RE: Waste Water Discharge Certificate of Authorisation for Newtown
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- Iris Underwood
- 5 years ago
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1 Fingal County Council Comhairle Contae Fhine Gall To: E.P.A., PO Box 3000, Johnstown Castle Estate, CO Wexford. F -! f - r-". Water Services Department Postal Address 5th May 2010 P.O. Box 174, County Hall. Swords, Fingal, Co. Dublin RE: Waste Water Discharge Certificate of Authorisation for Newtown Co ttages Agglomeration A Dear Sirs, We refer to your letter of 7th April 2010 headed "Notice in accordance with Reg. 25(c)(ii) of the Waste Water Discharge (Authorisation) Regulations 2007." The Newtown Cottages agglomeration discharges to the Swords Groundwater body and is within 5km of the Inner Broadmeadow Estuary. The Broadmeadow Estuary is a candidate Special Protection Area and a Special Area of Conservation. The likelihood of a significant effect on these two European sites is discussed in the attached document. There is no change required to the non technical summary previously submitted. Details of all discharges have been submitted to the web site. An Roinn Seirbhisl Uisce Bosca 174, Aras an Chontae, Sord, Fine Gall, Contae Atha Cliath Office Address Grove Road, Elanchardstown, Fingal, Dublin 15 Telephone Facsimile waterservices@ftngalcoco ie wwwfingalcoco ie Yours sincerely, Ferge Finch, Exec Eng.. Water Is precious. Let's conserve it. - Ta uisce luachmhar. Caomhnaimk e.
2 . Waste Water Discharge Certificate of Authorisation for Newtown Cottages Agglomeration A Flow chart from appendix 1 of Circular L8/08 from DoEHLG. I 1. Is the development in a nature conservation site. 2b. (If the development involves a groundwater discharge: ) Is the development in the groundwater catchment or within 5km (whichever is greater) of a nature Iconservation site (or part of such a site)? 3. Are the qualifying habitats and species of the site water dependant? 5. Is there a WFD subbasin plan for the the site or its protected habitatshecies? 1 No ASSESS IMPACTS
3 Comhairle Contae Fhine Gall Fingal County Council Fingal County Council Newtown Cottages Waste Water Discharge Certificate of Authorisation Application Application Register No. A Screening Apr 2010
4 6 of Authorisation Application DO Screening Con tents Figure 1 INTRODUCnON... 1 SCREENING DISCRIPTION OF PROJECT... 2 CHARACTERISTICS AND MANAGEMENT OF THE SITE Designated sites in the vicinity of the Project Characteristics of the site Conservation Objectives/Management... 7 IDENTIFICATION OF POTENTIAL IMPACTS... 8 ASSESSMENT OF SIGNIFICANCE... 8 CONCLUSION... 9 Figures Newtown Cottages Agglomeration extents... 3
5 of Authorisation Application Screening 1 INTRODUCTION Fingal County Council has submitted a Waste Water Discharge Certificate of Authorisation Application to the EPA for the Newtown Cottages Agglomeration under the Wastewater Discharge (Authorisation) Regulations 2007, S.I. 684 of The Primary Discharge point for the Agglomeration is to the Swords groundwater body and is within 5km of the Inner Broadmeadow Estuary. The Broadmeadow Estuary is a Special Protection Area (Broadmeadow Estuary SPA; Site Code: ) and a Special Area of Conservation (Malahide Estuary SAC; Site Code: 00205). The Environmental Protection Agency has required Fingal County Council under Regulation 25(c) (ii) of the Wastewater Discharge (Authorisation) Regulations to determine if there is likely to be a significant impact from the waste water discharges from the Newtown Cottages agglomeration on the relevant European Site, Broadmeadow Estuary. This report has been prepared in accordance with the recommendations of the EPA document Note on Appropriate Assessments for the purposes of the Waste Water Discharge (Authorisation) Regulations, 2007 and the Circular L8/08 Water Services Investment and Rural Water Programmes - Protection of Natural Heritage and National Monuments issued by the Department of the Environment, Heritage and Local Government. The EPA Note identifies 4 Stages in the Appropriate Assessment Process in line with the European Commission Methodological Guidance on the provision of Article 6(3) and 6(4) of the Habitats Directive 92/43/EEC (EC2001) and the European Commissions Guidance Managing Natura 2000 Sites and a number of steps within each stage. This report has been structured to generally follow the stages and steps identified in the above guidance as follows; Stage1 - Screening Step 1 - Description of the Project Step 2 - Characteristics and Management of the Site Step 3 - Identification of Potential Impacts Step 4 - Assessment of Significance Stage 2 - Appropriate Assessment Step 1 - Information Required Step 2 - Impact Prediction Step 3 - Conservation Objectives 1
6 of Authorisation Application DO Screening Step 4 - Mitigation Measures Stage 3 - Assessment of Alternative Solutions - Identify alternative ways of achieving the objectives of the project avoiding adverse impacts on the integrity of the designated site Stage 4 - Assessment where no alternative solution exists - Identify if there are imperative reasons of overriding public interest and if there are human health and safety considerations or important environmental benefits. 2 Screening 2.1 Description Of Project Newtown Cottages is a small cottage scheme in north County Dublin with a population equivalent of approx 20. The Newtown Cottages Agglomeration consists of the cottages. The character of the agglomeration is residential. The plant consists of a septic tank and a percolation area. These reduce the biological load to the standards required by SR6, the NSAI Standard Recommendation for septic tank systems. The extent of the agglomeration and the location of the primary discharge point is shown Fig. 1, below. 2
7 of Authorisation Application DO Screening Figure 1 Newtown Cottages Agglomeration extents. 3
8 of Authorisation Application DO104 = 01 - Screening 2.2 Characteristics and management of the site Designated sites in the vicinity of the Project The Newtown Cottages agglomeration is in the catchment of the Broadmeadow Estuary csac and SPA Characteristics of the site The following has been taken from the National Parks and Wildlife Service's (NPWS) website: MALAHIDE ESTUARY Special Area of Conservation SITE SYNOPSIS Malahide Estuary is situated immediately north of Malahide and east of Swords. It is the estuary of the River Broadmeadow. The site is divided by a railway viaduct built in the 1800s. The outer part of the estuary is mostly cut off from the sea by a large sand spit, known as "the island". The outer estuary drains almost completely at low tide, exposing sand and mud flats. There is a large bed of Eelgrass (Zostera noltii and 2. angustijolium) in the north section of the outer estuary, along with Tassel Weed (Ruppia maritima) and extensive mats of green algae (Enteromorpha spp., Ulva factuca). Cordgrass (Spartina angfica) is also widespread in this sheltered part of the estuary. The dune spit has a well developed outer dune ridge dominated by Marram Grass (Ammophila Arenaria). The dry areas of the stabilised dunes have a dense covering of Burnet Rose (Rosa pimpineflifolia), Red Fescue (Festuca rubra) and species such as Yellow Wort (Bfachtonia perfoliata), Field Gentian (Gentianeffa amareffa), Hound's Tongue (Cynoglossum oficinale), Carline Thistle (Carlina vulgaris) and Pyramidal Orchid (Anacamptis pyramidalis). Much of the interior of the spit is taken up by a golf course. The inner stony shore has frequent Sea-holly (Etyngium maritimum). Well-developed saltmarshes occur at the tip of the spit. Atlantic salt meadow is the principle type and is characterised by species such as Sea Purslane (Halimoine portufacoides), Sea Aster (Aster tripofium), Thft (Armeria maritima), Sea Arrowgrass (Trigfochin maritima) and Common Saltmarsh-grass (Puccineffia maritima). Elsewhere in the outer estuary, a small area of Mediterranean salt meadow occurs which is characterised by the presence of Sea Rush (Juncus maritimus). Below the salt marshes there are good examples of pioneering Glasswort swards and other annual species, typified by Salicornia dolichostachya and Annual Sea-blite (Suaeda maritima). 4
9 of Authorisation Application DO Screening The inner estuary does not drain at low tide apart from the extreme inner part. Here, patches of saltmarsh and salt meadows occur, with Sea Aster, Sea Plantain (Plantago maritima) and Sea Clubrush (Scirpus maritimus). Tassel Weed (Ruppia maritima) occurs in one of the channels. The site includes a fine area of rocky shore south-east of Malahide and extending towards Portmamock. This represents the only continuous section through the fossiliferous Lower Carboniferous rocks in the Dublin Basin, and is the type locality for several species of fossil coral. The estuary is an important wintering bird site and holds an internationally important population of Brent Geese and nationally important populations of a further 15 species. Average maximum counts during the 1995/ /98 period were Brent Geese 1217; Great Crested Grebe 52; Mute Swan 106; Shelduck 471; Pochard 200; Goldeneye 333; Red-breasted Merganser 116; Oystercatcher 1228; Golden Plover 2123; Grey Plover 190; Redshank 454; Wigeon 50; Teal 78; Ringed Plover 106; Knot 858; Dunlin 1474; Greenshank 38; Pintail 53; Black-tailed Godwit 345; Bar-tailed Godwit 99. The high numbers of diving birds reflects the lagoon-type nature of the inner estuary. The estuary also attracts migrant species such as Ruff, Curlew Sandpiper, Spotted Redshank and Little Stint. Breeding birds of the site include Ringed Plover, Shelduck and Mallard. Up to the 1950s there was a major tern colony at the southern end of the island and the habitat remains suitable for these birds. The inner part of the estuary is heavily used for water sports. A section of the outer estuary has recently been infilled for a marina and housing development. This site is a fine example of an estuarine system with all the main habitats represented. The site is important ornithologically, with a population of Brent Geese of international significance. BROADMEADOW/SWORDS ESTUARY Special Protection Area SITE SYNOPSIS This site is situated in north Co. Dublin, between the towns of Malahide and Swords. It is the estuary of the River Broadmeadow, a substantial river which drains a mainly agricultural, though increasingly urbanised, catchment. A railway viaduct, built in the 18OOs, crosses the site and has led to the inner estuary becoming lagoonal in character and only partly tidal. Much of the outer part of the estuary is well-sheltered from the sea by a large sand spit, known as The Island. This spit is now mostly converted to golf-course. The outer part empties almost completely at low tide and there are extensive intertidal flats exposed. The site extends eastwards to the rocky shore at Robswalls. Substantial stands of eelgrass (both Zostera noltii and 2. angustifolia) occur in the sheltered part of the outer estuary, along with Tasselweed (Ruppia maritima). Green algae, mostly Enteromorpha spp. and Ulva lactuca, are frequent on the sheltered flats. Common Cord-grass (Spartina anglica) is well established in the outer estuary and also in the innermost part of the site. The intertidal flats support a typical macroinvertebrate fauna, with polychaete worms (Arenicola marina and Hediste 5
10 of Authorisation Application DO104 = 01 - Screening diversicolor), bivalves such as Cerastoderma edule, Macoma balthica and Scrobicularia plana, the small gastropod Hydrobia ulvue and the crustacean Corophium volutator. Salt marshes, which provide important roosts during high tide, occur in parts of the outer estuary and in the extreme inner part of the inner estuary. These are characterised by such species as Sea Purslane (Halimione portulacoides), Sea Aster (Aster tripolium), Thfl (Armeria maritima), Sea Arrowgrass (Triglochin maritima) and Common Saltmarsh-grass (Puccinellia maritima). This site is of high importance for wintering waterfowl and supports a particularly good diversity of species. It has an internationally important population of Brent Goose (956) or 4.8% of the national total (figures given here and below are average maximum counts for the five winters 1995/ /00) and nationally important populations of a further 12 species as follows: Shelduck (439), Pintail (58), Goldeneye (2 19, Red-breasted Merganser (1 OS), Oystercatcher (1,493), Golden Plover (1,843), Grey Plover (201), Knot (91 5), Dunlin (1,594), Black-tailed Godwit (409), Redshank (581) and Greenshank (38). A range of other species occur in numbers of regional importance, including Great Crested Grebe, Mute Swan, Pochard, Ringed Plover, Lapwing, Bar-tailed Godwit, Curlew and Turnstone. The high numbers of diving ducks reflects the lagoon-type nature of the inner estuary, and this is one of the few sites in eastern Ireland where substantial numbers of Goldeneye can be found. The estuary also attracts on a regular basis migrant wader species such as Ruff, Curlew Sandpiper, Spotted Redshank, Green Sandpiper and Little Stint. These occur mainly in autumn, though occasionally in spring and winter. Breeding birds of the site include Ringed Plover, Shelduck and Mallard. Up to the 1950s there was a major tern colony at the southern end of Malahide Island. Grey Herons breed nearby and feed regularly within the site. The inner part of the estuary is heavily used for water sports, which causes disturbance to the bird populations. A section of the outer estuary has recently been in-filled for a marina and housing development. Broadmeadow/Swords Estuary SPA is a fine example of an estuarine system, providing both feeding and roosting areas for a range of wintering waterfowl. The lagoonal nature of the inner estuary is of particular value as it increases the diversity of birds which occur. The site is of high conservation importance, with an internationally important population of Brent Goose and nationally important populations of a further 12 species. Three of the species which occur regularly (Golden Plover, Bar-tailed Godwit and Ruff) are listed on Annex I of the E.U. Birds Directive. 6
11 of Authorisation Application DO104 = 01 - Screening Conservation Objectives/Management There is currently no management plan for the SPNcSAC, however the following conservation objectives have been identified for the site(s) by the NPWS. Broadmeadow/Swords Estuary Special Protection Area The site is selected for the light-bellied Brent goose, Goldeneye and Black-tailed Godwit. Additional Special Conservation Interests include; Shelduck, Pintail, Red-breasted Merganser, Oystercatcher, Golden Plover, Grey Plover, Knot, Dunlin, Bar-tailed Godwit, Redshank, Wetland & Waterbirds. The main conservation objective of the site is to maintain the special conservation interests for this SPA at favourable conservation status. Favourable conservation status of a species is achieved when: The population is maintaining itself The natural range of the species is neither being reduced or likely to be reduced for the foreseeable future, There is a sufficiently large habitat to maintain the population on a long term basis. Malahide Estuary Special Area of Conservation The NPWS lists three conservation objectives for this area; Objective 1: To maintain the Annex I habitats for which Malahide Estuary csac has been selected at favourable conservation status: Fixed coastal dunes with herbaceous vegetation (grey dunes); Shifting dunes along the shoreline with Ammophifa arenaria (white dunes); Mudflats and sandflats not covered by seawater at low tide; Salicornia and other annuals colonising mud and sand, Atlantic salt meadows (Gfauco-Puccineffietafia maritimae); Mediterranean salt meadows (Juncetalia maritimi) and Spartina swards (Spartinion maritimae). Objective 2: To maintain the extent, species richness and biodiversity of the entire site. Objective 3: To establish effective liaison and co-operation with landowners, legal users and relevant authorities. Favourable status of a habitat is achieved when; 0 0 its natural range, and area it covers within that range, is stable or increasing, and the ecological factors that are necessary for its long-term maintenance exist and are likely to continue to exist for the foreseeable future, and 7
12 of Authorisation Application DO Screening 0 the conservation status of its typical species is favourable (population is maintaining itself, sufficiently large habitat to maintain populations on a long-term basis). 2.3 Identification of potential impacts The discharge of effluent from the Newtown Cottages agglomeration that enters the Broadmeadow Estuary via the Swords groundwater body may result in a nutrient, carbon and bacterial load to the estuary in addition to the nutrient, carbon and bacterial load carried into the estuary by the rivers from sources upstream in its catchment. Such inputs have the potential to adversely impact on the quality of water that maintains many of the inter-tidal habitats and species for which the site(s) is designated. Excess nutrients and organic matter in the water may result in over production of algae and in a depletion of oxygen in the water column and underlying muds leading to a reduction in foraging habitat and food sources for protected bird species. Excessive enrichment may result in the loss of nutrient sensitive species of flora and fauna for which the site is designated. 2.4 Assessment of significance Physio-chemical data, trophic status data and data on benthic fauna communities indicate that there is significant enrichment of the inner estuary and that this condition has persisted for a significant number of years (since before 1993). This data is typical of an enclosed estuary with poor flushing characteristics. Physio-chemical and trophic status data indicate that the outer estuary is of moderate quality with in-faunal communities typical of enriched estuaries with good flushing. Birds continue to visit the estuary in nationally and internationally important numbers. Wastewater treatment facilities have been discharging to the inner and outer estuary since well before the estuary was designated as an SPNcSAC and while the volume of effluent discharged has increased in recent years so too has the level of treatment afforded to those discharges. Discharges from Swords and Malahide WwTW s add enrichment to the estuary as do inflows from the Broadmeadow River and drainage from surrounding agricultural, amenity land and groundwater. The current ecology of the estuary is supported by this enrichment which appears to be within the carrying capacity/assimilative capacity of the estuary. 8
13 of Authorisation Application DO Screening Following in depth water quality modelling and ecological assessment of the proposed upgrading of the Swords Wastewater Treatment Plant to cater for a population equivalent of 90,000 p.e. in 1998, it was concluded that discharges from a 60,000 p.e. works would be within the assimilative capacity of the estuary and while the 90,000 p.e. plant was likely to increase nitrogen levels in the inner estuary slightly, nitrogen levels would still be within the assimilative capacity of the estuarine system. Recent survey data bears out this conclusion with respect to the 60,000 p.e. plant. In summary, it would appear from recent studies in the estuary that the current discharges from the Swords and Malahide WwTW are not impacting the conservation objectives of the csac or SPA. As the discharge from the Newtown Cottages is miniscule in comparison with these WWTPs, it would appear that Newtown Cottages agglomeration is not impacting the conservation objectives of the csac or SPA. 3. Conclusion An Appropriate Assessment was carried out for the Swords Waste Water Discharge Licence application (D ) and submitted to the Agency. It concluded that based on recent surveys (2008) of bird populations and infaunal communities and a review of available data on bird populations, infaunal communities and water quality over the last 15 to 20 years, current discharges from Swords WwTW, in conjunction with discharges from the Malahide WwTW are not having a significant impact on the conservation objectives of the Malahide/Broadmeadow Estuary SPNcSAC. As the discharge fiom the Newtown Cottages agglomeration is miniscule in comparison with these two WWTP, it is concluded that the Newtown Cottages agglomeration is not having a significant impact on the estuary. It is therefore felt that a full Appropriate Assessment is not required. 9
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