Attachment F.1 (c) Natura Impact Statement · [Natura 2000] site but likely to have a significant...

Ahascragh Certificate of Authorisation Application

Attachment F.1 (c) Natura Impact Statement

Irish Water

Report

Natura Impact Statement as part of the Ahascragh Waste Water

Certification of Authorisation Application

2 | Irish Water Natura Impact Statement - Ahascragh

Contents

Introduction 3

Legislative Context 3

Methodology 5

Guidance Followed 5

Stages Involved in the Appropriate Assessment Process 6

Field Walkover Surveys 6

Consultation 6

Stage 1: Screening 7

Stage 2: Appropriate Assessment 8

Description of the Project 8

Description of the Receiving Environment and Monitoring Results 10

Waste Assimilative Capacity 11

Field Walkover Survey 12

Description of the Natura 2000 Site Affected 13

Description of the Conservation Interests of the SPA 14

Conservation Objectives of the River Suck Callows SPA 16

Impact Prediction 16

Impacts on Water Quality 16

Impacts on designated features of the SPA 17

Mitigation Measures 18

Stage 2 Appropriate Assessment Conclusion Statement 19

References 20


Introduction

This Natura Impact Statement provides an Appropriate Assessment (AA) of the existing Waste

Water Treatment Plant (WwTP), located at Ahascragh, County Galway, for the purposes of the

Waste Water Discharge (Authorisation) Regulations, 2007 (S.I. No. 684 of 2007), as amended. It

assesses whether the on-going operation of the plant, alone or in combination with other plans

and projects, is likely to have significant effects on a European Site(s) in view of best scientific

knowledge and the conservation objectives of the site(s). European Sites are those identified as

sites of European Community importance designated as Special Areas of Conservation under

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

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

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

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

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

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

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

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

This report was completed by Tobins Consulting Engineers and Irish Water.

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

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

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

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

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

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

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

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

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

Appropriate Assessment (AA):

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

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

combination with other plans or projects, shall be subjected to appropriate assessment

of its implications for the site in view of the site’s conservation objectives. In light of the

conclusions of the assessment of the implications for the site and subject to the

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

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

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

public.

Article 6(4) states:


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

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

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

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

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

Commission of the compensatory measures adopted.


Methodology

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

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

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

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

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

Agency, (EPA, 2009).

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

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

2010).

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

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

Local Government, (DoEHLG, 2008).

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

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

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

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

(EC, 2000b).

Assessment of plans and projects significantly affecting Natura 2000 sites:

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

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

Brussels (EC, 2001).

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

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

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

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

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

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

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

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

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

2011).

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

Commission (EC, 2013).


Stages Involved in the Appropriate Assessment Process Stage 1: Screening / Test of Significance

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

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

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

plans.

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

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

that site to be brought forward to Stage 2.

Stage 2: Appropriate Assessment

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

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

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

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

impacts

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

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

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

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

Stage 3: Assessment of Alternatives

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

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

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

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

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

Stage 4: Assessment Where Adverse Impacts Remain

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

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

proceed.

Field Walkover Surveys Field walkover surveys were undertaken by a qualified ecologist on 18

th June 2014 to identify the

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

Consultation The EPA, as the competent authority, will seek NPWS advice as may be required in reaching

their decision on a WwTP discharge. The NPWS can only communicate with the applicant (i.e.

Irish Water) on request from the competent authority, when the formal application process to the

competent authority has already commenced.

Inland Fisheries Ireland (IFI) identified that the Ahasgragh/Bunowen river supports trout. The

River Suck supports a population of native salmon and recent studies as part of the AARC


(Atlantic Aquatic Resource Conservation) project have focused on identifying and protecting wild

and feral salmon populations including re-establishment of populations. As part of this study

eggs were transferred from the Shannon Parteen hatchery to the Bunowen river for survival

experiments and results will inform efforts to re-establish salmon in the Ahascragh/Bunowen river

where it has been absent for many years. IFI note that there are issues with water quality and

capacity in the Ahasgragh/Bunowen river with respect to the WwTP.

Stage 1: Screening

Screening for Appropriate Assessment was undertaken by the Environmental Protection Agency

who determined that an Appropriate Assessment of the existing discharge from the Ahascragh

WwTP is required due to the potential adverse impact on the qualifying interests of the River

Suck Callows SPA. This determination was based on the following:

Ahascragh WwTP discharges into the Ahascragh river which continues into the

Bunowen river and joins the River Suck and SPA just over 7km to the south-east of

Ahascragh; and

The WwTP effluent is of poor quality.

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

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

2 Appropriate Assessment.


Stage 2: Appropriate Assessment

The River Suck Callows SPA is described and all the potential impacts resulting from the

Ahascragh WwTP discharge are discussed in relation to the conservation objectives of this

designated site.

Description of the Project The Ahascragh agglomeration is located in east County Galway, approximately 10km north-east

of Ballinasloe. The agglomeration is served by a combined network and treatment system that

was built in the 1950s. Preliminary treatment is provided by a grit settlement chamber and

manually raked inlet coarse bar screen at the Village Pumping Station which forwards

wastewater to the WwTP. The existing WwTP system consists of an Imhoff tank which provides

primary treatment. The estimated capacity of the Ahascragh Imhoff tank is 500 pe. Settled sludge

is removed from the Imhoff tank and brought to Ballinasloe wastewater treatment plant for

secondary and final treatment.

On the 09/01/2015 the EPA accepted the withdrawal of the WWDL application for Ahascragh

because the population equivalent is below the WWDL threshold. Irish Water estimates the

current population equivalent to be 341 and to increase to 349 pe for the year 2020 Based on a

loading of 225l/pp/day the dry weather flow for the current discharge is calculated at

0.00089m3/sec, while that for the future discharge is 0.00091m

3/sec. The current 95-percentile

flow for the receiving Ahascragh river, as obtained from the EPA Hydrotool website, is

0.166m3/sec.

Table 1.0 below shows the locations of the Ahascragh agglomeration discharges.

Table 1.0: Discharge Points

*not used

There are also 2 No. pumping stations on the network which do not have Emergency Overflows

built into them. During periods of heavy rainfall the pumping chambers can flood and at:

Pumping Station 1, Bridgecourt Estate can overflow locally to land, possibly into storm drain

and into the nearby Ahascragh river (~5 m away).

Pumping Station 2 – Ahascragh Village Pumping Station, discharge to land and possibly

Ahascragh river (~12 m away).

The Ahascragh river is not part of a Natura 2000 site at the effluent discharge location. The

Ahascragh river enters the Bunowen river ca. 5.5km downstream of the discharge point, which

Code Type Location Easting

6E

Northing

6N

SW1 Primary From Imhoff Tank into Ahascragh river 178291 237946

SW2 Storm Water

Overflow

At Main St Bridge discharging into

Ahascragh river

177728 238557

SW3* Secondary

Discharge

From Imhoff tank to Ahascragh river 178291 237946


then enters the River Suck Callows SPA (site code: 004097) ca. 8km downstream of the WwTP,

before joining the main channel of the River Suck a further 700m downstream of this point.

Table 2.0: Ahascragh WwTP 2015-2016 Monitoring Data (mg/l)

Date BOD COD SS

29/01/2015 2 53 36

25/02/2015 151 316 48

19/03/2015 119 280 41

17/04/2015 145 335 93

20/05/2015 46 150 49

30/06/2015 102 304 64

28/07/2015 162 364 60

27/08/2015 20 141 42

23/09/2015 50 176 40

27/10/2015 19 138 33

20/11/2015 2 31 4

15/12/2015 2 10 2

25/01/2016 44 156 28

17/02/2016 2 36 11

23/03/2015 87 243 56

18/04/2016 121 334 41

30/05/2016 133 335 80

23/06/2016 229 552 161

There are no effluent standards required for wastewater discharge Certificate of Authorisations,

however it is noted that the effluent discharge does not meet the Urban Wastewater Treatment

Regulations (2001) (S.I. No. 254/2001) standards for the parameters measured.

There is no current effluent monitoring data available for Orthophosphate or Ammonia, therefore

the latest available data for these parameters (from sampling undertaken by Galway County

Council in 2009) is presented below.

Table 3.0: Effluent monitoring data for Ammonia and Orthophosphate

Date Ammonia Orthophosphate

20/04/2009 22.16 2.99

15/04/2009 27.31 2.90


Description of the Receiving Environment and Monitoring Results

The WwTP discharges to the Ahascragh river. Monitoring data (EPA 2015 data) from both

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

the Ahascragh river upstream and downstream of the WwTP is in compliance with Schedule 5 of

the European Communities Environmental Objectives (Surface Water) Regulations 2009 (S.I.

No. 272 of 2009). The upstream monitoring site is RS26A010300 ‘Ahascragh West Bridge’,

while the downstream site is RS26A010400 ‘2.6km d/s Ahascragh Br’.

Table 4.0 Monitoring Data both Upstream and Downstream of WwTP Discharge

Ammonia-Total (as N)

BOD - 5 days (Total)

Dissolved Oxygen

ortho-Phosphate (as P) - unspecified

Total Oxidised Nitrogen (as N)

Total Nitrogen

Upstream

04/02/2015 0.062 0.5 97.8 0.011 1.553

12/05/2015 0.005 1 101.6 0.008

0.594

27/08/2015 0.06 1.3 85 0.016 0.676

04/11/2015 0.058 2.2 95.1 0.003 0.979

Downstream

27/08/2015 0.05 1.3 87.8 0.023 0.727

21/10/2015 0.029 1.4 87.8 0.014 1.039

01/12/2015 0.026 1.73 86.3 0.024 0.654

The EPA currently monitors sites on the Ahascragh stream for biological water quality. The

current monitoring sites are at Island Bridge ca. 2.5 km upstream of Ahascragh (RS26A010200 -

Q4 2014), 2.6km downstream of Ahascragh (RS26A010400 - Q3-4 2014) and Bunowen Bridge

ca. 8km downstream of Ahasgragh (RS26A010500 - Q4 2014). The results would appear to

indicate that the WwTP may be having a minor localised impact on the channel immediately

downstream of the discharge point with water quality declining from Good status to Moderate

status, however further downstream at Bunowen Bridge water quality improves to Good status

again.

During the field survey in July 2014 a Tobin’s ecologist sampled the river upstream and

downstream of the discharge at accessible locations. The first sample ca. 200m upstream of the

discharge was given a rating of Q3-4 with group A Heptagenia sp present together with group B

Leuctra sp. Group C Emphemerella ignita and copeoptera were common. Further downstream

(ca. 200m) the river also achieved a Q3-4 rating with group A Heptagenia sp common and Group

B cased caddis also found. Common species at this location included the group C Baetis

rhodani, Ephemerella ignita and Gammarus duebeni.

In terms of Water Framework Directive (WFD) status1, the Ahascragh river upstream and

downstream of the discharge is classed as Moderate status. The river improves to Good status

upstream of Bunowen Bridge, and then reverts to Moderate status downstream of the bridge and

1 http://gis.epa.ie/Envision/


in the main channel of the River Suck. The entire Ahascragh/Bunowen river is considered to be

‘at risk of not achieving good status’.

Waste Assimilative Capacity

Table 5.0 summaries the assimilative capacity calculations which are based on the future loading

of 349pe, 95%ile river flow (0.166m3/sec) and water quality standards in the European

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

2009). Assimilative capacity calculations use both actual background concentrations and the

‘notionally clean river’ approach. The effluent data used is the average of the figures presented

in Table 2.0 for BOD, and in Table 3.0 for Ammonia and Orthophosphate.

Table 5.0: Assimilative capacity calculations for the Ahascragh river at estimated

loadings of 349 pe for actual background concentrations and for a

notionally clean river

Parameter Effluent

(mg/l)

Background

(mg/l)

Predicted

downstream

quality (mg/l)

EQS* (mg/l)

BOD Actual Background 79.777 1.25 1.677 ≤2.6

Notionally Clean 79.777 0.260 0.693

Ammonia Actual Background 24.735 0.0462 0.181 ≤0.14


Orthophosphate Actual Background 2.945 0.0095 0.025 ≤0.075


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

(95%ile standards presented).

Using both the actual background concentrations and the notional clean river concentrations

demonstrates that the Ahascragh river has the capacity to assimilate BOD and Orthophosphate

but lacks the capacity to assimilate Ammonia even considering notionally clean water.

The Ahascragh river is a tributary of the River Suck. To assist in determining the possible

impacts on the River Suck Callows SPA, the assimilative capacity of the main channel of the

River Suck was determined using the effluent monitoring data, 95%ile River Suck flow

(2.017m3/sec, EPA HydroTool) and existing and notionally clean surface water concentrations.

The existing background figures are an average of the 2015 EPA data for the River Suck at

Ballinsloe Bridge (RS26S071300) which represents a worst case scenario as this site is actually

downstream of the Ahascragh river confluence (this site is used as there were no proximate

upstream sites).


Table 6.0: Assimilative capacity calculations for the River Suck at estimated

loadings of 349 pe for actual background concentrations and for a notionally clean river

Parameter Effluent

(mg/l)

Background

(mg/l)

Predicted

downstream

quality (mg/l)

EQS* (mg/l)

BOD Actual Background 79.777 1.108 1.142 ≤2.6


Ammonia Actual Background 24.735 0.017 0.028 ≤0.14


Orthophosphate Actual Background 2.945 0.027 0.028 ≤0.075


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

(95%ile standards presented).

As seen in Table 6.0 above, due to the high dilution capacity, the River Suck has the assimilative

capacity for the Ahascragh WwTP discharge for all parameters.

Field Walkover Survey

The Ahasgragh river in the vicinity of the WwTP is 3-5m wide and ca 0.3-1.0m deep and is

mainly a moderately fast flowing glide with some areas of riffle and deeper pool sections. The

river flows through wet grassland and improved grassland areas and there is abundant natural

bankside and marginal vegetation including flag iris Iris pseudocorus, reed canary grass Phalaris

arundinacea, purple loosestrife Lythrym salicaria, marsh cinquefoil Potentilla palustris, water

starwort Callitriche spp., watercress Rorippa nasturtium-aquaticum, marsh valerian Valeriana

sitchensis, meadowsweet Filipendula ulmaria, hard rush Juncus inflexus, reed sweetgrass

Glyceria maxima and club rush Scirpus lacustris.

The river appears suitable for spawning fish and lamprey species and the current distribution of

brook and river lamprey includes the 10K square M73 where the WwTP is located (NPWS,

2013). The Ahasgragh/Cloonlyne river is also a good trout river and recent efforts have been

made to re-establish a salmon population here. The Ahasgragh river at this location is also

suitable for otter and kingfisher. There are records of otter downstream at Ballinasloe (NBDC

database2).

No Annex I habitats were noted in the vicinity of the WwTP upstream or downstream of the

discharge. No protected bird species were recorded though it is noted many of the species for

which the SPA is designated are wintering populations.

2 http://maps.biodiversityireland.ie/#/Map


Description of the Natura 2000 Site Affected3 The River Suck Callows comprise a long, sinuous area of semi-natural lowland wet grassland,

which floods extensively each winter along the River Suck between Castlecoote in the north and

Shannonbridge in the south, and passing through Ballinasloe. The River Suck is the largest

tributary of the River Shannon. The site follows the river from Castlecoote, near Fuerty to its

confluence with the River Shannon, a distance of approximately 70 km of river course.

The main habitat is grassland, improved to varying extents, that is seasonally-flooded. The less-

improved areas are species-rich. Here the vegetation consists of Common Sedge (Carex nigra),

Creeping Bent (Agrostis stolonifera), Brown Sedge (Carex disticha), Marsh Foxtail (Alopecurus

geniculatus), Reed Canary-grass (Phalaris arundicacea), Creeping Buttercup (Ranunculus

repens), Jointed Rush (Juncus articulatus), Common Spikerush (Eleocharis palustris) and

Floating Sweet-grass (Glyceria fluitans). Many of these species are important food plants for the

wintering wildfowl which also forage on the improved grasslands within the site. A large area of

flooded fen with Black Bog-rush (Schoenus nigricans) and Common Reed (Phragmites australis)

occurs to the north of Derrycahill Bridge. Small patches of Common Club-rush (Scirpus lacustris)

occur in shallows along the river margin. The grassland is used mainly for pasture but some is

also used for silage or occasionally hay-making. The site adjoins several raised bogs and cutover

bogs, and there are turloughs in the vicinity.

The Suck River Callows is an important site for wintering waterfowl. Of particular note is the

internationally important Greenland White-fronted Goose flock that is based along the Suck. The

birds congregate mainly in the middle reaches of the river. A separate sub-flock is centred at

Glenamaddy turlough. The average maximum winter count for the period 1988/89 to 1993/94

was 386 birds. In recent years, the only complete count of waterfowl for the site was in January

2002. Three species had populations of national importance, i.e. Whooper Swan (124), Wigeon

(1,203) and Lapwing (3,640). Other species present included Mute Swan (90), Teal (325), Pintail

(5), Curlew (67) and Black-headed Gull (240). Golden Plover, a species that is listed on Annex I

of the E.U. Birds Directive, occurs at times. The good quality riverine and grassland habitats are

also home to populations of Otter and Irish Hare, and Brown Trout occur in the river. Arterial

drainage in the past has already reduced the area of naturally flooded grasslands, and drainage

and land improvement remain the principal threat to this site. The intensification of agriculture in

recent years, with earlier mowing and the replacement of hay with silage, is likely to have caused

the decline and eventual absence of breeding Corncrake.

Wildfowling causes some disturbance, though there is a Wildfowl Sanctuary at Muckanagh, north

of Ballyforan. This site is of considerable ornithological importance on account of the Greenland

White-fronted Goose population which is of international significance and which is one of the

largest in the country outside of the Wexford Slobs. Despite poor survey data for recent years, it

is known to support nationally important populations of at least three species, i.e. Whooper

Swan, Wigeon and Lapwing. Detailed survey is likely to show that other species also occur in

substantial numbers. Of note is that two of the species which occur regularly, Greenland White-

fronted Goose and Whooper Swan, are listed on Annex I of the E.U. Birds Directive.

3 Extracted from Site Synopsis dated 1.4.2005


Description of the Conservation Interests of the SPA

The SPA is designated for wintering populations of five bird species as well as the wetlands that

support them:

Whooper swan Cygnus Cygnus

Wigeon Anas penelope

Golden plover Pluvialis apricaria

Lapwing Vanellus vanellus

Greenland white-fronted goose Anser albifrons flavirostris

At its nearest point the River Suck SPA is 8km to the south-east of Ahasgragh WwTP. The

qualifying species are wintering populations and due to the time of year there were no

observations made during the site visit. However suitable agricultural wet grassland habitat for

these species is present at numerous locations thoughout the 8km stretch of the

Ahasgragh/Bunowen river downstream of the WwTP. The Suck Callows are surveyed as part of

I-Webs; however, due to the size and inaccessibility of many areas aerial surveys are necessary

(Crowe, 2005).

Population information (where available), requirements and sensitivities of these species are

considered in more details below with information taken from Crowe (2005), NPWS (2011) and

the referenced swan and geese census reports.

Whooper swans are primarily herbivorous, feeding on aquatic plants, grasses and agricultural

plants such as grain and vegetables. The most recent published swan census (Hall et al, 2012)

indicated that just over 50% of the habitat usage records for Whooper Swans were for dry

improved pasture with 37.5% seen on arable land. The count in the River Suck region for this

species in 2010 was 331 up 2% from 2005. Nationally the most important sites for Whooper

swan are Lough Foyle and Upper Lough Erne. They are an amber-listed species of conservation

concern (Colhoun & Cummins, 2013).

Greenland white-fronted geese historically wintered on bogland, callowland and rough

grassland where they fed by uprooting cyperacean species in particular Eriphorum angustifolium.

In the latter half of the 20th century they have increasingly used grassland habitats and have

shown good flexibility in adapting to new food sources including agricultural stubbles and fodder

beet. The decline in the global population continues and is mainly attributed to climate-related

changes and increased competition for nest sites with the expanding population of breeding

Canada geese. It is an amber-listed species of conservation concern (Colhoun & Cummins,

2013). The most significant population of these geese in Ireland is found in the Wexford slobs.

Counts for the River Suck published in the International Census of Greenland white-fronted

geese report indicates counts in the river have fluctuated in recent years with most recent counts

being 106 (autumn 2014 census) and 150 (spring 2015 census) (Fox et al, 2015).

The Lapwing wintering population moves in from continental Europe and northern and western

Britain (NPWS, 2011). They are traditionally ‘inland’ waders principally using lowland farmland

and freshwater wetlands (e.g. turloughs and callows). They are opportunistic and mobile birds

and will readily exploit temporary food sources such as newly-ploughed fields where they feed on


a variety of soil and surface-living invertebrates such as small arthropods and earthworms. They

are a red-listed species of conservation concern (Colhoun & Cummins, 2013).

Golden Plover that winter in Ireland are thought to be mostly the Icelandic-breeding subspecies.

In winter they primarily feed within agricultural grassland and arable land. They eat a wide range

of soil and surface-living invertebrate species including beetles and earthworms, but also on

plant material such as berries, seeds and grasses. They are a red-listed species of conservation


Wigeon are common and widespread throughout Ireland in the winter where they occur on the

coast and in inland wetlands, lakes and rivers. Away from coasts they graze on algae and also

regularly feed on grasslands and cereal crops. They are an amber-listed species of conservation


Wetlands are also listed as a feature of the SPA. Eutrophication has the potential to alter

wetland habitats as certain wetland species would be sensitive to changes in water quality.

Influxes in nutrients can result in a shift in species composition toward more tolerant competitive

species and a loss of rarer species which typically require lower nutrient inputs. Floristic diversity

generally decreases and sensitive invertebrate species may be lost. Some aquatic plants and

algae may increase in biomass. Wetlands associated with the SPA are the wet grasslands

downstream/east of Bunowen Bridge over 8km to the southeast of the WwTP discharge.

Table 7.0 Qualifying SPA Features along surveyed stretch

Site Qualifying

Species

Observed or signs of species

presence

Suitable Habitat Present

Middle

Shannon

Callows SPA

Whooper Swan Upstream No Upstream No

Downstream No Downstream Yes

Wigeon Upstream No Upstream No


Golden Plover Upstream No Upstream No


Lapwing Upstream No Upstream No


Greenland

white-fronted

goose

Upstream No Upstream No


Wetlands Upstream Yes

Downstream Yes


Conservation Objectives of the River Suck Callows SPA

Article 6 of the Habitats Directive states that:

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

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

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

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

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

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

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

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

monitoring of key species and habitats.

Site specific conservation objectives (SSCOs) are not yet available for the River Suck Callows

SPA. However reference was made to the generic objectives (NPWS, 2015) and to the SSCOs

for Wexford Slobs SPA (NPWS, 2011) which include the following targets for many of the

wintering bird species:

To maintain the long term population trend stable or increasing.

There should be no significant decrease in the numbers of range of areas used by

waterbird species other than that occurring from natural patterns of variation.

Impact Prediction

Impacts on Water Quality

Effluent monitoring results indicate that high levels of nutrients are discharged into the

Ahascragh River, and calculations indicate that the Ahascragh river has limited assimilative

capacity particularly for Ammonia.

EPA biological monitoring results indicate that water quality drops downstream of the WwTP, but

improves again by Bunowen Bridge ca. 8km downstream of the WwTP discharge. Furthermore,

based on monitoring results, levels of nutrients in downstream surface waters are within the

required quality standards.

Given the distance to the SPA, and the improvement of water quality further downstream along

the Bunowen river prior to entering the SPA, the WwTP does not appear to be significantly

affecting water quality in the SPA.

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

objectives. The poor quality discharge from Ahascragh WwTP has the potential to combine with

other sources of nutrient pollution in the Suck catchment and result in significant combined

effects on the integrity of the SPA.

The River Suck River Basin Management Plan 2009-2015 for the waterbody (IE_SH_Suck)

highlights that diffuse pollution from agriculture and pollution from unsewered properties


accounts for 92% of total phosphorus (ShRBD, 2010). It further notes that the waterbody within

which the Ahascragh river is located (IE-SH_26_3041) is specifically at risk from agriculture and

morphology works. Eight of the WwTPs within the River Suck Water Management Unit are

considered at risk, including Ahascragh WwTP. In addition the catchment is considered to be at

risk from three quarries and 2 industrial facilities.

Other impacts which are likely to act cumulatively and impact on the SPA result from the

following:

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

nitrogen, phosphorus, potassium and sulphur);

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

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

over a number of years (OECD, 1986);

Artificial drainage increases nitrate leaching and reduce the morphological qualities of

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

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

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

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

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

works (Routledge et al. 1998);

Forestry may alter water quality indirectly through increased evaporation losses and

hence an increase in solute concentrations;

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

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

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

to reducing flows and assimilation capacity.

The Ahascragh WwTP in combination with other catchment pressures has the potential to impact

on the water quality of the SPA, which is an important supporting function for overall site integrity.

Mitigation measures to improve water quality are detailed below.

Impacts on designated features of the SPA

The Natura 2000 Data form for the SPA notes that the principal threat to the ornithological

interests is agricultural improvement including drainage attempts to reduce winter flooding and

agricultural intensification which may also be affecting numbers of breeding waders. Wildfowling

is also an issue causing disturbance to species.

The closest SPA wetland habitats downstream of the WwTP are agricultural wet grasslands

which would not be particularly sensitive to minor levels of eutrophication. It is noted most of the

species listed as features of the SPA feed terrestrially in agricultural fields adjacent to the River

Suck over 8km to the south-east of the WwTP with no potential to be affected by the discharge.

However some species, such as Whooper Swan and Wigeon, may also feed on aquatic plants

and algae associated with the lower reaches of Ahascragh/Bunowen river and the main channel

of the River Suck.


Slight to moderate eutrophication is more likely to cause a shift in species composition and an

increase in biomass of these food sources which is not expected to impact negatively on birds

with generalist diets such as whooper swan or wigeon. The possibility that Ahascragh WwTP

may contribute to cumulative impacts on water quality resulting in more serious pollution cannot

be ruled out however and mitigation measures to address this risk are detailed below.

Table 8.0: Qualifying Features of SPA Potentially Impacted by WwTP Discharge

Qualifying

Habitats

Potential

Impacts

Brief Explanation Mitigation

required

Whooper

Swan

Yes Species that may graze on aquatic plants and algae and

therefore potential that the WwTP, combined with other

catchment pressures, could result in negative impacts.

Yes

Wigeon Yes Species that may graze on aquatic plants and algae and

therefore potential that the WwTP, combined with other

catchment pressures, could result in negative impacts.

Yes

Golden Plover No Species feeding predominately in terrestrial habitats

with little or no potential to be impacted by the WwTP

discharge.

No

Lapwing No Species feeding predominately in terrestrial habitats


discharge.

No

Greenland

White-fronted

goose

No Species feeding predominately in terrestrial habitats


discharge.

No

Wetlands

Yes While sensitive wetland habitats associated with the

designated site are located a significant distance

downstream, cumulative impacts on water quality could

potentially affect these habitats.

Yes

Mitigation Measures Due to poor effluent quality and limited assimilative capacity in the Ahascragh river the potential

for cumulative effects on the conservation status of the SPA special conservation interests, and

on the overall integrity of the SPA cannot be ruled out. Therefore, there is a need to improve the

quality of the effluent being discharged from Ahascragh WwTP.

Mitigation Measures recommended for the ongoing operation of the plant are as follows:

Implementation of an appropriate waste water treatment process in order to reduce the

levels of BOD, Ammonia and Orthophosphate currently being discharged from the plant

to ensure surface water regulation standards are met downstream;

Implementation of an appropriate performance management system for the plant;

Ensure that the capacity of the WwTP is not exceeded; and

Continuation of monitoring of the effluent on a consistent regular basis.


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

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

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

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

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

assessment for the Waste Water Discharge Authorisation investigates the potential adverse

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

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

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

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

measures necessary to avoid, reduce or offset negative effects.

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

significant adverse effects on the integrity of the River Suck Callows SPA in view of the site’s

conservation objectives and that the conservation status of the SPA features will not be

compromised by WwTP discharge either directly, indirectly or cumulatively.

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

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

Callows SPA, as long as the mitigation measures as listed above are implemented in full. Stage

2 concludes the Appropriate Assessment process of the Ahascragh Waste Water Discharge

Licence Application.


References

Colhoun, K & Cummins, S.(2013) Birds of Conservation Concern in Ireland 2014-2019. Irish

Birds 9: 523-544.

Crowe (2005) Irelands Wetlands and Their Waterbirds: Status and Distribution. Birdwatch

Ireland.

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

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

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

Strategy. Environment Agency, Bristol.

EPA (2009) Waste Water Discharge Licensing Appropriate Assessment Guidance Notes. Notes

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

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

Fox, T; Francis, I, Norriss, D & A. Walsh. (2015) Report of the 2014/2015 International Census

of Greenland White-fronted Geese. Greenland White-fronted Goose Study. Final Report –

October 2015.

Hall,C; Glanville, J.R.; Boland, H; Einarsson, O; McElwaine, G; Holt, C.A; Spray, C.J. and Rees,

E. (2012) Population size and breeding success of Iceland Whooper Swans Cygnys Cygnus:

results of the 2010 international census. Wildfowl 62: 73-96.

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

inputs. English Nature/Environment Agency, Peterborough.

Maitland & Campbell. (1992). Freshwater Fishes of the British Isles. Harper Collins Publishers.

Somerset, UK.

NPWS (2011). Wexford Harbour and Slobs SPA (004076) and the Raven SPA (004019):

Conservation Objectives Supporting Document[Version 1]. Unpublished Report.

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 (2015) Conservation objectives for River Suck Callows SPA [004097]. Generic Version

4.0. Department of Arts, Heritage and the Gaeltacht.

OECD (1986) Water pollution by fertilisers and pesticides. Organisation for Economic

Cooperation and Development, Paris, 144 pp.


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

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

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

ShRBD (2010) Shannon River Basin District - River Basin Management Plan River Suck Water

Management Unit:

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

%202015/ShIRBD%20RBMP%202010/Water%20Management%20Unit%20Action%20Plans/Su

ck%20WMU.pdf

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