AIE: Appeal to OCEI regarding release of NPWS monitoring reports on Bord na Mona PCAS programme (peatland rehabilitation project)

AIE request AIE-021-2022

Appeal submitted to Office of the Commissioner for Environmental Information

Delay of one month granted to 3rd party by NPWS to review release of monitoring reports has no basis in law under the AIE Regs

There is no provision under the AIE Regs for NPWS to make “all reasonable efforts to seek the consent or otherwise of Bord na Mona prior to release of the information”

Submissions to Bord na Móna under the Peatland Climate Action Scheme for 2021

AIE Request COSEC00326

Note: Insomuch as any further records may potentially exist, they would be held by Bord na Móna Energy Limited, which is responsible for the Peatlands Climate Action Scheme. It is that company’s position that it is not a public authority for the purposes of the AIE Regulations and therefore, the Regulations do not apply to it.

Longford CoCo Submission on Draft Edera Bog Cutaway Bog Decommissioning and Rehabilitation Plan 2020

DAFM Submission highlighting potential risks of works on adjoining landowners land

PCAS Response

EPA Map: Licensed Peat Extraction Installation Boundary

AIE: OEE AIE 2022 17

Abstract: This dataset demonstrates the location name and area of bogs licensed for the extraction of peat by Bord na Mona under nine separate licences.

Data Purpose: To facilitate the identification of the location and area of licensed peat extraction site boundaries.

https://gis.epa.ie/EPAMaps/

The concerned records have been published to the EPA website and are available at EPA Maps. To find the records, look in “WMS Layers” for “Licensed Peat Extraction Installation Boundary”.

Bord na Mona: Land Registry search, by county

Kildare

Galway

Laois

Longford

Mayo

Meath

Offaly

Roscommon

Tipperary

Westmeath

Notes;

Section 49 is an application for Adverse Possession

https://www.prai.ie/adverse-possession-registered-land-section-49/

Begnagh Bog: Cutaway Bog Decommissioning and Rehabilitation Plan 2022

Begnagh Bog, southeast of Cloondara, Longford

The bog is part of the Mount Dillon bog group

Area: 265ha

Begnagh has a pumped drainage regime

Begnagh bog is drained by the Fallan River which flows northward along the eastern site boundary. This river is a tributary of the Camlin River which in turn discharges into the River Shannon (Upper). The Royal Canal is located adjacent to part of the western boundary of Begnagh.

Begnagh bog has 5 treated surface water outlets to the Fallon River IE_SH_26F010200 FALLAN_020. The Fallon river flows to the Camlin River (IE_SH_26S021600 SHANNON (Upper)_090). While the Fallan is not at Risk or under pressure from peat extraction, the Shannon Upper was indicated as being under pressure from peat extraction in the second cycle of the river basin management plan and is indicated as remaining so in the third cycle, currently under preparation.

Derryfadda Bog, Co. Galway: Decommissioning and Rehabilitation Plan

Derryfadda Bog, Co. Galway, bordering Co. Roscommon, is part of the Derryfadda Bog group

Only a small portion of the whole Derryfadda Bog will be subject to the proposed decommissioning
and rehabilitation. The majority of Derryfadda Bog has been constrained out of the proposed decommissioning and rehabilitation due to alternative future land uses by Bord na Móna.

Bord na Móna are reviewing the potential to develop a potential renewable energy project at Derryfadda Bog. It is expected that this review will be completed in 1-2 years. In advance of this review of renewable energy potential, it is proposed to rehabilitate part of Derryfadda Bog in 2022-2024 that is not constrained

Any consideration of any other future after-uses for Derryfadda Bog, such as renewable energy, will be conducted in adherence to the relevant planning guidelines and consultation with relevant authorities and will be considered within the framework of this rehabilitation plan.

Some areas within and adjacent to the centre of the site (mostly outside of the BnM ownership boundary) are actively used for the production of domestic turf. Some small areas of plantation forestry also occur in the wider area, outside the west of the site.

Derryfadda bog is drained by the River Suck, located adjacent to the east of the site boundary.

Some small areas of turbary and former licenced plots also occur within the site boundary, notably within the centre of the site along an existing access road.

This bog is a pumped bog with the water table lower than the surrounding area.

Derryfadda/Killaderry bog has 16 treated surface water outlets to the River Suck. There are 7 direct to the River Suck (IE_SH_26S071200 SUCK_130), 5 to the Killaderry Stream (IE_SH_26K050940) and the balance of 4 to the Lughanagh Stream (IE_SH_26L530780).

Bloomhill Bog, Co. Offaly and Co. Westmeath: Cutaway Bog Decommissioning and Rehabilitation Plan – Screening for Appropriate Assessment and Natura Impact Statement

09.03.2022

Bord na Móna operates under IPC Licence issued and administered by the EPA to extract peat within the Blackwater bog group (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. Bloomhill bog is part of the Blackwater bog group. Bloomhill Bog straddles the Co. Offaly and Co. Westmeath border

Bloomhill Bog is located approximately 4km south-west of Ballynahown in County Offaly. Bloomhill Bog surrounds a large mineral island also known as Bloomhill. The mineral island is made up primarily of agricultural lands and residential lands.

Some surrounding areas utilised for domestic turf-cutting

The total area of Bloomhill Bog is 765ha of which 438.23ha or 57.28% of the present Landcover (2021) has been allocated enhanced rehabilitation measures

Bloomhill Bog has been in peat production since the early 1980’s. The peat was primarily harvested for fuel peat to be used in Cloghan Power Station, Derrinlough Brickette Factory and West Offaly Power in Shannonbridge, Offaly. The bog still retains deep peat reserves in some places. The site is dominated by bare peat former production bog land.

Bloomhill bog has 12 treated surface water outlets to the receiving waters. There is one to the IE_SH_26S021800 SHANNON (Upper)_120 (River Shannon), 3 treated outlets to the IE_SH_26B071200 BOOR_020 (Boor River) direct and the balance of 8 treated outlets to the IE_SH_26S021800 SHANNON (Upper)_120 (Curraghboy River). These watercourses provide connectivity to the River Shannon which is designated as part of the Middle Shannon Callows SPA (004096) and River Shannon Callows SAC (000216)

Peat extraction through turbary occurs around the northern margins of Bloomhill Bog and Mongan Bog to the south-west and at other locations within 15km.

Licensed turbary occurs at various locations within 15km of Bloomhill Bog, including several locations where the pathways for downstream in combination effects on European Sites may exist, primarily via drainage to EPA blue line watercourses to facilitate turbary. Unauthorised private turbary also occurs in discrete localised plots within the larger cutover raised bog complexes located to the south of Bloomhill Bog.

Bloomhill Bog has a pumped drainage regime.

Bord na Móna are reviewing the potential to develop a potential renewable energy project at Bloomhill Bog. It is expected that this review will be completed in 1-2 years. In advance of this review of renewable energy potential, it is planned to rehabilitate part of Bloomhill Bog in 2022-2024 that is not constrained

Parts of Bloomhill Bog (outside the areas owned and under the control of Bord na Móna) are currently used by domestic turf cutters to harvest peat. These areas are ecologically and hydrologically linked to the area owned by Bord na Móna where rehabilitation is planned. Nevertheless, Bord na Móna are aware of such issues which may constrain the proposed rehabilitation actions, and this rehabilitation plan considered potential impacts of these on the delivery of the stated objective.

Bord na Móna remain committed to rehabilitating all of Bloomhill Bog and to meeting IPC Licence conditions for this bog. The remaining area will be rehabilitated after the renewable energy review is complete. The peatland rehabilitation of the remaining area will either be in association with a potential renewable energy project, with peatland rehabilitation integrated into the proposed project, or will be completed in the future in the absence of any proposed renewable energy project.

Bunahinly-Kilgarvan Bogs, Co. Westmeath: Cutaway Bog Decommissioning and Rehabilitation Plan – Screening for Appropriate Assessment & Natura Impact Statement

25.02.2022

Bunahinly-Kilgarvan Bog comprises 394Ha in total.

Bord na Móna operates under IPC Licence issued and administered by the EPA to extract peat within the Blackwater bog group (Ref. P0502-01)

The Scheme will go beyond what is required to meet rehabilitation obligations under existing EPA IPC licence conditions.


Decommissioning seeks to address condition 10.1 of license Ref. PO502-01, which requires the following:

10.1 Following termination of use or involvement of all or part of the site in the licensed activity, the licensee shall:

10.1.1 Decommission, render safe or remove for disposal/recovery, any soil, subsoils, buildings, plant or equipment, or any waste, materials or substances or other matter contained therein or thereon, that may result in environmental pollution.

Decommissioning must take place at each bog prior to or concurrent with rehabilitation – the scale of decommissioning per bog varies dependant on the items/ infrastructure previously in place to facilitate prior peat extraction.

Rehabilitation seeks to address the requirements of Condition 10.2 of IPC License Ref. PO502-01, and is based on a reference document prepared by BNM per Bog for which the IPC license is applicable. See the following extract from IPC License Ref. PO502-01:

“The licensee shall prepare, to the satisfaction of the Agency, a fully detailed and costed plan for permanent rehabilitation of the cutaway boglands within the licensed area.”

Bunahinly-Kilgarvan Bog was drained and developed for industrial peat production in from the 1990’s. Industrial peat production ceased in 2018. The primary rehabilitation goal and outcome for Bunahinly-Kilgarvan Bog is environmental stabilisation of the bog.

Enhanced decommissioning as part of the PCAS will enhance the future after use of the bog for amenity value, security against access for illegal and unsocial activities and general State and community benefit.

The streams that flow through the site have been canalised

The total area of Bunahinly-Kilgarvan Bog is 394Ha of which 393.12ha or 99.78% of the present Landcover (2021) has been allocated enhanced rehabilitation measures.

Bunahinly-Kilgarvan has a pumped drainage regime

Bunahinly bog has three treated surface water outlets, two to the Shannon Upper tributary IE_SH_26S021800, and one direct to the Shannon (Upper)_120. Kilgarvan Bog also has three treated surface water outlets, two to the same Shannon (Upper)_120 tributary as Bunahinly Bog and the remaining one to the IE_SH_26B071200 BOOR_020 (Boor River)

Both the Shannon Upper tributary and the Boor River body are currently classified as At Risk and listed as being under pressure from peat extraction in the third cycle of the river basin management plan, currently under preparation.

Peat extraction through turbary occurs around the margins of Bloomhill Bog to the south and Mongan Bog to the south-west and at other locations within 15km.

Licensed turbary occurs at various locations within 15km of Bunahinly-Kilgarvan Bog, including several locations where the pathways for downstream in combination effects on European Sites may exist, primarily via drainage to EPA blue line watercourses to facilitate turbary. Unauthorised private turbary also occurs in discrete localised plots within the larger cutover raised bog complexes located to the south of Bunahinly-Kilgarvan Bog