arrabawn production upgrade, nenagh, co. tipperary · (shannon) spa and the lower river shannon...

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Arrabawn Production Upgrade, Nenagh,

Co. Tipperary

NATURA IMPACT STATEMENT

Version (13-8-19) FINAL

Tait Business Centre, Dominic Street,

Limerick City, Ireland. t. +353 61 419477 f. +353 61 414315

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mailto:[email protected]


NIS: Proposed Production Upgrade at Arrabawn Co-operative Society Ltd, Nenagh August 2019

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EXECUTIVE SUMMARY The current document provides a Natura Impact Statement (NIS) and assesses the likely significant

effects on the Lough Derg (Shannon) Special Protection Area (SPA) (Site Code: 004058) and the Lower

River Shannon Special Area of Conservation (SAC) (Site Code: 002165) arising from the proposed

production upgrade works at Arrabawn Co-operative Society Ltd., Nenagh, Co. Tipperary.

A Screening for Appropriate Assessment has already been carried out for the proposal by Mott

McDonald, which is included in Appendix 1 of the current report. This Screening report identified the

potential water quality impacts on the Natura 2000 network and concluded that there was no potential

for significant effects, and wastewater discharges from the operational phase would be regulated by the

EPA under Arrabawn’s Industrial Emissions Licence. Arrabawn are applying for a revision to the existing

Industrial Emissions Licence (P0791-03). The conclusion of the Screening report relied on the industrial

emissions licence revision and the regulation of Arrabawn’s wastewaters by the EPA which it is

understood the EPA considers to be mitigation. If mitigation measures are required to reduce or avoid

a significant adverse effect, then Appropriate Assessment (Natura Impact Statement) is required.

Therefore, the following report provides a NIS and mitigation is set out in this document.

There is a hydrological connection with the Lough Derg, North-east Shore SAC (Site Code: 002241),

but the qualifying interests of this SAC are terrestrial. There are no pathways identified for impacts on

this SAC and therefore the Lough Derg, North-east Shore SAC is not assessed in this NIS.

There is a downstream hydrological connection between the proposed works and the Lough Derg

(Shannon) SPA and the Lower River Shannon SAC. The Lough Derg (Shannon) SPA is located c. 12.5

river kilometres (rkm) downstream, via the Clareen stream (into which the Arrabawn WwTP discharges)

and the Nenagh River. Therefore, there is a potential for water quality impacts to arise which could

affect the bird species and the wetland and waterbirds habitat in the SPA. Although the Lower River

Shannon SAC is located over 30rkm downstream, the Salmon population of the SAC are known to

spawn in the Nenagh River, and therefore, could be indirectly and cumulatively impacted by the

proposed works. There is also potential spawning habitats for Sea Lampreys associated with the Lower

River Shannon SAC in the Nenagh River. During the current site visit, the Clareen stream was found to

be suffering from existing water quality impacts. As per Article 10, connectivity between Natura 2000

sites, specifically river systems, should also be considered.

Mitigation measures have been provided to protect water quality: silt fences, on-site refuelling in bunded

areas at least 50m away from any watercourse or drain; minimise excavation works near any

watercourse or drain; spill kits; equipment / machinery will be regularly maintained and if repairs are not

possible, will be removed from site; no concrete / cement mixing will be carried out adjacent to any

watercourse or drain; tool washing and waste / grey water will be stored securely behind bunded areas

until removal from the site; chemical portaloos toilets will be used and all sewage will be appropriately

removed from the site to an authorised treatment plant. Biosecurity guidelines will be followed on site.

Surface waters from hard-standing areas (the new access road, internal roundabout, car-park areas

and the roof of the Packaging Store) will pass through a new proprietary Class 1 By-Pass Separator

directed to the Clareen stream. Surface water run-off from further areas around process plant buildings

and around utility plant facilities, i.e. casein building, milk intake area and CIP wash areas, will be

collected via the site effluent drainage system to the site WWTP. Impermeable bunded areas will also

be used for the operational phase for refuelling and storage. Routine monitoring will also be carried out.

The mitigation measures proposed are considered to be sufficient to ensure that potential impacts

regarding water quality are minimised. From the evidence presented in the current assessment, it is

concluded that the potential indirect and cumulative impacts that may arise from the proposed upgrade

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works at Arrabawn Co-operative Society Ltd. in Nenagh, Co. Tipperary do not have the potential to

affect the integrity of either the Lough Derg (Shannon) SPA or the Lower River Shannon SAC.

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TABLE OF CONTENTS

1. INTRODUCTION ........................................................................................................................................ 5

1.1 CONSULTATION ........................................................................................................................................... 5 1.2 LEGISLATIVE CONTEXT ................................................................................................................................... 6

1.2.1 Habitat Connectivity ....................................................................................................................... 7

2. METHODOLOGY ....................................................................................................................................... 8

2.1 DESKTOP REVIEW ........................................................................................................................................ 8 2.2 SITE SURVEY ............................................................................................................................................... 8 2.3 APPROPRIATE ASSESSMENT METHODOLOGY ..................................................................................................... 8

2.3.1 Natura Impact Assessment ............................................................................................................. 9

3. NATURA IMPACT STATEMENT ................................................................................................................ 11

3.1 DESCRIPTION OF THE PROPOSED PROJECT....................................................................................................... 11 3.2 DESCRIPTION OF THE RECEIVING ENVIRONMENT ............................................................................................... 12

4 DESCRIPTION OF THE NATURA 2000 SITES AFFECTED ............................................................................. 13

4.1 OVERVIEW OF THE LOUGH DERG (SHANNON) SPA........................................................................................... 15 4.1.1 Annex I habitats listed as qualifying interests of the Lough Derg (Shannon) SPA ........................ 15 4.1.2 Annex II species listed as qualifying interests of the Lough Derg (Shannon) SPA ......................... 15

4.2 OVERVIEW OF THE LOWER RIVER SHANNON SAC ............................................................................................ 16 4.2.1 Annex I habitats listed as qualifying interests of the Lower River Shannon SAC........................... 16 4.2.2 Annex II species listed as qualifying interests of the Lower River Shannon SAC ........................... 18

5 IMPACT PREDICTION .............................................................................................................................. 20

5.1 DIRECT IMPACTS ........................................................................................................................................ 20 5.1.1 Direct impacts during construction phase ........................................................................................... 20 5.1.2 Direct impacts during operational phase ............................................................................................. 20

5.2 INDIRECT IMPACTS ..................................................................................................................................... 20 5.2.1 Indirect impacts during construction phase ......................................................................................... 20 5.2.2 Indirect impacts during operational phase .......................................................................................... 21

5.3 CUMULATIVE IMPACTS ................................................................................................................................ 24

6 MITIGATION MEASURES ........................................................................................................................ 26

6.1 CONSTRUCTION PHASE ............................................................................................................................... 26 6.1.1 Water Quality Protection .............................................................................................................. 26 6.1.2 Biosecurity..................................................................................................................................... 26

6.2 OPERATIONAL PHASE ................................................................................................................................. 26 6.2.1 Water Quality ............................................................................................................................... 26

7 IMPACTS AFFECTING THE CONSERVATION OBJECTIVES OF THE NATURA 2000 SITE ............................... 28

8 NIS CONCLUSION STATEMENT ............................................................................................................... 30

REFERENCES ................................................................................................................................................... 32

PLATES ........................................................................................................................................................... 34

APPENDIX 1 SCREENING FOR APPROPRIATE ASSESSMENT REPORT ....................................................... 37

APPENDIX 2 CONSTRUCTION ENVIRONMENTAL MANAGEMENT PLAN .................................................. 38

APPENDIX 3 NPWS SITE SYNOPSIS ......................................................................................................... 39

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1. INTRODUCTION

The current document is a Natura Impact Statement (NIS) and assesses the likely significant effects on

the Lough Derg (Shannon) SPA and the Lower River Shannon SAC arising from the proposed

production upgrade works at Arrabawn Co-operative Society Ltd., Nenagh, Co. Tipperary. The location

of the proposed works is given in Figure 1. A Screening for Appropriate Assessment has already been

carried out for the proposed development by Mott McDonald, which is included in Appendix 1 of the

current report. This Screening report identified the potential for water quality impacts on the Natura

2000 network. The report concluded that there was no potential for significant effects, and wastewater

discharges from the operational phase plant would be regulated by the EPA under Arrabawn’s Industrial

Emissions Licence. Arrabawn are applying for a revision to the existing Industrial Emissions Licence

(P0791-03). The conclusion of the pre-assessment Screening relies on the industrial emissions licence

revision and the regulation of Arrabawn’s wastewaters by the EPA, which is considered to be mitigation.

In case C-323/17 People Over Wind and Peter Sweetman v Coillte, the Court of Justice of the European

Union (CJEU) ruled that mitigation measures aimed or reducing or offsetting an adverse effect on the

conservation objectives of a designated site could not be taken into account when undertaking a

screening for Appropriate Assessment1. If mitigation measures are required to reduce or avoid a

significant adverse effect, then Appropriate Assessment (Natura Impact Statement) is required.

Therefore, the following report provides a Natura Impact Statement and mitigation is set out in this

document.

The preparation of this NIS for Appropriate Assessment is required under the Habitats Directive

(92/43/EEC) in instances where a plan or project may give rise to significant effects upon a Natura 2000

site. Natura 2000 sites are of European Importance and have been designated in accordance with the

requirements of the EC Habitats Directive (1992) and EC Birds Directive (2009/147/EC); transposed

into Irish legislation as the European Communities (Birds and Natural Habitats) Regulations 2011 (S.I.

477 of 2011). The Habitats Directive, in combination with the Birds Directive (2009), establishes a

network of internationally important sites designated for their ecological status; indentified as Special

Areas of Conservation (SACs) designated under the Habitats Directive for the protection of flora, fauna

and habitats and as Special Protection Areas (SPAs) designated under the Birds Directive to protect

rare, vulnerable and migratory birds. These sites together form a Europe-wide 'Natura 2000' network of

designated sites, referred to in this report as Natura 2000 sites.

This assessment follows the Habitats Directive 92/43/EEC, Article 6(3) and the guidance published by

the National Parks and Wildlife Service (DoEHLG, 2010) ‘Appropriate Assessment of Plans and

Projects in Ireland - Guidance for Planning Authorities’. The assessment also follows the EPA guidance

‘Waste Water Discharge Licensing: Appropriate Assessment’ (EPA, 2012). The current Natura Impact

Statement (NIS) assesses the impact of the proposed upgrade works at Arrabawn at both construction

and operation stages in relation to direct, indirect and cumulative effects on the Integrity of the Natura

2000 network.

1.1 Consultation

The following statutory bodies provided information via publically available sources for this report:

• National Parks and Wildlife Service (NPWS);

• Environmental Protection Agency (EPA);

• National Biodiversity Data Centre (NBDC).

1 The ruling set out by CJEU in People Over Wind and Sweetman v. Coillte Teoranta (Case C-323/17) (‘People Over Wind’) was recently applied by the Irish High Court in the judgement of Eoin Kelly v. An Bord Pleanála [2019] IEHC 84 (‘Eoin Kelly’)

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1.2 Legislative context The current assessment takes account of Council Directive 92/43/EEC on the conservation of natural

habitats and of wild fauna and flora - ‘The Habitats Directive’ which was transposed into Irish law by the

‘European Community (Natural Habitats) Regulations 1997’ (S.I. No. 94/1997). The most recent

transposition of this legislation in Ireland is the European Communities (Birds and Natural Habitats)

Regulations 2011 (S.I. No. 477 of 2011). The Birds Directive (2009/147/EC) which is now included in

the former Regulations seeks to protect birds of special importance by the designation of Special

Protection Areas (SPAs) whereas the Habitats Directive does the same for habitats and other species

groups within Special Areas of Conservation (SACs), which are designated or proposed as candidate

Special Areas of Conservation (cSACs). It is the responsibility of each member state to designate SPAs

and SACs, both of which will form part of Natura 2000, a network of protected areas throughout the

European Community. Article 6, paragraphs 3 and 4 of the EC ‘Habitats’ Directive (1992) state that:

6(3) ‘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 for the site in view of the site's

conservation objectives. In the 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.’

6(4) ‘If, in spite of a negative assessment of the implications for the 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, the Member State 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. Where the site concerned hosts

a priority natural habitat type and / or a priority species, the only considerations which may be raised

are those relating to human health or public safety, to beneficial consequences of primary importance

for the environment or, further to an opinion from the Commission, to other imperative reasons of

overriding public interest.’

In addition, the European Court of Justice in Case C-127/02 (the “Waddenzee Ruling”) has made a

relevant ruling in relation to Appropriate Assessment and this is reflected in the current assessment:

‘Any plan or project not directly connected with or necessary to the management of the site is to be

subject to an appropriate assessment of its implications for the site in view of the site’s conservation

objectives if it cannot be excluded, on the basis of objective information, that it will have a significant

effect on that site, either individually or in combination with other plans or projects” and that the plan or

project may only be authorised “where no reasonable scientific doubt remains as to the absence of

such effects.’

In case C-323/17 People Over Wind and Peter Sweetman v Coillte, the Court of Justice of the European

Union (CJEU) ruled that mitigation measures could not be taken into account when undertaking a

screening for Appropriate Assessment. If mitigation measures are required to reduce or avoid a

significant adverse effect, then Appropriate Assessment is required.

The European Commission guidelines (2018) states that the procedure for appropriate assessment

under Article 6(3) of the ‘Habitats’ Directive is not triggered by certainty but by the likelihood of significant

effects, and such likelihood exists if significant effects on the site cannot be excluded. In Kelly –v- An

Bord Pleanála 2013/802 High Court Judgement Ruling, it is stated that the ‘possibility of there being a

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significant effect on the site will generate the need for an appropriate assessment for the purposes of

Article 6(3).’; and that there is no need to establish such an effect, it is only merely necessary to

determine that there may be such an effect. The threshold at the first stage (pre-assessment Screening)

of Article 6(3) is therefore a very low one.

In a recent case in the High Court in the UK, in case R (on the Application of Preston) v Cumbria County

Council [2019] EWCA 1362, planning permission was sought for a water company to construct a

sewage outfall into a European Site river. Planning permission was quashed as the High Court did not

accept the County Council’s argument that it did not need to assess the operational phase impacts of

the discharge on the SAC River because it could rely on the competence of the Environment Agency

to regulate the discharges under the separate environmental permitting regime. Therefore, the

competent authority that is carrying out an appropriate assessment of a plan or project cannot rely on

the competence of other regulators to avoid conducting their own assessments. Although this is not a

CJEU ruling, this is considered relevant to the current project.

1.2.1 Habitat Connectivity

Article 10 of the Habitats Directive (92/43/EEC), concerns the protection of the Natura 2000 network

taking into account habitats outside protected areas in order to maintain and increase connectivity

between habitats and populations at risk of being cut off from each other. The article states that

"Member States shall endeavour, where they consider it necessary, in their land-use planning and

development policies and, in particular, with a view to improving the ecological coherence of the Natura

2000 network, to encourage the management of features of the landscape which are of major

importance for wild fauna and flora (such as rivers with their banks or the traditional systems for marking

field boundaries)". These features allow for habitat connectivity. Rivers are specifically mentioned as a

feature that links and provides habitat connectivity to Natura 2000 Sites. Article 3(2) of the EU Birds

Directive states that to provide sufficient habitat for birds it is necessary to carry out "upkeep and

management in accordance with the ecological needs of habitats inside and outside the protected

zones". Therefore the habitats around and connecting Natura 2000 Sites that are of importance to

protected species must also be considered.

Habitat fragmentation resulting from the loss of movement corridors and can affect individual species

in several ways such as reduced breeding success and reduced genetic diversity, in addition to effects

on overall ecosystem functioning. Connectivity between habitats and populations allows biodiversity to

persist, which increases ecosystem resilience (Kettunen et al, 2007). Species need wildlife corridors to

carry out natural dispersals between populations along with reaching resources such as feeding

grounds and mates. This highlights the importance of Natura 2000 networks and protecting species

movement between Natura 2000 sites.

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2. METHODOLOGY

2.1 Desktop Review A desktop study was undertaken to identify the extent and scope of the potentially affected designated

Natura 2000 sites within the current study area in relation to the development site, including the Lough

Derg (Shannon) SPA and the Lower River Shannon SAC. The desktop study identified the qualifying

interests (species and habitats) relevant to the designated sites within the area.

A review of published literature was undertaken in order to collate data on the receiving environment; a

range of additional sources of information including scientific reports produced by, and information on

the websites of the EPA and NPWS were also reviewed. Information sources reviewed as part of the

current assessment included NPWS site synopses, as well as protected species data held on the

NPWS/NBDC online databases. A full bibliography of information sources reviewed is given in the

reference section. Mapping software QGIS was used to illustrate the location of the proposed

development, in relation to watercourses and Natura 2000 sites. Additional information on biological

water quality in the Nenagh River supplied by Arrabawn Co-operative was also reviewed (Conservation

Services, 2018, 2019).

2.2 Site Survey A site visit was undertaken to the Arrabawn Co-operative Society Ltd. plant, the Clareen stream and

the Nenagh River on the 23rd of July 2019. The proposed works areas and environs were inspected for

evidence of ecological features of high conservation concern such as those flora and fauna that occur

in the closest Natura 2000 sites.

2.3 Appropriate Assessment Methodology

The preparation of this NIS for Appropriate Assessment follows the guidance published by DoEHLG

(2010) ‘Appropriate Assessment of Plans and Projects in Ireland. Guidance for Planning Authorities’.

According to these guidelines, assessing the impacts of a project or plan on a Natura 2000 site is a four

staged approach, as described below:

• Stage One: Screening / Test of Significance - The process which identifies the likely impacts

upon a Natura 2000 site of a project or plan, either alone or in combination with other projects

or plans, and considers whether these impacts are likely to be significant;

• Stage Two: Appropriate Assessment - The consideration of the impact of the project or plan

on the integrity of the Natura 2000 site, either alone or in combination with other projects or

plans, with respect to the site’s structure and function and its conservation objectives.

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

those impacts;

• Stage Three: Assessment of Alternative Solutions - The process which examines

alternative ways of achieving the objectives of the project or plan that avoid adverse impacts

on the integrity of the Natura 2000 site; and

• Stage Four: 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.

The safeguards set out in Article 6(3) and (4) of the Habitats Directive are triggered not by certainty but

by the possibility of significant effects. Thus, in line with the precautionary principle, it is unacceptable

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to fail to undertake an appropriate assessment on the basis that it is not certain that there are significant

effects.

2.3.1 Natura Impact Assessment A Natura Impact Statement (NIS) considers whether the plan or project, 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. The current report is set

out in the format of a NIS and comprises a scientific examination of the plan / project and the relevant

Natura 2000 sites; to identify and characterize any possible implications for the site in view of the site’s

conservation objectives, structure and function, taking account of in combination effects. The

requirements for Appropriate Assessment derive directly from Article 6(3) of the EU Habitats Directive

(1992).

Direct and indirect impacts in isolation or in combination with other plans and projects on the identified

Natura 2000 sites in view of the sites’ conservation objectives have been examined. Case law of the

European Court of Justice (ECJ) has established that Appropriate Assessment must be based on best

scientific knowledge in the field. These are the qualifying interests i.e. Annex I habitats, Annex I bird

species (EU Birds Directive, incorporated into the EU Habitats Directive) and Annex II species hosted

by a site and for which that site has been selected. The conservation objectives for Natura sites (SACs

and SPAs) are determined under Article 4 of the Habitats Directive and are intended to ensure that the

relevant qualifying interests i.e. Annex I habitats, Annex I bird species and Annex II species present

within the designated sites, are maintained in a favourable condition.

The current assessment of the proposed upgrade works to the Arrabawn Plant in Nenagh. Co. Tipperary

provides a description of the project and the receiving environment. The conservation objectives of

Natura 2000 sites potentially affected by the proposal are listed and potential impacts outlined with

respect to the integrity of the Natura 2000 site. Mitigation measures have been proposed for the

protection of the conservation interests and the avoidance of impacts to Natura 2000 sites occurring

within the study area.

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Figure 1 Location of Proposed Development Boundary at Arrabawn Co-operative Society Ltd. in

Nenagh, Co. Tipperary Showing Watercourses (No Natura 2000 Sites in Direct Vicinity).

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3. NATURA IMPACT STATEMENT

This Natura Impact Statement provides a description of the proposed works with regard to the

conservation objectives of the affected SPA and SAC, where the qualifying interests and conservation

objectives of these sites potentially affected by the proposed upgrade works are listed and potential

impacts outlined.

3.1 Description of the Proposed Project Arrabawn’s milk processing plant is located in Stafford Street in Nenagh, County Tipperary. Its

operations are divided between three sites, located in close proximity to each other, as follows:

● Arrabawn offices;

● Arrabawn milk processing facility; and

● Arrabawn wastewater treatment plant.

Both the offices and the milk processing facility are located on Stafford Street. The wastewater

treatment plant (WWTP) is located approximately 120 metres to the south of the milk processing plant.

Arrabawn is proposing an upgrade to the plant which will comprise an extension to its casein

process building and the installation of new plant and equipment within the existing wastewater

treatment plant. It is also proposed to provide a new vehicular / pedestrian access via the

existing roundabout on Kenyon Street and to provide new internal access routes for incoming

and outgoing heavy goods vehicles (HGVs) and other ancillary works.

The casein processing building is located to the south-west of the site. The current proposal aims to

double the capacity of the processing building, which currently produces 1.2 tons of acid casein powder

from approximately 34,000 litres of milk per hour, by installing a similar scale plant adjacent to the

existing building. This will involve two extensions to the existing building, which will necessitate the

removal of five derelict buildings and a treeline on the site.

The proposal also includes a new vehicular access route from the existing roundabout on Kenyon street

to accommodate HGVs. This new entrance will replace the existing entrance on Stafford street. The

existing entrance will be reduced in width and maintained for emergency access only, and the existing

access to the west of the site will be used for emergency exit only. This is to achieve a loop of a one-

way traffic system on the site. The new access from Kenyon Street will require a revised roundabout

layout. Additionally, it is proposed to construct: two new car parks to replace existing car parks within

the footprint of the works, a lorry wash area, a two-lane CIP/Wash area, two weigh bridges, a security

booth, a three-lane milk intake area, internal roadways, internal drainage and landscaping. Two derelict

buildings, two storage sheds and a truck wash will need to be removed. The drainage for the new

entranceway and associated buildings will tie in to the existing drainage scheme. The wastewater from

the lorry wash areas and the CIP/wash area will enter the WwTP prior to discharge to the Clareen

stream.

The Arrabawn plant in Nenagh processes wastewater discharges under Arrabawn’s industrial

emissions licence (P0791-02), regulated by the EPA. Wastewaters consist of cooling water and

condensate from evaporators (SW1, monitored by the EPA) and treated effluent from the WwTP (SW2,

monitored by the EPA). Arrabawn is applying for a revision to its existing Industrial Emissions Licence.

As part of it proposed upgrade, it is proposed to reconfigure and upgrade the existing WwTP in order

to achieve compliance with emission limit values. The new plant and equipment which are proposed

include the following:

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• Conversion of aeration tanks to emergency holding tanks;

• Modifications to the Dairy Balance Tank;

• Provision of new DAF unit;

• Modifications and reconfiguration of existing Anoxic tank and Aeration tank (AS3);

• Provision of new Aeration tank (AS4);

• Conversion of existing secondary settlement tank to Inter-stage settlement;

• Final settlement tank;

• Provision of additional sludge thickening tank; and

• Extension of the sludge dewatering building and installation of new dewatering centrifuge.

For the construction works at the casein processing building, a temporary contractor’s compound is

proposed to be located in the existing open yard area to the east of the existing milk intake. Temporary

car parking for construction site staff workers of the extensions/upgrade to the casein processing

building will be provided within the Mart site, adjoining Arrabawn and in close proximity to the casein

building location.

Additionally, a temporary contractor’s compound to facilitate construction of the new entrance and works

to Kenyon Street roundabout is proposed to be located within the area of the proposed new car park

located adjacent to Stafford Street. It is proposed that works to the milk intake and CIP/truck wash

areas, security control building and internal car park will be facilitated from this compound area also. It

is envisaged that the compound can be maintained at this location until all these works are complete.

At that stage, the contractor car parking could move to the new central car park area to facilitate

completion of the main car park, internal roundabout and closing down of the existing entrance from

Stafford Street.

3.2 Description of the receiving environment

The Clareen stream is a tributary of the Nenagh River. The Clareen stream runs south to north from its

source approximately 1km to the south of Nenagh town, and through Nenagh town to its confluence

with the Nenagh River east of the town and just south of the N7 road to Dublin. The Clareen stream

passes under the Arrabawn facility where it has been culverted for the majority of its length (1.5km) until

its confluence with the Nenagh River (approximately 850m to the north-west of the Arrabawn facility).

The Clareen stream, while recognised by the EPA as a watercourse (EPA Code: 25C11), is not

allocated a waterbody code as part of the characterisation of surface waters under the Water

Framework Directive (WFD); specifically, the Clareen stream is not considered a waterbody in its own

right, but part of a larger waterbody i.e. the Nenagh River (Nenagh_060/WFD code: IE-SH-25N010700).

As such, the EPA, who monitor emissions to surface water from the Arrabawn facility as part of its

industrial emission licence (P0701-02), acknowledge the Nenagh River as the receiving waterbody in

terms of assimilative capacity. Lough Derg itself is classified as ‘Poor’ lake waterbody Water Framework

Directive (WFD) status and is also assessed as being ‘At Risk’.

The Nenagh River rises in the Silvermine Mountains in County Tipperary. From the confluence point

with the Clareen stream, the Nenagh River flows in a north westerly direction prior to discharging into

Lough Derg at Dromineer, approximately 7.3km north west of Nenagh. Minor tributaries to the Nenagh

River are located within the town boundary, including the Clareen stream.

In 2018, the Environmental Protection Agency (EPA) carried out biological monitoring at 7 no. locations

on the River Nenagh. Their overall assessment was as follows: "The biological water quality declined

at three of the seven sites assessed in the Nenagh River in 2018. Four sites are now in unsatisfactory

moderate ecological condition." Upstream of Nenagh town, where the River Nenagh (EPA Segment

Code: 25_13135) crosses the R498, there is an EPA monitoring station (Station Code: 25N010500).

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This station was rated Q3-4 in 2018 equivalent to WFD status "Moderate". There is another EPA

monitoring station (Station Code: 25N010700) downstream of Nenagh town where the river crosses the

L1608. In 2018, this site was also rated Q3-4. Approximately 2.6rkm upstream of where the River

Nenagh flows into Lough Derg, there is an EPA monitoring station (Station Code: 25N010800). This

site was rated Q3-4 in 2018.

According to the subcatchment assessment on the catchments.ie online maps, the River Nenagh at

Nenagh town and downstream to Lough Derg is under pressure from hydromorphology (bank erosion

and steep slopes) and industry. It is also stated that the area of Lough Derg in this subcatchment is at

risk from hydromorphology, urban wastewater, invasive species and agriculture. This subcatchment

assessment also notes that the Clareen stream suffers from nutrient enrichment and organic pollution,

from industry and discharges.

Conservation Services, Ecological & Environmental Consultants, Killarney, Co. Kerry have carried out

four consecutive years of biological monitoring and habitat assessments at two sites on the River

Nenagh for the Arrabawn facility. The downstream site (ASW2) was located at R87413 79304 and the

upstream site was located at R87413 79304 (ASW1). Both sites were rated Q4 in 2016, Q3-4 in 2017

and Q4 in 2018. In the 2019 survey, the biological data did not indicate any deterioration in water quality

between Site ASW1 (immediately upstream of the creamery discharge) and Site ASW2 (immediately

downstream of the creamery discharge); there is therefore no evidence that the creamery is causing

any deterioration in the biological water quality of the Nenagh River according to Conservation Services

(2019).

4 DESCRIPTION OF THE NATURA 2000 SITES AFFECTED The proposed upgrade works at the Arrabawn Co-operative Society Ltd. are not located within any

Natura 2000 Site. The closest Natura 2000 site is the Lough Derg (Shannon) SPA (Site Code: 004058).

As the Arrabawn WwTP discharges into the Clareen stream, there is a hydrological connection to the

Lough Derg (Shannon) SPA, c. 12.5rkm downstream via the Clareen stream and the Nenagh River.

There is also a hydrological connection with the Lough Derg, North-east Shore SAC, but the qualifying

interests of this SAC are terrestrial. There are no pathways identified for impacts on this SAC, and

therefore, the Lough Derg, North-east Shore SAC will not be assessed further.

The proposed works are located c. 34.5km upstream of the Lower River Shannon SAC, via the Clareen

stream, the River Nenagh and Lough Derg. Although this is a considerable distance, the Atlantic Salmon

population of the Lower River Shannon SAC are known to spawn in the Nenagh River and therefore

there is a pathway for impacts on the qualifying interests of this SAC. Figure 2 below shows the location

of the nearest Natura 2000 Sites and watercourses.

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Figure 2 Location of the Proposed Works Boundary at Arrabawn Co-operative Society Ltd. in Nenagh,

Co. Tipperary Showing Closest Natura 2000 Sites.

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4.1 Overview of the Lough Derg (Shannon) SPA Lough Derg (Shannon) SPA is located in Tipperary, Galway and Clare. It is the largest lake on the River

Shannon. The lake has high levels of hardness and is classified as a mesotrophic system and some of

the shoreline has swamp vegetation. The SPA is designated under the E.U. Birds Directive for the

protection of Cormorant, Tufted Duck, Goldeneye and Common Tern and its associated habitat:

Wetlands & Waterbirds. There is a nationally important breeding population of Common Tern present

and one of the Islands where these birds’ nest has been managed to increase suitable habitat and nest

survival. The cormorant population is also nationally important. Tufted duck and Great Crested Grebe

also breed here. In winter, the lake holds a nationally important population of Tufted Duck and

Goldeneye. Hen Harrier has roosted on the reedbeds on the site edges during winter. Other important

species that overwinter here include Mute Swan. Whooper Swan, Green-land White-fronted Goose,

Hen Harrier and Common Tern are all Annex I species.

4.1.1 Annex I habitats listed as qualifying interests of the Lough Derg (Shannon) SPA

4.1.1.1 Wetland and Waterbirds [A999]

This habitat is not present in the direct study area of the proposed works at Arrabawn in Nenagh,

however, it is present some c. 12.5 river km downstream in Lough Derg. Therefore, there is a

downstream hydrological connection with this habitat and the proposed works via the Clareen stream

and the River Nenagh. This habitat has the potential to be indirectly or cumulatively impacted by the

proposed works. The birds listed as qualifying interests of the Lough Derg (Shannon) SPA rely on the

Wetland and Waterbirds habitat.

4.1.2 Annex II species listed as qualifying interests of the Lough Derg (Shannon) SPA

4.1.2.1 Cormorant (Phalacrocorax carbo) [A017]

Cormorants are mostly a resident species in Ireland and can be found in most areas of the country. The

colony located in Lough Derg are nationally important with 167 pairs recorded in 1995 and a partial

survey of the lake recorded 113 pairs in 2010. Cormorants are present c. 12.5 river km downstream of

the proposed works, in Lough Derg. These birds have the potential to be indirectly or cumulatively

impacted by the proposed works due to the hydrological connection to Lough Derg via the Clareen

stream and the River Nenagh.

4.1.2.2 Tufted Duck (Aythya fuligula) [A061]

Tufted Duck are a species that are both resident and a winter visitor to Ireland. A nationally important

population is present in Lough Derg, with 776 pairs recorded as the mean peaks for 4 of the 5 seasons

between 1995/6 and 1999/2000. Tufted duck are found c. 12.5 river km downstream in Lough Derg and

therefore have the potential to be indirectly or cumulatively impacted by the proposed works.

4.1.2.3 Goldeneye (Bucephala clangula) [A067]

Goldeneye are a winter visitor to Ireland, with most populations occurring in Ireland between November

and April. Lough Derg (Shannon) SPA itself supports a nationally important population of Goldeneye

with 157 pairs recorded as the mean peaks for 4 of the 5 seasons between 1995/6 and 1999/2000. This

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species is present c. 12.5 river km downstream in Lough Derg from November through April, and

therefore, has the potential to be indirectly or cumulatively impacted by the proposed works.

4.1.2.4 Common Tern (Sterna hirundo) [A193]

Common terns are a summer visitor to Ireland, present from October to March. The Lough Derg

(Shannon) SPA supports a nationally important breeding colony of Common Tern, with 55 pairs

recorded in 1995. This species is present c. 12.5 river km downstream in Lough Derg from November

through April. This species therefore has the potential to be indirectly or cumulatively impacted by the

river maintenance works.

4.2 Overview of the Lower River Shannon SAC

Lower River Shannon SAC stretches from Killaloe, Co. Clare to Loop Head/Kerry head. It is designated

for a wide range of habitats and species including Alluvial Forests, Molinia Meadows, Atlantic Salmon

(Salmo salar) and Otter (Lutra lutra). The freshwater part of this SAC includes the main River Shannon

channel and several tributaries. Molinia meadows dominated by rushes (Juncus spp.) and sedges

(Carex spp.) with a high biodiversity of vegetation and important species like Blue-eyed Grass

(Sisyrinchium bermudiana) and Pale Sedge (C. pallescens) are present. Alluvial woodlands are present

around the University of Limerick. All three Irish Lamprey species occur in this SAC as do Twaite Shad

(Allosa fallax fallax) and Salmon (Salmo salar). Other notable fish species include Smelt (Osmerus

eperlanus) and Pollan (Coregonus autumnalis pollan). Much of the land has been improved or

reclaimed and flood protection is common. Domestic and industrial waste in Limerick is an ongoing

threat. In the Shannon estuary part of the SAC there are several species protected under Annex I of

the E.U. Birds Directive.

Due to the hydrological connection between the proposed works and the Lower River Shannon SAC,

via the Clareen stream, Nenagh River and Lough Derg, habitat connectivity must be considered in the

current assessment. The potential for water quality impacts identified in the current report can all affect

the connectivity to this SAC and the availability of habitat in the Nenagh River to the conservation

interests of the Lower River Shannon SAC. Conservation Interests designated as part of the SAC are

also likely to occur in the Nenagh River, such as Salmon and Lamprey species.

4.2.1 Annex I habitats listed as qualifying interests of the Lower River Shannon SAC

4.2.1.1 Sandbanks which are slightly covered by sea water all the time [1110] The ‘Sandbanks which are slightly covered by sea water all the time’ habitat is not present in the study

area. This habitat within the SAC is present exceptionally far downstream of the proposed works, in the

Shannon estuary south of Carrigaholt in Co. Clare, based on the conservation objectives maps for this

habitat. There is no potential for impacts on this habitat.

4.2.1.2 Estuaries [1130] The Estuaries habitat is not present in the study area; it is located a considerable distance downstream

from the proposed works (based on the conservation objectives maps for this habitat), in Limerick City.

There is no potential for impacts on this habitat due to distance.

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4.2.1.3 Mudflats and sandflats not covered by seawater at low tide [1140] The ‘Mudflats and sandflats not covered by sea water at low tide’ habitat is not present in the study

area. This habitat is located a considerable distance downstream of the proposed works (based on

conservation objectives maps for this habitat), near Limerick City. There is no potential for impacts on

this habitat due to distance.

4.2.1.4 Coastal lagoons [1150] The ‘Coastal lagoons’ habitat is not present in the study area. The closest example of this habitat within

the Lower River Shannon SAC is located a considerable distance downstream of the proposed works

near Shannon Airport in the Shannon estuary (based on conservation objectives maps for this habitat).

Due to distance there is no potential for impacts on this habitat.

4.2.1.5 Large shallow inlets and bays [1160] The ‘Large shallow inlets and bays’ habitat is not located in the study area. This habitat is located a

considerable distance downstream of the proposed works (based on conservation objectives maps for

this habitat), in the Shannon estuary south of Kilrush, Co. Clare. There is no potential for impacts on

this habitat as it is located a far distance downstream.

4.2.1.6 Reefs [1170] The ‘Reefs’ habitat is not present in the study area. This habitat is located a considerable distance

downstream of the proposed works, in the Shannon estuary south of Kildysart (based on conservation

objectives maps for this habitat). There is no potential for impacts on this habitat due to distance.

4.2.1.7 Perennial vegetation of stony banks [1220] The ‘Perennial vegetation of stony banks’ habitat is not present in the study area. The closest example

of this habitat within the Lower River Shannon SAC is a considerable distance downstream of the

proposed works, in the Shannon estuary and Ballymacrinan bay (based on the conservation objectives

maps for this habitat). There is no potential for impacts on this habitat due to distance.

4.2.1.8 Vegetated sea cliffs of the Atlantic and Baltic coasts [1230] The ‘Vegetated sea cliffs of the Atlantic and Baltic coasts’ habitat is not present within the study area;

the closest example within the SAC being a considerable distance downstream of the proposed works,

in the Shannon estuary near Ballybunion (based on conservation objectives maps for this habitat).

There is no potential for impacts on this habitat.

4.2.1.9 Salicornia and other annuals colonizing mud and sand [1310] The ‘Salicornia and other annuals colonizing mud and sand’ habitat is not present in the study area.

This habitat is located an exceptional distance downstream of the proposed works, in the Shannon

estuary near Carrigaholt, Co. Clare (based on conservation objectives maps for this habitat). There is

no potential for impacts on this habitat due to distance.

4.2.1.10 Atlantic Salt Meadows (Glauco-Puccinellietalia maritimae) [1330] The ‘Atlantic Salt Meadows’ habitat is not present in the study area. This habitat as part of the Lower

River Shannon SAC is located a considerable distance downstream of the proposed works, in the

Shannon estuary south of Bunratty, Co. Clare (based on conservation objectives maps for this habitat).

There is no potential for impacts on this habitat due to distance.

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4.2.1.11 Mediterranean salt meadows (Juncetalia maritimi) [1410] The ‘Mediterranean salt meadows’ habitat is not located in the study area. This habitat is located a

considerable distance downstream of the proposed works, in the Shannon estuary east of Ballynacally,

Co. Clare (based on conservation objectives maps for this habitat). There is no potential for impacts on

this habitat as it is located a far distance downstream.

4.2.1.12 Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation [3260] The ‘Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion

vegetation’ habitat is not located in the study area. This habitat is located a far distance downstream of

the proposed works, in Limerick City (based on conservation objectives maps for this habitat). There is

no potential for impacts on this habitat as it is located a far distance downstream.

4.2.1.13 Molinia meadows on calcareous, peaty or clayey-silt-laden soils (Molinion caeruleae) [6410] The ‘Molinia meadow on calcareous, peaty or clayey-silt-laden soils’ habitat is not present in the study

area. This habitat has been recorded in Castleconnell, Co. Limerick, far downstream of the proposed

works. The full extent of this habitat within the SAC is currently unknown. This is a terrestrial habitat

and is not present in the study area or environs of the works and therefore there is no potential for

impacts on this habitat.

4.2.1.14 Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-Padion, Alnion incanae, Salicion albae) [91E0]

The ‘Alluvial forests’ habitat is not present in the study area. The closest example mapped by the

conservation objectives for the SAC being on the banks of the River Shannon at the University of

Limerick, Castletroy. As this is a terrestrial habitats that is not present in the study area or immediate

environs, there is not potential for impacts to arise that may affect this habitat.

4.2.2 Annex II species listed as qualifying interests of the Lower River Shannon SAC

4.2.2.1 Freshwater Pearl Mussel (Margaritifera margaritifera) [1029] Freshwater Pearl Mussel are not present in the study area. The only Freshwater Pearl Mussel

population within the Lower River Shannon SAC is located on the Cloon [Clare] River (upstream of the

works) in the Shannon Estuary. There is no potential for impacts on this species.

4.2.2.2 Sea Lamprey (Petromyzon marinus) [1095]

Sea Lamprey have the potential to be present in the proposed works areas, although located outside

the boundary of the SAC. Small numbers of Sea Lampreys pass through the downstream hydroelectric

scheme each year – but Lough Derg is also known to hold a freshwater-feeding population. Potential

spawning habitat for these lampreys occurs in the lower reaches of the Nenagh River.

4.2.2.3 Brook Lamprey (Lampetra planeri) [1096] Brook Lamprey are likely to be present in the proposed works areas, although located outside the

boundary of the SAC. Lampreys are considered to be present in the River Nenagh downstream of the

proposed works. There is potential for this species to be indirectly or cumulatively impacted by the

proposed works.

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4.2.2.4 River Lamprey (Lampetra fluviatilis) [1099] River Lamprey are unlikely to be present in the proposed works areas as their migration is blocked by

the downstream hydroelectric scheme.

4.2.2.5 Salmon (Salmo salar) [1106] Salmon are known to spawn in the Nenagh River. The Salmon present in the River Nenagh are the

Lower River Shannon SAC population; therefore, there is a potential for indirect and cumulative impacts

on this species. This population is currently at unfavourable conservation status and meeting <5% of

its conservation escapement limit.

4.2.2.6 Common Bottlenose Dolphin (Tursiops truncates) [1349] Common bottlenose dolphins are not present in the study area as this is a marine species. This species

is present in the Shannon estuary far downstream of the proposed works; therefore, there is no potential

for impacts to arise that would affect this species.

4.2.2.7 Otter (Lutra lutra) [1355] Otter are present in the Nenagh River due to the presence of suitable habitat. These Otters are unlikely

to be connected with the Lower River Shannon SAC population.

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5 IMPACT PREDICTION The impact of the project / plan affecting the integrity of a Natura 2000 site is considered with respect

to the conservation objectives of the site. Integrity is defined as: ‘the coherence of the site’s ecological

structure and function, across its whole area, or the habitats, complex of habitats and/or populations of

species for which the site is or will be classified’. Therefore, the integrity of a site is principally related

to the structure and function of the site with regard to its Annex I habitats and Annex II species listed as

the qualifying interests. The conservation status of these qualifying interests comprises the primary

conservation objectives for all designated Natura 2000 sites.

5.1 Direct impacts

5.1.1 Direct impacts during construction phase There are no direct impacts that may arise from the proposed works that would have the potential to

affect either the Lough Derg (Shannon) SPA or the Lower River Shannon SAC as all the proposed

works are located outside these Natura 2000 sites. Although some species listed under Annex II of the

habitat Directive may occur in the River Nenagh downstream, such as Atlantic Salmon, they are not

considered likely to occur in the Clareen stream into which the Arrabawn plant discharges. Therefore,

they do not have the potential to be directly impacted by the construction phase of the proposed works.

5.1.2 Direct impacts during operational phase

No direct operational phase impacts are likely to arise as the proposed works are located outside the

Natura 2000 network. Although some species listed under Annex II of the habitat Directive may occur

in the River Nenagh downstream, such as Atlantic Salmon, they are not considered likely to occur in

the Clareen stream into which the Arrabawn plant discharges. Therefore, they do not have the potential

to be directly impacted by the operational phase of the proposed works.

5.2 Indirect impacts

5.2.1 Indirect impacts during construction phase

Indirect (or secondary) impacts are defined as effects that are “caused by and result from the activity

although they are later in time or further removed in distance, but still reasonably foreseeable” (Bowers-

Marriott, 1997).

The main construction phase impacts that would arise during the proposed works would concern water

quality impacts. These impacts can arise from run-off of suspended solids and sediment from the

construction activities. Potential sources include erosion of exposed ground due to wind and rain, soil

compaction due to traffic and storage of stockpiles of soil, silt laden run-off from stockpiles of soil and

wheel-washing activities. Excavation works required as part of the construction works for drainage

channels, pipework and the construction of foundations may also lead to water quality impacts regarding

run-off. Oils and fuels required for machinery used during the construction phase lead to a potential of

spillages in addition to other polluting substances such as paints and sanitary waste. Any usage of

cement / uncured concrete on site may also lead to run-off and water quality impacts. As the Clareen

stream is located on the site, pollution from run-off, oils / fuels or cement / uncured concrete may enter

this watercourse, and subsequently, the Nenagh River.

Water quality impacts from the construction phase mentioned above could have a significant impact on

the Lough Derg (Shannon) SPA downstream and have the potential to impact the Wetland and

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Waterbirds habitat, and the bird species it supports, within the SPA, c. 12.5rkm downstream. During

construction works at the Arrabawn WwTP, there is a risk of an accidental release of effluent discharge

which could affect the SPA, specifically the wetland and waterbirds habitat in a worst case scenario.

Mitigation will be required. It is considered likely that potential water quality impacts arising from the

construction phase will be localized and short-term for the duration of the works. However, as mentioned

previously, the Atlantic Salmon population of the Lower River Shannon SAC are known to spawn in the

Nenagh River. Freshwater-feeding lampreys of Lough Derg and some of the Lower River Shannon SAC

population may also be present in the Nenagh River, and therefore, could be impacted by water quality

pollution.

The site visit completed for the current report revealed that the Clareen stream noted that this stream

was experiencing adverse water quality conditions on the day of the site visit. It is not known where the

source of this pollution is as there are several industrial discharges to the Clareen. As mentioned

previously, Conservation Services have carried out biological monitoring and habitat assessments at

two sites on the River Nenagh for the Arrabawn facility. In the 2019 survey, the biological data did not

indicate any deterioration in water quality between Site ASW1 (immediately upstream of the creamery

discharge) and Site ASW2 (immediately downstream of the creamery discharge); there is therefore no

evidence that the creamery is causing any deterioration in the biological water quality of the Nenagh

River according to Conservation Services (2019). Any water quality impacts from the construction phase

could lead to an impact on salmon and lampreys found in the Nenagh River downstream. As per Article

10, connectivity between Natura 2000 sites, specifically river systems, should also be considered.

Mitigation measures to protect water quality are required and are described in the mitigation measures

section of the current report.

It is noted that there is no potential for air quality impacts that could affect the Lough Derg (Shannon)

SPA due to distance, as discussed in the Screening Report (Appendix 1). It is clear from the results of

the modelling for Odour and NO2 emissions in the EIAR that these emissions will be below guideline

emission limit values (ELVs) following the completion of the proposed upgrade works.

5.2.2 Indirect impacts during operational phase

For the operational phase of the proposed development, there will be an increase in the volume of

effluent discharged to the Clareen stream in line with the emission limit values set out in the proposed

IED Licence (P0791-03). The upgrades proposed to the Arrabawn WwTP are required in order to

improve Arrabawn’s compliance with the EPA’s ELVs. As noted previously, adverse water quality

conditions were noted in the Clareen stream during the July visit. There are many other discharges into

this stream so the source of this is unknown. The operational phase is likely to bring an improvement

to water quality by upgrading the WwTP and resulting in an improvement in treatment of the effluent

from the plant. It is noted that Arrabawn has applied for a revision to the existing Industrial Emissions

Licence and that this NIS has been prepared in support of that licence review application. The proposed

future ELVs, compared with existing ELVs for the 2014-2016 monitoring period is given below in Table

1, as in Mott McDonald Screening in Appendix 1.

As indicated in Tables 3 and 4, there will be significant reductions in concentrations of BOD, Ammonia,

and Ortho-P in the discharge compared to the values indicated in Table 2 below. The assimilative

capacity calculation shows that ‘Good’ status EQS water will be achieved in the downstream receiving

waters for all parameters. In addition, the percentage headroom used by Arrabawn will be significantly

reduced for all parameters. It is noted that Conservation Services (2019) rated the Nenagh River as Q4

upstream and downstream of the Clareen stream confluence.

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Monitoring is carried out both upstream and downstream of the Clareen confluence with the Nenagh

River. Conservation Services, Ecological & Environmental Consultants, have carried out four

consecutive years of biological monitoring and habitat assessments at two sites on the River Nenagh

for the Arrabawn facility. The downstream site (ASW2) was located at R87413 79304 and the upstream

site was located at R87413 79304 (ASW1). Both sites were rated Q4 in 2016, Q3-4 in 2017 and Q4 in

2018. In the 2019 survey, the biological data did not indicate any deterioration in water quality between

Site ASW1 (immediately upstream of the creamery discharge) and Site ASW2 (immediately

downstream of the creamery discharge); there is therefore no evidence that the creamery is causing

any deterioration in the biological water quality of the Nenagh River according to Conservation Services

(2019).

There is no available data for ELVs in the Clareen stream.

The WwTP will be upgraded to achieve a higher standard of treatment, the current conditions will be

improved. It is noted that there are several other industrial discharges to the Clareen stream. Any water

quality issues in the Nenagh River downstream of the Clareen stream confluence would affect salmon

and lamprey populations in this river that are connected to the Lower River Shannon SAC. Similarly,

the Lough Derg (Shannon) SPA wetland and waterbirds habitat and the bird species it supports could

be potentially impacted by a deterioration in water quality. An improved standard of wastewater

treatment in the operational Arrabawn WwTP would be beneficial. Once the proposed ELVs set out in

the revised Industrial Emission Licence are achieved and remain the same, there would be no adverse

operational phase impacts on water quality.

Domestic foul effluent from the canteen building and changing/toilet block located near the Stafford

Street site boundary and from adjacent office/laboratory buildings is collected via an underground

gravity piped system. The system discharges to the existing public sewer which runs along Stafford

Street. This system will remain unchanged with the casein plant extension.

Surface water runoff will be generated from all surfaces within the main development site which are

exposed to rainwater. This includes all hardstanding surfaces, roofs and other impermeable surfaces.

The majority of hardstanding areas will drain by gravity to the existing / proposed surface water

collection system via kerbs and gullies. In general, surface water runoff results in relatively clean water.

However, as there is still the potential for impacts so basic mitigation will be provided for surface water.

Tables 2, 3 and 4 below provide the assimilative capacity calculations for the existing and proposed

licence emissions from combined process wastewater discharges at SW1 and SW2. These calculations

assume both peak flows and average flows (arising from the new WwTP upgrade).

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Table 1 Proposed Future ELVs for the Arrabawn WwTP Discharge (Nenagh River Values as per the

Industrial Emissions Licence Sampling Points).

Parameters SW1 (Old) SW1 (New) Commentary SW2 (Old) SW2 (New) Commentary

Maximum Daily

Rate

910m3 1250m3 Increase 2271 m3 3350 m3

(average)

4355 m3

(peak)

Increase

Temperature 25˚C (max) 25˚C (max) No change 25˚C

(max)

25˚C (max) No change

pH 6-9 6-9 No change 6-9 6-9 No change

BOD 7mg/l 7mg/l No change 20mg/l 10mg/l Reduction

Suspended

Solids

5mg/l 5mg/l No change Reduction

Orthophosphate 0.5 0.5 No change 1.0 0.5 Reduction

Total Ammonia

(as N)

1.0 1.0 No change 1.0 0.5 Reduction

Oils, Fats and

Greases

- - No change 10 5 Reduction

Table 2 Assimilative capacity calculations for existing licensed discharge at Arrabawn WwTP.

u/s river

conc

(2017)

SW1 SW2 Resultant

SW1 +

SW2

Good

status

limits

Headroom

available prior

to discharge **

% headroom

used by

discharge

Flow m3/s 0.524

(95%ile)

0.010532 0.0319*

Flow m/day 910 2271

BOD 0.6 7 20 1.811 2.6 2.1 61%

Ortho-P 0.0152 0.5 1 0.079 0.075 0.0598 108%

Total

Ammonia

0.0195 1 1 0.092 0.14 0.1205 61%

*Max licenced flow from SW2 in P0791-02 in 115m3/hr

**Difference in concentration between the background concentration and the EQS standard.

Table 3 Assimilative capacity calculations for proposed discharge (WwTP peak flow).

u/s river

conc.

(2016)

SW1 SW2 SW1 +

SW2

Good

Status

Limits

Headroom

available prior to

discharge

%

headroom used

by discharge

Flow m3/s 0.524 0.0144 0.050405

Flow m/day 1250 4355

BOD 0.6 7 10 1.5612 2.6 2.0 0.48

Ortho-P 0.0152 0.5 0.5 0.0685 0.075 0.598 0.89

Total

Ammonia

0.0195 1 0.5 0.0846 0.14 0.1205 0.54

*Source: Flow data for River Nenagh (station 25038 – upstream of the confluence with the Clareen stream) sourced

from the EPAs Hydronet website http://www.epa.ie/hydronet/#Water%20Levels

Water quality data sourced from EPA and is the mean concentration for 2015-2017 (based on 5 samples for each

of 3 years data.

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Table 4 Assimilative capacity calculations for Proposed Discharge (WwTP Average Flow).

u/s river

conc.

(2016)

SW1 SW2 SW1 +

SW2

Good

Status

Limits

Headroom

available prior to

discharge

%

headroom used

by discharge

Flow m3/s 0.524 0.0144 0.038773

Flow m/day 1250 3350

BOD 0.6 7 10 1.3911 2.6 2.0 0.40

Ortho-P 0.0152 0.5 0.5 0.0598 0.075 0.598 0.75

Total

Ammonia

0.0195 1 0.5 0.0762 0.14 0.1205 0.47

*Source: Flow data for River Nenagh (station 25038 – upstream of the confluence with the Clareen stream) sourced

from the EPAs Hydronet website http://www.epa.ie/hydronet/#Water%20Levels

Water quality data sourced from EPA and is the mean concentration for 2015-2017 (based on 5 samples for each

of 3 years data.

5.3 Cumulative impacts

Cumulative Impacts or effects are changes in the environment that result from numerous human-

induced, small-scale alterations. Cumulative impacts can be thought of as occurring through two main

pathways: first, through persistent additions or losses of the same materials or resource, and second,

through the compounding effects as a result of the coming together if two or more effects (Bowers-

Marriott, 1997).

As with indirect impacts, potential cumulative impacts that may affect the downstream Lough Derg

(Shannon) SPA and Lower River Shannon SAC concern water quality impacts in-combination with other

activities. The Nenagh WwTP discharges into the Nenagh River, c. 13.km downstream of the Clareen

stream confluence. A Licence examination report completed by the EPA in 2012 for the Nenagh WwTP

licence (D0027-01) concluded that BOD is compliant with the Surface Water Regulations (EPA, 2012),

but ammonia and ortho P emissions require a reduction in ELVs to be compliant with the Surface Water

Regulations (EPA, 2012). The most recent Inspectors report for the licence was completed in 2008,

which noted that the WwTP was in compliance with set emission limit values (EPA, 2008). It appears

from the information available that the Nenagh WwTP is adequately treating wastewater from Nenagh

town, and therefore, would not be having a negative impact on water quality in the Nenagh River.

Therefore, no cumulative impact on water quality would arise from the proposed development at

Arrabawn in-combination with the existing Nenagh WwTP.

A search of the Tipperary County Council online planning enquiry system was carried out on the 25th

July 2019. Finalised applications lodged in the vicinity of the Arrabawn plant, i.e. in the townlands of

Knockanpierce and Nenagh South within the last 5 years, were examined. Two projects related to

previous upgrades to the Arrabawn plant (Planning no.: 14520006 and 14600431) were lodged in 2014.

These works have been completed and are not considered further in relation to cumulative impacts.

Two applications were lodged in the townland of Knockanpierce within the last 5 years. These were for

extension of duration for a two-storey dwelling house (Planning Ref. no: 14520004), and for an

extension to an existing house, elevation alterations and modification to an existing entrance (Planning

Ref. no: 17600546). An application was also submitted and validated for the retention of demolition of

a derelict corridor (Planning Ref. no: 15600720), and permission for a change of use to an existing

building, and modifications to allow onsite parking and use of existing vehicular access, provision of

new signage; and all ancillary development works including provision of oil/petrol interceptor and use

of existing drainage infrastructure (Planning Ref. no: 17600515). These developments are small in

scale. Another application for a residential housing estate in Nenagh South was also submitted as a

new application in January 2019 (Planning Ref. no: 19600008). This site is located west of the Clareen

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stream and River Nenagh confluence. The Clareen stream is culverted underneath this site. There is

the potential for indirect water quality impacts to arise from run-off during the construction of the housing

estate. This could therefore act in-combination with impacts arising from the proposed development at

Arrabawn Co-Operative Society Ltd. Mitigation is required for the current Arrabawn proposal in order to

avoid cumulative impacts.

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6 MITIGATION MEASURES

Mitigation measures are proposed for the protection of the qualifying interests of the Lough Derg

(Shannon) SPA and the Lower River Shannon SAC. There is the potential for the proposed upgrade

works at Arrabawn Co-operative Society Ltd. to give rise to indirect and cumulative water quality impacts

affecting the qualifying interests of these Natura 2000 Sites; most notably Salmon and Lampreys as

part of the SAC and the Wetland and Waterbirds habitat for which the SPA is designated.

6.1 Construction Phase

The Construction Environmental Management Plan is provided in Appendix 2.

6.1.1 Water Quality Protection

The potential for disturbance works that expose soils and surface-water runoff will be mitigated for with

the placement of silt fences within the works area. Excavation works carried out adjacent to drainage

channels, access routes, or other potential pathways for water run-off will be minimised. Silt fences will

be placed on the outside of any excavation works area prior to the commencement of works, especially

in areas near the Clareen stream. Silt fences will be monitored regularly to ensure effectiveness.

Any oils or fuels that may be required for machinery required for the works will be stored appropriately

in the site compound to ensure no spillages occur. Any oiling or refuelling or machinery that may be

required will be carried out in designated bunded areas, only with appropriate safety precautions utilised

(drip-trays), at least 50m away from any watercourse or drain. Spill kits will be properly maintained near

working areas. Any and all spills / leaks will be cleaned up immediately. Equipment and machinery will

be regularly maintained, and any leaks will be repaired as soon as possible. If the equipment cannot be

repaired, it will be removed from the site.

As with any construction works, it is likely concrete / cement will be required. No concrete / cement

mixing will be carried out adjacent to any watercourse or drain. Mixing of concrete / cement will take

place within the site compound and any tool washing and any waste / grey water will be stored securely

behind bunded areas until its removal from the site.

Contained chemical portaloo toilets will be used on site during the construction phase. All sewage will

be appropriately removed from the site to an authorised treatment plant.

6.1.2 Biosecurity

As with any construction site, there is a risk of the spread or introduction of non-native invasive species.

Biosecurity measures will be followed for the construction phase and will follow the NRA Guidelines on

'The Management of Noxious Weeds and Non-Native Invasive Plant Species on National Roads' (NRA,

2010) and the IFI Guidelines 'Biosecurity Protocol for Field Survey Work' (IFI, 2010) as relevant.

6.2 Operational Phase

6.2.1 Water Quality

Surface water run-off from hard-standing areas (the new access road, internal roundabout, car-park

areas and the roof of the Packaging Store) will pass through a new proprietary Class 1 By-Pass

Separator directed to the Clareen stream. Surface water run-off from further areas around process plant

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buildings and around utility plant facilities, i.e. casein building, milk intake area and CIP wash areas, will

be collected via the site effluent drainage system to the existing site WWTP.

Chemicals and hydrocarbons will be stored in bunded areas at least 50m away from any watercourse

or drain. The capacity of the bunds will be a minimum of 110% of the volume of the largest container

stored therein. Where refuelling is to take place on site, it will be within a designated impermeable,

bunded area, at least 50m away from all drains. Any other potential sources of spillage (e.g. pumps,

sample points, level gauges etc) will be provided with local shelter and collection trays, sumps, or

interceptors as reasonably appropriate to contain any leaks / spillages. Routine monitoring and reporting

of tank maintenance and equipment integrity will continue to be carried out to ensure any potential leaks

are controlled.

Monitoring will continue to take place both upstream and downstream of the Nenagh River and will be

undertaken upstream and downstream on the Clareen stream. It should be noted that during the

summer months, the Clareen stream upstream of the Arrabawn facility is normally dry. The EPA will

also be provided with the results of this monitoring, as required.

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7 IMPACTS AFFECTING THE CONSERVATION OBJECTIVES OF THE

NATURA 2000 SITE

The overall aim of the Habitats Directive is to maintain or restore the favourable conservation status of

habitats and species of community interest. Favourable conservation status is defined for Annex I

habitats and Annex II species in the Habitat Directive (1992):

Article 1 (e)

Conservation status of a natural habitat means the sum of the influences acting on a natural

habitat and its typical species that may affect its long-term natural distribution, structure and

functions as well as the long-term survival of its typical species within the territory referred to in

Article 2.

The conservative status of a natural habitat will be taken as 'favourable' 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.

Article 1 (i)

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 within the

territory referred to in Article 2;

The conservation status will be taken as 'favourable' when: 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.

Favourable conservation status of a habitat is achieved when:

• its natural range, and area 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.

The favourable conservation status of a species is achieved when:

• 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 the Lough Derg (Shannon) SPA is given as a generic document

provided by the National Parks and Wildlife Service (NPWS, 2018). The conservation objectives for the

Lower River Shannon SAC are given as a site specific document by the National Parks and Wildlife

Service (NPWS, 2012). The current assessment utilises these conservation objective documents and

the national ‘Status of EU Protected Habitats and Species in Ireland’ report (NPWS, 2013a; NPWS,

2013b).

The proposed upgrade works to the Arrabawn Co-operative Society Ltd plant in Nenagh, Co. Tipperary

has been identified as having the potential to impact the wetland and waterbirds habitat, and the bird

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species it supports, for which the Lough Derg (Shannon) SPA is designated. The proposed

development has also been identified as having the potential to impact the Salmon and lamprey

populations in the River Nenagh which are connected with the Lower River Shannon SAC. The impacts

were identified as being impacts that would affect water quality, and therefore, affecting these Annex I

habitats and Annex II species in these Natura 2000 sites. Mitigation measures to protect water quality

are provided in the current report to avoid impacts affecting the qualifying interests of the Natura 2000

sites affected. The proposed upgrade works at Arrabawn will not affect the conservation objectives with

regard to the restoration of Annex I habitats and Annex II species to favourable conservation status,

once mitigation measures are followed.

The provisions of Article 6 of the ‘Habitats’ Directive 92/43/EEC (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’.

The proposed upgrade works at Arrabawn Co-operative Society Ltd. will comply with the required

mitigations to ensure that there will be no impacts arising which would have the potential to affect the

integrity of the Lough Derg (Shannon) SPA or the Lower River Shannon SAC.

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8 NIS CONCLUSION STATEMENT

The proposed upgrade works at the Arrabawn Co-operative Society Ltd plant in Nenagh, Co. Tipperary

are hydrologically connected to both the Lough Derg (Shannon) SPA and the Lower River Shannon

SAC. These two sites have the potential to be affected by the proposed upgrade works in Nenagh, Co.

Tipperary. A previous Screening for Appropriate Assessment Report was carried out for the proposed

works by Mott McDonald (Mott McDonald, 2018). The report concluded that there was no potential for

significant effects, on solely the Lough Derg (Shannon) SPA, as wastewater discharges from the plant

would be regulated by the EPA under Arrabawn’s Industrial Emissions licence.

Arrabawn are applying for a revision to the existing Industrial Emissions Licence (P0791-03) and the

EPA has requested that a Natura Impact Statement is prepared. The conclusion of the original pre-

assessment Screening relied on the industrial emissions licence revision and the regulation of

Arrabawn’s wastewaters by the EPA. It is understood that the EPA may consider this reliance to be

considered a mitigation. In case C-323/17 People Over Wind and Peter Sweetman v Coillte, the Court

of Justice of the European Union (CJEU) ruled that mitigation measures could not be taken into account

when undertaking a screening for Appropriate Assessment. If mitigation measures are required to

reduce or avoid a significant adverse effect, then Appropriate Assessment (Natura Impact Statement)

is required. Therefore, this NIS sets out mitigation for the proposed development.

The Lough Derg (Shannon) SPA is designated for a number of bird species and the Annex I Wetland

and waterbirds habitat that these bird species utilise. There is a hydrological connection between this

Natura 2000 site and the proposed upgrade works, via the Clareen stream and the River Nenagh. The

SPA is located c. 12.5 river km downstream

The Lower River Shannon SAC is also hydrologically connected to the proposed upgrade works,

although it is a considerable distance downstream, c. 34.5 river km. However, the Atlantic Salmon

population which come from the Lower River Shannon SAC are known to spawn in the Nenagh River.

Similarly, anadromous Sea Lampreys (and Lough Derg freshwater-feeding lampreys) could also

potentially use the Nenagh River. As above, water quality impacts may arise affecting the already

polluted Clareen stream, and the River Nenagh which it flows into.

Taking cognisance of potential impacts on the Natura 2000 network, mitigation measures have been

prepared for implementation on site to protect water quality. Water quality protection measures will be

implemented for the construction phase of the development: silt fences, on-site refuelling in bunded

areas at least 50m away from any watercourse or drain; minimise excavation works near any

watercourse or drain; the use of spill kits; any leaks will be cleaned up immediately; equipment and

machinery will be regularly maintained and if repairs are not possible, will be removed from site; no

concrete / cement mixing will be carried out adjacent to any watercourse or drain; any tool washing and

any waste / grey water will be stored securely behind bunded areas until its removal from the site;

contained chemical portaloos toilets will be used and all sewage will be appropriately removed from the

site to an authorised treatment plant. Biosecurity guidelines will be followed on site.

Surface water run-off from hard-standing areas (the new access road, internal roundabout, car-park

areas and the roof of the Packaging Store) will pass through a new proprietary Class 1 By-Pass

Separator directed to the Clareen stream. Surface water run-off from further areas around process plant

buildings and around utility plant facilities, i.e. casein building, milk intake area and CIP wash areas, will

be collected via the site effluent drainage system to the existing site WWTP. Impermeable bunded areas

will also be used for the operational phase for refuelling and storage. Routine monitoring will also

continue to be carried out. The proposed upgrade works are not considered to have the potential to

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adversely affect the conservation objectives of the Lough Derg (Shannon) SPA or the Lower River

Shannon SAC once mitigation measures are followed.

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’. The mitigation

measures proposed are considered to be sufficient to ensure that potential impacts regarding water

quality are minimised. From the evidence presented in the current assessment, it is concluded that the

potential indirect and cumulative impacts that may arise from the proposed upgrade works at Arrabawn

Co-operative Society Ltd. in Nenagh, Co. Tipperary do not have the potential to affect the integrity of

either the Lough Derg (Shannon) SPA or the Lower River Shannon SAC.

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Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.

https://www.npws.ie/sites/default/files/protected-sites/conservation_objectives/CO002165.pdf

NPWS (2013a). The Status of EU Protected Habitats and Species in Ireland. Habitat Assessments

Volume 2. Version 1.1. Unpublished Report, National Parks & Wildlife Service. Department of Arts,

Heritage and the Gaeltacht, Dublin, Ireland.

https://www.npws.ie/sites/default/files/publications/pdf/Article_17_Print_Vol_2_report_habitats_v1_1_

0.pdf

NPWS (2013b). The Status of EU Protected Habitats and Species in Ireland. Species Assessments

Volume 3. Version 1.0. Unpublished Report, National Parks & Wildlife Service. Department of Arts,

Heritage and the Gaeltacht, Dublin, Ireland.

https://www.npws.ie/sites/default/files/publications/pdf/Article_17_Print_Vol_3_report_species_v1_1_

0.pdf

NPWS, (2018). Conservation Objectives for the Lough Derg (Shannon) SPA [004058]. Generic Version

6.0. Department of Culture, Heritage and the Gaeltacht.


NRA, (2010). Guidelines on the Management of Noxious Weeds and Non-native Invasive Plant Species

on National Roads. National Roads Authority, St Martin's House, Waterloo Roads, Dublin 4.

https://www.tii.ie/technical-services/environment/construction/Management-of-Noxious-Weeds-and-

Non-Native-Invasive-Plant-Species-on-National-Road-Schemes.pdf

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https://www.fisheriesireland.ie/documents/73-biosecurity-protocol-for-field-survey-work-1/file.html

http://ec.europa.eu/environment/nature/ecosystems/docs/adaptation_fragmentation_guidelines.pdf


https://www.npws.ie/sites/default/files/publications/pdf/Article_17_Print_Vol_2_report_habitats_v1_1_0.pdf

https://www.npws.ie/sites/default/files/publications/pdf/Article_17_Print_Vol_2_report_habitats_v1_1_0.pdf

https://www.npws.ie/sites/default/files/publications/pdf/Article_17_Print_Vol_3_report_species_v1_1_0.pdf

https://www.npws.ie/sites/default/files/publications/pdf/Article_17_Print_Vol_3_report_species_v1_1_0.pdf


https://www.tii.ie/technical-services/environment/construction/Management-of-Noxious-Weeds-and-Non-Native-Invasive-Plant-Species-on-National-Road-Schemes.pdf

https://www.tii.ie/technical-services/environment/construction/Management-of-Noxious-Weeds-and-Non-Native-Invasive-Plant-Species-on-National-Road-Schemes.pdf


_________________________________________________________________________________

www.ecofact.ie 34

PLATES

Plate 1 The Nenagh River upstream of the Clareen stream confluence.

Plate 2 The Nenagh River at its confluence with the Clareen stream.

Plate 3 The Clareen stream just upstream of the Nenagh River confluence. There is a deep layer of silt present at this location.

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www.ecofact.ie 35

Plate 4 The Clareen stream is overgrown with dense instream vegetation and is heavily silted.

Plate 5A (23/07/19) The Clareen stream as it leaves the culverted section, before flowing into the River Nenagh.

Plate 5B (07/08/19) The Clareen stream as it leaves the culverted section, before flowing into the River Nenagh, approximately 2 no. weeks after Plate 5A was recorded.

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www.ecofact.ie 36

Plate 6 The Clareen stream in July 2019. Water quality issues are apparent in this photo. The source of this pollution is unknown and there are many discharges into the Clareen stream.

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www.ecofact.ie 37

APPENDIX 1 SCREENING FOR APPROPRIATE ASSESSMENT REPORT

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Arrabawn Co-operativeSociety: Production UpgradeScreening for Appropriate Assessment

29 May 2018

Arrabawn

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229100043 01 Ahttps://mottmac.sharepoint.com/teams/pj-a483/do/Documents/Screening for AppropriateAssessment/229100043 - Screening for Appropriate Assesment.docxMott MacDonald

Mott MacDonald5 Eastgate AvenueEastgateLittle IslandCo Cork T45 EE72Ireland

T +353 (0)21 480 9800mottmac.com

ArrabawnSociaety Limitedc/o Bord Gais Energy Ltd,1st FloorBuilding 6900,Stafford Street,Nenagh,County Tipperary

Arrabawn Co-operativeSociety: Production UpgradeScreening for Appropriate Assessment

29 May 2018

Directors: C O’Donovan BE MBA CEngMIET (Managing), J T Murphy BEHDipMM CEng FIEI CMCILT (DeputyManaging), D Herlihy BE MSc CEng, KHowells BSc MBA CEng MICE MCIWEM(British), F McGivern BSc DipEnvEngCEng MIEIInnealtoirí Comhairleach (ConsultingEngineers)Company Secretary: Ian Kilty BA (Hons)ACARegistered in Ireland no. 53280. MottMacDonald Ireland Limited is a member ofthe Mott MacDonald Group

Arrabawn

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Mott MacDonald | Arrabawn Co-operative Society: Production UpgradeScreening for Appropriate Assessment

229100043 | 01 | A | 29 May 2018https://mottmac.sharepoint.com/teams/pj-a483/do/Documents/Screening for Appropriate Assessment/229100043 - Screening for AppropriateAssesment.docx

Issue and Revision Record

Revision

Date Originator Checker Approver Description

A 29/05/2018 E. Johnston / A.Sands

R. Mansfield P. Kelly For Client Review

Document reference: 229100043 | 01 | A

Information class: Standard

This document is issued for the party which commissioned it and for specific purposes connected with the above-captioned project only. It should not be relied upon by any other party or used for any other purpose.

We accept no responsibility for the consequences of this document being relied upon by any other party, or being usedfor any other purpose, or containing any error or omission which is due to an error or omission in data supplied to us byother parties.

This document contains confidential information and proprietary intellectual property. It should not be shown to otherparties without consent from us and from the party which commissioned it.

This Re por t has be en p rep are d solely for use by t he p arty w hich c om mission ed it (the 'Client') i n co nnecti on wit h the cap tione d p roject . It s hould not be used for any oth er p urp ose. N o p erso n ot her tha n th e Client or any party who has expr essly a gre ed t er ms of relia nce wit h us (the 'Recipie nt(s )') m ay r ely on the cont ent, info rma tion or any view s exp ress ed in the R epo rt. This R epo rt is co nfide ntial and c ont ains p rop riet ary in tellect ual p rop erty and we ac cept no duty of ca re, resp onsibility or li ability t o any oth er recipi ent o f this R epo rt. N o re pre sent ation , wa rran ty o r un dert aking , exp ress or i mplie d, is made an d no res ponsi bility or liability is acce pted by us to any p arty oth er t han the Cli ent or a ny Reci pient (s), as t o the accu racy or c om plete ness of th e info rm ation cont aine d in t his Rep ort. Fo r t he av oida nce o f do ubt t his Re port do es no t in any way pu rpo rt to includ e a ny leg al, ins ura nce or fin ancial advic e or opini on.

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Mott MacDonald | Arrabawn Co-operative Society: Production UpgradeScreening for Appropriate Assessment


Contents

1 Introduction 71.1 Context 7

1.1.1 Appropriate Assessment and Planning 7

2 Description of Project 92.1 Project Overview 9

2.1.1 Casein Processing Building 92.1.2 Entranceway 92.1.3 Wastewater Treatment Plant 102.1.4 Construction compounds 11

2.2 Connectivity to European Sites 122.3 Assessment of Likely Effects 162.4 Plans and Projects Which Might Act in Combination 18

3 Assessment of Significance 193.1 Summary 19

4 Screening Statement 204.1 Summary 20

5 References 21

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Mott MacDonald | Arrabawn Co-operative Society: Production Upgrade 7Screening for Appropriate Assessment


1 Introduction

1.1 ContextArrabawn Co-operative Society Limited (hereafter referred to as ‘Arrabawn’) is a dairyprocessing plant located in Nenagh, Co. Tipperary. The plant operates on a 24-hour basisprocessing circa 50 million gallons of milk per annum. The product range from the plant includesskim milk powder, whey powder products, casein and caseinate products and butter. The siteon which the plant is located is split into three sections, the office block, the casein processingplant and the wastewater treatment plant (WWTP).

Arrabawn is proposing upgrade works which will comprise an extension to its casein processbuilding and the installation of new plant and equipment within the existing WWTP site. It is alsoproposed to provide a new vehicular / pedestrian access via the existing roundabout on KenyonStreet and to provide new internal access routes for incoming and outgoing heavy goodsvehicles (HGVs). These upgrade works are required in order to facilitate an expected increasein milk production which would result in peak milk intake increasing from 1.6m litres to 2.4mlitres and an overall increase in production to approximately 500,000,000 litres.

Further details on the project subject to Screening for Appropriate Assessment are included inSection 2.

1.1.1 Appropriate Assessment and Planning

In accordance with the requirements of the Habitats Directive (92/43/EEC) and the BirdsDirective (2009/147/EC), Member States have identified a network of sites of conservationimportance, hosting habitats and/or species identified in the Directives as needing to be eithermaintained at or returned to favourable conservation status. These sites are known as theNatura 2000 network of European Sites and in Ireland, European Sites comprise areasdesignated as Special Areas of Conservation (SACs), candidate Special Areas of Conservation(cSACs), Special Protection Areas (SPAs) and candidate Special Protection Areas (cSPAs).

These Directives require that where a project is likely to have a significant effect on a EuropeanSite, while not directly connected with or necessary to the nature conservation management ofthe site, it shall be subject to ‘Appropriate Assessment’ to identify any implications for the site inview of the site's conservation objectives1. Specifically, Article 6(3) of the Habitats Directivestates:

“Any plan or project not directly connected with or necessary to the management of the site butlikely to have a significant effect thereon, either individually or in combination with other plans orprojects, shall be subject to appropriate assessment of its implications for the site in view ofthe site’s conservation objectives. In the light of the conclusions of the assessment of theimplications for the site and subject to the provisions of paragraph 4, the competent nationalauthorities shall agree to the plan or project only after having ascertained that it will notadversely affect the integrity of the site concerned and, if appropriate, after having obtained theopinion of the general public”.

1 The NPWS is currently developing Conservation Management Plans for all SACs nationally. Objectives for theconservation of the features of interest for which the site is designated are set out in the Conservation ManagementPlans and the principal pressures impacting the achievement of Favourable Conservation Status are identified.Strategies to meet the objectives are also identified.

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The proposed upgrade works are not associated with the ‘management’ of a European Sitehaving regard to Article 6 of the Habitats Directive. Therefore, the project is not directlyconnected with or necessary to the management of any European Site and must undergoscreening for Appropriate Assessment in accordance with Regulation 42(1) of the EuropeanCommunities (Birds and Natural Habitats) Regulations 2011.

This report is to inform the screening for Appropriate Assessment. The intention of thisreport is to assist the Competent Authority (Tipperary County Council) in determining whetherthe proposed project is likely to have a significant effect on a European Site either alone or incombination with other plans or projects. Where significant effects are determined to be likelythe proposed project is statutorily required to be subjected to Appropriate Assessment.

This report for screening for Appropriate Assessment has been carried out in accordance withthe following European Commission and National Guidance:

● EC (2000) ‘Managing Natura 2000 Sites: The provisions of Article 6 of the ‘Habitats’Directive 92/43/EEC’;

● 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 Directive92/43/EEC’; and

● DEHLG (2010) Appropriate Assessment of Plans and Projects in Ireland Guidance forPlanning Authorities.

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2 Description of Project

2.1 Project OverviewThe existing Arrabawn Plant comprises an office site, a casein processing building and aWWTP all located in close proximity to each other. Upgrade works are required at the caseinprocessing building and WWTP. It is also proposed to provide a new vehicular / pedestrianaccess via the existing roundabout on Kenyon Street and to provide new internal access routesfor incoming and outgoing heavy goods vehicles (HGVs). No upgrade works are proposed atthe office site.

A description of the proposed upgrade works is presented hereunder.

2.1.1 Casein Processing Building

The existing casein processing building is located adjacent to the south-eastern boundary of theArrabawn site (refer Planning Application Drawing 118004-11). The building is approximately 43metres in length by 18.3 metres in width providing a building footprint of approximate area790m2. The current casein processing building has the capability of producing 1.2 tons of acidcasein powder from approximately 34,000 litres of milk per hour. The proposed developmentaims to double this capacity by installing a similar scale plant adjacent to the existing building. Itis proposed to extend the existing casein processing building to accommodate the new plant.

Two extensions to the existing casein processing building are proposed to accommodate thenew casein processing plant. These are labelled extension No. 1 and extension No. 2 on referPlanning Application Drawing 118005-02. The proposed upgrade works will require the removalof five derelict buildings and a treeline.

2.1.2 Entranceway

In addition to proposals to upgrade its casein processing plant to cater for increasing volumes ofmilk from its suppliers, Arrabawn is proposing the construction of a new vehicular access fromKenyon Street roundabout which will replace the existing access on Stafford Street. The existingStafford Street access will be reduced in width and maintained for emergency access only whilethe existing access at the west end of the site will be retained for emergency exit only. Theseworks will facilitate the implementation of a complete one-way traffic loop system within the milkprocessing site.

To facilitate the new entrance development, upgrade works will be carried out to the existingroundabout on Kenyon Street. These will include construction of a revised roundabout layout.To facilitate this entranceway, two derelict buildings, two storage sheds, and a truck wash willbe removed. In addition to the new entranceway it is proposed to construct:

● Two new car parks to replace existing car parks within the footprint of the works● A lorry wash area,● A two-lane CIP/Wash area● Two weigh bridges● A security booth

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● A three-lane milk intake area● Internal roadways● Internal drainage● Landscaping

The drainage within the new entranceway and associated buildings will tie in to the existingdrainage scheme. Wastewater from the lorry wash areas, and the CIP/Wash area will enter theWWTP prior to discharge into the Clareen stream.

2.1.3 Wastewater Treatment Plant

Process wastewater discharges are regulated by the EPA under Arrabawn’s IndustrialEmissions Licence (P0791-02). Wastewaters consist of the following:

● Cooling water and condensate from evaporators; (monitored by the EPA at SW1); and● Treated effluent from waste water treatment plant as (monitored by the EPA at SW2).

In order to facilitate the proposed production increase, there is also a need to upgrade theWWTP. The future hydraulic design load for the WWTP is:

● 1250m3/d (max) at SW1;● 3,350m3/d (average) at SW2;● 4,355m3/d as peak (factor of 1.3 x average) at SW2; and● 220m3/h = 61 l/s (as 1/20 of peak day).

Arrabawn is applying for a revision to its existing Industrial Emission Licence (P0791-02) fromthe Environmental Protection Agency for the following discharge parameters and emission limitvalues:

Table 1: Wastewater Parameters and Emission Limit ValuesParameter Emission Limit ValueFlow 1250m3/d (max) at SW1

4,335m3/d (max) at SW2

BOD 10mg/l

SS 15mg/l

PO4-P 0.5mg/l

NH4-N + NH3-N 0.5mg/l

FOG 5mg/l

It is proposed to modify and reconfigure the existing WWTP and to install the following newplant and equipment within the boundaries of the existing WWTP to achieve compliance withthe above emission limit values. The proposed modified/new plant are:

● Conversion of aeration tanks to emergency holding tanks;● Modifications to the Dairy Balance tank;● Provision of new DAF unit● Modifications and reconfiguration of existing Anoxic tank and Aeration tank (AS3);● Provision of new Aeration Tank (AS4);● Conversion of existing secondary settlement tank to Inter-stage settlement;● Final settlement tank;● Provision of additional sludge thickening tank; and

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● Extension of the sludge dewatering building and installation of new dewatering centrifuge.

The flow profile for the proposed WWTP following the upgrade works is shown schematically inFigure 1. Further detail is provided in the following sections.

Figure 1: Schematic Profile for the Upgraded WWTP at Arrabawn

Source: Mott MacDonald

2.1.4 Construction compounds

A temporary contractor’s compound to facilitate construction of the extensions/upgrade to thecasein processing building is proposed to be located within the Mart site adjoining Arrabawnand in close proximity to the casein building location. It is also proposed to provide a temporary

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car park for construction site staff workers within the Mart site. The provision of both facilitieshas been agreed by Arrabawn with the management of the Mart facility.

A temporary contractor’s compound to facilitate construction of the new entrance and works toKenyon Street roundabout is proposed to be located within the area of the proposed new carpark located adjacent to Stafford Street. It is proposed that works to the milk intake andCIP/truck wash areas, security control building and internal car park will be facilitated from thiscompound area also. It is envisaged that the compound can be maintained at this location untilall these works are complete. It is envisaged at that stage that contractor car parking couldmove to the new central car park area to facilitate completion of the main car park, internalroundabout and closing down of the existing entrance from Stafford Street.

2.2 Connectivity to European SitesEuropean Sites functionally connected2 to the Arrabawn Plant were identified using GISsoftware. As an initial approach, all European Sites within 15km of the Arrabawn Plant wereidentified (as per DoEHLG guidance, 2010). With the exception of hydrological connectivity, theGIS assessment determined no other European Sites beyond this 15km radius with connectivityto the project.

All European Sites located within 15km of the project are shown in Figure 2. Table 1 identifiesall European Sites with connectivity to the project and shows the distance between theEuropean Sites and the project. The qualifying features/special conservation interests of theEuropean Sites are also identified and the functional connectivity is presented.

2 Land “functionally connected with a European Site”, as defined in the European Communities (Birds and Natural Habitats) Regulations2011, means land connected with a site by air, soil, hydrology, geology, ecology or water (including surface water, groundwater andmarine water).

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Figure 2: European sites within 15km of the proposed development site

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Table 2: European Sites within 15km of the proposed upgrade works at the ArrabawnPlantSite Name and Code Distance

toproposedworks

Qualifying Interest/ SpecialConservation Interest

Functional Connectivity

Special Areas of Conservation (SAC)Silvermines mountains SAC(000939)

8km ● Northern Atlantic wet heaths with Ericatetralix [4010]

● Species-rich Nardus grasslands, onsiliceous substrates in mountain areas(and submountain areas, in ContinentalEurope) [6230]

The SAC is designated for two terrestrialhabits, no hydrological connectivity existsbetween the qualifying features and theproposed development site.Due to the distance there is no potentialfor dust associated impacts to thequalifying features.There is no physical or ecologicalconnectivity between the SAC and theproposed development site.No functional connectivity exists betweenthe SAC and the proposed developmentsite. There is therefore no potential forimpact.

Silvermines MountainsWest SAC (002258)

8.7km ● Northern Atlantic wet heaths with Ericatetralix [4010]

● European dry heaths [4030]● Calaminarian grasslands of the

Violetalia calaminariae [6130]

The SAC is designated for three terrestrialhabits, no hydrological connectivity existsbetween the qualifying features and theproposed development site.Due to the distance there is no potentialfor dust associated impacts to the habitats.There is no physical or ecologicalconnectivity between the SAC and theproposed development site.No functional connectivity exists betweenthe SAC and the proposed developmentsite. There is therefore no potential forimpact.

Bolingbrook Hill SAC(002124)

9.2km ● Northern Atlantic wet heaths with Ericatetralix [4010]

● European dry heaths [4030]● Species-rich Nardus grasslands, on

siliceous substrates in mountain areas(and submountain areas, in ContinentalEurope) [6230]

The SAC is designated for three terrestrialhabits, no hydrological connectivity existsbetween the qualifying features and theproposed development site.Due to the distance there is no potentialfor dust associated impacts to the habitats.There is no physical or ecologicalconnectivity between the SAC and theproposed development site.No functional connectivity exists betweenthe SAC and the proposed developmentsite. There is therefore no potential forimpact.

Lough Derg, North-eastShore SAC (002241)

11km ● Juniperus communis formations onheaths or calcareous grasslands [5130]

● Calcareous fens with Cladium mariscusand species of the Caricion davallianae[7210]

● Alkaline fens [7230]● Limestone pavements [8240]● Alluvial forests with Alnus glutinosa and

Fraxinus excelsior (Alno-Padion, Alnionincanae, Salicion albae) [91E0]

● Taxus baccata woods of the British Isles[91J0]

Hydrological connectivity identifiedbetween the SAC and the proposeddevelopment site via the Clareen streamand the River Nenagh. The qualifyingfeatures designated within the SAC areterrestrial habitats which lack connectivityto Lough Derg. There is therefore nohydrological connectivity to the qualifyingfeatures within the SAC.Due to the distance there is no potentialfor dust associated impacts to the SAC.There is no physical or ecologicalconnectivity identified between the SACand the proposed development site.

No functional connectivity exists between

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Site Name and Code Distancetoproposedworks



the SAC and the proposed developmentsite. There is no potential for impact.

Lower River Shannon SAC(002165)

11km ● Sandbanks which are slightly coveredby sea water all the time [1110]

● Estuaries [1130]● Mudflats and sandflats 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 fluitantisand Callitricho-Batrachion vegetation[3260]

● Molinia meadows on calcareous, peatyor clayey-silt-laden soils (Molinioncaeruleae) [6410]

● Alluvial forests with Alnus glutinosa andFraxinus excelsior (Alno-Padion, Alnionincanae, Salicion albae) [91E0]

● Margaritifera margaritifera (FreshwaterPearl Mussel) [1029]

● Petromyzon marinus (Sea Lamprey)[1095]

● Lampetra planeri (Brook Lamprey)[1096]

● Lampetra fluviatilis (River Lamprey)[1099]

● Salmo salar (Salmon) [1106]● Tursiops truncatus (Common

Bottlenose Dolphin) [1349]● Lutra lutra (Otter) [1355]

The proposed development site ishydrologically connected to the SAC viathe Clareen stream, the River Nenagh,Lough Derg and the River Shannon(hydrological route ca.30km). However,considering the distance of thehydrological route and volume of LoughDerg, coupled with the temporary workswhich will occur within the developmentsite, no impacts to the SAC areanticipated.Due to the distance there is no potentialfor dust or noise associated impacts to theSAC. No ecological or physicalconnectivity identified between the SACand the proposed development site.

No functional connectivity exists betweenthe SAC and the proposed developmentsite. There is therefore no potential forimpact.

Keeper Hill SAC (001197) 11km ● Northern Atlantic wet heaths with Ericatetralix [4010]

● Blanket bogs (* if active bog) [7130]

The SAC is designated for two terrestrialhabits, no hydrological connectivity existsbetween the qualifying features and theproposed development site.Due to the distance there is no potentialfor dust associated impacts to the SAC.

No functional connectivity exists betweenthe SAC and the proposed developmentsite. There is therefore no potential forimpact.

Special Protection Areas (SPA)Lough Derg (Shannon) SPA(004058)

7.5km ● Cormorant (Phalacrocorax carbo)[A017]

● Tufted duck (Aythya fuligula) [A061]

Hydrological connectivity identified via theClareen stream and the River Nenagh.The hydrological route is approximately13km long. There is potential for water

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Site Name and Code Distancetoproposedworks



● Goldeneye (Bucephala clangula) [A067]● Common tern (Sterna hirundo) [A193]● Wetland and waterbirds [A999]

quality impacts.Due to the distance there is no potentialfor dust or noise associated impacts to theSAC.Functional hydrological connectivityexists between the SPA and theproposed development site.

Slievefelim to SilverminesMountains SPA (004165)

8.5km ● Hen harrier (Circus cyaneus) [A082]● Merlin (Falco columbarius) [A098]

No hydrological connectivity existsbetween the SPA and the proposeddevelopment site.Due to the distance there is no potentialfor dust or noise associated impacts to theSPA.

No functional connectivity exists betweenthe SPA and the proposed developmentsite. There is therefore no potential forimpact.

Source: NPWS Conservation Objectives (Downloaded 13/03/2018)

2.2.1.1 Summary

As per Table 1, functional hydrological connectivity exists between the proposed developmentsite and Lough Derg (Shannon) SPA (004058).

2.3 Assessment of Likely Effects

The elements of the project that that have the potential to cause environmental impact areidentified in Table 3 in accordance with the European Commission Guidance (2001).

Table 3: Elements of the project with the potential to cause environmental impactCharacteristics DetailsPhysical changes thatwill arise due to theproject

● The Arrabawn site is not located within any European site.● The works within the existing milk processing plant (i.e. the extension to the Casein

building, and the new entranceway) are located within the existing site and theexisting roadway directly adjacent to the site. The milk processing plant consistslargely of hard standing areas. Outside of the hardstanding areas the site containsareas of amenity grassland, dry meadows and grassy verges, recolonising bareground, spoil and bare ground, and several treelines.

● The existing WWTP comprises buildings and artificial surfaces, spoil and bare ground,amenity grassland with treeline, hedgerow and palisade fence boundaries. TheClareen stream runs inside the eastern boundary of the WWTP before it is culvertedbeneath the milk processing plant for 1.2km before discharging into the Nenagh River.The works will largely take place within the existing site in the WWTP boundary.Works outside of the existing plant will be to facilitate two new tanks; the clarifier andthe aeration tanks. These tanks will be placed within the amenity grassland. No worksare required within the Clareen stream.

● There will be no requirement for land take outside of these areas.

Resource requirements ● There are no resource requirements for the proposed works. The upgrade works arewithin existing development lands.

Emissions and waste Construction Phase● Construction activities will cause a short-term localised increase in noise levels. Lough

Derg (Shannon) SPA is designated for four wetland bird species. The SPA is located7.5km (straight line measurement) from the proposed development site. The proposedworks are also buffered from the SPA by Nenagh town and a wide expanse of

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Characteristics Detailsfarmland. Given the nature and scale of the proposed works, and the considerabledistance to the SPA, there will be no impact as a result of noise during construction.

● The proposed construction works will include excavation activities. Excavated soil willeither be reinstated at the site or removed from site in accordance with WasteLegislation. Excavation works may result in the temporary generation of dust in thelocality of the works area. The Institute of Air Quality Management ‘Guidance on theAssessment of dust from demolition and construction (Holman et al, 2014) prescribespotential dust emission risk classes to ecological receptors. The guidelines specifythat receptor sensitivity is ‘High’ up to 20m from the source and reduces to ‘Medium’at 50m from the source. Dust may also be generated from trackout due to heavy dutyvehicle (HDV) movements from the site entrance. Trackout from the site wasdetermined as ‘Medium’ (10-50 HDV (>3.5t) outward movements in any one day)which equates to trackout occurring up to 50-100mm from the site. The spatial limit ofdust impacts is therefore determined as 100m from the proposed works area. LoughDerg SPA is located 7.5km (straight line measurement) from the proposed worksarea. Lough Derg SPA therefore occurs outside the spatial limit for impact via dust asdefined above. There is therefore no potential for impact to the European site as aresult of dust during construction.

● The proposed construction works will be located adjacent to the Clareen stream.Hydrological connectivity was identified between the Arrabawn Plant and Lough DergSPA (13km hydrological route) and Lough Derg north-east SAC (18km hydrologicalroute), via the Clareen stream and the Nenagh River. The Clareen stream andNenagh River form part of the Lower Shannon catchment (WFD catchment 25C)which covers an area of 1820.5km2. In the event that sedimentation and/or runoffoccurs and reaches the stream, water quality impacts are likely to be localised. Giventhe distance of the hydrological route between the Arrabawn Plant and Lough DergSPA, the size of the receiving catchment, and the localised, and temporary nature ofthe works, water quality impacts on the European site is extremely unlikely.

Operational Phase● During the operation of the Arrabawn Plant, the facility will be in keeping with the EPA

Limits (Daytime – 55dB LAr, T, Evening – 50dB LAr,T and Nigh-time 45dB LAeq, T).There will be no increase of staff onsite following the proposed upgrade works. Therewill therefore be no change to the existing background noise levels. No significantimpacts of noise on the surrounding environment are therefore envisaged during theoperational phase.

● The main source of lighting in the Arrabawn Plant is mercury and sodium energyefficient lighting. The offices are lit with fluorescent tubes. Lighting will be upgradedon a phased basis to LED lighting. There will therefore be no change to the existingprojection of light during the operation of the plant.

● The WWTP currently discharges into the Clareen stream which runs along the easternboundary of the site. The Clareen stream is listed as having a “moderate” ecologicalstatus by the EPA. The Clareen stream flows into the Nenagh River approximately 1.2km (straight line) downstream before flowing into the Lough Derg approximately 13kmdownstream. The Nenagh River is also currently listed as having a “moderate”ecological status by the EPA. Conservation Services, Ecological & EnvironmentalConsultants were commissioned by Arrabawn Co-Operative Creamery in 2017 toundertake biological sampling and water quality assessment in accordance with EPAQ-Rating methodology at two locations on the Nenagh River. Samples were takenabove and below the point at which the Clareen stream meets the Nenagh River. Thesurvey report concludes that there was no evidence that Arrabawn was causing anydeterioration in the biological water quality of the Nenagh River (Quirke and Twomey2017) 3.The proposed upgrade works will result in an increase in discharge into the ClareenStream. Assimilative capacity calculations carried out for the proposed upgrade indicatethat there will be a reduction in concentrations of BOD, Ammonia, and Ortho-P in thedischarge. The assimilative capacity calculation also shows that ‘Good’ status EQS(Environment Quality Standard) water will be achieved in the downstream receivingwaters. There is therefore no potential for the upgrade works to impact the water quality

3 Quirke, B., Twomey, H., (2017). Arrabawn Co-operative creamery, Nenagh, County Tipperary. Biological Assessment of Surface WaterQuality.

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Characteristics Detailsof the Clareen Stream during the operational phase. There is therefore no potential forwater quality impacts on Lough Derg SPA as a result of operational emissions.

● There will be no change in casein production levels as a result of the proposedextension to the casein building. The drainage from the casein building, from the truckwashes and surface water drainage from the car parks will tie into the existingdrainage network. Waste water from the truck washes will enter the WWTP.

Transportationrequirements

● Traffic management and traffic diversions will be necessary during works to facilitatethe alterations to the R498.

Duration of construction,operation,decommissioning, etc.

● It is expected that construction will commence in Q1 of 2019. The constructionactivities from initial mobilisation to substantial completion is estimated to be 12months. The total number of construction staff will vary but is expected to peak atapproximately 80 persons.

2.4 Plans and Projects Which Might Act in CombinationArticle 6(3) of the Habitats Directive requires that:

‘Any plan or project not directly connected with or necessary to the management of the site butlikely to have a significant effect thereon, either individually or in combination with otherplans or projects, shall be subject to appropriate assessment of its implications for the site inview of the site’s conservation objectives.’

It is therefore required that the potential impacts of the proposed works are considered incombination with any other relevant plans or projects. A search of the Tipperary County Councilplanning enquiry system (http://www.eplanning.ie/TipperaryCC/searchtypes) was carried out(March 2018). Finalised applications lodged in the vicinity of the Arrabawn plant, i.e. in thetownlands of Knockanpierce and Nenagh South within the last 5 years were examined. Twoprojects relating to previous upgrades to the Arrabawn plant (Planning no: 14520006 and14600431) were lodged in 2014. These works have been completed and so are not consideredfurther.

Two applications were lodged in the townland of Knockanpierce within the last 5 years. Thesewere for extension of duration for a two-storey dwelling house (Planning no: 14520004), and foran extension to an existing house, elevation alterations and modification to an existing entrance(Planning no: 17600546). A single application in Nenagh South, outside of the previouslymentioned Arrabawn plant upgrades, was lodged in the last 5 years. This was for retention ofdemolition of a derelict corridor, and permission for a change of use to an existing building, andmodifications to allow onsite parking and use of existing vehicular access, provision of newsignage; and all ancillary development works including provision of oil/petrol interceptor and useof existing drainage infrastructure. These developments are small in scale. Given that noimpacts were identified for the proposed upgrade works to the Arrabawn plant, and the distanceto European sites, there can be no cumulative impacts as a result of these works.

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3 Assessment of Significance

3.1 Summary

No impacts to Lough Derg SPA (004058) from the proposed upgrade works have beendetermined. There is therefore no potential for significant effects on the conservation objectivesof the European site.

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4 Screening Statement

4.1 SummaryThe current assessment investigates the potential for significant effects on the specialconservation interests of the Lough Derg (Shannon) SPA (004058) arising from the proposedupgrades to the Arrabawn plant. The assessment considers whether the proposeddevelopment, alone or in combination with other projects or plans, will have significant effects ofthe European sites.

It is concluded that there is no potential for significant effects on Lough Derg (Shannon) SPA(004058) from the proposed works, either alone or in-combination with other plans and/orprojects. The findings of this report for screening for Appropriate Assessment are summarised inthe Findings of no Significant Effects Matrix in Table 4 and are presented to aid the CompetentAuthority in their screening assessment.

Table 4: Findings of No Significant Effects MatrixName of project or plan Arrabawn UpgradesName and location of European site(s) ● Lough Derg (Shannon) SPA (004058) is located 7.5km north-west (straight

line measurement) of the proposed development site. There is alsohydrological connectivity via the Clareen Stream and Nenagh River betweenthe SPA and development site (13km hydrological route).

Description of the project or planIs the project or plan directly connected with ornecessary to the management of the site?

No

Are there other projects or plans that togetherwith the project or plan being assessed couldaffect the site?

No

The assessment of significance of effectsDescribe how the project or plan (alone or incombination) is likely to affect the Natura 2000site.

No likely effects were determined from the proposed upgrade works.

Explain why these effects are not consideredsignificant

No likely effects were determined, therefore there can be no alteration of theconservation condition or objectives of the European site due to the proposedworks.

List of agencies consulted: provide contactname and telephone or e-mail address

None

Response to consultation. N/a

Data collected to carry out the assessment

Who carried out the assessment? Erin Johnston / Aine Sands, Ecologists with Mott MacDonald

Sources of data? Refer to References Section.

Level of assessment? Site visit and desktop study

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5 References

Holman et al (2014). IAQM Guidance on the assessment of dust from demolition andconstruction, Institute of Air Quality Management, London.www.iaqm.co.uk/text/guidance/construction-dust-2014.pdf.

NPWS (2016) Conservation objectives for Silvermine Mountains SAC [000939]. GenericVersion 5.0. Department of Arts, Heritage, Regional, Rural and Gaeltacht Affairs.

NPWS (2017) Conservation Objectives: Silvermines Mountains West SAC 002258. Version 1.National Parks and Wildlife Service, Department of Culture, Heritage and the Gaeltacht.

NPWS (2016) Conservation objectives for Bolingbrook Hill SAC [002124]. Generic Version 5.0.Department of Arts, Heritage, Regional, Rural and Gaeltacht Affairs.

NPWS (2016) Conservation objectives for Lough Derg (Shannon) SPA [004058]. GenericVersion 5.0. Department of Arts, Heritage, Regional, Rural and Gaeltacht Affairs.

NPWS (2016) Conservation objectives for Slievefelim to Silvermines Mountains SPA [004165].Generic Version 5.0. Department of Arts, Heritage, Regional, Rural and Gaeltacht Affairs.

Quirke, B, Twomey, H (2017). Biological monitoring of water quality in the vicinity of ArrabawnCo-Operative Creamery, Nenagh, Co. Tipperary.

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mottmac.com

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_________________________________________________________________________________

www.ecofact.ie 38

APPENDIX 2 CONSTRUCTION ENVIRONMENTAL MANAGEMENT PLAN

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Arrabawn Co-operative Society: Production Upgrade

Construction Environmental Management Plan

05 March 2019

Arrabawn Co-operative Society Limited

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229100043 20 A C:\Users\BAX84692\Desktop\Arrabawn CEMP_Condition No. 7.docx Mott MacDonald

Mott MacDonald South Block Rockfield Dundrum Dublin 16 D16 R6V0 Ireland T +353 (0)1 2916 700

mottmac.com

Arrabawn Co-operative Society Limited Stafford Street, Nenagh, County Tipperary

Arrabawn Co-operative Society: Production Upgrade


05 March 2019

Directors: C O’Donovan BE MBA CEng MIET (Managing), J T Murphy BE HDipMM CEng FIEI CMCILT (Deputy Managing), D Herlihy BE MSc CEng, K Howells BSc MBA CEng MICE MCIWEM (British), F McGivern BSc DipEnvEng CEng MIEI Innealtoirí Comhairleach (Consulting Engineers) Company Secretary: Ian Kilty BA (Hons) ACA Registered in Ireland no. 53280. Mott MacDonald Ireland Limited is a member of the Mott MacDonald Group

Arrabawn Co-operative Society Limited

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Mott MacDonald | Arrabawn Co-operative Society: Production Upgrade Construction Environmental Management Plan

229100043 | 20 | A | 05 March 2019

Issue and Revision Record

Revision Date Originator Checker Approver Description

1B 05 March 2019

M McCarthy J Baxter

M McCarthy Planning Conditions Discharge

Document reference: 229100043 | 20 | A

Information class: Standard

This document is issued for the party which commissioned it and for specific purposes connected with the above-

captioned project only. It should not be relied upon by any other party or used for any other purpose.

We accept no responsibility for the consequences of this document being relied upon by any other party, or being

used for any other purpose, or containing any error or omission which is due to an error or omission in data supplied

to us by other parties.

This document contains confidential information and proprietary intellectual property. It should not be shown to other

parties without consent from us and from the party which commissioned it.

This R eport has been prepar ed sol el y for use by the party which commissi oned it (the 'Client') in connection wi th the capti on ed pr oject. It shoul d not be used for any other purpose. N o person other than the Client or any party who has expr essl y agreed terms of reli ance with us (the 'Recipi ent(s)') may r el y on the content, infor mation or any views expr essed in the R eport . This R eport is confi denti al and contains pr opri etary intell ectual pr operty and we accept no duty of car e, r esponsibility or li ability to any other recipi ent of this R eport . N o repr esentati on, warranty or undertaki ng, express or i mplied, is made and no responsi bility or liability is accepted by us to any party other than the Client or any Reci pient(s), as to the acc uracy or completeness of the i nfor mati on contai ned i n this R eport . For the avoi dance of doubt thi s Report does not i n any way pur port to i nclude any legal, insurance or fi nanci al advice or opi nion.

We disclai m all and any liability whether arising i n tort, contr act or other wise which we might otherwise have to any party other than the Cli ent or the Reci pient(s), in respect of this Report, or any infor mation contained in it. We accept no responsi bility for any error or omissi on in the Report which is due to an error or omissi on in data, i nfor mation or statements supplied to us by other parti es i ncludi ng the Cli ent (the 'Data'). We have not independentl y verified the D ata or other wise exami ned i t to deter mi ne the accuracy, completeness, sufficiency for any purpose or feasi bility for any particular outcome incl uding fi nanci al.

Forecasts presented i n this document were pr epared usi ng the Data and the Repor t is dependent or based on the D ata. Inevitabl y, some of the assumptions used to develop the for ecasts will not be realised and unantici pated events and circumstances may occur. C onsequentl y, we do not guarantee or warrant the conclusions c ontained in the R eport as ther e are li kel y to be differences between the forecas ts and the actual results and those dif fer ences may be material. While we consi der that the infor mation and opini ons given in this R eport are sound all parti es must rel y on their own skill and judgement when making use of it .

Infor mation and opi nions ar e current onl y as of the date of the Report and we acc ept no responsi bility for updati ng such infor mation or opi nion. It shoul d, therefor e, not be assumed that any such infor mati on or opi nion conti nues to be accurate subsequent to the date of the Report. U nder no circumstances may this Report or any extrac t or summar y thereof be used i n connecti on with any public or pri vate securities offeri ng incl udi ng any related memor andum or pr ospec tus for any securiti es offering or stock exchange listi ng or announcement.

By acceptance of this Repor t you agree to be bound by this disclai mer. This disclai mer and any issues, disputes or cl ai ms arising out of or in connection wi th it ( whether contractual or non-contractual i n natur e such as cl ai ms i n tort, from br each of statute or regul ati on or otherwise) shall be governed by, and constr ued i n accordance with, the laws of Engl and and Wales to the e xclusion of all conflict of l aws principles and r ules . All disputes or clai ms arising out of or r elati ng to this discl ai mer s hall be subjec t to the excl usi ve jurisdicti on of the English and Welsh courts to which the parties irrevocabl y submit.

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Mott MacDonald | Arrabawn Co-operative Society: Production Upgrade Construction Environmental Management Plan

229100043 | 20 | A | 05 March 2019

Contents

1 Introduction 1

1.1 Project Background 1

1.2 Purpose of this Construction Environmental Monitoring Plan 1

2 Key Roles and Responsibilities 2

2.1 Arrabawn 2

2.2 Contractors 2

2.3 Site Environmental Awareness 3

2.4 General Site Environmental Rules 3

2.5 Emergency Planning and Response 3

3 Construction Method Statement 5

3.1 Programme / Phasing 5

3.2 Casein Processing Building 5

3.3 Wastewater Treatment Plant 6

3.4 Construction of New Entranceway and of upgraded Milk Intake, Car Park & Security Control Facilities 7

3.4.1 Upgraded Roundabout on Kenyon Street 7

3.4.2 New Security Control Building 8

3.4.3 Extension & Upgrade to Milk Intake Facility 8

3.4.4 New CIP & Truck Wash Facility 9

3.4.5 Service Road, Weighbridge & Parking Facilities 9

3.5 Temporary Site Compounds 9

4 Construction Environmental Management Plan 11

5 Reporting Actions Overview 24

Appendices 25

A. Casein Extension Supporting CEMP 26

B. Outline Construction Programme 27

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Mott MacDonald | Arrabawn Co-operative Society: Production Upgrade 1 Construction Environmental Management Plan

229100043 | 20 | A | 05 March 2019

1 Introduction

1.1 Project Background

Arrabawn Co-operative Society Limited (hereafter referred to as ‘Arrabawn’) is a dairy

processing plant located in Nenagh, Co. Tipperary. The plant operates on a 24-hour basis

processing circa 50 million gallons of milk per annum and employs approximately 111 people.

The product range from the plant includes skimmed milk powder, whey powder products, casein

and caseinate products and butter.

Arrabawn is proposing an upgrade to the plant which will comprise of three main elements, as

described below:

1. An extension to its casein process building;

2. Installation of new plant and equipment within the existing wastewater treatment plant;

3. Provision of a new vehicular / pedestrian access via the existing roundabout on Kenyon

Street and to provide new internal access routes for incoming and outgoing heavy

goods vehicles (HGVs).

Further information on these works is provided in Section 3.0.

This Construction Environmental Management Plan (CEMP) has been prepared in order to

comply with the Condition No. 7 of the planning permission issued by Tipperary County Council

for the above upgrade works. An outline programme is provided in Appendix B which will be

finalised in consultation with Tipperary County Council.

1.2 Purpose of this Construction Environmental Monitoring Plan

The primary objective of the CEMP is to safeguard the environment, site personnel, and nearby

sensitive receptors, i.e. occupiers of residential and commercial properties from site activity

which may cause harm or nuisance. This CEMP is therefore intended to provide a framework to

ensure transparent and effective protection and monitoring of the receiving environment during

the construction phase of the proposed development. The results of this monitoring will be used

to inform activities on site and to demonstrate that the environmental impacts of the proposed

development are consistent with those anticipated in the EIA Report submitted with the planning

application for the proposed development.

The CEMP is a ‘live’ document and as such will be reviewed on a regular basis. Updates to the

CEMP will be necessary due to changes in environmental management practices and/or

contractors, and as such, a revised CEMP will be submitted to Tipperary Council for each of the

main project elements as described in Section 1.1. The reason for this approach is due to the

varying nature of each of these project elements and the associated requirement to appoint a

different main contractor for same.

This CEMP provides is an overarching framework for the environmental management of

potential construction phase impacts. It should be noted that this version of the CEMP

applies to the ‘Casein Building Extension’ which is the first element of construction

works to be progressed. The appointed Contractor for the casein works is Griffin

Brothers Contracting who have confirmed that they will comply with the commitments

specified in this CEMP. A supporting CEMP prepared by Griffin Brothers Contracting is

also included in Appendix A.

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229100043 | 20 | A | 05 March 2019

2 Key Roles and Responsibilities

2.1 Arrabawn

Arrabawn will have the overall responsibility for the compliance of the proposed upgrade works

with the planning permission and any associated planning conditions.

Contractors will be appointed with responsibility for construction. Arrabawn will monitor the

Contractors performance on a regular basis and will undertake the following throughout the

duration of the construction period:

● Review contractor documents against the requirements of this CEMP;

● Undertake regular audits;

● Continuously check records;

● Set up a contractor reporting structure; and

● Conduct regular meetings where Environment, Health, and Safety (EHS) is an agenda item.

With specific reference to this CEMP, a contractual obligation will be implemented to ensure

compliance with this CEMP in addition to:

● All relevant planning conditions;

● The methods, monitoring and mitigation included in the EIA Report as well as the methods

from the Screening for Appropriate Assessment.

It will be the responsibility of the appointed contractors to implement the construction phase

mitigation measures outlined within this document through a dedicated CEMP. The contractor

will be required to undertake regular monitoring and inspections and will be required to keep up

to date records as prescribed in this CEMP with regular reporting to Arrabawn.

2.2 Contractors

As described in Section 1.2 the CEMP is a ‘live’ document and as such will be reviewed on a

regular basis. A revised CEMP will be submitted to Tipperary Council for each of the main

project elements as described in Section 1.1. The reason for this approach is due to the varying

nature of each of these project elements and the associated requirement to appoint a different

main contractor for same.

It should be noted that contractors to be appointed for each of the main project elements are as

follows:

Table 1: Contractors

Key Project Element Contractor

Extension to casein process building Griffin Brothers Contracting

Installation of new plant and equipment within the existing wastewater treatment plant;

TBC

Provision of a new vehicular / pedestrian access via the existing roundabout on Kenyon Street and to provide new internal access routes

TBC

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229100043 | 20 | A | 05 March 2019

2.3 Site Environmental Awareness

The following general site Environmental Rules will apply for the construction phase of the

proposed development. These general rules will be communicated to all site personnel via the

site induction training and they will be posted across the site at strategic locations, such as the

site entrance and entrances to buildings.

2.4 General Site Environmental Rules

Report any signs of pollution or environmental damage to the site foreman/environmental

manager regardless of severity;

● Report any spills, incidents or near misses that occur on site immediately to the site foreman;

● Refuel only in designated areas with spill kits available;

● Do not dispose of anything into a river or stream or onto land. All waste must be sent to the

designated site waste management areas;

● Do not throw litter, all waste must be sent to the site waste management contractor;

● Do not drive plant or machinery outside the authorised working boundaries of the site.

The Contractor will ensure ongoing compliance with the recognised Environmental Management

System Standard to which it is registered (e.g. EN ISO 14001 or European Standard).

The Contractor will develop Environmental Procedures to control the potential impacts from the

construction phase of the development. These procedures will made available in the main office

and at the main EHS information points on site.

All personnel will be familiar with the Environmental Policy which will be made available in the

main Contractor offices and at the main EHS information points on site.

2.5 Emergency Planning and Response

In the event of an environmental emergency, a procedure for Environmental Emergency

Preparedness and Response will be implemented by the Contractor in order to contain

environmental impacts. An environmental emergency at the site may include;

● Discovery of a fire within the site boundary

● Flooding

● Uncontained spillage / leakage / loss of containment

● Discharge concentration of potential pollutants in excess of an environmental trigger level

The general required emergency response actions will be posted at strategic locations, such as

the site entrance and near the entrances to buildings.

An example of emergency response actions required, in the event of a spillage, is for the

following procedure to be followed:

● If safe, stop the source of the spill and raise the alarm to alert people working in the vicinity

of any potential dangers.

● If safe, contain the spill using the absorbent spills material provided. Do not spread or flush

away the spill;

● Cover or bund off any vulnerable areas where appropriate;

● If possible, clean up as much as possible using the absorbent spills materials;

● Do not hose the spillage down or use any detergents;

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● Contain any used absorbent material so that further contamination is limited;

● Notify the Contractor’s EHS Officer so that used absorbent material can be disposed of using

a licensed waste contractor;

● An accident investigation should be performed in accordance with procedures and the report

sent to the Construction Manager.

The following local emergency contact details will be used by the Contractor:

Table 2: Emergency Services and Contact Details

Emergency Services Contact Telephone Number

Ambulance 999 or 112

Tipperary County Council Fire Services 999 or 112

Tipperary County Council Environment Department 076 1065000

Tipperary County Council Roads Department 076 1065000

Inland Fisheries Ireland 052 6180 055

National Parks and Wildlife Services 1890 383 000

Environmental Protection Agency 1890 33 55 99

National Monuments Services 01 888 2178

ESB Emergency 1850 372 999

Bord Gais Emergency 1850 20 50 50

Irish Water Emergency 1850 278 278

Irish Rail 01 8555454

Health and Safety Authority 1890 289 389

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3 Construction Method Statement

3.1 Programme / Phasing

The construction activities from initial mobilisation to substantial completion is estimated to be

36 months. The total number of construction staff will vary but is expected to peak at

approximately 80 persons.

The construction works will be phased to facilitate milk processing operations which must be

maintained throughout the works period. Similarly, the upgrade works to the Kenyon Street

Roundabout will be carried out in phases to maintain traffic flows on Kenyon Street and on

Martyr’s Road during the works.

Normal working hours during the construction period are to be Monday to Friday between 08.00

to 18.00 hours (inclusive) and the hours between 08.00 to 14.00 (inclusive) on Saturdays

(excluding Bank/Public holidays).

3.2 Casein Processing Building

The substructure foundations will comprise reinforced concrete ground beams and pad

foundations/pile caps cast at a formation level of approximately 1.3 metres below ground level

and supported on cast-in-situ bored piles drilled through overburden sub-soils to suitable

bearing level in limestone bedrock. The depth to bedrock will be subject to confirmation by

detailed ground investigation but based on previous investigations carried out on the site,

bedrock is anticipated to be present at depths in the order of 6.0 metres below ground level.

Ground floor construction will comprise an in-situ reinforced concrete grade slab cast over a

granular crushed stone sub-base compliant with S.R.21: Annex E: Aggregates for use under

concrete floors.

The superstructure of the extensions will comprise reinforced concrete (or structural steel

encased concrete) framing up to roof eaves level with columns located in perimeter walls at

nominal centres of between 4.5 metres and 6.5 metres centres similar to the existing building.

There will also be columns located within main internal partition walls and some internal isolated

columns within plant room floor areas to support high level plant and any associated access

platforms or mezzanine floors. It is proposed that the roof structures will be flat comprising

profiled metal decking on steel purlins at nominal 1.3 metre centres supported on steel beams

spanning on to superstructure columns at centres as noted above.

It is proposed that the building envelope will comprise 215mm thick solid concrete blockwork

inner leaf infill between concrete framing for the full height of the building. A minimum 125mm

wide cavity with minimum 80mm thick high density insulation and 100mm outer leaf blockwork

will be provided to a height of approximately 3.0metres above ground floor on all elevations.

Above this level, it is proposed to clad the elevations of the extensions with a proprietary

composite insulated metal cladding system with minimum 100mm thick insulated core.

Internally, main partition walls between plantrooms and around stairs and main corridors within

the building extensions will also be constructed in 215mm thick solid blockwork. Suspended

floors at upper levels through the building extensions will comprise in- situ reinforced concrete

slab or precast concrete slab construction of minimum thickness 200mm.

Building finishes at roof level will comprise a proprietary roof membrane weathering system on a

minimum thickness of 120mm high density insulation board on vapour barrier over the metal

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decking structure. External block wall elevations at low level will be finished in smooth sand

cement plaster painted to selected colours. External door and louvred panel locations are

indicated on Planning Application Drawing 118005- 24.

The building design will be in accordance with the Irish Building Regulations which will be

certified by the designers in accordance with the Building Control Amendment Regulations

(BCAR). Monitoring of compliance of the construction of the building with Building Regulations

will be implemented and certified in accordance with requirements of the Building Control

Management System (BCMS).

Due to the proximity of the proposed development to an existing railway line, it is noted that the

method of construction will be subject to consultation with Irish Rail in accordance with their

procedures for 3rd party works. Prior to construction, railway protection arrangements are to be

agreed with Irish Rail. These arrangements will be incorporated into the contractor’s proposals

for safe systems of work which will be set out in method statements to be submitted to Irish Rail

for their approval.

3.3 Wastewater Treatment Plant

This overarching CEMP will be revised for the construction of the WWTP as described in

Section 1.1 and when a preferred Contractor has been appointed.

The WWTP upgrade is very flexible in design and can be done without major interference of the

treatment process during construction.

Table 3: WWTP Construction

New Plant Commentary

DAF100 The existing DAF unit can be reused without modification.

Upgrading Balance Tank Interim pumps transport water from primary DAF to DAF100 without overflow to balance tank. Aeration

system in balance tank can now be renovated and a new overflow box mounted. Guiderails for submerged

pumps will be checked and eventually renewed.

Upgrading AS3 The existing aeration grids can one-by-one be reorganized and leave bottom space for additional

grids. This can be done while the tank is in operation.

New grids and the new blower station can be installed without interference in operation of AS3. Eventual removal of surface aeration construction might be

necessary.

After upgrading AS3 the existing AS1 and AS2 can be taken out of operation without losing capacity.

Calamity tank (former AS1 and AS2) New piping with automatic valves from both casein and dairy stream will be forwarded to balance tank. The

automatic valves can cut-off the wastewater from each stream independently to calamity tanks.

Internal pump station Water from DAF100, by-pass and overflow will be collected in an internal pump station. Rearrangement

of pipes might be necessary.

New aeration tank (AS4) and final clarifier Construction of the new activated sludge tank, AS4, and new final clarifier can take place independently

from the existing treatment line. Only few hours of interruption are necessary to modify the effluent pipe

from the existing clarifier to the new AS4. At the same moment pipe from the new final clarifier to DAF150 can

be connected

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New Plant Commentary

SCADA The existing SCADA system will be upgraded before changes in the treatment line. Programming of control

strategies and parameter setpoints will be finalized and tested before tanks/units are active in the treatment

line.

3.4 Construction of New Entranceway and of upgraded Milk Intake, Car Park &

Security Control Facilities

This overarching CEMP will be revised for the construction of the WWTP as described in

Section 1.1 and when a preferred Contractor has been appointed.

The construction of the new entrance together with upgraded milk intake, car park and security

control facilities will be preceded by an enabling works phase. This phase will include setting up

of a temporary staff parking area for Arrabawn staff to replace the existing parking area on the

milk processing site. It is proposed that a temporary car park to cater for approximately 60 no.

car spaces will be constructed in the vacant field site located to the north of and adjoining the

existing Arrabawn Co-op head office site on Stafford Street as indicated on Drawing No.

118004-02. It is also envisaged that this enabling works phase will include preparatory works on

Kenyon Street including relocation of some public lighting and possibly some localised diversion

existing underground telecom services and of some ESB services.

The next phase of the works will comprise the demolition of the existing properties formerly

known as the Railway Bar property and the Suttons Coals property. Following clearance of the

sites of these properties, the site boundaries would be secured with suitable hoarding. It is

envisaged that a contractor’s compound and parking area for these works will be set up within

the area where the new car park adjoining the Stafford Street boundary will be located and

accessed via the existing Stafford Street entrance to the Co-op site. Thereafter the construction

of the various elements of the development will proceed on a phased basis to take account of

milk processing operation on the Arrabawn site and of traffic flows on Kenyon Street. The

construction methodology for the main elements of the works is outlined in the following

sections.

3.4.1 Upgraded Roundabout on Kenyon Street

The roundabout will be relocated from its existing position and partly recessed into the

Arrabawn site to facilitate the upgraded design as shown on Drawing No. 118004-21. The

boundary wall of the Co-op will be reconstructed to facilitate the roundabout and will comprise a

masonry faced blockwork wall of approximate height of 1.1 metres with railings over to provide

an overall wall and railing height of approximately 2.25 metres above footpath level.

The roundabout will be approximately 30 metres in diameter with a central island of approximate

diameter 8.0metres. It is proposed that the island will be raised and surrounded by a low

masonry wall and landscaped internally in a manner that will allow driver visibility across the

roundabout. The circulating carriageway will be 6.0 metres wide and finished with an asphalt

wearing course on asphaltic concrete binder and base courses. An overrun area between the

circulating carriageway and the central island will be constructed in concrete pavement slab.

Footpaths and traffic splitter islands around the roundabout will be reconstructed and surfaced

with concrete paving blocks similar to existing paving along the graveyard boundary wall

opposite the Co-op. Pedestrian crossing facilities will be provided on roundabout approaches as

shown on Drawing No. 118004-21.

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The roundabout will be designed in accordance with the Design Manual for Roads and Bridges

(DMRB) published by Transport Infrastructure Ireland and the Design Manual for Urban Roads

and Streets (DMURS) and the Traffic Signs Manual (TSM), both published by the Department of

Transport. The construction materials used in the road and roundabout construction will be in

accordance with the Manual of Contract Documents for Roadworks (MCDRW) published by

Transport Infrastructure Ireland.

3.4.2 New Security Control Building

Details of the proposed Security Control Building construction are contained on Planning

Application Drawings 118004-31 & 32. Sub-structure will comprise in situ reinforced concrete

spread footings supporting masonry blockwork rising walls to floor level and in-situ reinforced

concrete stub columns to support structural framing to the building superstructure. Ground floor

slab construction will comprise a reinforced concrete grade slab on insulation on damp

proof/radon barrier system on imported granular fill sub-base. Superstructure construction

above damp-proof course level will comprise masonry cavity wall construction for the external

walls around the toilet/ staff facilities area and along the rear elevation. It is proposed that these

wall elevations will be finished externally in cut limestone panels. Internal partition walls will be

constructed in be in blockwork masonry with smooth plastered finishes. The reception area will

be enclosed in proprietary glazing system in aluminium framing spanning from ground floor level

to roof over. The sloped roof over the reception will be supported on structural steel framing.

The lower level roof over the toilet/staff facilities area will be partly supported on steel framing

and partly on masonry walls under. The roof construction will comprise a proprietary metal panel

system on timber boarding and insulation on timber joists spanning onto the steel framing and

masonry walls.

The building design will be in accordance with the Irish Building Regulations which will be

certified by the designers in accordance with the Building Control Amendment Regulations

(BCAR). Monitoring of compliance of the construction of the building with Building Regulations

will be implemented and certified in accordance with requirements of the Building Control

Management System (BCMS).

3.4.3 Extension & Upgrade to Milk Intake Facility

The proposed works are outlined on Planning Application Drawings 118004-33 & 34. The

extension works will comprise the provision of an additional milk intake lane along the outside of

the existing milk intake facility. The new lane will be formed between new raised traffic islands to

guide the incoming milk tankers into position and to provide a raised plinth for milk intake plant.

The existing canopy roof structure over the milk intake area will be extended by approximately

4.0 metres to provide cover over this lane. The new lane pavement and the raised islands will

be formed in in-situ reinforced concrete. The extension to the canopy roof over will be supported

on structural steel roof spanning onto new steel stanchions located along the line of the outer

raised island and bearing on new concrete pad footings cast on a suitable subsoil formation at a

depth of approximately 1.3 metres below ground. The roof construction will comprise a

proprietary roof membrane system on metal decking and purlins spanning onto the steel trusses

under. The fascia of the new roof extension will be clad with a proprietary profiled metal

sheeting system to selected colour.

Upgrade works will comprise reconfiguration of existing milk intake plant and addition of new

plant to provide a total of 6 no. milk intake stations within the facility. It is also proposed to re-

clad the external elevations of the existing canopy roof and to repaint the existing steel structure

to match the roof extension structure and cladding.

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3.4.4 New CIP & Truck Wash Facility

The proposed works are outlined on Planning Application Drawings 118004-35 & 36. The new

CIP (cleaning-in-place) wash facility, for cleaning the inside of milk tankers after milk is

unloaded, will comprise 2 no. traffic lanes with 2 no. CIP wash stations provided in each lane. A

bypass lane will be provided on the southern side of the facility to provide access to the yard at

the rear of the store building adjacent to the CIP wash facility. A canopy roof structure will be

provided over the CIP wash and bypass lane. The construction of the roof will comprise a

proprietary flat roof membrane system on metal decking supported on structural steel framing

similar to the roof of the milk intake area. The roof fascia will be also clad to match the fascia of

the roof over the milk intake facility. The road pavement through the CIP wash area and onto

the weigh bridge for outgoing trucks will comprise in-situ reinforced concrete pavement slab cast

to falls for drainage purposes on imported granular fill sub-base of minimum thickness 300mm.

The truck wash facility will comprise 2no. screen walls enclosing the sides of a 6.0metre wide

wash bay for external cleaning of trucks. The facility will be fitted with power wash facilities.

The screen walls are proposed to be constructed in reinforced concrete to a height of

approximately 1metre above ground level with the upper portion of the screens constructed in

propriety metal cladding supported on structural steelwork framing to provide an overall screen

height of up to 5.0 metres.

It is not envisaged that every truck will use the facility on every milk delivery trip. A bypass lane

is therefore provided on the south side of the truck wash facility to allow trucks to proceed past

the wash facility and on to the weigh bridge facility for incoming trucks. The road pavement

through the truck facility and by pass lane and onto the weighbridge facility will comprise

concrete pavement construction similar to the CIP and milk intake areas.

3.4.5 Service Road, Weighbridge & Parking Facilities

The service road from the entrance on Kenyon Street to the internal roundabout in the Co-op

site will be split by a kerbed and paved median island construction separating incoming and

outgoing traffic. It is proposed that the roads and roundabout will be surfaced in asphalt wearing

course on asphaltic concrete binder and base courses granular crushed stone sub-base fill, all

in accordance with the Manual of Contract Documents for Roadworks (MCDRW) published by

Transport Infrastructure Ireland. The new car park areas located within the site will be surfaced

in asphaltic concrete wearing and binder courses on crushed stone sub-base. The weighbridge

facilities for outgoing and incoming milk tankers located to the south of the security control

building will comprise proprietary steel weighbridge facilities installed by specialists in a willow

pit formed in reinforced concrete. The installation will be designed to be accessible for cleaning

of void spaces under the bridges. The weighbridge controls and output screens will be located

in the Security Control Building.

3.5 Temporary Site Compounds

A temporary contractor’s set down area to facilitate construction of the extensions/upgrade to

the casein processing building is proposed to be located within the Mart site adjoining Arrabawn

and in close proximity to the casein building location. It is also proposed to provide a temporary

car park for construction site staff workers within the Mart site. The provision of both facilities

has been agreed by Arrabawn Co-op with the management of the Mart facility. A temporary

contractor’s compound to facilitate construction of the extensions/upgrade to the casein

processing building is proposed to be located in the existing open yard area to the east of the

existing milk intake.

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A temporary contractor’s compound to facilitate construction of the new entrance and works to

Kenyon Street roundabout is proposed to be located within the area of the proposed new car

park located adjacent to Stafford Street. It is proposed that works to the milk intake and

CIP/truck wash areas, security control building and internal car park will be facilitated from this

compound area also. It is envisaged that the compound can be maintained at this location until

all these works are complete. It is envisaged at that stage that contractor car parking could

move to the new central car park area to facilitate completion of the main car park, internal

roundabout and closing down of the existing entrance from Stafford Street.

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4 Construction Environmental Management

Plan

The pre-construction phase of the development includes preparatory works such as post-

planning environmental surveys and reporting and consultation with landowners, statutory

bodies and the public. Prior to the commencement of construction activities, the area for

development will be fenced off. Following this process, site clearance activities will commence.

Typical activities will include preparation of the construction working area and topsoil stripping,

as well as removal or diversion of walls, hedges, ditches, trees and other vegetation, and

services etc.

Mobilisation will include the putting in place of staff, temporary facilities, plant and equipment,

materials and systems for construction. Two temporary contractors compound will be erected on

site for the duration of the construction works, and will include temporary site offices

(portacabins), staff welfare facilities, and car parking and equipment laydown areas. The total

number of construction staff on-site will vary during the construction phases of the works but is

expected to peak at approximately 80. Training in health and safety will be provided for all staff

during the mobilisation period, and all staff will be required to hold SAFEPASS or equivalent

certification.

It should be noted that this CEMP provides an overarching framework for the

environmental management of potential construction phase impacts which all

Contractors will need to comply with, where relevant. This version of the CEMP applies

to the ‘Casein Building Extension’ which is the first element of construction works to be

progressed. The appointed Contractor for the casein works is Griffin Brothers

Contracting who have confirmed that they will comply with the commitments specified in

this CEMP. A supporting CEMP prepared by Griffin Brothers Contracting is also included

in Appendix A.

The following sub-sections address individual project construction activities identifying specific

mitigation and monitoring measures, as required.

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Table 4: Dust, Air Quality and Odour

Objective Activity Mitigation / Enhancement Responsibility Timescales Monitoring Implementation Route

Minimise dust emissions

Site clearing, earthworks and construction activities

● Minimise dust generating activities;

● Locate activities and rock / earth stockpiles away from sensitive receptors;

● Cover, seed or fence stockpiles to prevent wind whipping;

● Keep stockpiles for the shortest possible time;

● Ensuring all vehicles carrying loose or potentially dusty material to or from the site are fully sheeted;

● Plan site layout – machinery and dust causing activities (e.g. road works, stockpiles) should be located away from the site boundary and sensitive receptors where practicable;

● No site runoff of water or mud; and

● Minimise movement of construction traffic around site.

Arrabawn

Lead Contractor and any subcontractors

Mitigation and Monitoring ongoing throughout construction

Lead Contractor to undertake visual checks of construction areas.

Maintain logbook: record any exceptional incidents that cause dust and/or air emissions, either on- or off- site, and the action taken to resolve the situation in the log book.

Regular (weekly) visual monitoring of dust episodes, soiling of vegetation, dust suspension on the roads and dust clouds etc.;

.


Minimise NOX, PM10, PM2.5, SO2, emissions

On Site plant and vehicles

● Contractor to implement a Construction Traffic Management Plan (CTMP)

● Minimise movement of construction traffic around site; and

● Ensuring that the engines of all vehicles and plant on site are not left running unnecessarily.

Arrabawn

Lead Contractor and any subcontractors

Mitigation and Monitoring ongoing throughout construction

Lead Contractor to undertake weekly visual checks of construction vehicles and maintain servicing records for same.


Construction Traffic Management Plan

Odour ● All odorous sludge treatment and storage will be undertaken inside tanks/buildings at the facility, washing down of surfaces where waste or dairy contamination can occur is carried out regularly.

Arrabawn Mitigation and Monitoring ongoing throughout construction

● An updated odour management plan will be developed prior to the detailed design and construction of the upgrade to the facility and WWTP.

Odour Management Plan

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● Areas which have the potential to have such wastes are provided with a power hose, mop and adequate drainage.

● All odorous materials are removed from the facility in covered/enclosed vehicles; Good housekeeping practices (internally and externally) and a closed-door management strategy is maintained at all times;

● Regular inspections, monitoring and maintenance of processing areas is routinely carried out;

● Regular odour monitoring will be implemented on site as part of Arrabawn’s Industrial Emissions licence requirements.

● This plan will include management strategies for the prevention of emissions and a strict preventative maintenance and management program for ensuring that all odour mitigation techniques remain operational at optimal capacity throughout construction and all operational scenarios;

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Table 5: Archaeology (Entrance and Access only)


Recording and protection of

archaeological features during

works associated

with Provision of a new

vehicular / pedestrian

access via the existing

roundabout on Kenyon Street and to provide

new internal access routes

Excavation (including site

preparation groundworks)

● The National Museum of Ireland (NMS) will be consulted in

relation to the scope of pre-development investigations, and

to ascertain, if a Ministerial Consent is required for

investigations;

● An archaeological monitoring methodology will be agreed with

Tipperary County Council prior to commencement of

development and following planning approval with the

archaeological licensing section of the Department of Culture,

Heritage and the Gaeltacht and the National Museum of Ireland;

● Where feasible, a programme of archaeological test trenching

way be carried out in the footprint of ground works

proposed within undisturbed areas following planning

approval and prior to construction, if recommended

during consultation with relevant statutory bodies;

● All ground reduction works undertaken during the

construction phase in areas not available for pre-development

archaeological test trenching will be subject to constant

archaeological monitoring; and

● Any identified remains of the town wall will be preserved in

situ and no interventions to the structure will be undertaken

Arrabawn

Lead Contractor and any

subcontractors

Mitigation and Monitoring during

all excavations activities

The Lead Contractor will ensure that the site

preparation groundworks will be archaeologically

monitored by a qualified archaeologist to mitigate

against any potential archaeological impact

Construction Environmental

Management Plan

Archaeological Method Statement

Archaeological Licence from National

Monuments Service

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without prior agreement with the NMS.

Table 6: Landscape and Visual

Objective Activity Mitigation / Enhancement

Responsibility Timescales Monitoring Implementation Route

Visual impacts experienced by sensitive visual

receptors

Construction activities

● Good housekeeping measures including use of appropriate

hoard or boundary fencing; and appropriate storage of topsoil

and excavated materials;

● Utilisation of appropriate colour treatments and contemporary upgrades within the design to

mitigate visual impact (the final colour scheme will be as agreed with Tipperary County Council);

● The removal of vacant and derelict properties, and the

implementation of a consistent boundary treatment with ‘soft’

and ‘sympathetic’ edges will provide an appropriate level of

screening and security; and

● Establishment of landscape screen planting once key civil

works are complete as detailed within the Landscape

Masterplan.

Arrabawn


subcontractors

Mitigation and Monitoring ongoing

throughout construction

Lead Contractor to undertake regular (weekly)

visual checks of construction areas. Record findings on

log book.


Management Plan

Landscape Masterplan

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Table 7: Noise and Vibration


Avoid nuisance

generated by daytime

works affecting

closest sensitive receptors


● Unnecessary revving of engines will be avoided and

equipment will be switched off when not in use;

● Internal haul routes will be kept well maintained;

● Use of effective exhaust silence systems or acoustic

engine covers as appropriate;

● Plant will always be used in accordance with

manufacturers’ instructions. Care will be taken to site

equipment away from noise-sensitive areas. Where

possible, loading and unloading will also be carried

out away from such areas;

● Regular and effective maintenance by trained

personnel will be undertaken to keep plant and equipment

working to manufacturers specifications;

● Screening e.g. noise barriers and bunds, will be used as

appropriate; and

● Procedures for handling noise and vibration complaints;

Arrabawn


subcontractors

Mitigation and Monitoring

ongoing throughout

construction

Lead Contractor to monitor noise levels at quarterly intervals at the nearest

residential properties to construction activities for

comparison against British Standard 5228.

Additional monitoring will be carried out by Arrabawn as per Planning Condition No’s 14, 15

and 18.


Noise and Vibration Monitoring Plan

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Table 8: Traffic


Minimise road hazards,

congestion and damage to

road infrastructure


● A Construction Traffic Management Plan (CTMP) has been prepared

and is included in Appendix A for the ‘casein works’. The CTMP will

ensure safe movements and interactions between vehicles and

pedestrians, both on and adjacent to the site, and will cover all expected

work activities, delivery and storage areas, and will be expanded and / or

amended to cover new or altered activities as they arise; and

● CTMP will also provide for the requirement that the entrances and

roads are kept clean and clear of obstructions, and prevent the

spillage or deposit of debris. This will also include for items such as wheel washes, etc. to minimise dust due to

construction traffic.

Arrabawn


subcontractors


ongoing throughout

construction

An update on the implementation of the CTMP will be provided regularly to

Tipperary County Council as part of the implementation of

this EMP.


Management Plan

Construction Traffic Management Plan (refer

Appendix A for casein extension CTMP)

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Table 9: Ecology and Water


Protection of sensitive

ecological receptors


● All vegetation clearance will be carried out outside of birds nesting season (1st March to 31st August

inclusive) to ensure there is no impact on protected breeding birds;

and

● A pre-construction bat survey of the three derelict buildings and treeline will be undertaken by a competent Ecologist prior to the construction

phase commencing. This Relates to the entranceway and access

element of the project only;

Arrabawn


subcontractors



Lead Contractor to undertake regular

(weekly) visual checks of construction areas.

Record findings on log book.

An appropriately experienced

Ecological Clerk of Works (ECoW) will be present on site during

the construction works to ensure the

successful implementation of the

management and monitoring measures


Loss of habitat


● Good site practice as per the CIRIA C741 Environmental Good Practice

On Site Guide (fourth edition) will be implemented on site at all times;

● New trees will be planted within the development site which will provide

new habitats (Landscape Masterplan);

● A pre-construction invasive species survey will be undertaken by a

competent Ecologists during the optimal survey period to determine

the presence of invasive species listed under Part 1 of the Third

Schedule of S.I No. 477 of 2011; and

● Invasive species biosecurity measures, such as wheel washes and the inspection of vehicles, will be implemented on site to ensure

the translocation of invasive species into the proposed development site

Arrabawn


subcontractors






An appropriately experienced

Ecological Clerk of Works (ECoW) will be present on site during

the construction works to ensure the

successful implementation of the

management and monitoring measures


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does not occur. Where top soil or similar material is required to be

brought onto site, the contractor will ensure the material is not

contaminated with Japanese knotweed (Fallopia japonica) or

other invasive species.

Pollution Construction Activities

● A pollution emergency contingency plan will be put in place;

● A minimum separation distance of 10 metres will be maintained

between construction activities and the Clareen Stream;

● Unnecessary clearing and grading of the site will be avoided in order to

protect the Clareen Stream;

● Silt/sediment control measures will be installed along the perimeter of

excavation areas where there is potential to impact on drains or on

the Clareen Stream itself; including, silt traps and sediment traps, run-off

interceptors, geotextiles, etc;

● Chemicals and hydrocarbons will be stored in bunded areas. The

capacity of the bunds will be a minimum of 110% of the volume of

the largest container stored therein. Where refuelling is to take place on

site, it will be within a designated impermeable, bunded area, away

from all drains.

Arrabawn


subcontractors







Pollution Emergency Contingency Plan

Table 10: Soils, Geology and Hydrogeology


Prevent soil erosion and

contaminated

Construction activities.

● Construction activities will be phased to minimise soil exposure;

Arrabawn


ongoing


(weekly) visual


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soils or groundwater

● Exposed soils, where there is a risk of generating sediment in surface

water run-off, will be re-stabilised as soon as possible;

● Where appropriate, any stockpiles with be located upstream of sediment traps/covered with

geotextile covers or removed from site as soon as possible;

● To minimise the risk of instability, stockpiling of excavated materials will be undertaken only to heights

and slope angles which the material is capable of supporting;

● Bunds for the storage of chemicals and hydrocarbons will be lined or

constructed of materials resistant to damage by the materials stored

therein. In addition, the capacity of such bunds will be a minimum of

110% of the volume of the largest container stored therein. Bunds will

be designed in accordance with Environmental Protection Agency

guidance in relation to the storage of potentially polluting liquids (“IPC Guidance Note on Storage and

Transfer of Materials for Scheduled Activities”, 2004) and BS EN 1992-

3:2006 Eurocode 2. Design of concrete structures. Liquid retaining

and containing structures, paying due regard to procedures for

emptying potentially contaminated rainwater, if uncovered, orientation

of fill / discharge points, valves, and other risk connections within the

bund structure;

● Where refuelling is to take place on site, it will be within a designated

impermeable, bunded area, away from all drains;


subcontractors


checks of construction areas. Record findings on

log book.

Pollution Emergency Contingency Plan

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● Concrete pouring and filling will be fully controlled to ensure that cement

bound materials do not present any pollution risk; all concrete pouring

and filing will be supervised and monitored;

● Portable chemical toilets will be provided for the duration of the

works, and all waste material will be removed from site and disposed of to an appropriately licensed facility;

● A pollution emergency contingency plan will be put in place;

● All spills / leaks will be cleaned up immediately;

● Spill kits will be maintained on site at all times, and all staff will be trained in their use and know the locations

of the spill kits (near working areas);

● Drip trays will be used where hydrocarbons are being used for

vehicle maintenance/refuelling; and

● All plant will be inspected at the beginning and end of each shift, and

if leaks are evident, they are to be repaired immediately or removed

from site and replaced.

Table 11: Materials and Waste Management


Reduce the use of raw materials/ potentially finite

and or scarce resources


● Re-using materials on site wherever possible. The most significant opportunity in the

construction phase is with respect to excavated materials;

● Implementing good housekeeping practices including inventory

control to reduce the amount of

Arrabawn


subcontractors


ongoing throughout

construction

Lead Contractor to carry out quarterly waste audit during

contract scope.

Lead Contractor to implement Waste Management Plan


Management Plan

Waste Management Plan

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waste resulting from materials that are out-of-date, off-specification,

contaminated, damaged, or excess to plant needs;

● Implementing procurement measures that recognise

opportunities such as ordering the correct amount of materials to be delivered when needed, reducing the amount of packaging used by suppliers, and establishing a take

back system with suppliers;

● Seeking ways to reduce raw material consumption through

efficiency audits in the operational phase; and

● Substituting raw materials or inputs with less hazardous or toxic

materials wherever economically and technically feasible.

Minimisation and safe disposal of

waste and appropriate

handling and storage of waste

Waste generated

as a result of day to day

construction activities

● Implement Waste Management Plan (WMP) which identifies

measures for minimisation of waste and safe disposal of

construction wastes;

● Provision of appropriate facilities/containers for segregation

and temporary storage of general wastes on site and establishment

of regular disposal to licensed third party landfills or re-

use/recovery/recycling where possible;

● Disposal of hazardous waste to appropriate treatment facilities.

Segregation of waste streams to maximise reuse and recycling;

● All waste storage units to be covered;

Arrabawn


subcontractors


ongoing throughout

construction


contract scope.

Lead Contractor to implement Waste Management Plan


Management Plan


Closure and Aftercare Management Plan

(Industrial Emission Licence)

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● Spill kits to be available at all times; and

● Closure and Aftercare Management Plan, as noted in the Industrial Emissions Licencing, will

describe provisions to decommission and render safe, or

remove all materials, waste, ground, plant or equipment

contained on or in the site that may result in environmental

pollution.

Appropriate choice of final

waste disposal location

Waste generated

as a result of day to day

construction activities

● Identify licenced waste handling facilities in close proximity to the

proposed development to accept/ treat waste.

Arrabawn


subcontractors


ongoing throughout

construction


contract scope.

Lead Contractor to implement Waste Management Plan.


Management Plan


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5 Reporting Actions Overview

This CEMP provides is an overarching framework for the environmental management of

potential construction phase impacts.

The CEMP is a ‘live’ document and as such will be reviewed on a regular basis. Updates to the

CEMP will be necessary due to changes in environmental management practices and/or

contractors, and as such, a revised CEMP will be submitted to Tipperary Council for each of the

main project elements which are:

1. An extension to its casein process building;

2. Installation of new plant and equipment within the existing wastewater treatment plant;

3. Provision of a new vehicular / pedestrian access via the existing roundabout on Kenyon

Street and to provide new internal access routes for incoming and outgoing heavy

goods vehicles (HGVs).

It should be noted that this version of the CEMP applies to the ‘Casein Building Extension’

which is the first element of construction works to be progressed. The appointed Contractor for

the casein works is Griffin Brothers Contracting who have confirmed that they will comply with

the commitments specified in this CEMP. A supporting CEMP prepared by Griffin Brothers

Contracting is also included in Appendix A.

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Appendices

A. Casein Extension Supporting CEMP 26

B. Outline Construction Programme 27

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A. Casein Extension Supporting CEMP

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B. Outline Construction Programme

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mottmac.com

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APPENDIX 3 NPWS SITE SYNOPSIS Site name: Lough Derg (Shannon) SPA Site code: 004058 Lough Derg lies within counties Tipperary, Galway and Clare and is the largest of the River Shannon

Lakes, being some 40 km long. Its maximum breadth across the Scarriff Bay -Youghal Bay transect is

13 km but for most of its length it is less than 5km wide. The lake is relatively shallow at the northern

end being mostly 6 m in depth but in the middle region it has an axial trench and descends to over 25

m in places. The narrow southern end of the lake has the greatest average depth, with a maximum of

34 m. The greater part of the lake lies on Carboniferous limestone but the narrow southern section is

underlain by Silurian strata. Most of the lower part of the lake is enclosed by hills on both sides, the

Slieve Aughty Mountains to the west and the Arra Mountains to the east. The northern end is bordered

by relatively flat, agricultural country. The lake shows the high hardness levels and alkaline pH to be

expected from its mainly limestone catchment basin, and it has most recently been classified as a

mesotrophic system. The lake has many small islands, especially on its western and northern sides.

The shoreline is often fringed with swamp vegetation. Aquatic vegetation includes a range of charophyte

species, including the Red Data Book species, Chara tomentosa. The shoreline is often fringed by

swamp vegetation, comprised of such species as Common Reed (Phragmites australis), Great Fen-

sedge (Cladium mariscus) and Bottle Sedge (Carex rostrata).

The site is a Special Protection Area (SPA) under the E.U. Birds Directive, of special conservation

interest for the following species: Cormorant, Tufted Duck, Goldeneye and Common Tern. 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.

Lough Derg is of importance for both breeding and wintering birds. The site supports a nationally

important breeding colony of Common Tern (55 pairs recorded in 1995). Management of one of the

islands used for nesting has increased the area of suitable habitat available and prevented nests being

destroyed by fluctuating water levels. Large numbers of Black-headed Gull have traditionally bred on

the many islands (2,176 pairs in 1985) but the recent status of this species is not known. The islands in

the lake also support a nationally important Cormorant colony - 167 pairs were recorded in 1995; a

partial survey of the lake in 2010 recorded 113 pairs. Lough Derg is also a noted breeding site for Great

Crested Grebe (47 pairs in 1995) and Tufted Duck (169 pairs in May 1995).

In winter, the lake is important for a range of waterfowl species, including nationally important

populations of Tufted Duck (776) and Goldeneye (157) – all figures are mean peaks for 4 of the 5

seasons between 1995/96 and 1999/2000. Other species which occur in winter include Mute Swan

(164), Whooper Swan (18), Wigeon (249), Teal (301), Mallard (376), Little Grebe (14), Cormorant (90),

Coot (173), Lapwing (922), Curlew (66) and Black-headed Gull (732). Areas to north and south west of

Lough Derg have been utilised in the past by small numbers of Greenland Whitefronted

Goose – 19 geese were recorded on callowland near Portumna in 1996/97. A relatively small flock

based in the Lough Derg-Lough Graney area and possibly further afield have been recorded in the

Scarriff Bay area – 20 geese recorded in 2004. Few sightings, at either location have been made in

recent years.

Hen Harrier are also known to roost in the reedbeds on the margins of the site during

the winter.

Lough Derg (Shannon) SPA is of high ornithological importance as it supports nationally important

breeding populations of Cormorant and Common Tern. In winter, it has nationally important populations

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www.ecofact.ie 40

of Tufted Duck and Goldeneye, as well as a range of other species including Whooper Swan. The

presence of Whooper Swan, Greenland White-fronted Goose, Hen Harrier and Common Tern is of

particular note as these are listed on Annex I of the E.U. Birds Directive. Parts of Lough Derg (Shannon)

SPA are a Wildfowl Sanctuary.

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)

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.

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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 (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).

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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 sealavender, 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 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.

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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-ashalder 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 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.

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;

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1994/95), Whooper Swan (201; 1995/96), Pale-bellied Brent Goose (246; 1995/96), Golden Plover

(11,067; 1994/95) and Bartailed Godwit (476; 1995/96). In the past, three separate flocks of Greenland

Whitefronted 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.

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.

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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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