2 for doonbeg licence (d0324-01) - environmental protection ...or from the doonbeg golf club which...

Licensing Reply - Reg 18(3)(b) Reply Received - 2 for DoonbegLicence (D0324-01)

Licence: Doonbeg (D0324-01)

Action Type: Licensing Reply

Dear Applicant

I refer to your application for a waste water discharge licence relating to agglomeration named Doonbeg.

Having examined the documentation submitted, I am to advise that the Agency is of the view that the documentation does not comply with Regulation 16 of the Waste Water Discharge (Authorisation) Regulations 2007, as amended.

You are therefore requested, in accordance with Regulation 18(3)(b) of the regulations, to take the steps to supply the information detailed below:

REGULATION 16 COMPLIANCE REQUIREMENTS

Error: Subreport could not be shown.






Issued On:

ClosedStatus Reason:

Reg 18(3)(b) Reply ReceivedStatus History Action:

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Undertake a screening (Stage 1) for Appropriate Assessment and state whether the discharge(s), individually or in combination with other plans or projects is likely to have a significant effect on a European Site(s), in view of best scientific knowledge and the conservation objectives of the site(s).

You are furthermore advised to refer to the EPA’s guidance ‘Note on Appropriate Assessments for the purposes of the Waste Water Discharge (Authorisation) Regulations, 2007 (S.I. No. 684 of 2007), as amended’, which is available at www.epa.ie./downloads/forms/lic/wwda/ and to refer to the document ‘Appropriate Assessment of Plans and Projects in Ireland – Guidance for Planning Authorities’, issued in 2009 by the Department of the Environment, Heritage and Local Government, and revised in 2010. This document is available at: http://www.npws.ie/publications/archive/NPWS_2009_AA_Guidance.pdf.

Your reply to this notice should include a revised non-technical summary which reflects the information you supply in compliance with the notice, insofar as that information impinges on the non-technical summary.

In the case where any drawings already submitted are subject to revision consequent on this request, a revised drawing should be prepared in each case. It is not sufficient to annotate the original drawing with a textual correction. Where such revised drawings are submitted, provide a list of drawing titles, drawing numbers and revision status, which correlates the revised drawings with the superseded versions.

Please supply the information by 26/10/2012. Please note that all maps/drawings should not exceed A3 in size.

Please direct any queries that you may have in relation to the above to the Inspector Eimer Godsil or to OCLR Admin Team E.

Yours sincerely

Environmental Licensing Programme

Office of Climate, Licensing & Resource Use

Tel: 053-9160600

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http://www.epa.ie./downloads/forms/lic/wwda/

http://www.npws.ie/publications/archive/NPWS_2009_AA_Guidance.pdf

RI000172

Provide an update on the p.e. of the agglomeration B9(i)., and the DWF of the primary discharge. The figures provided should represent peak summertime p.e..

A pending development of 396 is stated in B.9(i), indicate if this development has been

built and if it is included in the updated agglomeration p.e. figure provided above.

a. The design population equivalent (PE) for the Doonbeg WWTP is 1500PE based on a BOD loading

of 60kg/d and DWF of 200m3/d. The peak pumping flow is 10l/s or 864m3/d, i.e. 3.9DWF.

The estimated current population equivalent within the Doonbeg agglomeration is 623 P.E. This

calculation is based on data compiled in 2012 from the Geodirectory database. However no account

is taken of the input from the private group sewerage scheme at Mountrivers (estimated as 96 P.E.)

or from the Doonbeg Golf Club which is licensed pursuant to Section 16 of the Local Government

(Water Pollution) Act, 1977 – 2007 (Ref WPD 07/33). The estimated P.E. from the Doonbeg Golf Club

in Low Season is 116 and in High Season is 245. This would give a total estimated P.E. of 964.

If the assessment for PE is calculated using 2012 influent flow data to the WWTP (from January 2012

to mid-November 2012), the average flow excluding excessive rainfall events is 284m3 and using the

average influent cBOD of 217.7mg/l, then the population equivalent is calculated as 1030 P.E.

b. The pending development as stated in Attachment B.9(i) to the licence application has been

amended to reflect the current status and is provided in Table 1 attached. It is estimated that a total

development of 250 P.E. is pending, however with regard to Planning Reference 04/825, it should be

noted that unless substantial development is in place prior to the expiry date of 31/01/2013, then

the development cannot proceed as an application to extend the appropriate period of planning was

refused in June 2012 - Ref: P12/244. This will then reduce the overall pending development to 111

P.E.

The population equivalent associated with the pending development is not included in the estimated

P.E. described in 1.1.2 above, however the WWTP has capacity to accommodate the additional P.E.

should the developments proceed.

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RI000173

Clarify if sewer system is combined, partially combined, or separate.

The sewer system is separate.

RI000174

Indicate the make-up of the influent load, including the percentage contributed by non-domestic (commercial, industrial etc.) activities.

The discharge to the Doonbeg wastewater treatment plant comprises of domestic wastewaters and

commercial waste streams only, i.e. 100% municipal wastewaters. There are no industrial inputs to

the Doonbeg sewer network or WWTP. The commercial wastewater stream comprises of one Golf

Club development which is licensed (Section 16 licence), a caravan park, and holiday home

development, restaurants, public houses, (all unlicensed), one school, B&B and a number of small

commercial shops.

It is estimated that the influent loading from the commercial waste stream is approximately 30%

during the high-season and 20% during the low-season.

RI000175

Give details, where available, on stormwater overflows as follows:

Number of storage tanks, Capacity of storage tanks,

There is no storm water storage tank associated with the WWTP facility.

There are two pump stations located within the Doonbeg agglomeration. One pump station is

situated in Doonbeg village and any overflow from the pump station discharges to the River

Doonbeg immediately downstream of the bridge in Doonbeg village. The second pump station is

located at Doonmore, to the north-west of the agglomeration. Any overflow from this pump station

discharges to a small stream draining into the lower stretches of the Doonbeg River before it enters

Doonbeg Bay.

During long periods of pump dysfuction, or power outages, the configuration at the pumping

stations is such that there is potential for overflow from the system via a high-level overflow pipe.

Normal operations of the units, even during heavy rainfall do not result in overflow. Both pumping

stations are inspected daily by the caretaker and there are no records available that stormwater has

discharged from either pump stations in the past.

••

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RI000176

Submit an Appropriate Assessment screening assessing the impact of discharges from the agglomeration on the relevant SAC (002250) and SPA (004182).

See attached AA for Doonbeg

RI000177

Provide information on the specification the plant can achieve for BOD, and other relevant parameters in the treated primary effluent.

The design specification for effluent quality is as follows:

No. Parameter Specification

1 BOD 25mg/l

2 COD 125mg/l

Design specifications were not specified for the parameters COD, Total Phosphorus, Total Nitrogen,

Ammonia and o-Phosphate and are not available.

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Table 1 Ref No. Development Permission

Granted P.E.1 Expiry Date Current Status

04/825 53 Houses (P.E. 153.7)

48 houses 139.2 31/01/2013 Development pending. Developer applied to extend the appropriate period of planning in June 2012. This application was refused.

05/2257 30 Houses (P.E. 87)

24 houses 70 09/09/2012 Development pending. Developer applied to extend the appropriate period of planning in August 2012. This application was granted with an expiry date of 08/09/2015.

06/1811 6 Houses (P.E. 17.4)

6 Houses 17.4 23/02/2012 Development pending. Developer applied to extent the appropriate period of planning in February 2012. This application was granted with an expiry date of 22/02/2014.

07/160 11 Houses (P.E. 31.9)

8 Houses 23.2 03/02/2013. Development pending.

07/2068 1 House (P.E.2.9)

1 House 2.9 Permission to demolish existing and construct new house

Total P.E. Granted 253

1 Population equivalent calculated as 2.9 per house;

Clare County Council Reg 18(3)(b) Response Ref:RI000172 Section 1.2 Table 1 Doonbeg D0324-01

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Clare County Council Attachment Appropriate Assessment Doonbeg D0324-01

1

APPROPRIATE ASSESSMENT for DOONBEG

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2

APPROPRIATE ASSESSMENT

1. Introduction

This “appropriate assessment” (AA) is undertaken in accordance with the Wastewater

Discharge Authorisation Note on Appropriate Assessments, issued by the EPA. Due

regard is given to the EC Guidance “Managing Natura 2000 Sites”. In compliance with

the requirements of Article 6 of the directive, and following the guidelines, this AA has

been structured in stages as set out hereunder:

Stage 1 Screening This includes a description of the activity and the discharge; identification of the Natura

2000 sites potentially affected; identification of cumulative impacts on the Natura 2000

site in the vicinity of the discharge; assessment of the significance of the impacts

identified on the site integrity

Stage 2 Appropriate Assessment

This includes a description of elements of the Natura 2000 site which will be considered

further; a description of significant impacts on the conservation features of the site likely

to occur from the discharge; and, recommendations regarding necessary measures to be

taken to ensure the protection of the site and its conservation objectives

Stage 3 Assessment of Alternatives

This examines the current provisions regarding the treatment plant and its discharge and

future provisions to ensure the ongoing protection of the Natura 2000 site

Stage 4 Assessment where no alternatives exist

This examines reasons (if they exist) of overriding public interest for continuation of a

discharge which has a negative impact on the Natura 2000 site.

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3

2. Stage 1 Screening:

Is the Doonbeg WWTP directly connected with or necessary to the management of the

site? No

2.1 Description of the treatment plant

The wastewater treatment plant (WWTP) associated with the Doonbeg application, is

located in the Townland of Doonbeg, County Clare.

The WWTP design consists of an activated sludge process. All sewage gravitates to the

main pumping station situated in the village of Doonbeg. It is then pumped to the

wastewater treatment plant at McGraths Point in Doonbeg Bay. The WWTP consists of a

Primary settlement Tank, Aeration Tank, Clarifier, Sludge Holding Tank and Ultra Violet

Treatment.

The effluent discharge is to the coastal receiving waters Doonbeg Bay Code:

IE_SH_080_0000, located approximately 150 meters offshore at McGraths Point in

Doonbeg Bay. The National Grid Reference for the Primary Discharge Point (SW1) at the

end of the outfall pipe is E096846; N167358.

A full description of the treatment plant and outfall location is set out in the licence

application D0324-01, and shown in Attachment 1 to this report.

2.2 Description of the Natura 2000 site1 The discharge is made to the Carrowmore Dunes SAC Site Code 002250, and comprises of Doughmore Bay and part of Doonbeg Bay. The site is approximately 585 HA in size. The site comprises of fine sandy beaches merging into cobble beach on the seaward side of the sand dunes. Exposed bedrock marks the northern and southern boundaries of the site, which extends seawards to include marine waters for approximately 500m. The site contains a diversity of habitats, plant and animal communities and species and is of considerable conservation significance as it supports good examples of four habitats that are listed on Annex I of the E. U. Habitats Directive as well as supporting a population of rare snail listed in Annex II. Additionally the site has been highly rated for the diversity of marine plant and animal species that it supports.

The site is selected as an SAC for Fixed dunes, Marram dunes, Embryonic shifting dunes

and Reefs. The Fixed dunes with herbaceous vegetation are the largest of the dune

habitats present within the site, with abundant Marram cover in the high dune areas. In

the drier sheltered areas, there is more diverse vegetation, especially in the undisturbed

areas. There is little bare sand and good cover in mosses and lichens within the site. The

1Site synopsis from www.npws.ie

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embryonic shifting dunes are not significantly developed as a result of the exposure and

high levels of coastal erosion at the site. Intertidal reefs occur and are well developed

near McGraths Point due to moderate exposure to wave action. The reef areas are rich in

algal and invertebrate species and support a number of rare taxa. The small area of

intertidal sandflats within the site occur along the length of the site before merging with

the low exposed reefs to the north and south and provide feeding areas for wintering

wildfowl and waders. The site also supports a population of rare snail, Vertigo angustior,

which is listed on Annex II of the E. U. Habitats Directive. A number of bird species use

the site including Clough, Curlew, Dunlin, Oystercatcher, Ringed Plover, Lapwing,

Widgeon, Black-headed Gull and Common Gull.

The discharge is also made to the Mid-Clare Coast SPA Code: 004182. The site extends

for 14 km along the Clare coastline in a south south-westerly direction from Spanish Point

(3km west of Miltown Malbay) to Rinnamryal, just west of Doonbeg Bay, and is

approximately 4641HA in size. The site comprises the mainland shoreline, Mutton Island

and Mattle Island, a series of rocky reefs and open marine water between the islands and

the mainland.

The main shoreline, which is highly exposed, is mostly rocky or stony with well developed

littoral reef communities. There are several sandy beaches as well as areas of intertidal

flats. The site has good examples of vegetated shingle and stony banks, all of which are

very exposed. The largest of the islands is Mutton Island, a medium sized uninhabited

island located approximately 1 km of Lurga Point. The island is dominated by a grassy

sward with some low cliffs on the west side. Mattle Island is a small island located 2km

south of Mattle Island. It is a low-lying island, rising to 12m in the central area. There are

a number of littoral reefs to the north of Mutton Island, namely Carrickaneelwar and Seal

Rock. The large marine area has good examples of sub-tidal reefs.

The site is of ornithological importance for a range of both breeding and wintering birds.

Of special interest are the following bird species: Cormorant, Ringed Plover, Sanderling,

Purple Sandpiper, Dunlin, Turnstone and Barnacle Goose.

Additionally the wetlands areas, waterbirds are a feature of interest of the site. Grey Seal

occur regularly in the area and haul out at the islands. Mutton Island has a high density

of hares, and also has rabbits and feral goats. A copy of the site descriptions is provided

as an attachment to this report Attachment 2.

2.3 Identification of potential impacts

Only those features of the operation of the wastewater treatment plant or the discharge,

which have the potential to impact on interests and conservation objectives of both the

SAC and the SPA sites are considered, together with any potential impact on priority

habitats or species. A number of factors were examined and then dismissed, or, carried

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forward for appropriate assessment, as relevant. The main issue examined in relation to

potential impact on the designated site was the water quality associated with the area of

the discharge from the WWTP.

The potential impacts on the receiving water quality associated with the wastewater

treatment plant are:

• Organic pollution of the receiving waters with untreated or poorly treated sewage.

• Microbial pollution of the receiving waters to the extent that natural marine

habitats or populations would suffer direct or indirect effects

• Pollution of the receiving waters by other pollutants associated with wastewater

(organic compounds or heavy metals)

A deterioration of water quality could affect some habitats or species for which the site

has been designated, either directly by impacting on water quality or indirectly by

impacting on the food chain for various species of flora or fauna.

The discharge is made to the Carrowmore Dunes SAC Site Code 002250 and to the Mid-

Clare Coast SPA Code: 004182. The sites have been selected for the conservation of

habitats listed on Annex I of the EU Habitats Directive i.e. Fixed dunes, Marram dunes,

Embryonic shifting dunes, Reefs and Intertidal sandflats, as well as supporting a

population of rare snail listed in Annex II and because of its ornithological importance for

a range of both breeding and wintering birds.

Clare County Council undertakes monitoring of marine waters in the area during the

period May-September every year, in compliance with the requirements of the EU Bathing

Water Quality Regulations, 2008. This monitoring is undertaken on a fortnightly basis,

during the season, by Clare County Council at White Strand beach Doonbeg

approximately 1.5km from the discharge point. Monitoring data as provided in

Attachment 3 indicates 100% compliance with the requirements of the Regulations for

the monitoring period 2012. Additionally 100% compliance is recorded when the

monitoring data is assessed for Mean and 95%ile values over the four year period 2008 -

2011. Taking account of the sensitivity of the coliform indicator test for impact on water

quality, the bathing water quality results are interpreted as evidence that the discharge

from the Doonbeg agglomeration is not having a detrimental impact on water quality in

the estuary, or on the flora and fauna of the designated site.

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2.4 Elements of the project which (alone or in combination) with other plans or projects have the potential to have a significant effect on the site.

In so far as discharges to marine waters are concerned, it is critical that discharges are

controlled and managed to ensure the impact of any discharge, or combination of

discharges does not

• Give rise to any reduction in the diversity of floral and faunal species

• Cause a change in the integrity of the principal community types;

• Impact on water quality to the extent that the integrity of the principal community

types are affected; and

• Give rise to changes in the extent of any habitat or any population such as to

compromise or threaten the integrity of any habitat or the long term survival of

species associated with any habitat.

The National Grid Reference for the Primary Discharge Point (SW1) at the end of the

outfall pipe is E096846; N167358 to Doonbeg Bay Code: IE_SH_080_0000 within the

boundary of the Carrowmore Dunes SAC Site Code 002250 and to the Mid-Clare Coast

SPA Code: 004182.

This discharge from the WWTP serving the Doonbeg agglomeration constitutes the

element of the project, which has potential for a significant effect on the adjacent

designated sites. The WWTP was constructed in 2005 and results of analysis of the

effluent discharge as provided in Attachment 4, indicates substantial compliance with

the requirements of the Urban Waste Water Treatment Regulations 2001 - 2010.

Other discharges, which can be identified as having potential to have a significant effect

on the site, include

• Discharges to waters in the immediate catchment of Doonbeg will include:

1. Storm water discharges from the roads network in the immediate catchment of

Doonbeg.

2. Diffuse agricultural discharges to waters within the catchment area, which drain

into the Doonbeg Bay coastal water area.

3. Discharges from housing not associated with the sewer network, but within the

catchment area.

These discharges, which are diffuse in nature, are not considered to present a

significant deterioration in water quality in the area or such as would compromise the

conservation status of the designated site, or any protected species within the site.

Other plans and projects considered to have potential to have “in combination” effects are

listed hereunder:

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West Clare Local Development Plan 2012 – 2018 (for which an appropriate

assessment, as required under Article 6 of the Habitats Directive is being

undertaken).

Clare County Development Plan 2011 – 2017 (for which an appropriate assessment,

as required under Article 6 of the Habitats Directive is being undertaken).

In so far as the impact of the combined discharges (listed above), which exist to date is

concerned, they can be assessed by the bathing water quality data recorded, as provided

in Attachment 3, there is no evidence of any compromised water quality in the receiving

waters area immediately adjacent to the discharge from the WWTP serving the Doonbeg

agglomeration.

2.5 Assessment of Significance of the discharge

The Carrowmore Dunes SAC and the Mid-Clare Coast SPA sites are designated as

conservation areas on the basis of a diverse range of marine and coastal habitats,

including Annex I habitats of the EU Habitats Directive. As there is no evidence of a

significant difference in water quality in the vicinity of the discharge from the WWTP

serving the Doonbeg agglomeration, it is considered that there is no impact associated

with the wastewater discharge from Doonbeg agglomeration on the designated habitats

of the protected site.

Referring to the L8/08 Circular, the following queries are raised and answered:

1. Is the development in or on the boundary of an SAC/NHA etc Yes

2. Will nationally protected species be directly impacted? No

3. Is the development a surface water discharge or downstream of a conservation site

with water dependent qualifying habitats/species No

4. Is the development a groundwater discharge/abstraction? No

5. Is the development in the surface water or groundwater catchment of salmonid

waters? No

6. Is the treatment plant in an active/former floodplain? No

7. Is the development a surface water discharge to/from marine waters and within

3km of a marine conservations site? Yes

8. Will the project in combination with other projects (existing and proposed) or

changes to such projects affect the hydrology or water levels of sites of conservation

interest or habitats of protected species? No

L8/08 states that if the conclusion of the screening process above is to “Assess Impacts”

then the project must be referred to the DEHLG Developments Application Unit. As the

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conclusion of the screening process is that there is no discernable impact, the application

has not been referred to the DEHLG Developments Application Unit.

2.6 Conclusion

A screening process was undertaken to determine the potential impact, if any, of the

Doonbeg WWTP discharge on the Carrowmore Dunes SAC and to the Mid-Clare Coast

SPA. No impact is considered likely taking account of the quality of the receiving waters

in the vicinity of the discharge.

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3. Stage 2 Appropriate Assessment

3.1 Introduction

The potential impacts resulting from the effluent discharge from the Doonbeg WWTP are

discussed in relation to the conservation objectives of the Carrowmore Dunes SAC (Site

Code: 002250) and to the Mid-Clare Coast SPA (Site Code: 004182). The conservation

objectives for the Carrowmore Dunes SAC is to maintain or restore the favourable

conservation condition of the Annex I habitats and/or AnnexII species for which the SAC

has been selected, namely the rare snail Vertigo angustior, Reefs, Embryonic shifting

dunes, Shifting dunes along the coastline (white dunes) and Fixed Coastal dunes with

herbaceous vegetation. Similarly the conservation objectives for the Mid-Clare Coast SPA

is to maintain or restore the favourable conservation condition of the bird species listed

as Special Conservation Interests in the SPA, namely Cormorant, Barnacle Goose, Ringed

Plover, Sanderling, Purple Sandpiper, Dunlin and Turnstone.

3.2 General Description

The discharge is made to the Carrowmore Dunes SAC Site Code 002250, and comprises

of Doughmore Bay and part of Doonbeg Bay. The site comprises of fine sandy beaches

merging into cobble beach on the seaward side of the sand dunes. Exposed bedrock

marks the northern and southern boundaries of the site, which extends seawards to

include marine waters for approximately 500m. The site contains a diversity of habitats,

plant and animal communities and species and is of considerable conservation

significance as it supports good examples of four habitats that are listed on Annex I of

the E. U. Habitats Directive as well as supporting a population of rare snail listed in Annex

II. Additionally the site has been highly rated for the diversity of marine plant and animal

species that it supports.

The site is selected as an SAC for Fixed dunes, Marram dunes, Embryonic shifting dunes

and Reefs. The Fixed dunes with herbaceous vegetation are the largest of the dune

habitats present within the site, with abundant Marram cover in the high dune areas. In

the drier sheltered areas, there is more diverse vegetation, especially in the undisturbed

areas. There is little bare sand and good cover in mosses and lichens within the site. The

embryonic shifting dunes are not significantly developed as a result of the exposure and

high levels of coastal erosion at the site. Intertidal reefs occur and are well developed

near McGraths Point due to moderate exposure to wave action. The reef areas are rich in

algal and invertebrate species and support a number of rare taxa. The small area of

intertidal sandflats within the site occur along the length of the site before merging with

the low exposed reefs to the north and south and provide feeding areas for wintering

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10

wildfowl and waders. The site also supports a population of rare snail, Vertigo angustior,

which is listed on Annex II of the E. U. Habitats Directive.

The discharge is also made to the Mid-Clare Coast SPA Code: 004182. The site extends

for 14 km along the Clare coastline in a south south-westerly direction from Spanish Point

(3km west of Miltown Malbay) to Rinnamryal, just west of Doonbeg Bay. The site

comprises the mainland shoreline, Mutton Island and Mattle Island, a series of rocky reefs

and open marine water between the islands and the mainland.

The main shoreline, which is highly exposed, is mostly rocky or stony with well developed

littoral reef communities. There are several sandy beaches as well as areas of intertidal

flats. The site has good examples of vegetated shingle and stony banks, all of which are

very exposed. The largest of the islands is Mutton Island, a medium sized uninhabited

island located approximately 1 km of Lurga Point. The island is dominated by a grassy

sward with some low cliffs on the west side. Mattle Island is a small island located 2km

south of Mutton Island. It is a low-lying island, rising to 12m in the central area. There

are a number of littoral reefs to the north of Mutton Island, namely Carrickaneelwar and

Seal Rock. The large marine area has good examples of sub-tidal reefs.

The site is of ornithological importance for a range of both breeding and wintering birds.

Of special interest are the following bird species: Cormorant, Ringed Plover, Sanderling,

Purple Sandpiper, Dunlin, Turnstone and Barnacle Goose.

Additionally the wetlands areas, waterbirds are a feature of interest of the site. Grey Seal

occur regularly in the area and haul out at the islands. Mutton Island has a high density

of hares, and also has rabbits and feral goats. A copy of the site descriptions is provided

as an attachment to this report Attachment 2.

3.3 Water Quality

There is no monitoring of the receiving waters, Doonbeg Bay Code: IE_SH_080_0000,

undertaken at present, other than monitoring for bathing waters. The Water Framework

Directive (WFD) 2000/60/EC, includes the objective of attaining good status in water

bodies that are of lesser status at present and retaining good status or better where such

status exists at present. A quality status has not been assigned to this waterbody.

Clare County Council undertakes monitoring of bathing waters at White Strand beach,

Doonbeg approximately 1.5 Km from the discharge point, during the period May –

September every year, in compliance with the requirements of the E.U. Bathing Water

Quality Regulations, 2008. The monitoring is undertaken on a fortnightly basis.

The site contains a wide diversity of habitats, plant and animal communities and species.

It is important that the habitat water quality is maintained to ensure the impact of any

discharge, or combination of discharges does not:

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• Give rise to any reduction in the diversity of floral and faunal species.

• Cause a change in the integrity of the principal community types.

• Impact on water quality to the extent that the integrity of the principal community

types is affected; and

• Give rise to changes in the extent of any habitat or any population such as to

threaten the long-term survival of species associated with any habitat.

The main consideration regarding the impact of the discharge from the Doonbeg WWTP in

relation to protection of the conservation status of these sites is to ensure the ongoing

diversity of aquatic species and plant communities, by ensuring the quality of the waters

in the vicinity of the discharge from the treatment plant. In this regard, the monitoring

data on receiving water quality provided in Attachments 3 and 4 to this report indicates

that the receiving waters are of high status, with no detectable deterioration in water

quality in this area.

It is noted that the Marine Strategy Framework Directive 2008, with the objective to

achieve good status for coastal waters by 2020 is in place and is in line with the

objectives of the WFD. It sets up clear targets and management programs for coastal

waters to protect the marine resource base.

3.4 Organic Pollution

When untreated or poorly treated sewage effluent is introduced to a water body, living

conditions for flora and fauna can be affected. Increased turbidity in the water affects

light penetration, which reduces the capacity of the water to support photosynthesizing

plants. Reduced oxygen levels can also have a significant damaging effect for all aquatic

species. Monitoring data (albeit limited data) for the bathing waters in the vicinity of the

discharge, do not indicate a reduction in the water quality status in the receiving waters.

The discharge itself does not contain any industrial component or any chemical liable to

give rise to disturbance in the population of any habitat. Data on the discharge for the

monitoring period January 2010 to June 2012 is provided in Attachment 5 to this report

and indicates substantial compliance with the requirements of the Urban Waste Water

Treatment Regulations, 2001 – 2010. It is therefore considered that organic pollution is

not giving rise to damage to the aquatic habitats.

3.5 Eutrophication

Eutrophication in the marine environment involves the enrichment of waters beyond

natural levels with the nutrient nitrogen. This phenomenon typically results in loss of

biodiversity and degradation of aquatic habitats. Monitoring data of the receiving waters

in the vicinity of the discharge from the Doonbeg WWTP, undertaken as part of the

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application process are provided in Attachment 4 to this report, and indicates low levels

of Nitrogen. While results for the parameter DIN are not available, the level of Total

Nitrogen recorded in the receiving waters would indicate the receiving waters are of high

status. In addition taking account that there is substantial compliance of the effluent

discharge with the requirements of the Urban Waste Water Treatment Regulations, 2001

– 2010, it is considered that the discharge is unlikely to be giving rise to damage to the

aquatic habitats.

3.6 Other potential pollutants

A range of organic compounds with the potential to pollute surface waters are present in

municipal wastewater from densely populated, industrial agglomerations. The sources of

these chemicals are landfills, industrial effluents, medical products and personal hygiene

chemicals. When municipal wastewater is treated in a conventional sewage treatment

plant the average removal of these compounds is in the range 75-95% in sewage

discharges. There is no industrial component, landfill discharge, other source of organic

pollution, or heavy metals in the Doonbeg agglomeration. There is no ongoing monitoring

program being undertaken at present for these substances.

3.7 Estimated impact of wastewater discharges from the Doonbeg WWTP on the receiving water quality

The impact of the discharge from the Doonbeg agglomeration on the nutrient status of

the receiving waters is the main element of consideration in this report. The nutrient

input is the most significant element for consideration in the protection of the

conservation status of the various habitats and species listed for protection in the SAC

and SPA. Water quality status is used as the underlying common denominator to define

the potential impact of this discharge on the waters in the area. The concentration of

nitrogen in the sample undertaken during the application process indicates levels of

nitrogen which are consistent with “high status” for these waters, together with the

results of the bathing water quality in the area and substantial compliance of the effluent

discharge with the requirements of the Urban Waste Water Treatment Regulations, 2001

– 2010, it is considered that the impact of the discharge, in combination with the other

existing discharges in the area is not giving rise to any reduction in the water quality

status, and does not compromise the achievement of the conservation objectives of the

protected area.

3.8 Analysis of in combination effects

The discharges from the Doonbeg WWTP and the diffuse discharges arising from the

catchment of the designated site are taken into account in the assessment of water

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quality at two designated SAC and SPA sites. The study of water quality data, as provided

in Attachments 3 and 4 to this report, indicates that the operation of the Doonbeg

WWTP is not having any adverse impact on water quality in the designated site, or any

adverse impact on the conservation status of the site.

A summary of the potential impacts on the designated site is set out hereunder in Table

1. This Table is prepared on the basis of consideration of various elements liable to give

rise to changes in the habitat area, fragmentation of the habitat area, or damage to

species in the protected area. In so far as the protection of these areas is concerned the

objective is to ensure thee conservation of the habitat type and to maintain its structure

for the future, given on the one hand the possible unfavorable influences and on the

other hand all the reasonable conservation effort which is possible. An essential feature

for their conservation, in the context of this licence application is the prevention of

deterioration of water quality.

Table 1: Assessment of impact of discharges from the Doonbeg agglomeration on SAC

and SPA sites. Describe any likely changes to the site arising as a result of : • reduction of habitat area: • disturbance to key species; • habitat or species fragmentation; • reduction in species density; • changes in key indicators of conservation value (water quality etc) Reduction of habitat area

The discharge from the Doonbeg agglomeration has been ongoing for many years. The WWTP was constructed with appropriate design capacity and treatment process, which includes disinfection of the effluent discharge, and it provides for ongoing protection of habitats in the area. No reduction in habitat area has been linked with the discharge and water quality data does not indicate any significant impact on receiving waters quality in the area.

Disturbance to key species; plants

None

Habitat or species fragmentation

No priority habitat is identified in the vicinity of the discharge.

Reduction in species density

No reduction in species density is anticipated.

Changes in key indicators of conservation value

The discharge from the Doonbeg agglomeration has not altered the conservation status of the site. No changes in the level or composition of the discharge are anticipated. The monitoring and management of the WWTP (under licence) will reduce the potential for pollution events by treatment of the pollution load prior to discharge, prevention of overload of the treatment facility on an ongoing basis, and, management of storm overflows to ensure no untreated wastewater discharges take place. This will have a positive impact on the conservation status of the site

Effects of climate change

Increases in storms and precipitation as a result of climate change are recognised as potential sources of untreated discharges to watercourses. The treatment works have included containment of the higher storm flows, therefore reducing the risk of discharge of nutrients to the receiving waters.

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Describe any likely impacts on the Natura 2000 site as a whole in terms of any interference with the key relationships that define the structure of the site;

Interference with the key relationships that define the structure of the site;

The location of the discharge from the agglomeration is in place many years and there are no proposals in place to make alterations in any way. The WWTP facility will provide ongoing protection of the water quality status of the receiving waters and associated habitats. Loss of species will not occur as a result of the discharge from the WWTP facility

Fragmentation Fragmentation of the site has not been reported as a result of the existing discharge.

Disruption and disturbance

Disruption is not associated with the discharge from the agglomeration. No change to the drainage regime is proposed. No bypassing of the treatment works is proposed at any time

Describe any likely impacts on the Natura 2000 site as a whole in terms of any interference with the key relationships that define the structure of the site;

Change to key elements of the site (e.g. water quality etc.)

Water quality is not currently showing evidence of impact from the existing discharge. The loading to the treatment plant in terms of population served and influent monitoring will be monitored. No potentially polluting substances will be permitted to discharge to off-site surface water or storm drains If analysis or observations of contamination occur, an immediate investigation will be carried out to isolate the source, measures will be put in place to reduce or eliminate the contamination to the environment and it will be reported to the Licensing Authority.

Describe from the above those elements of the project or plan, or combination of elements, where the above impacts are likely to be significant or where the scale or magnitude of impacts are not known.

To date no disruption or disturbance to the protected site has been reported.

3.9 Mitigation Measures

The principal mitigation measure is that appropriate infrastructure to treat wastewaters

from the Doonbeg agglomeration, management of the infrastructure and monitoring is in

place. The design capacity of the WWTP is such that it will ensure compliance with the

Urban Waste Water Regulations, 2001 – 2010. The treatment process includes

disinfection of the wastewaters before final discharge. The full description of the

treatment works is provided in the licence application.

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4. Stage 3 Alternatives

The appropriate assessment presented has not identified adverse impacts associated with

the project, or the project in combination with other projects on the receiving waters.

Appropriate mitigation measures are in place to ensure that any potential adverse

impacts are avoided through provision of appropriate infrastructure, management of the

infrastructure and monitoring of the receiving waters. As no residual adverse effects are

identified on the Special Protection Area or on the Special Area of Conservation,

consideration of alternatives is not required in this process.

5. Stage 4 Imperative Reasons of Overriding Public Interest 1. Are there imperative reasons of overriding public interest? No

2. Are there human health or safety considerations or important environmental benefits? No.

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Clare County Council Appriopriate Assessment Attachment 1 D0324-01 Doonbeg

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SITE SYNOPSIS

SITE NAME : CARROWMORE DUNES

SITE CODE : 002250

Carrowmore Dunes are situated on the south-western coast of County Clare, roughly

midway between Milltown Malbay and Kilkee, and extends from Carrowmore Point

in the north to Doonbeg Bay in the south. Fine sandy beach merges into a cobble

beach on the seaward side of a sand dune system. Exposed bedrock marks the

northern and southern boundaries of the site. Seaward, the site extends for 500m from

the shore to include shallow marine waters. The geology of the site comprises Upper

Carboniferous sandstone and shale. Pure sand dominates the soils on the seaward

side, with increasing organic content further inland.

The site is an SAC selected for fixed dunes, Marram dunes, embryonic shifting dunes

and reefs, habitats that are listed on Annex I of the E.U. Habitats Directive, and for

Vertigo angustior, a species of snail that is listed on Annex II of this directive.

Fixed dune with herbaceous vegetation is the largest dune habitat present within the

site. Typically, the high dunes have an abundant Marram (Ammophila arenaria)

cover and in places attain a height of up to 25 m. At the landward side, in the drier

sheltered hollows a closed grassy community with Red Fescue (Festuca rubra), White

Clover (Trifolium repens), Bulbous Buttercup (Ranunculus bulbosus), Ribwort

Plantain (Plantago lanceolata) and Field Wood-rush (Luzula campestris) has

developed. Species diversity is generally higher in these undisturbed areas, with

Lady’s Bedstraw (Galium verum), Daisy (Bellis perennis), Bird’s-foot Trefoil (Lotus

corniculatus), Common Mouse-ear (Cerastium fontanum) and Yarrow (Achillea

millefolium) being well represented. Notable species present include Squinancywort

(Asperula cynanchica) and a pansy, Viola cf. lutea. Generally, there is little bare sand

and a good cover of mosses (Homalothecium lutescens and Calliergon cuspidatum

most commonly) and lichens (particularly Peltigera canina).

Marram dunes occur on the steeper, seaward slopes of the dunes above the beach and

at the edges of blow-outs. Typically the cover of Marram is high and there is little

ground vegetation over bare sand. Common Scurvygrass (Cochlearia officinalis) and

Coltsfoot (Tussilago farfara) occur occasionally amongst the Marram on the seaward

side, with Red Fescue, Ragwort (Senecio jacobaea), White Clover and Cat’s-ear

(Hypochoeris radicata) increasing inland. Due to the exposure and high levels of

coastal erosion at this site, the embryonic shifting, or fore dunes are not significantly

developed, and consist of a loose sand slope grading into the back of the beach.

Characteristically, there is much bare sand (typically associated with the first stages of

dune building) and the habitat is species-poor, being dominated by Sand Couch

(Elymus farctus). Unlike similar habitat types in east coast dunes, the intensity of the

erosional processes are greater than the depositional ones, so that separate ridges of

different ages are not clearly discernible in this dune system.

Clare County Council Appropriate Assessment Attachment 2 D0324-01 Doonbeg

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Intertidal reefs occur on the seaward side of the site, and are particularly well-

developed about Magrath’s Point at the southern end of the site. Here the shore is

moderately exposed to wave action and comprises a wide expanse of shallowly

sloping bedrock that is stratified and set at an incline to form shallow ridges and

furrows running obliquely or horizontally across the shore. There are extensive rock

pools in the mid-shore and, below this, an area of unstable boulders, cobbles, pebbles

and gravel. The reef is particularly rich in algal and invertebrate species and supports

a number of rare taxa, including the snapping shrimp (Alpheus macrocheles) and the

algae Phyllophora sicula and Pterosiphonia pennata.

This site contains a relatively small area of intertidal sandflats, comprised of fine to

course sand. The main expanse of sandflats occurs along the length of the site before

merging northwards and southwards with low exposed reefs. Other than occasional

Eelgrass (Zostera marina), plant species are typically scarce. The sandflats provide

feeding areas for wintering wildfowl and waders.

The site supports a population of the rare snail, Vertigo angustior, a species that is

listed on Annex II of the E.U. Habitats Directive.

The site is used by a number of bird species, including Chough, a species that is listed

on Annex I of the E.U. Birds Directive, Curlew, Dunlin, Oystercatcher, Ringed

Plover, Lapwing, Wigeon, Black-headed Gull and Common Gull. A number of other

species are intermittent visitors and use a range of other sites along this coastline.

The Carrowmore Dunes site is of considerable conservation significance, supporting

as it does, good examples of four habitats that are listed on Annex I of the E.U.

Habitats Directive, as well as a population of the rare Annex II snail, Vertigo

angustior.

24.06.2003


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Generic Conservation Objective18 July 2011

Conservation Objectives for Carrowmore Dunes SAC [002250]

European and national legislation places a collective obligation on Ireland and its citizens to maintain habitats and species in the Natura 2000 network at favourable conservation condition. The Government and its agencies are responsible for the implementation and enforcement of regulations that will ensure the ecological integrity of these sites.

Favourable conservation status of a habitat is achieved when: • its natural range, and area it covers within that range, are stable or increasing, and • the specific structure and functions which are necessary for its long‐term maintenance exist and are likely to continue to exist for the foreseeable future, and • the conservation status of its typical species is favourable.

The favourable conservation status of a species is achieved when: • population dynamics data on the species concerned indicate that it is maintaining itself on a long‐term basis as a viable component of its natural habitats, and • the natural range of the species is neither being reduced nor is likely to be reduced for the foreseeable future, and • there is, and will probably continue to be, a sufficiently large habitat to maintain its populations on a long‐term basis.

Objective: To maintain or restore the favourable conservation condition of the Annex I habitat(s) and/or the Annex II species for which the SAC has been selected:

The overall aim of the Habitats Directive is to maintain or restore the favourable conservation status of habitats and species of community interest. These habitats and species are listed in the Habitats and Birds Directives and Special Areas of Conservation and Special Protection Areas are designated to afford protection to the most vulnerable of them. These two designations are collectively known as the Natura 2000 network.

The maintenance of habitats and species within Natura 2000 sites at favourable conservation condition will contribute to the overall maintenance of favourable conservation status of those habitats and species at a national level.

Start 002250

Vertigo angustior [1014]

Reefs [1170]

Embryonic shifting dunes [2110]

Shifting dunes along the shoreline with Ammophila arenaria ("white dunes") [2120]

* Fixed coastal dunes with herbaceous vegetation ("grey dunes") [2130]

For more information please go to: www.npws.ie/protectedsites/conservationmanagementplanning

NPWS (2011) Conservation objectives for Carrowmore Dunes SAC [002250]. Generic Version 3.0. Department of Arts, Heritage & the Gaeltacht.

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SITE SYNOPSISSITE SYNOPSISSITE SYNOPSISSITE SYNOPSIS

SITE NAMESITE NAMESITE NAMESITE NAME: MID-CLARE COAST SPA: MID-CLARE COAST SPA: MID-CLARE COAST SPA: MID-CLARE COAST SPA

SITE CODESITE CODESITE CODESITE CODE: 004182: 004182: 004182: 004182

This site extends along the Co. Clare coastline in a south-south-westerly direction from SpanishPoint (3 km west of Milltown Malbay) to just west of Doonbeg Bay, a distance of some 14 km. Itcomprises the mainland shoreline, Mutton Island and Mattle Island, a series of rocky reefs andthe open marine water of Mal Bay between the islands and the mainland. Underlying the site areCarboniferous grits which are bedded at a low angle and which give rise to surf conditions inplaces along the coast. The headlands and islands experience some of the most severeconditions of exposure in Ireland.

The mainland shoreline is mostly rocky or stony, though there are several sandy beaches andareas of intertidal flats. There are excellent examples of littoral reef communities, which haveextremely high species richness and include uncommon species such as Paracentrotus lividusand Bifurcaria bifurcata. Sublittorally, the area is important for its deep, exposed reefcommunities that are characterized by unusual and delicate, erect sponges, including the fragileanthozoan Eunicella verrucosa, the rare sponge Tetilla zetlandica and the anthozoanParazoanthus axinellae.

Shingle or stony banks are found at the base of cliffs and at the head of bays. Due to theirexposure these support a sparse cover of vegetation including such species as Sea Beet (Betavulgaris subsp. maritima), Orache (Atriplex spp.), Sea Mayweed (Matricaria maritima), Silverweed(Potentilla anserina) and Sea-milkwort (Glaux maritima). Small sand dune systems are foundnear Spanish Point, about Lurga Point and further south. The stretch of coastline between Quiltyand Lurga Point has extensive areas of mud and sand flats and supports nationally important birdpopulations. Further intertidal flats occur at Doughmore Bay and Doonbeg Bay.

Mutton Island is a medium-sized, uninhabited, island situated approximately 1 km from LurgaPoint. It is a fairly low-lying island, rising to 28 m in the west where some cliffs occur. The southand eastern shores are low-lying and comprised of cobbles and boulders. Several small sandycoves exist. Much of the interior of the island is unmanaged dry grassland with a maritimecharacter. Some of the plants present reflect the past agricultural activities. Wet grassland alsooccurs and, in places, heath vegetation has developed. A small freshwater pond occurs on theisland. The island is grazed in summer. A group of littoral reefs occur to the north, notablyCarrickaneelwar and Seal Rock. Mattle Island is a small island situated approximately 2 km southof Mutton Island. It is a low-lying island, rising to only 12 m in the central area. The island ishighly exposed to the force of the Atlantic Ocean. The terrestrial component of the island isdominated by maritime grassland.

The site is a Special Protection Area (SPA) under the E.U. Birds Directive, of special conservationinterest for the following species: Cormorant, Barnacle Goose, Ringed Plover, Sanderling, PurpleSandpiper, Dunlin and Turnstone. The E.U. Birds Directive pays particular attention to wetlands,and as these form part of this SPA, the site and its associated waterbirds are of specialconservation interest for Wetland & Waterbirds.


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The site is of ornithological importance for a range of both breeding and wintering birds. StormPetrel has long been known to breed on Mutton Island, though there has never been aquantitative estimate and there is no recent proof of breeding. Rats are common on the islandand if a colony still exists it is likely to be small. It is possible that Storm Petrel could also breedon Mattle Island but there is no proof of this.

Mattle Island supports a nationally important breeding colony of Cormorant, with 60 nestspresent in May 1990. Both Mutton and Mattle have breeding Shag, estimated at less than 40pairs in total in 1990. Both islands have nesting Herring Gull (probably less than 40 pairs) andGreat Black-backed Gull (possibly up to 70 pairs), while Mutton Island has Lesser Black-backedGull (24 pairs in 1995) and Common Gull (c. 10 pairs in 1995). Black Guillemot breed at least onMutton Island (7 pairs in 1990). The nesting seabirds utilise the shallow waters which surroundthe island for foraging and socializing. An up-to-date survey of all breeding seabirds on theislands is required.

An important population of Barnacle Goose winters on Mutton Island, with birds occasionallyvisiting Mattle Island and feeding sites on the mainland. Mutton provides both feeding androosting sites. The population is of national importance though at times exceeds the thresholdfor international importance (350 birds were present in spring 1994 and 215 in spring 1999).

The mainland shore is important for wintering waders, especially Ringed Plover (316), PurpleSandpiper (393), Dunlin (2,708), Sanderling (272) and Turnstone (571) - figures given are averagepeaks for the 5 winters 1995/96-1999/00; all of these populations exceed the respectivethresholds for national importance. Other species which occur in winter include Golden Plover,Grey Plover, Oystercatcher, Lapwing, Curlew and Redshank. Some of the waders may commute tothe islands. The shallow seas are frequented by both Great Northern Divers and Red-throatedDivers.

A variety of terrestrial birds occur on the island and are presumed to breed there. These includeSkylark, Meadow Pipit, Rock Pipit, Pied Wagtail, Raven, Swallow, Wheatear and Stonechat.

Grey Seal occur regularly in the area and haul out on the islands. Mutton Island has a highdensity of hares, and also has rabbits and feral goats.

The presence of rats on Mutton Island, and possibly Mattle, is considered to be an importantreason for the relatively low numbers of nesting seabirds. Grazing by goats and rabbits onMutton Island could lead to soil erosion. Increase in the number of tourists to Mutton Islandcould also affect breeding birds.

This site is of high ornithological importance. It supports a nationally important population ofwintering Barnacle Goose, as well as nationally important numbers of five wader species. Insummer it has nationally important breeding colonies of Cormorant and Great Black-backed Gull,as well as range of other seabird species. Storm Petrel may still breed. Of particular note is thatBarnacle Goose, Storm Petrel, Golden Plover, Great Northern Diver and Red-throated Diver arelisted on Annex I of the E.U. Birds Directive.

15.5.2007


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Generic Conservation Objective 26 January 2011

Conservation Objectives for Mid‐Clare Coast SPA [004182]

European and national legislation places a collective obligation on Ireland and its citizens to maintain habitats and species in the Natura 2000 network at favourable conservation condition. The Government and its agencies are responsible for the implementation and enforcement of regulations that will ensure the ecological integrity of these sites.

Favourable conservation status of a habitat is achieved when: • 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 • the conservation status of its typical species is favourable.

The favourable conservation status of a species is achieved when: • population data on the species concerned indicate that it is maintaining itself, and • the natural range of the species is neither being reduced or 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.

Objective: To maintain or restore the favourable conservation condition of the bird species listed as Special Conservation Interests for this SPA:

The overall aim of the Habitats Directive is to maintain or restore the favourable conservation status of habitats and species of community interest. These habitats and species are listed in the Habitats and Birds Directives and Special Areas of Conservation and Special Protection Areas are designated to afford protection to the most vulnerable of them. These two designations are collectively known as the Natura 2000 network.

The maintenance of habitats and species within Natura 2000 sites at favourable conservation condition will contribute to the overall maintenance of favourable conservation status of those habitats and species at a national level.

Start 004182

Phalacrocorax carbo [breeding ]Charadrius hiaticula [wintering]Calidris alba [wintering]Calidris maritima [wintering]Calidris alpina [wintering]Arenaria interpres [wintering]Branta leucopsis [wintering]

For more information please go to: www.npws.ie/en/protectedsites/conservationmanagementplanning

NPWS (2011) Conservation objectives for Mid‐Clare Coast SPA [004182]. Generic Version 2.0. Department of the Environment Heritage & Local Government.

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Clare County Coouncil Attachment 3 Appropriate Assessment D0324-01 Doonbeg

Blue Flag Beach Bathing Water Criteria 2011Country: Ireland No. of samplings year 1: 12bf-name: Whitestrand, Doonbeg No. of samplings year 2: 8bf-nat-id: IESHBWT080_0100_0100 No. of samplings year 3: 7Nuts-no: 8005010089160240898 No. of samplings year 4: 8

Bathing season Year 1: Bathing season Year 2:Start: 01/06/2008 Start: 01/06/2009End: 31/08/2008 End: 31/08/2009

Sampling dates Year 1: Sampling dates Year 2:Start: 03/06/2008 Start: 02/06/2009End: 26/08/2008 End: 24/08/2009

Bathing season Year 3: Bathing season Year 4:Start: 01/06/2010 Start: 01/06/2011End: 31/08/2010 End: 15/09/2011

Sampling dates Year 3: Sampling dates Year 4:Start: 01/06/2010 Start: 07/06/2011End: 23/08/2010 End: 14/09/2011

Frequency Frequencybetween OK / E. Coli (max 250 cfu/100 ml)

Sampling date E. Coli I.E. samplings NOT OK OK or exceeding? log 10 OK or exceeding? log 10(no. per 100 ml.) (no. per 100 ml.)

YEAR 1 03/06/2008 1 10 OK 0 OK 110/06/2008 1 10 7 OK OK 0 OK 116/06/2008 1 10 6 OK OK 0 OK 124/06/2008 1 10 8 OK OK 0 OK 101/07/2008 1 10 7 OK OK 0 OK 108/07/2008 1 10 7 OK OK 0 OK 122/07/2008 1 10 14 OK OK 0 OK 128/07/2008 2 10 6 OK OK 0.3010 OK 106/08/2008 11 10 9 OK OK 1.0414 OK 112/08/2008 1 31 6 OK OK 0 OK 1.491418/08/2008 1 31 6 OK OK 0 OK 1.491426/08/2008 1 10 8 OK OK 0 OK 1

YEAR2 02/06/2009 1 10 OK 0 OK 108/06/2009 1 10 6 OK OK 0 OK 115/06/2009 1 10 7 OK OK 0 OK 129/06/2009 1 20 14 OK OK 0 OK 1.301013/07/2009 75 46 14 OK OK 1.8751 OK 1.662827/07/2009 8 20 14 OK OK 0.9031 OK 1.301011/08/2009 23 30 15 OK OK 1.3617 OK 1.477124/08/2009 1 52 13 OK OK 0 OK 1.7160

IE (max 100 cfu/100 ml)

1

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Clare County Coouncil Attachment 3 Appropriate Assessment D0324-01 Doonbeg

YEAR 3 01/06/2010 10 10 OK 1 OK 114/06/2010 10 10 13 OK OK 1 OK 128/06/2010 10 10 14 OK OK 1 OK 112/07/2010 52 10 14 OK OK 1.7160 OK 126/07/2010 31 10 14 OK OK 1.4914 OK 109/08/2010 10 10 14 OK OK 1 OK 123/08/2010 20 10 14 OK OK 1.3010 OK 1

YEAR 4 07/06/2011 86 90 OK 1.9345 OK 1.954220/06/2011 10 10 13 OK OK 1 OK 105/07/2011 10 10 15 OK OK 1 OK 118/07/2011 10 10 13 OK OK 1 OK 102/08/2011 85 40 15 OK OK 1.9294 OK 1.602115/08/2011 31 1 13 OK OK 1.4914 OK 029/08/2011 10 10 14 OK OK 1 OK 114/09/2011 10 10 16 OK OK 1 OK 1

Necessary no. of samplings per year: 5Check: Enough samples taken in year 1? OK MEAN 0.696 MEAN 1.114Check: Enough samples taken in year 2? OK Standard deviation 0.685 Standard deviation 0.328Check: Enough samples taken in year 3? OK mean+1.65*std deviation 1.827 mean+1.65*std deviation 1.656Check: Enough samples taken in year 4? OK Upper 95th percentile 67.090 Upper 95th percentile 45.246Necessary no. of samplings for 4 years 20 Compliance? OK Compliance? OKCheck: Enough samples taken in Total 4 ye OK

95th percentile Calculation

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Clare County Council Attachment 3 Appropriate Assessment D0324-01 Doonbeg

Bathing Water Quality Whitestrand, Doonbeg Date E.Coli Entero 22/05/2012 52 52 05/06/2012 93 93 18/06/2012 <10 <10 03/07/2012 97 97 16/07/2012 Not Sampled Not Sampled 18/07/2012 <10 <10 20/07/2012 40 <10 24/07/2012 Not Sampled Not Sampled 30/07/2012 <10 <10 13/08/2012 <10 <10 27/08/2012 52 30

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WWD Licence Application - Doonbeg Wastewater Treatment Plant - Page: 1

WWD Licence Application

Agglomeration details

Contact details

Leading Local Authority Clare County CouncilCo-ApplicantsAgglomeration Doonbeg Wastewater Treatment PlantPopulation Equivalent 1500Level of Treatment TieretryTreatment plant address Mc Graths Point

DoonbegCo. Clare

Grid Ref (12 digits, 6E, 6N) 496908 / 667106 (Verifed using GPS)EPA Reference No:

Contact Name: Derek TroyContact Address: Kirush Town Council

Town HallKilrushCo. Clare

Contact Number: 065 9051047Contact Fax: 065 9052821Contact Email: [email protected]


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WWD Licence Application Annex I

Table D.1(i)(a): EMISSIONS TO SURFACE/GROUND WATERS (Primary Discharge Point)

Discharge Point Code: SW-1

Emission Details:

Local Authority Ref No:Source of Emission: Doonbeg Wastewater Treatment PlantLocation: Mc Graths Point, Doonbeg, Co. ClareGrid Ref (12 digits, 6E, 6N) 496846 / 667358 (Verifed using GPS)Name of Receiving waters: Doonbeg BayWater Body: Coastal Water BodyRiver Basin District Shannon IRBDDesignation of Receiving Waters: NoneFlow Rate in Receiving Waters: 0 m3.sec-1 Dry Weather Flow

0 m3.sec-1 95% Weather FlowAdditional Comments (e.g.commentary on zero flow or otherinformation deemed of value)

No Dry Weather Flows as waters are coastal.

(i)Volume emittedNormal/day 80 m3 Maximum/day 0 m3

Maximumrate/hour

0 m3 Period of emission(avg)

60 min/hr 24 hr/day 365 day/yr

Dry Weather Flow 0 m3/sec


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Table D.1(i)(b): EMISSIONS TO SURFACE/GROUND WATERS - Characteristics of The Emission

(Primary Discharge Point)


For Orthophosphate: this monitoring should be undertaken on a sample filtered on 0.45µm filter paper

For Phenols: USEPA Method 604, AWWA Standard Method 6240, or equivalent.

Substance As discharged

Unit ofMeasurement

Sampling Method Max Daily Avg. kg/day

pH pH Grab = 7.4

Temperature °C Grab = 0

Electrical Conductivity (@ 25°C) µS/cm Grab = 738

Suspended Solids mg/l Grab = 4

Ammonia (as N) mg/l Grab = 0.04

Biochemical Oxygen Demand mg/l Grab = 0

Chemical Oxygen Demand mg/l Grab = 18

Total Nitrogen (as N) mg/l Grab = 6.55

Nitrite (as N) mg/l Grab = 0.141

Nitrate (as N) mg/l Grab = 5.84

Total Phosphorous (as P) mg/l Grab = 1.37

OrthoPhosphate (as P) mg/l Grab = 0.001

Sulphate (SO4) mg/l Grab = 61

Phenols (Sum) µg/l Grab = 0


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Table D.1(i)(c): DANGEROUS SUBSTANCE EMISSIONS TO SURFACE/GROUND WATERS -

Characteristics of The Emission (Primary Discharge Point)




Substance As discharged

Unit ofMeasurement

Sampling Method Max Daily Avg. kg/day

Atrazine µg/l Grab = 0

Dichloromethane µg/l Grab = 0

Simazine µg/l Grab = 0

Toluene µg/l Grab = 0

Tributyltin µg/l Grab = 0

Xylenes µg/l Grab = 0

Arsenic µg/l Grab = 2.3

Chromium µg/l Grab = 0

Copper µg/l Grab = 0

Cyanide µg/l Grab = 4

Flouride µg/l Grab = 0.33

Lead µg/l Grab = 0

Nickel µg/l Grab = 0.4

Zinc µg/l Grab = 37.2

Boron µg/l Grab = 0

Cadmium µg/l Grab = 0

Mercury µg/l Grab = 0

Selenium µg/l Grab = 5.7

Barium µg/l Grab = 13.5


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Table D.1(iii)(a): EMISSIONS TO SURFACE/GROUND WATERS (Storm Overflow)


Emission Details:

Local Authority Ref No:Source of Emission: Doonbeg Pumping StationLocation: Doonbeg VillageGrid Ref (12 digits, 6E, 6N) 497116 / 665567 (Verifed using GPS)Name of Receiving waters: Doonbeg RiverWater Body: River Water BodyRiver Basin District Shannon IRBDDesignation of Receiving Waters: NoneFlow Rate in Receiving Waters: m3.sec-1 Dry Weather Flow

m3.sec-1 95% Weather FlowAdditional Comments (e.g.commentary on zero flow or otherinformation deemed of value)

No Dry Weather Flows available. No record as to quantityor frequencey this emergency overflow is used.

(i)Volume emittedNormal/day m3 Maximum/day m3

Maximumrate/hour

m3 Period of emission(avg)

min/hr hr/day day/yr

Dry Weather Flow m3/sec


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TABLE E.1(i): WASTE WATER FREQUENCY AND QUANTITY OF DISCHARGE – Primary and

Secondary Discharge Points

Identification Code for Discharge point Frequency of discharge (days/annum) Quantity of Waste Water Discharged

(m³/annum)

SW-1 365 29200


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TABLE E.1(ii): WASTE WATER FREQUENCY AND QUANTITY OF DISCHARGE – Storm Water

Overflows

Identification Code for Dischargepoint

Frequency of discharge(days/annum)

Quantity of Waste WaterDischarged (m³/annum)

Complies with Definition of StormWater Overflow

SW-2 Yes


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TABLE F.1(i)(a): SURFACE/GROUND WATER MONITORING

Primary Discharge Point



Discharge Point Code: SW-1MONITORING POINT CODE: aSW-1dGrid Ref (12 digits, 6E, 6N) 496818 / 667356 (Verifed using GPS)

Parameter Results (mg/l) Samplingmethod

Limit ofQuantitation

Analysismethod /technique

12/12/08

pH = 7.8 Grab 0.01 ELECTROMETRY

Temperature = 0 Grab 0

Electrical Conductivity (@25°C)

= 39500 Grab 0.5 SPECTROMETRY

Suspended Solids = 361 Grab 3 DRYING@104C

Ammonia (as N) = 0.24 Grab 0.09 COLORIMETRY

Biochemical Oxygen Demand = 0 Grab 2 ELECTROMETRY

Chemical Oxygen Demand = 10 Grab 5 COLORIMETRY

Dissolved Oxygen = 0 Grab 0

Hardness (as CaCO3) = 5143 Grab 10 COLORIMETRY

Total Nitrogen (as N) = 2.34 Grab 1 CALCULATION

Nitrite (as N) = 0.007 Grab 0.003 COLORIMETRY

Nitrate (as N) = 2.34 Grab 0.09 COLIMETRY

Total Phosphorous (as P) = 0.021 Grab 0.005 COLORIMETRY/DIGESTION

OrthoPhosphate (as P) = 0.001 Grab 0.006 COLORIMETRY

Sulphate (SO4) = 1276.33 Grab 2.11 COLORIMETRY

Phenols (Sum) = 0 Grab 0.1 GC-MS2

Additional Comments:


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TABLE F.1(i)(b): SURFACE/GROUND WATER MONITORING (Dangerous Substances)


Discharge Point Code: SW-1MONITORING POINT CODE: aSW-1dGrid Ref (12 digits, 6E, 6N) 496818 / 667356 (Verifed using GPS)

Parameter Results (µg/l) Samplingmethod



12/12/08

Atrazine = 0 Grab 0.01 HPLC

Dichloromethane = 0 Grab 1 GC-MS 1

Simazine = 0 Grab 0.01 HPLC

Toluene = 0 Grab 1 GC-MS 1

Tributyltin = 0 Grab 0.02 GCMS

Xylenes = 0 Grab 1 GC-MS 1

Arsenic = 7.4 Grab 0.96 ICPMS

Chromium = 0 Grab 0.93 ICPMS

Copper = 19.6 Grab 0.2 ICPMS

Cyanide = 2 Grab 5 COLORIMETRY

Flouride = 0.73 Grab 0.09 COLORIMETRY

Lead = 0 Grab 0.38 ICPMS

Nickel = 0 Grab 0.47 ICPMS

Zinc = 0 Grab 4.6 ICPMS

Boron = 3437 Grab 4.2 ICPMS

Cadmium = 0 Grab 0.09 ICPMS

Mercury = 0 Grab 0.2 ICPMS

Selenium = 31.9 Grab 0.74 ICPMS

Barium = 2.5 Grab 0.74 ICPMS



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TABLE F.1(i)(a): SURFACE/GROUND WATER MONITORING




Discharge Point Code: SW-1MONITORING POINT CODE: aSW-1uGrid Ref (12 digits, 6E, 6N) 496846 / 667358 (Verifed using GPS)

Parameter Results (mg/l) Samplingmethod



12/12/08

pH = 7.8 Grab 0.01 ELECTROMETRY

Temperature = 0 Grab 0

Electrical Conductivity (@25°C)

= 49000 Grab 0.5 SPECTROMETRY

Suspended Solids = 374 Grab 3 DRYING@104c

Ammonia (as N) = 0.3 Grab 0.09 COLORIMETRY

Biochemical Oxygen Demand = 0 Grab 2 ELECTROMETRY

Chemical Oxygen Demand = 5 Grab 5 COLORIMETRY

Dissolved Oxygen = 0 Grab 0

Hardness (as CaCO3) = 6517 Grab 10 COLORIMETRY

Total Nitrogen (as N) = 1.52 Grab 1 CALCULATION

Nitrite (as N) = 0.004 Grab 0.003 COLORIMETRY

Nitrate (as N) = 1.52 Grab 0.09 COLORIMETRY

Total Phosphorous (as P) = 0 Grab 0.005 COLORIMETRY/DIGESTION

OrthoPhosphate (as P) = 0.004 Grab 0.006 COLORIMETRY

Sulphate (SO4) = 1311.41 Grab 2.11 COLORIMETRY

Phenols (Sum) = 0 Grab 0.1 gc-ms2



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TABLE F.1(i)(b): SURFACE/GROUND WATER MONITORING (Dangerous Substances)


Discharge Point Code: SW-1MONITORING POINT CODE: aSW-1uGrid Ref (12 digits, 6E, 6N) 496846 / 667358 (Verifed using GPS)

Parameter Results (µg/l) Samplingmethod



12/12/08

Atrazine = 0 Grab 0.01 HPLC

Dichloromethane = 0 Grab 1 GC-MS 1

Simazine = 0 Grab 0.01 HPLC

Toluene = 0 Grab 1 GC-MS 1

Tributyltin = 0 Grab 0.02 GCMS

Xylenes = 0 Grab 1 GC-MS 1

Arsenic = 263.2 Grab 0.96 ICPMS

Chromium = 0.2 Grab 0.93 ICPMS

Copper = 14.3 Grab 0.2 ICPMS

Cyanide = 0 Grab 5 COLORIMETRY

Flouride = 0.82 Grab 0.09 COLORIMETRY

Lead = 0 Grab 0.38 ICPMS

Nickel = 0.6 Grab 0.47 ICPMS

Zinc = 0 Grab 4.6 ICPMS

Boron = 4098 Grab 4.2 ICPMS

Cadmium = 0 Grab 0.09 ICPMS

Mercury = 0 Grab 0.2 ICPMS

Selenium = 1508 Grab 0.74 ICPMS

Barium = 6.1 Grab 0.74 ICPMS



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WWD Licence Application Annex II

Annex 2: Check List For Regulation 16 Compliance

Regulation 16 of the waste water discharge (Authorisation) Regulations 2007 (S.I. No. 684 of 2007) sets out the information which must, in all

cases, accompany a discharge licence application. In order to ensure that the application fully complies with the legal requirements of regulation 16

of the 2007 Regulations, all applicants should complete the following.

In each case, refer to the attachment number(s), of your application which contains(s) the information requested in the appropiate sub-article.

Regulation 16(1)In the case of an application for a waste water discharge licence, the application shall -

Attachment Number Checked by Applicant

(a) give the name, address, telefax number (if any) and telephone number of theapplicant (and, if different, of the operator of any treatment plant concerned) and theaddress to which correspondence relating to the application should be sent and, if theoperator is a body corporate, the address of its registered office or principal office,

B1 Yes

(b) give the name of the water services authority in whose functional area the relevantwaste water discharge takes place or is to take place, if different from that of theapplicant,

B1 Yes

(c) give the location or postal address (including where appropriate, the name of thetownland or townlands) and the National Grid reference of the location of the wastewater treatment plant and/or the waste water discharge point or points to which theapplication relates,

B2 & B4 Yes

(d) state the population equivalent of the agglomeration to which the application relates, B 9(i) Yes

(e) specify the content and extent of the waste water discharge, the level of treatmentprovided, if any, and the flow and type of discharge,

F1 Yes

(f) give details of the receiving water body, including its protected area status, if any, anddetails of any sensitive areas or protected areas or both in the vicinity of thedischarge point or points likely to be affected by the discharge concerned, and fordischarges to ground provide details of groundwater protection schemes in place forthe receiving water body and all associated hydrogeological and geologicalassessments related to the receiving water environment in the vicinity of thedischarge.

F1 Yes

(g) identify monitoring and sampling points and indicate proposed arrangements for themonitoring of discharges and, if Regulation 17 does not apply, provide details of thelikely environmental consequences of any such discharges,

B2 TABLES IN ANNEX1

Yes

(h) in the case of an existing waste water treatment plant, specify the sampling datapertaining to the discharge based on the samples taken in the 12 months precedingthe making of the application,

E4 Yes

(i) describe the existing or proposed measures, including emergency procedures, toprevent unintended waste water discharges and to minimise the impact on theenvironment of any such discharges,

C1.1 Yes

(j) give particulars of the nearest downstream drinking water abstraction point or pointsto the discharge point or points,

NOT APPLICABLE Yes

(k) give details, and an assessment of the effects, of any existing or proposed emissionson the environment, including any environmental medium other than those into whichthe emissions are, or are to be made, and of proposed measures to prevent oreliminate or, where that is not practicable, to limit any pollution caused in suchdischarges,

F1 Yes

(l) give detail of compliance with relevant monitoring requirements and treatmentstandards contained in any applicable Council Directives of Regulations,

G1 Yes

(m) give details of any work necessary to meet relevant effluent discharge standards anda timeframe and schedule for such work.

B10 No

(n) Any other information as may be stipulated by the Agency. No

Regulation 16(3)Without prejudice to Regulation 16 (1) and (2), an application for a licence shall beaccompanied by -


(a) a copy of the notice of intention to make an application given pursuant to Regulation9,

B8 Yes

(b) where appropriate, a copy of the notice given to a relevant water services authorityunder Regulation 13,

NOT APPLICABLE Yes

(c) Such other particulars, drawings, maps, reports and supporting documentation as arenecessary to identify and describe, as appropriate -

B2 Yes

(c) (i) the point or points, including storm water overflows, from which a discharge ordischarges take place or are to take place, and

B2 Yes

(c) (ii) the point or points at which monitoring and sampling are undertaken or are to beundertaken,

B2 Yes

(d) such fee as is appropriate having regard to the provisions of Regulations 38 and 39. B9(iii) No


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WWD Licence Application Annex II

Regulation 16(4)An original application shall be accompanied by 2 copies of it and of all accompanyingdocuments and particulars as required under Regulation 16(3) in hardcopy or in an electronicor other format as specified by the Agency.


1 An Original Application shall be accompanied by 2 copies of it and of allaccompanying documents and particulars as required under regulation 16(3) inhardcopy or in electronic or other format as specified by the agancy.

ORIGINAL & 2 COPIES Yes

Regulation 16(5)For the purpose of paragraph (4), all or part of the 2 copies of the said application andassociated documents and particulars may, with the agreement of the Agency, be submitted inan electronic or other format specified by the Agency.


1 Signed original. ATTACHED Yes

2 2 hardcopies of application provided or 2 CD versions of application (PDF files)provided.

ATTACHED Yes

3 1 CD of geo-referenced digital files provided. ATTACHED Yes

Regulation 17Where a treatment plant associated with the relevant waste water works is or has beensubject to the European Communities (Environmental Impact Assessment) Regulations 1989to 2001, in addition to compliance with the requirements of Regulation 16, an application inrespect of the relevant discharge shall be accompanied by a copy of an environmental impactstatement and approval in accordance with the Act of 2000 in respect of the said developmentand may be submitted in an electronic or other format specified by the Agency


3 2 CD versions of EIS, as PDF files, provided. NOT APPLICABLE Yes

1 EIA provided if applicable NOT APPLICABLE Yes

2 2 hardcopies of EIS provided if applicable. NOT APPLICABLE Yes

Regulation 24In the case of an application for a waste water discharge certificate of authorisation, theapplication shall –


(a) give the name, address, telefax number (if any) and telephone number of theapplicant and the address to which correspondence relating to the application shouldbe sent and, if the operator of the waste water works is a body corporate, the addressof its registered office or principal office

(b) give the name of the water services authority in whose functional area the relevantwaste water discharge takes place or is to take place, if different from that of theapplicant,

(c) give the location or postal address (including where appropriate, the name of thetownland or townlands) and the National Grid reference of the location of thedischarge point or points to which the application relates,

(d) state the population equivalent of the agglomeration to which the application relates,

(e) in the case of an application for the review of a certificate, specify the referencenumber given to the relevant certificate in the register,

(f) specify the content and extent of the waste water discharge, the level of treatmentprovided and the flow and type of discharge,

(g) give details of the receiving water body, its protected area status, if any, and details ofany sensitive areas or protected areas, or both, in the vicinity of the discharge point orpoints or likely to be affected by the discharge concerned,

(h) identify monitoring and sampling points and indicate proposed arrangements for themonitoring of discharges and of the likely environmental consequences of any suchdischarges,

(i) in the case of an existing discharge, specify the sampling data pertaining to thedischarge based on the samples taken in the 12 months preceding the making of theapplication,

(j) describe the existing or proposed measures, including emergency procedures, toprevent unauthorised or unexpected waste water discharges and to minimise theimpact on the environment of any such discharges,

(k) give particulars of the location of the nearest downstream drinking water abstractionpoint or points to the discharge point or points associated with the waste water works,

(l) give details of any designation under any Council Directive or Regulations that applyin relation to the receiving waters,

(m) give details of compliance with any applicable monitoring requirements and treatmentstandards,

(n) give details of any work necessary to meet relevant effluent discharge standards anda timeframe and schedule for such work,

(o) give any other information as may be stipulated by the Agency, and

(p) be accompanied by such fee as is appropriate having regard to the provisions ofRegulations 38 and 39.


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Clare County Council Attachment 5 Appropriate Assessment D0324-01 Doonbeg

Doonbeg WWTP Effluent Monitoring 2010 - 2012 Date pH cBOD COD SS

2010 19/01/2010 7.48 12 31 12 24/02/2010 7.53 10 17 11 30/03/2010 7.44 8 19 7 15/04/2010 7.42 5 23 8 28/05/2010 7.5 6 19 7 01/06/2010 7.48 12 17 10 29/07/2010 7.52 20 91 19 03/08/2010 7.32 18 78 12 28/09/2010 7.26 4 24 4 12/10/2010 7.1 8 22 7 11/11/2010 12 31 18

2011 20/01/2011 7.5 9 28 7 10/02/2011 7.49 5 30 5 22/03/2011 --- 5 33 13 11/04/2011 --- 7 37 3 24/05/2011 7.02 28 30 < 2 21/06/2011 6.88 18 42 12 26/07/2011 7.14 35 141 18 27/09/2011 7.34 20 98 15 12/10/2011 7.88 45 141 9 29/11/2011 7.2 7 18 9 07/12/2011 7.2 2 28 7

2012 24/01/2012 7.2 2 28 7 03/02/2012 7.29 18 44 17 06/03/2012 7.33 20 51 19 24/04/2012 7.67 22 66 25 16/05/2012 7.42 20 103 2 19/06/2012 7.21 12 66 14

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EPA Export 29-11-2012:23:32:57

2 for doonbeg licence (d0324-01) - environmental protection ...or from the doonbeg golf club which...

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