alexandra basin redevelopment · 21. dr. simon berrow (expert witness for dublin port company on...
TRANSCRIPT
Alexandra Basin RedevelopmentForeshore Application
Oral Hearing - Relevant Information
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Dublin Port Company
Alexandra Basin West Redevelopment Project
Foreshore Application
Other Relevant Information relating to the Oral Hearing held by An Bord Pleanála from 8th to 17th October 2014
(venue of Oral Hearing – Best Western Academy Plaza, Dublin)
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The information presented in this document featured at the Oral Hearing for the ABR Project. The information is presented in the order as outlined below:
1. Presentation to An Bord Pleanála by Eamonn O’Reilly, CEO of Dublin Port Company
2. Clontarf Residents Association submission to oral hearing 3. National Roads Authority (NRA) submission to oral hearing 4. Dublin City Council submission to oral hearing 5. Irish Underwater Council submission to oral hearing 6. An Taisce submission to oral hearing 7. Dublin Bay Watch submission to oral hearing 8. Peadar Farrell submission to oral hearing 9. Presentation by Mr. Alexander Downes, Coastguard Cottages 10. Presentation by Dublin Graving Docks 11. Presentation by Roy Glenton (Aecom) for Dublin Graving Docks 12. Presentation by John Gannon (Tom Phillips & Associates) for Dublin
Graving Docks 13. Presentation by Mary Gallagher for Dublin Graving Docks 14. Submission by Paul O’Connell (Waterman Moylan Consulting
Engineers) for Dun Laoghaire Harbour Company 15. Submission by Dr. Diarmuid O Grada for Dun Laoghaire Harbour
Company 16. Submission by Stephen Reid for Irish Ferries and Stena Line 17. Photographs submitted by Sandymount and Merrion Residents
Association (SAMRA) 18. Response document by Dublin Port Company (expert witnesses) to
issues raised at oral hearing 19. Response by Chris Southgate (expert witness for Dublin Port Company
on conservation strategy) to Dublin Graving Docks submission 20. Submission by Terry Durney (expert witness for Dublin Port Company
on planning issues) on the conditions module 21. Dr. Simon Berrow (expert witness for Dublin Port Company on marine
mammals) – Proposed adjustments to Marine Mammals Mitigation Guidelines
22. Submission on behalf of Dublin Port Company by their Senior Counsel, Mr. Jarlath Fitzsimons
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1. Presentation to An Bord Pleanála by Eamonn O’Reilly, CEO of Dublin Port Company
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Redevelopment of Alexandra Basin and Berths 52 and 53
together with associated works in Dublin Port
PL29N.PA0034
Presentation to An Bord Pleanála
by
Eamonn O’Reilly, Chief Executive
Dublin Port Company
8th October 2014
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Contents
1. Qualifications and experience
2. Introduction to the project
3. Dublin Port, Dublin City and Dublin Bay
4. Overview of port operations
5. How the port developed in the past
6. Masterplan 2012 to 2040
7. ABR Project in the context of the Masterplan
8. Proposed development
9. Concluding remarks
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Qualifications and experience
• Chief Executive of Dublin Port Company (DPC) since August 2010
• Qualifications in engineering (BE from UCD) and business (MBA from TCD)
• Worked in the ports industry in a variety of roles since 1988. These roles included working as a consultant and as the chief executive of two cargo handling companies within Dublin Port:
• Marine Terminals Limited container terminal from 1992 to 1996
• Burke Shipping Group’s stevedoring operations from 2005 to 2010
• In my role as a consultant, I have carried out assignments in many Irish Ports including Dublin, Limerick Docks, Cork, Waterford, New Ross, Arklow, Wicklow, Drogheda, Dundalk and Greenore.
• Participated in a number of relevant reviews and policy initiatives in relation to ports including:
• McCarthy Review Group on State Assets
• Irish Competition Authority’s Review of the Irish Ports Sector
• EU Commission’s proposed Regulation on Port Services.
• Vice Chairman of the European Sea Ports Organisation
• Member of the General Stevedoring Council
• My port experience includes the planning, development and management of large container and other cargo handling facilities and the restructuring of dock labour.
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Introduction
• Alexandra Basin Redevelopment (ABR) Project is the first
major project from Masterplan 2012 to 2040
• About 1/3rd of the total development envisaged in the
Masterplan
• Needed to cater for foreseeable growth
• Dublin Port Company is an infrastructure provider –
shipping and cargo handling operations are carried out by
private sector companies operating in competitive
markets
• Project focuses on maximising the utilisation of the port’s
existing footprint
• This approach supports sustainable development of
nationally important port infrastructure
• National importance emphasised by DPC’s status as:
- One of the country’s three Tier 1 ports under
National Ports Policy
- One of the EU’s 83 core ports within the TEN-T
network
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The boundary of the ABR Project
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Dublin Port – 260 hectares of reclaimed land
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Need for the project
1. Anticipated growth
2. Dublin is the preferred location for the providers of
shipping services
3. Increases in ship sizes and the number of daily arrivals
4. Commitment to re-configure without additional infill
beyond the existing port boundaries
5. Existing infrastructure is approaching the end of its useful
life and needs to be renewed / replaced
6. Legacy contamination issue in Alexandra Basin West
0
50
100
150
200
250
300
350
400
Dublin Other east coast ports Remaining ports
-
50
100
150
200
250
300
350
400
450
19
90
19
91
19
92
19
93
19
94
19
95
19
96
19
97
19
98
19
99
20
00
20
01
20
02
20
03
20
04
20
05
20
06
20
07
20
08
20
09
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10
20
11
20
12
Tonnes GDP
Ore loading jetty legs in 2004 Repairs made in 2007 to extend the life of the jetty by 10 years
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Volumes will recover in 2014 (2014 based on figures to end-August)
100.0%
95.6%
85.7%
90.9% 90.8% 90.5%
93.2%
100.1%
75.0%
80.0%
85.0%
90.0%
95.0%
100.0%
105.0%
24.0m
25.0m
26.0m
27.0m
28.0m
29.0m
30.0m
31.0m
32.0m
2007 2008 2009 2010 2011 2012 2013 2014
Tonnes %
The Dublin Transport Initiative report of 1995 projected that Dublin Port’s volumes would reach 10.7m tonnes by 2011. However, by 2000, the volume through the port had already reached 21.0m gross tonnes
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Masterplan growth trends (five year rolling averages)
16.4m 57% 6.3m
22%
4.0m 14%
2.2m 7%
2010
Ro-Ro Lo-Lo Bulk Liquid Bulk Solid
41.9m 70%
10.5m 17%
4.0m 7%
3.6m 6%
2040
Ro-Ro Lo-Lo Bulk Liquid Bulk Solid
2010 '000 gross tonnes
2040 '000 gross tonnes
AAGR
Ro-Ro 16,403 41,920 3.2%
Lo-Lo 6,317 10,480 1.7%
Bulk Liquid 4,009 4,000 0.0%
Bulk Solid 2,054 3,500 1.8%
Break Bulk 96 100 0.1%
Total tonnes 28,879 60,000 2.5%
Ro-Ro (‘000 units) 701 1,791 3.2%
Lo-Lo (‘000 units) 377 625 1.7%
Totals 1,078 2,416 2.7%
Lo-Lo (‘000 TEU) 641 1,063 1.7%
Gross tonnes AAGR
1950 2.9m -
1980 7.3m 3.2%
2010 28.9m 4.7%
2040 60.0m 2.5%
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Dublin City and Dublin Port
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Dublin Port and Dublin City
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The entrance channel to Dublin Port
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Dublin Port and Dublin Bay
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Four Ro-Ro lines to GB
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Three Lo-Lo container terminals
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Bulk solid and containers on Ro-Ro
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Cruise ships
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Project cargos and trade vehicle imports
3rd October 2014 ARR DEP Totals
Ro-Ro 14 15 29
Lo-Lo 3 5 8
Bulk Liquid 2 2 4
Cruise 1 1 2
Bulk Solid 1 1
Totals 21 23 44
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Development by Harbour Works Orders, 1960 to 1980
Source: Managing Dublin Bay.
Edited by Mark Brunton, Frank J. Convery
and Anne Johnson 1987
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CLONTARF
RINGSEND
Grand Canal Dock Fairway
ESB
1 1
1. 1966 – Development of South Bank Quay SI 242/1966
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CLONTARF
RINGSEND
Grand Canal Dock Fairway
ESB
2
2
2
2
1 1
2. 1967 – Port expansion at East Point and Pigeon House Road – SI 203/1967
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CLONTARF
RINGSEND
Grand Canal Dock Fairway
ESB
2
2
2
2
1 1
3
3. 1969 – British Rail and B&I terminals (Ro-Ro and Lo-Lo) – SI 82 / 1969
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CLONTARF
RINGSEND
Grand Canal Dock Fairway
ESB
2
2
2
2
1 1
4 4
3
4. 1975 – Expansion of B&I terminals SI 31 / 1975
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CLONTARF
RINGSEND
Grand Canal Dock Fairway
ESB
2
2
2
2
1 1
5
5 4 4
3
5. 1977 – Expansion of British Rail container terminal SI 303 / 1977
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CLONTARF
RINGSEND
Grand Canal Dock Fairway
ESB
2
2
2
2
1 1
5
5 4 4
6
3
6. 1978 – Extension to South Bank Quay SI 245 / 1978
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CLONTARF
RINGSEND
Grand Canal Dock Fairway
ESB
2
2
2
2
1 1
5
5 4 4 7 6
3 7. 1980 – East Link Toll Bridge SI 251 / 1980
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CLONTARF
RINGSEND
Grand Canal Dock Fairway
ESB
2
2
2
2
1 1
5
5 4 4
8
7 6
3 8. 1982 – Infill in Alexandra Basin West SI 179 / 1982
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CLONTARF
RINGSEND
Grand Canal Dock Fairway
ESB
2
2
2
2
1 1
9
5
5 4 4
8
7 6
3
9. 1979 – HWO application for 38 hectare expansion Application withdrawn
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CLONTARF
RINGSEND
Grand Canal Dock Fairway
ESB
2
2
2
2
1 1
10
5
5 4 4
8
7 6
3
10. 1986 – HWO application for 21 hectare expansion (ultimately part of the Dublin Gateway) Consent refused
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Today’s port development challenges are not new
• John Purser Griffith, an engineer with Dublin Port & Docks Board from 1871 to 1913.
• Griffith worked alongside Bindon Blood Stoney for 27 years before replacing him as Chief Engineer in 1898. Joseph Mallagh came after Griffith.
• Presidential Address to the Institution of Civil Engineers in 1887:
My objective in dwelling so much upon the history of our profession has been to stimulate you to assist in making its future worthy of its past.
• Retired in 1913 in frustration at what he perceived as Dublin Port & Docks Board’s reluctance to continue with the development of deepwater berths in the Port
• We face the very same challenges today to develop deepwater berths and a deeper approach channel
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Progressive deepening of Dublin Port since 1818
0.0 m
1.0 m
2.0 m
3.0 m
4.0 m
5.0 m
6.0 m
7.0 m
8.0 m
9.0 m
1800 1819 1822 1828 1838 1856 1873 1939 1951 1976 2013
• Firstly by tidal scour and then by dredging
• 1818 to 1824 - North Bull Wall completed
• 1904 - Dublin Port & Docks Board acquired a suction dredger (the Sandpiper)
• 1909 – channel deepened to 6.0m
• 1970’s – today’s channel depth of 7.8m reached
Feet Metres
1819 6.5' 2.0 m
1822 8.5' 2.6 m
1828 9.5' 2.9 m
1838 10.5' 3.2 m
1856 13.0' 4.0 m
1873 16.0' 4.9 m
Source: River Bars; Notes on the causes of their formation and on their treatment by “induced tidal scour”, with a description of the successful reduction by this method of the bar at Dublin by I.J. Mann, 1881
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Source: Engineer’s Report by Joseph Mallagh in Dublin Port & Docks Board Annual Accounts 1922
Continual dredging since the foundation of the State
1922 783,545 tons
1923 870,125 tons
1924 1,357,175 tons
1925 1,277,130 tons
1926 728,755 tons
1927 1,338,715 tons
1928 811,125 tons
1929 975,030 tons
1930 1,330,250 tons
Total 9,471,850 tons
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Masterplan process
5th April 2011 28th July 2011 2nd November 2011 29th February 2012
• Pre consultation meetings – January 2011 • Soft Values seminar – 25th February • Masterplan Newsletter posted to 60,000 households • 500 posters and 25,000 flyers • Customer briefing session – 20th April • Local open days: East Wall - 26th April
Ringsend - 27th April Clontarf - 28th April • Conference - 11th May • Direct briefings with various groups • Public consultation ended 31st May • Draft Masterplan consultation period - 3rd November to 2nd December 2011 • Plan launched 29th February 2012
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Masterplan development alternatives
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Channel deepening was envisaged in the Masterplan
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ABR Project - the first major project of the Masterplan
ABR Project
ABR Project
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Evolution of the proposed development
• Complex process to prepare the project
proposal
• Masterplan gave strategic direction but did
not fill in all of the details (January 2011 to
February 2012)
• Cruise requirements analysis gave greater
understanding (2012)
• Franchise Review brought clarity on land
utilisation targets (2012 to 2014)
• Iterative and interactive process to reconcile
operational, engineering, heritage and
environmental constraints
• Resultant Environmental Impact Statement
and Natura Impact Statement are complex
and detailed, and address a wide range of
issues
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Rationalisation and development of port estate since 2012
Area #1: New trade car facility
Areas #3 and #9: Proposed amalgamation of two existing oil facilities into one new facility
New trade car facility opened 24th September 2014
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Franchise Policy - 41 hectares of lands for non-core uses
Between the lands being rationalised / redeveloped already and the lands used for non-core uses, there is a potential area of 56 hectares for cargo handling
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Proposed development - Navigation Channel
• Dredging of Liffey Channel to -10m CD, from East Link Bridge to Dublin Bay Buoy over a six year period
• Construction of surge protection / retaining wall at Poolbeg Marina
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Proposed development - Alexandra Basin West
• Dismantling of infrastructure and removal of infill
material
• Quay wall refurbishment/construction designed
to accommodate future dredging to a level of
-15.0m Chart Datum
• Installation of Ro-Ro ramps
• Ro-Ro jetty construction
• Dredging of basin and berths to -10.0m Chart
Datum
• Treatment of contaminated dredged material and
re-use as infill on site
• Excavation and restoration of Graving Dock No. 1
• Infilling of Graving Dock No. 2 with treated
dredged material
• Relocation of ore concentrates loading operations
to Alexandra Quay West Extension
• Development of cultural heritage interpretative
space
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• Dismantling and removal of existing
infrastructure
• Infilling of existing Berth 52 / 53 with treated
dredged material
• Raising of existing surface levels by approx. 1.4m
• Quay wall construction
• Mooring jetty construction
• Installation of Ro-Ro ramp
Proposed development - existing berths 52 / 53
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Concluding remarks
1. The ABR Project is the product of a fundamental change by DPC in our approach to providing necessary port capacity for future growth.
2. It is the product of a long term Masterplan which was produced with wide consultation with a range of stakeholders. This Masterplan was informed by a Strategic Environmental Assessment and by a Natura Impact Assessment.
3. The ABR Project is supplemented by a number of other Masterplan initiatives including, most recently, a Franchise Policy which identifies how DPC will increase the utilisation of the port’s existing lands.
4. The development works proposed in the project are integrally tied into the history and heritage of the port and are a continuum of progressive port development over two centuries.
5. The large scale and complex nature of the project so close to the city and to adjacent Natura sites gives rise to potential impacts. Our project application has, therefore, been supported by a detailed EIS and NIS which we hope will assist the Board in completing its assessments and in reaching its decision.
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2. Clontarf Residents Association submission to oral hearing
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R E S I D E N T S ' A S S O C I A T I O N
My name is Deirdre Tobin and I represent Clontarf Residents' Association
Our original submission is on file so I do not propose to refer to it other than to re-iterate that we welcome Dublin Port Company's decision to utilise their existing lands rather than seek to infill any more of Dublin Bay which is what we have been advocating for some 40 years.
We do however, have some concerns regarding the impact of the development on the nearby residents and in this we include our wildlife - in particular the seals.
Mammals: We have concerns regarding some of the responses by Dublin Port to the request for additional information by an Bord Pleanala. We are concerned about the possible impact on the mammals in the area. We believe that this important matter has not been dealt with in sufficient detail and the numbers of grey and harbour seals hauling out on Bull Island has been understated. Indeed in RFI Response 4 it states "The nearest well documented harbour seal haul out to the proposed works Is Lambay Island," This, we believe is incorrect -both harbour seals and grey seals are hauling out in numbers on the Bull Island and breeding there, as has been confirmed by Mr. Pat Corrigan, DCC Wildlife Ranger for Bull Island in yesterdays DCC submission. The grey seals are the world's first protected species and we believe that they need maximum consideration. Indeed with all the plans for cruise ships they should be considered an asset and a tourist attraction. Also, only last week a beached porpoise died on Bull Island.
Because of our concerns we recently contacted Mr. Brendan Price of the Irish Seal Sanctuary for advice on this issue and at this point lnspector, I would like to read into the record an email which we have received from him. Unfortunately, due to other commibnents, Mr. Price is not available to come along today or tomorrow but he could make himself available on Friday should you Inspector or anybody else wish to question him.
For Whom it Concerns,
I'd appreciate this ]>resentation, below being read into the record, by Clontarf Reside~its i\ssociation. I was sc~rprised at such late stage Lo be asked ibr. acivicc by stakef>olders in cur.l.elnt ABR, Bord Pleanala, Oral Heariilg and RFI and fi~rtlicr conccrnetl to be advised the Irish Scal Sanctuary (ISS) was cited as tltough giving credence to "non-facts" and impression that seals were a passing preseticc, liierely using the 13ay as haul-out and werc at no significant or actverse risk by ABIZ. Nothing coiild he flirther fro111 the "facts" and this is at variance wit11 the coiisultants and NPWS owrl iinnited firitlings on very lir~iitcd data a id ohservotion and wl~oiiy at variance with wl~at the ISS or. tilyself rcprescnting it, \voulcl contend. Indecci we'd heartily concur and even adcl to their monitoring recommendations on the iirrtller information wc are happy to provide. Indeed , were we contactcti, we would have beer> pleased to provide this earlier. identify and atidsess the tlata deiicits and ativise on mitigation ~neasures..... We still would! IIoivevei this lrearing is at s~rcli a c~ucial stage, anci with no clisrespect to thc compatiy aiitl it's consuliatlts, it is ~iiost important the ISS is not pcrceiveci to mislead or give firlsc comfort to any party and rnost especially Borcl Pleanala on the threatslimpacts for seals ancl tlie ecosysterll supporting their presence in the Ray. The ISS is gratef~il to tile Cloniai'f Reside~ifs Associntioi~ for their 121:I response lo correct n?isleiidingly iittribr~table trclvices, iinsnpportecl by ISS. h stimmary response Tor IZFI follows, I
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tilanit t i le ~ t i ~ k c l i o l d a s , wl lo ~espollt ietl anti t l i ist this of assistaiicc to al l
ABR anti RFI ..... 1)ubiin I'ost Development ... lmpact on seals and otiicr creatlwcs?'?? Data delicits???'??
The NIS, EIS, Avian Impact Assessment, Marine Mammal lmpact Assessment et a1 are extremely confined by their scoping (Dublin Port, Shipping Channel and Dredge Disposal Site), as though a line could be drawn around the development and beyond it unaffected by pliime, sediment transportation, silting, accretion, turbidity and iight dili~tion with knock on effects for re-colonisation, recovery of benthos, fish nurseries and up the ecosystem. The experts consulted as much as agree with this and point to the limited survey data and timeline throughout. For the marine mammals this is greatly understated. If a line indeed was to be drawn, i t should enconipass the UNESCO site, SPAS (Special Protected Areas) and proposed MPA (Marine Protected Area). Bord Pleanala (BP) are correct to seek further information and indeed the responses still fail to address data deficits. This development is not confined by the Liffey Walls and spoil site but at the heart of the 3 estauries and Bay, all of which will be affected by the outfall and limited mitigation measures.
As to the seals, the Irish Seal Sanctuary (ISS) though cited, was not invited by the developer to contribirte. Statements such as, "There are only a relatively small number of seals that regularly use Bull Islanu as a haul - out" and development "will have no long term, significant adverse effects" on seals et al. can not be cited as "fact" when in the 1st instance both species are observed all year round and with pups present and in the latter ongoing observations of disturbance demonstrate how flighty they can be. It would be highly significant, were they to disappear from the Bay or any part of it. As for so many species cited in the UN Giobal Biodiversity Outlook 4 they are holding to all remaining habitat and all remaining is important. City residents and visitors also hold these wild neighbours and hold them in great affection and esteem. Their ongoing presence, of inestimabie value in conservation terms, can only be a point of interest and engagement for cruise visitors entering the Bay and Port, The snap shot sightings and observations cited in the studies are no substitute for long sought, year round monitoring and at variance with the experience of year rotrnd observers. This is reflected in the consultant's recommendations for ongoing monitoring and a pre-works baseline needs be establislied in first instance.
The presence and activity of seals in the Bay is year round and they are a highiy significant, mixed colony, recorded from the time of the Rotschild reports a century ago. Dalkey Island holds the first recorded remains of Grey Seals (World's 1st Protected Species) for Ireland. The seals are a year round, long recorded presence .. . . feeding, breeding and liauling otit, very vulnerable to disturbance and furiher loss of habitat. They are higiily significant residents of UNESCO site, only one of it's kind within confines of capital city and linked to the greater Dublin Bay community. Any disturbance must be regarded with concern, closely monitored and subject to review and mitigation. It is significant the dredging schedule fails to note their October to March breeding season and presence of growing pitps, whose mortality is highest in this period. Sea going smolts are noted but not returning salmon or presence of lampreys. It is incorrect to dismiss the seals as a small, part time presence in the Bay arising from insufficient survey and monitoring ..... absence of evidence is not evidence of absence and you will find the experts and NPWS agree with me on data deficiency and I heartily concur with them on their recommendation for Marine Mammal Observers (MMOs) and would propose this be increased year round (not just during works but for recovery periods also) to extend to a full time ecologist for the lifetime of the project with additional conservation rangers in each L.A. area. Seai observations are better undertaken by human recording network tha~ i technology. In budgetary terms this is minusciile and is the least acceptable level of nionitoring and mitigation .... far preferable to "professionals differ, good projects (or seals etc.) die!"
I have addressed my observations largely at the seals, in some ways perceived as robust and resilient residents of the Bay, fragile in others . . . . and as indicator species of benthos, water quality, disturbance etc., they certainly merit closer consideration and monitoring. The risks they highlight and adequacy of mitigation measures to be tested, further iinderiine their importance.
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The EiS, NiS and associated wildlife "studies" are disjointed, stand alone, expert opinions ...... informed and valuable in their own right but the report fails to adopt an ecosystem approach to ABR or respond adequately to DP's RFI or mine. The Precautionary approach would indicate further information and better mitigation /contingency planning required. The consultants' reports reflect the scientific literature on the local seals and the paucity of information entered it. Indeed how were they to know of the wealth of itiformatior? with the Irish Seal Sanctuary, Dublin City Council, Srrtton Dinghy Club, Ciontarf and other residents. The iSS and Bull island manager have rescued orphaned and injured piips (mostly whitecoats or weaned greys) almost every other year for 30 years from the island, a succession of three hydroceplialous common seals, a common seal oniy last month etc. The island has been the venue for many seal releases over the years engaging and educating the public. The Port Company has assisted in rescues on the river and indeed mainly pups taking up temporary residence have been kept under surveillance and monitored for us by Garda cameras. There appears to have been a disconnect between the Company and other stakeholders, depriving the consultants of information and giving rise to An Bord Pleanala's RFI, which Ciontarf Residents Association have corrected to benefit of all and proposed development. It is most important adequate conditions attach ali developments potentially impacting the seals and other wildlife.
End of email
Piling and Dredging: We are worried about the large numbers of piles which it is proposed to drive over the course of the development and the effects of this noise on the adjoining communities and the wildlife. The dredging must disturb mammals, fish and birdlife however accustomed they may have become to the usual noises associated with the port activities. This includes possible disruption to the wildlife of the three river estuaries.
As we said in our original submission, should the Bord grant permission for this proposal, we would hope that it would condition that separate permissions would need to be sought for each subsequent dredging programme to ensure continuous monitoring of the dredging process.
In Conclusion: Is there the possibility of the additional scouring and depth of the dredging damaging the foundations o f the very old river walls? Finally we would ask the question do we really need Dublin Port to double its traffic. Surely, as we have argued with previous applications, the flow of imports and exports could be diversified and the traffic spread over other ports many of which are well equipped to handle it. It would also help with employment around our coast. So why does Dublin Port need to continue to grow and be the main port of the country? It and the other ports are all owned by the Government so what is the need for all this competition?
Thank you.
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