Proposed development at Former CIE Lands, Carnlough Road, Cabra, Dublin 7 Appropriate assessment (screening) Report prepared for Crekav Trading GP Limited November 2017 Roger Goodwillie & Associates, Lavistown House, Kilkenny. Tel. 056-7765145
1. INTRODUCTION Appropriate assessment was introduced by the EU Habitats Directive as a way of determining if a planned project is likely to have a significant effect on one of the Natura 2000 sites so far designated (i.e. the candidate SAC s and SPA s), or their conservation objectives. In this case the relevant sites are: North Dublin Bay csac (Site code 0206), South Dublin Bay csac (Site code 0210), North Bull Island SPA (Site code 4006), Sandymount Strand/Tolka Estuary SPA (Site code 4024). These are outlined on the map at end. Two other sites are within 15km of Cabra the Wicklow Mountains and Baldoyle Estuary, both of which are csac and SPA. There is no pathway by which significant impacts could reach them from this site however. Article 6(3) states: Any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subject to appropriate assessment of its implications for the site in view of the site s conservation objectives In the Irish context this has been interpreted as a four stage process. Firstly a screening exercise (Stage 1, this document) determines if a project could have significant effects on a Natura site. If it does or the situation is unclear, a Natura Impact Statement (Stage 2) is provided to the planning or regulatory authority which then conducts an assessment of the information supplied. Examples of significant effects are loss of habitat area, fragmentation of the habitat, disturbance to species using the site and changes in water resources or quality. If such negative effects come to light in the assessment, alternative solutions are investigated by the proponent (Stage 3) and modifications made unless the project is deemed to be driven by imperative reasons of overriding public interest in its current form. If this is so, Stage 4 then deals with compensatory action. 2. PROJECT DESCRIPTION The project is the residential and commercial development of about 3.88 ha. of the former CIE Lands. The proposed development consists of the provision of 421 no. residential units comprising 419 no. apartments (93 no. 1 beds, 259 no. 2 beds and 67 no. 3 beds) and 2 no. houses at No. 2 and No. 4 Carnlough Road. The proposed development also includes 3 no. retail units (Unit 1 143.9 sq.m.; Unit 3 466.7 sq.m. and Unit 4 451.5 sq.m.), a discount foodstore (including offlicence) of 1,704 sq.m., creche 338.3 sq.m. and community centre of 409.4 sq.m.
The proposed development includes 380 no. car parking spaces at basement level, 36 no. car parking spaces at surface level, 444 no. bicycle parking spaces, landscaped open space of 9.028 sq.m. and all ancillary works and services necessary to facilitate the development. A new vehicular entrance will be provided from Carnlough Road, which will be facilitated by the demolition of No. s 2 & 4 Carnlough Road and an upgraded junction between Cabra Road and Carnlough Road. The development will be connected to local services of water and sewerage. 3. NATURA SITES The four sites cover the greater part of Dublin Bay and will be taken together as a unit. The site synopses are given on the NPWS website and emphasise the value of the North Bull Island as an ecosystem with sand dunes and saltmarsh, and also the feeding value of the mudflats in Dublin Bay to bird life. The saltmarsh is a typical east coast one and shows a good transition to dune communities in places. The bird populations using the bay and the lagoons beside Bull Island consist of wildfowl and waders and involve many species. Light-bellied brent goose, knot, black-tailed godwit and bartailed godwit occur in numbers of international importance (Crowe et al 2012) while other wildfowl (shelduck, wigeon, teal, pintail, shoveler, red-breasted merganser, great crested grebe) and waders (oystercatcher, ringed plover, golden plover, grey plover, sanderling, dunlin, curlew, greenshank, redshank and turnstone) have populations of national value. In autumn large numbers of terns of all species roost on the sands in the southern part of the bay while common and arctic terns breed close to Dublin Port. All Irish terns are listed in Annex I of the EU Birds Directive as is the golden plover. 4. CONSERVATION OBJECTIVES North Dublin Bay/ South Dublin Bay. These are included in NPWS (2013 a & b). SAC Objectives: 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: 1140 Mudflats and sandflats not covered by seawater at low tide* 1210 Annual vegetation of drift lines* 1310 Salicornia and other annuals colonising mud and sand* 1330 Atlantic salt meadows (Glauco-Puccinellietalia maritimae) 1395 Petalwort Petalophyllum ralfsii 1410 Mediterranean salt meadows (Juncetalia maritimi) 2110 Embryonic shifting dunes* 2120 Shifting dunes along the shoreline with Ammophila arenaria (white dunes) 2130 Fixed coastal dunes with herbaceous vegetation (grey dunes) 2190 Humid dune slacks
List refers to North Dublin Bay; those features shared by South Dublin Bay have asterisks. SPA objectives (NPWS 2015a & b): To maintain the favourable conservation status of the Special Conservation Interests of the SPA s, i.e. Light-bellied Brent Goose Branta bernicla hrota [A046] Shelduck Tadorna tadorna [A048] Teal Anas crecca [A052] Pintail Anas acuta [A054 Shoveler Anas clypeata [A056] Oystercatcher Haematopus ostralegus [A130] Ringed Plover Charadrius hiaticula [A137] Golden Plover Pluvialis apricaria A140 Grey Plover Pluvialis squatarola [A141] Knot Calidris canutus Sanderling Calidris alba Dunlin Calidris alpina [A149] Black-tailed Godwit Limosa limosa [A156] Bar-tailed Godwit Limosa lapponica [A157] Curlew Numenius arquata [A160] Redshank Tringa totanus [A162] Turnstone Arenaria interpres [A169] Black-headed Gull Larus ridibundus [A179] Roseate Tern Sterna dougallii [A192] Common Tern Sterna hirundo [A193] Arctic Tern Sterna paradisaea [A194] The 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 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 the natural range of the species is neither being reduced nor is likely to be reduced for the foreseeable future there is, and will probably continue to be, a sufficiently large habitat to maintain its populations on a long-term basis 5. LIKELY EFFECTS The Cabra site is not included in any Natura 2000 site (see map below) and does not support any of the habitats or species of interest listed. Therefore, it cannot have a reservoir function in re-populating them, should this be necessary.
The Natura sites consist of Dublin Bay and the Bull Island. The Liffey River is not included so that any effluent from the site would have to reach Dublin Bay to have an impact. An effluent would then only be detrimental if heavy metals or other harmful chemicals were released during the construction process. Sediment by itself would not have a significant effect as it is one of the dominant habitat factors in an estuary that all organisms and habitats are adapted to. Standard protocols of construction to prevent material entering the local drainage systems would minimise any discharge during construction and effectively prevent any impact on the downstream Natura 2000 sites. Once operational there is no way the development would affect Dublin Bay provided wastewater treatment keeps pace with any expansion of population numbers 6. CONCLUSION Given the nature of the project and the distance between the site and the Natura 2000 sites, there is no likelihood of significant ecological effects on the Natura sites downstream (or any others), or on their conservation objectives. This applies both to construction and operation. The further, more detailed, stages of Appropriate Assessment are not required. References Crowe, O., Boland, H. & Walsh, A. 2012. Irish Wetland Bird Survey: results of waterbird monitoring in Ireland in 2010/11. Irish Birds, 9, 397-40. Dept of Environment, Heritage and Local Government (2009). Appropriate assessment of plans and projects in Ireland: guidance for planning authorities. Dublin. NPWS (2013a) Conservation Objectives: North Dublin Bay SAC 000206. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht NPWS (2013b) Conservation Objectives: South Dublin Bay SAC 000210. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht. NPWS (2015a) Conservation Objectives: North Bull Island SPA 004006. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht. NPWS (2015b) Conservation Objectives: South Dublin Bay and River Tolka Estuary SPA 004024. Version 1. National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht.
Development site (arrowed) and downstream SAC s (cross-hatched) and SPA s (vertical). Canals and Liffey Valley are pnha s.