COMHAIRLE CONTAE ÁTHA CLIATH THEAS
SOUTH DUBLIN COUNTY COUNCIL

MEETING OF SOUTH DUBLIN COUNTY COUNCIL

Monday, July 14, 2008

HEADED ITEM NO. 14

SUBMISSION TO AN BORD PLEANALA IN RESPECT OF N7 RESOURCE RECOVERY PROJECT AT BEHAN'S QUARRY, WINDMILL HILL, RATHCOOLE, COUNTY DUBLIN

Heritage Officer’s Report on the Flora and Fauna Survey of the EIS for the N7 Resource Recovery Project (N7RRP)

Introduction

The EIS report for the N7 RRP indicates that the ecological assessment section of the EIS comprised both a desktop study and on-site field surveys.  The nearest site designated for nature conservation was stated to be Slade of Saggart and Crooksling Glen pNHA, which is 3.7km southeast of the quarry.  The report indicates that there will be no direct impacts on this or any other site designated or proposed for nature conservation.

Following initial consultation with the Development Applications Unit of the Department of the Environment, Heritage and Local Government (DoEHLG), the Department highlighted the potential for the presence of protected species within the area, notably Peregrine Falcon, Falco

peregrinus, Irish Hare, Lepus timidus hibernicus and possibly raven Corvus corax.  The Department also indicated that a flora and fauna survey should be undertaken with appropriate mitigation measures subsequently produced.

A Flora and Fauna Survey was undertaken by Tobin Consulting Engineers in September 2007, recording habitat and general mammal observations both within the N7RRP site and the adjacent lands in the ownership of L.Behan & Sons Ltd.  During that survey, the presence of a pair of peregrine falcons was noted within the quarry.  This species is protected under the EU Birds Directive and under the Irish Wildlife Act (as amended 2000).  In order to determine whether this species is breeding within the quarry, a further survey was undertaken in April 2008.

Comments on EIS survey results of flora and fauna

Habitat and floral assessment

Eight habitat types were recorded during the survey of September 2007.  The EIS report indicates that any direct impacts arising from the proposed development will be confined to only two of these habitat categories: the existing quarry area (Active quarries and mines (ED4); and the farm buildings complex (Buildings and artificial surfaces (BL3)).  While both of these habitats are generally considered to have low ecological value, some important considerations must nonetheless be taken on board as outlined below.

While a number of rare or protected plant species are recorded as occurring in the 10km square survey grid in which the proposed development occurs, no rare or protected species were recorded during the habitat survey undertaken during September 2007.  The EIS report indicates that the improved nature of the landscape in the area is unlikely to support many of the listed species.  Only two of the habitats recorded, hedgerows and quarry spoil heaps, are likely to hold plant species of conservation interest.  The EIS report recognises, however, that the site visits were undertaken outside of the optimum period for botanical surveys.    

Recommendation:          Undertake additional survey during more optimal time periods for plant surveys e.g. late spring/early summer in order to establish a more comprehensive record in relation to rare or protected plant species.  In particular, the presence and status of any rare or protected flora in the quarry and in its vicinity needs to be established and any required mitigation measure undertaken.  

Peregrine falcon breeding survey

During the April 2008 survey, survey effort was concentrated in the south western part of the quarry, where the N7RRP is to be sited.  Observations were also made on the eastern side where active quarrying continues.  The presence of two peregrine falcons within the quarry was confirmed during this survey.  Plucking posts were observed but the birds were not seen to settle on a nest at that time.  The report states that it is possible that one of the birds, a male, may be too immature to breed this year but also indicates that an additional survey later in the breeding season should be undertaken to confirm if nesting has occurred.

Recommendation:          Undertake the second phase of the breeding-birds survey to

confirm whether or not the peregrine falcons are breeding in the quarry. 

 

As recommended in the EIS report, the status of the peregrine falcons should be assessed every year and any necessary mitigation measures should be undertaken to comply with legislation protecting these species.

Ravens

No evidence of the presence of ravens was observed during either of the surveys undertaken in September 2007 or April 2008.

Other bird species

A reasonably good species list for other bird species was recorded during the survey undertaken in September 2007.  The species are typical of the farmland and open country in the vicinity of the site.

Mammals

No detailed mammal survey was undertaken, with the EIS report indicating that only general evidence such as tracks and scats were noted.  Evidence of rabbit and fox was recorded and it was noted that other species such as hedgehog, wood mice, and pygmy shrew should also be expected given the nature of the habitats occurring on the site.  No evidence of the presence of Irish hare was recorded. 

The EIS report accepts that the network of hedgerows in the vicinity of the quarry, as well as the presence of old farm buildings and out houses included within the proposed site works, would provide suitable sites for bat roosts.  No survey for bats was undertaken as part of the EIS but such a survey was recommended as part of the EIS report.  All bat species are protected under Annex IV of the EU Habitats Directive and under the Irish Wildlife Act (as amended 2000).  The report lists some mitigation measures which will be required if bats are detected on the site.

Recommendation:          Undertake a bat survey during the appropriate time of the year to determine the presence and status of these protected species.  The farm house and out-buildings included in the planning proposals should be inspected for their potential as bat roosts.  The potential offered by the surrounding network of trees, scrub, and hedgerows as additional roosts and feeding routes should also be assessed.  Any necessary mitigation measures must be adhered to in order to comply with legislation protecting these species.   

The EIS report does not mention the presence or otherwise of badgers in the vicinity of the quarry.  Given the nature of the farming landscape and the network of hedgerows and scrub recorded in the habitat survey, there is the potential for either the presence of badger setts or the presence of established foraging paths.  While it is unlikely that badgers occur in the immediate vicinity of the quarry itself, their presence and status in the surrounding farm landscape within the area covered by this EIS needs to be established.  Mitigation measures will be required to counter any potential impacts.

Recommendation:          Undertake a survey to establish the presence or otherwise of badgers in the landscape surrounding the quarry.  Adhere to any mitigation measures that may be required if their presence is detected.