OCE-109597-B3M7V0
Judicial Review 740/2018
Author: admin
Flood Data – Access to Data, Data Usage and the Flood Map Review Programme
27th January 2023
Implementation of the Flood Risk Management Guidelines: OPW Presentation
Licence Utilisation Inspection – Standard Operational Procedures (Forestry)
Harvesting Inspections of Felling Licences (Draft), Forestry
Legal costs declared by ABP in 2020 to PAC Committee
EPA Water Abstraction Register 2023
Note: townslands are now included (Column K, L) but not for all records
Redactions are under appeal with OCEI
Notes from the notes
eg 47 points of abstraction in Longford, what is this for ? just says land drainage, but why so extensive?
DROMIDICLOGH WEST Cork,
Agri food abstraction, two river / two boreholes (likely Carbery Group)
KILLAGH MORE, Galway
Artificial groundwater level for landfill cell protection – Cone of depression
150-acre landfill at Killagh More, near Kilconnell
W0178-02 https://epawebapp.epa.ie/terminalfour/ippc/ippc-view.jsp?regno=W0178-02
3. I7 Groundwater Management
3.17.1 Effective groundwater management infrastructure shall be provided and maintained at the facility during construction, operation. restoration and aftercare of the facility. As a minimum. the infrastructure shall be capable of the following
a) the protection of the groundwater resources from pollution by the waste activities; and
The protection of other infrastructure, such as the liner, from any adverse effects caused by the groundwater.
b) 3.17.2 Any groundwater arising from the construction of the facility shall be diverted to the surface water lagoon.
KILREE Kilkenny
Quarrying, Bennettsbridge Limestone Quarries
W78
70,000m3/day with a maximum annual average of 22,000m3
BALLYKELLY Wexford
Quarrying,
Wexford County Council No. SS/W161/04
Abstraction is limited to 200m3/d from May to end of September and to 1,000m3/d from October to end of April.
Dublin City
Industrial
Groundwater well / borehole
Abstraction is restricted to 100m3/d
KILLIN Louth
Beverages,
MOYNE LOWER Wexford
Industrial – Groundwater Remediation
P0394-01
Abstraction rates agreed in consultation with the EPA and periodically reviewed.
Assaroe, Donegal
Hydropower
Assaroe reservoir working levels (Assaroe Lake is a 578-acre artificial lake created by the Cathleen falls and Cliff Hydro schemes and is controlled by the ESB)
CARRIGANASS CANSHANAVOE GLENLOUGH (Cork)
Hydropower, three abstractions,
Donegal
Hydropower,
cross border agreement, no further details
CAHERTEIGE Clare
Industrial
Daily limit of 300m3 and hourly limit of 40m3
Reservoir abstraction,
Sackville, Kerry
Discharge licence from Kerry County Council. Maximum daily discharge 40,000m3 . Note average daily discharge 13,700m3 approx with maximum seasonal discharge of 27,730m3
Rivers, Limerick
three abstractions
Cooling
discharge of cooling water from abstraction limited to 2300m3/day
TARBERT ISLAND Kerry
P0607-02
IED/IPC Licence conditions to comply with
GRAIGUENOE Tipperary
Hydropower,
If the water on the river is low ( no rain) the turbine is not operational
FARRANAVARRIGANE Cork
Licence agreement with ESB
Dublin
W0232-01
Limited to 14040 m3 per hour Maximum and 570000 m3 per day
Mallow Cork
Industrial, Groundwater,
P0403-03
Local Authority Planning Restriction 1300m3/day
LISNAGOWAN Cavan
Agriculture (Drinking consumption, parlour and herd washing)
Local Environmental Health Officer does not allowed us to use water for human consumption
KINDRUM Donegal
Aquaculture, lake abstraction,
Lwat25
Max volumetric flow per 24 hours (m3) = 6048
BALLYKILLEEN (COOLESTOWN BY) Offaly
Industrial
Maximum abstraction is 240m3/hr. under planning permission
CLONBULLOGE Offaly
Industrial
Maximum abstraction is 240m3/hr. under planning permission
Colligan River
W0032-03
Treatment of Landfill Leachate
Maximum abstraction to Colligan River is 186 cubic meters per day
GREATISLAND Wexford
Cooling
maximum allowable cooling water returned to the estuary under our IPPC permit is 792,000m3 per day
PROCKLIS (ED Dunlewy) Donegal
Aquaculture
Lwat26
Maximum daily flow (m3) = 34560
Aquaculture, Station Island Donegal
Lwat27
Yes Maximum daily flow (m3) = 34560
COOLADERRY (ED Fanad North) Donegal
Lwat28
Maximum volumetric flow (m3/24 hours) = 175
Clare
Hydropower
Minimum lake level & drawdown.
CLOGH LOWER Wicklow
Agriculture
not to cause any pollution issues
BALLINTEMPLE Carlow
Irrigation, Forest Nursery Production
River abstraction
Permissible limit from Inland Fisheries based on maximum of 60m3 per hour.
Dublin City
Temporary dewatering of an excavation on a construction site, Dublin
Five abstractions via Groundwater well / borehole
PJ Hegarty has applied for 2 Discharge Licences:
1. Dublin City Council, discharge licence to Waters, to recharge water back into the gravel aquifer within the site. DCC has issued the licence to discharge to waters (PCLW/005/18) and discharge limit is 432 m3/day.
2. Irish Water, discharge licence to sewer, to discharge water into the foul sewer.
Both licences will limit the volume of water allowed to recharge / discharge per day. This will restrict the abstraction.
MOYODE Galway
Quarrying
W376 04
Set of conditions relating to the discharge license W376 04
CASTLEGRACE Tipperary
Hydropower
Subject to agreed low flow compensation under terms of original planning. Effectively turbine cuts out automatically when flow is too low. Normal year approx 1 month. 2018 four months.!
LUNG and BANADA Roscommon
four abstractions
Industrial cooling
P0802-02
SW4 abstraction limited to 6000 m3/d
PARK NORTH Cork
industrial cooling, nine abstractions
P0442-02
The maximum water abstraction rate from the combined eight production wells shall be 4,300 m3/day.
ARDCLONE Kilkenny
Spring water used as an ingredient in the manufacture of beverages
Groundwater well / borehole abstraction
Treatment of the water is prohibited with the exception of filtration
DRUMCAVANY Donegal
Aquaculture
River abstraction
Lwat40
Volumetric flow per minute = 5m3
DROMALOUR Cork
WP(W)02/18 and WP(W)07/11
Wastewater Monitoring Programme for BOD, Suspended Solids, Total Nitrogen, Total Phosphorous and Mineral Oils
BALLYHEST WEST Cork
WP(W)02/18 and WP(W)07/11
Wastewater Monitoring Programme for BOD, Suspended Solids, Total Nitrogen, Total Phosphorous and Mineral Oils
EPA National Environmental Complaints Line (NECL) Database
OEE AIE 2022 39
AIE includes:
Excel files of the environmental complaints, which give a good overview of the types of complaints reports
Summary reports (for three quarters in 2022)
Note: these are all complaints about Non-Licensed sites (sites that do not have an EPA licence so not in LEAP/EDEN systems. Examples would be the ones noted as significant, eg Donegal pig farm under the EPA stocking threshold for an EPA licence, and the IDA site at Loughmore Canal (which while it serves some EPA licenced sites, is not itself a licenced site)
NON-LICENSED COMPLAINTS: JAN – MAR Q1 2022
This report summarises complaint matters handled by the OEE Complaints (Non-Licensed) Team in January-
March 2022 and complaints received pre-2018 handled by regional/thematic teams.
NON-LICENSED COMPLAINTS: HALF YEAR JAN – JUNE 2022
This report summarises complaint matters handled by the OEE Complaints (Non-Licensed) Team in the first half of the year, Jan – June 2022 – and complaints received pre-2018 handled by regional/thematic teams
NON-LICENSED COMPLAINTS: JUL – SEPT Q3 2022
This report summarises complaint matters handled by the OEE Complaints (Non-Licensed) Team in July-September 2022 and complaints received pre-2018 handled by regional/thematic teams.
EPA Requirement to keep a Water Abstraction Register, and legislation on Public Access to the Register
BirdWatch Ireland Submission to the draft Forest Strategy and Draft Forest Strategy Implementation Plan
Key Messages
1. Since 2014, the Forestry programme 2014-2022 has sanctioned the planting of 13,719 hectares or 14.1% of forestry planted nationally (Coillte and private planting) in hotspots for 6 of our most threatened breeding waders in Ireland.
2. Since 2014, the Forestry programme 2014-2022 has sanctioned the planting of 6,538
hectares or 6.7% of forestry nationally (Coillte and private planting) in hotspots important
for 28 of our red and amber listed birds of conservation concern.
3. BirdWatch Ireland mapping shows that since 1990 78,606 or 14.6% of total forestry planted
has been in breeding wader hotspots and 37,036 or 6.7% of total forestry planted in farmland
bird hotspots.
4. BirdWatch Ireland mapping shows that the total forestry replanted since 2014, within Breeding Hen Harrier SPAs is 12,382 [hectare] or 12.7% despite there being a moratorium on planting in place in that time period.
5. This is evidence that Ireland is in breach of the Birds Directive and the conditions of the European Commission State Aid Decision granting consent for the provision of €200 million to fund the 2014 Forestry Programme including:
a. Projects must be undertaken in compliance with national and EU legislation (e.g. several articles of the Birds Directive).
b. The condition to avoid planting on environmentally sensitive sites and
c. The inappropriate afforestation of sensitive habitats such as peat lands and wetlands will be avoided, as well as the negative effects on areas of high ecological value including areas under high natural value farming.
6. A disproportionate amount of forestry is being planted in important areas for birds in the wider countryside. There are likely several reasons for this.
a. There is no strategic planning of afforestation in Ireland
b. There is no ornithological assessment of sites/applications being proposed for afforestation.
c. The Land Types for Afforestation document which provides guidance on the land which can be planted, is potentially a driver of loss of Annex 1 habitat and habitat for birds and other biodiversity
d. The payments and tax-free status of afforestation premia are lucrative. No agri-environment scheme which would pay farmers to continue to farm for threatened bird species can compete. This creates the risk that even more areas of land will be opened up for afforestation further threatening bird species.
7. The draft Forestry Implementation plan for 2023-2030 which is underpinned by an almost 7-fold increase in funding does not contain any evident changes in individual environmental assessment of afforestation applications to account for the presence or absence of birds on a site proposed for afforestation compared to the 2014-2022 Forestry Programme. It is clear therefore that we can expect further losses of habitat important for breeding waders and other farmland birds unless changes are made.
8. The environmental assessments of the draft Forestry Programme fail to consider the impacts on the different measures on red and amber listed birds in the wider countryside. There is also woefully inadequate assessment of Annex 1 bird species in the wider countrywide (e.g. geese and swans) in breach of Article 6.3 of the Habitats Directive and various European Court of Justice rulings. The Article 12 reporting research only extracted data relating to Annex 1 species that are qualifying interests of an SPA are considered in this AA report and what is reported is incorrect. Also unclear as to why the BoCCI status of Curlew, a red listed
species for breeding and wintering has N/A status associated with Table 4 in the NIS. The BoCCI status for a range of red and amber listed species is listed as N/A with no rationale as to why. These should be listed.
9. The analysis of the effects of the Programme on Annex 1 species is extremely limited. It focuses in on Annex 1 species with ‘bad’ or ‘inadequate’ status that are already identified as being affected by forestry activities (according to Article 12 code)
10. Species assessments in NIS. The NIS only focuses on Merlin and Hen Harrier and fails to assess impacts on a range of other Annex 1 species or the conservation interests of the SPAs.
11. Incombination assessment of other plans and programmes is extremely general. For example the statement that the IFSIP is ‘broadly in line with the EU biodiversity Strategy’. Afforestation is a significant pressure and threat to a range of threatened bird species whose populations must be restored. Assessment fails to consider this.
12. The cumulative impacts of afforestation, intensification of agriculture, peat cutting, wind farm development etc have not been adequately considered in the environmental assessments of the draft Forestry Programme.
13. It is of serious concern to us that a farmer signed up to an ACRES contract can end that contract to afforest his/her land and not be subject to penalties.
14. The fact that a farmer can receive the Basic Payment which requires adherence to Article Article 3(1), Article 3(2)(b), Article 4 (1),(2), and (4) covering legal protection for birds and a requirement to protect birds in the wider countryside and receive an afforestation payment which wipes out habitat for birds is discordant and an abuse of taxpayers money. Taxpayers are paying on the double for both the protection of habitats and their destruction. This must change.
15. Unless afforestation is planned strategically with clear objectives and processes is put in place to avoid afforestation in important areas for birds, breeding waders in particular could be wiped out as a result of the state’s forestry programme to 2030.