Enhanced Decommissioning Rehabilitation and Restoration Scheme (EDRRS), Quarterly Reports – from Bord Na Mona to Dept of Housing

Received via AIE

Notes below on redactions for internal review.

Review will submit that Dept outline what the commercial or industrial interest is, and where it is protected in law. Plus will submit that Dept have failed to apply the public interest test properly in 10(3).

• Enhanced Decommissioning Rehabilitation and Restoration Scheme (EDRRS), Quarterly Report – Bord Na Mona Q1FY22, (Apr 2021 to June 2021)

• Enhanced Decommissioning Rehabilitation and Restoration Scheme (EDRRS), Quarterly Report – Bord Na Mona Q2FY22 (July 2021 to Sept 2021)

• Enhanced Decommissioning Rehabilitation and Restoration Scheme (EDRRS), Draft Quarterly Report – Bord Na Mona Q3FY22 (October 2021 to December 2021)

Notes (Qtr1)

Rehabilitation commenced on bogs later than was originally planned

Decommissioning of rail line and Bog Clean Up is progressing in line with expectations.

Submit AIE Request for the Risk Register (which is reviewed with NPWS and DECC on a monthly basis), if NPWS plan not to publish the risks of the project

Progress is monitored in two ways: recorded by Hectares Completed and also by Work Content Completed

A system is in place whereby BnM submit the work packages to NPWS for approval in advance

Details on Rehabilitation to Date are redacted

Rehabilitation Costs by Bog are redacted

Decommissioning by activity is not redacted, and is broken down as follows:

Monitoring and Verification (number of samples taken and surveys completed) is redacted

Submit AIE Request the separate Monitoring and Verification reports, if NPWS plan not to publish these reports (they likely contain the actual environmental data that underpin the short quarterly reports)

Grant claim information is redacted

Employment numbers involved in the project are redacted

First quarter targets/actuals: rehabilitation hectares in the model for Qtr1 is 2,786 Ha vs 272 Ha completed

All details on project risks are redacted

Notes (Qtr2)

Rehabilitation measures completed at Kellysgrove Bog

Key metrics for the quarter and comparison with the EDRRS Financial Model are redacted

The Total Area Rehabilitated consists of areas where specific rehabilitation measures have been carried out such as drain blocking, berms and blocking of outfalls. It also includes areas where rehabilitation is either not possible or not required, i.e. areas designated as MLT1 (Marginal Lands Type 1) or AW1 (Additional Works 1) rehabilitation types. While these areas will benefit from the adjoining rehabilitation, there is no specific rehabilitation carried out within them. For clarity a distinction has been made in Table 2.1 (redacted) below between the Total Area Rehabilitated, which includes the MLT1 and AW1 areas and Total Area Rehabilitated with Specific Measures which excludes the MLT1 andAW1 areas.

The ancillary benefits to date for areas from adjoining rehabilitation have been identified, but are redacted

By the end of Qtr2 rehabilitation measures had commenced on sixteen of the nineteen FY22 (2021) bogs

The three bogs where measures had not commenced were Boora Bog, Clonad Bog and Clooniff Bog

Clooniff Bog commencement date not noted

Reasons as to why no rehabilitation measures are proposed in MLT1 and AW1 areas:

– Areas where there are no drains to block;

– Inactive turf cutting areas where 3rd party turbary rights may exist;

– Narrow strips of land around bogs that are densely vegetated;

– Area adjacent to drains/streams that need to be retained to provide drainage to third party lands;

– Areas that are vegetated where rehabilitation measures are not considered necessary or beneficial.

Constraint include some active turfcutting areas and forestry areas

It’s perhaps worth a closer look at the MLT1 and AW1 areas (adjacent lands) as there is now an opportunity for them to commence rehabilitation works (obviously would not have been possible due to legacy BnM drainage operations) ?

Qtr2 progress: 41% of the work plan for this year (FY22) completed. 2,083 Ha completed (24% of the total area)

Decommissioning by activity is not redacted, and is broken down as follows:

Surface water samples refer to surface water quality monitoring where samples are taken and analysed for the following parameters – pH, suspended solids, total solids, ammonia, total phosphorous, chemical oxygen demand (COD), colour and dissolved organic carbon (DOC)

Note: check does water quality reporting go to other competent authorities (IFI, EPA, local authority, LAWPRO)?

Review (quarterly?) meeting minutes in relation to risks/progress with BnM, Dept and NPWS. Are these minutes published, if not request via AIE.

Notes (Qtr3)

Rehabilitation had commenced on sixteen bogs and by the end of the quarter rehabilitation was ongoing on seventeen bogs and completed on one bog

The total area to be rehabilitated in the FY22 (Year 1) bogs is 8,761 hectares. The area rehabilitated at the end of this quarter was 5,196 hectares which is 59% of the total area to be rehabilitated in the nineteen FY22 (Year 1) bogs. The Work Content completed at the end of the quarter was 69.5% of the Work Content for the nineteen FY22 (2021) bogs.

Note on Clooniff Bog appears to be redacted. Only bog where work has not commenced. Why?

69.5% of the Work Content for this year (FY22) completed by the end of the quarter. At the start of this quarter 40.7% of this work content had been completed

Chart to illustrate progress to date:

Decommissioning by activity is not redacted, and is broken down as follows:

Section on Carbon Monitoring is redacted

Total number of employees is unredacted in Qtr 3 reporting. Listed as 221.5 employees across 7 employee groups/types

Notes on Kellysgrove Bog

Kellysgrove Bog (203 ha) was drained in the 1980s in anticipation of industrial peat production but no peat harvesting ever took place. The bog was completely ditched and drained, but the vegetated surface was never removed.

The site is located adjacent to the River Suck and several designated conservation sites.

To minimise potential impacts on neighbouring land, some boundary drains around Kellysgrove Bog will be left unblocked as blocking boundary drains could affect adjacent land. This includes active private turbary. It is not proposed to carry out any rehabilitation in the cutover bog zone at the north of the site

The entire bog is not within the ownership of Bord na Móna and turf cutting is having a significant impact on the northern end of the bog, both within and outside the BnM boundary. There is no turf- cutting around the southern section. 40% of the bog is not under BnM ownership, and this area has significant turf extraction operations, anc issues with dumping and burning.

Quarterly EPA mandated water quality sampling has moved to monthly sampling.

Article 6(3) Appropriate Assessment Screening Report
Kellysgrove Bog, Co Galway
Decommissioning and Rehabilitation 2021

Notes on Clooniff Bog

Clooniff Bog (530.3 ha, Roscommon) peat extraction ceased recently, in 2019.

Parts of Clooniff Bog (outside the areas owned and under the control of Bord na Móna) are used by 3rd party contractors for the extraction peat. These areas are ecologically and hydrologically linked to Bord na Móna bog where rehabilitation is planned.

Stakeholders such as the IFA, ICMSA and multiple residential neighbours have queried likely impacts arising from the proposed re-wetting associated with the rehabilitation in relation to flooding on adjoining lands and, specifically, with regards to the maintenance of drains. The IFA also raised the issue of Health and Safety in relation to raising water levels as well as possible impacts on land and property prices.

Conservation groups have commented that ongoing turf cutting on the margins of the bog (within and outside of the area owned by Bord na Móna) needed to be addressed to maximise the benefits of the rehabilitation work being proposed.

Clooniff has a pumped hydrological regime. It is expected that when pumping is stopped that water levels will rise significantly across parts of the site. This has already occurred across a portion of the site.

Some parts the peat has been removed entirely to expose the rock / mineral deposits underlying the peat

The site is located adjacent to the River Shannon Callows and several designated conservation sites. In winter, the site can be inundated with water corresponding to winter flood levels on the River Shannon (the site forms part of the River Shannon floodplain).

EPA IPC Licence – Ref. P0502-01. As part of Condition 10.2 of this license, a rehabilitation plan must be prepared for permanent rehabilitation of the boglands within the licensed area. The key objective of ‘rehabilitation’, as required by this licence, is achieved by the environmental stabilisation of the bog.

To minimise potential impacts on neighbouring land, some boundary drains around Clooniff Bog will be left unblocked as blocking boundary drains could affect adjacent land.

Bord na Móna has extensive EPA financial obligations relating to rehabilitation and decommissioning under its Integrated Pollution Control Licence. It may be difficult to separate out the IPCL obligations (and resultant costs to BnM) from the works/costs funded by the EDRRS / PCAS scheme.

Funding provided under the Scheme cannot be used to cover costs for Bord Na Móna to meet their IPC licence obligations.

Reporting to the EPA continues until the IPC License is surrendered. The bog will be included in the full licence surrender process as per the Guidance to Licensees on Surrender, Cessation and Closure of Licensed Sites EPA, 2012, when:

1. The planned rehabilitation has been completed.

2. Water quality monitoring demonstrates that water quality of discharge is stabilising or improving.

3. The site has been environmentally stabilised.

Clooniff Bog
Pumping stations and sample points

Overall monitoring has improved, and scale of monitoring seems up from the basic EPA mandatory monitoring sites. The reporting is regular (perhaps monthly or quarterly, it’s unclear), but data is only published annually. Perhaps the data could be published by LAWPRO or EPA on catchments.ie or similar so there is improved transparency for WFD

For context, this is the list and map of all bogs covered by the scheme

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