Bord na Móna operates under IPC Licence issued and administered by the EPA to extract peat within the Kilberry Bog Group (Ref. P0506-01)
The Kilberry Bog Group IPC Licensed area is made up of five bog areas (Allen (Mouds), Gilltown, Kilberry, Prosperous and Ummeras) most of which were in active milled peat production up to 2019. These bogs primarily supplied horticultural peat with some fuel peat. Fuel peat was transported to other Bord na Móna facilities, depending on market demand. Bogs that have been in milled peat production for decades have been slowly becoming cutaway as horticultural peat is extracted from the individual bog areas.
Industrial peat production history varies across the Kilberry Bog group, so there is a wide range of residual peat depths present. The majority of the bogs have been in active peat production until recently and are bare peat, and a small proportion has become cutaway. Kilberry Bog has had a long peat production history that has focused on horticultural peat production. Cutaway areas where the more acidic horticultural peat has been harvested still have relatively deep peat reserves, as much of the fuel peat at this site has not been utilised. Ummeras and Mouds Bog both have areas where horticultural peat has been completely harvested and fuel peat was also harvested.
Prosperous and Gilltown have a much younger milled-peat production history and more acidic peat is still present in the upper levels of these sites. More acidic peat can lead to the development of Heather dominated communities in places or where it is wet, Sphagnum-rich vegetation (embryonic peat forming communities) can establish. Examples of these types of communities can be seen at Kilberry. The rehabilitation plan for the Kilberry Bog Group encompasses all areas involved in industrial peat production including milled peat production areas and associated facilities.
A breakdown of the component bog areas for the Kilberry Bog Group IPC License Ref. P0506-01 is outlined in Table Ap-2.
The material deposited here is typically silt pond screenings, degraded plastic wrap material and wood screenings.
The EPA noted that areas of the landfill deposits appear to have been recently opened and tracked through with possible more recent deposits of material.
The licensee has advised the EPA that the rehabilitation measures planned for the bogs under the P0499- 01 licence have been completed. The bogs under this licence are not currently part of the PCAS enhanced restoration rehabilitation scheme. In December 2018 the licensee submitted a draft rehabilitation plan for this licence to the EPA for consideration. This draft plan was not approved by the EPA.
Corrective action The licensee shall provide a site update to the EPA detailing the completion date of rehabilitation measures such as drain damming onsite. As required by Condition 10.2.2 a review of the rehabilitation plan shall be submitted to the EPA at least every two years. The licensee is referred to the EPA guidance on this matter. The review should include detail on the expected outcomes of rehabilitation, goals, key indicators and trending of monitoring data with a focus on environmental impact. The licensee shall also ensure that national legislation has been taken into account with regard to the rehabilitation measures undertaken.
Request: Any licensed or unlicensed peatland drainage schemes in operation at GPS location 53.63549108874079, -7.914128213534018, Folio No. LD18778F for 2019, 2020 and 2021, to include any Bord na Móna correspondence with local authority environmental staff, the Local Authority Waters Programme (LAWPRO), Environmental Protection Agency (EPA), Inland Fisheries Ireland or other environmental bodies, consultants or other contractors running drainage operations at this location.
ESB and Bord na Móna Powergen Limited (“BNM PGEN”) entered into a Co- Development Agreement (CDA) in August 2016 through which they intend to jointly develop, own and operate solar photovoltaic farms (solar farms) on up to 5000 acres of the BNM lands, with up to an aggregate generation capacity of 500 MW.
Sundew Solar was incorporated on the 12th April 2019 to develop, build and operate the portfolio of solar projects. Sundew Solar is a joint 50:50 venture company formed between BNM PGEN and ESB Wind Development Limited. Sundew Solar
The proposed renewable energy development will comprise of
(a) the construction and operation of 2 areas of solar photovoltaic arrays mounted on metal frames over an area of approximately 200ha, and having a maximum overall height of 3 metres over ground level.
(b) Internal solar farm underground cabling.
(c) 2 no. temporary construction compounds.
(d) recreation and amenity work, including looped walk (upgrade of existing tracks and provision of new tracks, car parking and vehicular access);
(e) 1 no. Battery Storage compound.
(f) upgrade of existing tracks and provision of new site access roads.
(g) site drainage.
(h) forestry felling and replanting.
(i) permanent signage; and
(j) all associated site development and ancillary works.
The proposed renewable energy development will have an operational life of 35 years from the date of commissioning.
The overall renewable energy project also includes the provision of a 110kV substation with associated electrical plant, welfare facilities, wastewater holding tank, security fencing, upgrade of existing tracks and provision of new site access roads, 110kV overhead line grid connection cabling with associated angle lattice masts and supporting polesets and all ancillary works
The project site is located in the townland of Timahoe, to the north of the Timahoe crossroads and 7 km south of Johnstown Bridge Co Kildare. The subject lands are referred to as the Timahoe North Bog. This land is a raised bog that forms part of Bord Na Mona (BNM) commercial bog at Timahoe. The site area of this bog is large at almost 8 km² (800 ha) in area.
The topography of the bog is saucer like with lands slightly elevated to the southwest and northeast and a large flat section in the middle generally at elevations below 80 m OD. The bog has large wide man-made drains running in a north-west – south-east longitudinal direction, spaced c. 250m apart and totalling 11 main (continuous) drains across the full width of the site. There are a number of other, similarly orientated, drains that are discontinued with standing water only. Two raised access tracks across the bog from the southwest to northeast are present which facilitated narrow gauge rail line access to the site during peat production. The bog is bounded to the northwest and north by a tributary of the Fear English River which flows northwards away from the site and joins the Kells Blackwater (Boyne River System). To the south the bog is bounded by open drains that form the Derrylea tributary which flows southeast away from the site past Doran Nurseries before heading northeast and north to join the Kells Blackwater.
Peat – Typically described as black and brown fibrous to amorphous peat. Peat thicknesses in the trial pits and window sampling carried out to date ranged from 0.0 to 3.5m.
Vegetation – Sections of the bog where Bord na Móna historically ceased production have started to revegetate with some areas of dense vegetation having become established.
Flooding – Sections of Timahoe North bog are subject to periodic flooding during the winter. Works in these areas should be completed during periods of dry weather and may need to be addressed as a priority area similar to those shown in drawings within Appendix A. Note that prioritised areas outlined within drawings must be completed first.
The Timahoe North Solar Farm site is regulated under the Environmental Protection Agency (EPA) Integrated Pollution Control (IPC) Licence No. P0503-01 (Bord na Móna Biomass Ltd.). Planning permission has been granted on appeal for Timahoe North Solar Farm by An Bord Pleanála (PL 305953).). Substation granted by ABP ( 303249). Bord na Móna have applied to the Department of Agriculture, Farm for a Tree Felling Licence.
The Contracting Entity, wishes to put a framework agreement in place with a number of logistic service providers for the provision of Road Bulk Transport Services.
Tender Description: Bord na Móna has significant road haulage requirements for bulk materials within its Peat and Horticulture businesses.
These materials currently include fuel peat, horticultural peat and various biomass materials, and are distributed to both internal and external customers.
Bord na Móna’s peat production bogs are widely spread across the Midlands of Ireland, supplying 1 power station, 1 briquette factories and a number of horticultural growing media facilities by both road and an internal rail network. The vast majority of road deliveries are carried out using “walking floor” trailers, on the basis of receiving site restrictions. Bord na Móna now wishes to invite suitably qualified transport companies to tender for the haulage of peat by road from and to multiple locations throughout the country.
Volumes and locations etc will be issued in stage 2 of this eTender.
I refer to the request you made under the European Communities (Access to Information on the Environment) Regulations 2007 to 2018 (S.I. No. 133 of 2007, S.I. No. 662 of 2011, S.I. 615 of 2014 and S.I. No. 309 of 2018) (hereafter referred to as the AIE Regulations) for access to information held by Bord na Móna Plc. relating to any licensed or unlicensed peatland drainage schemes in operation at GPS location 53.63549108874079, -7.914128213534018, Folio No. LD18778F for 2019, 2020 and 2021, to include any Bord na Móna correspondence with local authority environmental staff, the Local Authority Waters Programme (LAWPRO), Environmental Protection Agency (EPA), Inland Fisheries Ireland or other environmental bodies, consultants or other contractors running drainage operations at this location.
Summary of Decision
I have made a decision on your request. No records relevant to your request were located by Bord na Móna plc. I therefore refuse your request.
Insomuch as any records may potentially exist, they would be held by Bord na Móna Energy Limited. It is Bord na Móna Energy’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.
Right of review
Under Article 11 of the AIE Regulations you have a right to request an internal review of this decision. An internal review involves a complete reconsideration of the matter by a member of the staff of Bord na Móna plc, unconnected with the original decision, of the same or higher rank than the original decision-maker, who may affirm, vary or annul the original decision.
If you wish to request an internal review, you can do so in writing to InformationOfficer@bnm.ie, referring to this decision and quoting the AIE reference number. This request must be made within one month of the date of receipt of this decision. The decision of an internal review will be communicated to you within one month of receipt of your request for an internal review.
You can contact me at John.MacNamara@bnm.ie if I can assist you in any matter relating to your request.
AIE sent for Internal Review 22/12/21 on basis that BnM cannot circumvent environmental reporting obligations by setting up close companies (in this case, Bord na Mona Energy Ltd)
Pumping sites on a bog could mean that drainage operations are active
Mott MacDonald’s Remedial Environmental Impact Assessment Report highlighted a number of sites with drainage pumps
Example: Bellair North
During periods of heavy rainfall, when the pump P15-10 is pumping, flooding has occurred downstream of the silt pond that discharges through outfall SW37. Bord na Móna has mitigated this issue by switching off the pump in periods of wet weather and consequently flooding occurs to the production areas.
Example: Ballybeg
There are no historical records of any flooding events or any historical flooding of the site, however from local knowledge flooding of the peat production area has occurred where bog pumps have failed to operate or where pumps have not been able to meet the demands imposed by extreme rainfall events.
Example: Ticknevin
There are no historical records of any flooding events or any historical flooding of the site, however from local knowledge flooding of the peat production area has occurred in Ticknevin where existing surface water pumps have failed to operate, as well as more locally where drains have become blocked internally
Others
Glashabaun North
Codd South
Ballydermot South
Blackriver
Cuil na Gun
Milkernagh
Note: for this report the following were provided:
Hydrological features (drains, silt ponds, outfalls) provided by Bord na Móna.
Bord na Móna application to An Bord Pleanála for Substitute Consent under Section 177E (Application for Substitute Consent) of the Planning and Development Act 2000 (PDA 2000), as amended and under Part 19 of the Planning and Development Regulations, 2001 (as amended).
Substitute Consent is effectively a form of retrospective consent and is being applied for with the aim of regularising the planning status of historic peat extraction carried out by Bord na Móna on 41 individual bog units.
Bord na Móna’s peat extraction activities on the 41 individual bog units assessed for this report have been regulated by the Environmental Protection Agency (EPA) since 2000 under the Integrated Pollution Control (IPC) licencing regime, under Part IV of the Environmental Protection Agency Act 1992.
This application is for the bogs that are intended to be used by Bord na Móna in the future for peat production in line with our reduction in the extraction of peat from 6.5m tonnes in 2013 to 1.7m tonnes in 2019.
The bog units have supplied milled peat to West Offaly Power Station, Lough Ree Power Station, Edenderry Power Station, Derrinlough Briquette Factory and the now closed Littleton Briquette Factory. Milled peat and sod moss have also been supplied to the horticultural market.
Note from Report:
Data on quantities and uses of harvested peat was not available for each bog unit for the period 1985 – 1991 and was limited for the period 1992 to 2001 where horticultural peat was not included and limited for the period 1992 to 2012 where off-site usage destinations were not available.
A network of silt ponds exists across all BnM bogs. They are typically approximately 50 – 300m in length and 8m or 12m wide.
The silt ponds are all located hydraulically upgradient or before the outfall points. Silt ponds are generally excavated to a depth of 1.5 metres below the pipe invert level and they are cleaned twice a year.
Field drains have been installed at approximately 15 metre intervals across the bogs, the drains generally fall towards the headland which is located at both ends of each production field. This headland allows for the plant such as harrowers, millers or ridgers to turn from one field into the next field. The open drains are generally piped across the end of each production field to facilitate production plant and machinery to travel from field to field. The drainage network continues by either open channel or pipe to a silt pond or ponds prior to discharging to a local watercourse.
Drainage is by gravity flow where possible, however there are a number of pumping stations in some bogs, where required (due to low or absent flow gradients, i.e. water levels in surrounding watercourses are higher than those on the bogs), to drain the bogs.
In accordance with the existing Integrated Pollution Control licences, all drainage water from bog units in the licensed area is discharged via an appropriately designed silt pond treatment arrangement. The silt ponds serving operation bogs have been sized in accordance with a condition in the existing Integrated Pollution Control Licences which states:
Within three years of date of grant of this licence all existing silt ponds serving operational bogs shall achieve the following minimum performance criteria (flood periods excepted): Maximum flow velocity < 10 cms-1 Silt design capacity of lagoons, minimum 50m3 per nett ha of bog serviced
Silt ponds were generally designed and constructed with a width of 8 metres, however in some cases silt ponds are up to 12 metres in width. Silt ponds of 12m width are only provided in areas where access is available to both sides of the silt ponds for cleaning.
The length of the silt pond will vary depending on the capacity required (i.e. proportional to the area of catchment being drained). In some locations, baffles have been provided within the ponds to reduce the energy in the flow and elongate the pond thereby increasing residence time and aiding settlement.
Silt ponds are generally excavated to a depth of 1.5 metres below the pipe invert level, however in some locations, due to restricted space the silt pond depth is greater than this.
Flow velocity through the silt pond is generally controlled by inlet and outlet pipes at the silt ponds or up-stream of the silt pond. These pipes control the velocity of the flow into and out of the silt ponds so that the velocity within the silt pond itself is less than 0.1 m/sec.
Pipelines and pump capacities are assessed based on a run-off rate of 1.7 litres per second per hectare. This run-off rate is based on a report prepared by Bord na Móna in the 1980’s and the run-off equates to approximately 60% of 25mm of rainfall falling in 24 hours (these details are taken directly from Bord na Móna SWMPs for each Bog Group).
Pumping Stations As bogs have been developed and the draining of areas of bog by gravity is no longer feasible, pumps have been installed to drain part or all of the catchment. Bord na Móna have used Archimedean screw pumps for many years throughout their bogs and in recent years, submersible pumps have become more common. Pumps are usually installed on a duty/ standby basis with level sensors.
List of pumping stations on bogs (note this is not a list of all BnM bogs, it’s a list of the 41 submitted in EIA Report)
