re: clifden waste water discharge licence - technical ... · re: clifden waste water discharge...

Dr. Karen Creed

Environmental Licencing Programme

Office of Climate, Licencing and Resource Use

Environmental Protection Agency

PO Box 3000

Johnstown Castle Estate

Wexford

21st December 2016

IW-ER-LT0324

Dear Karen,

RE: Clifden Waste Water Discharge Licence - Technical Amendment Application

D0198-01

The Agency issued a Wastewater Discharge Licence for the Clifden Agglomeration (D0198-01)

on the 19th December 2011. Irish Water now requests a Technical Amendment under Section

33 (1) of the Waste Water Discharge (Authorisation) Regulations 2007, to amend Schedule A.3

Storm Water Overflows, to include an additional stormwater overflow as follows:-

Licence

Code

SWO

Discharge

Location

Storm Water

Overflow Location

Name of

Receiving

Water

WFD Code Receiving

Water

SW005 065282E;

250136N

WWTP Storm Tank

Overflow

Clifden Bay IE_WE_270_0100

The stormwater overflow, which is not currently included by the Licence, is the overflow from

the storm tank at the wastewater treatment plant and discharges to the same location as the

Primary Discharge Point.

Irish Water has had regard to the EPA’s publication EPA Guidance for Irish Water on Requests

for Alterations to a Waste Water Discharge Licence or Certificate of Authorisation in compiling

this submission for a Technical Amendment.

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Appendix 1. Map of Stormwater Overflow Location

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Drawn By:Checked By:Approved By:

Drawing No.:Scale @ A3:

Drawn DateChecked Date:Approved Date:

1:7,244

Coordinate System: TM65 Irish GridProjection: Transverse Mercator

0 90 18045Meters

MBS

IW-AGG-2016-457

13/12/201613/12/201612/12/2016

FLRS

COY

Q

ClifdenWWTP

© Ordnance Survey Ireland

±1. No part of this drawing may be reproduced or transmitted in any form or stored in any retrieval system of any nature without the written permission of Irish Water as copyright holder except as agreed for use onthe project for which the document was originally issued.2. Whilst every care has been taken in its compilation, Irish Water gives this information as to the position of its underground network as a general guide only on the strict understanding that it is based on the bestavailable information provided by each Local Authority in Ireland to Irish Water. Irish Water can assume no responsibility for and give no guarantees, undertakings or warranties concerning the accuracy, completeness or up to date nature of the information provided and does not accept any liability whatsoever arising from any errors or omissions.This information should not be relied upon in the event of excavations or any other works being carried out in the vicinity of the Irish Water underground network. The onus is on the parties carry ing out excavations or any other works to ensure the exact location of the Irish Water underground network is identified prior to excavations or any other works being carried out. Service connection pipes are not generally shown but their presence should be anticipated.© Copyright Irish WaterReproduced from the Ordnance Survey Of Ireland by Permission of the Government. License No. 3-3-34 Map Template Design: [email protected]

Location of Storm Water Overflow SW005 - Clifden

SW001 Primary DischargeSW005 Stormwater OverflowLocation: 065282 E; 250136 N

LegendQ WWTP

COY

Storm WaterOverflow

Cork

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Uisce Éireann Irish Water

Appendix 2. Appropriate Assessment Screening

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Irish Water

Report

Appropriate Assessment Screening as part of the Clifden Waste

Water Discharge Licence Technical Amendment

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2 | Irish Water AA Screening – Clifden Overflow

Contents

Introduction 3

Legislative Context 3

Methodology 5

Guidance Followed 5

Stages Involved in the Appropriate Assessment Process 6

Stage 1: Screening / Test of Significance 7

Screening 8

Description of the Project 8

Description of the Receiving Environment and Monitoring Results 9

Brief Description of the Natura 2000 Sites 10

Possible Effects of the Stormwater Tank Overflow on Natura 2000 Sites 16

Direct, Indirect or Secondary Impacts 16

Possible Cumulative Impacts with other Plans and Projects in the Area 17

Screening Assessment 18

Likely Changes to the Natura 2000 Site(s) 21

Elements of the Project where the Impacts are Likely to be Significant 21

Screening Conclusions and Statement 22

Finding of No Significant Effects Report Matrix 23

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Introduction

This report provides an Appropriate Assessment (AA) Screening of a stormwater tank overflow

from the existing Waste Water Treatment Plant (WwTP) at Clifden, Co Galway, for the purposes

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

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

with other plans and projects, is likely to have significant effects on a Natura 2000 Site(s) in view

of best scientific knowledge and the conservation objectives of the site(s). Natura 2000 Sites are

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

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

Directive.

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

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

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

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

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

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

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

This report was written by a qualified ecologist working for Irish Water.

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

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

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

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

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

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

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

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

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

Appropriate Assessment (AA):

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

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

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

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

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

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

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

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

public.

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Article 6(4) states:

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

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

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

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

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

Commission of the compensatory measures adopted.

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Methodology

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

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

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

guidance:

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

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

Agency, (EPA, 2009).

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

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

2010).

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

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

Local Government, (DoEHLG, 2008).

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

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

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

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

(EC, 2000b).

Assessment of plans and projects significantly affecting Natura 2000 sites:

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

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

Brussels (EC, 2001).

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

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

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

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

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

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

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

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

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

2011).

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

Commission (EC, 2013).

Stages Involved in the Appropriate Assessment Process

Stage 1: Screening / Test of Significance

This process identifies whether the stormwater tank overflow is directly connected to or

necessary for the management of a Natura 2000 Site(s); and identifies whether the overflow is

likely to have significant impacts upon a Natura 2000 Site(s) either alone or in combination with

other projects or plans.

The output from this stage is a determination for each Natura 2000 Site(s) of not significant,

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

that site to be brought forward to Stage 2.

Stage 2: Appropriate Assessment

This stage considers the impact of the stormwater tank overflow on the integrity of a Natura 2000

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

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

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

impacts

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

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

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

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

Stage 3: Assessment of Alternatives

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

avoid adverse impacts on the integrity of the Natura 2000 Site. This assessment may be carried

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

exist or all alternatives would result in negative impacts to the integrity of the Natura 2000 Sites

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

Stage 4: Assessment Where Adverse Impacts Remain

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

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

proceed.

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Stage 1: Screening / Test of Significance In complying with the obligations under Article 6(3) and following the appropriate guidelines, this

AA Screening has been structured as a stage by stage approach as follows:

Description of the project;

Identification of Natura 2000 sites potentially affected;

Identification and description of individual and cumulative impacts likely to result;

Assessment of the likely significance of the effects on the Natura 2000 site;

Exclusion of sites where it can be objectively concluded that there will be no significant

effects; and

Screening conclusion.

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Screening

Description of the Project

Clifden is a town located 55 miles west of Galway City. The town is a market centre for the

surrounding agricultural area and has traditionally been a centre for tourism and angling in

Connemara. There is no significant industrial activity at present in the town.

The new Clifden WwTP was commissioned in 2015. The new plant discharges via a long-sea

outfall into the marine environment in the Owenglin estuary channel. The discharge location is to

a transitional water body (IE_WE_270_0100).

The agglomeration is served by a wastewater treatment plant with a Plant Capacity PE of 6,000.

The treatment process includes the following:-

preliminary treatment (including screening / grit removal)

secondary treatment -. SBR

chemical dosing for phosphorus removal

tertiary treatment – UV treatment

This assessment relates to an overflow from the stormwater tank which connects to the main

outfall discharge pipe downstream of the UV installation. The tank provides sufficient stormwater

storage (>2hrs at 3DWF), however in 2016 the number of overflows exceeded the requirement

for bathing waters. Options for reducing the frequency of these overflows are currently being

investigated.

The current population equivalent for the agglomeration is 3114 (2015 AER). Emission Limit

Values (ELV’s) set by Schedule A of EPA licence (as amended) for the primary discharge point

are 25mg/l BOD, 125mg/l COD, 35mg/l TSS and 2mg/l Total P. Effluent data for the primary

discharge from 2016 is presented in Table 1.0 together with the ELVs. The effluent discharge

meets the ELV’s for all relevant parameters.

Table 1.0: Clifden WwTP Effluent Monitoring Data

Date BOD COD SS Total Phosphorus

25mg/l 125mg/l 35mg/l 2mg/l

12/01/2016 2 10 2 0.56

09/02/2016 2 10 2 0.27

14/03/2016 2 15 2 0.88

04/04/2016 2 20 2 0.91

04/05/2016 2 31 11 0.35

08/06/2016 2 35 9 0.6

26/07/2016 2 32 7 0.88

02/08/2016 2 27 2 0.88

06/09/2016 2 23 2 0.34

10/10/2016 2 20 2 0.95

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Description of the Receiving Environment and Monitoring Results

Monitoring data from a ‘downstream’ location by Galway County Council is provided below in

Table 2.0. The sample taken on 20/3/2015 is the only sample that was taken prior to the new

plant being commissioned. The grid reference for all of the ambient samples is East 65251 North

250155 and this location is shown on Figure 1.

Table 2.0: Clifden Bay Monitoring Data

Date BOD

mg/l

Total

Nitrogen

mg/l

Total

Phosphorus

mg/l

Ammonia

mg/l

DO

mg/l

Faecal

Coliforms

MPN/100ml

E.coli MPN

MPN/100ml

Intestinal

Enterococci

Cfu/100ml

20/03/15 <1 0.72 <0.05 0.35 10.9 380000 380000 5600

22/07/15 <1 0.69 <0.05 0.25 10.1 6300 6300 13

15/10/15 <1 0.69 <0.05 0.29 10.2 315 315 104

08/12/15 <1 <0.5 <0.05 0.08 9.9 140 140 15

21/03/16 <1 <0.5 <0.05 0.079 10 8500 8500 3700

26/07/16 <1 1.04 <0.05 0.015 10.3 7300 7300 3000

10/10/2016 <1 0.989 <0.05 0.03 9.5 1800 1800 3000

BOD measured is below the Surface Water Regulations EQS value for this parameter. There

are no Surface Water Regulations EQS values for Total Nitrogen and Total Phosphorus,

however given these parameters would be higher than DIN and MRP respectively, the results

obtained suggest they would meet the relevant EQS’s for Good status for mixed salinity waters.

Clifden Bay is a designated Shellfish Water and a classified production area. Clifden Bay inner

is Class A for clams and B for mussels, while Clifden Bay outer is Class A for clams. The Sea

Fisheries Protection Authority (SFPA) and Marine Institute (MI) monitor these waters for

compliance with the relevant water quality and shellfish flesh quality standards for designated

areas/production areas. A Shellfish Impact Assessment was submitted to the EPA with the 2014

AER as referenced in Section 5.2 of the 2015 AER which considered the SFPA/MI data. The

report identified that Clifden WwTP (pre-upgrade) was not impacting on the microbiological

quality of Shellfish. A review is proposed once the new plant has been operational for 1 year.

In terms of Water Framework Directive Status1, the transitional and coastal waterbodies of

Clifden Bay are currently unassinged. The EPA water quality status (2010-2012) is Unpolluted

for both the Clifden Bay transitional waterbody and the Western Atlantic Seaboard coastal

waterbody.

Bathing water quality at Clifden Beach is noted as ‘Changes –classification not yet possible’

while the effect of the new WwTP is monitored. Water quality results for this site have varied in

2016 with some Poor results still being recorded2.

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

2 http://splash.epa.ie/#idbw/IEWEBWT270_0100_0100

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Brief Description of the Natura 2000 Sites

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

the stormwater tank overflow location. A 15km buffer zone has been chosen as a precautionary

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

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

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

Local Government.

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

discharge location, and Figure 1.0 shows their location in relation to the Clifden WwTP

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

Table 3.0: SACs located within 15km from Clifden WwTP stormwater overflow

Site

Code

Site Name Qualifying Habitats Qualify Species

002031 Twelve Bens/Garraun

Complex SAC

Oligotrophic waters containing very

few minerals of sandy plains

(Littorelletalia uniflorae) [3110]

Oligotrophic to mesotrophic standing

waters with vegetation of the

Littorelletea uniflorae and/or Isoeto-

Nanojuncetea [3130]

Alpine and Boreal heaths [4060]

Blanket bogs (* if active bog) [7130]

Depressions on peat substrates of

the Rhynchosporion [7150]

Siliceous scree of the montane to

snow levels (Androsacetalia alpinae

and Galeopsietalia ladani) [8110]

Calcareous rocky slopes with

chasmophytic vegetation [8210]

Siliceous rocky slopes with

chasmophytic vegetation [8220]

Old sessile oak woods with Ilex and

Blechnum in the British Isles [91A0]

Margaritifera margaritifera

(Freshwater Pearl Mussel)

[1029]

Salmo salar (Salmon)

[1106]

Lutra lutra (Otter) [1355]

Najas flexilis (Slender

Naiad) [1833]

002034 Connemara Bog Complex

SAC

Coastal lagoons [1150]

Reefs [1170]






Euphydryas aurinia (Marsh

Fritillary) [1065]

Salmo salar (Salmon)

[1106]

Lutra lutra (Otter) [1355]


Naiad) [1833]

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Site

Code



Nanojuncetea [3130]

Natural dystrophic lakes and ponds

[3160]

Water courses of plain to montane

levels with the Ranunculion fluitantis

and Callitricho-Batrachion

vegetation [3260]

Northern Atlantic wet heaths with

Erica tetralix [4010]

European dry heaths [4030]

Molinia meadows on calcareous,

peaty or clayey-silt-laden soils

(Molinion caeruleae) [6410]

Blanket bogs (* if active bog) [7130]

Transition mires and quaking bogs

[7140]



Alkaline fens [7230]

Old sessile oak woods with Ilex and

Blechnum in the British Isles [91A0]

002074 Slyne Head Peninsula

SAC

Coastal lagoons [1150]

Large shallow inlets and bays [1160]

Reefs [1170]

Annual vegetation of drift lines

[1210]

Perennial vegetation of stony banks

[1220]

Atlantic salt meadows (Glauco-

Puccinellietalia maritimae) [1330]

Mediterranean salt meadows

(Juncetalia maritimi) [1410]

Embryonic shifting dunes [2110]

Shifting dunes along the shoreline

with Ammophila arenaria (white

dunes) [2120]

Machairs (* in Ireland) [21A0]






Petalophyllum ralfsii

(Petalwort) [1395]


Naiad) [1833]

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Site

Code



Nanojuncetea [3130]

Hard oligo-mesotrophic waters with

benthic vegetation of Chara spp.

[3140]


Juniperus communis formations on

heaths or calcareous grasslands

[5130]

Semi-natural dry grasslands and

scrubland facies on calcareous

substrates (Festuco-Brometalia) (*

important orchid sites) [6210]

Molinia meadows on calcareous,

peaty or clayey-silt-laden soils

(Molinion caeruleae) [6410]

Lowland hay meadows (Alopecurus

pratensis, Sanguisorba officinalis)

[6510]

Alkaline fens [7230]

002265 Kingstown Bay SAC Large shallow inlets and bays [1160]

000330 Tully Mountain SAC European dry heaths [4030]

Alpine and Boreal heaths [4060]

002130 Tully Lough SAC Oligotrophic to mesotrophic standing



Nanojuncetea [3130]


Naiad) [1833]

000328 Slyne Head Islands SAC Reefs [1170]

Halichoerus grypus (Grey

Seal) [1364]

0002998 West Connacht Coast

SAC

Tursiops truncatus

(Common Bottlenose

Dolphin) [1349]

002129 Murvey Machair SAC Machairs (* in Ireland) [21A0]


(Petalwort) [1395]

001257 Dogs Bay SAC Annual vegetation of drift lines

[1210]

Embryonic shifting dunes [2110]

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Site

Code


Shifting dunes along the shoreline

with Ammophila arenaria (white

dunes) [2120]

Fixed coastal dunes with

herbaceous vegetation (grey dunes)

[2130]


001251 Cregduff Lough SAC Transition mires and quaking bogs

[7140]


Naiad) [1833]

000324 Rosroe Bog SAC Blanket bogs (* if active bog) [7130]



001311 Rusheenduff Lough Oligotrophic to mesotrophic standing



Nanojuncetea [3130]


Naiad) [1833]

001228 Aughrusbeg Machair and

lake




Northern Atlantic wet heaths with

Erica tetralix [4010]

001309 Omey Island Machair Machairs (* in Ireland) [21A0]

Hard oligo-mesotrophic waters with

benthic vegetation of Chara spp.

[3140]


(Petalwort) [1395]

002118 Barnahallia Lough Oligotrophic to mesotrophic standing



Nanojuncetea [3130]


Naiad) [1833]

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Table 4.0: SPAs located within 15km of Clifden WwTP

Site Code Site Name Special Conservation Interests

004159 Slyne Head to Ardmore

Point Islands SPA

Barnacle Goose (Branta leucopsis) [A045]

Sandwich Tern (Sterna sandvicensis) [A191]

Arctic Tern (Sterna paradisaea) [A194]

Little Tern (Sterna albifrons) [A195]

004231 Inishbofin, Omey Island and

Turbot Island SPA

Corncrake (Crex crex) [A122]

004221 Illaunnanoon SPA Sandwich Tern (Sterna sandvicensis) [A191]

004170 Cruagh Island SPA Manx Shearwater (Puffinus puffinus) [A013]

Barnacle Goose (Branta leucopsis) [A045]

004181 Connemara Bog Complex

SPA

Cormorant (Phalacrocorax carbo) [A017]

Merlin (Falco columbarius) [A098]

Golden Plover (Pluvialis apricaria) [A140]

Common Gull (Larus canus) [A182]

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Figure 1.0: Natura 2000 Sites

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Possible Effects of the Stormwater Tank Overflow on Natura 2000 Sites

The purpose of this section of the screening is to examine the possibility that the stormwater tank

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

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

identified.

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

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

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

source-pathway-receptor model, the qualifying interests of two Natura 2000 sites have

connectivity with the overflow discharge:

Twelve Bens/Garraun Complex SAC

West Connacht Coast SAC

The Conservation Objectives of these sites were reviewed as part of this Screening Assessment:

NPWS (2016) Conservation objectives for The Twelve Bens/Garraun Complex SAC

[002031]. Generic Version 5.0. Department of Arts, Heritage, Regional, Rural and

Gaeltacht Affairs.

NPWS (2015) Conservation Objectives: West Connacht Coast SAC 002998. Version 1.

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

The Clifden WwTP and associated overflows is not directly connected with or necessary to the

management of the site for nature conservation.

Direct, Indirect or Secondary Impacts

The stormwater tank outfall discharges into the primary outfall pipe. As such existing ambient

monitoring is likely to detect any significant changes in water quality. It is noted that the

transitional and coastal waters of Clifden Bay are classed as Unpolluted by the EPA and meet

relevant Surface Water Regulations standards for Good status. They are also monitoring by the

SFPA and Marine Institute and maintain the water quality and shellfish flesh standards required

for a classified production area for shellfish. Bathing water quality has failed to meet the required

standards on a number of occasions in 2016 and there is the possibility that this has

corresponded with times when the overflow has been operational. In the context, the relevant

qualifying interests are identified below, and the likely impact of the overflow on their

conservation status is considered.

Salmon and Otter are qualifying interest of Twelve Bens/Garraun complex, and would be

associated with the Owenglin river which is designated as part of this SAC and is located ca.

600m to the east of the outfall. Salmon associated with the SAC would pass through the Clifden

Bay area on migration to and from the Owenglin River. Otter associated with the SAC may

forage in Clifden Bay. Bottlenose Dolphin are the qualifying interest of West Connacht coast

SAC ca. 4.7km to the west of the main outfall pipe and there is the possibility that they may

occasionally enter Clifden Bay.

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The risk to these mobile species from the overflow is considered negligible. Ambient water

quality monitoring indicates there has been no overall water quality deterioration in the bay.

Given the stormwater overflow would only operate in times of heavy rain, any effluent released

would be extremely diluted. Its discharge via the main outfall pipe also provides significant

dispersal and dilution for any overflow discharge. While there may be a plume of reduced-

quality water at times when the overflow is operational, salmon would pass quickly through the

area. The overflow therefore is unlikely to impact any migrating salmon that would be moving

through the area should their movements through the bay happen to coincide with a time when

the overflow is operational. While otter associated with the SAC may rely to some extent on fish

stocks in the Clifden Bay area, it is not expected that the operation of the overflow would have

any impact on the diversity, abundance or biomass of fish species and no direct/indirect impacts

to otter are predicted. While their conservation status is not defined for this SAC, they are at

favourable conservation status nationally. Similarly, bottlenose dolphin may rely to some extent

on fish stocks in the area. This species is at favourable conservation status in the SAC and the

designated area and core population is located ca. 4.7km west of the overflow/primary outfall.

Given the dilution and dispersal available for any effluent in intervening coastal waters, no impact

to the population is predicted. Any occasional movement through the Clifden Bay area in the

vicinity of a diluted overflow discharge is not expected to affect the conservation status of this

species.

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

2007) the waste water discharged from the Clifden stormwater tank overflow does not have the

potential to impact the relevant qualifying interests identified, and therefore will no affect the

conservation objectives of the Twelve Bens/Garraun Complex SAC or West Connacht Coast

SAC. No significant adverse impacts on the Annex II species are anticipated as a result of the

stormwater overflow from Clifden WwTP.

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

identified within 15km of the overflow discharge location is considered likely due to lack of

hydrological connection between the discharge and the relevant terrestrial SACs and SPAs, or

the dilution and dispersion provided by intervening coastal waters for remote coastal/marine

SACs and SPA sites.

Possible Cumulative Impacts with other Plans and Projects in the Area

As part of Stage 1 Screening, in addition to the stormwater overflow, other relevant projects and

plans in the relevant region must also be considered. This step aims to identify at this early stage

any possible significant effects on the Natura 2000 Sites from the waste water discharge in-

combination or cumulative with other plans and projects. Existing plans which have been

examined include:

Galway County Development Plan 2015-2021;

West Galway Management Unit Action Plan3; and

Clifden Tidy Towns Biodiversity Plan 2014-2018.

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

%202015/WRBD%20RBMP%202010/Water%20Management%20Unit%20Action%20Plans/West%20Galway%20WMU_190310.pdf

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

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

significant effects on the integrity of the Natura 2000 network.

The potential cumulative/in-combination impacts with the existing Clifden WwTP and wastewater

network were also considered. The primary discharge is now compliant with the licence ELV’s

and the requirements of the UWWT Directive. Appropriate Assessment was carried out for the

new scheme and, once operated within the terms of its licence, it was concluded there would be

no adverse effects on any Natura 2000 site. The overflow has no potential to contribute to

cumulative impacts with the existing wastewater infrastructure at Clifden.

Galway County Council online planning maps were reviewed for any significant developments

that have the potential to contribute to cumulative impacts. A school development was granted

permission in 2015 (Planning Ref 15671). The development was subject to Appropriate

Assessment with no significant effects predicted for any Natura 2000 site. A packaged

Envirocare sewage treatment system will be installed as part of the development.

Screening Assessment Table 5.0 provides a summary of the likely significant impact of the current overflow discharge on

the conservation objectives of the Natura 2000 sites potentially linked to the Clifden WwTP

stormwater tank overflow as identified in Tables 3.0 and 4.0.

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Table 5.0: Potential Significant Impacts on Natura 2000 sites from the Clifden Overflow Discharge

Site Name Direct Impacts

Indirect/ Secondary

Resource Requirements (Drinking Water Abstraction Etc.)

Emissions (Disposal to Land, Water or Air)

Excavation Requirements

Transportation Requirements

Duration of Construction, Operation, Decommissioning

Twelve Bens/Garraun

Complex SAC

No impact on qualifying interest







Connemara Bog Complex

SAC








Slyne Head Peninsula

SAC








Kingstown Bay SAC No impact on qualifying interest







Tully Mountain SAC No impact on qualifying interest







Tully Lough SAC No impact on qualifying interest







Slyne Head Islands SAC No impact on qualifying interest







West Connacht Coast

SAC








Murvey Machair SAC No impact on qualifying interest







Dogs Bay SAC No impact on qualifying interest







Cregduff Lough SAC No impact on qualifying interest







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Site Name Direct Impacts

Indirect/ Secondary

Resource Requirements (Drinking Water Abstraction Etc.)

Emissions (Disposal to Land, Water or Air)

Excavation Requirements

Transportation Requirements

Duration of Construction, Operation, Decommissioning

Rosroe Bog SAC No impact on qualifying interest







Rusheenduff Lough No impact on qualifying interest







Aughrusbeg Machair and

lake








Omey Island Machair No impact on qualifying interest







Barnahallia Lough No impact on qualifying interest







Slyne Head to Ardmore

Point Islands SPA








Inishbofin, Omey Island

and Turbot Island SPA








Illaunnanoon SPA No impact on qualifying interest







Cruagh Island SPA No impact on qualifying interest







Connemara Bog Complex

SPA








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Likely Changes to the Natura 2000 Site(s)

The likely changes that will arise from the Clifden overflow discharge have been examined in the

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

2000 Sites. Overall, it has been found that the current overflow discharge will not affect the

integrity of the identified Natura 2000 Sites, alone or in-combination with other plans or projects.

Table 6.0: Likely Affect on Natura 2000 Sites

Site Name Reduction

of Habitat

Area

Disturbanc

e to Key

Species

Habitat or

Species

Fragmentation

Reductio

n in

Species

Density

Changes in

Key Indicators

of

Conservation

Value (Water

Quality Etc.)

Climate

Change

Twelve Bens/Garraun

Complex SAC

None None None None None None

Connemara Bog

Complex SAC


Slyne Head Peninsula

SAC


Kingstown Bay SAC None None None None None None

Tully Mountain SAC None None None None None None

Tully Lough SAC None None None None None None

Slyne Head Islands SAC None None None None None None

West Connacht Coast

SAC


Murvey Machair SAC None None None None None None

Dogs Bay SAC None None None None None None

Cregduff Lough SAC None None None None None None

Rosroe Bog SAC None None None None None None

Rusheenduff Lough None None None None None None

Aughrusbeg Machair

and lake


Omey Island Machair None None None None None None

Barnahallia Lough None None None None None None

Slyne Head to Ardmore

Point Islands SPA


Inishbofin, Omey Island

and Turbot Island SPA


Illaunnanoon SPA None None None None None None

Cruagh Island SPA None None None None None None

Connemara Bog

Complex SPA


Elements of the Project where the Impacts are Likely to be Significant

No elements of the current overflow discharge are likely to cause significant impacts on NATURA

2000 Sites.

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Screening Conclusions and

Statement

The likely impacts that will arise from the current stormwater overflow discharge have been

examined in the context of a number of factors that could potentially affect the integrity of the

Natura 2000 network. None of the sites within 15km of the discharge location will be adversely

affected. A finding of No Significant Effects Matrix has been completed and is presented in next

section of this Screening Statement.

On the basis of the findings of this Screening for Appropriate Assessment of Natura 2000 Sites, it

is concluded that the current overflow discharge from the Clifden overflow will not have a

significant effect on the Natura 2000 network and a Stage 2 Appropriate Assessment is not

required.

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Finding of No Significant Effects

Report Matrix

Name of project or plan

Name and location of Natura 2000 site Twelve Bens/Garraun Complex SAC

West Connacht Coast SAC

Description of the project or plan The new Clifden WwTP was commissioned in 2015. The

new plant discharges via a long-sea outfall into the

marine environment in the Owenglin estuary channel.

The discharge location is to a transitional water body

(IE_WE_270_0100).

The agglomeration is served by a wastewater treatment

plant with a Plant Capacity PE of 6,000. The treatment

process includes the following:-

preliminary treatment (including screening / grit

removal)

secondary treatment -. SBR

chemical dosing for phosphorus removal

tertiary treatment – UV treatment

This assessment relates to an overflow from the

stormwater tank which connects to the main outfall

discharge pipe downstream of the UV installation. The

tank provides sufficient stormwater storage (>2hrs at

3DWF), however in 2016 the number of overflows

exceeded the requirement for bathing waters. Options

for reducing the frequency of these overflows are

currently being investigated.

Is the project or plan directly

connected with or necessary to the

management of the site?

No.

Are there other projects or plans that

together with the project or plan being

assessed could affect the site?

No.

The Assessment of Significance of Effects

Describe how the project or plan

(alone or in combination) is likely to

affect the European Site(s).

The stormwater tank outfall discharges into the primary

outfall pipe. As such existing ambient monitoring is likely

to detect any significant changes in water quality. It is

noted that the transitional and coastal waters of Clifden

Bay are classed as Unpolluted by the EPA and meet

relevant Surface Water Regulations standards for Good

status. They are also monitoring by the SFPA and

Marine Institute and maintain the water quality and

shellfish flesh standards required for a classified

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production area for shellfish. Bathing water quality has

failed to meet the required standards on a number of

occasions in 2016 and there is the possibility that this has

corresponded with times when the overflow has been

operational. In the context, the relevant qualifying

interests are identified below, and the likely impact of the

overflow on their conservation status is considered.

Salmon and Otter are qualifying interest of Twelve

Bens/Garraun complex, and would be associated with

the Owenglin river which is designated as part of this

SAC and is located ca. 600m to the east of the outfall.

Salmon associated with the SAC would pass through the

Clifden Bay area on migration to and from the Owenglin

River. Otter associated with the SAC may forage in

Clifden Bay. Bottlenose Dolphin are the qualifying

interest of West Connacht coast SAC ca. 4.7km to the

west of the main outfall pipe and there is the possibility

that they may occasionally enter Clifden Bay.

Explain why these effects are not

considered significant. The risk to these mobile species from the overflow is

considered negligible. Ambient water quality monitoring

indicates there has been no overall water quality

deterioration in the bay. Given the stormwater overflow

would only operate in times of heavy rain, any effluent

released would be extremely diluted. Its discharge via

the main outfall pipe also provides significant dispersal

and dilution for any overflow discharge. While there may

be a plume of reduced-quality water at times when the

overflow is operational, salmon would pass quickly

through the area. The overflow therefore is unlikely to

impact any migrating salmon that would be moving

through the area should their movements through the bay

happen to coincide with a time when the overflow is

operational. While otter associated with the SAC may

rely to some extent on fish stocks in the Clifden Bay area,

it is not expected that the operation of the overflow would

have any impact on the diversity, abundance or biomass

of fish species and no direct/indirect impacts to otter are

predicted. While their conservation status is not defined

for this SAC, they are at favourable conservation status

nationally. Similarly, bottlenose dolphin may rely to some

extent on fish stocks in the area. This species is at

favourable conservation status in the SAC and the

designated area and core population is located ca. 4.7km

west of the overflow/primary outfall. Given the dilution

and dispersal available for any effluent in intervening

coastal waters, no impact to the population is predicted.

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Any occasional movement through the Clifden Bay area

in the vicinity of a diluted overflow discharge is not

expected to affect the conservation status of this species.

In accordance with the Waste Water Discharge

(Authorisation) Regulations 2007 (S.I. No. 684 of 2007)

the waste water discharged from the Clifden stormwater

tank overflow does not have the potential to impact the

relevant qualifying interests identified, and therefore will

no affect the conservation objectives of the Twelve

Bens/Garraun Complex SAC or West Connacht Coast

SAC. No significant adverse impacts on the Annex II

species are anticipated as a result of the stormwater

overflow from Clifden WwTP.

List of agencies consulted: provide

contact name and telephone or e-mail

address.

N/A

Response to consultation. N/A

Data Collected to Carry Out the Assessment

Who carried out the assessment? Qualified Ecologist, Irish Water

Sources of data NPWS database;

EPA database;

WFD Ireland database; and

Information from Irish Water.

Level of assessment completed Desktop survey

Where can the full results of the

assessment be accessed and viewed?

EPA

Overall Conclusion Stage 1 Screening indicates that the Clifden WwTP

stormwater overflow discharge will not have a significant

negative impact on the Natura 2000 network. Therefore, a

Stage 2 'Appropriate Assessment' under Article 6(3) of the

Habitats Directive 92/43/EEC is not required.

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