for inspection purposes only. consent of copyright owner … · lough gash sac site synopsis (npws)...

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Irish Water

Report

Natura Impact Statement as part of the Newmarket-on-Fergus

Wastewater Discharge Licence (D0079-01)

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2 | Irish Water Natura Impact Statement – Newmarket on Fergus

Contents

Introduction 3

Legislative Context 3

Methodology 5

Guidance Followed 5

Stages Involved in the Appropriate Assessment Process 6

Field Walkover Surveys 6

Consultation 6

Stage 1: Screening 7

Stage 2: Appropriate Assessment 8

Description of the Project 8

Description of the Receiving Environment and Monitoring Results 9

Waste Assimilative Capacity 11

Field Walkover Survey 11

Description of the Natura 2000 Site Affected 12

Lough Gash SAC Site Synopsis (NPWS) 12

Description of the Conservation Interests of the SAC 13

Annex I Habitats 13

Lower River Shannon SAC Site Synopsis (NPWS) 14

Description of the Conservation Interests of the SAC 18

Annex I Habitats 18

Annex II Species 20

River Shannon and River Fergus Estuary SPA Site Synopsis (NPWS) 26

Description of the Conservation Interests of the SPA 27

Impact Prediction 32

Impacts on Water Quality 32

Impacts on Annex I Habitats 34

Impacts on Annex II Species 35

Impacts on designated features of the SPA 35

Mitigation Measures 38

Stage 2 Appropriate Assessment Conclusion Statement 38

References 39

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Introduction

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

Water Treatment Plant (WwTP), located at Newmarket on Fergus, County Clare, for the

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

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

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

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

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

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

Directive.

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

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

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

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

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

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

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

The field survey and report was completed by a qualified ecologist, and full member of the

CIEEM, working for Tobins Consulting Engineers on behalf of Irish Water.

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

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

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

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

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

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

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

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

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

Appropriate Assessment (AA):

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

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

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

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

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

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

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

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

public.

Article 6(4) states:

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

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

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

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

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

Commission of the compensatory measures adopted.

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Methodology

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

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

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

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

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

Agency, (EPA, 2009).

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

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

2010).

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

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

Local Government, (DoEHLG, 2008).

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

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

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

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

(EC, 2000b).

Assessment of plans and projects significantly affecting Natura 2000 sites:

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

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

Brussels (EC, 2001).

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

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

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

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

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

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

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

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

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

2011).

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

Commission (EC, 2013).

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

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

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

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

plans.

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

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

that site to be brought forward to Stage 2.

Stage 2: Appropriate Assessment

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

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

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

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

impacts

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

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

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

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

Stage 3: Assessment of Alternatives

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

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

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

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

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

Stage 4: Assessment Where Adverse Impacts Remain

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

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

proceed.

Field Walkover Surveys Field walkover surveys were undertaken by a suitably qualified ecologist on the 23

rd of April 2015

to identify the potential for qualifying species and habitats in the surrounding environs of the

WwTP discharge.

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

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

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

competent authority has already commenced.

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Inland Fisheries Ireland (IFI) Limerick division identified that sensitive species in the area include

salmonids and three lamprey species.

Stage 1: Screening

Screening for Appropriate Assessment was undertaken by the Environmental Protection Agency

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

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

Lough Gash Turlough SAC, the Lower River Shannon SAC and River Shannon and River

Fergus Estuary SPA. This determination was based on the following:

The limited availability of ambient monitoring information available to demonstrate any

impacts that the discharge may have on the European Sites.

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

Habitats Directive, the current WwTP discharge at Newmarket on Fergus will be brought forward

for a Stage 2 Appropriate Assessment.

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Stage 2: Appropriate Assessment

Lough Gash Turlough SAC, the Lower River Shannon SAC and River Shannon and River

Fergus Estuary SPA, which have been determined as requiring AA, are described and all the

potential impacts resulting from the Newmarket-on-Fergus WwTP discharge are discussed in

relation to the conservation objectives of these designated sites.

Description of the Project

Newmarket on Fergus is located approximately 11.5km southeast of Ennis, Co. Clare. The

WwTP is located in Newmarket on Fergus in the townland of Boheroroan.

Data provided by Irish Water indicates that the current (2015) population equivalent for the

agglomeration is 2,167p.e. increasing to 2,332p.e. by 2021. Based on a loading of 225l/pp/day

the dry weather flow for the current discharge is calculated at 0.00564m3/sec. The 95-percentile

flow for the receiving Treannahow stream downstream of Lough Gash turlough as obtained from

the J.B. Barry (2014) wastewater discharge assessment report is 0.014m3/sec. No flow data was

available for the Mill stream.

The Newmarket on Fergus Wastewater Treatment Plant was constructed in the 1980’s and was

subsequently upgraded in 2010 to treat a population equivalent of 5000. The plant comprises of

a domestic wastewater treatment plant including primary, secondary and ferric sulphate

treatment (phosphate reduction as part of the upgrade in 2010). The treatment works now

consists of the following elements:

The inlet pumping station, with an overflow to a storm tank, which holds excess flows

during heavy rainfall. The flows from the storm tanks are fed back through the system

when the rainfall abates.

Screening on the inlet works.

Forward feed pumping station, which delivers flow to the oxidation ditch and an aeration

chamber, both of which provide secondary treatment of the waste water load in the

system.

Flow from the secondary treatment elements of the plant go to a clarifier, in which scum

is skimmed from the settled wastewater and sludge settlement is completed.

Discharge from the clarifier is to the discharge outlet, which is located on an inflowing

stream (the Mill stream) into Lough Gash.

Sludge is removed from the secondary treatment elements (oxidation ditch and aeration

basin) and from the clarifiers to a sludge holding tank. Sludge processing generally

takes place in Sixmilebridge WwTP. Some limited processing can be undertaken at the

site.

Ferric sulphate is dosed into the feed pipe to the aeration tank to facilitate phosphorus

removal from the wastewater.

The final effluent from the domestic wastewater treatment plant discharges into an outfall pipe

and is discharged into Lough Gash via the Mill stream. The National Grid Reference for the

Primary Discharge Point at the end of the outfall pipe is E139,196 N167,687.

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Secondary emergency discharges may also take place from a storm overflow pipe located at the

inlet works in the wastewater treatment plant.

Effluent data from 2013 and 2014 is presented in Table 1.0 together with Urban Wastewater

Treatment Regulations (UWWT) limit values.

Table 1.0: Newmarket on Fergus WwTP Effluent Monitoring Data (mg/l)

Date pH BO

D m

g/l

O2

CO

D

mg

/l O

2

SS

mg

/l

Am

mo

nia

To

tal

Nit

rog

en

Ort

ho

ph

os

ph

ate

To

tal

Ph

os

ph

oru

s

UWWT EQS

25 125 35

15*

2*

10/06/14 7.43 2 26 10 0.04 10.5 1.75 1.8

07/05/14 7.48 - 24 6 - 16.1 - 1.96

08/04/14 7.68 4.2 41 11 - 12.9 - 0.44

11/03/14 7.45 2.2 25 16 - 5.9 - 0.4

11/02/14 7.97 3.2 19 12 - 8.4 - 0.36

14/01/14 7.81 4.3 12 2 - 9 - 0.46

03/12/13 7.32 - 30 9 0.03 13.3 0.046 0.18

11/11/13 7.75 2 - 5 - 8.9 - 0.22

01/10/13 6.85 12.4 53 21 - 42.3 - 1.8

03/09/13 7 4.1 33 2 - 36 - 2.84

06/08/13 7.84 4.2 19 3 - 29.9 - 1.08

16/07/13 7.55 - 27 19 - 8.9 - 1.56

02/07/13 7.49 2 24 8 - 7.3 - 0.96

04/06/13 7.95 - 21 4 - 9.3 - 5

14/05/13 7.83 5.3 40 23 - 10.1 - 2.12

30/04/13 7.57 9.8 58 9 - 24.1 - 1.4

09/04/13 7.79 - 23 13 - 19.5 - 2.32

19/03/13 7.57 3 25 8 -

- -

05/03/13 7.64 - 18 10 - 6.25 - 3.32

05/02/13 7.55 - - 6 - 7.23 - 0.32

15/01/13 7.43 - - - - 7.09 - 0.54

*Limits set for sensitive waters listed in Schedule 1 of the Urban Waste Water Treatment (Amendment)

Regulations 2010 (S.I. No. 48/2010).

The effluent discharge is in compliance with the Urban Wastewater Treatment Regulations

(2001) (S.I. No. 254/2001). The WwTP does not discharge to a sensitive water listed on

Schedule 1 of the Urban Waste Water Treatment (Amendment) Regulations 2010 (S.I. No.

48/2010).

Description of the Receiving Environment and Monitoring Results

The WwTP discharges into Lough Gash turlough, a seasonal water body which can dry out

during late summer. When the turlough is flooded water exits via a man made channel at the

head of the Treannahow stream to the west of the turlough. The path of the groundwater was

investigated using dye tracing studies in 2000. The results indicate that the line of flow from the

turlough runs approximately south-westerly via both overground and underground channels.

The water exiting the turlough then disappears down a swallow hole approximately 170m

downstream of the Lough Gash outlet, and a spring feeding the Treannahow stream, likely to

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contain the flow from Lough Gash, resurfaces ca. 1km downstream of the outlet (J.B. Barry,

2014). In periods of low flow the WwTP is effectively discharging directly to groundwater, while

in periods of high flow the discharge may not reach groundwater and may flow directly via the

man-made channel to the Trennahow stream. (Geosyntec, 2014)

There is no water quality monitoring data available for Lough Gash Turlough. It is not monitored

by the EPA and has not been assigned a water quality status. The EPA does not monitor the Mill

stream or the Treannahow stream (IE_SH_27_88) for water quality.

The WWDL Application (Regulation 18(3)(b) response) include results of a sampling event on the

Mill stream in 2010 prior to the completion of the WwTP upgrade.

Table 2.0:Monitoring Data both Upstream and Downstream of WwTP Discharge

Pa

ram

ete

r

Su

sp

en

de

d S

oli

ds

CO

D

pH

To

tal

Ox

idis

ed

Nit

rog

en

Mo

lyb

da

te R

eac

tive

Ph

os

ph

oru

s

Am

mo

nia

BO

D

Nit

rite

Nit

rate

mg/l mg/l pH Units mg/l N mg/l P mg/l N mg/l mg/l mg/l

SW EQS

4.5-9

≤0.14 (good) ≤0.090 (high)

≤2.6 (good) ≤2.2 (high)

Upstream 4 9 7.89 0.055 Bld* 0.068 0.28 0.001 0.55

Downstream 3 32 7.94 1.65 Bld* 0.058 0.83 0.011 1.64

*Bld = Below limit of detection

A Tobins ecologist sampled the Mill stream for water quality upstream of the WwTP discharge.

The outfall enters the lower Mill stream channel/Lough Gash in an area of wet woodland and

therefore there was no suitable location downstream of the discharge for kick sampling or

assigning a Q rating.

Upstream of the WwTP discharge the Mill stream is ca 2m wide, 30-60cm deep, with a

fast riffle-type flow and a cobble/stone-dominated substrate. Instream vegetation

included fools watercress Apium nodiflorum, the moss Fontinalis antipyretica and some

Cladophora spp. algae on larger rocks. The macroinvertebrate fauna, dominated by

relatively pollution-tolerant taxa, indicates a Q3 rating would apply to this watercourse.

The Water Framework Directive mapping website1 indicate that the Lough Gash waterbody

(IE_SH_27_88) has overall High status but is ‘1a – At Risk’. The Fergus Estuary transitional

waterbody (IE_SH_060_1100), has an overall status of Moderate with a risk score indicating the

estuary is ‘Strongly expected to achieve good status’. Therefore, the objective under the Water

Framework Directive (2000/60/EC) is to restore the river to ‘Good Status’.

1 http://watermaps.wfdireland.ie/NsShare_Web/Viewer.aspx?Site=NsShare&ReloadKey=True

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Photo 1: Mill stream upstream WwTP discharge Photo 2: Lough Gash downstream

of WwTP discharge

Waste Assimilative Capacity

It was not possible to carry out reliable waste assimilative capacity calculations for either the Mill

stream of the Treannahow stream.

With regard to the Millss tream flow data was not available and ambient monitoring data was

limited. Futhermore the discharge enters the stream directly upstream of Lough Gash where

flow conditions change completely, with the discharge effectively being into a lake waterbody

rather than a stream.

With regard to the Treannahow stream J.B. Barry (2014) note that flow figures may be unreliable

for this watercourse due to the karst environment. Ambient monitoring data for this stream is not

available. Due to the potential flow issues there appears to be doubt regarding the ability of the

Trennahow or Ballynacraga streams to assimilate the discharge (J.B. Barry, 2014).

Field Walkover Survey

Newmarket on Fergus WwTP is located directly adjacent to the boundary of Lough Gash SAC,

which is designated for Annex I turlough habitat, and discharges directly into it. Marginal habitats

around the turlough in the vicinity of the discharge include wet woodland, reedbeds and wet

grassland. The wet woodland was dominated by willows Salix spp. and alder Alnus glutinosa

interspersed with stands of reeds Phragmites australis and flag iris Iris pseudacorus. The

turlough marginal/littoral areas supported a diverse range of aquatic plants including water

crowfoot Ranunculs sp., brooklime Veronica beccabunga, great yellow-cress Rorippa amphibia,

water mint Mentha aquatica, watercress Rorippa nasturtium-aquaticum, water horsetail

Equisetum fluviatile, marsh marigold Caltha palustris and duckweed Lemna minor. Adjacent wet

grassland, which also forms part of the SAC, appeared to be grazed by horses had been heavily

disturbed by machinery and was subject to illegal dumping. Common plant species included

meadowsweet Filipendula ulmaria, hardrush Juncus inflexus, silverweed Potentilla anserina,

dock Rumex obtusifolius, flag iris Iris pseudacorus and clover Trifolium pratense. No signs of any

Annex II species were noted.

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Fish Stocks

The Fergus estuary was surveyed in 2014 by IFI (Kelly et al, 2015). A total of 19 fish species

were recorded with sprat being the most abundant species followed by sand goby and flounder.

Based on fish populations present the Fergus estuary was assigned a draft classification of Good

status. The River Fergus is a designated salmonid water under the European Communities

(Quality of Salmonid Waters) Regulations of 1988 (S.I. No. 293, 1988). The River Fergus is a

notable salmon fishery (O’Reilly, 2004).

Figure 1: Site location relative to European Sites (Source: NPWS Mapviewer)

Description of the Natura 2000 Site Affected

Lough Gash SAC Site Synopsis (NPWS)

Lough Gash Turlough lies in the low landscape west of Newmarket-on-Fergus, Co. Clare. The

turlough has a very flat basin and is overlooked by houses to the east and pasture to the west.

The shore of the turlough rises as a stony slope on the west side, where outcropping rocks are

visible. Water rises mainly from the rocks at the southern end, but there is overground flow also -

one stream discharges from the town's sewage works

This turlough is particularly late-draining, and as a result supports a very distinctive plant

community. The central zone is covered by an open vegetation of Red Goosefoot (Chenopodium

rubrum), Small Water-pepper (Polygonum minus), Trifid Bur-marigold (Bidens tripartita), Fine-

leaved Water-dropwort (Oenanthe aquatica), Toad Rush (Juncus bufonius) and the rare Northern

Yellow-cress (Rorippa islandica). The rare annual moss Ephemerum cohaerens occurs on open

mud.

On the slightly higher ground, around the centre of the turlough, Fine-leaved Water-dropwort

dominates, with Great Yellow-cress (Rorippa amphibia), Thread-leaved Water-crowfoot

(Ranunculus trichophyllus), Pink Water-speedwell (Veronica catenata) and some Amphibious

Bistort (Polygonum amphibium) also occurring.

Lower River Shannon SAC & River Shannon and River Fergus Estuary SPA

Lough Gash SAC

WwTP

Treannahow Stream

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Parts of the shore have a more grassy vegetation, comprising Floating Sweet-grass (Glyceria

fluitans), Creeping Bent (Agrostis stolonifera), Marsh Foxtail (Alopecurus geniculatus) and the

rare Orange Foxtail (Alopecurus aequalis) (listed in the Flora (Protection) Order, 1999). This

grades into a narrow fringe of Hairy Sedge (Carex hirta) and cinquefoil (Potentilla spp.) species.

The streams introduce a different flora; by the stream from the sewage works such species as

Fool's Water-cress (Apium nodiflorum), Reed Canary-grass (Phalaris arundinacea), Yellow Iris

(Iris pseudacorus) and Nodding Bur-marigold (Bidens cernua) are found, while at the southern

end there is a marshy area with Willows (Salix spp.) and sedges (Carex spp.).

Gadwall, Pochard and Tufted Duck are regular in winter; Coot, Moorhen, Mallard, Snipe and a

high number of Mute Swan (71 individuals, average peak from 3 counts, 1984/85 - 1986-87) are

also found.

Lough Gash Turlough is one of the latest turloughs to dry out in any year and may fail to do so

sometimes; as such it is highly rated for being at one of the extremes of turlough variation, i.e.

wetness. It is also of considerable ecological interest for its eutrophic nutrient status. The annual

flora found at the site is highly distinctive and well-developed: there are only fragments of such

vegetation at other turloughs. The presence of an abundance of the rare Northern Yellow-cress

and of the protected Orange Foxtail (in its only Clare site) is notable.

Description of the Conservation Interests of the SAC

Annex I Habitats

Lough Gash Turlough SAC supports one Annex I habitat:

[3180] Turloughs

Threats identified by NPWS (2013a) are drainage, intensive

grazing and groundwater phosphorus enrichment. Most

turloughs suffer from unfavourable water quality or biological

responses (negative algal or vegetation indicators) mainly

due to nutrient enrichment (NPWS, 2013a). As described

above Lough Gash turlough receives the WwTP discharge

via the Mill stream to the east. While there is no water

quality data for the turlough, the abundance of macrophytes

would indicate mesotrophic-eutrophic conditions.

The turlough habitat is considered to have the potential to be

adversely affected by the Newmarket on Fergus WwTP.

Photo 3: Lough Gash Turlough

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Lower River Shannon SAC Site Synopsis (NPWS)

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 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).

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

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

natural sedimentary lagoon impounded by a low cobble barrier. Seawater enters by percolation

through the barrier and by overwash. This lagoon represents a type which may be unique to

Ireland since the substrate is composed almost entirely of peat. The adjacent shore features one

of the best examples of a drowned forest in Ireland. Aquatic vegetation in the lagoon includes

typical species such as Beaked Tasselweed (Ruppia maritima) and green algae (Cladophora

sp.). The fauna is not diverse, but is typical of a high salinity lagoon and includes six lagoon

specialists (Hydrobia ventrosa, Cerastoderma glaucum, Lekanesphaera hookeri, Palaemonetes

varians, Sigara stagnalis and Enochrus bicolor). In contrast, Shannon Airport Lagoon (2 ha) is an

artificial saline lake with an artificial barrier and sluiced outlet. However, it supports two Red Data

Book species of stonewort (Chara canescens and Chara cf. connivens).

Most of the site west of Kilcredaun Point/Kilconly Point is bounded by high rocky sea cliffs. The

cliffs in the outer part of the site are sparsely vegetated with lichens, Red Fescue, Sea Beet

(Beta vulgaris subsp. maritima), Sea Campion (Silene vulgaris subsp. maritima), Thrift and

plantains (Plantago spp.). A rare endemic type of sea-lavender, Limonium recurvum subsp.

pseudotranswallianum, occurs on cliffs near Loop Head. Cliff-top vegetation usually consists of

either grassland or maritime heath. The boulder clay cliffs further up the estuary tend to be more

densely vegetated, with swards of Red Fescue and species such as Kidney Vetch (Anthyllis

vulneraria) and Common Bird’s-foot-trefoil (Lotus corniculatus).

The site supports an excellent example of a large shallow inlet and bay. Littoral sediment

communities in the mouth of the Shannon Estuary occur in areas that are exposed to wave

action and also in areas extremely sheltered from wave action. Characteristically, exposed

sediment communities are composed of coarse sand and have a sparse fauna. Species richness

increases as conditions become more sheltered. All shores in the site have a zone of sand

hoppers at the top, and below this each of the shores has different characteristic species giving a

range of different shore types.

The intertidal reefs in the Shannon Estuary are exposed or moderately exposed to wave action

and subject to moderate tidal streams. Known sites are steeply sloping and show a good

zonation down the shore. Well developed lichen zones and littoral reef communities offering a

high species richness in the sublittoral fringe and strong populations of the Purple Sea Urchin

Paracentrotus lividus are found. The communities found are tolerant to sand scour and tidal

streams. The infralittoral reefs range from sloping platforms with some vertical steps, to ridged

bedrock with 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).

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

catchments, the Shannon from Killaloe to Limerick (along with some of its tributaries, including a

short stretch of the Kilmastulla River), the Fergus up as far as Ennis, and the Cloon River. These

systems are very different in character: the Shannon is broad, generally slow flowing and

naturally eutrophic; the Fergus is smaller and alkaline; while the narrow, fast flowing Cloon is

acid in nature. The Feale and Mulkear catchments exhibit all the aspects of a river from source to

mouth. Semi-natural habitats, such as wet grassland, wet woodland and marsh occur by the

rivers, but improved grassland is the most common habitat type. One grassland type of particular

conservation significance, Molinia meadows, occurs in several parts of the site and the examples

at Worldsend on the River Shannon are especially noteworthy. Here are found areas of wet

meadow dominated by rushes (Juncus spp.) and sedges (Carex spp.), and supporting a diverse

and species-rich vegetation, including such uncommon species as Blue-eyed Grass

(Sisyrinchium bermudiana) and Pale Sedge (C. pallescens).

Floating river vegetation characterised by species of water-crowfoot (Ranunculus spp.),

pondweeds (Potamogeton spp.) and the moss Fontinalius antipyretica are present throughout

the major river systems within the site. The rivers contain an interesting bryoflora with

Schistidium alpicola var. alpicola recorded from in-stream boulders on the Bilboa, new to Co.

Limerick.

Alluvial woodland occurs on the banks of the Shannon and on islands in the vicinity of the

University of Limerick. The woodland is up to 50 m wide on the banks and somewhat wider on

the largest island. The most prominent woodland type is gallery woodland where White Willow

(Salix alba) dominates the tree layer with occasional Alder (Alnus glutinosa). The shrub layer

consists of various willow species with Rusty Willow (Salix cinerea ssp. oleifolia) and what

appear to be hybrids of S. alba x S. viminalis. The herbaceous layer consists of tall perennial

herbs. A fringe of bulrush (Typha sp.) occurs on the river side of the woodland. On slightly higher

ground above the wet woodland and on the raised embankment remnants of mixed oak-ash-

alder woodland occur. These are poorly developed and contain numerous exotic species but

locally there are signs that it is invading open grassland. Alder is the principal tree species, with

occasional Pedunculate Oak (Quercus robur), elm (Ulmus glabra and U. procera), Hazel

(Corylus avellana), Hawthorn (Crataegus monogyna) and 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

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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.

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.

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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.

Description of the Conservation Interests of the SAC

Annex I Habitats

The Lower River Shannon supports fourteen Annex I habitats:

[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*

The estuarine habitats ‘Estuaries’, ‘Tidal Mudflats

and Sandflats’, Saltmarsh (Atlantic and

Mediterranean Salt Meadows) and Reefs are the

closest designated habitats to the WwTP being

located in the Fergus estuary ca. 4km downstream

of the groundwater flow from Lough Gash (at the

closest point). Given that these are not highly

sensitive habitats with regard to nutrient input, and

the distance involved, there is no potential for these

habitats to be adversely affected by the ongoing

discharge.

Photo 4: River Fergus Estuary

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The other marine and estuarine habitats are all located a significant distance from the potential

groundwater connection between Lough Gash and Fergus estuary, and therefore have no

potential to be adversely affected by the ongoing discharge.

The coastal and terrestrial habitats are not linked in any way to the groundwater flow from Lough

Gash and have no potential to be adversely affected by the ongoing discharge.

Habitats associated with the freshwater section of the SAC (Floating River Vegetation and

Alluvial Forests) are upstream of the Fergus estuary and have no potential to be adversely

affected by the ongoing discharge.

No Annex I habitats of the Lower River Shannon SAC are considered to have the potential to be

adversely affected by the ongoing discharge.

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Table 4.0: Qualifying Habitats along Surveyed Stretch

Site Qualifying Habitats Present within the potential zone of influence of the

WwTP discharge

Lough Gash

SAC

Turlough Upstream No

Downstream Yes

Lower River

Shannon

SAC

Sandbanks Upstream No

Downstream No

Estuaries Upstream No

Downstream Yes

Tidal Mudflats and Sandflats Upstream No

Downstream Yes

Coastal Lagoons* Upstream No

Downstream No

Large Shallow Inlets and Bays Upstream No

Downstream No

Reefs Upstream No

Downstream Yes

Perennial Vegetation of Stony

Banks

Upstream No

Downstream No

Vegetated Sea Cliffs Upstream No

Downstream No

Salicornia Mud Upstream No

Downstream No

Atlantic Salt Meadows Upstream No

Downstream Yes

Mediterranean Salt Meadows Upstream No

Downstream Yes

Floating River Vegetation Upstream No

Downstream No

Molinia Meadows Upstream No

Downstream No

Alluvial Forests Upstream No

Downstream No

Annex II Species

The Lower River Shannon SAC is selected for the following Annex II species:

[1029] Freshwater Pearl Mussel (Margaritifera margaritifera)

[1095] Sea Lamprey (Petromyzon marinus)

[1096] Brook Lamprey (Lampetra planeri)

[1099] River Lamprey (Lampetra fluviatilis)

[1106] Atlantic Salmon (Salmo salar)

[1349] Bottle-nosed Dolphin (Tursiops truncatus)

[1355] Otter (Lutra lutra)

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Freshwater Pearl Mussel (1029)

The distribution of freshwater pearl mussel Margaritifera margaritifera is well known and mapped

in Ireland. There have been no documented population extinctions since before the 1970s,

therefore the species’ range is stable. The population has been in decline for a very long time,

and was likely initiated by early drainage schemes in Ireland (NPWS, 2013b). Pearl mussels

have a complicated life cycle, involving native salmon or trout. The key cause of decline in pearl

mussel populations in Ireland is unsuitable habitat for juvenile mussels after they fall off the gills

of host salmonids (Moorkens, 1999). This stage requires the safety of remaining within the river

bed gravels, before growing to a size that allows the emergence of the filtering siphons into the

open water body. While the juvenile mussels remain within the river bed gravels, they filter the

interstitial water within the gravels. Where the gaps between the gravel and stones gets clogged

with fine silt, either physical (from suspended solids entering the river) or organic (from algal

growth and decay prompted by nutrients in the water), the flow of water in the interstices

becomes very restricted. Without adequate water movement and replacement, oxygen levels are

exhausted and young mussels die.

The freshwater pearl mussel occurs in the Cloon River within the Lower River Shannon. The

Cloon River enters the main Shannon Estuary a significant distance downstream of the WwTP.

These populations therefore have no potential to be impacted by the WwTP discharge.

Sea Lamprey (1095)/River Lamprey (1099)

Sea lamprey Petromyzon marinus (1095) and River lamprey Lampetra fluviatilis (1099) are

anadromous species, spending part of their life cycle in the marine environment and returning to

natal watercourses to spawn. Adult fish can migrate long distances into freshwater but artificial

barriers to passage can result in spawning being confined to downstream of these barriers

(NPWS, 2013b). Spawning of river lampreys starts when the water temperature reaches 10–

11ºC, usually in March and April (Morris & Maitland 1987). The sea lamprey usually spawns in

late May or June, when the water temperature reaches at least 15ºC (Maitland, 2003).

While their distribution is not indicated in the 10K square R36 where the WwTP and Fergus

estuary are located (NPWS, 2013b), they are known to occur further upstream in the River

Fergus. There are historic records of sea lamprey spawning upstream in the River Fergus at

Ennis (Kurz & Costello, 1999). BES/CS (2009) also notes records from ‘Inis Environmental

Services’ of sea and river lamprey occurring in the vicinity of Ennis. Suitable spawning gravels

and juvenile silt beds occur in the freshwaters of the River Fergus. Adult lamprey will therefore

travel through the Fergus estuary in the vicinity of where groundwater flow is likely to be entering

from Lough Gash.

The NPWS (2013b) overall assessment of the conservation status of sea lamprey is 'Bad', with

the overall trend in conservation status and the habitat status is 'Good'. The status of river

lamprey is evaluated as being of 'Favourable' conservation status nationally (NPWS, 2013b).

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Brook Lamprey (1096)

The brook lamprey Lampetra planeri is the smallest of the three lamprey species native to Ireland

and it is the only one of the three species to spend all its life in freshwater (Maitland, 2003).

Brook lamprey completes its life cycle in freshwater, spawning in gravels in the upper reaches of

rivers, with larval development occurring in burrows in soft sediments in slower flowing waters

downstream. Lampreys show a preference for gravel-dominated substratum for spawning, and

mainly silt and sand-dominated substratum for nursery habitat (Harvey & Cowx, 2003). The

spawning season of brook lampreys starts when the water temperatures reach 10–11ºC

(Maitland, 2003). This usually occurs in March/April. Brook lamprey is evaluated as being of

'Favourable' conservation status nationally (NPWS 2013b). Brook lamprey are confined to the

freshwater section of the River Fergus and do not have the potential to be adversely affected by

the WwTP discharge.

Atlantic salmon (1106)

The Atlantic salmon Salmo salar is an anadromous species using rivers to reproduce and as

nursery areas during their juvenile phase (NPWS, 2013b). The River Fergus supports a notable

population of salmon. Suitable physical habitat for spawning and juvenile salmon occurs in the

freshwater sections of the Fergus. The species is dependent on good water quality requiring

clean (Q4) water for spawning and early life stages. Aside from water quality, other threats noted

relate to mortality at sea (NPWS 2013b). This species is evaluated as being of overall 'Bad'

conservation status nationally (NPWS 2013b). Salmon will pass through the Fergus estuary on

their migrations upstream and downstream.

Bottlenose Dolphin (1349)

The size, community structure, distribution and habitat use of bottlenose dolphin inhabiting the

Lower River Shannon are well understood (NPWS, 2012a). The population is considered

resident within the site with dolphin groups present in the estuary throughout the year, and

repeated occurrence of known individuals within and between years. The most recent population

estimates 107 (+/- 12) individuals based on a survey carried out in 2010. The population is

confined to the Shannon estuary a significant distance downstream of the WwTP (Berrow et al,

2010).

Otter (1355)

Otter are known to occur throughout the freshwater sections of the River Fergus. In the Fergus

estuary a 10m terrestrial buffer along shoreline (above HWM and along river banks) has been

identified as critical for otters (NPWS, 2013b). While no evidence of this species was observed

during the site visit, and NPWS(2013b) or the NBDC database does not indicate its distribution in

the 10km square R36 where the site is located, suitable habitat is present in the vicinity of the

WwTP and given this species wide territorial range populations associated with the Lower River

Shannon SAC could potentially use Lough Gash and connecting surface waters. Otters have

two basic requirements: aquatic prey and safe refuges where they can rest. This species is

dependent on fish stocks which are ultimately dependent on water quality. The overall

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

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Annex II species assessed as having the potential to be impacted by the WwTP are sea lamprey,

river lamprey, Atlantic salmon and otter.

Table 5.0: Qualifying Species along Surveyed Stretch

Site Qualifying

Species

Observed or signs of species

presence

Suitable Habitat Present

Lower River

Shannon SAC

Freshwater

Pearl Mussel

Upstream No Upstream No

Downstream No Downstream No

Sea Lamprey Upstream No Upstream No

Downstream No Downstream Yes

Brook Lamprey Upstream No Upstream No


River Lamprey Upstream No Upstream No


Atlantic Salmon Upstream No Upstream No


Bottle-nosed

Dolphin

Upstream No Upstream No


Otter Upstream Yes Upstream Yes


Conservation Objectives of the SAC’s

Article 6 of the Habitats Directive states that:

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

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

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

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

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

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

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

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

monitoring of key species and habitats.

Favourable conservation status of a habitat is achieved when:

Its natural range, and area it covers within that range, are stable or increasing;

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;

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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 generic conservation objective is to maintain or restore the favourable conservation

condition of the Annex I habitat(s) and/or the Annex II species for which the SAC’s have been

selected:

Lough Gash SAC:

[3180] Turloughs (conservation status: inadequate, stable)

Lower River Shannon SAC:

[1110] Sandbanks (conservation status: favourable)

[1130] Estuaries (conservation status: inadequate, improving)

[1140] Tidal Mudflats and Sandflats (conservation status: inadequate, improving)

[1150] Coastal Lagoons* (conservation status: bad, stable)

[1160] Large Shallow Inlets and Bays (conservation status: inadequate, improving)

[1170] Reefs (conservation status: bad, declining)

[1220] Perennial Vegetation of Stony Banks (conservation status: inadequate, stable)

[1230] Vegetated Sea Cliffs (conservation status: inadequate, stable)

[1310] Salicornia Mud (conservation status: inadequate, declining)

[1330] Atlantic Salt Meadows (conservation status: favourable)

[1410] Mediterranean Salt Meadows (conservation status: inadequate, stable)

[3260] Floating River Vegetation (conservation status: inadequate, declining)

[6410] Molinia Meadows (conservation status: bad, declining)

[91E0] Alluvial Forests* (conservation status: bad, improving)

[1029] Freshwater Pearl Mussel (Margaritifera margaritifera) (conservation status: bad,

declining)

[1095] Sea Lamprey (Petromyzon marinus) (conservation status: bad, stable)

[1096] Brook Lamprey (Lampetra planeri) (conservation status: favourable)

[1099] River Lamprey (Lampetra fluviatilis) (conservation status: favourable)

[1106] Atlantic Salmon (Salmo salar) (conservation status: inadequate, stable)

[1349] Bottle-nosed Dolphin (Tursiops truncatus) (conservation status: favourable)

[1355] Otter (Lutra lutra) (conservation status: favourable)

Detailed conservation objectives, where available, for the qualifying interests assessed as having

the potential to be impacted (NPWS, 2012) are as follows:

River Lamprey

Attribute: Distribution;

Target: Access to all watercourses down to fist order stream.

Attribute: Population structure of juveniles;

Target: At least three age/size groups of brook/river lamprey present.

Attribute: Juvenile density in fine sediment;

Target: Mean catchment juvenile density of brook/river lamprey at least 2/m2.

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Attribute: Extent and distribution of spawning habitat;

Target: No decline in extent and distribution of spawning beds

Attribute: Availability of juvenile habitat;

Target: More than 50% of sample sites positive.

Sea Lamprey


Target: Greater than 75% of main stem length of rivers accessible from estuary.

Attribute: Population structure of juveniles;

Target: At least three age/size groups present.

Attribute: Juvenile density in fine sediment;

Target: Mean catchment juvenile density of brook/river lamprey at least 1/m2.

Attribute: Extent and distribution of spawning habitat;

Target: No decline in extent and distribution of spawning beds

Attribute: Availability of juvenile habitat;

Target: More than 50% of sample sites positive.

Atlantic Salmon


Target: 100% of river channels down to second order accessible from estuary.

Attribute: Adult spawning fish;

Target: Conservation limit (CL) for each system consistently exceeded.

Attribute: Salmon fry abundance;

Target: Maintain or exceed 0+ fry mean catchment-wide abundance threshold value.

Currently set at 17 salmon fry/5min sampling.

Attribute: Out-migrating smolt abundance;

Target: No significant decline.

Attribute: Number and distribution of redds;

Target: No decline in number and distribution of spawning redds due to anthropogenic

causes.

Attribute: Water quality;

Target: At least Q4 at all sites sampled by EPA.

Otter



Attribute: Extent of terrestrial habitat;

Target: No significant decline (596.8ha above HWM, 958.9ha along river banks/ponds).

Attribute: Extent of marine habitat;

Target: No significant decline (4461.6ha).

Attribute: Extent of freshwater habitat;

Target: No significant decline (500.1km).

Attribute: Extent of freshwater lake/lagoon habitat;

Target: No significant decline (125.6ha).

Attribute: Couching sites and holts;


Attribute: Fish biomass available;

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Attribute: Barriers to connectivity;

Target: No significant increase.

River Shannon and River Fergus Estuary SPA Site Synopsis (NPWS)

The estuaries of the River Shannon and River Fergus form the largest estuarine complex in

Ireland. The site comprises all of the estuarine habitat west from Limerick City and south from

Ennis, extending west as far as Killadysert and Foynes on the north and south shores

respectively of the River Shannon (a distance of some 25 km from east to west). Also included

are several areas in the outer Shannon estuary, notably Clonderalaw Bay and Poulnasherry Bay,

as well as the intertidal areas on the south shore of the Shannon between Tarbert and Beal

Point. The site has vast expanses of intertidal flats. The main macro-invertebrate community

present is a Macoma-Scrobicularia-Nereis community which provides a rich food resource for the

wintering birds. Other species occurring include Common Cockle (Cerastoderma edule),

Lugworm (Arenicola marina), the polychaete Nepthys hombergii, the gastropod Hydrobia ulvae

and the crustacean Corophium volutator. Eelgrass (Zostera spp.) is present in places, along with

green algae (e.g. Ulva spp. and Enteromorpha spp.). Salt marsh vegetation frequently fringes the

mudflats and this provides important high tide roost areas for the wintering birds. 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) and Saltmarsh Rush (Juncus gerardi). 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. lacustris subsp.

tabernaemontani). Also found is the nationally rare Triangular Club-rush (Scirpus triqueter).

Elsewhere in the site the shoreline comprises stony or shingle beaches.

The site is the most important coastal wetland site in the country and regularly supports in

excess of 50,000 wintering waterfowl (mean of 59,183 for the 4 seasons 1996-97 to 1999/00), a

concentration easily of international importance. The site has internationally important

populations of Dunlin (14,987), Black-tailed Godwit (706) and Redshank (1,983) - all figures are

average peaks for 3 of the 5 seasons in the 1995/96-1999/00 period. A further 16 species have

populations of national importance, i.e. Cormorant (148), Whooper Swan (141), Greylag Goose

(88), Shelduck (895), Wigeon (3,025), Teal (1,558), Pintail (40), Shoveler (56), Scaup (76),

Golden Plover (4,073), Grey Plover (564), Lapwing (13,007), Knot (686), Bar-tailed Godwit (481),

Curlew (1,231) and Greenshank (33). The site is among the most important in the country for

several of these species, notably Dunlin (11% of national total), Grey Plover (7.5% of total),

Lapwing (6.5% of total), Redshank (6% of total) and Shelduck (6.0% of total). The site is also

used by Oystercatcher (363), Ringed Plover (70), Brent Goose (135), Great Crested Grebe (47),

Red-breasted Merganser (14), Mallard (247), Turnstone (71), Mute Swan (54), Grey Heron (25),

Black-headed Gull (1,233) and Common Gull (194).

The Shannon / Fergus system was formerly frequented by a Greenland Whitefronted Goose

population but this declined during the 1980s and 1990s and the birds now appear appear to

have abandoned the area. The site provides both feeding and roosting areas for the wintering

birds. Habitat quality for most of the estuarine habitats is good. Some species, particularly

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Whooper Swan and Greylag Goose, utilise areas outside of the site for feeding. Apart from the

wintering birds, large numbers of some species also pass through the site whilst on migration in

spring and/or autumn. Regular species include Blacktailed Godwit, Whimbrel and Greenshank.

Much of the land adjacent to the rivers and estuaries has been reclaimed and improved for

agriculture and is protected by embankments (especially along the River Fergus estuary).

Further reclamation, especially near to the urbanised and industrial areas continues to pose a

threat. The site receives pollution from several sources, including industry and agriculture, but it

is not known if this has any significant impacts on the wintering birds. Aquaculture occurs in

some areas of the site – future increases in this activity could cause disturbance to the habitats

and the associated birds. Common Cord-grass (Spartina anglica) is well-established and may

threaten some of the estuarine habitats. Some disturbance occurs from boating activities.

This site is of great ornithological interest, being of international importance on account of the

numbers of wintering birds it supports. It also supports internationally important numbers of three

species, i.e. Dunlin, Black-tailed Godwit and Redshank. In addition, there are 16 species that

have populations of national importance. For several of the bird species, it is the top site in the

country. Also of note is that three of the species which occur regularly are listed on Annex I of the

E.U. Birds Directive, i.e. Whooper Swan, Golden Plover and Bar-tailed Godwit. The site is most

effectively censused from the air and this is carried out in most winters.

Description of the Conservation Interests of the SPA

The SPA is designated for the following bird species and the wetlands that support them:

Phalacrocorax carbo [breeding + wintering Cormorant]

Cygnus cygnus [wintering Whooper Swan]

Branta bernicla hrota [wintering Light-bellied Brent Goose]

Tadorna tadorna [wintering Shelduck]

Anas penelope [wintering Wigeon]

Anas crecca [wintering Teal]

Anas acuta [wintering Pintail]

Anas clypeata [wintering Shoveler]

Aythya marila [wintering Scaup]

Charadrius hiaticula [wintering Ringed Plover]

Pluvialis apricaria [wintering Golden Plover]

Pluvialis squatarola [wintering Grey Plover]

Vanellus vanellus [wintering Lapwing]

Calidris canutus [wintering Knot]

Calidris alpina [wintering Dunlin]

Limosa limosa [wintering Black-tailed Godwit]

Limosa lapponica [wintering Bar-tailed Godwit]

Numenius arquata [wintering Curlew]

Tringa totanus [wintering Redshank]

Tringa nebularia [wintering Greenshank]

Chroicocephalus ridibundus [wintering Black-headed Gull]

Wetland and Waterbirds

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Detailed conservation objectives are available for this SPA (NPWS, 2012c) which further define

the attributes and targets necessary to maintain the favourable conservation status of the

wintering species listed above as follows:

Attribute: Population Trend;

Target: Long term population trend stable or increasing.


Target: No significant decrease in the numbers or range of areas used by waterbird

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

For wetlands:

Attribute: Wetland Habitat (Area);

Target: The permanent area occupied by the wetland habitat should be stable and not

significantly less than the area of 32,261ha other than that occurring from natural

patterns of variation.

The relevant population and distribution data is provided in the Conservation objectives

supporting document (NPWS, 2012d).

For the River Shannon and River Fergus estuaries conservation condition was assigned to two

species only: Whooper Swan (Favourable condition) and Wigeon (Highly Unfavourable

condition).

Information on populations (where available), requirements and sensitivities of key species are

considered in more detail below with data taken from Crowe (2005), BirdWatch Ireland website

and iWeBS data2, NPWS (2012d) and the referenced geese census reports.

Cormorants breed primarily on rocky cliffs and offshore islands. While most are resident, a

proportion of the Irish population migrates south during winter. The greatest numbers of

Cormorants winter in coastal sites with some using inland freshwater sites. All winter counts in

2010/2011 represented numbers of all-Ireland importance, and numbers do not appear to have

significantly declined relative to the baseline population (NPWS, 2012d). A total of 93 pairs

represent the baseline breeding population (NPWS, 2012b).

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

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

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

improved pasture with 37.5% seen on arable land. Whooper Swan in Ireland are part of the

Icelandic population which migrate south for the winter to Ireland and the UK. Numbers in the

Shannon and Fergus during the last published swan census in 2010 were 339, up 54% relative

to 2005 (Hall et al, 2012) and indicating a population of international importance. Aerial iWeBS

counts indicate that peak yearly counts can vary between nationally important and internationally

important numbers. This species has been assigned favourable conservation status at this site

(NPWS, 2012d).

Light-bellied Brent geese winter almost entirely in Ireland. They are amber-listed as they

winter at less than ten sites. During winter they feed mostly on eel-grass which grows in muddy

estuaries, and also on grasslands when coastal supplies have been depleted at estuarine sites.

2 www.birdwatchireland.ie iWeBS site summary data for the River Fergus Estuary 2008/2009-2012/2013

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http://www.birdwatchireland.ie/


The Shannon and Fergus estuaries continues to be an important site for this species where they

feed at low tide in the mudflats and sandflats (Robinson et al, 2004). Aerial iWeBS counts show

that numbers recorded in recent years have not meet the threshold for national or international

importance (peak count 228) and are lower than the baseline population (494) (NPWS, 2012d).

Shelduck are amber listed in Ireland as the majority of the wintering population occurs at less

than ten sites. Their chief source of food is the estuarine snail Hydrobia ulvae, spatial distribution

of Shelduck within estuaries is strongly influenced by the behaviour of this prey, particularly in

relation to water depth. Aerial iWeBs counts for the Shannon and Fergus Estuaries indicate

numbers of national importance occur, however this represents a decline relative to the

internationally important baseline population (NPWS, 2012d).

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

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

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

concern (Colhoun & Cummins, 2013). NPWS (2012d) note they were recorded in nationally

important numbers in 2010 and Aerial iWeBS counts indicate nationally important numbers have

occurred in all recent count years. However recent counts indicate a decline relative to the

baseline population (NPWS, 2012d).

Wintering Teal are widespread in Ireland on wetlands both coastal and inland. They feed

predominately on small seeds, with algae (Ulva spp.) and molluscs also taken. NPWS (2012d)

note they were recorded in nationally important numbers in 2010 and Aerial iWeBS counts

indicate nationally important numbers have occurred in all recent count years. However recent

counts indicate a decline relative to the baseline population (NPWS, 2012d).

Pintail winter within estuaries and coastal brackish lagoons. They feed on a variety of plant and

animal material obtained from shallow water although they can be observed foraging on land.

Peak numbers of Pintail in 2010-2011 were 94 (NPWS, 2012d) indicating a nationally important

population.

Shoveler prefer shallow eutrophic waters rich in plankton and are found wintering in a variety of

habitats including coastal estuaries, lagoons and inland lakes. They feed mainly on zooplankton,

and also small molluscs, insects and larvae, seeds and plant material. Counts during 2010/2011

surpassed the threshold for national importance however indicate a decline relative to the


Scaup are a winter visitor from Iceland, they occur mostly in coastal estuaries and bays, on

brackish lagoons, and in shallow marine waters less than 10m deep. Their diet principally

comprises shellfish and molluscs. The iWeBS counts for this species and data from NPWS

(2012d) indicate that low numbers are typical (4 no. in 2012/2013) in recent years.

Ringed Plover are visual foragers searching the sediment surface for the visible signs of prey

such as worms, crustaceans and insects. Peak numbers in 2010 (223no) surpassed the

threshold for national importance.

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

During winter Golden Plovers feed primarily within agricultural grassland and arable land. Tidal

flats are used more as a roosting/resting habitat and the birds tend to favour large open flats.

Intertidal feeding is observed to a greater degree during cold weather periods when grassland

feeding areas are frozen over. Counts in November 2010 surpassed the threshold for

international importance (NPWS, 2012d) and aerial iWeBS data indicate that nationally important

numbers are typical. However this represents a decline relative to the baseline population

(NPWS, 2012d).

Grey Plovers in Ireland occur as both passage and wintering birds and are thought to originate

from the Arctic-Russian breeding population. A peak count in 2010 of 206 birds represented

numbers of all-Ireland importance (NPWS, 2012d). Aerial iWeBS surveys have also recorded

nationally-important counts in recent years, although counts for this species can underestimate

the population (NPWS, 2012d). Counts indicate a potential decline relative to the baseline

population (NPWS, 2012d).

Lapwing breeding in Ireland are partial migrants with some residing overwinter and some

migrating south. The wintering population is enhanced by Lapwings coming in from continental

Europe and Britain. Lapwings are traditionally inland waders but can be observed across a wide

variety of habitats in winter including lowland farmland and freshwater habitats. Estuaries are

often used as roosting areas. Peak numbers in November 2010 surpassed the threshold for all-

Ireland importance (NPWS, 2012d). Aerial iWeBS surveys have also recorded nationally-

important counts in recent years. However this represents a decline relative to the baseline


Knot winter on the coasts of Ireland, preferring estuarine sites with extensive areas of muddy

sands. They feed on bivalve mussels and crustaceans in the upper surface of the sediment.

Peak numbers in October 2010 surpassed the threshold for all-Ireland importance (NPWS,

2012d) but indicate the population has declined relative to the baseline.

Dunlin are common along coastal areas in Ireland, especially on tidal mudflats and estuaries.

They feed on small invertebrates of estuarine mudflats, particularly polychaete works and small

gastropods. They feed in the muddier sections of the estuaries close to the tide edge. Peak

numbers in November 2010 surpassed the threshold for international importance (NPWS,

2012d). Aerial iWeBS data indicates counts of national importance in recent years. There has

been a potential decline relative to the baseline population (NPWS, 2012d).

Black-tailed Godwit are large long-billed wading birds that forage within intertidal flats for their

preferred prey of bivalves. The species is adaptable however utilising other habitat for foraging

where available such as terrestrial grassland, coastal marshes and freshwater callows. All

counts in 2010/2011 surpassed the threshold for international importance (NPWS, 2012d).

Bar-tailed Godwit forage by probing within intertidal sediment for invertebrate species,

predominately large polychaete works. They often feed at the tide edge with their heads in

water. The species is characteristic of sites with sandy substrates. All site counts in 2010/2011

surpassed the threshold of all-Ireland importance.

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Curlew winter in a wide range of wetland habitats both coastal and inland. They feed mostly on

invertebrates including ragworms, crabs and molluscs. Numbers of Curlew in 2010/2011

exceeded the threshold for all-Ireland importance (NPWS, 2012d). Aerial iWeBS data indicates

counts of national importance in recent years, but a potential decline relative to the baseline


Redshank winter all around the coast of Ireland, but favour mudflats, large estuaries and inlets.

They feed along the upper shore of estuaries and along muddy river channels on Hydrobia sp.

(bivalve mollusc), Corophium sp.(amphipod) and nereid worms (polychaete). Numbers of

Redshank in 2010/2011 exceeded the threshold for all-Ireland importance (NPWS, 2012d).

Aerial iWeBS data indicates counts have not reached national importance in recent years

however such surveys can underestimate this species (NPWS, 2012d). Counts indicate there

has been a potential decline relative to the baseline population (NPWS, 2012d).

Greenshank have a mainly coastal distribution with the majority being found in estuaries. They

feed on deep water sites, channels, brackish pools and lakes, predominately on invertebrate

crustaceans and small fish. Numbers of Greenshank in 2010/2011 exceeded the threshold for

all-Ireland importance (NPWS, 2012d). Aerial iWeBS data indicates counts have not reached

national importance in recent years however such surveys can underestimate this species

(NPWS, 2012d). There has been a potential decline relative to the baseline population (NPWS,

2012d).

Black-headed Gull feed by direct predation, piracy and scavenging, and have a varied diet

composed of animal and vegetable matter, those often found feeding on insects especially in

arable fields. In Ireland they breed both inland and on the coast, with winter numbers boosted by

birds arriving from northern and eastern Europe. Recent iWeBS counts indicate populations can

fluctuate widely between years, sometimes surpassing, and sometimes falling below, the


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

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

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

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

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

algae may increase in biomass. The closest wetlands to the WwTP within the SPA are in the

upper Fergus estuary.

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Table 6.0: Qualifying SPA Features along Surveyed Stretch

Site Qualifying Species Observed or signs of species

presence within potential zone

of influence of discharge

Suitable habitat present

within potential zone of

influence of discharge

River

Shannon

and

River

Fergus

Estuaries

SPA

Cormorant No No

Whooper Swan No No

Light-bellied Brent

Goose

No No

Shelduck No No

Wigeon No No

Teal No No

Pintail No No

Shoveler No No

Scaup No No

Ringer Plover No No

Golden Plover No No

Grey Plover No No

Lapwing No No

Knot No No

Dunlin No No

Black-tailed Godwit No No

Bar-tailed Godwit No No

Curlew No No

Redshank No No

Greenshank No No

Black-headed Gull No No

Wetlands - No

Impact Prediction

Impacts on Water Quality

The aquatic conservation interests of Lough Gash SAC, the Lower River Shannon SAC and the

River Shannon and River Fergus Estuary SPA are directly dependant on the aquatic

environment. As the Newmarket on Fergus WwTP discharges directly into Lough Gash SAC and

is upstream (via groundwater) of the Lower River Shannon SAC and the River Shannon and

River Fergus Estuaries SPA, there is a connection between this facility and the ecological

receptors of these European Sites.

There is no water quality data for Lough Gash. The lake is eutrophic (its natural state) and there

was no obvious signs of organic pollution observed during the site visit. It is possible that the

reedbeds and wet woodland species facilitate the absorption of some nutrients. Newmarket on

Fergus WwTP is currently operating under-capacity and the discharge is compliant with the

UWWT standards.

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J.B. Barry (2014) state that it would be prudent to consider discharging any treated effluent to a

sufficient location downstream of the spring to ensure adequate mixing and dilution. This will

bypass the Turlough (SAC) and ensure that the flow is to surface water. Other options

considered viable are to discharge to another stream in the local area (Ballynacragga stream) or

directly to the Fergus estuary via a longer pipeline.

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

objectives. The potential threat(s) of the Newmarket on Fergus WwTP on water quality (long term

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

in the catchment.

The Fergus Water Management Unit Action Plan (ShIRBD, 2010) indicates that the largest

sources of phosphorus in the catchment are from agriculture (48%), WwTP’s (28%), unsewered

populations (11%) and forestry (7%). Eleven other WwTP’s in this catchment are noted as

posing risks to water quality and measures requiring upgrading and licensing are detailed.

Newmarket on Fergus WwTP is noted as being ‘At Risk’ with measures to ‘Implement an

appropriate performance management system’. There are 25 Section 4 licensed facilities and 12

IPPC licensed facilities within the Fergus catchment with a particular concentration of these

facilities in the Shannon area. In addition there are 17 registered quarries, 1 mine and 2 landfills.

Other impacts which have the potential to act cumulatively and impact on the SAC result from the

following:

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

nitrogen, phosphorus, potassium and sulphur);

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

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

over a number of years (OECD, 1986);

Artificial drainage increases nitrate leaching and reduce the morphological qualities of

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

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

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

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

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

works (Routledge et al. 1998);

Forestry may alter water quality indirectly through increased evaporation losses and

hence an increase in solute concentrations; and

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

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

Given the uncertainty regarding the impact of the discharge on the turlough habitat, it is

considered that Newmarket on Fergus WwTP has the potential to contribute to cumulative effects

on the catchment when considered with other point-source and diffuse catchment pressures.

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Impacts on Annex I Habitats

Eutrophication, particularly from phosphorus sources, is a known threat to turlough habitats.

Nutrient enrichment can result in the loss of sensitive indicator species and their replacement

with more tolerant negative indicator species. The ongoing input of nutrients, albeit within

UWWT standards for non-sensitive waters, has the potential to adversely affect this sensitive

habitat.

As discussed previously it is not anticipated that any of the Annex I habitats of the Lower River

Shannon SAC have the potential to be adversely affected by the discharge. The habitats

potentially closest to the entry location(s) of the groundwater flow exiting Lough Gash are

Estuaries, Mudflats and Sandflats, Salt marsh and Reefs. These habitats would be robust in

terms of pollution tolerance and given the distance involved and the dilution provided by the

waters of the Fergus estuaries, there will be no adverse effects to the integrity of the Lower River

Shannon SAC.

Table 7.0: Qualifying Habitats Potentially Impacted by WwTP Discharge

Qualifying Habitats Potential

Impacts

Brief Explanation Mitigation

required

Turloughs Yes Eutrophication potentially

resulting in the loss of

sensitive indicator

species.

Yes

Sandbanks

Estuaries

Tidal Mudflats and Sandflats

Coastal Lagoons*

Large Shallow Inlets and Bays

Reefs

Salicornia Mud

Atlantic Salt Meadows

Mediterranean Salt Meadows

No Marine/Estuarine

habitats significantly

removed from the

WwTP. Any discharge

will achieve significant

dilution in the River

Fergus estuary. No

potential for conservation

status of these habitats,

or overall integrity of the

SAC, to be adversely

affected

No

Floating River Vegetation

Alluvial Forests

No Habitats associated with

freshwater section of

River Fergus upstream

of potential connection

with water exiting Lough

Gash.

No

Molinia Meadows

Perennial Vegetation of Stony Banks

Vegetated Sea Cliffs

No Coastal/Terrestrial

habitat - no potential for

conservation status to be

adversely affected.

No

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Impacts on Annex II Species

There is no potential for the conservation status of the freshwater pearl mussel population of

the Lower River Shannon SAC to be adversely effected by the WwTP due to a lack of a

hydrological connection. Similarly bottlenose dolphin has no potential to be adversely affected

due to its location a significant distance downstream. Brook lamprey has no potential to be

adversely affected as it is confined to the freshwater section of the River Fergus.

Sea lamprey, river lamprey and Atlantic salmon have the potential to occur in the Fergus

estuary in the vicinity of where groundwater originating from Lough Gash may enter. Spawning

or nursery habitats will occur further upstream. Localised effects to these species migrating

upstream or downstream in the vicinity of the groundwater influx are considered highly unlikely

due to the distance from the source and the significant dilution which will be achieved in the

Fergus estuary. It is not considered that there is any potential to adversely affect the

conservation status of these species or the overall integrity of the Lower River Shannon SAC.

There is a slight possibility that otter populations associated with the Lower River Shannon SAC

may use Lough Gash which is connected to the Fergus estuary via surface water channels and

drains. No signs of this species were observed during the site visit however and its distribution in

the 10km square is not indicated on distribution maps. Lough Gash is unlikely to support any

significant fish populations given it dries out in the summer months and the turlough is not

expected to be a favoured habitat for this species. There is no indication that the ongoing

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

whole, and no specific additional mitigation is required.

Table 8.0: Qualifying Species Potentially Impacted by WwTP Discharge

Qualifying

Species

Potential

Impact


Required

Freshwater pearl

mussel

No No hydrological link to this population - no potential

for conservation status to be adversely affected.

No

Sea lamprey/River

lamprey/ Atlantic

Salmon

No no potential to impact sensitive life stages.

Significant dilution of any nutrients in Fergus

estuary.

No

Brook Lamprey No Upstream of any potential connection to

groundwater from Lough Gash.

No

Otter No Key designated areas for this species are not in the

vicinity of the WwTP. If it was to occur otter are

unlikely to be highly sensitive to ongoing operation

of the WwTP. Significant effects on the

conservation status of otter not predicted.

No

Bottlenose Dolphin No Marine species significantly removed from the

WwTP - no potential for conservation status to be

adversely affected.

No

Impacts on designated features of the SPA

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The effects of eutrophication on wetland birds species can be varying and complex.

Eutrophication causing increased phytoplankton growth could increase the amount of food

available for bird species, however it can also lead to an increase algal blooms which may impact

on fishing species such as Cormorant during the breeding season. There is also evidence to

suggest that reduced primary production (measured as chlorophyll a) due to better water quality

can lead to a decline in the density and biomass of benthic invertebrates, and a consequent

reduction in the abundance of diving ducks as has been the case on Lough Neagh where

Pochard, Tufted Duck, Scaup and Goldeneye have all declined in numbers over the last 10 years

(Burton et al, 2003; Tom nkov , 2013).

The species for which the SPA is designated are not considered highly sensitive to minor-

moderate levels of eutrophication. The distance of the WwTP upstream and the dilution

achieved by the effluent downstream in the Fergus estuary mean there is little or no chance for

the WwTP to impact significantly on the bird species of the SPA. In addition pollution or

eutrophication due to domestic/urban waste water was not highlighted as a pressure/threat in the

Fergus estuary in the conservation objectives supporting document (NPWS, 2012d)

Population fluctuations/declines are indicated for many of the SPA species, however, difficulty in

counting this large site is considered to contribute to uncertainty in count figures, and therefore a

conservation status was only assigned to 2 species (NPWS, 2011d). There is no evidence that

to suggest that SPA species have been negatively affected by the operation of the WwTP’s

located upstream to date.

The potential for adverse effects on the conservation status of SPA Annex I bird species or their

wetland habitats is considered negligible, and no specific additional mitigation is required.

Table 9.0: Qualifying Features of SPA Potentially Impacted by WwTP Discharge

Qualifying Features Potential

Impacts


required

Cormorant No There is no evidence to suggest that breeding or

wintering Cormorant have been impacted by the

WwTP to date, or that they would be particularly

sensitive to minor changes in nutrient levels in the

River Fergus Estuary.

No

Whooper Swan No Feed primarily on agricultural lands and unlikely

to affected by any change in the nutrient status of

the River Fergus estuary. Internationally

important numbers occur regularly in recent years

while the operation of the WwTP has been

ongoing. No evidence to suggest that these

species have been impacted by the WwTP to

date, or that they would be particularly sensitive

to minor changes in nutrient levels in the River

Fergus Estuary.

No

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Light-bellied Brent

Goose

No There is no evidence to suggest that this species

have been impacted by the WwTP to date, or that

they would be particularly sensitive to minor

changes in nutrient levels in the River Fergus

Estuary.

No

Shelduck No

Count data suggests species continue to hold

nationally important number with the exception of

redshank, and that Golden Plover occur in

internationally important numbers.

Declines relative to baseline populations have

been recorded for most of these species,

however difficulties in counting this large site

have resulted in uncertainty regarding trends for

many species (NPWS, 2012d)

No qualifying species were observed in the

vicinity of the WwTP.

There is no evidence to suggest that these

species have been impacted by the WwTP to

date, or that they would be particularly sensitive

to minor changes in nutrient levels in the River

Fergus

No

Wigeon

Teal

Pintail

Shoveler

Scaup

Ringer Plover

Golden Plover

Lapwing

Knot

Dunlin

Black-tailed Godwit

Bar-tailed Godwit

Curlew

Redshank

Greenshank

Black-headed Gull

Wetlands No Given the distance to any SPA wetland habitats

and the dilution achieved in the River Fergus

Estuary, the conservation status of wetlands will

not be affected by the ongoing operation of the

WwTP.

No

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Mitigation Measures Newmarket on Fergus WwTP is identified as posing a risk to water quality in the Fergus WMU

Action Plan (ShIRBD, 2010). Several options have been considered in hydrogeological

assessments of the discharge including relocation of the outfall and further effluent treatment

options. The EPA (2014) note that, where possible, discharges should be made to surface

waters.

In order to avoid adverse effects to the integrity of Lough Gash SAC the following mitigation is

required:

Redirect the outfall to avoid Lough Gash SAC to a watercourse with sufficient

assimilative capacity for the discharge or to a sufficiently sized constructed wetland.

To ensure satisfactory operation of the existing plant mitigation measures recommended for the

ongoing operation of the plant are as follows:

Optimisation of the current waste water treatment process and investigate further

measures to reduce the levels of Nitrogen and Phosphorus currently being discharged

from the plant;

Implementation of an appropriate performance management system;

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

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

on a consistent regular basis.

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

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

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

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

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

assessment for the Waste Water Discharge Licence Application investigates the potential

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

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

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

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

measures necessary to avoid, reduce or offset negative effects.

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

significant adverse effects on the integrity of Lough Gash SAC, the Lower River Shannon SAC or

the River Shannon and River Fergus Estuaries SPA in view of these site’s conservation

objectives and that the conservation status of the Annex I habitats, Annex II species or Annex I

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

cumulatively.

It is therefore concluded that the Newmarket on Fergus WwTP discharge, alone or in-

combination with other plans and / or projects will not give rise to significant effects on the

integrity of Lough Gash SAC, the Lower River Shannon SAC or River Shannon and the River

Fergus Estuaries SPA, as long as the mitigation measures as listed above are implemented in

full. Stage 2 concludes the Appropriate Assessment process of the Newmarket on Fergus Waste

Water Discharge Licence Application.

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References

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Biosphere Environmental Services (BES)/Conservation Services (CS) (2009) Ennis Wastewater

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Council.

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

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EPA (2014) Guidance on the Authorisation of Direct Discharges to Groundwater.

Geosyntec (2014) Tier 3 Hydrogeology Assessment. Newmarket on Fergus, WwTP Discharge

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Harvey J & Cowx I (2003). Monitoring the River, Brook and Sea Lamprey, Lampetra fluviatilis, L.

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J.B. Barry (2014) Newmarket on Fergus Agglomeration. Wastewater Discharge Assessment

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Gaeltacht.

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Arts, Heritage and the Gaeltacht.

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

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

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

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O’Reilly (2004) Rivers of Ireland – A flyfishers guide.

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

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

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