.

• Temporary welfare facilities will be located within the site compound.

5 DESCRIPTION OF THE RECEIVING ENVIRONMENT

This section describes the existing environment within the proposed development site, as well as

other wider environmental factors that occur within, or influence the brackish components of the

Lower River Shannon cSAC. The site, overall, sits on the northern shore of the Shannon Estuary

which is the largest estuary in Ireland and one of the most important deep-water navigational

channels in the country3. The Shannon Estuary forms part of both the Lower River Shannon cSAC

(002165) and the River Shannon and River Fergus Estuaries SPA (004077).

5.1 GEOLOGY/LAND USE

The geology surrounding both the western and eastern embankments at Shannon Airport is

comprised of ‘Dark Muddy Limestone and Shale’ extending into ‘Massive Unbedded Lime

Mudstone’, with some pockets of ‘Old Red Sandstone, Shale and Mudstone’ to the northeast, inland,

and to the southeast along the southern bank of the River Shannon4.

Soil cover at Shannon Airport consists of made (man-made) land, while the area comprising the

lagoon and western embankment which occurs along the estuary margins consists of marine

deposits of estuarine sediments (silts/clays). Soil cover extending away from the area is comprised of

a mosaic of marine deposits, Limestone Till (Carboniferous) with some bedrock at the surface’ (EPA,

2019).

The surrounding land cover of Shannon Airport is classified as ‘Artificial surfaces (124) comprised of

industrial, commercial and transport units’, which extends into the Shannon Free zone ‘Artificial

Surfaces (121)’, and Shannon Town which is largely comprised of industrial units and housing estates

that make up the ‘urban fabric (112)’ of the area. The area extending north of Shannon Airport is

comprised of ‘Agricultural Areas (231)’ with small localised areas of ‘Forest and Semi-natural Areas

3 https://shannonestuarysifp.files.wordpress.com/2015/08/executive_summary_22112013.pdf [Accesssed 10/07/2019] 4 https://dcenr.maps.arcgis.com/apps/MapSeries/index.html?appid=a30af518e87a4c0ab2fbde2aaac3c228 [accessed 10/07/2019]

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(313/321)’, while the land directly contiguous to the Shannon Airport embankments is classified as

‘Coastal Wetlands (423)’5.

5.2 HYDROGEOLOGY

The proposed development overlies the Tulla-Newmarket on Fergus ground waterbody

(IE_SH_G_229) , which has a Ground Waterbody WFD Status 2010-2015 of ‘Good’. In terms of risk

status, this ground waterbody is currently under review.

The Summary of Initial Characterisation report for this GWB indicates that the water table is above

or close to the base of the sub-soils and that the streams crossing the aquifer are gaining. Due to the

shallow groundwater flow in this aquifer the groundwater and surface waters are closely linked.

There are several ecosystems in the GWB at least partially dependent on groundwater6.

5.3 INTERTIDAL PROCESSES

The existing tidal currents in the vicinity of the works are very low, given that the main tidal flows

are out in the deeper water and are pushed away from the embankment by the existing rock armour

breakwater to the west that extends some 800m towards the channel from the embankment. Such

an effect would be dominant on the flood tide. The headlands and in river islands to the east also

help deflect the strongest currents into the main channel on the ebb. These effects result in a wide

intertidal area fronting the east embankment - some 800m wide. Wave conditions at the east

embankment are locally generated and because of the relatively short fetch are relatively small, with

a significant wave height less than 0.8m and period of less than 3 seconds except in the more

extreme cases.

The intertidal area consists of silt sized material. Such material is deposited along the sides of

estuaries in areas of lower tidal currents. The material is a cohesive material so called because the

weak bonding between the clay/silt particles. This complicates their transport regime. While apart

the individual particles can stay in the water column for a very long time only being deposited out in

areas of quiescent water and are easily transported by low velocities. However, once bonded to

other particles they can require high currents to overcome the bonding and reabsorb them into the

water column. Mud flats would have a thin layer of very mobile individual particles or flocs of mud

overlying a much more cohesive layer that is much more resistant to erosion.

5.4 SURFACE WATER

There are two 2nd order watercourses within the vicinity of the Shannon Free Zone. These drain an

industrial/residential area to the east of the Airport both discharging to the Shannon Estuary7. These

watercourses are the Urlan Beg Stream which is mapped as running through the eastern limit of the

eastern embankment, and the Clonloghan Stream which flows into the estuary ca. 150m east of the

eastern embankment, at Drumgeely Creek. These streams are highly modified waterbodies as they

have been straightened and some reaches have been culverted.

There is an artificial waterbody that runs at the landward side of and parallel to the East

Embankment, however (see Plate 3). This channel is connected to the Shannon Estuary via a sluice

gate located near the western limit of the East Embankment (see Plate 4). It is considered that this

5 https://gis.epa.ie/EPAMaps/ [Corine 2018, accessed 10/07/2019] 6 http://spatial.dcenr.gov.ie/GSI_DOWNLOAD/Groundwater/Reports/GWB/TullaNewmarketOnFergusGWB.pdf [Accessed 29/08/2019] 7 http://maps.biodiversityireland.ie/#/Map [Accessed 10/07/2019]

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channel carries the Urlan Beg Stream to the sea. It was obvious during the site visit that this channel

had some water quality problems, as evident by an oil film on the surface near the sluice..

Plate 3 Modified channel which runs behind and parallel to the East Embankment and carries the

Urlan Beg Stream to the sea

Plate 4 Sluice gate at junction of modified channel (which runs parallel to East Embankment) and the

estuary

An artificial lagoon, known as the Shannon Airport Lagoon, is located behind the West Embankment.

This drainage lagoon is separated from the sea by artificial barriers comprising the embankment and

an access road. The lagoon was developed in the 1940’s when a seawall was constructed out into

the estuary to prevent Shannon Airport from flooding. The water level in the lagoon is managed via a

sluiced outlet through which water drains via a drainage channel located in the lagoons north-

western corner.

Compliance with the reporting requirements of the Water Framework Directive (Directive

2000/60/EC) obliges each member state to publish reports providing summary information about

individual water bodies relating to their status, risks and objectives. Within this reporting framework

the Urlan Beg and Clonloghan Streams are situated within the WFD Catchment ‘Shannon Estuary

North’, the WFD Sub-catchment ‘Ballygirreen_SC_010’ and the WFD River Sub-basin ‘Urlan

Beg_010’8. With regards to WFD Risk status the ‘Urlan Beg_010’ river waterbody is under review due

to its ‘Unassigned’ status. Significant pressures which have been identified in relation to this river

waterbody are ‘Urban run-off’ and ‘Diffuse sources run-off’9. Biological water quality values, or Q

values, are unavailable for both of these water courses; they are not monitored presumably due to

their size and urban context.

With regards to the WFD Transitional Waterbody identified as the ‘Upper Shannon Estuary’ into

which both watercourses flow this has been assigned a WFD Status (2010-2015) of ‘Poor’ and a Risk

category of ‘at risk’. Significant pressures which have been identified in relation to the ‘Upper

Shannon Estuary’ comprise ‘Agriculture’. The risk status of the WFD Transitional Waterbody

identified as the ‘Shannon Airport Lagoon’ which is located on the landward side of the West

Embankment is also under review due to its ‘Unassigned’ status. ‘Anthropogenic pressures’ have

been identified in relation to this drainage waterbody.

8 https://gis.epa.ie/EPAMaps/ [Accessed 21/08/2019] 9 https://www.catchments.ie [Accessed 21/08/2019]

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Plate 5 View of Shannon Airport Lagoon

Plate 6 Groenlandia densa in the channel drainage between the lagoon and the western embankment

5.5 HUMAN POPULATION AND LAND USE

Shannon Airport occurs within the Electoral Division (ED) of Clenagh (027) with a reported

population of 355 persons in a 2016 national census10. The Shannon Free Zone is located

immediately adjacent to Shannon Airport which is one of the country’s main airports and the

airport's runways bound the western side of this industrial area. The Shannon Airport and Shannon

Free Zone are bounded by the fringes of Shannon town to the east and by predominantly

agricultural land to the north.

5.6 HABITATS AND FLORA

The site comprises the entire estuarine habitat from Limerick City westwards as far as Doonaha in

Co. Clare and Dooneen Point in Co. Kerry, and is surrounded by the largest port and some of the

most extensive areas of industrial development in the west of Ireland. The Shannon Estuary is

subject to permanent marine inundation and is macro-tidal, having the largest tidal range (5.44 m at

Limerick Docks) on the Irish coast. Extensive reclamation of intertidal mudflats has been carried out

around the site. These areas are protected from tidal flooding by flood embankments, a common

feature across the site. The site includes the Shannon Airport Lagoon; an artificial saline lake that

was developed in the 1940’s when a seawall was constructed out to the estuary to prevent Shannon

Airport from flooding11.

10 http://airomaps.nuim.ie/id/Census_2016/P1_Housing/ [accessed 10/07/2019] 11https://www.npws.ie/sites/default/files/publications/pdf/004077RiverShannonandRiverFergusEstuariesSPASupportingD

ocV1.pdf [Accessed 03/09/2019]

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Figure 2 Habitats at the western embankment

The habitats identified within the proposed development site during July 2018, as well as the

Shannon Estuary in the zone of influence of the project, are listed in Table 1. The extents of these

habitats are illustrated in Figure 3. These habitats are described below with an outline of their

spatial distribution within the site. The River Shannon Estuary in the vicinity of the study area, given

the nature of the surrounding airfield/industrial environment, is in an urbanized setting with existing

rock armour providing a tidal defence.

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Figure 3 Habitats at the eastern embankment

The habitats extant in the proposal site and surrounding environs were classified according to Fossitt

classification (2000) and were determined to be locally defined by; estuaries (MW4), coastal lagoons

(CW1), dry meadows and grassy verges (GS2), sea walls (CC1), buildings and artificial surfaces (BL3),

re-colonising bare ground (ED3), muddy and sandy shores (LS3), upper salt marsh (CM2) and reed

and large sedge swamps (FS1).

Plate 7 Overview of typical GS2 on eastern

embankment

Plate 8 Overview of typical GS2 on western

embankment

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Table 2 Habitats identified within the study area

Habitat Habitat

code

Spatial description within site

Estuaries MW4 This comprises the estuarine tidal habitat of the Upper Shannon Estuary

to which the existing West and East Embankments form the landward

boundary. Sea water within the estuary is diluted by freshwater input

from several waterbodies in the surrounding area. This combined with

tidal processes results in variable salinity.

Lagoons and saline

lakes

CW1 This comprises the brackish artificial lagoon located behind the West

Embankment (Shannon Airport Lagoon). This habitat is separated from

the sea by artificial barriers comprising the embankment and an access

road. Water levels are managed via a sluiced outlet and the lagoon is

surrounded by a range of habitats including saltmarsh, reed bed and

freshwater marsh12.

Dry meadows and

grassy verges

GS2 This is the dominant habitat present along both embankments. Where

this occurs, this habitat is unmanaged and tends to be dominated by

rank and tussock-forming grasses. Dominant species recorded include

abundant False-oat Grass (Arrhenatherum elatius) and Red Fescue

(Festuca rubra) and frequent Creeping Bent (Agrostis stolonifera),

Yorkshire Fog (Holcus lanatus), Cock’s-foot (Dactylis glomerata), Rough

Meadow Grass (Poa Trivialis), Tall Fescue (Festuca arundinacea) and

Common Couch (Elytrigia repens). As the grassland sward is rank

broadleaved herb cover is low overall, but includes typical species; Bush

Vetch (Vicia sepium), Creeping Thistle (Cirsium arvense), Tufted Vetch

(V. crecca), Bird’s-foot Trefoil (Lotus corniculatus), Ribwort plantain

(Plantago lanceolata), Creeping Cinquefoil (Potentilla reptans) and

Lady’s Bedstraw (Galium verum).

Sea walls CC1 The seawards side of the embankments are comprised of natural stone,

with occasional mortar persisting in parts, particularly on the western

embankment. A narrow band of loose large rock and small stone is

present along the base of sections of the western embankment. A

section of newer and larger rock armour has also been installed on part

of the eastern embankment. Vegetation cover is occasional to very rare

with just occasional Sea Plantain (P. maritima), Buck’s-horn Plantain (P.

coronopus), Sea Aster (Aster tripolium), Sea Beet (Beta vulgaris subsp.

Maritima) and Common Scurvy Grass (Cochlearia officinalis) on lower

sections of the walls.

Buildings and artificial

surfaces

BL3 A gravel track is present along the landward side of each of the

embankments. As these tracks are not in regular use vegetation has re-

colonised the gravel substrate.

Re-colonising bare

ground

ED3 Vegetation has re-colonised the gravel substrate of the trackways,

particularly along the central verges, where dry calcareous and neutral

grassland is establishing. Typical species recorded for both re-colonising

tracks include; Yorkshire Fog, Creeping Bent, Red Fescue, Wild Carrot

(Daucus carota), Common Centaury (Centaurium erythraea), Lesser

Bird’s-foot Trefoil, Prickly Sow-thistle (Sonchus asper), Ribwort Plantain,

Red Clover (Trifolium pratense), White Clover (T. repens), Fairy Flax

(Linum catharticum) and Common Ragwort (Senecio jacobaea). The

12 https://www.npws.ie/sites/default/files/publications/pdf/004077_RiverShannonandRiverFergusEstuariesSPASupporting

Doc_V1.pdf

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Habitat Habitat

code

Spatial description within site

tracks and associated re-colonising vegetation along the western

embankment was being managed at the time of the site visit. Dry

meadow and grassy verge (GS2) is present along the tracks immediately

inland, where drainage channels (FW4) are also present.

Drainage channels FW4 An artificial channel runs at the landward side of and parallel to the East

Embankment. This channel is connected to the Shannon Estuary via a

sluice gate located near the western limit of the East Embankment. It is

considered that this channel carries the Urlan Beg Stream to the sea.

Muddy sand shores LS3 Muddy and Sandy Shore is present along the seaward side of the sea

walls at both embankments. This habitat is exposed at low tide. Inter-

tidal mudflats are a dominant feature of the estuarine environment.

This may correspond to the Annex I habitat ‘mudflats and sandflats not

covered by sea water at lower tide (1140)’.

Upper salt marsh CM2 Upper salt marsh was recorded at two locations at the northern end of

the West Embankment and two locations at the northern end of the

East Embankment. Of note is that previously mapped areas of Atlantic

Salt Meadow ASM (1330) to the north-east of the eastern embankment

was not recorded in 2019, with such areas now dominated by reed and

large sedge swamp (FS1) along and immediately out from the

embankment. Some small pockets may persist outside the reed and

large sedge swamp (FS1), but were not visible from the shoreline.

Typical species recorded for Atlantic Salt Meadow include; Common

Saltmarsh-grass (Puccinellia maritima), Saltmarsh Rush (Juncus geradii),

Creeping bent, Common Scurvygrass, Sea Aster and Sea Plantain.

Common Cord-grass (Spartina anglica) is abundant along the outer

edges of each of the Atlantic Salt Meadow habitat areas.

Reed and large sedge

swamps

FS1 Reed and large sedge swamp dominated by dense stands of Common

Reed is present towards the north-west end of the West Embankment

and is the dominant habitat towards the northern end of the East

Embankment.

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Plate 9 Mud-flat adjacent to the eastern embankment

showing where some similar works have been undertaken

Plate 10 Existing track between western embankment and

lagoon

Plate 11 Overview of typical sea-wall on eastern

embankment

Plate 12 Overview of typical sea-wall on western

embankment

Plate 13 Salt-marsh located west of the western

embankment

Plate 14 Salt-marsh located east of the eastern

embankment

Plate 15 Overview of typical Atlantic Salt Meadow (1300) habitat showing area located at northern end of western

embankment

Plate 16 Overview of extent of Spartina along edge of

Atlantic Salt Meadow at eastern embankment

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5.7 FAUNA

5.7.1 Otter

Otters likely utilise the shoreline and intertidal habitats adjacent to the site for both foraging and

commuting. No evidence of otter holts or couches were recorded along the embankments within

the study area, or within 50m of the site boundary. The built-up nature of the landscape and level of

disturbance through human activity in the surrounding area would make the study area less

favourable relative to less disturbed areas of the estuary shoreline.

5.7.2 Avifauna

The River Shannon and River Fergus Estuaries SPA is the largest wetland complex in Ireland; the SPA

covering some 32,261 hectares. The site encompasses the entire estuarine habitat west from

Limerick City and south from Ennis, extending west as far as Killadysert and Foynes on the north and

south shores of the Shannon respectively (a distance of some 25 km from east to west). In addition

to the Shannon and Fergus, the site has numerous sub-estuaries including Ballylongford Creek

(Ballylongford Bay), the Glencorbly river at Glin, the White river at Loghill, Robertstown River and

Poulweala creek at Foynes and Aughinish, the River Deel at Courtbrown Point and the Maigue at

Rinekirk Point.

Figure 4 Count sub-site boundaries for the 2010/11 Waterbird Survey Programme (Source NPWS, 2012b)

Both the Fergus and inner Shannon estuaries feature vast expanses of intertidal mudflats with tidal

creeks and channels which provide rich foraging grounds for wintering birds. Saltmarsh vegetation

frequently fringes the mudflats and this provides important high tide roost areas for the wintering

birds. This vast area is home to a large number of important wintering and migratory wildfowl.

Non-breeding waterbirds have been counted regularly at the River Shannon and River Fergus

Estuaries as part of the Irish Wetland Bird Survey (I-WeBS) since the survey commenced in 1994.

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Table 3 below shows species recorded during waterbird counts undertaken at two of the River

Shannon and River Fergus Estuaries count sub-sites for the 2010/11 Waterbird Survey Programme

(Sub-site: 0H510, located adjacent to the West Embankment and Sub-site: 0H512, located adjacent

to the East Embankment – see Figure 4 below). The table is adapted from data tables included in the

River Shannon and River Fergus Estuaries SPA (004077) Conservation Objectives Supporting

Document (Version 1)(NPWS, 2012b).

Table 3 Waterbird species recorded during surveys at Sub-sites 0H510 and 0H512 at low and high tides

across all behaviours and habitats (2010/2011 Waterbird Survey Programme)

Site Special Conservation Interests

(SCIs)

Species

codes

OH510 (West

Embankment)1,2

OH512 (East

Embankment) 1,2

Whooper Swan WS

Light-bellied Brent Goose PB

Shelduck SU X X

Wigeon WN X X

Teal T.

X

Cormorant CA

X

Ringed Plover RP

Golden Plover GP

X

Grey Plover GV X X

Lapwing L. X X

Knot KN X X

Dunlin DN X X

Black-tailed Godwit BW X X

Bar-tailed Godwit BA

Curlew CU

X

Greenshank GK

X

Redshank RK X X

Pintail PT

Shoveler SV

Scaup SP

Black-headed Gull BH X X

5.7.3 Fish

Inland Fisheries Ireland have published WFD reports on fish stock surveys held in transitional waters

in Ireland. The River Shannon and River Fergus Estuaries are divided into four components; the

Limerick Docks (Limerick City), the Shannon Estuary (upper), the Shannon Estuary (lower) and the

Fergus Estuary. Detailed surveys have been carried out at each location13 and are available online in

the following report ‘Sampling Fish for the Water Framework Directive; Transitional Waters 2014,

Shannon and Fergus Estuaries’.

The proposed refurbishment works will take place in the Lower Shannon Estuary. During the October

2014 survey a total of 29 fish species were recorded in the Lower Shannon Estuary. Sprat was the

most abundant fish species recorded at this location, followed by sand goby, thick-lipped mullet,

sand smelt and flounder (which was found throughout this water body).

13 http://wfdfish.ie/wp-content/uploads/2015/03/Shannon_Estuary_final_report.pdf [accessed 18/07/2019]

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Comparisons with previous surveys completed in 2008 showed several newly recorded species in the

Lower Shannon River in more recent years, including bib, coalfish/saithe, grey gurnard, mackerel and

sand sole. Other species caught but not captured during the 2014 survey included black goby,

thornback ray (which was only recorded in this waterbody), cod, European sea bass and European

Eel. It is noted that European eel (Anguilla Anguilla) is listed as ‘Critically endangered’ and is now

‘Red Listed’ according to the recently published ‘Red List No. 5: Amphibians, Reptiles & Freshwater

Fish’ (King et al., 2011).

The Urlan Beg Stream which flows into the estuary through the eastern embankment is an

unsuitable watercourse for Salmonids and Lampreys, owing to apparently degraded water quality

and the absence of spawning areas. There are no suitable nursery habitats in the lower reaches of

this watercourse.

6 IDENTIFICATION OF OTHER PROJECTS, PLANS AND ACTIVITIES

6.1 WASTEWATER TREATMENT PLANT

The Shannon Town Wastewater Treatment Plant (Licence No. D0045-01)14 is located south-east of

Shannon on Inishbonane Point. This WWTP, which has a Plant Capacity (PE) of 12,500, has a primary

effluent discharge point to the Shannon Estuary east of the proposed development. Shannon WWTP

and pumping stations in the sewer network that serves Shannon Town are operated by Irish Water

and a private operator, Response Engineering Ltd., who are employed on behalf of Shannon Airport

subsequent to the establishment of an airport waste water treatment plant which became fully

operational in March 200715.

The aim of the treatment process is to treat and removed physical and chemical components from

the waste waters generated before the final treated effluent is released into the Shannon estuary.

The treatment process includes the following:

• Preliminary Treatment (including screening and grit removal)

• Primary Treatment

• Secondary Treatment (Conventional Activated Sludge)

The treatment process for the industrial stream is no longer operational, while the supernatant from

the centrifuge and leachate continues to be sent to the industrial side of the plant and is discharged

into the large final effluent lagoon before being discharged to the Shannon estuary.

According to the Annual Environmental Report16 (AER 2017) which has been prepared for D0045-01,

in accordance with the requirements of the wastewater discharge licence, the final effluent from the

primary discharge point for this WWTP was found to be non-compliant with the Emission Limit

Values in 2017 (EPA). The overall plant compliance for this WWTP is ‘Fail’. The proposed

embankment works will not act in combination with the WWTP emissions to negatively affect water

quality in the Shannon Estuary to a significant degree, given their separation by ca. 4km.

14 http://www.epa.ie/terminalfour/wwda/wwda-view.jsp?regno=D0045-01 [accessed 26/07/2019] 15 https://www.shannonairport.ie/corporate/about/community-and-sustainability/ [accessed 26/07/2019] 16 http://www.epa.ie/licences/lic_eDMS/090151b280670e36.pdf [accessed 26/07/2019]

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The overall results for Shannon Town WWTP (and Shannon Airport) are poor. In the 2017 AER

assessment of the operation criteria, the SWO, code name: ‘SW2’ (E143381 N159426), was found to

be non-compliant with DoEHLG guidance, while compliance of other criteria were ‘unknown’ and

their significance in relation to the Lower River Shannon cSAC was unknown due to a lack of data.

Therefore, further assessment of the agglomeration SWOs is required. Design improvements are

planned at the Shannon Town WWTP, which will serve to address the issues of SWO non-

compliance. Consultants have been appointed to carry out design improvements to the plan, and to

undertake a design upgrade in the interim. These improvements are included in the Capital

Investment Plan 2017-2021 (Irish Water).

6.2 LICENSED SITES

A search of the Environmental Protection Agency (EPA) online resources17 indicates that there are

four licensed IPC and four licensed IEL facilities within the vicinity of the proposal site. These licenses

pertain to:

• Lufthansa Technik Painting Shannon Limited (Surface coatings)(IPC License No. P0069-02)

• International Aerospace Coatings Ltd (Coatings) (IPC License No.P0497-02)

• Elements Six Limited (Synthetic materials) (IPC License No. P0533-01)

• Heraeus Metal Processing Limited (Metals) (IPC Licence No. P0145-01)

• Badgers Blinds Limited (Blinds) (IEL Licence No. P0132-02)

• AVARA Shannon Pharmaceutical Companies (Pharmaceutical) (IEL Licence No. P0020-02)

• Molex Ireland Limited (Electronics) (IEL Licence No. P0288-02)

• ITW Ireland Unlimited Company (Polymers) (IEL Licence No. P0072-04)

Another four IEL licensed facilities are located further north-east of the proposed site in Smithstown

Industrial Estate. While these facilities are not in the immediate vicinity, the adoption of the

precautionary principal approach for this assessment means that these facilities have been included

for the purposes of this report. These licenses pertain to:

• Chemifloc Limited (Chemicals) (IEL Licence No. P0076-01)

• Shannon Circuit Technology (Technology) (IEL Licence No. P0240-01)

• Enva Ireland Limited (Waste disposal) (IEL Licence No. W0041-01)

• Galvotech International Limited (Construction) (IEL Licence No. P0292-01).

6.3 PLANS

Plans in place for the area include:

• Irish Water Capital Investment Plan 2017-202118

• Clare County Development Plan 2017 – 202319

• Shannon Town and Environs Local Area Plan 2012 – 2018 (amendment 1)

17 http://gis.epa.ie/Envision [accessed 10/07/2019] 18 https://www.cru.ie/wp-content/uploads/2019/04/CRU190426-CRU-Monitoring-Report-No-2-Irish-Water-Capital-

Investment-Plan-2017-2021.pdf [accessed 26/07/2019] 19 http://www.clarecoco.ie/services/planning/publications/clare-county-development-plan-2017-2023-volume-3a-ennis-

municipal-district-written-statement-and-maps-24146.pdf [accessed 10/07/2019]

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6.4 PLANNING APPLICATIONS

Other activities, such as residential, commercial, infrastructural or recreational development could potentially give rise to either direct impacts on habitats or

species (loss of habitat, disturbance to species) or indirect impacts (e.g. activities which could affect water quality or hydrology which could in turn affect the

status/health of populations of water dependant habitats or species). A review of the Clare County Council’s on-line planning enquiry system was carried out to

determine what development has been permitted in the area.

Table 4 below lists planning applications granted within the last five years for development within the surrounding townlands, namely Rineanna South,

Drumgeely, Lismacleane and Shannon Airport20 together with summary development descriptions.

Table 4 List of planning permissions granted by Clare County Council in surrounding townlands for the period 2014-2019

File Number Decision Date Applicant Name Townland Development Description

14587 18/11/2014 Transaero Engineering Ireland Ltd.

Shannon Airport

To use an existing Aircraft Hangar for the breakup of end-of-life aircraft for recycling

15121 21/04/2015 Shannon Airport Authority

Lismacleane Shannon Airport

For the construction of a new single storey office extension, ancillary car parking including all associated site services, and minor internal hangar work space modifications at the existing Hangar Development

1517 08/04/2015 Shannon Town United

Drumgeely Tullyglass

For the construction of changing rooms at existing Soccer Pitch, including ancillary works

15234 07/10/2015 Drumgeely Playground Association

Drumgeely To construct a community playground and activity park, perimeter fencing and all ancillary site works

15329 07/07/2015 Shannon Airport Authority

Shannon Airport

For the extension of the landside covered walkway. The development will comprise of an extension to the existing landside covered walkway located across from the airport terminal building including some minor landscaping works and footpath re-instatement. An Appropriate Assessment screening statement accompanies this Planning Applications.

15450 25/08/2015 Shannon Airport Authority

Shannon Airport

For the refurbishment and localised reconfiguration of the existing Arrivals/Immigration Hall, Transit Lounge and Block A, Departure Gates areas within the Shannon Airport Terminal Building. All works are to take place 'Airside' ( past security checks) and comprise of the following : 1) Arrivals/Immigration Hall: The relocation of the existing 'European Arrivals Door', localised replacement of the existing cladding and curtain walling facade at ground and first floor levels and associated reconfiguration and refurbishment of the internal office and arrivals, immigration and baggage hall areas; 2) Transit Lounge: The reconfiguration and refurbishment of the existing internal public areas resulting in the generation of

20 http://www.eplanning.ie/ClareCC/searchresults/Default/1 [Accessed 10/07/2019]

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File Number Decision Date Applicant Name Townland Development Description

46m2 of new airside retail space; 3) Block 'A' Departure gates 1-5: The localised replacement of the existing cladding and curtain walling facade at ground and first floor levels as well as the refurbishment of the internal public waiting and toilet areas, including all ancillary site and service works

1557 26/03/2015 Shannon Airport Authority

Rineanna South Ballyhenessy

To Extend the Appropriate Period of Planning Permission P08-1992(APB Ref 03.233151 for demolition of existing buildings, construction of new facade and adjoining building and construction of staff car park

1614 01/03/2016 Shannon Airport Authority

Shannon Airport Fire Station Shannon Airport

For construction of a ground floor extension (118m2) to the existing fire station whereby the new space is to be used as a gym. This will be completed using modular units and will require the removal of the existing portacabin type gym as well as some minor alterations to the existing fire station and all ancillary works at Shannon Airport Fire Station

16361 27/06/2016 Shannon Commercial Properties

Lismacleane Drumgeely

For the demolition of 3 No existing industrial/office buildings within Shannon Industrial Estate and associated site clearance works along with all other associated site works

16543 19/08/2016 Derk Estates Drumgeely For RETENTION permission to RETAIN alterations carried out to two apartment blocks including alterations to corridor and window arrangement, enclosing of some open balconies and elevational changes at Hawthorn and Linden Apartment Blocks, Drumgeely, Shannon

16788 20/01/2017 Shannon Airport Authority

Shannon Airport

For the development within a Strategic Development Zone of a Fire Training Ground at the Secondary Surveillance Radar Equipment site on the north side of Runway 06-24, Shannon Airport, Co Clare. The development will comprise of the installation of a Simulated Steel Aircraft Shell, a Fire Screen and Engine Rig for the purpose of training fire fighting personnel. Also included in the development will be an overground Water Storage Tank, 2 No. 2 Tonne LPG Gas Tanks, a 300 Gallon Jet A1 Fuel Tank, 3 No. sheds to house controls and fuel pressurisation unit, security fencing to surround site perimeter, concrete hardstanding areas, site lighting and all other associated site works. An Appropriate Assessment screening statement accompanies this planning Application.

17125 22/05/2017 Rocktwist Holdings Ltd.

Caherteige Drumgeely

Construct an industrial unit with office accommodation for industrial, warehouse and logistic usage, including ancillary site development works

17494 04/08/2017 Nan & Mul Catering Ltd. t/a Freshtoday

Ballymurtagh Drumgeely

To construct new mezzanine floor space of 120m2 for use as storage area at existing unit ( Originally granted under Planning Ref. P01-626) including ancillary site works

1724 15/03/2017 Shannon Airport Authority DAC

Lismacleane & Ballyhennessy Bunratty Lower, Shannon

For the following proposed development which will comprise of the construction of a new steel framed aircraft hangar within the airport lands at Shannon Airport, Co. Clare. The hangar building includes for ancillary office space, workshops, plant rooms and storage space. The building will have signage on the eastern, southern and western facades. Ancillary buildings and structures within the curtilage of the site including an external pump house, gas skid and fire suppression tank are also proposed. Site works proposed include car parking, hardstands, landscaping, and all ancillary site developments at this

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File Number Decision Date Applicant Name Townland Development Description

address. An Integrated Pollution and Control License is required for the facility

17602 27/09/2017 Shannon Airport Rineanna South Shannon Airport

For development which will consist of the extension of existing covered walkways at car parks. An appropriate assessment screening statement accompanies this application

17910 19/01/2018 Shannon Airport Authority DAC

Shannon Airport

For proposed alterations and refurbishment works to the New Terminal Building at Shannon Airport. The development, within a Strategic Development Zone, will consist of upgrade works to the existing arrivals Hall at Shannon Airport including alterations to the existing southern and eastern elevations and provision of additional floor area of 42.5m2 to facilitate new Café and 16m2 for ancillary accommodation

17998 23/02/2018 Shannon Commercial Properties

Shannon Airport Shannon

Further to previously granted planning application Ref: P16-405 for amendments and additions to the car parking area and all associated site works and services. Previously granted were 202 nr. parking spaces. The new total will be 298 nr spaces (96 nr. additional) including 15 nr. accessible spaces and 29 nr. electrical car recharge spaces

18417 24/09/2018 Shannon Commercial Properties

Caherteige Drumgeely

For the demolition of existing industrial / office buildings within Block K, within Shannon Industrial Estate and associated site clearance works along with all other associated site works to allow for future development on site

18514 16/08/2018 Shannon Airport Authority

New Terminal Building Shannon Airport

For alterations and refurbishment works which were carried out to the New Terminal Building

18545 20/08/2018 The Board of Management, St. John’s NS

Drumgeely Tullyglass

For the installation of a portacabin to be used as a pre-school facility with connection to services including ancillary site works.

19207 15/05/2019 Shannon Town Ltd.

Drumgeely Tullyglass

For the construction of changing rooms at existing Soccer Pitch, including ancillary site works

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6.5 ONGOING ACTIVITIES

The most important impacts and activities with high effect on the Lower River Shannon cSAC are

outlined in the sites Natura 2000 Standard data form. These are limited to ‘Medium’ and ‘Low’

ranking threats and pressures, as listed in Table 5 below. The main threats to the site, ranked as

medium include agriculture (fertilisation, grazing), urbanisation, residential and commercial

development, and reclamation of land. Lesser threats include invasion by non-native species,

sylviculture, forestry and removal of beach materials.

Table 5 Impacts and activities with high effect on the Lower River Shannon cSAC (Adapted from the Natura 2000 Standard Data Form)

Rank Threats and

pressures [code]

Description inside/outside/both

[i|o|b]

Medium A08 Fertilisation o

E01 Urbanisation, residential and commercial

development

o

H04 Air pollution, air-borne pollutants o

E03 Discharges o

K02.03 Eutrophication (natural) o

A04 Grazing i

J02.01.01 Polderisation i

J02.01.02 Reclamation of land from sea, estuary or marsh o

Low I01 Invasive non-native species i

D01.01 Paths, tracks, cycling tracks i

G01.01 Nautical sports i

B Sylviculture, forestry i

F01 Marine and Freshwater Aquaculture i

F03.01 Bait digging / collection i

C01.01.02 Removal of beach materials i

The discharge of polluting substances from point (industrial pollutants, wastewater effluents, storm-

water sewers) and diffuse (urban runoff) sources associated with ongoing activities in Shannon, Co.

Clare, but also point (industrial pollutants, wastewater effluents) and diffuse (e.g. agriculture and

forestry) sources along the entire River Shannon Catchment upstream of Shannon Airport have the

potential to contribute to a cumulative impact on the Natura 2000 sites of the lower catchment and

estuary.

6.6 SHANNON AIRPORT

6.6.1 Bird Strike

Birds pose an air safety hazard and present a risk of collision or bird strike with aircrafts operating in

and out of Shannon Airport. According to NPWS the risk of collision/bird strikes with aircrafts is

greatest during take-off, approach, climb and landing21. Many of these collisions will result in little to

no effect on the aircraft, in terms of damage, but some more serious collisions have the potential to

damage the structural integrity of aircrafts (Soldatini et al. 2010).

21 https://www.npws.ie/sites/default/files/files/Public%20Consultation%20Document%20Art9%20Birds%20Directive.pdf

[section 4.2. accessed 26/07/2019]

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The Irish Aviation Authority (IAIP) has published a detailed report in July 2019 which outlines

regulations and procedures for aircrafts and airports in Ireland, and also includes a section on Bird

Migration and Areas with Sensitive Fauna22 (ENR 5.6). This brief section of the report assesses bird

concentrations and movements in Ireland, identifies important bird areas/areas of sensitivity and

outlines the procedure for reporting incidences of bird strikes/collisions23 to the relevant person(s).

This report takes note of the key areas where birds are concentrated that pose a risk to aircrafts and

personnel such as shallow estuaries, inland waters, exposed headlands, cliffs and offshore islands.

Flocks of gulls are recognised as the birds most responsible for the majority of Irish bird strikes, and

as such maps have been included in the report showing where these flocks occur, which happens to

be heavily concentrated along the west coast of Ireland, as-well as along areas of the east coast such

as Cork, Waterford, Wexford, Dublin and County Down. Pilots are instructed to be cognisant of the

fact that bird concentrations are subject to constant change and they should familiarise themselves

with these changes to stay updated. Shannon Airport is listed as an area of high bird sensitivity all

year round owing to the proximity of the site to important bird habitats, namely estuaries, wetlands

and inland waters.

There have been incidences of collisions/bird strikes that have occurred at Shannon Airport, where

aircraft had to be diverted or landed in order to avoid further risk of damage or harm to passengers.

These incident reports have been detailed in local and national newspapers in Ireland, with one

incident cited as most recently as December 2018, where an executive jet had to be grounded at

Shannon airport following a bird strike.

6.6.2 Airport Activities

Activities at Shannon Airport and all other Irish airports are monitored in terms of their potential

impacts on air quality, water quality, energy and carbon consumption, noise emissions, waste, and

biodiversity, all of which can be found in sustainability reports which are published online by the

DAA24; a global airports and travel retail group, which are owned by the Irish State. The table below,

extrapolated from a 2011 Sustainability Report25, contains the following information about potential

impacts of Shannon Airport Activities on the receiving environment.

Table 6 Key Points extrapolated from DAA Sustainability Report 2011 on Shannon Airport

Parameter Report

Air Quality The average nitrogen dioxide and particulate matter concentrations at Shannon Airport were

significantly below the national limit value for 2011

Water Quality Tests taken throughout the year indicate that the water quality at Shannon Airport is in good

status throughout the site. Shannon Airport had the second highest consumption of potable

water (300000-350000 M3) in 2010 and 2011, when compared against Dublin (the highest)

and Cork (second highest).

Energy

Consumption

Energy consumption was lowest in Shannon Airport when compared with Cork and Dublin

Airport. Consumption fell to 21,239 (MWh) in 2011 from 24,266 (MWh) in 2010.

Noise

Emissions

The report shows an overall decline in the number of noise complaints received for all

airports over the years, with a slight increase in complaints in 2011, which was attributed to

22 http://iaip.iaa.ie/iaip/Published%20Files/AIP%20Files/ENR/EI_ENR_5_6_EN.pdf [accessed 26/07/2019] 23 https://www.iaa.ie/general-aviation/forms/wildlife-strike-form [accessed 26/07/2019] 24 https://www.daa.ie/our-company/our-team/ [accessed 26/07/2019] 25 https://www.daa.ie/wp-content/uploads/2016/04/sustainability-2011.pdf [accessed 26/07/2019]

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Parameter Report

increased runway usage of runway 16.

Waste Total waste at Shannon Airport (<1000 overall) was the second highest compared with the

two other airports, with over 12% of this being recycled in 2010 and 2011.

Biodiversity Measures to improve this include:

• Chemicals used only where necessary

• Efficient water systems in place

• Greenhouses in place

• Grass clippings reused on flower beds

• Significant range of trees and grassed areas maintained at airports

7 IDENTIFICATION OF NATURA 2000 SITES

The screening for AA undertaken for this project concluded that significant effects on the

Conservation Objectives of two Natura 2000 sites could potentially ensue from the proposed

development. It has been concluded that the proposed development at Shannon Airport

Embankments is likely to have a significant effect, or significant effects cannot be ruled out at this

stage, on the following Natura 2000 sites:

• Lower River Shannon cSAC (002165)

• River Shannon and River Fergus Estuaries SPA (004077)

Therefore, further assessment is required to determine whether the project is likely to adversely

affect the integrity of these Natura 2000 sites.

7.1 LOWER RIVER SHANNON CSAC (002165)

7.1.1 Description of the Natura 2000 Site

The Lower River Shannon cSAC is very large, long site approximately 14km wide and 120km long

encompassing: the drained river valley which forms the River Shannon Estuary; the broader River

Fergus Estuary, plus a number of smaller estuaries e.g. Poulnasherry Bay; the freshwater lower

reaches of the Shannon River between Killaloe and Limerick, plus the freshwater stretches of much

of the Feale and Mulkear catchments; a marine area at the mouth of the Shannon estuary with high

rocky cliffs to the north and south; ericaceous heath on Kerry Head and Loop Head; and several

lagoons. The underlying geology ranges from Carboniferous limestone (east of Foynes) to Namurian

shales and flagstones (west of Foynes) to Old Red Sandstone (at Kerry Head). The salinity of the

system varies daily with the ebb and flood of the tide and with annual rainfall fluctuations

seasonally.

Both the Fergus and inner Shannon Estuaries feature vast expanses of intertidal mudflats. Plant

species are typically scarce on the mudflats, although there are some eelgrass (Zostera spp.) beds

and patches of green algae (e.g. Ulva sp. and Enteromorpha sp.). In the transition zone between

mudflats and saltmarsh, specialised colonisers of mud predominate e.g. Common Cord-grass

(Spartina anglica) which frequently occurs in the upper parts of the estuaries. In the innermost parts

of the estuaries, the tidal channels or creeks are fringed with species such as Common Reed

(Phragmites australis) and club-rushes (Scirpus maritimus, S. tabernaemontani and S. triquetrus).

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Saltmarsh vegetation frequently fringes the mudflats. Over twenty areas of estuarine saltmarsh have

been identified within the site. The dominant type of saltmarsh present is Atlantic salt meadow

occurring over mud. Characteristic species occurring include Common Saltmarsh-grass (Puccinellia

maritima), Sea Aster (Aster tripolium), Thrift (Armeria maritima), Sea-milkwort (Glaux maritima), Sea

Plantain (Plantago maritima), Red Fescue (Festuca rubra), Creeping Bent (Agrostis stolonifera),

Saltmarsh Rush (Juncus gerardi), Long-bracted Sedge (Carex extensa), Lesser Sea-spurrey

(Spergularia marina) and Sea Arrowgrass (Triglochin maritima). Areas of Mediterranean salt

meadows, characterised by clumps of Sea Rush (Juncus maritimus), occur occasionally.

Saltmarsh vegetation also occurs around a number of lagoons within the site, two of which have

been surveyed as part of a National Inventory of Lagoons. Cloonconeen Pool (4-5 ha) is a natural

sedimentary lagoon impounded by a low cobble barrier. This lagoon represents a type which may be

unique to Ireland since the substrate is composed almost entirely of peat. The fauna is not diverse,

but is typical of a high salinity lagoon and includes lagoon specialist species. In contrast, Shannon

Airport Lagoon (2 ha) is an artificial saline lake with an artificial barrier and sluiced outlet. However,

it supports two Red Data Book species of stonewort (Chara canescens and Chara cf. connivens).

Most of the site west of Kilcredaun Point/Kilconly Point is bounded by high rocky sea cliffs, which are

sparsely vegetated with lichens, Red Fescue, Sea Beet (Beta vulgaris subsp. maritima), Sea Campion

(Silene vulgaris subsp. maritima), Thrift and plantains (Plantago spp.), particularly in the outer part

of the site. Cliff-top vegetation usually consists of either grassland or maritime heath. The site

supports an excellent example of a large shallow inlet and bay. The sediment communities in the

mouth of the Shannon Estuary occur in areas that are exposed to wave action and also in areas

extremely sheltered from wave action. Characteristically, exposed sediment communities are

composed of coarse sand and have a sparse fauna. Species richness increases as conditions become

more sheltered. The intertidal reefs in the Shannon Estuary are exposed or moderately exposed to

wave action and subject to moderate tidal streams. Other coastal habitats that occur within the site

include stony beaches and bedrock shores, shingle beaches, sandbanks which are slightly covered by

sea water at all times and sand dunes.

Freshwater rivers have been included in the site, most notably the Feale and Mulkear catchments,

the Shannon from Killaloe to Limerick (along with some of its tributaries), the Fergus up as far as

Ennis and the Cloon River. These systems are very different in character: the Shannon is broad,

generally slow flowing and naturally eutrophic; the Fergus is smaller and alkaline; while the narrow,

fast flowing Cloon is acid in nature. Semi-natural habitats, such as wet grassland, wet woodland and

marsh occur by the rivers, but improved grassland is the most common habitat type. One grassland

type of particular conservation significance, Molinia meadows, occurs in several parts of the site.

Here are found areas of wet meadow dominated by rushes (Juncus spp.) and sedges (Carex spp.),

and supporting a diverse and species-rich vegetation. Floating river vegetation characterised by

species of water-crowfoot (Ranunculus spp.), pondweeds (Potamogeton spp.) and the moss

Fontinalius antipyretica are present throughout the major river systems within the site.

Alluvial woodland occurs on the banks of the Shannon and on some islands. The most prominent

woodland type is gallery woodland where White Willow (Salix alba) dominates the tree layer with

occasional Alder (Alnus glutinosa). On slightly higher ground above the wet woodland and on the

raised embankment remnants of mixed oak-ash-alder woodland occur. The ground flora is species

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rich. While woodland is infrequent within the site, Cahiracon Wood contains an area of old oak

woodland. Sessile Oak (Q. petraea) forms the canopy, with an understorey of Hazel and Holly (Ilex

aquifolium). Patches of semi-natural broadleaf woodland dominated by Ash, Hazel, oak and birch

occur on higher ground north-east of Cappamore. There is a small area of actively regenerating cut-

away raised bog at Ballyrorheen, Co. Limerick. The bog contains some wet areas with good cover of

bog mosses (Sphagnum spp.). Species of particular interest include Cranberry (Vaccinium oxycoccos)

and White Sedge (Carex curta), along with two regionally rare mosses.

There is a resident population of Bottle-nosed Dolphin in the Shannon Estuary. This is the only

known resident population of this E.U. Habitats Directive Annex II species in Ireland. Otter, a species

also listed on Annex II of this Directive, is commonly found on the site. Five species of fish listed on

Annex II of the E.U. Habitats Directive are found within the site. These are Sea Lamprey (Petromyzon

marinus), Brook Lamprey (Lampetra planeri), River Lamprey (Lampetra fluviatilis), Twaite Shad

(Allosa fallax fallax) and Salmon (Salmo salar). The three lampreys and Salmon have all been

observed spawning in the lower Shannon or its tributaries. Twaite Shad is not thought to spawn

within the site. There are few other river systems in Ireland which contain all three species of

lamprey. Freshwater Pearl Mussel (Margaritifera margaritifera), a species listed on Annex II of the

E.U. Habitats Directive, occurs abundantly in parts of the Cloon River.

This site is of great ecological interest as it contains a high number of habitats and species listed on

Annexes I and II of the E.U. Habitats Directive, including the priority habitats lagoon and alluvial

woodland, the only known resident population of Bottle-nosed Dolphin in Ireland and all three Irish

lamprey species. A number of species listed on Annex I of the E.U. Birds Directive are also present,

either wintering or breeding. Most of the estuarine part of the site has been designated a Special

Protection Area (SPA), under the E.U. Birds Directive, primarily to protect the large numbers of

migratory birds present in winter (adapted from Lower River Shannon cSAC 002165 Site Synopsis).

This SAC is designated for the following habitats and species:

• Sandbanks which are slightly covered by sea water all the time [1110]

• Estuaries [1130]

• Mudflats and sand flats not covered by seawater at low tide [1140]

• Coastal lagoons [1150]*

• Large shallow inlets and bays [1160]

• Reefs [1170]

• Perennial vegetation of stony banks [1220]

• Vegetated sea cliffs of the Atlantic and Baltic coasts [1230]

• Salicornia and other annuals colonising mud and sand [1310]

• Atlantic salt meadows (Glauco-Puccinellietalia maritimae) [1330]

• Mediterranean salt meadows (Juncetalia maritimi) [1410]

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

Callitricho-Batrachion vegetation [3260]

• Molinia meadows on calcareous, peaty or clayey-silt-laden soils (Molinion caeruleae)

[6410]

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

incanae, Salicion albae) [91E0]*

• Freshwater Pearl Mussel (Margaritifera margaritifera) [1029]

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• Sea Lamprey (Petromyzon marinus) [1095]

• Brook Lamprey (Lampetra planeri ) [1096]

• River Lamprey (Lampetra fluviatilis) [1099]

• Salmon (Salmo salar ) [1106]

• Common Bottlenose Dolphin (Tursiops truncates) [1349]

• Otter (Lutra lutra) [1355]

7.1.2 Identification of Potential for Significant Impacts to Qualifying Features

When Natura 2000 sites are selected for stage 2 assessments, then all the qualifying features of

conservation interest must be included in that stage of the assessment. However, when assessing

impact, qualifying features are only considered relevant where a credible or tangible source-

pathway-receptor link exists between the proposed development and a protected species or habitat

type. In order for an impact to occur there must be a risk initiated by having a 'source' (e.g.

excavation works), a 'receptor' (e.g. a protected species associated aquatic or riparian habitats), and

an impact pathway between the source and the receptor (e.g. a watercourse which connects the

proposed development site to the Natura 2000 site). Identifying a risk that could, in theory, cause an

impact does not automatically mean that the risk event will occur, or that it will cause or create an

adverse impact. However, identification of the risk does mean that there is a possibility of ecological

or environmental damage occurring, with the level and significance of the impact depending upon

the nature of the risk, the extent of the exposure to the risk and the characteristics of the receptor.

Bearing in mind the scope, scale, nature and size of the project, its location relative to the

distribution of the species and habitats listed and the degree of connectedness that exists between

the project and the potential receptors, it is considered that not all of them are within the zone of

potential impact of the proposal. An evaluation based on these factors to determine which species

and habitats are the plausible ecological receptors for potential impacts of the unmitigated proposal

has been conducted below.

The following table lists the qualifying features of the Lower River Shannon cSAC and evaluates

through a scientific examination of evidence and data whether or not these features should or

should not be selected for further assessment in the NIS. The qualifying features that are selected

for further assessment are then discussed further followed by an assessment of potentially

significant effects arising from the proposed development.

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Table 7 Identification of potential for significant impacts to qualifying features of the Lower River Shannon cSAC26

Qualifying

Feature

Potential for

Significant Impacts Rationale

Sandbanks which

are slightly

covered by sea

water all the time

No

The extent of mapped ‘sandbanks which are slightly covered by seawater all the time’ in the Lower River Shannon cSAC is given in

NPWS (2012a). This habitat is mapped as occurring south of Rinevella Point, Co. Clare and west of Ballybunion, Co. Kerry in the mouth

of the Shannon Estuary. This habitat is in excess of 50km to the west of the proposed development. Given the intervening distance

between the proposal and this habitat it is considered that the project does not have potential for significant effects on sandbanks.

Thus, the project will not affect the conservation objectives for ‘sandbanks which are slightly covered by sea water all the time’ and the

habitat is not considered further in the NIS.

Estuaries Yes

The Shannon and Fergus Estuaries form a unit stretching from the upper tidal limits of the Shannon and Fergus Rivers to the mouth of

the Shannon Estuary (considered being a line across the narrow strait between Kilcredaun Point and Kilconly Point). Within this main

unit, there are several tributaries with their own ‘sub-estuaries’ e.g. the Deel River, Mulkear River, and Maigue River. Estuarine habitat

surrounds the proposed development as the existing embankments form the land boundary with the estuary channel (NPWS, 2012a).

While it is considered that any potential water quality impacts will be localised in view of the localised nature, extent and scale of the

proposed works and due to the dilution potential of the River Shannon and estuary, there is the potential for significant impacts to

occur, and as such, ‘Estuaries’ are to be considered further in the NIS.

Mudflats and

sandflats not

covered by

seawater at low

tide

Yes

‘Mudflats and sandflats not covered by seawater at low tide’ occur extensively throughout the site, in particular along the edges of the

Shannon Estuary channel. They occur within the vicinity of Shannon Airport, beginning at Shannon Bridge and increasing in extent

further downstream as the estuary channel widens. This habitat is mapped as occurring immediately adjacent to both the West and

East Embankments (NPWS, 2012a). The proposal will result in removal/alteration of mudflat habitat as a result of excavation works and

installation of rock armour. Given the characteristics of the project, it is considered that there is potential for significant effects to

occur, and as such, this habitat is to be considered further in the NIS.

Coastal lagoons* Yes

According to habitat mapping presented in NPWS (2012a), there are four coastal lagoons within the SAC, namely Quayfield and

Poulaeala Loughs, Shannon Airport Lagoon, Scattery Lagoon, and Cloonconneen Pool. The west embankment, to which works are

proposed, lies adjacent to the Shannon Airport Lagoon. While there is some land intervening, the lagoon is in close proximity to the

proposed works, therefore the project has the potential to affect the lagoons conservation objectives and thus ‘Coastal lagoon’ habitat

is to be considered further in the NIS.

Large shallow

inlets and bays No

The habitat ‘large shallow inlets and bays’ is a large physiographic feature that may wholly or partly incorporate other Annex I habitats

including reefs, sandbanks and mudflats and sandflats within its area. In contrast to estuaries, large shallow inlets and bays have limited

26 https://www.npws.ie/sites/default/files/protected-sites/conservation_objectives/CO002165.pdf [accessed 25/07/2019]

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Qualifying

Feature

Potential for

Significant Impacts Rationale

freshwater influence. This habitat-type, with an estimated area of approximately 25,000ha, is mapped as occurring west of Shannon

towards the mouth of the estuary. The habitat comprises the channel south of Kilrush, Co. Clare extending westwards to the outer

extent of the estuary (NPWS, 2012a). This habitat is in excess of 40km to the west of the proposed development. Given the intervening

distance between the proposal and this habitat it is considered that the project does not have potential for significant effects on this

habitat. Thus, the project will not affect the conservation objectives for ‘large shallow inlets and bays’ and the habitat is not considered

further in the NIS.

Reefs No

‘Reef’ occurs throughout the estuary, mainly as scattered and isolated pockets within the inner estuary and covering more extensive

areas towards the middle and outer reaches of the channel. A review of mapping available for this habitat-type determined that the

closest areas of reef to the proposed development comprise an area located on the shoreline approximately 950m west of the northern

end of the West Embankment and another area located out in the main channel, approximately 670m south-east of the southern end

of the West Embankment (NPWS, 2012a). It is considered that any potential water quality impacts will be localised in view of the

localised nature, extent and scale of the proposed works and due to the dilution potential of the River Shannon and estuary, there is no

potential for significant impacts to occur, and as such, ‘Reefs’ will not be considered further in the NIS.

Perennial

vegetation of

stony banks

No

This habitat occurs along the coast where shingle (cobbles and pebbles) and gravel have accumulated to form elevated ridges or banks

above the high tide mark. This habitat is recorded in 9 locations along the Shannon River and Estuary. At its closest, this habitat occurs

at Ballymacrinan Bay (NPWS, 2012a), a distance in excess of 39km west of the project. Given the characteristics of the project, and the

distance intervening, it is not considered that the proposal has any potential to significantly impact on this habitat-type. Thus, the

project will not affect the conservation objectives for ‘perennial vegetation of stony banks’ and the habitat is not considered further in

the NIS.

Vegetated sea

cliffs of the

Atlantic and

Baltic coasts

No

‘Vegetated sea cliffs of the Atlantic and Baltic coasts’ occur at the western extent of the Shannon Estuary. At its closest, this habitat is

located at Baurrane on the southern coast of Co. Clare (NPWS, 2012a), in excess of 30km west of the proposed development. Given the

characteristics of the project, and the distance intervening, it is not considered that the proposal has any potential to significantly

impact on this habitat-type. Thus, the project will not affect the conservation objectives for ‘Vegetated sea cliffs of the Atlantic and

Baltic coasts’ and the habitat is not considered further in the NIS.

Salicornia and

other annuals

colonizing mud

and sand

No

Salicornia and other annuals colonizing mud and sand are classified by Fossitt (2000) as lower salt marsh. A review of habitat mapping

and the coastal habitats supporting document available for the SAC determined that of the ten sub-sites surveyed, mapped and

assessed as part of the Saltmarsh Monitoring Project (McCorry & Ryle, 2009) the closest site to the proposal site where Salicornia

habitat is mapped as occurring is the ‘Inishdea, Owenshere’ sub-site (SMP 0083)(NPWS, 2012a). Inishdea saltmarsh is located in

southern Co. Clare, along the western side of the Fergus Estuary, in excess of 10km north-west of the proposed development. Within

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Qualifying

Feature

Potential for

Significant Impacts Rationale

the sub-site Salicornia habitat is not well-developed occupying a single patch of ground of 0.003ha (NPWS, 2012a). Given the

characteristics of the project including the localised nature, extent and scale of the proposed works, and the distance intervening, it is

not considered that the proposal has any potential to significantly impact on this habitat-type. Thus, the project will not affect the

conservation objectives for ‘Salicornia and other annuals colonizing mud and sand’ and the habitat is not considered further in the NIS.

Atlantic salt

meadows

(Glauco-

Puccinellietalia

maritimae)

Yes

‘Atlantic salt meadows’ (ASM) generally occupy the widest part of the salt marsh gradient. A review of habitat mapping and the coastal

habitats supporting document available for the SAC determined that of the ten sub-sites surveyed, mapped and assessed as part of the

Saltmarsh Monitoring Project (McCorry & Ryle, 2009) the closest site to the proposal site where ASM habitat is mapped as occurring is

the ‘Bunratty’ sub-site (SMP 0081)(NPWS, 2012a). Bunratty saltmarsh is located in the upper part of the Shannon Estuary in Co. Clare,

approximately 2.8km east of the proposal area. Within the sub-site, ASM is the most extensive of all the saltmarsh habitats, estimated

to measure approximately 27ha. Typically it occurs within this sub-site as a narrow band at the landward side of the brackish

vegetation. However, potential ASM is mapped as occurring along the shoreline extending westwards from this area as far as and

immediately adjacent to the northern extent of the East Embankment (NPWS, 2012).

During habitat surveys undertaken for the proposed works two small areas of previously unmapped Upper salt-marsh (CM2)

corresponding to Annex I ‘Atlantic salt meadow’ were identified immediately adjacent to the East Embankment towards its northern

end. The proposal will result in works immediately adjacent to and in the general vicinity of these areas of ASM. Given the

characteristics of tse project, it is considered that there is potential for significant effects to occur, and as such, ‘Atlantic salt meadows’

is to be considered further in the NIS.

Mediterranean

salt meadows

(Juncetalia

maritimi)

No

‘Mediterranean salt meadows’ (MSM) occupy the upper zone of salt marshes and usually occur adjacent to the boundary with

terrestrial habitats. They are widespread on the Irish coastline; however, they are not as extensive as Atlantic salt meadows. A review of

habitat mapping and the coastal habitats supporting document available for the SAC determined that of the ten sub-sites surveyed,

mapped and assessed as part of the Saltmarsh Monitoring Project (McCorry & Ryle, 2009) the closest site to the proposal site where

MSM habitat is mapped as occurring is the ‘Bunratty’ sub-site (SMP 0081)(NPWS, 2012a). Bunratty saltmarsh is located in the upper

part of the Shannon Estuary in Co. Clare, approximately 2.8km east of the proposal area. The MSM is not well-developed or as

widespread as the ASM within the sub-site and is generally confined to narrow fragmented patches in the ASM or towards the back of

the marsh. The MSM is estimated to measure approximately 0.9ha within the site.

Given the characteristics of the project including the localised nature, extent and scale of the proposed works, and the distance

intervening, it is not considered that the proposal has any potential to significantly impact on this habitat-type. Thus, the project will

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Qualifying

Feature

Potential for

Significant Impacts Rationale

not affect the conservation objectives for ‘Mediterranean salt meadows’ and the habitat is not considered further in the NIS.

Watercourses of

plain to montane

levels with the

Ranunculion

fluitantis and

Callitricho-

Batrachion

vegetation

Yes

This annexed habitat has a broad definition, covering from upland, flashy, oligotrophic, bryophyte- and algal-dominated rivers, to tidal

reaches dominated by higher plants. The full distribution of this habitat and its sub-types within the SAC are currently unknown. The

Groenlandia densa (L.) Fourr., Opposite-leaved Pondweed sub-type has been identified as a high conservation element in the site. In

Ireland, this particular sub-type is associated with tidal reaches of rivers and other periodically disturbed watercourses (e.g. canals and

drains) (NPWS, 2012a). Groenlandia densa was identified within a drainage channel associated with the Shannon Airport Lagoon during

habitat surveys carried out on-site. Therefore, ‘Floating river vegetation’ as the habitat is commonly known is considered to be within

the zone of influence of the project and thus, there is potential for significant effects to this habitat.

Molinia meadows

on calcareous,

peaty or clayey-

silt-laden soils

(Molinion

caeruleae)

No

‘Molinia meadows on calcareous, peaty or clayey-silt-laden soils’ is represented in Ireland by both fen and grassland communities on

nutrient-poor soils. The habitat is either managed as traditional hay meadows or more usually by extensive pasture.

Molinia meadows occur in lowland plains on neutral to calcareous gleys, sometimes with a marl layer beneath the surface, or on peaty

soils both in lowland and upland situations (NPWS, 2019). The full extent of this habitat within the SAC is currently unknown. It has

been recorded on the eastern bank of the Shannon, just north of Castleconnell, Co. Limerick NPWS (2012a).

Given the characteristics and location of the project, it is not considered that the proposal has any potential to significantly impact on

this habitat-type. Thus, the project will not affect the conservation objectives for ‘Molinia meadows’ and the habitat is not considered

further in the NIS.

Alluvial forests

with Alnus

glutinosa and

Fraxinus excelsior

(Alno-Padion,

Alnion incanae,

Salicion albae)*

No

Alluvial woodland is a priority Annex I habitat. A number of variants of this habitat exist, of which riparian forests of Fraxinus excelsior

and Alnus glutinosa of temperate and Boreal Europe lowland and hill watercourses are the most common type found in Ireland.

The Interpretation Manual of EU habitats (2013) states that all types occur on heavy soils which are periodically inundated by

the annual rise of river levels, but which are otherwise well-drained and aerated during low water. In addition, there are gallery

forests of tall willows alongside river channels and occasionally on river islands, where the tree roots are almost continuously

submerged (NPWS, 2019a).

Alluvial woodlands occur along the Shannon, in the valley bottoms of the tributaries and on seepage zones on valley sides. Within the

SAC five sites have been surveyed as part of the National Survey of Native Woodlands. These are small stands, restricted to narrow

bands where the ground is subject to flooding (NPWS, 2012a). The nearest mapped area of this habitat is at Clare Glen along the main

channel of the Clare River, approximately 25km east of the proposal area. Given the characteristics and location of the project, it is not

considered that the proposal has any potential to significantly impact on this habitat-type. Thus, the project will not affect the

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Qualifying

Feature

Potential for

Significant Impacts Rationale

conservation objectives for ‘Alluvial forests’ and the habitat is not considered further in the NIS.

Freshwater Pearl

Mussel

(Margaritifera

margaritifera)

No

The freshwater pearl mussel is a large, long-lived bivalve mollusc found in clean, fast-flowing, well-oxygenated rivers with

unconsolidated substrates. Stable, clean gravel and sand with adequate availability of dissolved oxygen provides ideal habitat for

juveniles. Water pH and hardness is also important with distribution mainly restricted to acidic, soft waters over-lying non-calcareous

rock-types. Low nutrient status is also critical such that excess macrophyte and algal growth is prevented; therefore oligotrophic

waterbodies are required. Conservation objectives for this species within the SAC apply to the freshwater pearl mussel population in

the Cloon River, County Clare. This population is confined to the main channel and is distributed from Croany Bridge to upstream of

Clonderalaw Bridge (NPWS (2012a). The Cloon River enters the main Shannon Estuary in excess of 23km west of the proposal site.

Given the characteristics and location of the project, and the ecology of this species, it is not considered that the proposal has any

potential to significantly impact on freshwater pearl mussel. Thus, the project will not affect the conservation objectives for ‘Freshwater

Pearl Mussel’ and the species is not considered further in the NIS.

Sea Lamprey

(Petromyzon

marinus)

No

The life cycle of the sea lamprey (Petromyzon marinus) contains both a marine phase and a freshwater phase. Sea lampreys spend

their adult life in marine and estuarine waters, living as external parasites on other fish species. They migrate up rivers in spring to

spawn in areas of clean gravel, after which they die. Sea lamprey is known to spawn within the lower Shannon and its tributaries (Kelly

and King, 2001). The two 10km grid squares, R35 and R36, which encompass the proposal site, are included within the current known

range for sea lamprey (NPWS, 2019b). This distribution is based on records in freshwater habitats, but adult sea lamprey, and

transformers (intermediate stage between larvae and adult) occur in the Shannon Estuary.

The early life stages of this species require clean substrates in fast flowing freshwater habitats during spawning and ova development.

The proposed development will not adversely affect these habitats. The proposed development will not affect the attributes and

targets for this species, namely: distribution; population structure of juveniles; juvenile density in fine sediment, extent and distribution

of spawning habitat and availability of juvenile habitat.

It is considered that any potential water quality impacts will be localised in view of the localised nature, extent and scale of the

proposed works and the dilution potential of the River Shannon Estuary. There is therefore no potential for significant impacts to sea

lamprey, and as such ‘Sea lamprey’ will not considered further in the NIS.

Brook Lamprey

(Lampetra

planeri)

No

Unlike sea and river lamprey, brook lamprey is not parasitic and is non-migratory, spending its entire life in freshwater. Species

distribution within river catchments is dependent on the availability of suitable habitat; adults require fine sand/gravel areas in which to

spawn while the juvenile form needs clean, fine sediment into which to burrow (King, et al., 2011).

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Qualifying

Feature

Potential for

Significant Impacts Rationale

Given the characteristics and location of the project, and the exclusively freshwater ecology of this species, it is not considered that the

proposal has any potential to significantly impact on brook lamprey. Thus, the project will not affect the conservation objectives for

‘Brook Lamprey’ and the species is not considered further in the NIS.

River lamprey

(Lampetra

fluviatilis)

No

River lamprey has a similar life history to sea lamprey. River lampreys spend their adult life in marine and estuarine waters, living as

external parasites on other fish species. River lamprey is known to spawn within the lower Shannon and its tributaries (Kelly and King,

2001). The two 10km grid squares, R35 and R36, which encompass the proposal site, are included within the current known range for

river lamprey (NPWS, 2019b). This distribution is based on records in freshwater habitats, but adult river lamprey, and transformers

(intermediate stage between larvae and adult) occur in the Shannon Estuary.

It is considered that any potential water quality impacts will be localised in view of the localised nature, extent and scale of the

proposed works and the dilution potential of the River Shannon Estuary. The early life stages of this species require clean substrates in

fast flowing freshwater habitats during spawning and ova development. The proposed development will not adversely affect these

habitats. The proposed development will not affect the attributes and targets for this species, namely: distribution; population

structure of juveniles; juvenile density in fine sediment, extent and distribution of spawning habitat and availability of juvenile habitat.

There is therefore no potential for significant impacts to river lamprey, and as such ‘River lamprey’ will not considered further in the

NIS.

Atlantic Salmon

(Salmo salar) No

Salmon is an anadromous species, living in freshwater for at least the first two or three years of life before migrating to sea. Most Irish

fish spend one winter at sea before returning to their natal rivers. Salmon has been observed spawning in the lower Shannon and its

tributaries. The 10km grid square, R35, which encompasses the proposal site, is included within the current known range and

distribution for Atlantic salmon (NPWS, 2019b). This distribution is based on records in freshwater habitats. Adult salmon occur in the

Shannon Estuary prior to returning to natal streams to spawn, and smolts occur in the estuary on their journey from influent rivers to

the sea.

It is considered that any potential water quality impacts will be localised in view of the localised nature, extent and scale of the

proposed works, and the dilution potential of the River Shannon Estuary, therefore there is no potential for significant impacts to

salmon, and as such ‘Atlantic salmon’ is not considered further in the NIS.

Common

Bottlenose

Dolphin (Tursiops

No

There is a resident population of bottle-nosed dolphin in the Shannon Estuary. This is the only known resident population of this Annex

II species in Ireland. The majority of the Shannon Estuary is considered to comprise suitable habitat for this species, apart from the

inter-tidal areas of the Fergus Estuary and the inner estuary channel in the vicinity of Shannon town stretching east towards Limerick;

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Qualifying

Feature

Potential for

Significant Impacts Rationale

truncates) however, a review of on-line species records shows that sightings are concentrated in the outer channel. Within the SAC two ‘critical

areas’, representing habitat used preferentially by bottlenose dolphin, have been identified. These are located in the vicinity of

Tarbert/Killimer and further west towards the mouth of the estuary in the vicinity of Ballybunion and Kilcredaun Point (NPWS, 2012). A

review of studies (unpublished reports) available on the NPWS website on the Shannon Estuary bottlenose dolphin population

determined that previous surveys have focussed on the outer estuary channel, including these ‘critical areas’, rather than in the inner

estuary in the vicinity of Shannon and the proposed works.

Given the characteristics and location of the project including the localised nature, extent and scale of the proposed works, the dilution

potential of the River Shannon and estuary and the distribution of bottlenose dolphin habitat and records within the estuary, it is not

considered that the proposal has any potential to significantly impact on this species. Thus, the project will not affect the conservation

objectives for ‘Common Bottlenose Dolphin’ and the species is not considered further in the NIS.

Otter (Lutra

lutra) Yes

Otter are widespread in Ireland throughout freshwater and coastal habitats. Otter has two basic requirements: aquatic prey and safe

refuges in which to rest. In Ireland, otters are found along rivers, lakes and coasts, where fish and other prey are abundant, and where

the bank-side habitat offers sufficient cover. The presence of freshwater, a sufficient prey-base and suitable sites for holts/couches are

key factors in determining otter distribution.

The 10km grid square, R35, which encompasses the proposal site, is included within the current known range and distribution for otter

(NPWS, 2019b). A review of on-line records held by the NBDC determined that there are no records of otter within the vicinity of

Shannon Airport; however, based on the ubiquitous nature of this species and the abundance of suitable foraging and commuting

habitat in the area it is considered that otter are likely to occur in the general vicinity of the proposed works, and as such may be

subject to impacts. There is, therefore, potential for significant impacts to otter, and as such ‘Otter’ is to be considered further in the

NIS.

This evaluation has determined that certain habitats and species, which are listed as qualifying interests for the Natura 200 site, should be selected for further

assessment as plausible ecological receptors, as outlined in Table 7 above.

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7.1.3 Qualifying Features Selected for Further Assessment

7.1.3.1 Estuaries [1130]

The Shannon and Fergus Estuaries form the largest estuarine complex in Ireland. They form a unit

stretching from the upper tidal limits of the Shannon and Fergus Rivers to the mouth of the Shannon

Estuary.

Estuaries are semi-enclosed bodies of water which have a connection with the open sea and so are

subject to tidal influence while also having significant freshwater influence. They differ from other

coastal inlets, such as ‘large shallow inlets and bays’ in that there is dilution of seawater with

freshwater which results in permanent variability in salinity. Estuaries are frequently observed to be

composed of a range of distinct substrates stretching from the high water mark to the sub-tidal

zone. The high water points of estuaries are often formed from boulders/shingle and frequently

from man-made margins in urban areas. The intertidal flanks exposed to the forces that form the

estuarine habitat can be composed of deposited material such as sand and mud/silt. The estuarine

bed or channel is eroded to the greatest extent by the movement of the river channel and is

consequently generally coarse material or bedrock. The current conservation status for estuaries has

been assessed as ‘Inadequate’ (NPWS, 2019b).

The conservation objective is to maintain the favourable conservation condition of ‘Estuaries’ in the

Lower River Shannon cSAC, which is defined by the following list of attributes and targets.

Table 8. Attributes and targets for ‘Estuaries’ within the Lower Shannon SAC (NPWS, 2012a)

Attribute Measure Target/Notes

Habitat Area Hectares The permanent habitat area is stable or increasing, subject to natural processes.

Habitat area estimated as 24,273ha.

Community

Distribution Hectares

Conserve the following community types in a natural condition: Intertidal sand to

mixed sediment with polychaetes, molluscs and crustaceans community complex;

Estuarine sub-tidal muddy sand to mixed sediment with gammarids community

complex; Sub-tidal sand to mixed sediment with Nucula nucleus community

complex; Sub-tidal sand to mixed sediment with Nephtys spp. community

complex; Fucoid‐dominated intertidal reef community complex; Faunal

turf‐dominated sub-tidal reef community; and Anemone‐dominated sub-tidal reef

community.

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Figure 5 Distribution of estuaries within the Lower River Shannon cSAC (NPWS, 2012a)

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

These sediment habitats are found between the low water and mean high water tide marks. It is

often a sub-set of the Annex I habitats ‘large shallow inlets and bays’ and ‘estuaries’ but is not

dependent on those habitats for occurrence. The finer silt and clay sediments are dominant in

mudflats and the larger sand particles are associated with areas exposed to greater wave forces. A

range of physical pressures operate resulting in significant changes in salinity, temperature, and

exposure to air. The competing forces of seaward-flowing freshwater meeting the flooding tide

reduces net flow velocity and consequently the carrying capacity for sediment leading to deposition.

These sediments are often rich in nutrients. The depth of sediment habitat suitable for fauna is

limited by oxygen levels. Where tide and wave exposure conditions are suitable the sediment can

form into stable mixed sediment flats. The current conservation status for mudflats and sandflats

has been assessed as ‘Inadequate’ (NPWS, 2019b).

Conservation objectives are to maintain the favourable conservation condition of ‘Mudflats and

sandflats not covered by seawater at low tide’ in the Lower River Shannon cSAC, as defined by the

following attributes and targets.

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Table 9 Attributes and targets for ‘Mudflats and sand flats not covered by sea water at low tide’ within the Lower River Shannon cSAC (NPWS, 2012a)

Attribute Measure Target/Notes

Habitat Area Hectares The permanent habitat area is stable or increasing, subject to natural processes.

Habitat area estimated using OSi data as 8,808ha.

Community

Distribution Hectares

Conserve the following community types in a natural condition: Intertidal sand

with Scolelepis squamata and Pontocrates spp. community; and Intertidal sand

to mixed sediment with polychaetes, molluscs and crustaceans community

complex.

Figure 6 Distribution of mudflats and sandflats within the Lower River Shannon cSAC (NPWS, 2012a)

Two marine community types occur within the channel in the vicinity of Shannon Airport, as shown

in Figure 7 below. These are:

• Inter-tidal sand to mixed sediment with polychaetes, molluscs and crustaceans community

complex

• Sub-tidal sand to mixed sediment with Nephtys spp. community complex

7.1.3.2.1 Inter-tidal sand to mixed sediment with polychaetes, molluscs & crustaceans community

complex

This intertidal community is found extensively throughout the site. Mixed sediment is the dominant

sediment type within this community. The sediment type is highly variable throughout this

community evidenced by the wide ranges in sediment fractions (NPWS, 2012a). This community

type is mapped as occurring along the seaward face of the East Embankment.

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7.1.3.2.2 Sub-tidal sand to mixed sediment with Nephtys spp. community complex

This community complex occurs extensively east of Battle Island to Foynes; elsewhere it is recorded

from Labasheeda Bay, Clonderalaw Bay, Ballymacrinan Bay, Ballylongford Bay and Carrigaholt Bay.

The sediment of the complex is that of sand to mixed sediment with a great deal of variation within

the sediment fractions. The community is distinguished by the polychaete genera Nephtys spp.

NPWS, 2012a).

Figure 7 Distribution of marine community types within the inner Shannon Estuary (NPWS, 2012a)

7.1.3.3 Coastal Lagoons [1150]*

A coastal lagoon is defined as a lake or a pond that may be fully or partially separated from the sea

by a permeable barrier, which may be entirely natural (shingle) or unnatural (artificial barrier such as

an embankment). Salinity can vary greatly due to factors such as freshwater/saltwater inputs and

barrier permeability. Lagoons support unique assemblages of flora and fauna, in particular, a unique

assemblage of invertebrates. Typical species include Chara canescens, Chara baltica, Chara

connivens, Lamprothamnium papulosum, Palaemon adspersus and Ruppia maritima. Coastal lagoons

are a priority Annex I habitat. The current conservation status for coastal lagoons has been assessed

as ‘Bad’ (NPWS, 2019a). There are four coastal lagoons listed for the Lower River Shannon cSAC, as

outlined in Table 10 below.

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Table 10 ‘Coastal Lagoons’ within the Lower River Shannon cSAC (NPWS, 2012a)

Code Name County Salinity Conservation Assessment

IL031 Quayfield &

Poulaweala Loughs

Limerick Oligohaline/

polyhaline

Unfavourable - inadequate

IL032 Shannon Airport

Lagoon

Clare Oligohaline Unfavourable - Bad

IL033 Scattery Lagoon Clare Euhaline Unfavourable - inadequate

IL034 Cloonconeen Pool Clare Euhaline Unfavourable - inadequate

Figure 8 Shannon Airport Lagoon (NPWS, 2012a)

Shannon Airport Lagoon lies south-west of Shannon Airport at the landward side of the West

Embankment. The lagoon comprises an area of approximately 24ha. This artificial drainage lagoon is

separated from the sea by man-made barriers comprising the embankment and an access road. The

lagoon was developed in the 1940’s when a seawall was constructed out into the estuary to prevent

Shannon Airport from flooding. The water level in the lagoon is managed via a sluiced outlet through

which water drains via a drainage channel located in the lagoons north-western corner.

Conservation objectives are to restore the favourable conservation condition of ‘Coastal lagoons’ in

the Lower River Shannon cSAC, as defined by the following attributes and targets.

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Table 11 Attributes and targets for ‘Coastal lagoons’ within the Lower River Shannon cSAC (NPWS, 2012a)

Attribute Measure Target/Notes

Habitat area Hectares

Area stable or increasing subject to natural processes. Favourable

reference area 33.4ha ‐ Shannon Airport Lagoon 24.2ha;

Cloonconeen Pool 3.9ha; Scattery Lagoon 2.8ha; Quayfield and

Poulaweala Loughs 2.5ha.

Habitat distribution Occurrence No decline, subject to natural processes.

Salinity regime

Practical

salinity units

(psu)

Median annual salinity and temporal variation within natural

ranges. The lagoons in the site vary from oligohaline to euhaline.

Hydrological regime Metres Annual water level fluctuations and minima within natural ranges.

Lagoons listed for this site are all considered to be shallow.

Barrier connectivity:

between lagoon and

sea

Permeability

Appropriate hydrological connections between lagoons and sea,

including where necessary, appropriate management. The lagoons

within this site exhibit a variety of barrier types including

cobble/shingle, karst and artificial embankment.

Water quality:

Chlorophyll a µg/L

Annual median chlorophyll a within natural ranges and less than

5μg/L.

Water quality:

Molybdate Reactive

Phosphorous (MRP)

mg/L Annual median within natural ranges and <0.1mg/l.

Water quality:

Dissolved Inorganic

Nitrogen (DIN)

mg/L Annual median within natural ranges and <0.15mg/l.

Depth of macrophyte

colonisation Metres

Macrophyte colonisation to maximum depth of lagoons. As these

lagoons are all shallow, it is expected the macrophytes should

extend to their deepest points.

Typical plant species Number and m2 Maintain number and extent of listed lagoonal specialists, subject

to natural variation.

Typical animal

species Number

Maintain listed typical lagoonal specialists, subject to natural

variation.

Negative indicator

species

Number and %

cover Negative indicator species absent or under control.

7.1.3.4 Atlantic salt meadows (Glauco-Puccinellietalia maritimae) [1330]

Atlantic salt meadow generally occupies the widest part of the saltmarsh gradient. They also contain

a distinctive topography with an intricate network of creeks and salt pans occurring on the medium

to large sized salt marshes. Atlantic salt meadows contain several distinctive zones that are related

to elevation and submergence frequency. The lowest part along the tidal zone is generally

dominated by common saltmarsh-grass (Puccinellia maritima) with species like glassworts (Salicornia

spp.), annual seablite (Suaeda maritima) and lax-flowered sea-lavender (Limonium humile) also

important. The invasive common cordgrass (Spartina anglica) can be locally abundant in this habitat.

The mid-marsh zones are generally characterised by thrift (Armeria maritima) and/or sea plantain

(Plantago maritima).This zone is generally transitional to an upper marsh herbaceous community.

This habitat is also important for other wildlife including wintering waders and wildfowl. Atlantic salt

meadows are distributed around most of the coastline of Ireland. The intricate topography of the

Irish coastline with many inlets has created an abundance of sites that are sheltered and allow

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muddy sediments to accumulate, leading to the development of saltmarsh. The current conservation

status for Atlantic salt meadow has been assessed as ‘Inadequate’ (NPWS, 2012a).

Conservation objectives are to restore the favourable conservation condition of ‘Atlantic salt

meadows’ in the Lower River Shannon cSAC, as defined by the following attributes and targets.

Table 12 Attributes and targets for ‘Atlantic salt meadows’ within the Lower River Shannon cSAC (NPWS, 2012a)

Attribute Measure Target/Notes

Habitat area Hectares

Area stable or increasing, subject to natural processes,

including erosion and succession. For sub‐sites mapped:

Carrigafoyle‐ 6.774ha; Barrigone, Aughinish‐ 10.288ha; Beagh‐

0.517ha; Bunratty‐ 26.939ha; Shepperton, Fergus Estuary‐

37.925ha; Inishdea, Owenshere;‐ 18.127ha; Killadysert,

Inishcorker‐ 2.604ha; Knock‐ 0.576ha; Querin‐ 3.726ha;

Rinevilla Bay‐ 11.883ha.

Habitat distribution Occurrence No decline or change in habitat distribution, subject to natural

processes.

Physical structure:

sediment supply

Presence/absence of

physical barriers

Maintain natural circulation of sediments and organic matter,

without any physical obstructions

Physical structure:

creeks and pans Occurrence

Maintain creek and pan structure, subject to natural processes,

including erosion and succession

Physical structure:

flooding regime

Hectares flooded,

frequency Maintain natural tidal cycle

Vegetation

structure: zonation Occurrence

Maintain the range of coastal habitats including transitional

zones, subject to natural processes including erosion and

succession

Vegetation

structure:

vegetation height

Centimetres Maintain structural variation within sward

Vegetation

structure:

vegetation cover

Percentage cover at a

representative

sample

of monitoring stops

Maintain more than 90% of the saltmarsh area vegetated

Vegetation

composition:

typical species and

sub‐communities

Percentage cover at a

representative

sample

of monitoring stops

Maintain range of sub‐communities with typical species listed

in Saltmarsh Monitoring Project (McCorry and Ryle, 2009)

Vegetation

structure: negative

indicator species‐

Spartina anglica

Hectares No significant expansion of common cordgrass (Spartina

anglica), with an annual spread of less than 1%

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Figure 9 Distribution of saltmarsh habitats within the Lower River Shannon cSAC (NPWS, 2012a)

A review of habitat mapping and the coastal habitats supporting document available for the SAC

determined that of the ten sub-sites surveyed, mapped and assessed as part of the Saltmarsh

Monitoring Project (McCorry & Ryle, 2009) the closest site to the proposal site where ASM habitat is

mapped as occurring is the ‘Bunratty’ sub-site (SMP 0081)(NPWS, 2012a). Bunratty saltmarsh is

located in the upper part of the Shannon Estuary in Co. Clare, approximately 2.8km east of the

proposal area. Within the sub-site, ASM is the most extensive of all the saltmarsh habitats,

estimated to measure approximately 27ha. Typically it occurs within this sub-site as a narrow band

at the landward side of the brackish vegetation. However, potential ASM is mapped as occurring

along the shoreline extending westwards from this area as far as and immediately adjacent to the

northern extent of the East Embankment (NPWS, 2012a).

During habitat surveys undertaken for the proposed works in 2019 a previously mapped area of

potential Atlantic Salt Meadow ASM (1330) located to the north-east of the eastern embankment

was found to be dominated by reed and large sedge swamp (FS1) along and immediately out from

the embankment. However, two small areas of Upper salt-marsh (CM2) corresponding to Annex I

‘Atlantic salt meadow’ were identified to the south of this area, immediately adjacent to the East

Embankment towards its northern end.

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

Batrachion vegetation [3260]

This habitat-type, commonly known as ‘Vegetation of flowing waters’, is typically characterised by

species of water-crowfoot (Ranunculus spp.), pondweeds (Potamogeton spp.) and the moss

Fontinalius antipyretica and is present throughout the major river systems within the SAC. Although

the full distribution of this habitat and its sub-types within the SAC is currently unknown, it will occur

in most watercourses in Ireland. The highest riverine conservation interest is associated with

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lowland depositing and tidal rivers and unmodified, fast-flowing, low-nutrient rivers. River

connectivity with the floodplain is essential for the functioning of this habitat.

A number of rare submerged and marginal species are found in the former including opposite-leaved

pondweed (Groenlandia densa), starworts (e.g. Callitriche truncata), triangular club-rush

(Schoenoplectus triqueter), needle spike rush (Eleocharis acicularis) and mud-dwelling mosses (e.g.

Ephemerum spp.) (NPWS, 2019a). Review of the available data identifies three high conservation

elements (sub-types) in the site, namely:

1. Groenlandia densa (L.) Fourr., Opposite-leaved Pondweed;

2. Schoenoplectus triqueter (L.) Palla, Triangular Club-rush;

3. Bryophyte-rich streams and rivers.

The sub-types of this habitat are poorly understood and their typical species have not yet been

defined. The typical species may include higher plants, bryophytes, macroalgae, and microalgae. The

first two sub-types are associated with tidal reaches of rivers, while the latter sub-type is found in

fast-flowing stretches of unmodified streams and rivers. In addition to these three sub-types, it is

likely that other high conservation value sub-types exist within the site (NPWS, 2012a).

Table 13 Attributes and targets for ‘Vegetation of flowing waters’ within the Lower River Shannon cSAC (NPWS, 2012a)

Attribute Measure Target/Notes

Habitat area Kilometres

Area stable or increasing, subject to natural processes. Three

sub‐types of high conservation value are known to occur in the

site

Habitat distribution Occurrence No decline, subject to natural processes.

Hydrological regime:

river flow Metres per second Maintain appropriate hydrological regimes

Hydrological regime:

tidal influence

Daily water level

fluctuations ‐

metres

Maintain natural tidal regime

Hydrological regime:

freshwater seepages Metres per second Maintain appropriate freshwater seepage regimes

Substratum

composition:

particle size range

Millimetres

The substratum should be dominated by the particle size

ranges, appropriate to the habitat sub‐type (frequently sands,

gravels and cobbles)

Water quality:

nutrients

Milligrammes per

litre

The concentration of nutrients in the water column should be

sufficiently low to prevent changes in species composition or

habitat condition. The specific targets may vary among sub‐

types

Vegetation

composition:

typical species

Occurrence Typical species of the relevant habitat sub‐type should be

present and in good condition

Floodplain

connectivity Area

The area of active floodplain at and upstream of the habitat

should be maintained

Riparian habitat Area The area of riparian woodland at and upstream of the

bryophyte‐rich sub‐type should be maintained

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Figure 10 Distribution of floating river vegetation within the Lower River Shannon cSAC (NPWS, 2012a)

The current conservation status of floating river vegetation is considered ‘Inadequate’ (NPWS,

2019a). Conservation objectives are to maintain the favourable conservation condition of ‘Water

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

vegetation’ in the Lower River Shannon cSAC, as defined by the following attributes and targets.

In Ireland, the Groenlandia densa sub-type is associated with tidal reaches of rivers and other

periodically disturbed watercourses (e.g. canals and drains) (NPWS, 2012a). Groenlandia densa was

identified within a drainage channel associated with the Shannon Airport Lagoon during habitat

surveys carried out on-site.

7.1.3.6 Otter [1355]

Otters are found in a variety of aquatic habitats in Ireland such as lakes, rivers, streams, estuaries,

marshland, and canals and along the coast. Their preferred habitat has good cover of vegetation,

such as scrub with a herbaceous under layer. Because otters are mainly nocturnal they require

access to safe refuges to use as denning sites, known as holts, within which they remain for most of

the day. Holts are the main den locations used by otters and these are most commonly situated

underground along a river’s bank or among the root systems of trees. Several holts will be located

within an individual’s territory and lying up sites known as couches will also be used at ground level

within vegetated areas. In freshwater areas, a variety of fish from sticklebacks to salmon and eels

will be taken, while crayfish and frogs can be important locally or seasonally.

Otters maintain territories and will defend their stretches of river bank or lake shore from other

individuals. Territories are only held against members of the same sex, so those of males and

females may overlap (Erlinge, 1968). In lowland rivers and fish-rich lakes, otters only need to

Shannon Airport

Embankments

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maintain small territories. The breeding season is variable, with a peak of births from May to August

– though cubs may be born at any time of year.

While no otter holts were identified along the stretch of the Shannon River Estuary within 50m of

the proposed development site, results of the ecological field survey (see Section 5.6 above)

indicated that otters may potentially utilise habitats in the vicinity of the proposed development site

due to their suitability for this species. The shoreline in the general area of the proposal site and

extending along the banks of the Shannon River, and of islands in the main channel, is mapped as

‘commuting buffer’ within the Conservation Objectives for the Lower River Shannon cSAC (NPWS,

2012a).

The current conservation status of otter is considered ‘Favourable’ (NPWS, 2012b). Conservation

objectives are to restore the favourable conservation condition of ‘Otter’ in the Lower River Shannon

cSAC (only in fresh water), as defined by the following attributes and targets:

Table 14 Attributes and targets of otter within the Lower River Shannon cSAC (NPWS, 2012a)

Attribute Measure Target/Notes

Distribution Percentage positive survey

sites No significant decline

Extent of

terrestrial habitat Hectares

No significant decline. Area mapped and calculated as

596.8ha above high water mark (HWM); 958.9ha along

river banks/ around ponds. No field survey. Areas mapped

to include 10m terrestrial buffer along shoreline (above

HWM and along river banks) identified as critical for

otters

Extent of marine

habitat Hectares

No significant decline. Area mapped and calculated as

4,461.6ha. No field survey. Area mapped based on

evidence that otters tend to forage within 80m of the

shoreline (HWM)

Extent of

freshwater (river)

habitat

Kilometres

No significant decline. Length mapped and calculated as

500.1km. No field survey. River length calculated on the

basis that otters will utilise freshwater habitats from

estuary to headwaters

Extent of

freshwater

(lake/lagoon)

habitat

Hectares

No significant decline. Area mapped and calculated as

125.6ha. No field survey. Area mapped based on evidence

that otters tend to forage within 80m of the shoreline

Couching sites

and holts Number

No significant decline. Otters need lying up areas

throughout their territory where they are secure from

disturbance

Fish biomass

available Kilograms

No significant decline. Broad diet that varies locally and

seasonally, but dominated by fish, in particular salmonids,

eels and sticklebacks in freshwater and wrasse and

rockling in coastal waters

Barriers to

connectivity Number

No significant increase. Otters will regularly commute

across stretches of open water up to 500m. E.g. between

the mainland and an island; between two islands; across

an estuary. It is important that such commuting routes

are not obstructed

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Figure 11 Extent of mapped ‘commuting buffer’ for otter within the Lower River Shannon cSAC

(NPWS, 2012a)

7.2 RIVER SHANNON AND RIVER FERGUS ESTUARIES SPA (004077)

7.2.1 Description of the Natura 2000 Site

The estuaries of the River Shannon and River Fergus form the largest estuarine complex in Ireland.

The site comprises the entire estuarine habitat from Limerick City westwards as far as Doonaha in

Co. Clare and Dooneen Point in Co. Kerry. The site has vast expanses of intertidal flats which contain

a diverse macro-invertebrate community, e.g. Macoma-Scrobicularia-Nereis, which provides a rich

food resource for the wintering birds. Salt marsh vegetation frequently fringes the mudflats and this

provides important high tide roost areas for the wintering birds. Elsewhere in the site the shoreline

comprises stony or shingle beaches.

The site is selected as a Special Protection Area because it regularly supports over 20,000 waterbirds

during the non-breeding season making this a site of international importance. The site regularly

supports in excess of 50,000 wintering waterfowl (57,133 - five year mean for the period 1995/96 to

1999/2000) making it one of the most important coastal sites in the country. The E.U. Birds Directive

pays particular attention to wetlands and, as these form part of this SPA, the site and its associated

waterbirds are of special conservation interest for Wetland & Waterbirds. The site holds

internationally important populations of three species, namely dunlin (C. alpina), light bellied Brent

goose (B. bernicla hrota) and whooper swan (C. cygnus)(I-WeBS: Waterbird Monitoring 2015/16).

The remaining 18 species have populations of national importance. The site previously supported an

internationally-important population of black-tailed godwit (L. limosa), now listed as nationally-

Shannon Airport

Embankments

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important27. Of particular note is that three of the species which occur regularly are listed on Annex I

of the E.U. Birds Directive, i.e. whooper swan, golden plover and bar-tailed godwit.

This is the most important coastal site in Ireland for a number of the waders including lapwing,

dunlin, snipe and redshank. It also provides an important staging ground for species such as black-

tailed godwit and greenshank. The site also supports a nationally important breeding population of

cormorant (93 pairs in 2010). Other species that occur include mute swan, mallard, red-breasted

merganser, great-crested grebe, grey heron, oystercatcher, turnstone and common gull. Apart from

the wintering birds, large numbers of some species also pass through the site whilst on migration in

spring and/or autumn (adapted from River Shannon and River Fergus Estuaries SPA 004077 Site

Synopsis). This site is a designated Special Protection Area (SPA) under the E.U. Birds Directive for

the special conservation interest of the following features of interest:

• Cormorant (Phalacrocorax carbo) [A017]

• Whooper Swan (Cygnus cygnus) [A038]

• Light-bellied Brent Goose (Branta bernicla hrota) [A046]

• Shelduck (Tadorna tadorna) [A048]

• Wigeon (Anas penelope) [A050]

• Teal (Anas crecca) [A052]

• Pintail (Anas acuta) [A054]

• Shoveler (Anas clypeata) [A056]

• Scaup (Aythya marila) [A062]

• Ringed Plover (Charadrius hiaticula) [A137]

• Golden Plover (Pluvialis apricaria) [A140]

• Grey Plover (Pluvialis squatarola) [A141]

• Lapwing (Vanellus vanellus) [A142]

• Knot (Calidris canutus) [A143]

• Dunlin (Calidris alpina) [A149]

• Black-tailed Godwit (Limosa limosa) [A156]

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

• Curlew (Numenius arquata) [A160]

• Redshank (Tringa totanus) [A162]

• Greenshank (Tringa nebularia) [A164]

• Black-headed Gull (Chroicocephalus ridibundus) [A179]

• Wetland and Waterbirds [A999]

Species vary considerably in different aspects of their ecology with regards to trophic (foraging)

guild, food/prey requirements, principal supporting habitat within the site, ability to use alternative

habitats within the site and site fidelity/faithfulness (NPWS, 2012b). Species will vary in this use of

habitats within a site. This may vary between times of day, seasons and between different sites. The

following table outlines the ecological characteristics, requirements and specialities for non-

breeding waterbird SCIs within the River Shannon and River Fergus Estuaries SPA (table adapted

from NPWS, 2012b).

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Table 15 Ecological Characteristics, requirements and specialities of non-breeding waterbird SCI species for River Shannon and River Fergus Estuaries SPA28

Species DistributionA Trophic GuildB

Food Prey RequirementsC

Principal Habitat within siteD Ability to use alternative

habitatsE

Bar-tailed godwit Localised 4 Wide Intertidal mud/sand flats 2

Black-headed gull N/C 1,2,4,6,7 Wide Intertidal flats and shallow and sheltered subtidal 2

Black-tailed godwit Localised 4 Wide Intertidal mud/sand flats 2

Cormorant Widespread 3 Highly specialised Sheltered and shallow subtidal 1

Curlew Widespread 4 Wide Intertidal mud/sand flats 2

Dunlin Intermediate 4 Wide Intertidal mud/sand flats 3

Golden plover Intermediate 4 Wide Intertidal mud/sand flats 2

Green shank Intermediate 6 Wide Intertidal mud/sand flats 3

Grey plover Localised 4 Wide Intertidal mud/sand flats 3

Knot Localised 4 Narrower Intertidal mud/sand flats 3

lapwing Widespread 4 Wide Intertidal mud/sand flats 2

Light-bellied Brent Goose Localised 1,5,7 Highly specialised Intertidal mud/sand flats 2

Red shank Intermediate 4 Wide Intertidal flats and sheltered shallow subtidal 2

Ringed Plover Localised 4 Wide Intertidal mud/sand flats 3

Pintail Localised 1 Wide Intertidal mud/sand flats, sheltered and shallow subtidal 2

Scaup Highly Restricted 2 Wide Subtidal 1

Shelduck Localised 1,5 Wide Intertidal mud/sand flats, shallow subtidal 3

Shoveler Localised 1 Wide Lagoon, brackish and freshwater lakes, plus intertidal sand and mud flats 3

Teal Widespread 1 Wide Intertidal mud/sand flats, shallow subtidal and lagoons 3

Whooper Swan Widespread 1,7 Wide Lagoon and associated habitats, intertidal mudflats and shallow subtidal 2

Wigeon Widespread 1,5 Narrower Intertidal mud/sand flats, sheltered and shallow subtidal lagoons 2

A: Distribution – Very Widespread (>300 sites), Widespread (200-300 sites), Intermediate (100-200 sites), Localised (50-100 sites), Highly Restricted (<50 sites) (based on Boland & Crowe, 2012)

B: Trophic Guild – 1= surface swimmer, 2= water column diver (Shallow), 3= water column diver (deeper), 4/5= Intertidal walker (out of water), 6= Intertidal walker (in water), 7= terrestrial walker

C: Food/Prey Requirements – species with a wide prey/food range, a narrow prey range (e.g. a species that forage upon a few species/taxa only), and species with highly specialised foraging

requirements (e.g. piscivores)

D: Principal Supporting Habitat present within the SPA (Note that this is the main habitat used when foraging with the exception of Whooper Swan that utilise wetland habitats for roosting and forage

within terrestrial grasslands outside of the SPA)

E: Ability to Use Alternative Habitat – refers to the species ability to utilise other habitats adjacent to the site: 1= wide-ranging species, 2= reliant on site but highly likely to use alternative habitat at

certain times (e.g. high tide), 3= considered totally reliant on wetland habitats due to unsuitable surrounding habitats and/or species limited by habitat requirements

F: Site fidelity on non-breeding grounds: Unknown; Weak; Moderate; or High.

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7.2.2 Identification of Potential for Significant Impacts to Qualifying Features

Bearing in mind the scope, scale, nature and size of the project, its location relative to the

distribution of the species and habitats listed and the degree of connectedness that exists between

the project and the potential receptors, it is considered that not all features of interest are within

the zone of potential impact of the proposal. An evaluation based on these factors to determine

which species and habitats are the plausible ecological receptors for potential impacts of the

unmitigated proposal has been conducted below.

The following table lists the qualifying features of the River Shannon and River Fergus Estuaries SPA

and evaluates through a scientific examination of evidence and data whether or not these features

should or should not be selected for further assessment in the NIS. The qualifying features that are

selected for further assessment are then discussed further followed by an assessment of potentially

significant effects arising from the proposed development.

Table 16 Identification of potential for significant impacts to qualifying features of the River Shannon &

Fergus River Estuaries SPA

Qualifying Feature

Potential

for

Significant

Impacts

Rationale

Cormorant

(Phalacrocorax

carbo)

Yes

A review of waterbird distribution for SCI species within the SPA

carried out as part of the sub-site assessments for the 2010/11

Waterbird Survey Programme, as outlined in NPWS (2012b)

determined that cormorant was recorded within the vicinity of the

proposal site (0H511, 0H512). Based on this, this species is considered

to be within the zone of potential influence of the proposal and will be

considered further in the NIS.

Whooper swan

(Cygnus cygnus) Yes

Relatively few intertidal/sub-tidal observations of whooper swan were

made during the 2010/11 surveys (no records of foraging whooper

swan within the vicinity of the proposal site). Whooper swan were

recorded roosting at Shannon Airport Lagoon (0H509) in October 2011.

Shannon Airport Lagoon has been noted previously as a regularly-used

site during autumn (Robinson et al. 2004a).

A review of waterbird distribution for SCI species within the SPA

carried out as part of the sub-site assessments for the 2010/11

Waterbird Survey Programme, as outlined in NPWS (2012b)

determined that whooper swan was recorded within the vicinity of the

proposal site (0H509). Based on this, this species is considered to be

within the zone of potential influence of the proposal and will be

considered further in the NIS.

Light-bellied brent

goose (Branta

bernicla hrota)

No

The site is designated for wintering light-bellied Brent goose. This

species is amber-listed as the majority winter at less than ten sites and

the Irish population is also internationally significant. It winters on

coastal estuaries during the autumn and early winter as well as on

grasslands from mid-winter before departing to breeding grounds in

Canada in late April. Brent Geese are grazers and are known for their

preference for foraging in intertidal areas with the Eelgrass Zostera sp.

(Robinson et al. 2004b). Where this food source is absent the birds

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Qualifying Feature

Potential

for

Significant

Impacts

Rationale

feed upon algae and saltmarsh plants and the species also grazes

terrestrially.

A review of waterbird distribution for SCI species within the SPA

carried out as part of the sub-site assessments for the 2010/11

Waterbird Survey Programme, as outlined in NPWS (2012b),

determined that Brent geese exhibited a relatively restricted

distribution occurring in only seven sub-sites, and were associated

mostly with the outer section of the site. There were no records of

foraging or roosting Brent Geese within the vicinity of the proposal

site. Based on this, this species is not considered to be within the zone

of potential influence of the proposal and will not be considered

further in the NIS.

Shelduck (Tadorna

tadorna) Yes

A review of waterbird distribution for SCI species within the SPA

carried out as part of the sub-site assessments for the 2010/11

Waterbird Survey Programme, as outlined in NPWS (2012b)

determined that shelduck was recorded within the vicinity of the

proposal site (0H510, 0H511, 0H512). Based on this, this species is

considered to be within the zone of potential influence of the proposal

and will be considered further in the NIS.

Wigeon (Anas

penelope) Yes

A review of waterbird distribution for SCI species within the SPA

carried out as part of the sub-site assessments for the 2010/11

Waterbird Survey Programme, as outlined in NPWS (2012b)

determined that wigeon was recorded within the vicinity of the

proposal site (0H509 – including birds foraging at the Shannon Airport

Lagoon, 0H511, 0H510, 0H512). Based on this, this species is

considered to be within the zone of potential influence of the proposal

and will be considered further in the NIS.

Teal (Anas crecca) Yes

A review of waterbird distribution for SCI species within the SPA

carried out as part of the sub-site assessments for the 2010/11

Waterbird Survey Programme, as outlined in NPWS (2012b)

determined that teal was recorded within the vicinity of the proposal

site (0H509 – including birds foraging at the Shannon Airport Lagoon,

0H512). Based on this, this species is considered to be within the zone

of potential influence of the proposal and will be considered further in

the NIS.

Pintail (Anas acuta) No

Pintail is red-listed due to a decline in its non-breeding (wintering)

population. It is an extremely rare breeding species with records from

the Midlands and north (Dempsey and O’ Cleary, 2002). Wintering

takes places primarily within estuaries or coastal brackish lagoons.

Pintail feed on a variety of plant and animal material obtained from

shallow water although they can be observed foraging on land.

A review of waterbird distribution for SCI species within the SPA

carried out as part of the sub-site assessments for the 2010/11

Waterbird Survey Programme, as outlined in NPWS (2012b)

determined that pintail was recorded in only two sub-sites: 0H519

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Qualifying Feature

Potential

for

Significant

Impacts

Rationale

(Poulnasherry outer bay) and 0K509 (Carrig Island), both in the outer

section of the site. Based on this, this species is not considered to be

within the zone of potential influence of the proposal and will not be

considered further in the NIS.

Shoveler (Anas

clypeata) Yes

A review of waterbird distribution for SCI species within the SPA

carried out as part of the sub-site assessments for the 2010/11

Waterbird Survey Programme, as outlined in NPWS (2012b)

determined that shoveler was recorded in six sub-sites overall

including 0H509 (otherwise known as Shannon Airport Lagoon), where

peak numbers were recorded during low tide surveys. Shoveler was

also recorded here during high tide surveys. Low numbers of shoveler

in roosting/other behaviour were also recorded within 0H509

(Shannon Airport Lagoon). Based on this, this species is considered to

be within the zone of potential influence of the proposal and will be

considered further in the NIS.

Scaup (Aythya

marila) No

Scaup are a winter visitor to Ireland, arriving from breeding sites to the

north between November and April to coastal areas, estuaries,

brackish lagoons and freshwater lakes close to the coast. They forage

in sub-tidal areas, diving to hunt for molluscs and crustaceans as well

as feeding on marine plants in areas typically with a depth of less than

10m. Scaup is amber-listed for its small breeding population and its

localised wintering range.

A review of waterbird distribution for SCI species within the SPA

carried out as part of the sub-site assessments for the 2010/11

Waterbird Survey Programme, as outlined in NPWS (2012b)

determined that scaup was recorded in only three sub-sites: 0H519

(Poulnasherry outer bay), 0H521 (Clonderlaw Bay outer) and 0H522

(Clonderlaw Bay inner). Based on this, this species is not considered to

be within the zone of potential influence of the proposal and will not

be considered further in the NIS.

Ringed plover

(Charadrius hiaticula) No

Ringed plovers are ‘visual foragers’ searching the sediment surface for

the visible signs of prey such as worms, crustaceans and insects. A

substantial proportion of ringed plovers occur on non-estuarine coasts,

the species exhibiting a degree of plasticity in habitat choice and being

found in habitats such as shingle shores, saltmarsh and short grassland

as well as artificial habitats. Ringed plover is amber-listed as

internationally important numbers winter in Ireland. They breed on

shingle and sandy beaches (Dempsey and O’Cleary, 2002) and rough

ground around the coast. They are found in the outer estuary on

intertidal mudflats.

A review of waterbird distribution for SCI species within the SPA

carried out as part of the sub-site assessments for the 2010/11

Waterbird Survey Programme, as outlined in NPWS (2012b)

determined that ringed plover was not recorded anywhere in the

vicinity of the proposal site. Based on this, this species is not

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Qualifying Feature

Potential

for

Significant

Impacts

Rationale

considered to be within the zone of potential influence of the proposal

and will not be considered further in the NIS.

Golden plover

(Pluvialis apricaria) Yes

A review of waterbird distribution for SCI species within the SPA

carried out as part of the sub-site assessments for the 2010/11

Waterbird Survey Programme, as outlined in NPWS (2012b)

determined that golden plover was recorded regularly (three low tide

surveys or more) within 12 sub-sites including 0H512 (Connor's Rock),

where significant numbers (>1500 individuals) were recorded. Based

on this, this species is considered to be within the zone of potential

influence of the proposal and will be considered further in the NIS.

Grey plover (Pluvialis

squatarola) Yes

A review of waterbird distribution for SCI species within the SPA

carried out as part of the sub-site assessments for the 2010/11

Waterbird Survey Programme, as outlined in NPWS (2012b)

determined that grey plover was recorded regularly (three low tide

surveys or more) within 0H510. The February 2011 roost survey

recorded birds in 0H511 (Rinnanna South) in the inner estuary.

Supratidal roosting was recorded in 0H512 (Connor's Rock). Based on

this, this species is considered to be within the zone of potential

influence of the proposal and will be considered further in the NIS.

Lapwing (Vanellus

vanellus) Yes

A review of waterbird distribution for SCI species within the SPA

carried out as part of the sub-site assessments for the 2010/11

Waterbird Survey Programme, as outlined in NPWS (2012b)

determined that lapwing was regularly recorded foraging inter-tidally

in 0H512 (Connor's Rock). This sub-site also supported roosting birds.

Lapwings were also recorded in 0H510 and 0H511. Based on this, this

species is considered to be within the zone of potential influence of the

proposal and will be considered further in the NIS.

Knot (Calidris

canutus) Yes

A review of waterbird distribution for SCI species within the SPA

carried out as part of the sub-site assessments for the 2010/11

Waterbird Survey Programme, as outlined in NPWS (2012b)

determined that knot was recorded in the sub-sites 0H510, 0H511 and

0H512. Based on this, this species is considered to be within the zone

of potential influence of the proposal and will be considered further in

the NIS.

Dunlin (Calidris

alpina) Yes

A review of waterbird distribution for SCI species within the SPA

carried out as part of the sub-site assessments for the 2010/11

Waterbird Survey Programme, as outlined in NPWS (2012 4077 CO

supp doc) suggest that dunlin have a widespread foraging distribution

across the site and as a versatile species, they are likely to exploit a

variety of intertidal food resources. Dunlin was found to occur regularly

during low tide surveys within sub-sites 0H510 and 0H512. Dunlin was

also recorded in 0H511. Based on this, this species is considered to be

within the zone of potential influence of the proposal and will be

considered further in the NIS.

Black-tailed godwit

(Limosa limosa) Yes

A review of waterbird distribution for SCI species within the SPA

carried out as part of the sub-site assessments for the 2010/11

Waterbird Survey Programme, as outlined in NPWS (2012b) found that

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Qualifying Feature

Potential

for

Significant

Impacts

Rationale

black-tailed godwits were relatively widespread in their distribution

within the site. The species was found to occur in all four sub-sites in

the vicinity of the works.

They were found to occur regularly within 0H510 (Brackinish Rock to

Carrigkeal) with peak numbers recorded during low tide surveys.

0H512 (Connor’s Rock) held peak numbers during low tide surveys in

October. 0H509 (Golf Tee- Shannon), otherwise known as Shannon

Airport Lagoon, held 1,068 foraging individuals during the October

2010 low tide survey. Terrestrial foraging, outside of the SPA boundary,

was not recorded regularly but is likely to be widespread around the

site. Records of black-tailed godwits in roosting/other behaviour during

low tide surveys were irregular (of note was the count of 2,400

roosting within 0H512 (Connor's Rock) on 21/10/10. Although

relatively versatile in terms of habitat choice, black-tailed godwits are

generally found in muddier sediments within inner estuaries, favouring

biotopes that support favoured prey such as bivalves Macoma balthica,

Scrobicularia plana or polychaete Hediste diversicolor. This is in

agreement with the pattern of distribution noted above i.e. the

preference for inner estuary sub-sites. Based on this, this species is

considered to be within the zone of potential influence of the proposal

and will be considered further in the NIS.

Bar-tailed godwit

(Limosa lapponica) No

Bar-tailed godwits forage by probing within intertidal sediment for

invertebrate species, predominantly large polychaete worms such as

Arenicola marina and Nepthys sp. They often feed at the tide edge with

their heads in water. The species is characteristic of sites with sandy

substrates (e.g. Hill et al. 1993) or sections of a site that have sandy (as

opposed to muddy) sediment. The dominant intertidal benthic

community type across the site is ‘intertidal sand to mixed sediment

with polychaetes, molluscs and crustaceans’ (NPWS, 2012b). This

broad community type has a wide variability in sediment type from

gravel to fine sand to muds. Of note are high abundances of Nephtys

hombergii that occur from the lower Fergus Estuary westwards, this

polychaete a known prey species of bar-tailed godwits. The bar-tailed

godwit is amber-listed in Ireland as the majority winter at less than ten

sites.

A review of waterbird distribution for SCI species within the SPA

carried out as part of the sub-site assessments for the 2010/11

Waterbird Survey Programme, as outlined in NPWS (2012b) found bar-

tailed godwits to have a relatively restricted foraging distribution

within the site. They were not recorded in any of the sub-sites in the

vicinity of the proposal site. Based on this, this species is not

considered to be within the zone of potential influence of the proposal

and will not be considered further in the NIS.

Curlew (Numenius

arquata) Yes

A review of waterbird distribution for SCI species within the SPA

carried out as part of the sub-site assessments for the 2010/11

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Qualifying Feature

Potential

for

Significant

Impacts

Rationale

Waterbird Survey Programme, as outlined in NPWS (2012b) found that

curlew exhibited a widespread foraging distribution across the site.

Curlews were recorded in the sub-sites 0H510, 0H511 and 0H512.

Based on this, this species is considered to be within the zone of

potential influence of the proposal and will be considered further in

the NIS.

Redshank (Tringa

totanus) Yes

A review of waterbird distribution for SCI species within the SPA

carried out as part of the sub-site assessments for the 2010/11

Waterbird Survey Programme, as outlined in NPWS (2012b) found that

redshank to be widespread within the site. Redshanks were recorded

roosting in the sub-site 0H511 (Rinnanna South) where a single

intertidal roost of 90 individuals was recorded. Redshanks were

recorded regularly (three or more low tide surveys) in 0H512.

Redshank was also recorded in 0H510. Based on this, this species is

considered to be within the zone of potential influence of the proposal

and will be considered further in the NIS.

Greenshank (Tringa

nebularia) Yes

A review of waterbird distribution for SCI species within the SPA

carried out as part of the sub-site assessments for the 2010/11

Waterbird Survey Programme, as outlined in NPWS (2012b)

determined that greenshank were recorded in the sub-site 0H512.

Based on this, this species is considered to be within the zone of

potential influence of the proposal and will be considered further in

the NIS.

Black-headed gull

(Chroicocephalus

ridibundus)

Yes

A review of waterbird distribution for SCI species within the SPA

carried out as part of the sub-site assessments for the 2010/11

Waterbird Survey Programme, as outlined in NPWS (2012b)

determined that black-headed gull was recorded in all four sub-sites in

the vicinity of the works (0H509, 0H510, 0H511 and 0H512). Based on

this, this species is considered to be within the zone of potential

influence of the proposal and will be considered further in the NIS.

Wetlands &

waterbirds Yes

The River Shannon and River Fergus Estuaries SPA is designated for the

protection of ‘Wetlands’. The proposed works will result in an increase

in the overall footprint of both embankments. There is spatial overlap

between the proposal site and the SPA. Therefore, there is potential

for direct/indirect impacts to wetland habitat within the River Shannon

and River Fergus Estuaries SPA, and as such ‘Wetlands’ will be

considered further in the NIS.

This evaluation has determined that certain habitats and species, which are listed as qualifying

interests for the Natura 200 site, should be selected for further assessment as plausible ecological

receptors, as outlined in Table 20 above.

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7.2.3 Qualifying Features Selected for Further Assessment

7.2.3.1 Cormorant (Phalacrocorax carbo)

Cormorant is a resident species in Ireland occurring along the coast and breeding in colonies mainly

on off-shore islands and rocky coast-lines although there are some inland breeding populations. This

diving species feeds on fish, foraging mainly in shallow waters (<30m depth) and may roost in inter-

tidal or supra-tidal areas. The species is amber-listed in Ireland due to a localised breeding

population. Cormorant is the only qualifying species with a breeding population within the River

Shannon and River Fergus Estuaries SPA (NPWS, 2012b).

Conservation objectives are to maintain the favourable conservation condition of ‘Cormorant’ in the

River Shannon and River Fergus Estuaries SPA, as defined by the following attributes and targets.

Table 17 Attributes and targets of cormorant in the River Shannon and River Fergus estuaries SPA (NPWS, 2012b)

Attribute Measure Target/Notes

Breeding population

abundance: apparently

occupied nest (AONs)

Number No significant decline.

Productivity rate Mean number No significant decline.

Distribution: breeding

colonies

Number, location,

area (hectares) No significant decline.

Prey biomass available Kilograms No significant decline.

Barriers to connectivity

Number, location,

shape, area

(hectares)

No significant increase.

Disturbance at breeding

site Level of impact

Human activities should occur at levels that do not

adversely affect the breeding cormorant population

Population trend Percentage change Long term population trend stable or increasing

Distribution

Range, timing and

intensity of use of

areas

There should be no significant decrease in the range,

timing or intensity of use of areas by cormorant other

than that occurring from natural patterns of variation

7.2.3.2 Whooper swan (Cygnus cygnus)

The site is designated for wintering whooper swan that visits lakes and marshes and can be found

grazing in fields and slob lands. Birds arrive in Ireland in late autumn and leave by mid-April and a

few may remain throughout the summer (Dempsey and O’Cleary, 2002). Whooper swan tends to

congregate at discrete and safe wetland sites during the evening to roost, and disperse by day to

forage. They are primarily herbivorous, feeding on aquatic plants, grasses and agricultural plants

such as grain, vegetables and stubble. Whooper swans that spend the winter at the Shannon and

Fergus estuaries complex forage primarily outside of the SPA boundary NPWS (2012b). Whooper

swan is amber-listed as Ireland hosts more than 20% of the European wintering population.

7.2.3.3 Shelduck (Tadorna tadorna)

Shelduck is amber-listed in Ireland as the majority of the wintering population occurs at less than ten

sites. Shelduck nest on islands and grassy embankments of the estuary. In July the adults depart to

the Waddenzee to moult returning to the Shannon Estuary in November. Shelduck forage in a

variety of ways from scything their bill through wet mud on exposed tidal flats, to dabbling and

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scything in shallow water and up-ending in deeper waters. They can therefore forage throughout the

tidal cycle. The benthic community of the Fergus Estuary and Poulnasherry Bay is assigned the broad

classification ‘Intertidal sand to mixed sediment with polychaetes, molluscs and crustaceans’ (NPWS,

2012b). The gastropod mollusc Hydrobia ulvae, a favoured prey of shelduck, is a distinguishing

invertebrate of this community, occurring in moderate to high abundances.

7.2.3.4 Wigeon (Anas penelope)

Wigeon is red-listed due to a decline in its non-breeding (wintering) population. Wigeon are highly-

migratory, arriving to Ireland in August/September and wintering in ponds and flooded fields around

the estuary .Their diet is almost entirely vegetarian and a major part of the diet comprises seagrass

and algae species which are taken by grazing or dabbling in shallow water. Wigeon also forage within

grasslands and agricultural crops for seeds, stems and rhizomes. A gregarious bird, they are rarely

seen far from water.

7.2.3.5 Teal (Anas crecca)

Teal are largely migratory, moving south of their breeding range during winter. Being highly

responsive to cold spells they can show rapid and extensive movement during these periods. Teal is

amber-listed due to a decline in the breeding population. Teal is a very common winter visitor to the

estuary. They are omnivorous and have a variety of foraging methods (e.g. dabbling and up-ending)

within differing habitats. Areas of shallow water are favoured including shallow estuaries, tidal

creeks and the edges of salt and freshwater marsh.

7.2.3.6 Shoveler (Anas clypeata)

The small numbers of shoveler breeding in Ireland are largely sedentary or dispersive and are

supplemented during winter by migratory birds from other locations within northwest and central

Europe. Shovelers are omnivorous, taking a range of items from planktonic crustaceans and small

molluscs, to insects, larvae, plant material and seeds. A true dabbling duck, shovelers feed by

surface-feeding, swimming with head and neck immersed, up-ending, and less often, by shallow

dives. Shoveler is red-listed due to a decline in its non-breeding (wintering) population.

7.2.3.7 Golden plover (Pluvialis apricaria)

During winter, golden plovers feed primarily within agricultural grassland and arable land. Tidal flats

are used more as a roosting/resting habitat and the birds tend to favour large, open tidal flats. As a

consequence, golden plovers tend to be in large aggregations when observed upon tidal flats.

Intertidal feeding is observed to a greater degree during cold weather periods when grassland

feeding areas are frozen over. Although golden plovers eat a wide range of invertebrate species,

relatively little is known about intertidal feeding patterns (Gillings et al. 2006). Golden plover is red-

listed as a breeding species due to a decline in the breeding and non-breeding (wintering)

population.

7.2.3.8 Grey plover (Pluvialis squatarola)

Grey plovers forage intertidally and have a characteristic mode of foraging whereby they stand

motionless watching the mudflat surface before snatching a prey item (often a worm) from the

sediment surface. Grey plovers take a wide range of prey species including lugworms (Arenicola

marina), ragworms (Hediste diversicolor), amphipod crustaceans and small bivalves (e.g. Macoma

balthica and Scrobicularia plana). A degree of sub-site preference is therefore evident although the

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sub-sites favoured are not clustered and occur in both the inner and outer site. The benthic

community of sub-sites used by grey plovers is classified as ‘intertidal sand to mixed sediment with

polychaetes, molluscs and crustaceans’ (NPWS, 2012b). This broad community type has a wide

variability in sediment type from gravel to fine sand to muds. Grey plover is amber-listed as the

majority winter at less than ten sites in Ireland.

7.2.3.9 Lapwing (Vanellus vanellus)

Lapwings are traditionally ‘inland’ waders. During winter they can be observed across a wide variety

of habitats, principally using lowland farmland and freshwater wetlands (e.g. turloughs and callows)

but also coastal wetlands where they feed on a variety of soil and surface-living invertebrates. They

are opportunistic and mobile birds and will readily exploit temporary food sources such as newly-

ploughed fields. Estuaries are typically used as roosting areas where large flocks may be observed

upon the tidal flats. Coastal habitats tend to be used more during cold weather events when

farmland and freshwater habitats freeze over. Lapwing is red-listed due to a decline in the breeding

and non-breeding population.

7.2.3.10 Knot (Calidris canutus)

During the winter knots are coastal in their distribution with preferred sites mainly comprising

estuaries with extensive mudflats. They are specialist foragers of molluscs and crustaceans in inter-

tidal areas, being particularly adapted to hunt prey buried in the substrate. The preferred prey items

are bivalve molluscs including Scrobicularia plana, Macoma balthica and Mytilus edulis of smaller

size-classes. Although knot was red-listed in Ireland the wintering population has increased in recent

times and as such knot has now been re-assigned as amber-listed.

7.2.3.11 Dunlin (Calidris alpina)

Dunlin is a common wader along Irish coasts. Wintering populations favour coastal areas such as

estuaries and mudflats with the population peaking in mid-winter. They tend in feed in groups on

mudflats, often at the water’s edge, taking a variety of prey including molluscs, crustaceans and

worms. Dunlin is widespread within the site favouring inter-tidal foraging areas. Dunlin is amber-

listed in Ireland as the majority winter at less than ten sites.

7.2.3.12 Black-tailed godwit (Limosa limosa)

Black-tailed godwits are large long-billed wading birds that forage within intertidal flats for their

preferred prey of bivalves such as Macoma balthica, Scrobicularia plana and Mya arenaria. At some

sites, polychaete worms form a larger proportion of the diet and the species is relatively adaptable,

utilising other habitats for foraging where available, such as terrestrial grassland, coastal marshes or

freshwater callows. Black-tailed godwit is amber-listed in Ireland as the majority winter at less than

ten sites.

7.2.3.13 Curlew (Numenius arquata)

Curlews are the largest wader to spend the non-breeding season within Ireland. Within intertidal

areas they seek out larger prey items such as crabs, large worms and bivalves and their de-curved

bill is ideally suited to extracting deep-living worms such as Lugworms (Arenicola marina). Curlews

also feed amongst damp grasslands where they take terrestrial worms. Ireland supports a small and

declining population of breeding curlew. Irish breeding curlew are thought to make only short

migrations, many are resident during winter. Wintering numbers are enhanced by birds moving in

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from breeding grounds. Curlew is red-listed due to a long-term decline in the breeding and wintering

population and its breeding range. Curlews winter in the estuary and coastal grasslands and feed on

intertidal mudflats. Numbers of curlew of all-Ireland importance were recorded in all but one of the

surveys completed within the site.

7.2.3.14 Redshank (Tringa totanus)

Redshank feed along the upper shore of estuaries and along muddy river channels. Redshanks

forage mainly by pecking at the surface or probing within intertidal mudflats; often favouring the

muddier sections of sites where they prey upon species such as the Ragworm Hediste diversicolor

and Mud Snail Hydrobia ulvae. A particularly favoured prey is the burrowing amphipod Corophium

volutator which occurs within the dominant intertidal benthic community type across the site

‘intertidal sand to mixed sediment with polychaetes, molluscs and crustaceans’ (NPWS, 2012b).

Redshank is red-listed due to a long-term decline in its breeding population.

7.2.3.15 Greenshank (Tringa nebularia)

Ireland supports a small population of greenshank during winter, mainly on estuaries with some

occurring along non-estuarine coasts. Apart from certain times when they flock together (e.g.

passage birds), greenshanks are generally widely distributed due to their territorial nature over their

foraging patch; hence a relatively wide distribution is to be expected. Greenshanks usually forage

within (wading) or beside watercourses where they exhibit a variety of feeding methods to take a

diversity of prey including insects, polychaete worms and small fish. Greenshank is green-listed for

its wintering population.

7.2.3.16 Black-headed gull (Chroicocephalus ridibundus)

Black-headed gull is resident in Ireland throughout the year with winter numbers boosted by

wintering individuals arriving from mainland Europe. The species over-winters and breeds in both

coastal and inland locations, nesting in colonies in sand dunes, coastal islands, moorland polls, bogs

and on freshwater lake islands. They take a wide variety of food items including fish, worms,

molluscs, insects and plant material and are opportunistic feeders, taking advantage of any available

food-source including domestic/fishing waste. They are widely-distributed within the SPA favouring

inter-tidal foraging areas. Black-headed gull is red-listed due to a long term decline in its breeding

population and distribution.

Conservation objectives are to maintain the favourable conservation condition of the above SCIs in

the River Shannon and River Fergus Estuaries SPA, as follows:

• Whooper swan

• Shelduck

• Wigeon

• Teal

• Shoveler

• Golden plover

• Grey plover

• Lapwing

• Knot

• Dunlin

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• Black-tailed godwit

• Curlew

• Redshank

• Greenshank

• Black-headed gull

The conservation objective, with regards to these SCIs is defined by the following attributes and

targets:

Table 18 Attributes and targets for relevant SCIs in the River Shannon and River Fergus estuaries SPA (NPWS, 2012b)

Qualifying Feature Attribute Measure Target/Notes

Whooper swan

Shelduck

Wigeon

Teal

Shoveler

Golden plover

Grey Plover

Lapwing

Knot

Dunlin

Black-tailed godwit

Curlew

Redshank Greenshank

Black-headed gull

Population

trend Percentage change

Long term population trend stable or

increasing

Distribution

Range, timing and

intensity of use of

areas

There should be no significant decrease

in the range, timing or intensity of use of

areas other than that occurring from

natural patterns of variation

7.2.3.17 Wetlands [A999]

The wetland habitats contained within the River Shannon and River Fergus Estuaries SPA are

identified to be of conservation importance for non-breeding (wintering) migratory waterbirds.

Therefore the wetland habitats are considered to be an additional Special Conservation Interest.

Conservation objectives are to maintain the favourable conservation condition of the wetland

habitat in the River Shannon and River Fergus Estuaries SPA as a resource for the regularly-occurring

migratory waterbirds that utilise it, as defined by the following attributes and targets.

Table 19 Attributes and targets for wetlands in the River Shannon and River Fergus Estuaries SPA (NPWS, 2012b)

Parameter Attribute Measure Target/Notes

Area

Wetland

habitat Area (ha)

The permanent area occupied by the wetland habitat

should be stable and not significantly less than the

area of 32,261 ha, other than that occurring from

natural patterns of variation.

The boundary of the River Shannon and River Fergus Estuaries SPA was defined to include the

primary wetland habitats of this expansive site. The wetland habitats can be categorised into five

broad types: sub-tidal; inter-tidal; supra-tidal; lagoon and associated; and freshwater and associated.

Over time and though natural variation these subcomponents of the overall wetland complex may

vary due to factors such as changing rates of sedimentation, erosion etc. Many waterbird species will

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use more than one of the habitat types for different reasons throughout the tidal cycle NPWS,

2012b).

Sub-tidal areas refer to those areas contained within the SPA that lie below the mean low water

mark and are predominantly covered by marine water. Tidal rivers, creeks and channels are included

in this category. For the River Shannon and River Fergus Estuaries SPA this broad category is

estimated to be 20,636 ha. Sub-tidal areas are continuously available for benthic feeding and

dabbling ducks (e.g. Wigeon and Teal) and piscivorous/other waterbirds (e.g. Cormorant). Various

waterbirds roost in sub-tidal areas.

The intertidal area is defined, in this context, as the area contained between the mean high water

mark and the mean low watermark. For the River Shannon and River Fergus Estuaries SPA this is

estimated to be 9,085 ha. When exposed or partially exposed by the tide, inter-tidal habitats provide

important foraging areas for many species of waterbirds, particularly wading birds, as well as

providing roosting/loafing areas. When the intertidal area is inundated by the tide it becomes

available for benthic and surface-feeding ducks and piscivorous/other waterbirds. During this tidal

state this area can be used by various waterbirds as a loafing/roosting resource NPWS, 2012 b).

The supra-tidal category, in this context, refers to areas that are not frequently inundated by the tide

(i.e. occurring above the mean high watermark) but contain shoreline and coastal habitats and can

be regarded as an integral part of the shoreline. For the River Shannon and River Fergus Estuaries

SPA this is estimated to be 2,448 ha. Supratidal areas are used by a range of waterbird species as a

roosting resource as well as providing feeding opportunities for some species.

The category known as ‘Lagoon and associated habitats’ in this context refers to lagoons and

brackish lakes and their associated habitats. For the River Shannon and River Fergus Estuaries SPA

this habitat category is estimated to be 36 ha, and relates to Mangan’s Lagoon, near Aughinish

Island, and the larger Shannon Airport Lagoon. This latter area provides was included in the SPA

primarily for supporting large concentrations of Black-tailed Godwit but it also provides both feeding

and roosting/refuge habitats for a several other waterbird species.

The category known as ‘Freshwater and associated habitats’ in this context refers to freshwater

lakes and their associated habitats. For the River Shannon and River Fergus Estuaries SPA this habitat

category is estimated to be 56 ha, and relates specifically to Bunlickey Lake and Cooperhill Lakes.

These habitats provide both feeding and roosting/refuge habitats for a variety of waterbird species

that also use the wider estuarine habitats NPWS, 2012 b).

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8 ASSESSMENT OF POTENTIALLY SIGNIFICANT EFFECTS

There follows an evaluation of significance of potential impacts of the proposed project on the

qualifying features that have been selected for impact assessment. This section considers the

habitats and species identified in the preceding sections together with any potential impacts, and

determines whether the proposed works are likely to have significant effects on any of the Natura

2000 sites designated for the protection of the qualifying features selected.

The likelihood of adverse effects to each Natura 2000 site from the project was determined based on

a number of indicators including:

• Habitat loss and/or alteration

• Water quality

• Disturbance and/or displacement of species

• Habitat or species fragmentation

The likelihood of significant cumulative/in-combination effects is assessed in Section 6.5 below.

8.1 WATER QUALITY

8.1.1 Construction Phase

The footprint of the proposal overlaps with the Shannon River and Estuary, which forms part of the

Lower River Shannon cSAC and the River Shannon and River Fergus Estuaries SPA.

There are several aspects of the proposal which could potentially result in impairment of water

quality within either the SAC or SPA. Potential water quality effects arising as a result of the proposal

could potentially occur as a result of erosion and run-off of fines/nutrient-enriched material from

excavations, denuded embankments or temporary storage areas for turf and top-soil. Adverse water

quality effects could also potentially arise due to the accidental release of pollutants such as fuels,

oils and other such substances to the aquatic environment. These impacts are considered to have

the most potential to occur during the construction phase of the project. Contamination or water

quality impacts on the Shannon Estuary could result in impacts on the intertidal-marine ecosystem

and therefore the species that are dependent on good water quality for survival.

The potential significant impacts of the project on intertidal-marine ecology (without mitigation) are

summarised as follows:

• Risk to water quality via suspended solids pollution, through mobilisation of soils and other

substances that can occur in suspension in water, associated with excavations and

stockpiles;

• Pollution of watercourses with nutrients due to ground disturbance during construction. The

main potential sources of nutrient inputs to brackish/marine water due to ground

disturbance are from nutrients adsorbed or chemically bound to eroded suspended solids;

and

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• Pollution, with other substances such as fuels, lubricants, waste water from wash facilities,

etc.; and

• Potential risk of organic pollution of the intertidal zone-marine environment during

construction phase through accidental spillage of hydrocarbons from construction related

vehicles, machinery and equipment.

In conclusion, the release of non-attenuated suspended solids and potentially contaminated run-off

waters into the Shannon Estuary or nearby connecting drains/watercourses has the potential to

have a negative impact on water quality, and thus the Lower River Shannon cSAC and the River

Shannon and River Fergus Estuaries SPA. This would potentially be a temporary negative impact. The

risk of occurrence however can be adequately prevented by the implementation of standard best

management practices and controls. Therefore, certain mitigation measures are recommended with

regards to protection of water quality and are included in Section 9 below.

8.1.2 Operational Phase

Post construction, storm activity may result in loss of some loose sediment from the upgraded

embankment, but stability of sediments can be expected following a few such episodes. No

significant operational phase water quality impacts are envisaged.

8.2 HABITAT LOSS/ALTERATION

8.2.1 Lower River Shannon cSAC

8.2.1.1 Estuaries

Excavation works for the foundation pocket required to facilitate installation of rock armour along

the seaward face of the East Embankment and installation of rock armour will result in the

permanent removal and alteration of littoral benthic habitat and associated infaunal species within

the estuarine habitat of the Lower River Shannon cSAC. Excavations to -1.0ODM will be required

along approximately 0.8km of the East Embankment, extending seawards to approximately 5m from

the existing embankment toe.

In the context of overlap with estuarine habitat, this will result in permanent removal of

approximately 0.4ha of littoral estuarine sediment. Installation of rock armour in this same area will

result in the alteration of littoral estuarine habitat of an approximate area of 4,000m2.

A review of maps contained within the Conservation Objectives for the SAC determined that the

proposed area of excavation along the seaward face of the East Embankment overlaps with the

mapped distribution of the ‘Intertidal sand to mixed sediment with polychaetes, molluscs &

crustaceans’ community complex (see Figure 7 above for mapped extent of community complex as

per Conservation Objectives documentation). Mixed sediment is the dominant sediment type within

this community. The sediment type is highly variable throughout this community evidenced by the

wide ranges in sediment fractions. The polychaete Hediste diversicolor and the bivalve Macoma

balthica are recorded in moderate to high abundances throughout this community complex. The

gastropod Hydrobia ulvae also generally occurs in moderate to high abundances. Distinguishing

species of this community complex include Hediste diversicolor, Macoma balthica, Hydrobia ulvae,

Nephtys hombergii and Corophium volutator (NPWS, 2012b).

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While infauna present within the foundation pocket will be completely removed from the area by

excavation works, and potentially subsequently covered over with rock armour, the species which

occur there are distributed throughout the surrounding area as this intertidal community is found

extensively throughout the estuary (NPWS, 2012b). Such species as are found in these estuarine

community complexes have typically evolved to take advantage of disturbed habitats and

consequently thrive in such environments. For example, Nephtys hombergii can move very quickly

through the substratum, downwards on the ebb tide and up again on the flood tide (Clay, 1967). It is

also capable of swimming short distances with an undulatory movement. It also releases

planktotrophic (planktonic-dispersing larva that derives its nourishment by feeding in the plankton)

and lecithotrophic (a planktonic-dispersing larva that lives off yolk supplied via the egg) larvae. Such

species typically have the ability to re-establish themselves from surrounding populations through

the colonisation of larvae.

There also exists the potential for surrounding habitat communities to be indirectly impacted via

sedimentation effects as re-suspended sediment settles out of the water column following bed

disturbance associated with excavation works. This can also occur as a result of accidental spillage of

material during transportation via excavator to the trucks. Mudflats are accreting environments

where deposition rather than erosion is the primary process. As a result, the communities which

exist there have evolved to withstand smothering by light sedimentation. Any sedimentation

impacts are not expected to be significant on estuarine habitat.

With installation of additional rocks along the intertidal zone fronting the east embankment, there

would be a concern with regard to potential changes to local hydrodynamics and therefore erosive-

deposition processes. The concern would be that the works could alter the intertidal zone at the

seaward side of the proposed development fronting the east embankment. The magnitude of any

changes of the estuarine habitats would be expected to decrease with distance from the upgraded

embankment.

Anthropogenic disturbance may be considered significant when it causes a change in biotic and/or

abiotic variables in excess of what could reasonably be envisaged under natural processes. The

capacity of the habitat to recover from this change is obviously an important consideration (i.e.

habitat resilience) thereafter. Excavation works will result in the permanent loss of approximately

4,000m3 of littoral estuarine sediment comprising the community type ‘Intertidal sand to mixed

sediment with polychaetes, molluscs & crustaceans’ within the Lower River Shannon cSAC. Similarly,

installation of rock armour within the same footprint will result in the alteration of approximately

0.4ha of estuarine littoral habitat within the SAC.

In the context of the overall community extent within the site, a review of the marine habitats

supporting document for the SAC has determined the estimated area of the community type

‘Intertidal sand to mixed sediment with polychaetes, molluscs & crustaceans’ within the ‘Estuaries’

habitat to be approximately 8,130ha (NPWS, 2012b). Therefore, the area of proposed excavation

works/rock armour installation represents approximately 0.004% of the overall estimated area of

this community type within the estuary. Loss/alteration of this littoral area is therefore not

considered to be significant in the context of the overall community extent within the site.

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In summary, with regards to the Conservation Objectives for the Annex I habitat ‘Estuaries’, there

will be no change in permanent habitat area and significant impacts to community distribution are

not envisaged given the scale of the works, and the natural life traits and resilience of estuarine

benthic communities.

With regards to the potential for indirect habitat impacts to estuaries through water quality effects it

has been determined that there is potential for significant water quality effects within the SAC, or

significant water quality effects cannot be ruled out at this stage, as a result of the unmitigated

proposal. Therefore, certain mitigation measures are recommended with regards to protection of

water quality and are included in Section 9 below.

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

Excavation works will result in the removal of littoral benthic habitat within the foundation pocket

along the seaward face of the East Embankment in the SAC. With regards to the Annex I habitat

‘Mudflats and sandflats not covered by seawater at low tide’ there is overlap between the proposal

area and this habitat-type, as mapped in the Lower River Shannon cSAC Conservation Objectives

supporting documentation (NPWS, 2012b), therefore there will be removal of mudflat habitat as a

result of the proposal (see Figure 6 above for mapped extent of mudflat habitat as per Conservation

Objectives documentation).

In order to maintain the favourable conservation condition of ‘Mudflats and sandflats not covered

by seawater at low tide’ within the SAC, targets have been defined pertaining to permanent habitat

area, which should be stable or increasing subject to natural processes, and the conservation of

defined community types in a natural condition.

The overall area of mudflat habitat within the SAC has been estimated to be approximately 8,808ha

(NPWS, 2012b). The area of overlap between mapped mudflat habitat and the proposed works will

be approximately 0.4ha. Therefore, there will be loss/alteration to approximately 0.004% of mudflat

habitat within the SAC. Significant loss of ‘Mudflats and sandflats not covered by seawater at low

tide’ within the SAC is therefore not envisaged.

With regards to potential impacts to the ‘Intertidal sand to mixed sediment with polychaetes,

molluscs & crustaceans’ community complex, which is considered to be a structurally important

community type within the Annex I marine habitat ‘Mudflats and sandflats not covered by seawater

at low tide’, potential direct and indirect impacts to community distribution are assessed in terms of

‘Estuaries’. Modelling indicates that the proposed remedial works to the existing eastern

embankment as represented in the model domain does not have a significant impact on the

morphodynamics of the adjacent mudflats.

In summary, with regards to the Conservation Objectives for the Annex I habitat ‘Mudflats and

sandflats not covered by seawater at low tide’, there will be no change in permanent habitat area

and significant impacts to community distribution are not envisaged given the scale of the works,

and the natural life traits and resilience of estuarine benthic communities.

With regards to the potential for indirect habitat impacts to mudflats and sandflats through water

quality effects it has been determined in Section 8.2.1.1 above that there is potential for significant

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water quality effects within the SAC, or significant water quality effects cannot be ruled out at this

stage, as a result of the unmitigated proposal. Therefore, certain mitigation measures are

recommended with regards to protection of water quality and are included in Section 9 below.

8.2.1.3 Coastal Lagoons [1150]*

Shannon Airport Lagoon is artificial waterbody that lies at the landward side of the West

Embankment. Based on the area of lagoon mapped by NPWS (2012a), the proposed works at the

West Embankment are at a remove of approximately 15m proposed works. It is noted however that

the surface area of water in the lagoon is contracting due to colonisation of the margins by reeds,

the proposed works at the West Embankment are at a remove of approximately 80m the main

lagoonal waterbody. Shannon Airport Lagoon lagoon is separated from the sea by man-made

barriers comprising the embankment and an access road. The water level in the lagoon is managed

via a sluiced outlet through which water drains via a drainage channel located in the lagoons north-

western corner.

With regards to direct habitat loss/alteration there is no spatial overlap between the proposed

works and the lagoon; therefore, there will be no direct habitat loss/alteration of this Annex I

priority habitat. There will be no reduction or decline in habitat area or distribution as a result of the

proposed works.

With regards to indirect habitat alteration, it is considered that there is potential for indirect impacts

to lagoon habitat via potential water quality effects which may arise as a result of the unmitigated

proposal. Such effects, which could arise as a result of ingress of un-attenuated surface run-off or

the accidental release of fuels/oils etc, could also indirectly impact on the assemblage of typical

plant and animal species associated with this habitat, thus potentially impacting on the conservation

objectives of ‘Coastal lagoons’ within the SAC. As there is potential for significant water quality

effects within the SAC, or since significant water quality effects cannot be ruled out at this stage, as a

result of the unmitigated proposal, certain mitigation measures are recommended with regards to

protection of water quality and are included in Section 9 below.

8.2.1.4 Atlantic salt meadows (Glauco-Puccinellietalia maritimae) [1330]

A review of mapping available for this habitat-type determined that the closest areas of Atlantic salt

meadows to the proposed development comprises an area located ca. 5m from the bottom of the

northern end of the East Embankment. Another area of this habitat is indicated approximately

1.1km west West Embankment (NPWS, 2012a). During the habitat survey, two areas of upper

saltmarsh Atlantic salt meadows habitat was recorded west of the western embankment, and the

extent of this habitat adjacent to the East embankment was greater than that mapped in NPWS.

As there is no spatial overlap between the works and Atlantic salt meadows there will be no direct

loss or alteration of reef habitat within the SAC. There will be no reduction or decline in habitat area

or distribution as a result of the proposed works.

With regards to indirect habitat alteration, it is considered that there is potential for indirect impacts

to reef habitat via potential water quality effects which may arise as a result of the unmitigated

proposal. Such effects, which could arise as a result of ingress of un-attenuated surface run-off or

the accidental release of fuels/oils etc, could also indirectly impact on the community complexes

associated with this habitat, thus potentially impacting on the conservation objectives of ‘Atlantic

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salt meadows’ within the SAC. As there is potential for significant water quality effects within the

SAC, or since significant water quality effects cannot be ruled out at this stage, as a result of the

unmitigated proposal, certain mitigation measures are recommended with regards to protection of

water quality and are included in Section 9 below.

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

Batrachion vegetation [3260]

This habitat is associated with running fresh water. It comprises submerged or floating vegetation of

the Ranunculion fluitantis and Callitricho-Batrachion (low water level during summer) or aquatic

mosses. Within the Lower River Shannon cSAC, this habitat consists of three high conservation

elements (sub-types), one being Opposite-leaved Pondweed Groenlandia densa.

Groenlandia densa was identified within a drainage channel associated with the Shannon Airport

Lagoon during habitat surveys carried out on-site. The drainage channel supporting this plant lies

adjacent and downslope of the proposed development. Works at the East Embankment could

adversely affect water quality in the drainage channel and therefore result in habitat loss or

alteration. This assessment takes account that Groenlandia densa appears to be sensitive to

eutrophication (Preston, 2003).

As there is potential for significant water quality effects within the SAC, or since significant water

quality effects cannot be ruled out at this stage, as a result of the unmitigated proposal, certain

mitigation measures are recommended with regards to protection of water quality and are included

in Section 9 below.

8.2.2 River Shannon and River Fergus Estuaries SPA (004077)

8.2.2.1 Wetlands [A999]

The wetlands of northwest Europe are a vital resource for millions of northern and boreal nesting

waterbird species that overwinter on these wetlands or visit them when migrating further south. To

acknowledge the importance of Ireland's wetlands to wintering waterbirds the term ‘Wetland &

Waterbirds’ can be included as a Special Conservation Interest for a Special Protection Area that has

been designated for wintering waterbirds, and is or contains a wetland site of significant importance

to one or more of the species of Special Conservation Interest.

Table 20 Assessment of potential impacts of the project on ‘wetlands’.

Attribute/Measure Target Assessment of Potentially Significant Effects Mitigation

required

Wetland habitat

area/hectares

The permanent

area occupied by

the wetland

habitat should be

stable and not

significantly less

than the area of

32,261ha, other

than that occurring

from natural

patterns of

variation

The wetland habitat area was estimated as

32,261ha (NPWS, 2012a). The estuarine habitat

adjacent to the proposed development likely

forms part of this wetland area. The proposed

development would not have any direct impacts

on habitat area but could have indirect impacts

on water quality and therefore habitat quality.

Yes

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The Shannon Estuary features this conservation interest, with mudflats and mixed sediment shores

providing feeding opportunities for over-wintering birds. The loss and alteration of wetlands habitat

in the River Shannon and River Fergus Estuaries SPA correspond to habitats listed as conservation

interests of the Lower River Shannon cSAC i.e. estuaries, mudflats, sandflats and lagoons.

As there is potential for significant water quality effects within the SPA, or since significant water

quality effects cannot be ruled out at this stage, as a result of the unmitigated proposal, certain

mitigation measures are recommended with regards to protection of water quality and are included

in Section 9 below.

8.3 DISTURBANCE AND/OR DISPLACEMENT OF SPECIES

Intertidal habitats areas adjacent to the proposed works provide important foraging areas for many

species of waterbirds, especially wading birds. The lagoon is recognised as a roosting/loafing area

(loafing can be described as any behaviour not connected with breeding or feeding, and includes

preening and resting). When the intertidal area is inundated by the tide it becomes available for

diving ducks and piscivorous/other waterbirds. When exposed or partially exposed by the tide,

intertidal habitats provide important foraging areas for many species of waterbirds, especially

wading birds. The proposed works have the potential to disturb birds of conservation interest the

SPA.

The proposed works at the shore will take ca. 12months to complete. The fauna of conservation

interest in the Shannon Estuary in the environs of the proposed works would be disturbed during

this period. Disturbance of Otter and birds can be expected to result in their movement to other

parts of the estuary.

There is potential for indirect disturbance or displacement of species arising from potential

pollutants entering the Shannon Estuary during the construction phase of the proposed works.

Pollutants include silt, chemicals or hydrocarbons associated with construction activities. Siltation of

the substrate and eutrophication leading to increased biomass of filamentous algae would reduce

the available suitable habitat.

8.4 HABITAT OR SPECIES FRAGMENTATION

Habitat fragmentation has been defined as ‘reduction and isolation of patches of natural

environment’ (Hall et al., 1997 cited in Franklin et al., 2002) which results in spatial separation of

habitat areas which had previously been in a state of greater continuity. Adverse effects of habitat

fragmentation on species include the increased isolation of populations which can detrimentally

impact on the resilience or robustness of the populations.

There is potential for pollutants to enter the Shannon Estuary during the construction phase. Habitat

and species fragmentation can be caused by polluted bodies of water, where fish cannot survive.

Impacts on fish could have negative consequences for Otter. The proposed development is not

expected to cause any significant fragmentation of habitats or species given its location adjacent to

an existing embankment, spatial extent and short-term construction phase.

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8.5 ASSESSMENT OF SIGNIFICANCE OF POTENTIAL IMPACTS

8.5.1 Habitat Loss and Alteration

The proposal site occurs along existing rock armour embankments contiguous to estuarine mudflats

and adjacent to Shannon Airport Lagoon. As the embankments lie within/adjacent to the Lower

River Shannon cSAC and the River Shannon and River Fergus Estuaries SPA, these sites will be subject

to direct/indirect habitat loss to the intertidal mudflats and sandflats or along rock armour structure

at the upper intertidal zone. In addition, there lies a direct pathway between the proposed

development site and the Shannon Airport Lagoon.

However, the impact is considered to be low, given the localised and temporary nature of the works

and that the works will be restricted to the existing rock armour structure. Target 1 of the

conservation objectives for ‘mudflats and sandflats not covered by seawater at low tide’ refers to

the stability of the permanent habitat area, subject to natural processes (NPWS, 2012a). There will

be some loss of mudflat habitat to accommodate the works. Habitat area was estimated using OSi

data as 8,808ha.

One of the concerns regarding potential impact of the rock armour facing relates to the potential

change in reflectivity of the front face of the embankment as the rock protection becomes larger.

Modelling was undertaken of the combined wave and water level conditions and the resulting

sediment transport of the intertidal muds (silt sized material) for the existing case and with the

proposed armouring installed. An assessment of wave reflection indicated that the reflection

coefficients of the existing armourstone, which for the purposes of the assessment is considered to

be a one layer rock armour revetment, and that of the proposed larger stone, which for the

purposes of the assessment is considered to be a two layer rock armour revetment are both

relatively low in the range 0.15 to 0.2. This is due for the most part to the relative shortness of the

locally generated waves. This means that the total significant wave height in front of the

embankment is close to that of the incoming wave because the reflection coefficient is relatively

low. The difference between the total significant wave height for the existing and new structures is

in the order of 2%. If the existing armour was considered to be smooth the reflection coefficient is

greater and the difference between the existing and proposed would be greater, but still in the order

of 10%, which is equivalent to a difference of less than 0.1m for the more extreme waves at the site.

Hydrodynamic/morphodynamic differences between the existing environment and those expected

following construction are not considered to be at a level that will significantly change the local

estuarine environment.

The works may temporarily displace commuting or foraging otters, however, the impact is

considered to be limited given the localised and temporary nature of the works and the wide

availability of suitable habitat in the vicinity of the works, it is not expected that otter will be

significantly impacted by the proposed repair works.

With the appropriate mitigations in place, it is concluded that significant habitat loss or alteration

impacts to the Lower Shannon River SAC during the construction phase of the proposal are not likely

to occur as a result of the proposed works.

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8.5.2 Habitat or Species Fragmentation

Given that the works occur in such close association with the Lower River Shannon cSAC and the

River Shannon and River Fergus Estuaries SPA, there is the potential for habitat or species

fragmentation to occur. The primary concern in terms of habitat fragmentation lies with the

localised floating river vegetation, and the mudflats and sandflats, which, will likely be fragmented

due to the proposed works, along the Shannon embankments.

However, accounting for the fact that floating river vegetation is considered to be widespread in

water systems throughout Ireland and given the abundance of available alternative habitat along the

estuary, it is determined that the potential impact to qualifying habitats and species will be low,

temporary and very localised in nature as the species will make use of the available surrounding

habitats during the construction phase of the works. Once works are complete they will be available

for use again, with the impact on the qualifying habitats being temporary and localised. The CEMP

will ensure that the works keep to the existing footprint of the site and that all steps necessary to

ensuring the conservation of qualifying interest habitats and species are protected.

With the appropriate mitigations in place, it is concluded that significant habitat or species

fragmentation impacts to the Lower Shannon River SAC during the construction phase of the

proposal are not likely to occur as a result of the proposed works.

8.5.3 Disturbance and/or Displacement of Species

A primary impact associated with construction and maintenance is displacement and avoidance of

foraging birds from the works areas and surrounding environment. The Lower River Shannon cSAC

and the River Shannon and River Fergus Estuaries SPA are designated for the protection of a variety

of species, as listed in Section 7 above. The proposed development site area may be used by

foraging SCI species. A certain amount of activity already exists in the area, including the Shannon

Airport and Shannon Free Zone, the Shannon Golf Course, and the surrounding dwellings of Shannon

Town to the northeast and beyond, vehicular/air traffic associated with the main road and airport,

and agricultural activities in the areas extending further away from the built area (agricultural

grassland/silage harvesting/arable land, etc). However, the previous sections have concluded that

the works will not impede the movement of these species and the biggest risk to these species lies

with potential water quality impacts, which is assessed in section 8.5.4 below.

There is the potential for some very localized and temporary disturbance and/or displacement to

otter potentially foraging in the area. Chanin (2003a) indicate that otters will rest under roads, in

industrial buildings, close to quarries, and at other sites close to high levels of human activity, clearly

indicating that otters are very flexible in their use of resting sites and do not necessarily avoid

‘disturbance’ in terms of noise or proximity to human activity. Though not found during the surveys

carried out in 2019, it is possible that otter could use a space at the proposed development site for a

holt, so the proposed works could potentially displace a pair of breeding otter.

Bearing in mind the scale of the proposed works, the level of activity currently in the area, in the

location of the proposed works are situated at the extremity of the SAC/SPA site, and the wide

availability of suitable habitat in the vicinity of the works, it can be concluded that any potential

disturbance/displacement impacts during the construction phase will be localized and short-term in

nature. Any impacts are considered limited given the localised and short-term nature of the works.

Mitigation will be required for otter i.e. preconstruction otter survey.

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8.5.4 Water Quality

The receiving environment of the proposed refurbishment works to Shannon Airport Embankments

is the River Shannon and River Fergus Estuary. The main risk to water quality arises as a result of the

potential for discharge of polluting substances required to carry out the repair works such as grout

and concrete wastewaters and fuels/oils. There is potential for uncontrolled discharge of polluting

substances from the following activities:

• The potential risk of organic pollution through accidental spillage of hydrocarbons from

construction-related vehicles, machinery, and equipment

• Surface water run-off

• Increased nutrients/sedimentation

It is considered that the main threat to the habitat types of the Lower River Shannon cSAC relate to

water quality impacts. The habitat and species types that may suffer potentially significant impacts

are:

• Estuaries/Mudflats and sandflats not covered by seawater at low tide

• Atlantic salt meadows

• Floating river vegetation

• Otter

Estuaries support a diverse range of plant and animal species dependent on good water quality for

optimum ecological functioning. There is potential for significant water quality impacts to occur to

the estuarine habitat type and associated dependent species.

In the event a relatively large accidental spillage of fuels/oils occurred during the repair work from

machinery and equipment being used to facilitate the repair works, this may have a significant

impact on local small mudflats exposed at low tide in the vicinity of the works. In the event of a

reduction in water quality as a result of the discharge of polluting substances to the river, otter may

be directly or indirectly impacted should their food source be significantly affected.

Floating river vegetation of the sub-type Opposite-leaved Pondweed Groenlandia densa occurs in a

channel connected to the lagoon in the vicinity of the repair works. A reduction in water quality

could result in indirect significant impacts to this floating water vegetation.

With the appropriate mitigations in place, it is concluded that significant water quality impacts to the

Lower Shannon River SAC during the construction phase of the proposal are not likely to occur as a

result of the proposed works.

8.6 ASSESSMENT OF EFFECT ON CONSERVATION OBJECTIVES

Detailed conservation objectives (COs) have been developed for the Lower River Shannon cSAC and

for the River Shannon and River Fergus Estuaries SPA. In Section 7 above, an evaluation was

undertaken to determine which of the qualifying interests of the potentially lie within the zone of

influence of the project and required further assessment in the NIS. This was done through a

scientific examination of ecological evidence and data. The effects of the project on the qualifying

interests which have been identified as being potentially within the zone of influence have been

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assessed against the measures designed to achieve the conservation objectives. An assessment of

the effect of the project on Cos selected for further assessment has been presented below under the

Lower River Shannon cSAC and the River Shannon and River Fergus Estuaries SPA. Where a measure

may be negatively affected by the project the need for mitigation is indicated.

8.6.1 Lower River Shannon cSAC

The following tables give the assessment of effect of the project on the Conservation Objectives for

special conservation interests identified as being potentially significantly affected by the proposed

development.

Table 21 Assessment of potential impacts of the project on estuaries

Attribute/

Measure Target Assessment of Potentially Significant Effects

Mitigation

Required

Habitat

area/

hectares

Area stable or

increasing,

subject to

natural

processes

The project will not result in a significant reduction in area of

this habitat type. The area of overlap between the proposed

excavation works/rock armour installation and the distribution

of ‘Intertidal sand to mixed sediment with polychaetes,

molluscs & crustaceans’ community complex represents

approximately 0.004% of the overall estimated area of this

community type within the estuary. The project will not result

in a significant reduction in area of this community type.

No

Community

distribution/

hectares

To conserve the

community

types for which

this habitat is

designated in a

natural

condition

The project has the potential to result in significant water

quality impacts which may affect the communities for which

this habitat type is designated.

Yes

Table 22 Assessment of potential impacts of the project on mudflats

Attribute/

Measure Target Assessment of Potentially Significant Effects

Mitigation

Required

Habitat

area/

hectares

Area stable or

increasing,

subject to

natural

processes

The project will not result in a significant reduction in area of

this habitat type. The area of overlap between mapped

mudflat habitat and the proposed works will be approximately

0.4ha (approximately 0.004% of mapped mudflat habitat

within the SAC).

No

Community

distribution/

hectares

To conserve the

community

types for which

this habitat is

designated in a

natural

condition

The area of overlap between the proposed excavation

works/rock armour installation and the distribution of

‘Intertidal sand to mixed sediment with polychaetes, molluscs

& crustaceans’ community complex represents approximately

0.004% of the overall estimated area of this community type

within the estuary. The project will not result in a significant

reduction in area of this community type.

The project has the potential to result in significant water

quality impacts which may affect the communities for which

this habitat type is designated.

Yes

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Table 23 Assessment of potential impacts of the project on coastal lagoons

Attribute/

Measure Target Assessment of Potentially Significant Effects

Mitigation

Required

Habitat

area/

Hectares

Area stable or

increasing,

subject to

natural

processes

The project will not result in a reduction wholly or in part of

the Shannon Airport Lagoon No

Habitat

distribution/

Occurrence

No decline,

subject to

natural

processes

The project will not result in a decline in the distribution or

occurrence of this habitat type No

Salinity

regime/

Practical

salinity units

(psu)

Median annual

salinity and

temporal

variation within

natural ranges.

The project will not result in any change in salinity regime. No

Hydrological

regime/

metres

Annual water

level

fluctuations

and minima

within natural

ranges.

The tidal regime is a very important influence on coastal

lagoons. The project will not affect the hydrological regime of

the lagoon or the Shannon Estuary.

No

Barrier

connectivity:

between

lagoon and

sea/

Permeability

Appropriate

hydrological

connections

between

lagoons and

sea, including

where

necessary,

appropriate

management.

Connectivity between the lagoon and the sea is an important

attribute of coastal lagoons. The project will not disrupt,

disturb, disconnect or provide any barrier to the connectivity

between Shannon Airport Lagoon and the sea.

No

Water

quality:

Chlorophyll

a/ µg/L

Annual median

chlorophyll a

within natural

ranges and less

than 5μg/L.

The construction phase of the project could potentially result

in the release of sediment/pollutants and affect the quality of

the water associated with the lagoon. Therefore, there is

potential for this conservation objective to be negatively

affected.

Yes

Water

quality:

Molybdate

Reactive

Phosphorous

(MRP)/ mg/L

Annual median

within natural

ranges and

<0.1mg/l.

The construction phase of the project could potentially result

in the release of sediment/pollutants and affect the quality of

the water associated with the lagoon. Therefore, there is

potential for this conservation objective to be negatively

affected.

Yes

Water Annual median The construction phase of the project could potentially result Yes

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Attribute/

Measure Target Assessment of Potentially Significant Effects

Mitigation

Required

quality:

Dissolved

Inorganic

Nitrogen

(DIN)/ mg/L

within natural

ranges and

<0.15mg/l.

in the release of sediment/pollutants and affect the quality of

the water associated with the lagoon. Therefore, there is

potential for this conservation objective to be negatively

affected.

Depth of

macrophyte

colonisation/

Metres

Macrophyte

colonisation to

maximum

depth of

lagoons

The project will not affect the depth of macrophyte

colonisation within the lagoon. No

Typical plant

species/

Number and

m2

Maintain

number and

extent of listed

lagoonal

specialists,

subject to

natural

variation

The project will not affect the plant species typical of lagoonal

specialists. No

Typical

animal

species/

number

Maintain listed

typical lagoonal

specialists,

subject to

natural

variation

The project will not affect the typical animal species typical

associated with the lagoon. No

Negative

indicator

species/

Number and

% cover

Negative

indicator

species absent

or under

control

The project will not affect number or cover of negative

indicator species associated with the lagoon. No

Table 24 Assessment of potential impacts of the project on Atlantic salt meadows

Attribute/Measure Target Assessment of Potentially

Significant Effects

Mitigation

required

Habitat area/Hectares

Area stable or

increasing, subject to

natural processes,

including erosion and

succession.

The project will not result in a

reduction wholly or in part of

this habitat

No

Habitat distribution/Occurrence

No decline or change in

habitat distribution,

subject to natural

processes.

The project will not result in a

decline in the distribution or

occurrence of this habitat type

No

Physical structure: sediment

supply/Presence absence of

physical barriers

Maintain natural

circulation of sediments

and organic matter,

without any physical

obstructions

There will be no additional

barriers other than those

(pitched stone on front face of

embankments) that have

always been in existence.

No

Physical structure: creeks and Maintain creek and pan The project footprint will not No

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Attribute/Measure Target Assessment of Potentially

Significant Effects

Mitigation

required

pans/ Occurrence structure, subject to

natural processes,

including erosion and

succession

incur any significant physical

change to the foreshore in the

environs of this habitat.

Physical structure: flooding

regime/ Hectares flooded;

frequency

Maintain natural tidal

regime

The project will not affect the

flooding regime or impact the

area of the habitat.

No

Vegetation structure:

zonation/Occurrence

Maintain the range of

coastal habitats

including transitional

zones, subject to natural

processes including

erosion and succession

The project footprint will not

incur any significant physical

change to the foreshore in the

environs of this habitat, so no

change to this attribute is

expected.

No

Vegetation structure: vegetation

height/ Centimeters

Maintain structural

variation within sward

The saltmarsh habitat adjacent

to the proposed development is

apparently not grazed. The

proposal will not change access

to the foreshore, so no change

to this attribute is expected.

No

Vegetation structure: vegetation

cover/ Percentage cover at a

representative sample of

monitoring stops

Maintain more than

90% of the saltmarsh

area vegetated

No poaching was noted at the

saltmarsh habitat adjacent to

the proposed development. The

proposal will not change access

to the foreshore, so no change

to this attribute is expected.

No

Vegetation composition: typical

species and sub‐communities/

Percentage cover at a

representative sample of

monitoring stops

Maintain range of sub‐

communities with

typical species listed in

Saltmarsh Monitoring

Project (McCorry and

Ryle, 2009)

The project footprint will not

incur any significant physical

change to the foreshore in the

environs of this habitat, so no

change to this attribute is

expected.

No

Vegetation structure: negative

indicator species‐ Spartina

anglica/ Hectares

No significant expansion

of common cordgrass

(Spartina anglica), with

an annual spread of less

than 1%

The project footprint will not

incur any significant physical

change to the foreshore in the

environs of this habitat, so no

change to this attribute is

expected.

No

Table 25 Assessment of potential impacts of the project on ‘Vegetation of flowing waters’

Attribute/Measure Target Assessment of Potentially Significant Effects Mitigation

required

Habitat area

/Kilometres

Area stable or

increasing, subject

to natural

processes. Three

sub‐types of high

conservation value

are known to occur

in the site

The full extent of this habitat is unknown, but

Opposite-leaved Pondweed does occur in a

channel adjacent to the East embankment. The

construction phase of the project could

potentially result in sediment release from

excavations and deposit silt in the channel,

possibly affecting the area of the habitat suitable

for colonisation. Therefore, there is potential for

Yes

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Attribute/Measure Target Assessment of Potentially Significant Effects Mitigation

required

this conservation objective to be negatively

affected.

Habitat distribution/

Occurrence

No decline, subject

to natural

processes.

The construction phase of the project could

potentially result in sediment release from

excavations and deposit silt in the channel

possibly affecting the distribution of the habitat.

Therefore, there is potential for this

conservation objective to be negatively affected.

Yes

Hydrological regime:

river flow/Metres per

second

Maintain

appropriate

hydrological

regimes

A natural flow regime is required for both plant

communities and channel geomorphology to be

in favourable condition. The project will could

affect the hydrological regime of the channel

supporting Opposite-leaved pondweed, for

example by blocking the connection between the

channel and the estuary. Effects to this

conservation objective are therefore possible.

Yes

Hydrological regime:

tidal influence/Daily

water level

fluctuations ‐ metres

Maintain natural

tidal regime

Tidal regime appears to be an important

influence on the distribution of certain

pondweed. The project will not affect the

hydrological regime of the channel supporting

Opposite-leaved pondweed. The connection

between the lagoon and the estuary will be

maintained, as is necessary for lagoon drainage.

No

Hydrological regime:

freshwater seepages/

Metres per second

Maintain

appropriate

freshwater

seepage regimes

Freshwater seepages are considered important

for the Groenlandia densa subtype. The

proposed development would not influence

freshwater seepage regimes so this attribute will

not be affected.

No

Substratum

composition:

particle size range/

Millimetres

The substratum

should be

dominated by the

particle size

ranges,

appropriate to the

habitat sub‐type

(frequently sands,

gravels and

cobbles)

The construction phase of the project could

potentially result in sediment release and

deposit silt in the channel. Therefore, there is

potential for this conservation objective to be

negatively affected.

Yes

Water quality:

nutrients/

Milligrammes per

litre

The concentration

of nutrients in the

water column

should be

sufficiently low to

prevent changes in

species

composition or

habitat condition.

The specific targets

may vary among

Phosphorous (MRP) is typically the limiting

nutrient, however increased nitrogen negatively

impacts upon some aquatic plant communities.

Nutrient enrichment typically leads to increased

filamentous algae biomass and consequent

changes in algae, bryophyte and macrophyte

species composition and abundance. The project

could potentially result in nutrient release to teh

channel supporting Groenlandia densa, through

sediment releases. Therefore, there is potential

for this conservation objective to be negatively

Yes

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Attribute/Measure Target Assessment of Potentially Significant Effects Mitigation

required

sub‐ types affected.

Vegetation

composition:

typical

species/Occurrence

Typical species of

the relevant

habitat sub‐type

should be present

and in good

condition

The sub-types of this habitat are poorly

understood and their typical species have yet to

be defined. The construction phase of the

project could potentially result in nutrient

release, which could alter vegetation

composition. Therefore, there is potential for

this conservation objective to be negatively

affected.

Yes

Floodplain

connectivity/Area

The area of active

floodplain at and

upstream of the

habitat should be

maintained

River connectivity with the floodplain is essential

for the functioning of this habitat and is

particularly important in terms of sediment

sorting and nutrient deposition. The project will

not affect floodplain connectivity within the

catchment. No significant effects to conservation

objective anticipated.

No

Riparian habitat/Area

The area of

riparian woodland

at and upstream of

the bryophyte‐rich

sub‐type should be

maintained

While some trees are potentially affected,

riparian woodland of conservation value

(alluvial) will not.

No

8.6.2 River Shannon and River Fergus Estuaries SPA

The overall objective for the River Shannon and River Fergus Estuaries SPA is to maintain or restore

the favourable conservation condition of the bird species listed as Special Conservation Interests for

this SPA. This section provides the conservation objectives (conservation targets) for the qualifying

interest species of the River Shannon and River Fergus Estuaries SPA (004077). The following tables

give the assessment of effect of the project on the Conservation Objectives for special conservation

interests identified as being potentially significantly affected by the proposed development. The

following tables assesses the effects of the project against the measures designed to achieve the

conservation objectives for SCIs. Where a measure may be negatively affected by the project the

need for mitigation is indicated.

8.6.2.1 Cormorant [A017]

Table 26 Assessment of conservation objectives and potential impact for Cormorant [A017]

Attribute29 Target Notes Potential Impacts Mitigation

Required

Breeding

population

abundance

No significant

decline

This measure is based

on standard survey

methods (Walsh et al.,

1995). Mitchell et al.

(2004) provides

summary population

information. The

There is ample suitable habitat

along the Shannon Estuary for this

species and it is known to occur

further upstream of the proposal

site. The project is not expected to

cause a significant decline in the

breeding population of cormorant.

No

29 Attributes/measures apply to breeding cormorant

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Attribute29 Target Notes Potential Impacts Mitigation

Required

Seabird Monitoring

Programme (SMP)

online database (JNCC,

2012) provides

population data for this

species.

Therefore, no significant effects to

this measure are expected.

Productivity

rate

No significant

decline

This measure is based

on standard survey

methods (Walsh et al.,

1995). Mitchell et al.

(2004) provides

summary population

information. The

Seabird Monitoring

Programme (SMP)

online database (JNCC,

2012) provides

population data for this

species.

The project is not expected to

cause a significant decline on the

productivity of this species.

Therefore, no significant effects to

this measure are expected.

No

Distribution

of breeding

colonies

No significant

decline

Cormorant colonies are

usually sited on flat or

rocky islets or sea stack

tops, less often on cliffs

but they can also nest

in trees (Walsh et al.,

1995)

The project is does not affect

habitat types for which Cormorant

are often sited on, namely’ rocky

islets, sea stack tops and cliffs.

Therefore, no significant effects to

this measure are expected.

No

Prey

biomass

available

No significant

decline

Key prey items include

fish (mostly benthic)

and some crustaceans.

Key habitats include

sandy areas used by

populations, rocky and

vegetated substrate.

Foraging range: max.

50km, mean 31.67km,

mean 8.46km. Birdlife

International Seabird

Database (BirdLife

International, 2012)

Cormorant are pescivorous.

Cormorant are recorded to contain

a recorded foraging distribution

across 3430 sites along the River

Shannon & Fergus Estuaries SPA,

and are not shown to use the area

surrounding the proposed

embankment refurbishments for

foraging31 activities.

No

Barriers to

connectivity

No significant

increase

Seabird species can

make extensive use of

The works will be small and

localised in nature and are not

No

30

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gus%20Estuaries%20SPA%20Supporting%20Doc_V1.pdf [accessed 19/07/2019] 31

https://www.npws.ie/sites/default/files/publications/pdf/004077_River%20Shannon%20and%20River%20Fer

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Attribute29 Target Notes Potential Impacts Mitigation

Required

the marine waters

adjacent to their

breeding colonies.

Foraging range: max.

50km, mean max.

31.67km, mean 8.46km

(BirdLife International

Seabird Database

(BirdLife International,

2012)

expected to cause any barriers to

connectivity for this CI species.

Therefore no impact to this

measure is expected.

Disturbance

at the

breeding

site

Human

activities

should occur at

levels that do

not adversely

affect the

breeding

cormorant

population

Cormorant colonies are

usually sited on flat or

rocky islets or sea stack

tops, less often on cliffs

but they can also nest

in trees (Walsh et al.,

1995)

Key habitats include sandy areas,

rocky and vegetated substrate. As

the project occurs on the

embankments contiguous to the

mud and sand flats, there is

potential for water quality

impacts/disturbance. Cormorant

are recorded to roost along the

eastern side of the project,

however, any impacts that occur

will be small and localised in

nature, and the River and Estuaries

cover an extensive area that will

provide an abundance of suitable

habitat.

Yes

Population

trend

Long term

population

trend stable or

increasing

Waterbird population

trends are presented in

part four of the

conservation objectives

supporting document.

County Clare has experienced a

breeding population decrease

from 162 to 28 pairs between

the 1969-70 and 1999-2002

seabird census counts (Mitchell

et al., 2004). Cormorant occurs

upstream of the development

site. The project is not expected

to cause any potential

significant impact on this

measure.

No

Distribution No significant

decrease in

range, timing

or intensity of

use of areas by

cormorant

other than that

occurring from

natural

patterns of

variation

As determined by

regular low tide and

other waterbird

surveys. (and discussed

in the 2010/2011

waterbird survey

programme IFI)

County Clare has experienced a

breeding population decrease

from 162 to 28 pairs between

the 1969-70 and 1999-2002

seabird census counts (Mitchell

et al., 2004). Cormorant occurs

upstream of the development

site. The project is not expected

to cause any potential

significant impact on this

No

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Attribute29 Target Notes Potential Impacts Mitigation

Required

measure.

8.6.2.2 Whooper Swan [A038]

Table 27 Assessment of conservation objectives and potential impacts for Whooper Swan [A038]

Attribute Target Notes Potential Impacts Mitigation

Required

Population

Trend

Long term

population

trend stable

of increasing

Waterbird

population

trends are

presented in

part four of the

conservation

objectives

supporting

documentation

The project is not a suitable habitat for this

SCI species. Potential impacts to this measure

are not expected to occur.

No

Distribution No significant

decrease in

the range,

timing or

intensity of

use of areas

by this

species other

than that

occurring

from natural

patterns of

variation

As determined

by regular low

tide and other

waterbird

surveys. (and

discussed in the

2010/2011

waterbird

survey

programme IFI)

During the most recent international swan

census, just over half of habitat records for

Whooper Swans were for dry improved

pasture (Boland et al. 2010). Whooper Swans

that spend winter at the Shannon and Fergus

estuaries complex are known to forage

primarily outside of the SPA boundary.

Changes in feeding distribution occur through

the winter as food supplies become

exhausted and new ones are exploited. The

project will not impact on any habitats

identified above, as such, it is not expected to

impact on this measure.

No

8.6.2.3 Light-bellied Brent Goose [A046]

Table 28 Assessment of conservation objectives and potential impacts for Light-bellied Brent Geese [A046]

Attribute Target Notes Potential Impacts Mitigation

Required

Population

Trend

Long term

population trend

stable of

increasing

Waterbird population

trends are presented

in part four of the

conservation

objectives supporting

documentation

This species is not recorded in the

area surrounding the proposed

works, which are small and

localised in nature and not

expected to cause any potential

impacts on this measure.

No

Distribution No significant

decrease in the

range, timing or

intensity of use of

areas by this

species other than

As determined by

regular low tide and

other waterbird

surveys. (and

discussed in the

2010/2011 waterbird

Brent Geese are grazers and are

known for their preference for

foraging in intertidal areas with

the Eelgrass Zostera sp. (Robinson

et al. 2004b). Where this food

source is absent the birds feed

No

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Attribute Target Notes Potential Impacts Mitigation

Required

that occurring

from natural

patterns of

variation

survey programme

IFI)

upon algae and saltmarsh plants

and the species also grazes

terrestrially. 2010/2011 waterbird

distribution (NPWS) records

indicate that this species is found

in seven subsites of the SPA, the

nearest records occurring further

downstream of the proposal site,

west of Carrig Island (where the

only record of roost sites for this

species occurred). Due to the

significant intervening distance

between the nearest population

and the project, potential impacts

on this measure are not expected

to occur.

8.6.2.4 Shelduck [A048]

Table 29 Assessment of conservation objectives and potential impacts for Shelduck [A048]

Attribute Target Notes Potential Impacts Mitigation

Required

Population

Trend

Long term

population trend

stable of

increasing

Waterbird population

trends are presented

in part four of the

conservation

objectives supporting

documentation

Shelduck individuals have been

recorded in the vicinity of the

proposed works. However, there is

more suitable habitat in other

locations such as the benthic

community of the Fergus Estuary

and Poulnasherry Bay which is

assigned the broad classification

‘Intertidal sand to mixed sediment

with polychaetes, molluscs and

crustaceans’ where (NPWS,

2012b). the gastropod mollusc

Hydrobia ulvae, a favoured prey of

Shelduck, is a distinguishing

invertebrate of this community,

occurring in moderate to high

abundances. As this species occur

on many sub sites and there is

suitable habitat and prey available,

the project can not be expected to

cause an impact on this measure.

No

Distribution No significant

decrease in the

range, timing or

intensity of use of

areas by this

species other than

As determined by

regular low tide and

other waterbird

surveys. (and

discussed in the

2010/2011 waterbird

During the 2010/11 waterbird

survey programme, Shelduck were

recorded within 41 sub sites

overall, and within 38 during low

tide surveys, with highest densities

occurring upstream of the

No

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Attribute Target Notes Potential Impacts Mitigation

Required

that occurring

from natural

patterns of

variation

survey programme

IFI)

proposal site, on the River Fergus

near Breckinish. The project is not

expected to have the potential to

impact this measure.

8.6.2.5 Wigeon [A050]

Table 30 Assessment of conservation objectives and potential impacts for Wigeon [A050]

Attribute Target Notes Potential Impacts Mitigation

Required

Population

Trend

Long term

population trend

stable of

increasing

Waterbird population

trends are presented

in part four of the

conservation

objectives supporting

documentation

The project is not expected to

impact this conservation objective.

No

Distribution No significant

decrease in the

range, timing or

intensity of use of

areas by this

species other than

that occurring

from natural

patterns of

variation

As determined by

regular low tide and

other waterbird

surveys. (and

discussed in the

2010/2011 waterbird

survey programme

IFI)

Wigeon foraged intertidally across

33 subsites and were not recorded

on the subsites that surround the

proposed works.

Eleven subsites recorded the

species foraging intertidally on a

regular basis (three or more low

tide surveys): 0H519, 0H521,

0H527, 0H528, 0I426, 0I436,

0I437, 0I439, 0I489, 0K508, and

0K509. Only two subsites held

intertidally foraging individuals

during all four low tide counts:

0I437 (Aughinish East) and 0K509

(Carrig Island). Peak numbers

were recorded for 0K508

(Bunaclugga Bay), 0I437

(Aughinish East), 0I445 (Scarlet

Reach) and 0H528 (Drumquin Pt.-

Inishmore Pt.) for the four low tide

surveys respectively. Impacts to

this conservation object are not

likely.

No

8.6.2.6 Teal [A052]

Table 31 Assessment of conservation objectives and potential impacts for Teal [A052]

Attribute Target Notes Potential Impacts Mitigation

Required

Population

Trend

Long term

population trend

stable of

increasing

Waterbird population

trends are presented

in part four of the

conservation

The project is not expected to

impact this conservation objective.

No

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objectives supporting

documentation

Distribution No significant

decrease in the

range, timing or

intensity of use of

areas by this

species other than

that occurring

from natural

patterns of

variation

As determined by

regular low tide and

other waterbird

surveys. (and

discussed in the

2010/2011 waterbird

survey programme

IFI)

Teal populations are recorded

upstream of the project site, as-

well as further downstream near

Aughinish Island and along the

River Fergus. The project is not

expected to impact this

conservation objective. Teal are a

widespread bird species that use

Intertidal mud/sand flats, shallow

subtidal and lagoon type habitats

but will are also considered highly

likely to use alternative habitat

types. The project may possess the

potential to temporarily deter

populations to use the suitable

habitat along the western

embankment, however there is

ample suitable habitat further

downstream of the project site,

therefore significant potential

impacts to this conservation

objective are not expected.

No

8.6.2.7 Pintail [A054]

Table 32 Assessment of conservation objectives and potential impacts for Pintail [A054]

Attribute Target Notes Potential Impacts Mitigation

Required

Population

Trend

Long term

population trend

stable of

increasing

Waterbird population

trends are presented

in part four of the

conservation

objectives supporting

documentation

The project is not expected to

impact this conservation objective.

No

Distribution No significant

decrease in the

range, timing or

intensity of use of

areas by this

species other than

that occurring

from natural

patterns of

variation

As determined by

regular low tide and

other waterbird

surveys. (and

discussed in the

2010/2011 waterbird

survey programme

IFI)

Pintail populations were not

recorded in the Inner Shannon

River Estuary during the winter

Low Tide Counts (2010). The

nearest record for this species

occurred at Poulnasherry Bay. This

species is considered a localised

species with wide food prey

requirements, and likely to occur

along Intertidal mud/sand flats,

sheltered and shallow subtidal

habitats. The project is not

expected to impact this

conservation objective.

No

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8.6.2.8 Shoveler [A056]

Table 33 Assessment of conservation objectives and potential impacts for Shoveler [A056]

Attribute Target Notes Potential Impacts Mitigation

Required

Population

Trend

Long term

population trend

stable of

increasing

Waterbird population

trends are presented

in part four of the

conservation

objectives supporting

documentation

The project is not expected to

impact this conservation objective.

No

Distribution No significant

decrease in the

range, timing or

intensity of use of

areas by this

species other than

that occurring

from natural

patterns of

variation

As determined by

regular low tide and

other waterbird

surveys. (and

discussed in the

2010/2011 waterbird

survey programme

IFI)

East of the project site, in Limerick

City, they mainly winter at the

Coonagh Settlement Ponds and

Westfield’s Marsh with some

found at Healy’s field. While the

nearest population to the

development site is recorded to

roost further west on the southern

Shannon bank at Ballinvoher. This

species was recorded near the

west embankment of the Shannon

Airport Embankments during the

Low Tide Count (2011), in small

numbers foraging, and further

downstream near Aughinish Island.

They are a rare breeding species

nesting in the grass or rushes close

to the water. Breeding Shoveler is

not likely to be significantly

affected by the proposed works as

these birds breed on land and

nowhere near the proposal site.

Therefore, the project will not

significantly affect the population

trend or distribution of wintering

teal.

No

8.6.2.9 Scaup [A062]

Table 34 Assessment of conservation objectives and potential impacts for Scaup [A062]

Attribute Target Notes Potential Impacts Mitigation

Required

Population

Trend

Long term

population trend

stable of

increasing

Waterbird population

trends are presented

in part four of the

conservation

objectives supporting

documentation

The project will not impact this

conservation objective.

No

Distribution No significant

decrease in the

range, timing or

As determined by

regular low tide and

other waterbird

Scaup have been recorded along

the western limits of the River

Shannon Estuary (Low Tide Count,

No

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intensity of use of

areas by this

species other than

that occurring

from natural

patterns of

variation

surveys. (and

discussed in the

2010/2011 waterbird

survey programme

IFI)

2011), in and around Clonderalaw

Bay, where they can be found

restricted to subtidal habitats

where they forage on a wide range

of food prey requirements. Given

the significant intervening distance

between the project site and this

species, impacts to this

conservation object are not

expected to occur.

8.6.2.10 Ringed Plover [A137]

Table 35 Assessment of conservation objectives and potential impacts for Ringed Plover [A137]

Attribute Target Notes Potential Impacts Mitigation

Required

Population

Trend

Long term

population trend

stable of

increasing

Waterbird population

trends are presented

in part four of the

conservation

objectives supporting

documentation

The project will not impact this

conservation objective.

No

Distribution No significant

decrease in the

range, timing or

intensity of use of

areas by this

species other than

that occurring

from natural

patterns of

variation

As determined by

regular low tide and

other waterbird

surveys. (and

discussed in the

2010/2011 waterbird

survey programme

IFI)

This species has been recorded

concentrated along the western

extent of the Shannon River

Estuary (Low Tide Count, 2011),

past Aughinish Island, Clonderalaw

Bay and Poulnasherry Bay west of

Kilrush. This species occur on

localised Intertidal mud/sand flats

habitats feeding on a wide range of

food prey requirements and are

considered highly likely to use

alternative habitats. Due to the

ecological characteristics of this

species and the significant

intervening distance between

recorded populations and the

project site, significant impacts to

this conservation objective are not

expected.

No

8.6.2.11 Golden Plover [A140]

Table 36 Assessment of conservation objectives and potential impacts for Golden Plover [A140]

Attribute Target Notes Potential Impacts Mitigation

Required

Population

Trend

Long term

population trend

stable of

increasing

Waterbird population

trends are presented

in part four of the

conservation

The project will not impact this

conservation objective.

No

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objectives supporting

documentation

Distribution No significant

decrease in the

range, timing or

intensity of use of

areas by this

species other

than that

occurring from

natural patterns

of variation

As determined by

regular low tide and

other waterbird

surveys. (and

discussed in the

2010/2011 waterbird

survey programme

IFI)

This species has been recorded in

abundance across a number of sub

sites within the River Shannon

Estuary, both upstream (Shannon

and Bunratty) and downstream

(River Fergus and Carrig Island) of

the project. The species is an

intermediately distributed species

with wide food prey requirements

that is considered reliant on the

sites upon which is occurs buts is

likely to use alternative habitats

where required. As a result, the

project is not expected to

potentially cause significant

impacts to this conservation

objective.

No

8.6.2.12 Grey Plover [A141]

Table 37 Assessment of conservation objectives and potential impacts for Grey Plover [A141]

Attribute Target Notes Potential Impacts Mitigation

Required

Population

Trend

Long term

population trend

stable of

increasing

Waterbird

population trends

are presented in part

four of the

conservation

objectives supporting

documentation

Grey plover is amber-listed as

the majority winter at less than

ten sites. However, the project will

not impact on this conservation

objective.

No

Distribution No significant

decrease in the

range, timing or

intensity of use of

areas by this

species other

than that

occurring from

natural patterns

of variation

As determined by

regular low tide and

other waterbird

surveys. (and

discussed in the

2010/2011 waterbird

survey programme

IFI)

This species is a localised (50-

100 sites) intertidal (out of the

water) walker that has wide

food prey requirements and is

considered totally reliant on

wetland habitats due to

unsuitable surrounding habitats

or is limited by habitat

requirements. This species are

mainly found in the mid and

outer estuary on intertidal

mudflats, downstream of the

project, and are a rare bird in

the upper estuary. The works

will take place outside of the

wintering season; therefore, the

project will not significantly

No

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affect wintering the population

trend or distribution of grey

plover.

8.6.2.13 Lapwing [A142]

Table 38 Assessment of conservation objectives and potential impacts for Lapwing [A142]

Attribute Target Notes Potential Impacts Mitigation

Required

Population

Trend

Long term

population trend

stable of

increasing

Waterbird

population trends

are presented in part

four of the

conservation

objectives supporting

documentation

Lapwing is red-listed due to a

decline in the breeding and non-

breeding population. The project

will not have any impact on this

conservation objective.

No

Distribution No significant

decrease in the

range, timing or

intensity of use of

areas by this

species other

than that

occurring from

natural patterns

of variation

As determined by

regular low tide and

other waterbird

surveys. (and

discussed in the

2010/2011 waterbird

survey programme

IFI)

The site is designated for

wintering lapwing, a widespread

(200-300 sites) intertidal (out of

the water) walker that has wide

food prey requirements and is

considered highly likely to use

alternative habitats. It has been

recorded upstream (east

embankment) and downstream

(Greenish Islands) of the project

site. Lapwing winter on mudflats

and estuaries as well as inland

on open grasslands or ploughed

fields and breed on grasslands

and grassy wetlands (Dempsey

and O’ Cleary, 2002). Breeding

lapwing is not likely to be

significantly affected by the

proposed works as birds breed

away from the main river

channel. The works will take

place outside of the wintering

season; therefore, the project

will not significantly affect the

population trend or distribution

of wintering lapwing.

No

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8.6.2.14 Knot [A143]

Table 39 Assessment of conservation objectives and potential impacts for Knot [A143]

Attribute Target Notes Potential Impacts Mitigation

Required

Population

Trend

Long term

population trend

stable of

increasing

Waterbird

population trends

are presented in part

four of the

conservation

objectives supporting

documentation

Knot is amber-listed due to a

moderate decline over a long -

term. It is the only bird that has

moved from the BOCCI3 red-list

to the amber-list due to a short-

term increase in wintering

population. The project will not

impact this conservation objective.

No

Distribution No significant

decrease in the

range, timing or

intensity of use of

areas by this

species other

than that

occurring from

natural patterns

of variation

As determined by

regular low tide and

other waterbird

surveys. (and

discussed in the

2010/2011 waterbird

survey programme

IFI)

This species is a localised (50-

100 sites) intertidal (out of the

water) walker that has a narrow

range of food prey requirements

and is considered totally reliant

on wetland habitats due to

unsuitable surrounding habitats

or is limited by habitat

requirements. Knot mainly

occurs in the middle and outer

estuary along mudflats and is

known to occur to the west

(west embankment at Shannon

Airport, Fergus River and

Greenish Islands) of the

proposed works. The works may

potentially cause a disturbance

to the species.

Yes

8.6.2.15 Dunlin [A149]

Table 40 Assessment of conservation objectives and potential impacts for Dunlin [A149]

Attribute Target Notes Potential Impacts Mitigation

Required

Population

Trend

Long term

population trend

stable of

increasing

Waterbird population

trends are presented

in part four of the

conservation

objectives supporting

documentation

Dunlin is amber-listed in

Ireland as the majority winter

at less than ten sites. The

project will not impact this

conservation objective.

No

Distribution No significant

decrease in the

range, timing or

intensity of use of

areas by this

species other than

As determined by

regular low tide and

other waterbird

surveys. (and

discussed in the

2010/2011 waterbird

Dunlin mainly occurs in the

middle and outer estuary along

mudflats but few individuals

can also be found around the

city. A small breeding

population can be found in the

No

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that occurring

from natural

patterns of

variation

survey programme

IFI)

Midlands (Dempsey and

O’Cleary, 2002). Records (Low

Tide Count, 2011) show that

Dunlin has been recorded

extensively using the River

Shannon Estuary for foraging,

with records of potential

roosting Dunlin along the

western Bank of the River

Fergus. Dunlins are a wintering

species. The works will take

place outside of the wintering

season; therefore, the project

will not significantly affect the

population trend or

distribution of wintering

dunlin.

8.6.2.16 Black-tailed Godwit [A156]

Table 41 Assessment of conservation objectives and potential impacts for Black-tailed Godwit [A156]

Attribute Target Notes Potential Impacts Mitigation

Required

Population

Trend

Long term

population trend

stable of

increasing

Waterbird

population trends

are presented in part

four of the

conservation

objectives supporting

documentation

Black-tailed godwit is amber-

listed in Ireland as the majority

winter at less than ten sites. The

project will not impact this

conservation objective.

No

Distribution No significant

decrease in the

range, timing or

intensity of use of

areas by this

species other

than that

occurring from

natural patterns

of variation

As determined by

regular low tide and

other waterbird

surveys. (and

discussed in the

2010/2011 waterbird

survey programme

IFI)

This species is a localised (50-

100 sites) intertidal (out of the

water) walker that has wide

food prey requirements and is

considered highly likely to use

alternative habitats. These birds

have wide prey food

requirements and feed on

intertidal mudflats, brackish

pools, and rough grassland. This

species occurs primarily west of

the site, but has been recorded

to use the area directly adjacent

to the proposed works on the

embankments (Low Tide Count,

October 2010). Birds arrive in

September and October. The

works may take place in

Yes

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September, as a result there is

the potential for impact on the

species should this occur.

8.6.2.17 Bar-tailed Godwit [A157]

Table 42 Assessment of conservation objectives and potential impacts for Bar-tailed Godwit [A157]

Attribute Target Notes Potential Impacts Mitigation

Required

Population

Trend

Long term

population trend

stable of

increasing

Waterbird population

trends are presented

in part four of the

conservation

objectives supporting

documentation

The bar-tailed godwit is amber-

listed in Ireland as the majority

winter at less than ten sites.

The project will not affect this

conservation objective.

No

Distribution No significant

decrease in the

range, timing or

intensity of use of

areas by this

species other

than that

occurring from

natural patterns

of variation

As determined by

regular low tide and

other waterbird

surveys. (and

discussed in the

2010/2011 waterbird

survey programme

IFI)

This species is a localised (50-

100 sites) intertidal mudflat

(out of the water) walker that

has wide food prey

requirements and is considered

a wide-ranging species that

likely uses a range of alternative

habitats. No observations of this

species were recorded near the

project site during the

2010/2011 High and Low Tide

Counts, however there are

records of this species along the

western bank of the River

Fergus, which connects to the

River Shannon Estuary

downstream of the proposal

site. The works will take place

outside of the wintering season;

therefore, the project will not

significantly affect the

population trend or distribution

of wintering bar-tailed godwit.

No

8.6.2.18 Curlew [A160]

Table 43 Assessment of conservation objectives and potential impacts for Curlew [A160]

Attribute Target Notes Potential Impacts Mitigation

Required

Population Long term Waterbird population Curlew is red-listed due to a No

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Trend population trend

stable of

increasing

trends are presented

in part four of the

conservation

objectives supporting

documentation

long-term decline in its

breeding and wintering

population and its breeding

range. The project will not impact

this conservation objective.

Distribution No significant

decrease in the

range, timing or

intensity of use of

areas by this

species other than

that occurring

from natural

patterns of

variation

As determined by

regular low tide and

other waterbird

surveys. (and

discussed in the

2010/2011 waterbird

survey programme

IFI)

Curlew winter in the estuary

and coastal grasslands and feed

on intertidal mudflats. They

nest in bogs, damp meadows

and farmland (Dempsey and

O’Cleary, 2002), therefore,

breeding curlew will not be

significantly impacted by the

proposal. The site is designated

for wintering curlew which is a

widespread (200-300 sites)

intertidal walker that has a

wide food prey requirement

and is considered highly likely

to use alternative habitats. The

works will take place outside of

the wintering season;

therefore, bearing all of this in

mind, the project is not

expected to significantly affect

the distribution of wintering

curlew.

No

8.6.2.19 Redshank [A162]

Table 44 Assessment of conservation objectives and potential impacts for Redshank [A162]

Attribute Target Notes Potential Impacts Mitigation

Required

Population

Trend

Long term

population trend

stable of

increasing

Waterbird population

trends are presented

in part four of the

conservation

objectives supporting

documentation

Redshank is red-listed due to a

long-term decline in its

breeding population. The

project will not impact this

conservation objective.

No

Distribution No significant

decrease in the

range, timing or

intensity of use of

areas by this

species other than

that occurring

from natural

patterns of

variation

As determined by

regular low tide and

other waterbird

surveys. (and

discussed in the

2010/2011 waterbird

survey programme

IFI)

Redshank has been recorded to

feed along the upper shore of

the River Shannon Estuary and

River Fergus, as-well as along

muddy river channels in small

numbers around the project

site location. Redshank is a

wintering species, as the works

will take place outside of the

No

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wintering season; the project

will not significantly affect the

population trend or

distribution of wintering

redshank.

8.6.2.20 Greenshank [A164]

Table 45 Assessment of conservation objectives and potential impacts Greenshank [A164]

Attribute Target Notes Potential Impacts Mitigation

Required

Population

Trend

Long term

population trend

stable of

increasing

Waterbird

population trends

are presented in part

four of the

conservation

objectives supporting

documentation

Greenshank is green-listed for

its wintering population. It was

moved from the amber to the

green list in BoCCI3 as 50% of

the wintering population occurs

at more than ten sites. The

project will not impact this

conservation objective.

No

Distribution No significant

decrease in the

range, timing or

intensity of use of

areas by this

species other

than that

occurring from

natural patterns

of variation

As determined by

regular low tide and

other waterbird

surveys. (and

discussed in the

2010/2011 waterbird

survey programme

IFI)

It winters mainly on estuaries

within some along non-

estuarine coasts. It feeds in

shallow water and soft mud.

This species is an intermediate

(100-200 sites) intertidal walker

(in water) that has wide food

prey requirements and is

considered totally reliant on

wetland habitats due to

unsuitable surrounding habitats

or is limited by habitat

requirements. It has been

recorded (Low Tide Counts,

2011) in small numbers around

Aughinish Island and along the

upper Fergus River. The works

will take place outside of the

wintering season; therefore, the

project will not significantly

affect the population trend or

distribution of wintering

greenshank.

No

8.6.2.21 Black-headed Gull [A179]

Table 46 Assessment of conservation objectives and potential impacts for Black-headed Gull [A179]

Attribute Target Notes Potential Impacts Mitigation

Required

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Population

Trend

Long term

population trend

stable of

increasing

Waterbird population

trends are presented

in part four of the

conservation

objectives supporting

documentation

Black-headed gull is red-listed

due to a long term decline in its

breeding population. The

project will not impact this

conservation objective.

No

Distribution No significant

decrease in the

range, timing or

intensity of use of

areas by this

species other

than that

occurring from

natural patterns

of variation

As determined by

regular low tide and

other waterbird

surveys. (and

discussed in the

2010/2011 waterbird

survey programme

IFI)

A widespread species in Ireland,

this species is can be found in

the summer, is a water column

diver, an intertidal walker both

in and out of the water and a

terrestrial walker. It has a wide

food prey requirement and is

considered highly likely to use

alternative habitats. The site is

designated for wintering black-

headed gull. Black-headed gull

are widespread during the

winter along the coast and

inland. Black-headed gull use

the main river channel and are

handfed at O’Callaghan’s Strand

Limerick. They are a very

common widespread breeding

species nesting in colonies in

sand dunes, coastal islands,

moorland polls, bogs and on

freshwater lake islands

(Dempsey and O’Cleary, 2002)

and have been recorded

extensively using the habitats

from Limerick City as far as

Poulnasherry Bay. Due to the

timing and nature of the works,

they will not significantly affect

any of their breeding habitats.

The works will take place

outside of the wintering season;

therefore, the project will not

significantly affect the

population trend or distribution

of wintering black-headed gull.

No

8.6.2.22 Wetlands [A999]

Table 47 Assessment of conservation objectives and potential impacts to wetlands [A999]

Attribute Target Notes Potential

Impacts

Mitigation

Required

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Wetland

habitat

area

The permanent area

occupied by the wetland

habitat should be stable

and not significantly less

than the area of 32,261

hectares, other than that

occurring form natural

patterns of variation

The wetland habitat area was

estimated as 32,261 hectares

using OSI data and relevant

ortho-photographs. For

further information see part

three of the conservation

objectives supporting

document.

No potential

impacts are

expected to affect

this conservation

objective.

No

8.7 ASSESSMENT OF POTENTIALLY SIGNIFICANT CUMULATIVE EFFECTS

NPWS have identified the main threats to the SAC from agriculture sources (fertilisation, grazing),

urbanisation, residential and commercial development, and reclamation of land.

The current pressures on the Shannon River catchment include discharges to waters from the

WWTP, industrial licensed sites and ongoing activities. These are set out in a local context in Section

6 above. There is potential for cumulative effects from these pressures on water quality during the

construction phase of the project. The proposed development works do not pose a significant

cumulative impact on water quality however. This assessment is based on the proposed works being

limited in spatial extent and low magnitude of water quality impacts. This takes into account the

large tidal exchange rates coupled with temporal nature of works (i.e. taking between 6 – 9 months).

Climate is an important environmental influence on ecosystems. Changing climate affects

ecosystems in a variety of ways. For instance, warming may force species to migrate to higher

latitudes or higher elevations where temperatures are more conducive to their survival. Similarly, as

sea level rises, saltwater intrusion into a freshwater system may force some key species to relocate

or die, thus removing predators or prey that are critical in the existing food chain.

Climate change not only affects ecosystems and species directly, it also interacts with other human

stressors such as development. Although some stressors cause only minor impacts when acting

alone, their cumulative impact may lead to dramatic ecological changes (Settele et al, 2014). For

instance, climate change may exacerbate the stress that land development places on fragile coastal

areas. Additionally, recently reclaimed land near watercourses within and upstream of the Lower

River Shannon cSAC may become vulnerable to erosion if climate change leads to increases in heavy

rain storms.

Because species differ in their ability to adjust, asynchronies can develop, increasing species and

ecosystem vulnerability. These asynchronies can include mismatches in the timing of migration,

breeding, pest avoidance, and food availability. Growth and survival are reduced when migrants

arrive at a location before or after food sources are present (Horton et al. 2014).

Ecosystems can serve as natural buffers from extreme events such as wildfires, flooding, and

drought. Climate change and human modification may restrict ecosystems’ ability to temper the

impacts of extreme conditions, and thus may increase vulnerability to damage. An example is

riparian areas that act as buffer zones protecting riverine ecosystems from runoff of silt/nutrient

laden waters via overland/pluvial flow, by absorbing/attenuating surface floodwaters.

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Climate change and shifts in ecological conditions could support the spread of pathogens, parasites,

diseases and non-native biota, with potentially serious effects on agriculture and aquatic

ecosystems.

NPWS list the threats, pressures and activities with high effect on the Lower River Shannon cSAC.

Among these are invasive non-native species, also known as alien invasive species (IAS). Invasive

non-native plant and animal species are the second greatest threat to biodiversity worldwide after

habitat destruction. They can negatively impact on native species, can transform habitats and

threaten whole ecosystems causing serious problems to the environment.

Most of Atlantic salt marsh in the Shannon Estuary is bounded on its seaward side by the extensive

Common cordgrass Spartina anglica sward. Spartina was introduced during the 1940s to increase

sediment accretion in coastal protection schemes (Bleakley 1979). It has been effective in this

respect. In the past Spartina has been associated with lowering invertebrate faunal diversities and

densities and changing the course of mudflat-saltmarsh succession by altering plant communities,

although there is recent controversy regarding these effects (McCorrey et al. 2003). Spartina

replaces the mudflat habitat with a less diverse, monospecific sward and subsequently reduces the

intertidal feeding ground for waders and other birds. Mud and saltflat communities based on

bottom-dwelling microalgae will decline, being replaced by food webs driven by the supply of

Spartina detritus. Spartina also alters the physical shape of coastal areas. Prior to colonization, in

areas where the norm is gently-sloping mudflats and shallow estuaries, Spartina alters the landscape

to form badly drained marshes that commonly have steeply sloping seaward edges and deep, steep-

sided channels (McCorrey et al. 2003). The proposed development is not considered to represent a

risk to the spread of Spartina, but there is potential for importation of other IAS to the works site.

9 MITIGATION

The key to avoid impacts to water during the works is good site management practices, tight

controls, regular inspections and ongoing vigilance with staff and employees on site.

In order to avoid or reduce the risks associated with the potential impacts, the mitigation measures

described below will be followed to reduce impact significance and adhere with the conservation

objectives for the Lower River Shannon cSAC.

A Construction Environmental Management Plan (CEMP) will be prepared by the appointed

contractor for the project in advance of works commencing, which will include management and

control measures for noise, dust, traffic, waste and surface run-off. It will describe the construction

practices and environmental management measures which are to be implemented during the

construction phase of the project in order to ensure that the project is constructed in accordance

with best practice, with the minimum impact on the surrounding environment and to comply with

any planning conditions. The CEMP will be fully implemented by the appointed contractor and

audited by the project ecologist during the project to ensure there are no significant negative

impacts.

A concise list of the primary mitigation measures are outlined in Appendix 3 (Environmental

Commitments). This is a summary of the full measures listed hereunder. The Environmental

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Commitments are to provide environmental awareness for a prospective contractor.

Implementation of the full mitigation will be required by the appointed contractor however.

At a minimum, the project characteristics listed above in Section 4.4 will be implemented to reduce

impacts. The following additional measures will also be undertaken.

9.1.1 Method statements

Method statements are used to translate the project requirements into planned systems of work

instructions to the site staff and operatives. They are prepared for activities identified in the

specification and risk assessments and are issued to all personnel responsible for and involved with

the activity concerned.

They define the proposed method of working for an element or section of work taking into account

the particular requirements of the project including site conditions, safety hazards, the contract

drawings, specification or code of practice. They define the proposed use of plant, labour and

materials, any hold points or permits and may be supplemented by drawings, sketches and produce

data as necessary.

The principle aim of a method statement is to ensure that:

• Resources are available prior to start;

• Tasks are thought out in advance; and

• Safe working methods are defined, and workers involved are aware of the risks associated

with the task

Prior to the commencement of any activities deemed to involve a significant risk to the environment,

as identified, the contractor will develop a written method statement incorporating the mitigations

outlined below. The proposed development will be constructed in cognisance of the following

guidelines to minimise the impact on the Shannon Estuary:

• 'Guidelines on Protection of Fisheries during Construction Works in and Adjacent to Waters'

(IFI, 2016); and

• 'Control of water pollution from construction sites - Guidance for consultants and

contractors' (Masters-Williams et al. 2001)

The contractor appointed to carry out the work(s) will furnish method statements on construction

methodologies prior to carrying out the works. These method statements will be submitted to

Tipperary County Council, project engineers and the project ecologist for amendment/agreement

prior to construction. All works will take place according to the final approved detailed method

statement, including the exact detail of each aspect and timing of works.

9.1.2 Protection of Habitats

To describe the measures for the management and protection of habitats on the site, the following

measures will be put in place to minimise any disturbance or impact.

• Minimise the ‘footprint’ of the development to avoid impacting the lagoon and reduce

insofar as possible the extent of mudflat directly affected.

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• Machinery required for the works will either be located on the crest of existing

embankments or will track along the sections of completed works. Plant movement will be

restricted to the embankment and the footprint of the works. Plant and vehicle movement

will be precluded on the adjacent shoreline due to ground conditions.

• Several (perhaps 3) ramps will be constructed along the access road of both embankments.

These ramps will be used primarily to bring materials to the top of the embankments, and

potentially for future maintenance works.

• Access to the proposed development site will be from the local road network.

• The site compounds will consist of bunded areas for storage of machinery and material.

Temporary secured cabins, toilets and other materials and machinery will also be

stored/located in this area. The site compound and machinery etc. will be secured at times

when construction staff are not present on site

• The access from the local road to the site compound, the site compound, and the works area

required to carry out construction will be demarcated by secure stakes and robust high

visibility tape prior to construction. This layout will be decided to ensure habitats of

conservation interest will be avoided insofar as possible. Tracking of machinery, storage and

site personnel etc. will be confined to the agreed demarcated boundaries for the duration of

the construction stage of the project.

9.1.3 Project ecologist

A project ecologist will be appointed to monitor the works on a weekly basis for the full duration of

the project. The project ecologist shall induct all construction members via ‘tool box talks’ making

them aware of the method statement and the sensitivities of the site before they are allowed to

access the site. The project ecologist will check that relevant staff are familiar with emergency

response procedures and trained in the use of spill kits. Tool box talks will be undertaken on a

weekly basis and for any new worker prior to commencement of work on site. The topics will be

determined by the nature of the work being undertaken at the time.

The project ecologist will have the authority to suspend works if works are not being carried out in

line with the agreed method statement or daily monitoring indicates that the proposed measures

are not functioning adequately to minimise the potential impact to local ecology.

9.1.4 Temporary Construction Compound(s)

The following measures will be undertaken to avoid or minimise negative effects to water quality as

a result of the erection of the temporary compound:

• Drainage within the temporary site compound will be directed to an oil interceptor to

prevent pollution if any spillage occur;

• Temporary toilet facilities will be connected to the public sewer network during the

construction phase, alternatively, discharges from the toilets will go to a holding tank where

the effluent will be temporarily stored and removed at regular intervals by an appropriate

permitted/licensed and approved contractor;

• A bunded containment area will be provided within the compound for the storage of fuels,

lubricants, oils etc; and

• The site compound will be in place for the duration of the construction phase and will be

removed once the project is complete.

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9.1.5 Excavation and Embankment Works

The following measures will be undertaken to avoid or minimise negative effects to water quality as

a result of excavations and earth works:

• Drainage and associated pollution control measures will be implemented on site before the

main body of construction activity commences

• Turf and top-soil will only be removed from the section of the embankment being worked on

(estimated length of sections to be worked on at a time approx. 50m).

• Geo-textile will be laid over coming days so denuded embankment will not be left exposed

for any extended period;

• The timing of the construction phase soil stripping and excavation works will take account of

predicted weather, particularly rainfall;

• Excavations and soil stripping activities will be suspended during periods of prolonged

rainfall events;

• The earthworks materials will be placed and compacted in layers to prevent water ingress

and degradation of the material;

• The 24 hour advance meteorological forecasting service from Met Éireann will be used; and

• In the event that petroleum contaminated soils or subsoils containing other potentially

contaminated material are discovered during excavation activities (identified through

staining, discoloration, or odour), this soil will be segregated, stockpiled, sampled for

characterisation purposes sufficient to meet the requirements of the applicable disposal

facility, transported off-site by a licensed transporter, and disposed of in an approved

treatment or disposal facility.

9.1.6 Storage and Stockpiles of Excavated Material

The following measures will be undertaken to avoid or minimise negative effects to water quality as

a result of the storage and stockpiling of excavated earth:

• Temporary stockpiles of excavated earth will be constructed within the lands made

available;

• Stockpiles of stripped soil will be strored in locations with minimum trafficking to prevent

damage and dusting;

• Stockpiled sub-soils will be located at suitably sheltered areas to prevent erosion or

weathering and shall be shaped to ensure rainfall does not degrade the stored material;

• Where unsuitable material is encountered this will be stockpiled separately and removed in

accordance with a Site Waste Method Statement;

• Stockpiles will be located away from drainage systems and silt retaining measures (silt fence,

/ silt curtain or other suitable materials) shall be installed along the down-gradient edges of

stockpiled earth materials to reduce risk of silt run-off;

• All excavated materials from the site or introduced materials for construction will be either

used or removed from the site; and

• No permanent spoil or stockpiles will be left on site, other than those materials required for

landscaping, berm construction and construction generally.

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9.1.7 Timing of works

The Shannon Estuary is known to support an array of wintering waterbirds listed as special

conservation interests in the River Shannon and River Fergus Estuaries SPA. To reduce the potential

for disturbance impacts on avifauna, it is recommended that works be carried out in agreement with

the project ecologist.

9.1.8 Hydrocarbon Control

• Fuels/oils etc will be stored within a bunded area in the enclosed compound along with

tools, materials etc. All plant is to be refuelled in this compound and a drip tray fitted to any

stationary plant working in proximity to surface waters.

• All equipment will be in good condition to avoid spillage or discharge of oil, smoke and

excessive noise.

• An appropriate waste container will be placed at a suitable location at the harbour to collect

waste before disposal by an authorised company.

• Refuelling will be carried out by competent and trained people away from any

environmentally sensitive areas; and dredger to be moored up securely

• Excavators and other equipment will be checked for any fuel/oil leaks on a regular basis by

the crew.

• Any spills we be reported immediately to the site agent/authorities

• Use absorbent materials from the spill kit to mop up the spill (sand or absorbent materials

will be used rather than detergents).

• Place boom around any affected water as a precaution.

• Do not wash spillage. Washing will only make the situation worse and disperse the pollutant

• Shovel contaminated sand/earth/absorbent granules into sacks or skips and

• A specialist oil removal company or contaminated soil company will remove pooled oil

and/or soils contaminated oil.

9.1.9 Storage

The storage of materials, containers, stockpiles and waste, however temporary, should follow best

practice at all times and be stored at designated areas. Storage will be located as follows:

• Away from drains and any watercourses or drains;

• Fuel oils etc. should be stored on a sheltered dry elevated site well removed from aquatic

zones;

• On an impermeable base;

• Under cover to prevent damage from the elements;

• In secure areas;

• Well away from moving plant, machinery and vehicles;

• On land not required until later in the development; and

• Hazardous material storage areas will be identified, labelled, and properly marked and fitted

with spill containment systems.

All containers will be stored upright and clearly labelled. Sufficient storage should be supplied near

to all working areas.

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9.1.10 Waste management

To contain and manage construction phase waste, two types of skip will be provided at the site

compound; one for recyclable waste and others for various construction wastes. These skips will be

emptied when required by a licensed waste management company.

Any waste lubricants/oils will be collected and stored in drums in the site compound within a

prefabricated bunded storage unit and will be removed and disposed of by a licensed waste

management company without delay.

There will be no discharge of effluent or waste water on site. Waste water tank and sewage will be

emptied as required and removed from site to a licensed facility. These staff facilities will be

removed at the end of the construction phase.

9.1.11 Otters

A preconstruction otter survey will be carried out in advance of the works to check the proposed

development site for otter dwellings. This survey will be carried out by a suitable qualified ecologist.

Methodology will follow Monitoring the Otter Lutra lutra by Chanin (2003b). Should a holt be found,

protocols for otters will follow Guidelines for the Treatment of Otters prior to the Construction of

National Road Schemes (NRA, 2008).

9.1.12 Invasive Species Control

The following measures will be put in place to risk of spread and importation of non-native and

invasive species.

• All plant and equipment will be checked for attached debris or plant fragments, and if

present, these will require power washing prior to entry to site

• All plant and equipment will be similarly checked prior to leaving the site, and subsequently

properly cleaned if required

• Any areas identified as supporting non-native plants will need to be treated in accordance

with established non-native species control guidance

• Non-native species control prevention will be in accordance with NRA (2010) and IFI

guidelines32

• The use of equipment that has been used in known infested waters will be avoided and

• The IFI documents ‘Invasive species biosecurity guidelines for boaters’ (IFI, 2013)33 and ‘IFI

Biosecurity Protocol for Field Survey Work (IFI, 2010)34 will be available at the site compound

for the duration of the works. The above guidance documents outline the necessary

measures for all staff in contact with the water or using equipment in contact with water.

The protocols in these documents and will form the basis of biosecurity in the lagoon during

the proposed works.

32 https://www.fisheriesireland.ie/Biosecurity/biosecurity.html 33 https://www.fisheriesireland.ie/extranet/invasive-species-1/360-invasive-species-biosecurity-guidelines-for-

boaters-leaflet-1.html 34 https://www.fisheriesireland.ie/component/docman/?task=doc_download&gid=73&Itemid=

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9.2 RESIDUAL IMPACTS

Provided that the project is built according to the project description and that recommended

mitigation measures set out above are implemented in full, it is not expected that significant impacts

will result to the qualifying features identified for appraisal in this NIS and thus it is not expected that

the proposal will have an adverse impact on the integrity of Natura 2000 sites.

9.3 CONCLUSION

In conclusion, provided the recommended mitigation measures are implemented in full it is not

expected that the construction and operation of the proposed Shannon Embankments

refurbishments adjacent to Shannon Airport will result in an adverse residual impact on the integrity

of Natura 2000 sites considered in this NIS, namely the:

• Lower River Shannon cSAC (002165)

• River Shannon and River Fergus Estuaries SPA (004077)

The provisions of Article 6 of the ‘Habitats’ Directive 92/43/EC (2000) defines ‘integrity’ as the

‘coherence of the site’s ecological structure and function, across its whole area, or the habitats,

complex of habitats and/or population of species for which the site is or will be classified’. It is

considered that the scale of the works, in addition to the implementation of the prescribed

mitigation measures, would not give rise to significant impacts affecting the integrity of the Lower

River Shannon cSAC. It is concluded that the Shannon Airport Embankments Refurbishment project,

subject to the proposed mitigation measures and conditions above, will not result in direct, indirect

or cumulative impacts which would have the potential to adversely affect the conservation

objectives of the Lower River Shannon cSAC or the River Shannon and River Fergus Estuaries SPA in

relation to the relevant Annex II species and Annex I habitats; with regard to their range, population

densities or conservation status within these designated areas.

The loss/alteration of estuarine habitat, related to revetment works on mudflat habitat adjacent to

the existing embankment within the Shannon Estuary would equate to an area of less than 0.4ha, or

less than 0.004% of the overall estimated area of this habitat type within the estuary.

Potential impacts on water quality in the Lower River Shannon cSAC are minimal due to the nature

of the proposed works and tidal exchange rates, along with mitigation measures proposed. There

would be no changes to the Lower River Shannon cSAC or River Shannon and River Fergus Estuaries

SPA with regard to the qualifying interests of these sites or key indicators of conservation value (i.e.

water quality) or changes to site integrity.

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10 REFERENCES

Bleakley, B. 1979. Spartina – an unwelcome immigrant, Irish Hare, 2, 10-12.

Chapman, P.J. and Chapman, L.L. (1982). Otter survey of Ireland Unpublished Report to Vincent

Wildlife Trust.

Chanin P (2003a). Ecology of the European Otter. Conserving Natura 2000. Rivers Ecology Series No.

10. English Nature, Peterborough.

Chanin P (2003b). Monitoring the Otter Lutra lutra. Conserving Natura 2000 Rivers Monitoring Series

No. 10, English Nature, Peterborough.

CIRIA, CUR, CETMEF (2007). The Rock Manual. The use of rock in hydraulic engineering (2nd edition).

C683, CIRIA, London,

Department of the Environment, Heritage and Local Government (DoEHLG) (2009). Appropriate

Assessment of Plans and Projects in Ireland: Guidance for Planning Authorities. Department of

Environment, Heritage and Local Government.

EC (2000). Managing Natura 2000 Sites: The provisions of Article 6 of the ‘Habitats’ Directive

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

European Commission (2007) Interpretation manual of European Union habitats- EUR 27. DG

Environment, Brussels.

EC (2001). 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. Luxembourg: Office for Official Publications of the European Communities.

IFI (2016) Guidelines on Protection of Fisheries during Construction Works in and Adjacent to

Waters. Inland Fisheries Ireland, 3044 Lake Drive, Citywest Business Campus Co. Dublin. IFI/2016/1-

4298.

Horton, R., G. Yohe, W. Easterling, R. Kates, M. Ruth, E. Sussman, A. Whelchel, D. Wolfe, and F.

Lipschultz (2014) Climate Change Impacts in the United States: The Third National Climate

Assessment, Eds., U.S. Global Change Research Program, 16-1-nn.

IFI (2016) Guidelines on Protection of Fisheries during Construction Works in and Adjacent to

Waters. Inland Fisheries Ireland, 3044 Lake Drive, Citywest Business Campus Co. Dublin. IFI/2016/1-

4298.

Kelly, F.L., Matson, R., Connor, L., Feeney, R., Morrissey, E., Coyne, J. and Rocks, K. (2014) Water

Framework Directive Fish Stock Survey of Rivers in the South Western River Basin District. Inland

Fisheries Ireland, 3044 Lake Drive, Citywest Business Campus, Dublin 24.

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Kurz, I. and Costello, M.J. (1999). An Outline of the Biology, Distribution and Conservation of

Lampreys in Ireland. Irish Wildlife Manuals, No. 5.

Maitland PS (2003) Ecology of the River, Brook and Sea Lamprey. Conserving Natura 2000 Rivers

Ecology Series No. 5. English Nature, Peterborough.

Masters-Williams, H., Heap, A., Kitts, H., Greenshaw, L., Davis, S., Fisher, P., Hendrie, M., Owens, D.

(2001) Control of water pollution from construction sites. Guidance for consultants and contractors.

DETR/CIRIA. London.

McCorrey, M, Curtis, T.G.F. & Otte, M.L., 2003. Spartina in Ireland. In Wetlands of Ireland,

distribution, ecology, uses and economic value. Otte, M.L. (ed.) University College Press Dublin, 44-

50.

McGinnity, P., Gargan, P., Roche W., Mills, P., and McGarrigle M. (2003) Quantification of the

freshwater Salmon habitat asset in Ireland using data interpreted in a GIS platform. Issue 3 of Irish

Freshwater Fisheries Ecology and Management Series, Central Fisheries Board, Dublin, 3. 131 pp.

NPWS (2007) Supporting documentation for the Habitats Directive Conservation Status Assessment ‐

backing documents, Article 17 forms and supporting maps. Unpublished Report to NPWS.

NPWS (2012a) Conservation Objectives: Lower River Shannon cSAC 002165. Version 1.0. National

Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.

NPWS (2012b) Conservation Objectives: River Shannon and River Fergus Estuaries SPA 004077.

Version 1.0. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.

NPWS (2013) The Status of EU Protected Habitats and Species in Ireland. Species Assessments

Volume 3. Version 1.0. Unpublished Report, National Parks & Wildlife Services. Department of Arts,

Heritage and the Gaeltacht, Dublin, Ireland.

NPWS (2019a). The Status of EU Protected Habitats and Species in Ireland. Volume 2: Habitat

Assessments. Unpublished NPWS report. Edited by: Deirdre Lynn and Fionnuala O’Neill.

NPWS (2019b). The Status of EU Protected Habitats and Species in Ireland. Volume 3: Species

Assessments. Unpublished NPWS report. Edited by: Deirdre Lynn and Fionnuala O’Neill

NRA (2008) Guidelines for the Treatment of Otters prior to the Construction of National Road

Schemes. National Roads Authority, St Martin’s House, Waterloo Road, Dublin 4.

NRA (2010) ‘Guidelines on the Management of Noxious Weeds and Non-Native Invasive Plant Species on National Roads’ Revision 1. National Roads Authority, St Martin’s House, Waterloo Road, Dublin 4

NRA (2006) ‘Guidelines for the protection and preservation of trees, hedgerows and scrub prior to,

during and post construction of national road schemes. National Roads Authority.

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NRA (2008) Guidelines for the Treatment of Otters prior to the Construction of National Road

Schemes. National Roads Authority.

NS 2. (2010). Freshwater Pearl Mussel Second Draft Allow Sub-Basin Management Plan. Produced by

NS 2, funded by DEHLG.

NRA (2006) A Guide to Landscape Treatments for National Road Schemes in Ireland. National Roads

Authority, Dublin.

O’Grady, M. (2006). Channels and Challenges. The enhancement of Salmonid rivers. Central Fisheries

Board, Dublin. 142pp.

Preston, C.D. (2003) Pondweeds of Great Britain and Ireland. BSBI Handbook, No. 8, Botanical

Society of the British Isles, London.

Reynolds, J.D. (1998). Conservation management of the white-clawed crayfish, Austropotamobius

pallipes Part 1. Irish Wildlife Manuals No. 1. Dúchas, the Heritage Service, Dublin.

Settele, J., R. Scholes, R. Betts, S. Bunn, P. Leadley, D. Nepstad, J.T. Overpeck, and M.A. Taboada

(2014). Terrestrial and Inland Water Systems. In: Climate Change 2014: Impacts, Adaptation and

Vulnerability. Part A: Global and Sectoral Aspects. Contribution of Working Group II to the Fourth

Assessment Report of the Intergovernmental Panel on Climate Change. Cambridge University Press.

SNH (2006) Guidance for Competent Authorities when dealing with proposals affecting SAC

freshwater sites. Scottish Natural Heritage. http://

http://www.snh.org.uk/pdfs/publications/heritagemanagement/guidanceforcompetentauthorities.p

df

TEGOS (2018) Report of the Technical Expert Group on Salmon to Inland Fisheries Ireland (IFI). The

Status of Irish Salmon Stocks in 2017 with Catch Advice for 2018.

Whilde, A., (1993) Threatened Mammals, Birds, Amphibians and Fish in Ireland – Irish Red Data Book

2: Vertebrates. HMSO, Belfast.

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Appendix

Appendix 1

Screening for Appropriate Assessment Report

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Screening for Appropriate Assessment

Shannon Airport Embankments Refurbishment,

Shannon, Co. Clare

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ISSUE FORM

Project number 19986

Document number 6001

Document revision A

Document title Screening for Appropriate Assessment: Shannon Airport Embankments

Refurbishment, Shannon, Co. Clare

Document status Final

Document prepared by CH, HD

Document checked by GH

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Table of contents

1 SUMMARY OF FINDINGS ............................................................................................ 1

1.1 Screening for Appropriate Assessment .............................................................................. 1

2 INTRODUCTION ......................................................................................................... 2

2.1 Purpose of Assessment ..................................................................................................... 2

2.2 Legislative context ............................................................................................................ 2

2.3 Stages of Appropriate Assessment..................................................................................... 2

3 ASSESSMENT METHODOLOGY ................................................................................... 2

3.1 Appropriate Assesment Guidance ..................................................................................... 2

3.2 Desk Study ........................................................................................................................ 3

3.3 Field Survey ...................................................................................................................... 3

3.3.1 Site Walkover/Habitats ......................................................................................................................... 3

3.3.2 Flora ...................................................................................................................................................... 3

3.3.3 Otter ...................................................................................................................................................... 4

3.4 Screening for Appropriate Assessment .............................................................................. 4

4 SCREENING FOR APPROPRIATE ASSESSMENT ............................................................. 4

4.1 Management of Natura 2000 sites ..................................................................................... 4

4.2 Description of Plan/Project ............................................................................................... 4

4.2.1 Brief Project Description ....................................................................................................................... 4

4.2.2 Purpose of the works ............................................................................................................................ 4

4.2.3 Site Location .......................................................................................................................................... 6

4.2.4 Description of the Site ........................................................................................................................... 6

4.2.5 Characteristics of the Project ................................................................................................................ 9

4.2.6 Identification of Other Projects or Plans or Activities ......................................................................... 12

4.3 Identification of Natura 2000 Sites .................................................................................. 18

4.3.1 Zone of Impact Influence .................................................................................................................... 18

4.3.2 Identification of Natura 2000 Sites ..................................................................................................... 18

4.3.3 Characteristics of Natura 2000 and Ramsar Sites ............................................................................... 19

4.3.4 Conservation Objectives ..................................................................................................................... 21

4.4 Identification of Potential Impacts ................................................................................... 23

4.5 Assessment of Significance of Potential Impacts .............................................................. 24

4.5.1 Natura 2000 sites outside the zone of potential impact influence ..................................................... 25

4.5.2 Natura 2000 sites within the zone of potential impact influence ....................................................... 26

4.5.3 Habitat Loss/Alteration ....................................................................................................................... 27

4.5.4 Water Quality ...................................................................................................................................... 28

4.5.5 Disturbance/Displacement of Species ................................................................................................ 28

4.5.6 Habitat or Species Fragmentation....................................................................................................... 30

4.5.7 Cumulative/In-combination Impacts .................................................................................................. 30

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4.6 Conclusion of Screening Stage ......................................................................................... 30

5 REFERENCES ............................................................................................................ 32

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TABLE OF TABLES

Table 1. List of planning permissions granted by Clare County Council in surrounding townlands for the

period 2014-2019 .................................................................................................................................. 14

Table 2. Designated conservation sites within 15km radius of proposal site....................................... 18

Table 3. Designated site with qualifying features of conservation interest ......................................... 20

Table 4: Natura 2000 sites considered to be outside the zone of potential impact influence ............ 25

TABLE OF FIGURES

Figure 1. Natura 2000 sites within 15km of the proposed embankment works at Shannon Airport .. 19

LIST OF APPENDICES

Appendix 1 Stages of Appropriate Assessment

Appendix 2 Site Synopses

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1 SUMMARY OF FINDINGS

1.1 SCREENING FOR APPROPRIATE ASSESSMENT

Project Title Shannon Airport Embankments Refurbishment

Project Proponent Shannon Airport Authority

Project Location Shannon Airport Embankments, Shannon, Co. Clare

Screening for

Appropriate

Assessment

The screening for Appropriate Assessment is undertaken to determine the

potential for likely significant effects of proposed refurbishment works at Shannon

Airport Embankments, either individually, or in combination with other plans or

projects, in view of the conservation objectives of certain Natura 2000 Sites.

Conclusion It has been objectively concluded during the screening process that significant

impacts on the following Natura 2000 sites, as a result of the proposal, are not

considered likely:

• Askeaton Fen Complex SAC (002279)

• Lough Gash Turlough SAC (000051)

• Curraghchase Woods SAC (000174)

• Ratty River Cave SAC (002316)

• Barrigone SAC (000432)

• Knockanira House SAC (002318)

• Newhall and Edenvale Complex SAC (002091)

• Poulnagordon Cave (Quin) SAC (000064)

• Kilkishen House SAC (002319)

It cannot be objectively concluded, at this stage, that significant adverse impacts

to the following sites, will not occur:

• Lower River Shannon SAC (002165)

• River Shannon and River Fergus Estuaries SPA (004077)

Therefore, it is necessary to proceed to Appropriate Assessment and as such a

Natura Impact Statement is required for these sites.

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2 INTRODUCTION

2.1 PURPOSE OF ASSESSMENT

This screening for Appropriate Assessment has been undertaken to determine the potential for

significant impacts of a proposed refurbishment of the Shannon Airport Embankments, Shannon, Co.

Clare, either independently or in combination with other plans/projects in the area, on nearby sites

with European conservation designations (i.e Natura 2000 sites).

This screening for Appropriate Assessment has been undertaken by staff ecologists from Malachy

Walsh and Partners, Engineering and Environmental consultants. A dedicated botanical survey was

undertaken by Michelle O’Neill of Cluain Ecology.

2.2 LEGISLATIVE CONTEXT

The Habitats Directive (92/43/EEC) seeks to conserve natural habitats of wild fauna and flora by the

designation of Special Areas of Conservation (SACs). The Birds Directive (2009/147/EEC) seeks to

protect birds of special importance by the designation of Special Protected Areas (SPAs). It is the

responsibility of each member state to designate SPAs and SACs, both of which form part of Natura

2000; a network of protected sites throughout the European Community. Further information is

available at:

• http://ec.europa.eu/environment/nature/legislation/habitatsdirective/

• http://ec.europa.eu/environment/nature/legislation/birdsdirective/index_en.htm

• http://www.npws.ie/planning/appropriateassessment/

• https://www.npws.ie/protected-sites/guidance-appropriate-assessment-planning-

authorities

As outlined in these, it is the responsibility of the proponent of the project, Shannon Airport Authority,

to provide a comprehensive and objective Screening for Appropriate Assessment, which can then be

used by the competent authority in order to conduct the Appropriate Assessment (DoEHLG, 2009).

2.3 STAGES OF APPROPRIATE ASSESSMENT

The Appropriate Assessment process is a four-stage process with issues and tests at each stage. The

purpose of the screening assessment is to record in a transparent and reasoned manner the likely

effects on Natura 2000 sites of a proposed development. An important aspect of the process is that

the outcome at each successive stage determines whether a further stage in the process is required.

The stages of Appropriate Assessment are set out in Appendix 1.

3 ASSESSMENT METHODOLOGY

3.1 APPROPRIATE ASSESMENT GUIDANCE

This Screening for Appropriate Assessment (Stage 1) has been undertaken in accordance with the

European Commission Methodological Guidance on the provision of Article 6(3) and 6(4) of the

‘Habitats’ Directive 92/43/EEC (EC, 2001) and the European Commission Guidance ‘Managing Natura

2000 sites’ (EC, 2000) and using guidance prepared by the NPWS (DoEHLG, 2009). This guidance

stipulates that if there are any significant, potentially significant, or uncertain effects, it will be

necessary to proceed to Appropriate Assessment and submit a Natura Impact Statement (NIS).

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A plan or project can only be authorised by a competent authority if it has made certain that it will not

adversely affect the integrity of the Natura 2000 sites relevant to the particular project. This can only

be the case where “no reasonable scientific doubt remains as to the absence of such effects”1.

3.2 DESK STUDY

In order to complete the Screening for Appropriate Assessment certain information on the existing

environment is required. A desk study was carried out to collate available information on the site’s

natural environment. This comprised a review of the following publications, data and datasets:

• OSI Aerial photography and 1:50000 mapping

• National Parks and Wildlife Service (NPWS)

• National Biodiversity Data Centre (NBDC) (on-line map-viewer)

• BirdWatch Ireland

• Teagasc soil area maps (NBDC website)

• Geological Survey Ireland (GSI) area maps

• Environmental Protection Agency (EPA) water quality data

• Shannon International River Basin District (ShIRBD) datasets (Water Framework Directive)

• Other information sources and reports footnoted in the course of the report

3.3 FIELD SURVEY

3.3.1 Site Walkover/Habitats

An ecological field survey was conducted by staff ecologists with Malachy Walsh and Partners

Environmental Consultants on February 24th and April 2nd 2019. The aim of these surveys was to

characterise the site and environs and establish the ecological features and resources at the site,

particularly in relation to the conservation interests of the Lower River Shannon SAC.

Aerial photography was used together with GPS to accurately enable field navigation. Notes were

made on all habitats encountered, including notes on dominant and indicative vegetation. A

qualitative assessment was made of plant species diversity, vegetation structure, topography and

drainage, disturbance and management. Habitats were categorised according to the Heritage

Council’s A Guide to Habitats in Ireland (Fossitt, 2000). The presence of invasive plant species was

noted.

The survey included an aquatic habitat assessment of the surface water features adjacent to the site.

Physical characteristics were noted and evaluated in cognisance of the leaflet ‘The Evaluation of

habitat for Salmon and Trout’ (DANI, 1995) and the publication ‘Ecology of the Atlantic Salmon’

(Hendry and Cragg-Hine, 2003) to assess habitat suitability for salmonids. An evaluation of lamprey

nursery habitat was also carried out based on the habitat requirements of juvenile lampreys as

outlined in Maitland (2003).

3.3.2 Flora

A dedicated botanical survey was undertaken on August 8th 2019 by Michelle O’Neill of Cluain Ecology.

1 European Court of Justice Case C-127/02 Landelijke Vereniging tot Behoud van de Waddenzee

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3.3.3 Otter

Searches for signs of otter including tracks, spraints, slides, hauling-out sites and holts were carried

out. The otter survey was conducted according to methodology described in Animal Tracks and Signs

(Bang and Dahlstrom, 2001) and The Mammal Detective (Strachan, 1995).

3.4 SCREENING FOR APPROPRIATE ASSESSMENT

As set out in the NPWS guidance, the task of establishing whether a plan or project is likely to have an

effect on a Natura 2000 site(s) is based on a preliminary impact assessment using available information

and data, including that outlined above, and other available environmental information,

supplemented as necessary by local site information and ecological surveys. This is followed by a

determination of whether there is a risk that the effects identified could be significant. The

precautionary principle approach is required.

Once the potential impacts that may arise from the proposal are identified the significance of these is

assessed through the use of key indicators:

• Habitat loss

• Habitat alteration

• Habitat or species fragmentation

• Disturbance and/or displacement of species

• Water quality and resource.

Guidance stipulates that if there are any significant, potentially significant, or uncertain effects, it will

be necessary to proceed to Appropriate Assessment and submit an NIS.

4 SCREENING FOR APPROPRIATE ASSESSMENT

Screening for Appropriate Assessment (Stage 1) determines the need for a full Appropriate

Assessment (Stage 2) and consists of a number of steps, each of which is addressed in the following

sections of this report:

4.1 Establish whether the project is necessary for the management of a Natura 2000 site

4.2 Description of the project (refurbishment of the existing Shannon Airport Embankments)

4.3 Identification of Natura 2000 sites potentially affected

4.4 Identification and description of individual and cumulative impacts of the project

4.5 Assessment of the significance of the impacts on the integrity of Natura 2000 sites

4.6 Conclusion of screening stage

4.1 MANAGEMENT OF NATURA 2000 SITES

The proposal is not connected with or necessary to the conservation management of a Natura 2000

site.

4.2 DESCRIPTION OF PLAN/PROJECT

4.2.1 Brief Project Description

Shannon Airport was constructed in the late 1930’s and 1940’s. As significant areas of the site lie below

High Tide Level, a series of flood defence measures were included in the original design of the airport.

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These measures, installed to protect the site from high tides, included the construction of sea walls

from the mainland to Dernish Island (now lying at the south-east tip of the Shannon Airport Drainage

Lagoon) and the provision of a number of drainage systems for the airport. Drawings indicating the

extent and details of the proposed development are provided in Appendix 2.

It is proposed to carry out refurbishment works to existing coastal defence structures, namely the East

Embankment and West Embankment at Shannon Airport. The proposed works at the East

embankment consist of the placement of rock armour on the front slope of the embankment. The

crest of this embankment will also be strengthened using either small rock armour or a gravel filled

geotextile. There will be a short (approx. 100m) section of the east embankment where the armouring

of the front face will be undertaken using an alternative method (armorflex or similar mattressing)

within the existing profile in order not to disturb the salt marsh habitat fronting this area. The

proposed works to the West Embankment consist of the armouring of the crest and back slope using

either small rock armour or a gravel filled geo-synthetic cellular confinement system.

4.2.2 Purpose of the works

The purpose of the project is to refurbish the existing West and East Embankments following the

winter storms of 2013/2014. The embankments are essential to the protection of the airport from

flooding from the River Shannon Estuary. The existing embankments and drainage system are

essential to the airport for the following reasons:

• To facilitate the proper drainage of the aerodrome to provide a safe aviation environment;

• To ensure that critical infrastructure and equipment including navigational aids and

pavements are not undermined through flooding;

• To ensure that water levels in the Shannon Airport Drainage Lagoon are maintained at a level

that minimises swan presence and usage of the lagoon;

• To ensure that bird activity within the airfield is minimised and that there are no other

unavoidable areas of standing water at the airport that could give rise to bird hazard (e.g.

flooding of the airfield).

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Plate 1. View of eastern embankment

Plate 2. View of western embankment

4.2.3 Site Location

The subject embankments are located at two locations along the shoreline to the south of Shannon

Airport in County Clare.

The proposed development areas form part of the boundary with and lie directly adjacent to the

Shannon Estuary. The Shannon Estuary and some areas on the landward side of the West

Embankment are designated as a Special Area of Conservation (Lower River Shannon SAC 002165) and

a Special Protection Area (River Shannon and River Fergus Estuaries SPA 004077).

4.2.4 Description of the Site

Shannon Airport is one of the country’s main airports. The Shannon Free Zone industrial area is located

immediately adjacent to the eastern boundary of the airport with Shannon town extending further

eastwards. Shannon Airport, the Shannon Free Zone and Shannon town are bounded by the Shannon

Estuary to the south and predominantly agricultural land to the north. The proposal site,

encompassing the existing West and East Embankments, sits on the northern shore of the Shannon

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Estuary which is the largest estuary in Ireland and one of the most important deep-water navigational

channels in the country2.

The Shannon Estuary forms part of both the Lower River Shannon SAC (002165) and the River Shannon

and River Fergus Estuaries SPA (004077). The Shannon and Fergus Estuaries form the largest estuarine

complex in Ireland featuring extensive intertidal mudflats, often fringed with saltmarsh vegetation

(see Plate 3 and Plate 4). The Shannon Estuary in the vicinity of the study area, given the nature of the

surrounding airfield/industrial environment, is in an urbanized setting. Existing coastal defence

structures in the form of embankments and rock armour provide a tidal defence within the section of

the estuary.

Plate 3. Mud-flat adjacent to the eastern

embankment

Plate 4. Salt-marsh located west of the western

embankment

There are two 2nd order watercourses located east of the airport within the vicinity of the Shannon

Free Zone. These drain this industrial/residential area to the east of the Airport both discharging to

the Shannon Estuary. These watercourses are the Urlan Beg Stream located close to the eastern limit

of the eastern embankment, and the Clonloghan Stream which flows into the estuary at Drumgeely

Creek3 ca. 150m east of the eastern embankment. These streams have been straightened with some

reaches also culverted and are therefore considered highly modified waterbodies.

There was no evidence of the Urlan Beg Stream passing through the eastern end of the East

Embankment during the site visit. However, there is an artificial waterbody that runs at the landward

side of, and parallel to the East Embankment. This artificial channel is connected to the Shannon

Estuary via a sluice gate located near the western limit of the East Embankment (see Plate 6). It is

considered that this channel carries the Urlan Beg Stream to the sea. Water quality issues within this

artificial channel were obvious during the site visit as an oil film was noted on the water surface near

the sluice gate. This channel is considered unsuitable for salmonids and lampreys, owing to the

apparently degraded water quality, an absence of spawning areas and unsuitable nursery habitats for

these species.

2 https://shannonestuarysifp.files.wordpress.com/2015/08/executive_summary_22112013.pdf [Accesssed 08/04/2019] 3 http://maps.biodiversityireland.ie/#/Map [Accessed 08/04/2019]

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Plate 5. View of Shannon Airport Lagoon

Plate 6. Sluice gate at junction of modified canal (which runs parallel to East Embankment) and the estuary

An artificial lagoon, known as the Shannon Airport Lagoon, is located behind the West Embankment

(see Plate 5). This drainage lagoon is separated from the sea by artificial barriers comprising the

embankment and an access road. The lagoon was developed in the 1940’s when a seawall was

constructed out into the estuary to prevent Shannon Airport from flooding. The water level in the

lagoon is managed via a sluiced outlet through which water drains via a drainage channel located in

the lagoons north-western corner.

Compliance with the reporting requirements of the Water Framework Directive (Directive

2000/60/EC) obliges each member state to publish reports providing summary information about

individual water bodies relating to their status, risks and objectives. Within this reporting framework

the Urlan Beg and Clonloghan Streams are situated within the WFD Catchment ‘Shannon Estuary

North’, the WFD Sub-catchment ‘Ballygirreen_SC_010’ and the WFD River Sub-basin ‘Urlan Beg_010’4.

With regards to WFD Risk status the ‘Urlan Beg_010’ river waterbody is under review due to its

‘Unassigned’ status. Significant pressures which have been identified in relation to this river

waterbody are ‘Urban run-off’ and ‘Diffuse sources run-off’5. Biological water quality values, or Q

values, are unavailable for both of these water courses; they are not monitored presumably due to

their size and urban context.

With regards to the WFD Transitional Waterbody identified as the ‘Upper Shannon Estuary’ into which

both watercourses flow this has been assigned a WFD Status (2010-2015) of ‘Poor’ and a Risk category

of ‘at risk’. Significant pressures which have been identified in relation to the ‘Upper Shannon Estuary’

comprise ‘Agriculture’. The risk status of the WFD Transitional Waterbody identified as the ‘Shannon

Airport Lagoon’ which is located on the landward side of the West Embankment is also under review

due to its ‘Unassigned’ status. ‘Anthropogenic pressures’ have been identified in relation to this

drainage waterbody.

4 https://gis.epa.ie/EPAMaps/ [Accessed 21/08/2019] 5 https://www.catchments.ie [Accessed 21/08/2019]

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4.2.5 Characteristics of the Project

The proposal is described below and has been confirmed with the project engineer.

Size, scale, area, land-take

It is proposed to carry out refurbishment works on the East Embankment and

West Embankment at Shannon Airport.

The East Embankment is:

• Approximately 1.3km long;

• Has an average crest level of approximately +4.20mODM to

+5.20mODM (varies);

• An average crest width of approximately 1.5m to 5m (varies greatly);

• An average seaward toe level of approximately +0.40mODM to

+1.80mODM (varies);

• An average landward toe level of approximately +0.5mODM to

+2.00mODM (varies);

• The embankment has a plan area of approximately 23,985m2.

The proposed works are to the front face and crest of the east embankment.

The works to the front will extend for much of the length some 5m seawards

of the existing embankment toe. There are two areas where this will not occur:

firstly, along an approximately 150m section that has in the past been faced

with rock armour; and, secondly a length some 100m long immediately north

east of this rock armour.

The West Embankment is:

• Approximately 1.6km long;

• Has an average crest level of approximately +4.80mODM to

+5.50mODM (varies);

• An average crest width of approximately 1.5m to 3m (varies);

• An average seaward toe level of approximately -0.50mODM to

+1.60mODM (varies);

• An average landward toe level of approximately +2.00mODM to

+3.40mODM (varies);

• The embankment has a plan area of approximately 22,320m2.

The proposed works are to the crest and backslope of the west embankment.

There will be no works on the seaward side of this embankment.

There is spatial overlap between the proposed areas of work and both the

Lower River Shannon SAC (002165) and River Shannon and River Fergus

Estuaries SPA (004077). There will be land-take within both the SAC and SPA

as a result of the proposal.

Details of physical changes that will take place during the various stages of implementing the proposal

East Embankment

In summary the works are to consist of the placement of rock armour on the

front slope of the east embankment and the strengthening of the crest of this

embankment using either small rock armour or a gravel filled geotextile. This

will result in an increase in the width of the east embankment (the footprint

will extend seawards by 5m from the existing toe - except where there is

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existing rock armour in place and a length some 100m just north east of this

armour).

The following works to the East Embankment are proposed:

• Material will be excavated to approximately -1.0mODM for

foundation pocket of proposed rock armour to the seaward face;

• The excavator will be located either on the crest of the existing

embankment or on the partly completed rock armour immediately

adjacent. Plant movement will be restricted to the embankment and

the footprint of the works.

• Gravel will be placed to blind the face of existing pitched stone on

seaward face of the section of embankment being worked on – this

gravel blinding will have a layer thickness of 100mm perpendicular to

the slope face;

• Geotextile will be placed on the gravel blinding layer;

• 2 layers of 1.3T rock armour will be placed on the geotextile;

• Turf and top soil layer will be removed from the section of

embankment being worked on (estimated length of sections to be

worked on at a time approx. 50m) to facilitate the formation of crest

protection;

• Geotextile will be placed on the prepared crest;

• Required rock armour/geosynthetic cellular confinement system will

be placed on the crest, over the geotextile;

• Gravel will be placed to blind face of armouring works on crest of

embankment – this gravel blinding will have a layer thickness of

100mm ;

• Turf and topsoil will be reinstated to complete the works.

• In the case of the 100m section north east of the existing armour it is

proposed to widen the embankment landwards by some 1m in this

area; to place a layer of proprietary protection (armorflex or similar)

within the existing front face; and to provide protection to the crest

and backface of the widened embankment. Prior to the placing of

protection (rock armour or proprietary armouring) turf and topsoil

will have been removed from the existing embankment, stored and

replaced on the newly armoured crest and backslope.

West Embankment

The works to the West Embankment are to consist of the armouring of the

crest and back slope using either small rock armour or a gravel filled geo-

synthetic cellular confinement system.

The following works to the West Embankment are proposed:

• There are no proposed works to the seaward slope of the

embankment;

• Turf and top soil layer will be removed to form crest and landward

slope protection;

• Landward slope protection will extend a minimum of 1m beyond the

embankment toe;

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• Geotextile will be placed on the prepared crest and landward slope;

• Required rock armour/geo-synthetic cellular confinement system will

be placed on the crest and landward slope, over the geotextile;

• Gravel will be placed to blind face of armouring works on crest of

embankment – this gravel blinding will have a layer thickness of

100mm;

• Turf and topsoil will be reinstated to complete the works.

In general, machinery required for the works will track along the access path

east of the west embankment. Plant and vehicle movement will be precluded

on the adjacent shoreline due to ground conditions.

Several (perhaps 3) ramps will be constructed along the access road of both

embankments. These ramps will be used primarily to bring materials to the

top of the embankments, and potentially for future maintenance works.

Description of resource requirements for the construction/operation and decommissioning of the proposal (water resources, construction material, human presence etc)

The equipment and resources required for the works will include:

• Rock armour, gravel (Imported material will be clean and will be

sourced from a licensed establishment)

• Geo-textile membrane

• Geo-synthetic cellular confinement system

• Excavator for lifting rock armour and geo-synthetic materials into

place

• Trucks for transport of rock armour/geo-synthetic materials

• Total number of excavators could range from 1 to 3 on each

embankment. Personnel on each embankment 2 to 6 plus truck

drivers.

• Welfare facilities, potable water, power source, secure site

compound

Description of timescale for the various activities that will take place as a result of implementation (including likely start and finish date)

• Duration of approximately 6-9 months between January 2020 and

December 2020.

• Works will be undertaken at each embankment in a staged manner

(at a number of locations (2 to 3) on each embankment at the same

time). This will be governed by access and storage space limitations.

Key Quantities

East Embankment:

• 1.3T Rock armour to front face: 22,000m3

• Geotextile: 24,000m2

• Gravel: 1,400m3

• Proprietary armour (armorflex or similar):1,000m3

• 75kg rock armour to crest: 1,900m3

Or:

• Geo-synthetic cellular confinement system: 6,500 m2

• Geo-synthetic cellular confinement system fill: 1,000m3

West Embankment

• 75kg Rock armour: 5,300m3

• Geotextile: 18,000m2

Or:

• Geo-synthetic cellular confinement system: 18,000m2

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• Geo-synthetic cellular confinement system fill: 2,700m3

Description of wastes arising and other residues (including quantities) and their disposal

• Turf and top layer spoil generated by works will be inert and will be

stockpiled at locations adjacent to the works until reinstatement. All

turf and top-soil is to be reinstated on-site prior to completion of the

works at each section.

• Fuels/oil/lubricants associated with plant and machinery

• Effluent from temporary on-site welfare facilities will be transported

to a suitably licensed facility for treatment

• No hazardous waste material will be generated.

Identification of wastes arising and other residues (including quantities) that may be of particular concern in the context of the Natura 2000 network

• Turf and top layer spoil generated by works will be inert and will be

reinstated on-site prior to completion of the works.

• Fuels/oil/lubricants associated with plant and machinery

• Fuels/oils etc will be stored within a bunded area in the enclosed

compound along with tools, materials etc. All plant is to be refuelled

in this compound and a drip tray fitted to any stationary plant working

in proximity to the watercourse.

Description of any additional services required to implement the project or plan, their location and means of construction

• A site compound will be required for the successful contractor to

undertake the works. This will be situated at either end of the

embankment.

• Temporary welfare facilities will be located within the site compound.

4.2.6 Identification of Other Projects or Plans or Activities

4.2.6.1 Wastewater Treatment Plant

The Shannon Town Wastewater Treatment Plant (Licence No. D0045-01)6 is located south-east of

Shannon on Inishbonane Point. This WWTP, which has a Plant Capacity (PE) of 12,500, has a primary

effluent discharge point to the Shannon Estuary upstream of the proposed development. Shannon

WWTP and pumping stations in the sewer network that serves Shannon Town are operated by Irish

Water and a private operator, Response Engineering Ltd., who are employed on behalf of Shannon

Airport subsequent to the establishment of an airport waste water treatment plant which became

fully operational in March 20077. The overall plant compliance for Shannon Town WWTP is ‘Fail’.

4.2.6.2 Licenced Sites

A search of the Environmental Protection Agency (EPA) on line resources8 indicates that there are four

licensed IPC and four licensed IEL facilities within the vicinity of the proposal site. These licenses

pertain to:

• Lufthansa Technik Painting Shannon Limited (Surface coatings)(IPC License No. P0069-02)

• International Aerospace Coatings Ltd (Coatings) (IPC License No.P0497-02)

• Elements Six Limited (Synthetic materials) (IPC License No. P0533-01)

• Heraeus Metal Processing Limited (Metals) (IPC Licence No. P0145-01)

• Badgers Blinds Limited (Blinds) (IEL Licence No. P0132-02)

• AVARA Shannon Pharmaceutical Companies (Pharmaceutical) (IEL Licence No. P0020-02)

6 http://www.epa.ie/terminalfour/wwda/wwda-view.jsp?regno=D0045-01 [accessed 26/07/2019] 7 https://www.shannonairport.ie/corporate/about/community-and-sustainability/ [accessed 26/07/2019] 8 http://gis.epa.ie/Envision [accessed 08/04/2019]

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• Molex Ireland Limited (Electronics) (IEL Licence No. P0288-02)

• ITW Ireland Unlimited Company (Polymers) (IEL Licence No. P0072-04)

Another four IEL licensed facilities are located further north-east of the proposal site in Smithstown

Industrial Estate. While these facilities are not in the immediate vicinity, the adoption of the

precautionary principal approach for this assessment means that these facilities have been included

for the purposes of this report. These licenses pertain to:

• Chemifloc Limited (Chemicals) (IEL Licence No. P0076-01)

• Shannon Circuit Technology (Technology) (IEL Licence No. P0240-01)

• Enva Ireland Limited (Waste disposal) (IEL Licence No. W0041-01)

• Galvotech International Limited (Construction) (IEL Licence No. P0292-01)

4.2.6.3 Planning Applications

Other activities, such as residential, commercial, infrastructural or recreational development could

potentially give rise to either direct impacts on habitats or species (loss of habitat, disturbance to

species) or indirect impacts (e.g. activities which could affect water quality or hydrology which could

in turn affect the status/health of populations of water dependant habitats or species). A search of

Clare County Council’s On-line Planning Enquiry System was carried out to determine what

development has been permitted in the area.

Table 1 below lists planning applications granted within the last five years for development within the

surrounding townlands, namely Rineanna South, Drumgeely, Lismacleane and Shannon Airport9

together with summary development descriptions.

9 http://www.eplanning.ie/ClareCC/searchresults/Default/1 [Accessed 08/04/2019]

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Table 1. List of planning permissions granted by Clare County Council in surrounding townlands for the period 2014-2019

File Number Decision Date Applicant Name Townland Development Description

14587 18/11/2014 Transaero Engineering Ireland Ltd.

Shannon Airport

To use an existing Aircraft Hangar for the breakup of end-of-life aircraft for recycling

15121 21/04/2015 Shannon Airport Authority

Lismacleane Shannon Airport

For the construction of a new single storey office extension, ancillary car parking including all associated site services, and minor internal hangar work space modifications at the existing Hangar Development

1517 08/04/2015 Shannon Town United

Drumgeely Tullyglass

For the construction of changing rooms at existing Soccer Pitch, including ancillary works

15234 07/10/2015 Drumgeely Playground Association

Drumgeely To construct a community playground and activity park, perimeter fencing and all ancillary site works

15329 07/07/2015 Shannon Airport Authority

Shannon Airport

For the extension of the landside covered walkway. The development will comprise of an extension to the existing landside covered walkway located across from the airport terminal building including some minor landscaping works and footpath re-instatement. An Appropriate Assessment screening statement accompanies this Planning Applications.

15450 25/08/2015 Shannon Airport Authority

Shannon Airport

For the refurbishment and localised reconfiguration of the existing Arrivals/Immigration Hall, Transit Lounge and Block A, Departure Gates areas within the Shannon Airport Terminal Building. All works are to take place 'Airside' ( past security checks) and comprise of the following : 1) Arrivals/Immigration Hall: The relocation of the existing 'European Arrivals Door', localised replacement of the existing cladding and curtain walling facade at ground and first floor levels and associated reconfiguration and refurbishment of the internal office and arrivals, immigration and baggage hall areas; 2) Transit Lounge: The reconfiguration and refurbishment of the existing internal public areas resulting in the generation of 46m2 of new airside retail space; 3) Block 'A' Departure gates 1-5: The localised replacement of the existing cladding and curtain walling facade at ground and first floor levels as well as the refurbishment of the internal public waiting and toilet areas, including all ancillary site and service works

1557 26/03/2015 Shannon Airport Authority

Rineanna South Ballyhenessy

To Extend the Appropriate Period of Planning Permission P08-1992(APB Ref 03.233151 for demolition of existing buildings, construction of new facade and adjoining building and construction of staff car park

1614 01/03/2016 Shannon Airport Authority

Shannon Airport Fire Station Shannon Airport

For construction of a ground floor extension (118m2) to the existing fire station whereby the new space is to be used as a gym. This will be completed using modular units and will require the removal of the existing portacabin type gym as well as some minor alterations to the existing fire station and all ancillary works at Shannon Airport Fire Station

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File Number Decision Date Applicant Name Townland Development Description

16361 27/06/2016 Shannon Commercial Properties

Lismacleane Drumgeely

For the demolition of 3 No existing industrial/office buildings within Shannon Industrial Estate and associated site clearance works along with all other associated site works

16543 19/08/2016 Derk Estates Drumgeely For RETENTION permission to RETAIN alterations carried out to two apartment blocks including alterations to corridor and window arrangement, enclosing of some open balconies and elevational changes at Hawthorn and Linden Apartment Blocks, Drumgeely, Shannon

16788 20/01/2017 Shannon Airport Authority

Shannon Airport

For the development within a Strategic Development Zone of a Fire Training Ground at the Secondary Surveillance Radar Equipment site on the north side of Runway 06-24, Shannon Airport, Co Clare. The development will comprise of the installation of a Simulated Steel Aircraft Shell, a Fire Screen and Engine Rig for the purpose of training fire fighting personnel. Also included in the development will be an overground Water Storage Tank, 2 No. 2 Tonne LPG Gas Tanks, a 300 Gallon Jet A1 Fuel Tank, 3 No. sheds to house controls and fuel pressurisation unit, security fencing to surround site perimeter, concrete hardstanding areas, site lighting and all other associated site works. An Appropriate Assessment screening statement accompanies this planning Application.

17125 22/05/2017 Rocktwist Holdings Ltd.

Caherteige Drumgeely

Construct an industrial unit with office accommodation for industrial, warehouse and logistic usage, including ancillary site development works

17494 04/08/2017 Nan & Mul Catering Ltd. t/a Freshtoday

Ballymurtagh Drumgeely

To construct new mezzanine floor space of 120m2 for use as storage area at existing unit ( Originally granted under Planning Ref. P01-626) including ancillary site works

1724 15/03/2017 Shannon Airport Authority DAC

Lismacleane & Ballyhennessy Bunratty Lower, Shannon

For the following proposed development which will comprise of the construction of a new steel framed aircraft hangar within the airport lands at Shannon Airport, Co. Clare. The hangar building includes for ancillary office space, workshops, plant rooms and storage space. The building will have signage on the eastern, southern and western facades. Ancillary buildings and structures within the curtilage of the site including an external pump house, gas skid and fire suppression tank are also proposed. Site works proposed include car parking, hardstands, landscaping, and all ancillary site developments at this address. An Integrated Pollution and Control License is required for the facility

17602 27/09/2017 Shannon Airport Rineanna South Shannon Airport

For development which will consist of the extension of existing covered walkways at car parks. An appropriate assessment screening statement accompanies this application

17910 19/01/2018 Shannon Airport Authority DAC

Shannon Airport

For proposed alterations and refurbishment works to the New Terminal Building at Shannon Airport. The development, within a Strategic Development Zone, will consist of upgrade works to the existing arrivals Hall at Shannon Airport including alterations to the existing southern and eastern elevations and provision of additional floor area of 42.5m2 to facilitate new Café and 16m2 for ancillary accommodation

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File Number Decision Date Applicant Name Townland Development Description

17998 23/02/2018 Shannon Commercial Properties

Shannon Airport Shannon

Further to previously granted planning application Ref: P16-405 for amendments and additions to the car parking area and all associated site works and services. Previously granted were 202 nr. parking spaces. The new total will be 298 nr spaces (96 nr. additional) including 15 nr. accessible spaces and 29 nr. electrical car recharge spaces

18417 24/09/2018 Shannon Commercial Properties

Caherteige Drumgeely

For the demolition of existing industrial / office buildings within Block K, within Shannon Industrial Estate and associated site clearance works along with all other associated site works to allow for future development on site

18514 16/08/2018 Shannon Airport Authority

New Terminal Building Shannon Airport

For alterations and refurbishment works which were carried out to the New Terminal Building

18545 20/08/2018 The Board of Management, St. John’s NS

Drumgeely Tullyglass

For the installation of a portacabin to be used as a pre-school facility with connection to services including ancillary site works.

19207 15/05/2019 Shannon Town Ltd.

Drumgeely Tullyglass

For the construction of changing rooms at existing Soccer Pitch, including ancillary site works

The potential for cumulative/in-combination effects between the proposal and other plans, projects and activities, as identified above, is assessed in Section 4.5.7

below.

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4.3 IDENTIFICATION OF NATURA 2000 SITES

4.3.1 Zone of Impact Influence

The screening stage of AA involves compiling a ‘long list’ of European sites within a zone of potential

impact influence for later analysis which may or may ultimately not be significantly impacted upon by

the proposal. All Natura 2000 sites within 15km of the proposal location will be characterised in the

context of the rationale for designation and qualifying features, in accordance with NPWS guidance.

In line with the precautionary principle, this report considers any Natura 2000 sites that lie outside

15km that may be significantly impacted as a result of the proposed development. Following this, the

potential impacts associated with the proposal will be identified before an assessment is made of the

likely significance of these impacts.

As described above, the test for the screening for Appropriate Assessment is to assess, in view of best

scientific knowledge, if the development, individually or in combination with other plan/project is

likely to have a significant effect on a Nature 2000 site. If there are any significant, potentially

significant, or uncertain effects, it will be necessary to proceed to Appropriate Assessment and submit

an NIS.

4.3.2 Identification of Natura 2000 Sites

Adopting the precautionary principle in identifying potentially affected European sites it has been

decided to include all SACs and SPAs within a 15km radius of the proposal site.

Table 2 below lists the designated SACs and SPAs within 15km, or the zone of influence of the proposal

site, including their proximity. A map showing all Natura 2000 sites within 15km of the proposal is

shown in Figure 1.

Table 2. Designated conservation sites within 15km radius of proposal site

No. Designated Site Site Code Approximate distance and direction from the

proposed development

1 Lower River Shannon SAC 002165 Within and adjacent to the proposal site

2 River Shannon and River Fergus

Estuaries SPA

004077 Within and adjacent to the proposal site

3 Askeaton Fen Complex SAC 002279 5.5km to the south of the proposal site

4 Lough Gash Turlough SAC 000051 6.3km to the north of the proposal site

5 Curraghchase Woods SAC 000174 7.5km to the south-east of the proposal site

6 Ratty River Cave SAC 002316 11km to the north-east of the proposal site

7 Barrigone SAC 000432 11km to the south-west of the proposal site

8 Knockanira House SAC 002318 13km to the north-west of the proposal site

9 Newhall and Edenvale Complex SAC 002091 13.3km to the north-west of the proposal site

10 Poulnagordon Cave (Quin) SAC 000064 13.3km to the north-east of the proposal site

11 Kilkishen House SAC 002319 14.9km to north-east of the proposal site

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Figure 1. Natura 2000 sites within 15km of the proposed embankment works at Shannon Airport

4.3.3 Characteristics of Natura 2000 and Ramsar Sites

The following tables list the features of interest for the SAC and SPA sites that lie within 15km of the

proposal site. Information pertaining to designated sites is from site synopses, conservation objectives

and other information available on www.npws.ie.

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Table 3. Designated site with qualifying features of conservation interest

Site name Site code Qualifying features

Lower River

Shannon SAC 002165

• Sandbanks which are slightly covered by sea water all the time

[1110]

• Estuaries [1130]

• Mudflats and sand flats not covered by seawater at low tide

[1140]

• Coastal lagoons [1150]

• Large shallow inlets and bays [1160]

• Reefs [1170]

• Perennial vegetation of stony banks [1220]

• Vegetated sea cliffs of the Atlantic and Baltic coasts [1230]

• Salicornia and other annuals colonising mud and sand [1310]

• Atlantic salt meadows (Glauco-Puccinellietalia maritimae) [1330]

• Mediterranean salt meadows (Juncetalia maritimi) [1410]

• Water courses of plain to montane levels with the Ranunculion

fluitantis and Callitricho-Batrachion vegetation [3260]

• Molinia meadows on calcareous, peaty or clayey-silt-laden soils

(Molinion caeruleae) [6410]

• Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-

Padion, Alnion incanae, Salicion albae) [91E0]

• Freshwater Pearl Mussel (Margaritifera margaritifera) [1029]

• Sea Lamprey (Petromyzon marinus) [1095]

• Brook Lamprey (Lampetra planeri ) [1096]

• River Lamprey (Lampetra fluviatilis) [1099]

• Salmon (Salmo salar ) [1106]

• Common Bottlenose Dolphin (Tursiops truncates) [1349]

• Otter (Lutra lutra) [1355]

Askeaton Fen

Complex SAC 002279

• Calcareous fens with Cladium mariscus and species of the

Caricion davallianae [7210]

• Alkaline fens [7230]

Lough Gash

Turlough SAC 000051

• Turloughs [3180]

• Rivers with muddy banks with Chenopodion rubri p.p. and

Bidention p.p. vegetation [3270]

Curraghchase

Woods SAC 000174

• Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-

Padion, Alnion incanae, Salicion albae) [91E0]

• Taxus baccata woods of the British Isles [91J0]

• Lesser Horseshoe Bat (Rhinolophus hipposideros) [1303]

Ratty River

Cave SAC 002316

• Caves not open to the public [8310]

• Lesser Horseshoe Bat (Rhinolophus hipposideros) [1303]

Barrigone SAC 000432

• Juniperus communis formations on heaths or calcareous

grasslands [5130]

• Semi-natural dry grasslands and scrubland facies on calcareous

substrates (Festuco-Brometalia) (* important orchid sites)

[6210]

• Limestone pavements [8240]

• Marsh Fritillary (Euphydryas aurinia) [1065]

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Site name Site code Qualifying features

Knockanira

House SAC 002318 • Lesser Horseshoe Bat (Rhinolophus hipposideros) [1303]

Newhall and

Edenvale

Complex SAC

002091 • Caves not open to the public [8310]

• Lesser Horseshoe Bat (Rhinolophus hipposideros) [1303]

Poulnagordon

Cave (Quin)

SAC

000064 • Caves not open to the public [8310]

• Lesser Horseshoe Bat (Rhinolophus hipposideros) [1303]

Kilkishen

House SAC 002319 • Lesser Horseshoe Bat (Rhinolophus hipposideros) [1303]

River Shannon

and River

Fergus

Estuaries SPA

004077

• Cormorant (Phalacrocorax carbo) [A017]

• Whooper Swan (Cygnus cygnus) [A038]

• Light-bellied Brent Goose (Branta bernicla hrota) [A046]

• Shelduck (Tadorna tadorna) [A048]

• Wigeon (Anas penelope) [A050]

• Teal (Anas crecca) [A052]

• Pintail (Anas acuta) [A054]

• Shoveler (Anas clypeata) [A056]

• Scaup (Aythya marila) [A062]

• Ringed Plover (Charadrius hiaticula) [A137]

• Golden Plover (Pluvialis apricaria) [A140]

• Grey Plover (Pluvialis squatarola) [A141]

• Lapwing (Vanellus vanellus) [A142]

• Knot (Calidris canutus) [A143]

• Dunlin (Calidris alpina) [A149]

• Black-tailed Godwit (Limosa limosa) [A156]

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

• Curlew (Numenius arquata) [A160]

• Redshank (Tringa totanus) [A162]

• Greenshank (Tringa nebularia) [A164]

• Black-headed Gull (Chroicocephalus ridibundus) [A179]

• Wetland and Waterbirds [A999]

4.3.4 Conservation Objectives

According to the Habitat’s Directive, the conservation status of a natural habitat will be taken as

‘favourable’ within its biogeographic range when:

• Its natural range and areas it covers within that range are stable or increasing, and

• The specific structure and functions which are necessary for its long-term maintenance exist

and are likely to continue to exist for the foreseeable future, and

• The conservation status of its typical species is favourable as defined below.

According to the Habitat’s Directive, the conservation status of a species means the sum of the

influences acting on the species concerned that may affect the long-term distribution and abundance

of its populations. The conservation status will be taken as ’favourable’ within its biogeographic range

when:

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• Population dynamics data on the species concerned indicate that it is maintaining itself on a

long-term basis as a viable component of its natural habitats, and

• The natural range of the species is neither being reduced nor is likely to be reduced for the

foreseeable future, and

• There is, and will probably continue to be, a sufficiently large habitat to maintain its

populations on a long-term basis.

The conservation objectives for each site are available on www.npws.ie. These have been accessed

for the sites listed in the tables above on the 22nd August 2019.

Site specific and detailed conservation objectives are available for the following sites:

• Lower River Shannon SAC (002165). Version 1.0. Produced August 2012

• River Shannon and River Fergus Estuaries SPA (004077). Version 1.0. Produced September

2012.

• Lough Gash Turlough SAC (000051). Version 1. Produced November 2017.

• Askeaton Fen Complex SAC (002279). Version 1. Produced May 2018.

• Curraghchase Woods SAC (000174). Version 1. Produced July 2018.

• Ratty River Cave SAC (002316). Version 1. Produced July 2018.

• Barrigone SAC (000432). Version 1. Produced February 2019.

• Knockanira House SAC (002318). Version 1. Produced July 2018.

• Newhall and Edenvale Complex SAC (002091). Version 1. Produced July 2018.

• Poulnagordon Cave (Quin) SAC (000064). Version 1. Produced July 2018.

• Kilkishen House SAC (002319). Version 1. Produced July 2018.

Management plans were not available for any sites.

All conservation objectives together with other designated site information are available on

http://www.npws.ie/protectedsites/.

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4.4 IDENTIFICATION OF POTENTIAL IMPACTS

Potential likely ecological impacts arising from the project are identified in this section.

Description of elements of the project likely to give rise to potential ecological impacts.

East Embankment

- The east embankment lies directly adjacent to the

boundary of the Lower River Shannon SAC and overlaps

with the River Shannon and River Fergus Estuaries SPA.

- Enlargement of embankment footprint (increasing width

by 5m seawards along approx. 0.8km of embankment

length, and increasing width by 1m landwards along

approx. 100m length)

- Site preparation works including excavations to -1.0ODM

for rock armour foundation pocket on seaward face

- Placement of gravel to blind face of existing pitched

stone on seaward face

- Installation of rock armour on front slope of

embankment

- Removal of existing turf and top-soil layer on crest of

embankment

- Installation of rock armour (or geo-synthetic cellular

confinement system) on top of geotextile on crest

- Installation of gravel to blind face of armouring works on

crest

- Re-instatement of turf and top-soil

West Embankment

- The west embankment partially overlaps with the Lower

River Shannon SAC and the River Shannon and River

Fergus Estuaries SPA.

- Enlargement of embankment footprint (increasing width

by c.1m landwards from embankment toe. There are no

proposed works to the seaward slope of the

embankment

- Removal of existing turf and top-soil layer on crest and

landward slope

- Installation of rock armour (or geo-synthetic cellular

confinement system) on top of geotextile on crest and

landward slope

- Installation of gravel to blind face of armouring works on

crest

- Re-instatement of turf and top-soil

General

- Use of heavy machinery and vehicles (excavators/trucks)

for the duration of the works

- Construction of access ramps/temporary site compound

- Import of materials to site (rock armour, gravel)

- Increase in human activity for duration of works

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- Duration of the project (expected duration 6-9 months

between January 2020 and December 2020)

Describe any likely direct, indirect or secondary ecological impacts of the project (either alone or in combination with other plans or projects) by virtue of:

• Size and scale;

• Land-take;

• Distance from Natura 2000 Site or key features of the Site;

• Resource requirements;

• Emissions;

• Excavation requirements;

• Transportation requirements;

• Duration of construction, operation etc.; and

• Other.

East Embankment

- Increasing embankment width by 5m seawards along

approximately 0.8km will result in land take within

Natura 2000 sites (ca. 0.4ha)

- Permanent removal of habitat within Natura 2000 sites

through removal via excavation to -1.0ODM

- Loss/alteration of mudflat habitat (c. 0.4ha total) within

Natura 2000 sites through installation of rock armour

West Embankment

- The west embankment has a total length of c.1.6km

- Of this, approx. 300m is situated outside of any Natura

2000 site boundary

- Therefore associated land take within Natura 2000 sites

as a result of increasing embankment width by 1m will be

c.1,300m2

General

- Risk of water quality impacts during construction phase

via:

o Erosion and run-off of fines/nutrient-enriched

material from excavations, denuded embankments,

temporary storage areas for turf and top-soil

o Disturbance of littoral sediment during excavation

works

o Use and storage of fuel, oils and other such

substances

- Risk of species disturbance/displacement impacts via:

o Increased noise from plant/machinery and human

presence

o Potential habitat impacts

- Risk of habitat alteration/disturbance via:

o Use of machinery/vehicles

o Construction of access ramps/temporary site

compound

o Slippage of gravel material from seaward face of

east embankment onto adjacent habitat

o Potential alteration of sediment supply from

construction of physical barriers (rock armour)

4.5 ASSESSMENT OF SIGNIFICANCE OF POTENTIAL IMPACTS

This section considers the list of sites identified in Section 4.3.2 above, together with the potential

ecological impacts identified in the previous section and determines whether the project is likely to

have significant effects on a Natura 2000 site. When assessing impact, Natura 2000 sites are only

considered relevant where a credible or tangible source-pathway-receptor link exists between the

proposed development and a protected species or habitat type. In order for an impact to occur there

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must be a risk initiated by having a 'source' (e.g. dredging), a 'receptor' (e.g. a protected

habitat/species and/or the habitats on which they depend), and an impact pathway between the

source and the receptor (e.g. a waterbody which connects the proposal site to the protected species

or habitats).

An evaluation based on these factors to determine which species and habitats are the plausible

ecological receptors for potential impacts of the proposed development will be conducted in Sections

4.5.1 and 4.5.2 below. The evaluation takes cognisance of the scope, scale, nature and size of the

project, its location relative to the Natura 2000 sites listed in Table 2 above, and the degree of

connectedness that exists between the project and each Natura 2000 site’s potential ecological

receptors.

4.5.1 Natura 2000 sites outside the zone of potential impact influence

It is considered that the proposal does not include any element that has the potential to significantly

alter the favourable conservation status of species and habitats for which certain Natura 2000 sites,

listed in Table 2 above, are designated. It is considered that conditions required to initiate a potential

‘source-pathway-target’ vector connecting the proposal site to these Natura 2000 sites will not be

created and that no plausible potential impact pathway connects these sites to the location of the

proposed development. It is considered that these Natura 2000 sites are outside the zone of potential

impact influence of the proposed works. These sites are listed in Table 4 below and the rationale for

exclusion from further discussion is provided.

Table 4: Natura 2000 sites considered to be outside the zone of potential impact influence

Natura 2000 site Distance intervening

and direction to Natura

2000 site

Rationale for exclusion from assessment

Askeaton Fen Complex

SAC (002279)

Approx. 5.5km to the

south

• Designated for the protection of two fen

habitats

• No spatial overlap

• No plausible impact pathway

• No significant effects likely

Lough Gash Turlough

SAC (000051)

Approx. 6.3km to the

north

• Designated for the protection of

wetland/riparian habitats

• No spatial overlap

• No plausible impact pathway

• No significant effects likely

Curraghchase Woods

SAC (000174)

Approx. 7.5km to the

south-east

• Designated for the protection of woodland

habitats and lesser horseshoe bat

• No spatial overlap/distance intervening

• No plausible impact pathway

• No significant effects likely

Ratty River Cave SAC Approx. 11km to the

north-east

• Designated for the protection of caves and

lesser horseshoe bat

• No spatial overlap/distance intervening

• No plausible impact pathway

• No significant effects likely

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Natura 2000 site Distance intervening

and direction to Natura

2000 site

Rationale for exclusion from assessment

Barrigone SAC (000432) Approx. 11km to the

south-west

• Designated for the protection of terrestrial

habitats and marsh fritillary

• No spatial overlap/distance intervening

• No plausible impact pathway

• No significant effects likely

Knockanira House SAC

(002318)

Approx. 13km to the

north-west

• Designated for the protection of lesser

horseshoe bat

• No spatial overlap/distance intervening

• No plausible impact pathway

• No significant effects likely

Newhall and Edenvale

Complex SAC (002091)

Approx. 13.3km to the

north-west

• Designated for the protection of caves and

lesser horseshoe bat

• No spatial overlap/distance intervening

• No plausible impact pathway

• No significant effects likely

Poulnagordon Cave

(Quin) SAC (000064)

Approx. 13.3km to the

north-east

• Designated for the protection of caves and

lesser horseshoe bat

• No spatial overlap/distance intervening

• No plausible impact pathway

• No significant effects likely

Kilkishen House SAC Approx. 14.9km to

north-east

• Designated for the protection of lesser

horseshoe bat

• No spatial overlap/distance intervening

• No plausible impact pathway

• No significant effects likely

Bearing in mind the rationale for exclusion from assessment outlined in Table 4 above, it is objectively

concluded that significant impacts on the above sites are not reasonably foreseeable as a result of the

programme of works described at Section 4.2.5 above. As such these sites will not be considered

further in this document.

4.5.2 Natura 2000 sites within the zone of potential impact influence

There is spatial overlap between the proposed works and both the Lower River Shannon SAC (002165)

and the River Shannon and River Fergus Estuaries SPA (004077). It is therefore considered that

potential exists for significant effects on these sites.

Therefore, the assessment of significance of potential impacts that follows focuses on the following

designated sites considered to be within the zone of impact influence of the proposal:

• Lower River Shannon SAC (002165)

• River Shannon and River Fergus Estuaries SPA (004077)

The likelihood of significant effects to a Natura 2000 site from the project was determined based on a

number of indicators which include:

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• Habitat loss and habitat alteration

• Disturbance and/or displacement of species

• Habitat or species fragmentation

• Water quality and resource

The likelihood of significant cumulative/in-combination effects is assessed in Section 4.5.7 below.

4.5.3 Habitat Loss/Alteration

4.5.3.1 Lower River Shannon SAC (002165)

The Lower River Shannon SAC is designated for the protection of fourteen habitat types. Of these,

eleven are categorised as coastal or halophytic in distribution, one is freshwater, one is described as

a natural and semi-natural grassland formation and one is categorised as forests (DGE, 2013). The

habitats are as follows:

• Sandbanks which are slightly covered by sea water all the time [1110]

• Estuaries [1130]

• Mudflats and sand flats not covered by seawater at low tide [1140]

• Coastal lagoons [1150]

• Large shallow inlets and bays [1160]

• Reefs [1170]

• Perennial vegetation of stony banks [1220]

• Vegetated sea cliffs of the Atlantic and Baltic coasts [1230]

• Salicornia and other annuals colonising mud and sand [1310]

• Atlantic salt meadows (Glauco-Puccinellietalia maritimae) [1330]

• Mediterranean salt meadows (Juncetalia maritimi) [1410]

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

Batrachion vegetation [3260]

• Molinia meadows on calcareous, peaty or clayey-silt-laden soils (Molinion caeruleae)

[6410]

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

Salicion albae) [91E0]

The proposed works will result in an increase in the overall footprint of both embankments. Proposed

works to the East Embankment will extend the structures footprint both seawards and landwards. The

proposed works to the West Embankment will extend onto habitats on the landward side of the

existing structure. There is spatial overlap between the proposal site and the SAC. Therefore, there is

potential for direct habitat loss/alteration within the Lower River Shannon SAC.

There is also a risk of indirect habitat alteration/disturbance within the SAC as a result of movement

of plant, machinery and vehicles associated with the works, construction of access ramps and a

temporary site compound and/or potential slippage of gravel from embankments onto adjacent

habitats. With regards to the potential for indirect habitat alteration via water quality impacts it is

considered that the proposal has the potential to result in impairment of water quality within the

Lower River Shannon SAC. This aspect of the proposal is discussed further in Section 4.5.4 below.

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Bearing in mind the nature, scale and location of the proposed works, direct/indirect loss or alteration

impacts on Annex I habitats within the Lower River Shannon SAC are uncertain. In summary, it is

objectively concluded that there is potential for significant habitat loss and alteration effects, or

significant habitat loss and alteration effects cannot be ruled out at this stage, to the Lower River

Shannon SAC, as a result of the proposal considered in this report.

4.5.3.2 River Shannon and River Fergus Estuaries SPA (004077)

The River Shannon and River Fergus Estuaries SPA is designated for the protection of ‘Wetlands’. The

proposed works will result in an increase in the overall footprint of both embankments. There is spatial

overlap between the proposal site and the SPA. Therefore, there is potential for habitat loss/alteration

to ‘Wetland’ habitat within the River Shannon and River Fergus Estuaries SPA.

There is also potential for indirect habitat alteration effects to ‘Wetlands’ through use and movement

of plant, installation of access ramps or the site compound, loss of gravel material and/or potential

water quality impacts associated with the proposal, as outlined in Section 4.5.3.1 above.

Bearing in mind the nature, scale and location of the proposed works, direct/indirect loss or alteration

impacts on ‘Wetland’ habitat, or alternatively habitats which may potentially be utilised by SCI species

for the River Shannon and River Fergus Estuaries SPA, are uncertain. In summary, it is objectively

concluded that there is potential for significant habitat loss and alteration effects, or significant habitat

loss and alteration effects cannot be ruled out at this stage, to the River Shannon and River Fergus

Estuaries SPA, as a result of the proposal considered in this report.

4.5.4 Water Quality

There are several aspects of the proposal which could potentially give rise to adverse water quality

impacts within either the Lower River Shannon SAC or the River Shannon and River Fergus Estuaries

SPA, as outlined in Section 4.4 above.

Impairment of water quality could potentially occur as a result of erosion and run-off of sediment from

excavations, denuded embankments or temporary spoil storage areas or from accidental spillage or

leakage of fuel/oil from machinery/plant which will be in-use during the works or fuel

storage/refuelling areas. These elements of the proposal, left unmanaged, could therefore give rise

to point or diffuse source inputs of pollution. Therefore, while the proposal to refurbish the existing

embankments, as outlined in Section 4.2.5 above, is not unusual or inherently complex, it is

considered to have the potential to impact on water quality within Natura 2000 sites.

Bearing in mind the nature, scale and location of the proposed works, water quality impacts to Natura

2000 sites as a result of the proposal are uncertain. In summary, it is objectively concluded that there

is potential for significant water quality effects, or significant water quality effects cannot be ruled out

at this stage, within the Lower River Shannon SAC and the River Shannon and River Fergus Estuaries

SPA, as a result of the proposal considered in this report.

4.5.5 Disturbance/Displacement of Species

4.5.5.1 Lower River Shannon SAC (002165)

The Lower River Shannon SAC is designated for the protection of seven aquatic/semi-aquatic species,

as follows:

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• Freshwater Pearl Mussel (Margaritifera margaritifera) [1029]

• Sea Lamprey (Petromyzon marinus) [1095]

• Brook Lamprey (Lampetra planeri ) [1096]

• River Lamprey (Lampetra fluviatilis) [1099]

• Salmon (Salmo salar ) [1106]

• Common Bottlenose Dolphin (Tursiops truncates) [1349]

• Otter (Lutra lutra) [1355]

Given the nature of these species it is considered that potential impacts on water quality arising as a

result of the proposal are the most likely sources of potential disturbance/displacement effects. As

well as direct disturbance/displacement through potential water quality deterioration within the SAC

disturbance/displacement effects could also arise indirectly through adverse impacts on QI prey

species. With regards to otter, proposed works along the shoreline such as installation of rock armour

will lead to alteration of coastal/inter-tidal habitat, which could lead to indirect

disturbance/displacement effects as a result of the modification of potential foraging/commuting

habitat.

Qualifying interest species potentially occurring in the vicinity of the works during construction activity

could also potentially be subject to disturbance/displacement effects via fugitive noise emissions

associated with the works, as well as the increase in human activity/presence throughout the

construction phase of the project.

Bearing in mind the nature, scale and location of the proposed works, direct/indirect

disturbance/displacement impacts on qualifying interest species for the Lower River Shannon SAC are

uncertain. In summary, it is objectively concluded that there is potential for significant species

disturbance/displacement effects, or significant species disturbance/displacement effects cannot be

ruled out at this stage, for the Lower River Shannon SAC, as a result of the proposal considered in this

report.

4.5.5.2 River Shannon and River Fergus Estuaries SPA (004077)

The River Shannon and River Fergus Estuaries SPA is designated for a variety of wintering bird species.

Given that the works, as scheduled, will overlap with the wintering season (6-9 month duration

between January 2020 and December 2020), and that SCI species are known to occur within the

vicinity of the proposal site including in the Shannon Airport Drainage Lagoon, it is considered that the

proposal has potential to result in direct and indirect disturbance/displacement effects to SCI species.

Such effects could arise directly as a result of noise emissions and human activity or indirectly through

habitat alteration.

Bearing in mind the nature, scale and location of the proposed works, direct/indirect

disturbance/displacement impacts on qualifying interest species for the River Shannon and River

Fergus Estuaries SPA are uncertain. In summary, it is objectively concluded that there is potential for

significant species disturbance/displacement effects, or significant species disturbance/displacement

effects cannot be ruled out at this stage, for the River Shannon and River Fergus Estuaries SPA, as a

result of the proposal considered in this report.

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4.5.6 Habitat or Species Fragmentation

Habitat fragmentation has been defined as ‘reduction and isolation of patches of natural environment’

(Hall et al., 1997 cited in Franklin et al., 2002) which results in spatial separation of habitat areas which

had previously been in a state of greater continuity. Adverse effects of habitat fragmentation on

species include the increased isolation of populations which can detrimentally impact on the resilience

or robustness of the populations.

The preceding sections have concluded that uncertainty exists with regards to habitat loss/alteration,

water quality and species disturbance/displacement effects potentially arising as a result of the

proposal within both the Lower River Shannon SAC and the River Shannon and River Fergus Estuaries

SPA.

Bearing in mind the nature, scale and location of the proposed works, it is objectively concluded that

there is potential for significant habitat or species fragmentation effects, or significant habitat or

species fragmentation effects cannot be ruled out at this stage, for the Lower River Shannon SAC and

the River Shannon and River Fergus Estuaries SPA, as a result of the proposal considered in this report.

4.5.7 Cumulative/In-combination Impacts

As well as singular effects, the potential for in-combination or cumulative impacts also need to be

considered. A cumulative impact arises from incremental changes caused by past, present and

proposed projects together with the proposed development considered in this document. Relevant

plans and projects have been identified in Section 4.2.6 above.

The preceding sections, Section 4.5.3 to 4.5.6 above, have concluded that uncertainty exists with

regards to habitat loss/alteration, water quality, species disturbance/displacement and

habitat/species fragmentation effects which may potentially arise as a result of the proposal within

both the Lower River Shannon SAC and the River Shannon and River Fergus Estuaries SPA.

Bearing in mind the nature, scale and location of the proposed works, it is objectively concluded that

there is potential for significant cumulative/in-combination effects, or significant cumulative/in-

combination effects cannot be ruled out at this stage, for the Lower River Shannon SAC and the River

Shannon and River Fergus Estuaries SPA, as a result of the proposal considered in this report.

4.6 CONCLUSION OF SCREENING STAGE

In conclusion, to determine the potential impacts, if any, of the project on nearby Natura 2000 sites,

a screening process for Appropriate Assessment was undertaken. The proposed development is within

15km of eleven Natura 2000 sites.

It has been objectively concluded during the screening process that nine of the sites within 15km of

the proposal are not likely to be significantly impacted and these include:

• Askeaton Fen Complex SAC (002279)

• Lough Gash Turlough SAC (000051)

• Curraghchase Woods SAC (000174)

• Ratty River Cave SAC (002316)

• Barrigone SAC (000432)

• Knockanira House SAC (002318)

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• Newhall and Edenvale Complex SAC (002091)

• Poulnagordon Cave (Quin) SAC (000064)

• Kilkishen House SAC (002319)

It has been objectively concluded during the screening process, however, that significant effects on

two of the sites within 15km of the proposal cannot be ruled out and thus these sites have the

potential to be significantly impacted as a result of the proposal. Therefore, the recommendation is

to proceed to Stage 2: Appropriate Assessment for these two sites, namely:

• Lower River Shannon SAC (002165)

• River Shannon and River Fergus Estuaries SPA (004077)

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5 REFERENCES

Department of the Environment, Heritage and Local Government (DoEHLG) (2009). Appropriate

Assessment of Plans and Projects in Ireland: Guidance for Planning Authorities. Department of

Environment, Heritage and Local Government.

DGE, 2013. Interpretation Manual of European Union Habitats EUR28, s.l.: European Commission

Directorate General of Environment.

EC (2000). Managing Natura 2000 Sites: The provisions of Article 6 of the ‘Habitats’ Directive

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

EC (2001). 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.

Luxembourg: Office for Official Publications of the European Communities.

Franklin, Alan B., Noon, Barry R. & Luke George T., (2002). What is Habitat Fragmentation?, Studies

in Avian Biology No. 25: 20-29.

NPWS, 2013. The Status of EU Protected Habitats and Species in Ireland. Habitats Assessment Volume

2. Version 1.1., Dublin, Ireland: Unpublished report, National Parks and Wildlife Service, Department

of Arts, Heritage and the Gaeltacht.

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Appendix

Appendix 1

Stages of Appropriate Assessment

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Appendix

Stage 1 - Screening

This is the first stage of the Appropriate Assessment process and that undertaken to determine the

likelihood of significant impacts as a result of a proposed project or plan. It determines need for a full

Appropriate Assessment.

If it can be concluded that no significant impacts to Natura 2000 sites are likely then the assessment

can stop here. If not, it must proceed to Stage 2 for further more detailed assessment.

Stage 2 - Natura Impact Statement (NIS)

The second stage of the Appropriate Assessment process assesses the impact of the proposal (either

alone or in combination with other projects or plans) on the integrity of the Natura 2000 site with

respect to the conservation objectives of the site and its ecological structure and function. This is a

much more detailed assessment that Stage 1. A Natura Impact Statement containing a professional

scientific examination of the proposal is required and includes any mitigation measure to avoid,

reduce or offset negative impacts.

If the outcome of Stage 2 is negative i.e. adverse impacts to the sites cannot be scientifically ruled out,

despite mitigation, the plan or project should proceed to Stage 3 or be abandoned.

Stage 3 - Assessment of alternative solutions

A detailed assessment must be undertaken to determine whether alternative ways of achieving the

objective of the project/plan exists.

Where no alternatives exist the project/plan must proceed to Stage 4.

Stage 4 - Assessment where no alternative solutions exist and where adverse impacts remain

The final stage is the main derogation process examining whether there are imperative reasons of

overriding public interest (IROPI) for allowing a plan or project to adversely affect a Natura 2000 site

where no less damaging solution exists.

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19986-6001-A Screening for Appropriate Assessment September 2019

Appendix

Appendix 2

Site Synopses

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SITE SYNOPSIS

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Site Name: Lower River Shannon SAC Site Code: 002165 This very large site stretches along the Shannon valley from Killaloe in Co. Clare to Loop Head/ Kerry Head, a distance of some 120 km. The site thus encompasses the Shannon, Feale, Mulkear and Fergus estuaries, the freshwater lower reaches of the River Shannon (between Killaloe and Limerick), the freshwater stretches of much of the Feale and Mulkear catchments and the marine area between Loop Head and Kerry Head. Rivers within the sub-catchment of the Feale include the Galey, Smearlagh, Oolagh, Allaughaun, Owveg, Clydagh, Caher, Breanagh and Glenacarney. Rivers within the sub-catchment of the Mulkear include the Killeenagarriff, Annagh, Newport, the Dead River, the Bilboa, Glashacloonaraveela, Gortnageragh and Cahernahallia. The site is a Special Area of Conservation (SAC) selected for the following habitats and/or species listed on Annex I / II of the E.U. Habitats Directive (* = priority; numbers in brackets are Natura 2000 codes):

[1110] Sandbanks [1130] Estuaries [1140] Tidal Mudflats and Sandflats [1150] Coastal Lagoons* [1160] Large Shallow Inlets and Bays [1170] Reefs [1220] Perennial Vegetation of Stony Banks [1230] Vegetated Sea Cliffs [1310] Salicornia Mud [1330] Atlantic Salt Meadows [1410] Mediterranean Salt Meadows [3260] Floating River Vegetation [6410] Molinia Meadows [91E0] Alluvial Forests* [1029] Freshwater Pearl Mussel (Margaritifera margaritifera) [1095] Sea Lamprey (Petromyzon marinus) [1096] Brook Lamprey (Lampetra planeri) [1099] River Lamprey (Lampetra fluviatilis) [1106] Atlantic Salmon (Salmo salar) [1349] Bottle-nosed Dolphin (Tursiops truncatus) [1355] Otter (Lutra lutra)

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The Shannon and Fergus Rivers flow through Carboniferous limestone as far as Foynes, but west of Foynes Namurian shales and flagstones predominate (except at Kerry Head, which is formed from Old Red Sandstone). The eastern sections of the Feale catchment flow through Namurian rocks and the western stretches through Carboniferous limestone. The Mulkear flows through Lower Palaeozoic rocks in the upper reaches before passing through Namurian rocks, followed by Lower Carboniferous shales and Carboniferous limestone. The Mulkear River itself, immediately north of Pallas Green, passes through an area of Rhyolites, Tuffs and Agglomerates. The Shannon and Fergus Estuaries form the largest estuarine complex in Ireland. They form a unit stretching from the upper tidal limits of the Shannon and Fergus Rivers to the mouth of the Shannon Estuary (considered to be a line across the narrow strait between Kilcredaun Point and Kilconly Point). Within this main unit there are several tributaries with their own ‘sub-estuaries’ e.g. the Deel River, Mulkear River, and Maigue River. To the west of Foynes, a number of small estuaries form indentations in the predominantly hard coastline, namely Poulnasherry Bay, Ballylongford Bay, Clonderalaw Bay and the Feale or Cashen River estuary. Both the Fergus and inner Shannon Estuaries feature vast expanses of intertidal mudflats, often fringed with saltmarsh vegetation. The smaller estuaries also feature mudflats, but have their own unique characteristics, e.g. Poulnasherry Bay is stony and unusually rich in species and biotopes. Plant species are typically scarce on the mudflats, although there are some eelgrass (Zostera spp.) beds and patches of green algae (e.g. Ulva sp. and Enteromorpha sp.). The main macro-invertebrate community which has been noted from the inner Shannon and Fergus estuaries is a Macoma-Scrobicularia-Nereis community. In the transition zone between mudflats and saltmarsh, specialised colonisers of mud predominate. For example, swards of Common Cord-grass (Spartina anglica) frequently occur in the upper parts of the estuaries. Less common are swards of Glasswort (Salicornia europaea agg.). In the innermost parts of the estuaries, the tidal channels or creeks are fringed with species such as Common Reed (Phragmites australis) and club-rushes (Scirpus maritimus, S. tabernaemontani and S. triquetrus). In addition to the nationally rare Triangular Club-rush (Scirpus triqueter), two scarce species are found in some of these creeks (e.g. Ballinacurra Creek): Lesser Bulrush (Typha angustifolia) and Summer Snowflake (Leucojum aestivum). Saltmarsh vegetation frequently fringes the mudflats. Over twenty areas of estuarine saltmarsh have been identified within the site, the most important of which are around the Fergus estuary and at Ringmoylan Quay. The dominant type of saltmarsh present is Atlantic salt meadow occurring over mud. Characteristic species occurring include Common Saltmarsh-grass (Puccinellia maritima), Sea Aster (Aster tripolium), Thrift (Armeria maritima), Sea-milkwort (Glaux maritima), Sea Plantain (Plantago maritima), Red Fescue (Festuca rubra), Creeping Bent (Agrostis stolonifera), Saltmarsh Rush (Juncus gerardi), Long-bracted Sedge (Carex extensa), Lesser Sea-spurrey

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(Spergularia marina) and Sea Arrowgrass (Triglochin maritima). Areas of Mediterranean salt meadows, characterised by clumps of Sea Rush (Juncus maritimus) occur occasionally. Two scarce species are found on saltmarshes in the vicinity of the Fergus estuary: a type of robust saltmarsh-grass (Puccinellia foucaudii), sometimes placed within the species Common Saltmarsh-grass (P. maritima) and Hard-grass (Parapholis strigosa). Saltmarsh vegetation also occurs around a number of lagoons within the site, two of which have been surveyed as part of a National Inventory of Lagoons. Cloonconeen Pool (4-5 ha) is a natural sedimentary lagoon impounded by a low cobble barrier. Seawater enters by percolation through the barrier and by overwash. This lagoon represents a type which may be unique to Ireland since the substrate is composed almost entirely of peat. The adjacent shore features one of the best examples of a drowned forest in Ireland. Aquatic vegetation in the lagoon includes typical species such as Beaked Tasselweed (Ruppia maritima) and green algae (Cladophora sp.). The fauna is not diverse, but is typical of a high salinity lagoon and includes six lagoon specialists (Hydrobia ventrosa, Cerastoderma glaucum, Lekanesphaera hookeri, Palaemonetes varians, Sigara stagnalis and Enochrus bicolor). In contrast, Shannon Airport Lagoon (2 ha) is an artificial saline lake with an artificial barrier and sluiced outlet. However, it supports two Red Data Book species of stonewort (Chara canescens and Chara cf. connivens). Most of the site west of Kilcredaun Point/Kilconly Point is bounded by high rocky sea cliffs. The cliffs in the outer part of the site are sparsely vegetated with lichens, Red Fescue, Sea Beet (Beta vulgaris subsp. maritima), Sea Campion (Silene vulgaris subsp. maritima), Thrift and plantains (Plantago spp.). A rare endemic type of sea-lavender, Limonium recurvum subsp. pseudotranswallianum, occurs on cliffs near Loop Head. Cliff-top vegetation usually consists of either grassland or maritime heath. The boulder clay cliffs further up the estuary tend to be more densely vegetated, with swards of Red Fescue and species such as Kidney Vetch (Anthyllis vulneraria) and Common Bird’s-foot-trefoil (Lotus corniculatus). The site supports an excellent example of a large shallow inlet and bay. Littoral sediment communities in the mouth of the Shannon Estuary occur in areas that are exposed to wave action and also in areas extremely sheltered from wave action. Characteristically, exposed sediment communities are composed of coarse sand and have a sparse fauna. Species richness increases as conditions become more sheltered. All shores in the site have a zone of sand hoppers at the top, and below this each of the shores has different characteristic species giving a range of different shore types. The intertidal reefs in the Shannon Estuary are exposed or moderately exposed to wave action and subject to moderate tidal streams. Known sites are steeply sloping and show a good zonation down the shore. Well developed lichen zones and littoral reef communities offering a high species richness in the sublittoral fringe and strong populations of the Purple Sea Urchin Paracentrotus lividus are found. The communities found are tolerant to sand scour and tidal streams. The infralittoral reefs range from sloping platforms with some vertical steps, to ridged bedrock with

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gullies of sand between the ridges, to ridged bedrock with boulders or a mixture of cobbles, gravel and sand. Kelp is very common to about 18 m. Below this it becomes rare and the community is characterised by coralline crusts and red foliose algae. Other coastal habitats that occur within the site include stony beaches and bedrock shores (these support a typical zonation of seaweeds such as Fucus spp., Ascophyllum nodosum and kelps), shingle beaches (with species such as Sea Beet, Sea Mayweed - Matricaria maritima, Sea Campion and Curled Dock - Rumex crispus), sandbanks which are slightly covered by sea water at all times (e.g. in the area from Kerry Head to Beal Head) and sand dunes (a small area occurs at Beal Point, where Marram – Ammophila arenaria is the dominant species). Freshwater rivers have been included in the site, most notably the Feale and Mulkear catchments, the Shannon from Killaloe to Limerick (along with some of its tributaries, including a short stretch of the Kilmastulla River), the Fergus up as far as Ennis, and the Cloon River. These systems are very different in character: the Shannon is broad, generally slow flowing and naturally eutrophic; the Fergus is smaller and alkaline; while the narrow, fast flowing Cloon is acid in nature. The Feale and Mulkear catchments exhibit all the aspects of a river from source to mouth. Semi-natural habitats, such as wet grassland, wet woodland and marsh occur by the rivers, but improved grassland is the most common habitat type. One grassland type of particular conservation significance, Molinia meadows, occurs in several parts of the site and the examples at Worldsend on the River Shannon are especially noteworthy. Here are found areas of wet meadow dominated by rushes (Juncus spp.) and sedges (Carex spp.), and supporting a diverse and species-rich vegetation, including such uncommon species as Blue-eyed Grass (Sisyrinchium bermudiana) and Pale Sedge (C. pallescens). Floating river vegetation characterised by species of water-crowfoot (Ranunculus spp.), pondweeds (Potamogeton spp.) and the moss Fontinalius antipyretica are present throughout the major river systems within the site. The rivers contain an interesting bryoflora with Schistidium alpicola var. alpicola recorded from in-stream boulders on the Bilboa, new to Co. Limerick. Alluvial woodland occurs on the banks of the Shannon and on islands in the vicinity of the University of Limerick. The woodland is up to 50 m wide on the banks and somewhat wider on the largest island. The most prominent woodland type is gallery woodland where White Willow (Salix alba) dominates the tree layer with occasional Alder (Alnus glutinosa). The shrub layer consists of various willow species with Rusty Willow (Salix cinerea ssp. oleifolia) and what appear to be hybrids of S. alba x S. viminalis. The herbaceous layer consists of tall perennial herbs. A fringe of bulrush (Typha sp.) occurs on the river side of the woodland. On slightly higher ground above the wet woodland and on the raised embankment remnants of mixed oak-ash-alder woodland occur. These are poorly developed and contain numerous exotic species but locally there are signs that it is invading open grassland. Alder is the principal tree species, with occasional Pedunculate Oak (Quercus robur), elm (Ulmus glabra and U. procera), Hazel (Corylus avellana), Hawthorn (Crataegus monogyna) and

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the shrubs Guelder-rose (Viburnum opulus) and willows. The ground flora is species-rich. While woodland is infrequent within the site, however Cahiracon Wood contains a strip of old oak woodland. Sessile Oak (Q. petraea) forms the canopy, with an understorey of Hazel and Holly (Ilex aquifolium). Great Wood-rush (Luzula sylvatica) dominates the ground flora. Less common species present include Great Horsetail (Equisetum telmeteia) and Pendulous Sedge (Carex pendula). In the low hills to the south of the Slievefelim Mountains, the Cahernahallia River cuts a valley through the Upper Silurian rocks. For approximately 2 km south of Cappagh Bridge at Knockanavar, the valley sides are wooded. The woodland consists of birch (Betula spp.), Hazel, oak, Rowan (Sorbus aucuparia), some Ash (Fraxinus excelsior) and willow (Salix spp.). Most of the valley is not grazed by stock, and as a result the trees are regenerating well. The ground flora features prominent Great wood-rush and Bilberry (Vaccinium myrtillus), along with a typical range of woodland herbs. Bracken (Pteridium aquilinum) is a feature in areas where there is more light available. The valley sides of the Bilboa and Gortnageragh Rivers, on higher ground north-east of Cappamore, support patches of semi-natural broadleaf woodland dominated by Ash, Hazel, oak and birch. There is a good scrub layer with Hawthorn, willow, Holly and Blackthorn (Prunus spinosa) common. The herb layer in these woodlands is often open, with a typically rich mixture of woodland herbs and ferns. Moss species diversity is high. The woodlands are ungrazed. The Hazel is actively coppiced in places. There is a small area of actively regenerating cut-away raised bog at Ballyrorheen. It is situated approximately 5 km north-west of Cappamore in Co. Limerick. The bog contains some wet areas with good cover of bog mosses (Sphagnum spp.). Species of particular interest include Cranberry (Vaccinium oxycoccos) and White Sedge (Carex curta), along with two regionally rare mosses, including the bog moss S. fimbriatum. The site is being invaded by Downy Birch (Betula pubescens) scrub woodland. Both commercial forestry and the spread of Rhododendron (Rhododendron ponticum) has greatly reduced the overall value of the site. A number of plant species that are listed in the Irish Red Data Book occur within the site, and several of these are protected under the Flora (Protection) Order, 1999. These include Triangular Club-rush (Scirpus triquetrus), a species which is only found in Ireland only in the Shannon Estuary, where it borders creeks in the inner estuary. Opposite-leaved Pondweed (Groenlandia densa) is found in the Shannon where it passes through Limerick City, while Meadow Barley (Hordeum secalinum) is abundant in saltmarshes at Ringmoylan and Mantlehill. Hairy Violet (Viola hirta) occurs in the Askeaton/Foynes area. Golden Dock (Rumex maritimus) is noted as occurring in the River Fergus estuary. Finally, Bearded Stonewort (Chara canescens), a brackish water specialist, and Convergent Stonewort (Chara connivens) are both found in Shannon Airport Lagoon.

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Overall, the Shannon and Fergus Estuaries support the largest numbers of wintering waterfowl in Ireland. The highest count in 1995-96 was 51,423 while in 1994-95 it was 62,701. Species listed on Annex I of the E.U. Birds Directive which contributed to these totals include: Great Northern Diver (3; 1994/95), Whooper Swan (201; 1995/96), Pale-bellied Brent Goose (246; 1995/96), Golden Plover (11,067; 1994/95) and Bar-tailed Godwit (476; 1995/96). In the past, three separate flocks of Greenland White-fronted Goose were regularly found, but none were seen in 1993/94. Other wintering waders and wildfowl present include Greylag Goose (216; 1995/96), Shelduck (1,060; 1995/96), Wigeon (5,976; 1995/96), Teal (2,319; 1995-96), Mallard (528; 1995/96), Pintail (45; 1995/96), Shoveler (84; 1995/96), Tufted Duck (272; 1995/96), Scaup (121; 1995/96), Ringed Plover (240; 1995/96), Grey Plover (750; 1995/96), Lapwing (24,581; 1995/96), Knot (800; 1995/96), Dunlin (20,100; 1995/96), Snipe (719, 1995/96), Black-tailed Godwit (1,062; 1995/96), Curlew (1,504; 1995/96), Redshank (3,228; 1995/96), Greenshank (36; 1995/96) and Turnstone (107; 1995/96). A number of wintering gulls are also present, including Black-headed Gull (2,216; 1995/96), Common Gull (366; 1995/96) and Lesser Black-backed Gull (100; 1994/95). This is the most important coastal site in Ireland for a number of the waders including Lapwing, Dunlin, Snipe and Redshank. It also provides an important staging ground for species such as Black-tailed Godwit and Greenshank. A number of species listed on Annex I of the E.U. Birds Directive breed within the site. These include Peregine Falcon (2-3 pairs), Sandwich Tern (34 pairs on Rat Island, 1995), Common Tern (15 pairs: 2 on Sturamus Island and 13 on Rat Island, 1995), Chough (14-41 pairs, 1992) and Kingfisher. Other breeding birds of note include Kittiwake (690 pairs at Loop Head, 1987) and Guillemot (4,010 individuals at Loop Head, 1987). There is a resident population of Bottle-nosed Dolphin in the Shannon Estuary. This is the only known resident population of this E.U. Habitats Directive Annex II species in Ireland. The population is estimated (in 2006) to be 140 ± 12 individuals. Otter, a species also listed on Annex II of this Directive, is commonly found on the site. Five species of fish listed on Annex II of the E.U. Habitats Directive are found within the site. These are Sea Lamprey (Petromyzon marinus), Brook Lamprey (Lampetra planeri), River Lamprey (Lampetra fluviatilis), Twaite Shad (Allosa fallax fallax) and Salmon (Salmo salar). The three lampreys and Salmon have all been observed spawning in the lower Shannon or its tributaries. The Fergus is important in its lower reaches for spring salmon, while the Mulkear catchment excels as a grilse fishery, though spring fish are caught on the actual Mulkear River. The Feale is important for both types. Twaite Shad is not thought to spawn within the site. There are few other river systems in Ireland which contain all three species of lamprey.

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Two additional fish species of note, listed in the Irish Red Data Book, also occur, namely Smelt (Osmerus eperlanus) and Pollan (Coregonus autumnalis pollan). Only the former has been observed spawning in the Shannon. Freshwater Pearl Mussel (Margaritifera margaritifera), a species listed on Annex II of the E.U. Habitats Directive, occurs abundantly in parts of the Cloon River. There is a wide range of land uses within the site. The most common use of the terrestrial parts is grazing by cattle, and some areas have been damaged through over-grazing and poaching. Much of the land adjacent to the rivers and estuaries has been improved or reclaimed and is protected by embankments (especially along the Fergus estuary). Further, reclamation continues to pose a threat, as do flood relief works (e.g. dredging of rivers). Gravel extraction poses a major threat on the Feale. In the past, cord-grass (Spartina sp.) was planted to assist in land reclamation. This has spread widely, and may oust less vigorous colonisers of mud and may also reduce the area of mudflat available to feeding birds. Domestic and industrial wastes are discharged into the Shannon, but water quality is generally satisfactory, except in the upper estuary where it reflects the sewage load from Limerick City. Analyses for trace metals suggest a relatively clean estuary with no influences of industrial discharges apparent. Further industrial development along the Shannon and water polluting operations are potential threats. Fishing is a main tourist attraction on the Shannon and there are a large number of angler associations, some with a number of beats. Fishing stands and styles have been erected in places. The River Feale is a designated Salmonid Water under the E.U. Freshwater Fish Directive. Other uses of the site include commercial angling, oyster farming, boating (including dolphin-watching trips) and shooting. Some of these may pose threats to the birds and dolphins through disturbance. Specific threats to the dolphins include underwater acoustic disturbance, entanglement in fishing gear and collisions with fast moving craft. This site is of great ecological interest as it contains a high number of habitats and species listed on Annexes I and II of the E.U. Habitats Directive, including the priority habitats lagoon and alluvial woodland, the only known resident population of Bottle-nosed Dolphin in Ireland and all three Irish lamprey species. A good number of Red Data Book species are also present, perhaps most notably the thriving populations of Triangular Club-rush. A number of species listed on Annex I of the E.U. Birds Directive are also present, either wintering or breeding. Indeed, the Shannon and Fergus Estuaries form the largest estuarine complex in Ireland and support more wintering wildfowl and waders than any other site in the country. Most of the estuarine part of the site has been designated a Special Protection Area (SPA), under the E.U. Birds Directive, primarily to protect the large numbers of migratory birds present in winter.

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SITE SYNOPSIS SITE NAME: RIVER SHANNON AND RIVER FERGUS ESTUARIES SPA SITE CODE: 004077 The estuaries of the River Shannon and River Fergus form the largest estuarine complex in Ireland. The site comprises the entire estuarine habitat from Limerick City westwards as far as Doonaha in Co. Clare and Dooneen Point in Co. Kerry. The site has vast expanses of intertidal flats which contain a diverse macro-invertebrate community, e.g. Macoma-Scrobicularia-Nereis, which provides a rich food resource for the wintering birds. Salt marsh vegetation frequently fringes the mudflats and this provides important high tide roost areas for the wintering birds. Elsewhere in the site the shoreline comprises stony or shingle beaches. The site is a Special Protection Area (SPA) under the E.U. Birds Directive, of special conservation interest for the following species: Cormorant, Whooper Swan, Light-bellied Brent Goose, Shelduck, Wigeon, Teal, Pintail, Shoveler, Scaup, Ringed Plover, Golden Plover, Grey Plover, Lapwing, Knot, Dunlin, Black-tailed Godwit, Bar-tailed Godwit, Curlew, Redshank, Greenshank and Black-headed Gull. It is also of special conservation interest for holding an assemblage of over 20,000 wintering waterbirds. The E.U. Birds Directive pays particular attention to wetlands and, as these form part of this SPA, the site and its associated waterbirds are of special conservation interest for Wetland & Waterbirds. The site is the most important coastal wetland site in the country and regularly supports in excess of 50,000 wintering waterfowl (57,133 - five year mean for the period 1995/96 to 1999/2000), a concentration easily of international importance. The site has internationally important populations of Light-bellied Brent Goose (494), Dunlin (15,131), Black-tailed Godwit (2,035) and Redshank (2,645). A further 17 species have populations of national importance, i.e. Cormorant (245), Whooper Swan (118), Shelduck (1,025), Wigeon (3,761), Teal (2,260), Pintail (62), Shoveler (107), Scaup (102), Ringed Plover (223), Golden Plover (5,664), Grey Plover (558), Lapwing (15,126), Knot (2,015), Bar-tailed Godwit (460), Curlew (2,396), Greenshank (61) and Black-headed Gull (2,681) - figures are five year mean peak counts for the period 1995/96 to 1999/2000. The site is among the most important in the country for several of these species, notably Dunlin (13 % of national total), Lapwing (6% of national total) and Redshank (9% of national total). The site also supports a nationally important breeding population of Cormorant (93 pairs in 2010). Other species that occur include Mute Swan (103), Mallard (441), Red-breasted Merganser (20), Great Crested Grebe (50), Grey Heron (38), Oystercatcher (551),

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Turnstone (124) and Common Gull (445) - figures are five year mean peak counts for the period 1995/96 to 1999/2000. Apart from the wintering birds, large numbers of some species also pass through the site whilst on migration in spring and/or autumn. The River Shannon and River Fergus Estuaries SPA is an internationally important site that supports an assemblage of over 20,000 wintering waterbirds. It holds internationally important populations of four species, i.e. Light-bellied Brent Goose, Dunlin, Black-tailed Godwit and Redshank. In addition, there are 17 species that have wintering populations of national importance. The site also supports a nationally important breeding population of Cormorant. Of particular note is that three of the species which occur regularly are listed on Annex I of the E.U. Birds Directive, i.e. Whooper Swan, Golden Plover and Bar-tailed Godwit. Parts of the River Shannon and River Fergus Estuaries SPA are Wildfowl Sanctuaries.

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19986-6002-B Natura Impact Statement December 2019

Appendix

Appendix 2

Shannon Embankment Modelling

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Appendix

Appendix 3

Environmental Commitments

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19986-6002-B Natura Impact Statement December 2019

Appendix

Note: To be read in conjunction with the full suite of mitigation in Section 9

1. Method statements will be prepared by the appointed contractor. These will be used to

translate the project requirements into planned systems of work instructions to the site staff

and operatives involved. They will define the proposed method of working for an element or

section of work taking into account the particular requirements of the project including site

conditions, safety hazards, the contract drawings, specification or code of practice. They

define the proposed use of plant, labour and materials, any hold points or permits and may

be supplemented by drawings, sketches and produce data as necessary.

2. The site boundary will be marked by secure posts and robust high visibility tape. The site

boundary will be demarcated and avoided once this construction element has been

completed. These areas will be agreed with the site ecologist to ensure sensitive areas will

be avoided. Machinery will not be permitted breach these agreed boundaries during

subsequent work.

3. Substances that can cause water quality problems will need to be controlled adequately at

all times during the works. The main risks are associated with excavated/bare soils and oils.

Measures to prevent erosion of soils and releases of oil will be required. There will be no

discharge of effluent or waste water on site. Spill kits and personnel practised in their use

will be required in case of an oil spillage.

4. All construction equipment/gear will be stored at a site compound. Wastes generated on-

site (construction and waste water) will be managed properly and taken to a licensed waste

management company.

5. A good knowledge of working in the marine environment will be necessary, as water levels

at the seaward side of the embankment undergo fluctuations according to the tidal cycle.

6. A project ecologist (environmental clerk of works) will be appointed to monitor the works on

a weekly basis for the full duration of the project. The contractor will work with the ecologist

to deliver environmental compliance on site, as set out in the mitigation in the NIS. The

ecologist will audit the construction works from an environmental viewpoint.