APPENDIX B.6(d2) Letter from Cork County Council in reference to EIS for previous planning permissions granted

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APPENDIX B.6(d2)

Letter from Cork County Council in reference to EIS for previous planning permissions granted

For inspection purposes only.

Consent of copyright owner required for any other use.

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APPENDIX B.6(f1)

Letter from Cork County Council

requesting an Appropriate Assessment be conducted

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APPENDIX B.6(f2)

Appropriate Assessment and Natura Impact Statement

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North Cork Co-operative Creameries Kanturk, Co. Cork

Proposed Milk Evaporator and Spray Drying Plant

Article 6 Appropriate Assessment:

Natura Impact Statement

Version: 2.1 (Final) 15

^th

August 2011

Tait Business Centre, Dominic Street, Limerick City, Ireland.

t. +353 61 313519, f. +353 61 414315 e. [email protected]

w. www.ecofact.ie For inspection purposes only.

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1. INTRODUCTION

This report provides an assessment of the likely significant effects on the Natura 2000 network arising from the proposed development of a milk evaporator and spray drying plant within the existing creamery facility located at North Cork Co-operative Creameries Ltd., Kanturk, Co. Cork. The proposed evaporation plant will be installed on the banks of the River Allow, within the existing Co-op site. The plant will process approximately 15,000 L hour^-1 of whole milk. Effluent arising from the proposed evaporation process will be passed to the existing wastewater treatment plant, which discharges into the River Allow downstream of Kanuturk. Liquid effluent will be processed at approximately 5,000 L day^-1. Additional discharges arising from the proposed process include wash-out of wastewater from the plant (2,500 L day^-1) and treatment of caustic soda and Nitric acid and floor washings which will all be diverted to the existing wastewater treatment plant. All rainwater and surface water will be discharged to the River Allow.

An Article 6 Appropriate Assessment or Natura Impact Statement is required under the Habitats Directive (92/43/EEC), in instances where a plan or project may give rise to significant effects upon a Natura 2000 site. Natura 2000 sites are those identified as sites of European Community importance designated under the Habitats Directive as Special Areas of Conservation (hereafter referred to as SACs) or under the Birds Directive (2009) as Special Protection Areas (hereafter referred to as SPAs). This Appropriate Assessment therefore considers the potential impacts of the proposed development at the North Cork Co-op Creamery at Kanturk and the effects upon the conservation objectives and qualifying interests (including habitats and species) within the affected designated area identified adjacent to the site. The preparation of this Natura Impact Statement follows the guidance published by the National Parks and Wildlife Service (NPWS, 2009) ‘Appropriate Assessment of Plans and Projects in Ireland. Guidance for Planning Authorities’. The current assessment identifies designated sites within 15km of the proposed scheme. The proposed facility is located directly adjacent to the Blackwater River (Cork/Waterford) cSAC (site code 002170). The NPWS site synopsis for this site is provided in Appendix 1.

The current document meets the requirements of an Article 6 Assessment by providing a Screening Assessment (Stage 1) and a further Stage 2 Natura Impact Statement of the proposed development and follows the guidance published by the National Parks and Wildlife Service (NPWS 2009) ‘Appropriate Assessment of Plans and Projects in Ireland. Guidance for Planning Authorities’. According to NPWS (2009), screening is the process that addresses and records the reasoning and conclusions in relation to the first two tests of Article 6(3) of the EU Habitats Directive: i.e. whether a plan or project is directly connected to or necessary for the management of the site; and whether a plan or project, alone or in combination with other plans and projects, is likely to have significant effects on a Natura 2000 site in view of its conservation objectives.

When assessing the significance of potential effects, NPWS (2009) recommends that “a precautionary approach is fundamental and, in cases of uncertainty, it should be assumed the effects could be significant”. Consequently due to the intrusive nature of the works proposed, the Article 6 Appropriate Assessment process proceeds to Stage 2 Appropriate Assessment:

Natura Impact Statement (NIS). Both the Screening Report and NIS are detailed below. The current report was prepared by ECOFACT Environmental Consultants Ltd. on behalf of North Cork Co-operative Creameries Ltd.

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1.1 Consultation

Consultation, including the review of publically available material, has been undertaken with the following:

 National Parks and Wildlife Service (NPWS);

 Inland Fisheries Ireland (IFI);

 Environmental Protection Agency (EPA);

 Cork County Council;

 South Western River Basin District (SWRBD).

1.2 Legislative context

Council Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora - ‘The Habitats Directive’, has been transposed into Irish law by The European Community (Natural Habitats) Regulations 1997 (S.I. No. 94/1997). The 1997 Regulations were updated in 1998 by The European Communities (Natural Habitats) (Amendment) Regulations 1998 (S.I. No. 233/1998) to include Council Directive 97/62/EC which served to update Council Directive 92/43/EEC, adapting it to technical and scientific progress made in the intervening years. The 1997 Regulations were again updated in 2005, by The European Communities (Natural Habitats) (Amendment) Regulations 2005 (S.I. No. 378/2005). This amendment served to consolidate the main nature conservation legislation enacted in Ireland, meaning The Wildlife Act 1976, The Wildlife (Amendment) Act 2000, The European Communities (Natural Habitats) Regulations 1997, The European Communities (Natural Habitats) (Amendment) Regulations 1998, and to draw direct reference upon Council Directive (2009/147/EC) on the conservation of wild birds – ‘The Birds Directive’.

The Birds Directive (2009/147/EC) seeks to protect birds of special importance by the designation of Special Protection Areas (SPAs) whereas the Habitats Directive does the same for habitats and other species groups within Special Areas of Conservation (SACs). It lists certain rare habitats (Annex I) and species (Annex II) whose conservation is of community interest. It is the responsibility of each member state to designate SPAs and SACs, both of which will form part of Natura 2000, a network of protected areas throughout the European Community.

Article 6, paragraphs 3 and 4 of the Habitats Directive state that:

6(3) Any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subject to appropriate assessment of its implications for the site in view of the site's conservation objectives. In the light of the conclusions of the assessment of the implications for the site and subject to the provisions of paragraph 4, the competent national authorities shall agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the site concerned and, if appropriate, after having obtained the opinion of the general public.

6(4) If, in spite of a negative assessment of the implications for the site and in the absence of alternative solutions, a plan or project must nevertheless be carried out for imperative reasons of overriding public interest, including those of a social or economic nature, the Member State shall take all compensatory measures necessary to ensure that the overall

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2. METHODOLOGY 2.1 Desk study

A desktop study was undertaken to identify the location and conservation interests of designated Natura 2000 sites which may potentially be affected by the proposed milk evaporator plant and associated processes / discharges. The desktop study identified the conservation interests of the designated sites with respect to the qualifying interests (species and habitats) relevant to the designated sites within the study area. The site synopsis for designated Natura 2000 sites is presented in Appendix 1. Further desk study research included publically available information from statutory bodies such as the National Parks and Wildlife Service, the Environmental Protection Agency and Water Framework Directive (WFD) Ireland. The desk study included data gathering with regard to ecological interests; current and historical water quality; and hydrological data within the study area.

North Cork Co-op treatment plant effluent volume and quality data for May and June 2011 supplied by the Co-op was reviewed. Water quality data for the Allow River supplied by Cork County Council upstream and of the Co-op treatment plant discharge point was examined and used in combination by river flow data (source: EPA Hydrometric Data System) to calculate the assimilation capacity of the receiving water, with reference to the European Communities Environmental Objectives (Surface Waters) Regulations 2009 (S.I. 272 of 2009). The Waste Assimilation Capacity (WAC) of the Allow River upstream of the Co-op discharge point was calculated for the parameters used to assign water quality status in the above regulations. The WAC assessment was used to evaluate the impact of the proposal on water quality. It is noted that very limited water quality monitoring data was available, with data available for only one sampling date for the River Allow upstream of the plant.

2.2 Field survey

The preparation of this Appropriate Assessment included field survey work to characterise the habitats and ecological features within the River Allow riparian corridor and the aquatic ecological interests of this watercourse, designated within the Blackwater River cSAC adjacent to the Kanturk Creamery. Site surveys were undertaken with regard to the key qualifying interests of the site. Annex I habitats for which the cSAC is designated were recorded within the study area, as was any evidence of Annex II species or suitable habitats supporting these species within the cSAC. The River Allow corridor both upstream and downstream of the Kanturk creamery was surveyed to approximately 1 kilometre along the river bank. Macroinvertebrate sampling was undertaken at three locations on the River Allow adjacent to the bank; upstream of the creamery at Kanturk; adjacent to the creamery; and downstream of the creamery. Macroinvertebrate sampling was carried out using a kick- sampling net following standard EPA kick-sampling methodology (Toner et al., 2005).

2.3 Appropriate Assessment Methodology

This Natura Impact Statement follows the guidance published by the National Parks and Wildlife Service (NPWS 2009) ‘Appropriate Assessment of Plans and Projects in Ireland:

Guidance for Planning Authorities’. Based on these guidelines, the Appropriate Assessment process is a four-staged approach described below:

 Stage One: Screening / Test of Significance - the process which identifies the likely impacts upon a Natura 2000 site of a project or plan, either alone or in combination with other projects or plans, and considers whether these impacts are likely to be significant;

 Stage Two: Appropriate Assessment - the consideration of the impact of the project or plan on the integrity of the Natura 2000 site, either alone or in combination with other projects or plans, with respect to the site’s structure and function and its conservation objectives. Additionally, where there are adverse impacts, an assessment of the potential mitigation of those impacts;

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 Stage Three: Assessment of Alternative Solutions - the process which examines alternative ways of achieving the objectives of the project or plan that avoid adverse impacts on the integrity of the Natura 2000 site; and

 Stage Four: Assessment Where Adverse Impacts Remain - an assessment of compensatory measures where, in the light of an assessment of Imperative Reasons of Overriding Public Interest (IROPI), it is deemed that the project or plan should proceed.

The safeguards set out in Article 6(3) and (4) of the Habitats Directive are triggered not by certainty, but by the possibility of significant effects. Thus, in line with the precautionary principle, it is necessary to undertake an appropriate assessment to ascertain the potential for significant effects.

2.3.1 Stage 1: Screening

Following the guidelines set out by DoEHLG (2009) Appropriate Assessment Stage 1:

Screening is the process that addresses and records the reasoning and conclusions in relation to the first two tests of Article 6(3); i.e. whether a plan or project can be excluded from Appropriate Assessment requirements because it is directly connected with or necessary to the management of the site; and the potential effects of a project or plan, either alone or in combination with other projects or plans, on a Natura 2000 site in view of its conservation objectives, and considering whether these effects will be significant. According to DoEHLG (2009), screening is the process that addresses and records the reasoning and conclusions in relation to the first two tests of Article 6(3) of the EU Habitats Directive:

1) Whether a plan or project is directly connected to or necessary for the management of the site and

2) Whether a plan or project, alone or in combination with other plans and projects, is likely to have significant effects on a Natura 2000 site or sites in view of its conservation objectives.

The proposed development within the Kanturk Creamery site does not comply with the first screening test (i.e. the proposed works are not directly connected to or necessary for the management of any Natura 2000 site). The current Screening Assessment therefore sets out to determine whether the proposed project, alone or in combination with other plans and projects, is likely to have significant effects on the Natura 2000 sites within the study area. If the effects are deemed to be significant, potentially significant, or uncertain, or it the screening process becomes overly complicated, then the process must proceed to Stage 2 Appropriate Assessment i.e. a Natura Impact Statement. When assessing the significance of potential effects, the NPWS Guidelines (2009) recommend that “a precautionary approach is fundamental and, in cases of uncertainty, it should be assumed the effects could be significant”.

2.3.2 Stage 2: Appropriate Assessment

This stage considers whether the plan or project, alone or in combination with other projects or plans, will have adverse effects on the integrity of a Natura 2000 site, and includes any mitigation measures necessary to avoid, reduce or offset negative effects. The Stage 2 Appropriate Assessment will comprise a scientific examination of the plan / project and the relevant Natura 2000 sites; to identify and characterise any possible implications for the site

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SPAs) are determined under Article 4 of the Habitats Directive and are intended to ensure that the relevant qualifying interests i.e. Annex I habitats and Annex II species present on a site are maintained in a favourable condition.

The current report includes a Stage 2 Appropriate Assessment. This provides a description of the project and the receiving environment. The conservation objectives of Natura 2000 sites potentially affected by the proposed development are listed and potential impacts outlined with respect to the integrity of the Natura 2000 site. Mitigation measures have been proposed for the protection of the conservation interests and the avoidance of impacts to the cSAC located in close proximity to the proposed development.

3. STAGE 1: SCREENING / TEST OF SIGNIFICANCE 3.1 Description of the project

The proposed development will be located within the existing North Cork Co-operative Creameries Ltd. site at Kanturk, Co. Cork. This site is located on the west bank of the River Allow. The River Allow is designated within the River Blackwater (Cork/Waterford cSAC) as it supports populations of Annex II freshwater pearl mussels, Atlantic salmon and lamprey species, as well as the Annex I habitat ‘floating river vegetation’, listed on the EU Habitats Directive (1992). The Kanturk creamery site is located on the bank of the River Allow and a portion of the site along the riparian corridor lies within the designated cSAC boundary. It is considered that the Natura 2000 site boundary follows the historical 6 inch mapping field boundaries along the river corridor and therefore has not taken account of the presence of the creamery facility at this location. It is not expected that the creamery yard and portions of the processing plant would be included for designation within this cSAC.

The proposed evaporation plant and spray drying plant will process approximately 15,000 L/hour of whole milk. Effluent arising from the proposed evaporation process will be passed to the existing wastewater treatment plant within the site. Liquid effluent will be processed at approximately 500 L/hour. Additional discharges arising from the proposed process include wash-out of wastewater from the plant, treatment of caustic soda and Nitric acid and floor washings which will all be diverted to the existing wastewater treatment plant. All rainwater and surface water will be discharged to the River Allow.

3.2 Identification of relevant Natura 2000 Sites

3.2.1 Screening of Natura 2000 Sites within 15km of the study area

The current Screening Assessment has identified the designated Natura 2000 sites within a 15km radius of the proposed development within the Kanturk Creamery site. Only two sites were identified, the River Blackwater cSAC (site code 02170) and the Stacks to Mullaghareirks, West Limerick Hills and Mount Eagle SPA (site code 04161).

The Blackwater River cSAC designation includes the aquatic habitats and riparian corridor of the River Blackwater (Cork/Waterford) and its major tributaries including the River Allow which flows directly adjacent to the Kanturk creamery. The designation boundary on the River Allow includes the aquatic habitats and the riparian corridor within the study area, where elements of the existing Kanturk creamery site are located within the site designation.

The Stacks to Mullaghareirks, West Limerick Hills and Mount Eagle SPA is located approximately 15 kilometres north west of the proposed development site at Kanturk. The SPA extends across the county borders of south Limerick, north east Kerry and northwest Cork. This designation is principally for the conservation of the Annex I listed Hen Harrier.

There are no pathways, either geographical or hydrological by which the proposed development may adversely affect this designated Natura 2000 site; it is therefore not considered further in the current assessment.

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3.2.2 Description of Natura 2000 site likely to be affected by the proposed project

The Blackwater rises in boggy land of east Kerry, where Namurian grits and shales build the low heather-covered plateaux. The site consists of the freshwater stretches of the River Blackwater as far upstream as Ballydesmond, the tidal stretches as far as Youghal Harbour and many tributaries, the larger of which includes the Licky, Bride, Flesk, Chimneyfield, Finisk, Araglin, Awbeg (Buttevant), Clyda, Glen, Allow, Dalua, Brogeen, Rathcool, Finnow, Owentaraglin and Awnaskirtaun. The extent of the Blackwater and its tributaries in this site, flows through the counties of Kerry, Cork, Limerick, Tipperary and Waterford. The site is selected for alluvial wet woodlands and Yew wood, both priority habitats listed on Annex I of the E.U. Habitats Directive. The site is also selected for floating river vegetation, estuaries, tidal mudflats, Salicornia mudflats, Atlantic salt meadows, Mediterranean salt meadows, perennial vegetation of stony banks and old Oak woodlands, all habitats listed on Annex I of the E.U. Habitats Directive. The site is also selected for the following species listed on Annex II of the same directive - Sea Lamprey, River Lamprey, Brook Lamprey, Freshwater Pearl Mussel, Crayfish, Twaite Shad, Atlantic Salmon, Otter and the Killarney Fern.

The River Allow, including the riparian corridor, directly adjacent to the Kanturk creamery is designated within the River Blackwater cSAC. The River Allow is included in this designation due to the importance of this watercourse for the Annex I listed habitat ‘Floating river vegetation’ and the Annex II listed Freshwater pearl mussel (Margaritifera margaritifera), Atlantic salmon (Salmo salar), otter (Lutra lutra) and lamprey species (sea, river and brook according to King & Linnane, 2004). The site synopsis for the River Blackwater cSAC is presented in Appendix 1.

3.3 Screening Assessment of Likely Effects

3.3.1 Assessment of likely direct impacts affecting the Natura 2000 sites The proposed milk evaporator plant and spray drying plant would be constructed within the existing Kanturk creamery site which is located directly adjacent to and partially within the cSAC site boundary. The existing discharge pipelines associated with the wastewater treatment plant with the creamery site which will receive effluent from the proposed development lie within the designated site boundary and discharge into the aquatic environment of the cSAC.

Direct habitat loss affecting the Annex I conservation interests of the cSAC is considered unlikely. However there is the potential for direct impacts arising from development works with regard to increased traffic / construction disturbance; spread of invasive non-native species;

and discharges from the WwTP and surface water run-off occurring directly adjacent to and within the boundary of the designated site affecting water quality which is a key indicator of conservation value for this cSAC.

3.3.2 Assessment of likely indirect impacts affecting the Natura 2000 site Conservation interests of the River Blackwater cSAC may potentially be affected by indirect water quality impacts, in relation suspended solids impacts and also the release of pollutants during the construction and operational phases of the proposed development. This would have the potential to affect both the Annex II species and their invertebrate food sources

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Further indirect impacts may potentially arise via the further spread of invasive, non-native species which occur within and adjacent to the Kanturk creamery site (namely Japanese knotweed and Himalayan balsam). These species already occur within the river corridor adjacent to the development site; however, further spread or introduction to uncontaminated areas along the Allow corridor is possible. Any construction phase impacts arising may potentially be significant, particularly in relation to water quality impacts affecting the cSAC.

3.3.3 Assessment of likely cumulative impacts affecting the Natura 2000 Network

Cumulative impacts or effects are changes in the environment that result from numerous human-induced, small-scale alterations. Cumulative impacts can be thought of as occurring through two main pathways: first, through persistent additions or losses of the same materials or resource, and second, through the compounding effects as a result of the coming together of two or more effects (Bowers-Marriott, 1997).

The River Allow is evaluated as being of moderate status i.e. unsatisfactory due to the unsatisfactory conservation status of the Freshwater pearl mussel populations in this river upstream of Kanturk. Overall, biological water quality in this watercourse is rated as Q4-5 i.e.

‘high status’ upstream of Kanturk with a slight decrease to Q4 ‘good status’ downstream of Kanturk, upstream of the River Blackwater confluence. Therefore cumulative impacts in this sub-catchment, including the existing effluent discharge from the Kanturk Creamery and the Kanturk municipal WwTP are identified as having an operational impact on the ecological status of this watercourse. The sensitive freshwater pearl mussel which occurs in the River Blackwater main channel downstream of the River Allow confluence requires ‘high status’

water quality and therefore cumulative impacts affecting water quality in the Allow and Blackwater catchments would have the potential to adversely affect this species.

Ongoing polluting discharges to the River Allow upstream of the development would comprise a cumulative pressure on the conservation interests of the SAC; where Annex II aquatic species are considered to be under stress due to background water quality, irrespective of the current proposal. Other pressures on the catchment include erosion, diffuse nutrient enrichment, drainage and riparian damage along with abstractions and discharges.

Discharges to the River Allow affecting water quality are highlighted in annual EPA water quality monitoring reports, as well as in the River Allow Sub-basin Management Plan (DoEHLG, 2010). Other projects/ developments that exist or are currently proposed near / within the River Blackwater cSAC and the designated portion of the River Allow include a concrete products plant south of Kanturk, and the Kanturk WwTP which is operated by Cork County Council. This WwTP plant is identified as a point pressure on water quality within the Allow catchment (DoEHLG, 2010).

In combination with these activities, the proposed development gives rise to the potential for cumulative impacts affecting the conservation interests of the SAC; with particular reference to water-dependant Annex I habitats and Annex II species occurring within the River Allow and the River Blackwater downstream.

3.4 Screening statement with conclusions

According to NPWS (2009), the Appropriate Assessment Screening exercise can either identify that an Appropriate Assessment is not required; or that there is no potential for significant effects (i.e. Appropriate Assessment is not required); or that significant effects are certain, likely or uncertain (i.e. the project must either proceed to Stage 2 (AA) or be rejected).

From the examination of the information available it is considered that construction and operation of the proposed Milk Evaporator Plant and Spray Drying Plant at the Kanturk Creamery site has the potential to result in impacts to the Natura 2000 site network, specifically in relation to direct, indirect and cumulative impacts affecting the water-dependant qualifying interests of the River Blackwater cSAC occurring within the River Allow directly adjacent to, and downstream of, the proposed development site. Impacts on the key

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conservation interests of this Natura site i.e. water quality and protected Annex II species are uncertain following the Precautionary Principle and may be significant.

The current Screening Assessment has determined that the proposal must progress to Stage 2 with regard to the potential for impacts affecting the River Allow within the River Blackwater cSAC; i.e. a Stage 2 Appropriate Assessment for the proposed Milk Evaporator Plant and Spray Drying Plant at the Kanturk Creamery site is required.

4. STAGE 2: APPROPRIATE ASSESSMENT

This stage considers whether the plan or project, alone or in combination with other projects or plans, will have adverse effects on the integrity of a Natura 2000 site, and includes any mitigation measures necessary to avoid, reduce or offset negative effects. The Stage 2 Appropriate Assessment comprises a scientific examination of the plan / project and the relevant Natura 2000 sites; to identify and characterise any possible implications for the site in view of the site’s conservation objectives, structure and function; taking account of in combination effects.

During the Stage 2 assessment additional data and information on the existing effluent treatment plant, the proposed process, and other ongoing improvements in the plant, was provided for use in the assessment by North Cork Co-op. This information is presented in Appendix 4.

According to North Cork Co-op, the design loading for the existing effluent treatment plant is 2278 kg BOD/day and 677 kg SS/day. The average existing BOD loading into the effluent plant at peak production is 1820 kg BOD/day. According to North Cork Co-op, the evaporator/dryer process will contribute 5000 L of wastewater at 50 Kg BOD/day which will arise from the daily flushing of the evaporator as part of the washing cycle. With regard to future loading arising from this project, there will be however a net overall reduction to the effluent plant according to North Cork Co-op arising from the following:

 Automation of the milk handling process which will incorporate a product recovery step resulting in a daily reduction at peak to effluent of 100kgs BOD;

 Automation of cream handling with product recovery will result in a reduction of 44kg BOD and

 Lactose recovery in casein process will result in a reduction of load to effluent of 112kg BOD.

According to North Cork Co-op, the improved operation proposed evaporator processing will result in an increased effluent (comprising dilute milk solids containing fat, protein and lactose) of 50kg BOD/day (a 2.7% increase). This increase would be within the licensed capacity for the design loading of the existing plant at 2278kgs BOD/day. Overall however North Cork Co-op says that this will result in an 11% reduction of loading to the effluent plant which applies to BOD, SS, Nitrate, Ammonia and Orthophosphate. The information supporting this is presented in Appendix 4.

The mean concentration of Suspended Solids in the effluent from the Co-op treatment plant between May and June 2011 was 28.75mg/l (N=8). In the same time period and at the same frequency of sampling, the mean concentration of BOD was 10.2mg/l, while the mean concentration of Orthophosphate and Ammonia was 1.542mg/l and 0.53mg/l respectively. It is

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4.1 Description of the Receiving Environment

4.1.1 Overview of the River Allow within the study area

The River Allow (EPA code 18A02), rises on the eastern flanks of the Mullaghareirk Mountains, flowing in an easterly direction for twelve kilometres before turning south at Freemount, and continuing for a further 12 kilometres to Kanturk town, the main centre of population in the Allow River catchment. The Allow catchment area is 323.46km² and is located in the South Western IRBD. Five kilometres downstream of Kanturk the Allow flows into the Blackwater River (EPA code 18B02).

The River Allow is included in the Blackwater River cSAC, and has been designated partly on the basis of the presence of freshwater pearl mussel populations within this watercourse and also within the River Blackwater main channel, occurring directly downstream of the Allow confluence. The Annex I habitat ‘floating river vegetation’ and Annex II listed Atlantic salmon, otter and lamprey species also occur within the River Allow catchment adding to its conservation importance.

4.1.1.1 Water quality in the River Allow

From the River Blackwater (Munster) Water Management Unit (WMU) Action Plan (SWRBD, 2010) the River Allow is identified as being of ‘moderate status’, i.e. unsatisfactory. This is dictated by the ecological status of the river, driven by the unsatisfactory status of the Annex II listed Freshwater pearl mussel in the catchment, above Kanturk. The Kanturk Wastewater Treatment Plant operated by Cork County Council is identified as a point pressure in the Blackwater WMU (SWRBD, 2010), affecting both the River Allow and River Blackwater. This is based on visual impacts within the designated Natura 2000 site (SWRBD, 2010).

According to the EPA water quality monitoring for 2009 the River Allow achieved a biological water quality rating of Q4 at the monitoring station (EPA station 0490) approximately 1.3km downstream of Kanturk, which also lies downstream of the existing Kanturk Creamery and Kanturk WwTP discharges. The Allow was also rated as Q4 directly upstream of its confluence with the River Blackwater at Leader Bridge (EPA station 0600). Above Kanturk the River Allow is rated as Q4-5 within the freshwater pearl mussel reaches of the river at John’s Bridge (EPA station 0300).

Cork County Council undertakes chemical water quality at monitoring stations on the River Allow upstream and downstream of Kanturk town as part of the EC Water Framework Directive (WFD) monitoring programme. The downstream station is located downstream of both the Kanturk WwTP discharge and the North Cork Co-op discharge to the River Allow.

The upstream monitoring station results for 2010 and 2011 are presented in Table 1, with the downstream monitoring results for 2010 and 2011 presented in Table 2. WFD Good status and High status limits from the Surface Water Regulations (2009) are shown. From this data it can be seen that the chemical water quality in the River Allow is adversely affected downstream of Kanturk on one occasion only, on the 26^th of August, likely during low flow conditions. The increased dilution available downstream of the Dalua River confluence below Kanturk Bridge accounts for the reduction in Orthophosphate and Ammonium downstream during March 2010. Elevated Orthophosphate and BOD at the downstream station during 2010 indicate water quality problems in the River Allow downstream of the Kanturk WwTP discharge and cannot be directly associated with the North Cork Creamery Co-op.

North Cork Co-op undertook water sampling upstream and downstream of the effluent plant discharge on 28^th July 2011. Upstream and downstream of the discharge the respective BOD was <2mg/l and <2mg/l, Ammonia was 0.12mg/l and 0.14mg/l, Nitrate was 1.5mg/l and 1.6mg/l while Orthophosphate was 0.04mg/l and 0.08mg/l. These results indicate that the existing discharge is adversely affecting chemical water quality with the nutrient Orthophosphate doubling in concentration downstream of the discharge (See Appendix 4 for results).

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Table 1 River Allow chemical water quality upstream of Kanturk, from Cork Co. Co. data (2010-2011).

Parameter Orthophosphate mg/l

Ammonium NH4 mg/l

Cond.

µS/cm DO

% DO mg/l

Nitrate mg/l

Nitrite mg/l

pH BOD mg/l Statutory

limit (mean) from SWR, 2009

0.035 (G.S.) 0.025 (H.S.)

0.04 (H.S.) 0.065 (G.S.)

120 ≤1.3

(H.S.)

≤1.5 (G.S.)

24-Mar-10 0.079 0.617 137 98 10.8 4.5 0.045 7.6 4.5

26-Aug-10 0.021 0.056 194 115 11.6 4.7 0.062 7.9 2.8

30-Sep-10 0.016 0.018 150 100 10.9 3.47 < 0.013 7.5 1.6 (within 95%ile limit)

09-Mar-11 0.011 0.238 162 109 12.5 0.023 7.9

19-Apr-11 < 0.006 0.017 174 128 13.5 0.024 8.1 < 1 Table 2 River Allow chemical water quality downstream of Kanturk, from Cork Co. Co. data (2010-2011).

Parameter Orthophosphate mg/l

Ammonium NH4 mg/l

Cond.

µS/cm DO

% DO mg/l

Nitrate mg/l

Nitrite mg/l

pH BOD mg/l Statutory

limit (mean) from SWR, 2009

0.035 (G.S.) 0.025 (H.S.)

0.04 (H.S.) 0.065 (G.S.)

120 ≤1.3

(H.S.)

≤1.5 (G.S.) 24-Mar-10

0.03 0.18 108 98 11 3.7 0.039 7.5

2.2 (high status 95%ile limit) 26-Aug-10

0.052 0.694 212 109 11 4.5 0.076 7.9

2.6 (good status 95%ile limit)

30-Sep-10 0.016 0.072 166 97 10.6 6.5 0.055 7.5 1

09-Mar-11 0.012 0.029 154 109 12.4 7.5 0.027 7.6 < 1 19-Apr-11 0.01 0.007 166 139 13.9 4.3 0.028 8.2 < 1 4.1.1.2 Waste Assimilation Capacity in the River Allow

From the flow duration curve returned by the EPA Hydrotool, the 95%ile flow of the Allow River (river segment code 18_54) is 0.771m³/s while the mean flow is 8.203m³/s (mean flow taken as the 30%ile flow as in MacCarthaigh (1997)). In the Allow River upstream of the effluent discharge, the background concentration for BOD (<2mg/l), Ammonia (0.12mg/l) and Orthophosphate (0.04mg/l) means there is limited or no Waste Assimilation Capacity (WAC).

These values are the results from a single sample and have been provided by North Cork Co- op. It is also noted that the Level of Detection (L.O.D) used in relation to BOD was not adequate for assessments following the Surface Water Quality Objective Regulations (2009).

Cork County Council results were not used as they are for the Allow River – the discharge is to the Allow River downstream of its confluence with the Dalua River. The WAC assessment is provided in Appendix 2.

There is no WAC for BOD at mean flow as the background value (taken as 2mg/l) is greater than the SWR (2009) for both good and high status. It is noted that the background BOD may be significantly less due to the lack of sampling data and inadequate LOD used, and that

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4.1.2 Ecological survey of the study area

The proposed milk evaporator and spray drying plant will be constructed within the existing Kanturk Creamery site, which comprises buildings and artificial surfaces (BL3). The River Allow adjacent to the existing creamery and proposed development site is an eroding watercourse (FW1), the riparian corridor is dominated by the non-native Himalayan balsam (Impatiens glandulifera) with an established stand of Japanese knotweed (Fallopia japonica) recorded on the bank at the site boundary. A treeline of ash (Fraxinus excelsior) and alder (Alnus glutinosa) was recorded on the river bank adjacent to the proposed development site, outside of the site boundary. The riparian treeline was found to be more intact further downstream, below the site. The opposite bank was dominated by reed canary grass (Phalaris arundinacea).

Macroinvertebrate kick-sampling was undertaken at three stations on the River Allow by ECOFACT aquatic ecologists during the preparation of the current assessment. These sites were located downstream of the existing discharge from the Kanturk Creamery site, adjacent to the existing site and upstream of the Kanturk Creamery site, directly downstream of the confluence of the Allow and Dalua Rivers as shown in Table 3. Table 4 presents the physical character of the aquatic habitat recorded at each site and Table 5 presents the chemical water quality results recorded from each site on the day of the survey. A detailed species list of the macroinvertebrates recorded from the three sites is included in Appendix 3.

Table 3 Locations of the biological sampling sites examined on the River Allow at Kanturk in June 2011.

Site 1 Site 2 Site 3

Location Approx. 50m downstream of the discharge from the Co-op effluent treatment plant discharge (approx.

750m downstream of confluence of the Allow and Dalua Rivers)

Adjacent to Co-op (Approx. 150m downstream of confluence of the Allow and Dalua Rivers

Upstream of Co-op (just downstream of the confluence of the Allow and Dalua Rivers NOS Grid

Reference

R38514 02289 R38297 02679 R38290 03021

Table 4 Physical characteristics of the biological sampling sites on the River Allow at Kanturk in June 2011.

Site 1 Site 2 Site 3

Wetted width (cm) 22 19 29

Mean depth (cm) 40 35 30

Maximum depth (cm) 110 100 70

Riffle (%) 25 20 30

Glide (%) 50 60 55

Pool (%) 25 20 15

Rock (%) 15 65 10

Cobble (%) 50 25 55

Gravel (%) 30 10 30

Fine (%) 5 0 5

Shade (%) 10 10 0

In-stream vegetation (%) 10 0 10

Bank height (m) 50 40 40

Bank slope (º) 90 85 85

Bank cover (%) 100 90 95

Table 5 Selected chemical water quality results of the sites examined on the River Allow at Kanturk in June 2011.

Site 1 Site 2 Site 3

Conductivity (µS cm^-1) 182.8 143.8 145.3

Temperature (°C) 13.5 14.3 14

Dissolved Oxygen (%) 106.6 106.5 98.9

Dissolved Oxygen (mg O2l^-1) 11.09 10.87 10.18 For inspection purposes only.

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4.1.2.1 Site 1

This site was located approximately 50 meters downstream of the discharge from the Co-op effluent treatment plant discharge (approx. 750m downstream of confluence of the Allow and Dalua Rivers). The river at this location had a mix of substrate types, flow features with some pool habitat recorded. This site was considered to be sub-optimal / optimal in terms of habitat for macroinvertebrates. A macroinvertebrate family richness of 21 was recorded at the downstream site. Trichopterans were the best represented group with 7 families recorded; cased caddisfly larvae of Sericostoma personatum, Athripsodes sp., Lepidostoma hirtum and Potamophylax latipennis along with caseless larvae of Hydropsyche siltalai, Rhyacophila dorsalis and Polycentropus flavomaculatus (generally recorded in small numbers). Six species of mayfly at larval stage were recorded and included Ecdyonurus insignis which occurred in fair numbers, Heptagenia sulphurea (present), Caenis rivulorum (fair numbers), Ephemerella ignita (fair numbers), Baetis muticus (scarce) and Baetis rhodani which was numerous. The only stonefly larvae recorded was Leutra hippopus which was scarce. True fly larvae of Simulidae were common and green chironomidae were found in small numbers. Gammarus duebeni was the sole crustacean representative at this site while the only Mollusc was Ancylus fluviatilis (both in small numbers). Other macroinvertebrates recorded included (Hydracarina), Erpobdella testacea, E.

octoculata and Elmis sp. of which there were small numbers in general.

4.1.2.2 Site 2

This site was located adjacent to Kankurk Co-op, or approximately 150 m downstream of confluence of the Allow and Dalua Rivers. The substrate at this riffled site was mostly of bedrock and was considered sub-optimal with reference to macroinvertebrate production. At this location, a rich macroinvertebrate assemblage was recorded with 24 different macroinvertebrate families occurring.

Together, the cased and caseless caddisfly larvae accounted for the most diverse taxonomic group with a total of 9 species recorded. These were generally recorded in small numbers and included Lepidostoma hirtum, Potamophylax latipennis, Hydropsyche siltalai, Rhyacophila dorsalis and Agapetus fuscipes. Ephmeropteran larvae were more abundant and with Baetis rhodani and Ephemerella ignita (numerous), Heptagenia sulphurea (fair numbers) and Baetis muticus (present). Stonefly larvae of Leutra hippopus were found in small numbers the only snail recorded at this location (Lymnaea peregra) was present. Small numbers of Ancylus fluviatilis and Gammarus duebeni were recorded. Three families of leech were recorded; Erpobdella octoculata, Piscicola geometra and Glossiphonia complanata.

4.1.2.3 Site 3

This site was located upstream of Kankurk Co-op, or downstream of the confluence of the Allow and Dalua Rivers. This site was immediately downstream of a small weir. The right hand side of the river (looking in a downstream direction) was deemed to be influenced by the Dalua River and the left hand side by the Allow River. Macroinvertebrates in 24 different families were recorded at this location by sampling along the width of the river downstream of the weir. Macroinvertebrate habitat was considered optimal to sub-optimal.

A rich macroinvertebrate assemblage was recorded at this location (family diversity of 24).

Ephemeropterans, Plecopterans and Trichopterans were all well represented at this site. Mayfly larvae of Heptagenids were common with Heptagenia sulphurea, Rhithrogena semicolorata and

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4.1.3 Biological water quality 4.1.3.1 Site 1

Pollution sensitive (Group A) indictors (Heptagenidae) were recorded in fair numbers at this site.

The substrate at this location was lightly silted and Dissolved Oxygen (D.O.) was 106.6%. Using EPA freshwater biological monitoring criteria (Toner et al., 2005), this part of the river was rated

‘Unpolluted (Q4)’, equivalent to Water Framework Directive (WFD) ‘Good Status’. The Biological Monitoring Working Party (BMWP) score for this site was 132.2 which indicates ‘Very good’ water quality or ‘Unpolluted, un-impacted’ conditions. The Average Score per Taxon (ASPT) for this location was 7. Again, this score is well above the 5.5 score, above which water quality is deemed to be good. On a scale of 1-15, the Trent score for this site was 10.

4.1.3.2 Site 2

At this site, Group A mayfly larvae were present in fair numbers with Group C indicators comprising the bulk of the macroinvertebrate population. The substrate and floating river vegetation at this location was lightly silted and Dissolved Oxygen (D.O.) was 106.5%. This site was therefore rated ‘Unpolluted (Q4), equivalent to WFD ‘Good Status’. Very good water quality is also signified by the BMWP score of 139.6, the ASPT score of 6.6 and the Trent score of 11.

4.1.3.3 Site 3

This site contained three species of pollution sensitive mayfly larvae and three species of stonefly larvae with the former being common. It was clear that the rocks and other substrates in this part of the river had a light coat of silt. Dissolved Oxygen (D.O.) was 98.9%. Using these observations and the Q determination scheme, this site was rated ‘Unpolluted (Q4-5)’, equivalent to WFD ‘High Status’. This rating is supported with the other indices used to evaluate water quality. The BMWP score of 169.5 far exceeds the threshold score of 100 that indicates very good water quality.

Similarly, the ASPT was 7.7 and the Trent score was 13, the maximum attainable Trent score being 15.

4.1.4 Functional group analysis

Based on the results of the macroinvertebrates recorded during the biological sampling, there was little variation identified in the functional group analysis between the three sites, with regard to the feeding requirements of the macroinvertebrate communities identified (see Table 7). All sites had a macroinvertebrate assemblage indicative of heterotrophic conditions, the P/R ratio being less than 0.75. P/R is the ratio of behavioral drifters (filtering and gathering collectors) to accidental drifters (grazers, shredders and predators). The P/R ratio at Site 1, Site 2 and Site 3 was 0.35, 0.33 and 0.27 respectively. The juvenile salmonid index result for Site 1, Site 2 and Site 3 was 1.4, 1.12 and 1.25 in that order. These results show that there is a ‘Predictable’ macroinvertebrate food supply for young salmonids in the Allow River at Kanturk, where Site 1 is identified as being the most productive in terms of macroinvertebrate food availability for salmonids.

Table 6 Biological indices results and macroinvertebrate richness in the biological sites investigated in the River Allow at Kanturk in June 2011.

Biotic indices, ratings &

macroinvertebrate richness

Site 1 Site 2 Site 3

Macroinvertebrate family richness

21 24 24

Q-value Q4 Q4 Q4-5

Quality status (EPA) Unpolluted Unpolluted Unpolluted

WFD Status Good Status Good Status High Status

Quality class Class A Class A Class A

BMWP score 132.2 139.6 169.5

BMWP category Very good Very good Very good

BMWP interpretation Unpolluted un-impacted

Unpolluted un-impacted

ASPT 7.0 6.6 7.7

Trent biotic index 10 11 13

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Table 7 Functional feeding group (FFG) characteristics of the sites investigated in the River Allow at Kanturk in June 2011.

FFG Site 1 Site 2 Site 3

Number % of total

Filtering collector 89 24 68 18 98 22

Gathering collector 126 34 129 35 150 34

Scraper 89 24 86 23 90 20

Predator 23 6 30 8 22 5

Shredder 42 11 60 16 86 19

Total 369 100 373 100 446 100

P/R¹ ratio 0.35 0.33 0.27

Trophic status Heterotrophic Heterotrophic Heterotrophic

Juvenile salmonid index² 1.4 1.12 1.25

Predictable / Unpredictable food supply Predictable Predictable Predictable

1 Ratio of scrapers to total collectors and shredders (Plafkin et al., 1989).

2 Ratio of behavioural drifters (filtering and gathering collectors) / accidental drifters (scrapers, shredders and predators). From Rabenil et al., (2005).

4.2 Description of the Natura 2000 site affected

The site consists of the freshwater stretches of the River Blackwater as far upstream as Ballydesmond, the tidal stretches as far as Youghal Harbour and many tributaries, the larger of which includes the Licky, Bride, Flesk, Chimneyfield, Finisk, Araglin, Awbeg (Buttevant), Clyda, Glen, Allow, Dalua, Brogeen, Rathcool, Finnow, Owentaraglin and Awnaskirtaun. The extent of the Blackwater and its tributaries in this site, flows through the counties of Kerry, Cork, Limerick, Tipperary and Waterford.

The site is a candidate SAC selected for alluvial wet woodlands and Yew wood, both priority habitats listed on Annex I of the E.U. Habitats Directive. The site is also selected as a candidate SAC for floating river vegetation, estuaries, tidal mudflats, Salicornia mudflats, Atlantic salt meadows, Mediterranean salt meadows, perennial vegetation of stony banks and old Oak woodlands, all habitats listed on Annex I of the E.U. Habitats Directive. The site is also selected for the following species listed on Annex II of the same directive - Sea Lamprey, River Lamprey, Brook Lamprey, Freshwater Pearl Mussel, Crayfish (in the Awbeg catchment), Twaite Shad, Atlantic Salmon, Otter and the Killarney Fern.

Landuse at the site is mainly centred on agricultural activities. The banks of much of the site and the callows, which extend almost from Fermoy to Cappoquin, are dominated by improved grasslands which are drained and heavily fertilised. These areas are grazed and used for silage production. Slurry is spread over much of this area. Arable crops are grown. The spreading of slurry and fertiliser poses a threat to the water quality of this salmonid river and to the populations of Habitats Directive Annex II animal species within it.

Areas of importance for habitats and flora within the cSAC in the vicinity of the proposed development site are detailed below. Table 8 presents the qualifying interests of the River Blackwater cSAC, i.e. habitats and species listed on Annex I and Annex II of the EU Habitats Directive (1992) that occurs within the study area.

4.2.1 Annex I habitats

According to the site synopsis for the River Blackwater cSAC good examples of wet For inspection purposes only.

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The cSAC boundary designation along the riparian corridor of the River Allow at this location is therefore considered to be with regard to the water dependant Annex I habitat ‘Floating river vegetation’ which occurs within the study area and with particular reference to the Annex II species which occur within this watercourse.

4.2.2 Annex II species 4.2.2.1 White-clawed crayfish

This species has been recorded from the Blackwater catchment, specifically from the Awbeg River sub-catchment which meets the River Blackwater downstream of the River Allow confluence. Records for white-clawed crayfish (Austropotamobius pallipes) are shown on the Biodiversity Ireland database (www.biodiversityireland.ie) and are part of the EPA biological water quality monitoring data records. The white-clawed crayfish has not been recorded from the River Allow and is not expected to occur in this watercourse due to unfavourable water chemistry for this species.

4.2.2.2 Freshwater Pearl Mussel

The Pearl Mussel is listed under Annex II and V of the Habitats Directive (92:43:EEC). It is legally protected in Ireland under Schedule 1 of the Wildlife Act (1976 (Protection of Wild Animals) (Statutory Instrument No. 112, 1990) and the European Communities (Natural Habitats) Regulations (Statutory Instrument No. 94, 1997). This species is listed as one of the conservation interests of the River Blackwater cSAC. This species occurs in the Allow River sub-basin, with populations occurring upstream of Kanturk. There are no records of populations from the river downstream of Kanturk (DoEHLG, 2010) and no mussels were seen during the current aquatic survey.

The River Blackwater contains significant freshwater pearl mussel populations, particularly downstream of the Allow River confluence and in the vicinity of Mallow. Significantly, there is a population of this species located directly downstream of the confluence between the River Allow and the River Blackwater. This gives rise for potential impacts affecting this species downstream of the proposed development.

4.2.2.3 Brook, River, and Sea lampreys

The brook lamprey is the smallest of the three lamprey species native to Ireland and it is the only one of the three species that is non-parasitic and spends all its life in freshwater (Maitland & Campbell 1992). The River lamprey is larger in size than the brook lamprey and exhibits an anadromous life cycle (i.e. where anadromous fish spend most of their adult lives in salt water, and migrate to freshwater rivers and lakes to reproduce). The sea lamprey is the largest of the Irish lampreys. Brook lamprey and Sea lamprey are listed in Appendix II, while River lamprey is listed in both Appendices II and IV of the Habitats Directive (92:43:EEC).

An extensive sampling programme for lamprey and shad was undertaken in the River Blackwater (Cork/Waterford) cSAC, by Inland Fisheries Ireland staff (King and Linnane, 2004). The project was undertaken between April 2003 and March 2004. Juvenile River/brook lamprey were found to be widespread in the Allow catchment within the River Blackwater cSAC. Juvenile sea lamprey were also recorded in the River Blackwater catchment, including the Allow sub-catchment (King & Linnane, 2004). Lamprey spawning habitat was recorded from within the study area; however, suitable silt deposits for juvenile lamprey are limited along the margins of the River Allow corridor within the study area.

4.2.2.4 Atlantic salmon

The Atlantic salmon is listed under Annexes II and V of the EU Habitats Directive and Appendix III of the Berne Convention. Salmon are listed as one of the key conservation objectives of the River Blackwater cSAC. Salmon spawning and nursery areas are present throughout the River Allow within the study area.

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Table 8 Qualifying interests of the River Blackwater (Cork/Waterford) cSAC potentially affected by the proposed development at the Kanturk Creamery site.

Qualifying interests Potential occurrence within the

River Allow or the River Blackwater downstream

Annex I Habitats

Estuaries (1130)

Mudflats and sandflats not covered by seawater at low tide (1140)

Perennial vegetation of stony banks (1220)

Salicornia and other annuals colonizing mud and sand (1310)

Atlantic salt meadows Glauco-Puccinellietalia maritimae (1330)

Mediterranean salt meadows Juncetalia maritime (1410) Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation (3260)



Old sessile oak woods with Ilex and Blechnum in British Isles (91A0)

Alluvial forests with Alnus glutinosa and Fraxinus excelsior Alno-Padion, Alnion incanae, Salicion albae (91E0)



Taxus baccata woods of the British Isles (91J0)

Annex II Species

Sea lamprey (1095) River lamprey (1099)

Brook lamprey (1096) 

Freshwater pearl mussel (1029) 

Twaite Shad (1103) Allis Shad (1102)

Atlantic salmon (1106) 

White-clawed crayfish (1092)

Otter (1355) 

Killarney fern (1421) 4.2.2.5 Shad

Twaite Shad (Alosa fallax) and Allis Shad (Alosa alosa) are among the rarest species of fish breeding in Irish freshwaters and are listed under Annexes II and V of the EU Habitats Directive (1992). Both species are also listed in Appendix III of the Bern Convention. Shad have an anadromous life cycle and both species have been recorded from the Lower Blackwater, with a record of Twaite shad from Fermoy (Kelly and Linnane, 2004). Neither of these species occur within the study area, being generally restricted to the estuarine and lower freshwater reaches of the Blackwater. The status of both shad species is considered to be very vulnerable in the Blackwater River cSAC.

4.2.2.6 Eurasian Otter

The otter Lutra lutra is listed under Annex II of the EU Habitats Directive and under Annex II of the Berne Convention; it is also a legally protected species under the Wildlife Act, 1976 (and Wildlife (Amendment) Act, 2000). Otter are found throughout Ireland and tend to occupy linear territories along watercourses and are rarely found far away from water. This species is listed as one of the qualifying interests of the River Blackwater cSAC designation. Otters

APPENDIX B.6(d2) Letter from Cork County Council in reference to EIS for previous planning permissions granted

APPENDIX B.6(d2)

Letter from Cork County Council in reference to EIS for previous planning permissions granted

APPENDIX B.6(f1)

Letter from Cork County Council

requesting an Appropriate Assessment be conducted

APPENDIX B.6(f2)

Appropriate Assessment and Natura Impact Statement

North Cork Co-operative Creameries Kanturk, Co. Cork

Proposed Milk Evaporator and Spray Drying Plant

Article 6 Appropriate Assessment:

Natura Impact Statement

Version: 2.1 (Final) 15

August 2011

TABLE OF CONTENTS

1. INTRODUCTION

1.1 Consultation

1.2 Legislative context

2. METHODOLOGY 2.1 Desk study

2.2 Field survey

2.3 Appropriate Assessment Methodology

3. STAGE 1: SCREENING / TEST OF SIGNIFICANCE 3.1 Description of the project

3.2 Identification of relevant Natura 2000 Sites

3.3 Screening Assessment of Likely Effects

3.4 Screening statement with conclusions

4. STAGE 2: APPROPRIATE ASSESSMENT

4.1 Description of the Receiving Environment

4.2 Description of the Natura 2000 site affected