Newcastle and Kilcoole Waste Water Treatment Plants Habitats Directive Assessment. January 2010 FINAL REPORT

Transcription

1 Newcastle and Kilcoole Waste Water Treatment Plants Habitats Directive Assessment January 2010 FINAL REPORT

2 NATURA ENVIRONMENTAL CONSULTANTS FINAL REPORT TABLE OF CONTENTS 1 INTRODUCTION REGULATORY CONTEXT METHODOLOGY RESULTS OF HABITATS DIRECTIVE ASSESSMENT CONCLUSION REFERENCES...3 APPENDIX 1: Screening Matrix

3 1 INTRODUCTION 1.1 Background NATURA Environmental Consultants Ltd. was commissioned by Wicklow County Council to prepare a Habitats Directive Assessment (HDA) otherwise known as an Appropriate Assessment for the existing waste water treatment plants at Kilcoole and Newcastle in County Wicklow. An application for a Wastewater Discharge Licence for the existing treatment works was submitted to the EPA by Wicklow County Council in accordance with the Waste Water Discharge (Authorisation) Regulations 2007 (SI 864 of 2007). Section F of the waste water discharge licence application requires an assessment of the impacts of discharges on the existing environment and requires that Initial Screening be carried out in accordance with Appendix 1 of the Circular L8/08 entitled Water Services Investment and Rural Water Programmes Protection of Natural Heritage and National Monuments issues by the Department of the Environment, Heritage and Local Government (DoEHLG) in As part of a request for additional information Wicklow County Council was asked to supply an appropriate assessment of potential impacts to protected areas. The purpose of this report is to determine the effects, if any, of the existing WWTPs at Kilcoole and Newcastle on the Murrough Wetlands csac/spa and to further assess if any of the predicted impacts have the potential to have significant negative impacts on the qualifying interests or on the conservation objectives of these designated areas for nature conservation. 2 REGULATORY CONTEXT The Habitats Directive (Council Directive 92/43/EEC on the Conservation of Natural Habitats and of Wild Fauna and Flora) formed a basis for the designation of Special Areas of Conservation (SACs). Similarly, Special Protection Areas are legislated for under the Birds Directive (Council Directive 79/409/EEC on the Conservation of Wild Birds). Collectively, SACs and SPAs are referred to as Natura 2000 sites. In general terms, they are considered to be of exceptional importance in terms of rare, endangered or vulnerable habitats and species within the European Community. Under Article 6(3) of the Habitats Directive an Appropriate Assessment must be undertaken for any plan or program that is likely to have a significant effect on the conservation objectives of a Natura 2000 site. An Appropriate Assessment is an evaluation of the potential impacts of a plan on the conservation objectives of a Natura 2000 site, and the development, where necessary, of mitigation or avoidance measures to preclude negative effects. Article 6, paragraphs 3 of the Habitats Directive state that: Any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subject to appropriate assessment of its implications for the site in view of the site's conservation objectives. In the light of the conclusions of the assessment of the implications for the site and subject to the provisions of paragraph 4, the competent national authorities shall agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the site concerned and, if appropriate, after having obtained the opinion of the general public. The statutory agency responsible for Natura 2000 sites is the National Parks and Wildlife Service of the Department of Environment, Heritage and Local Government. The European Court of Justice has recently (December ) issued a judgment in a legal case against Ireland that found that Ireland has failed in its statutory duty to confer adequate protection on designated areas. Following on from this the Circular Letter 1/08 & NPWS 1/08 on Appropriate Assessment of Land Use Plans (from the Department of the Environment, Heritage and Local Government) states that all plans and projects will be subject to critical assessment to ensure that they comply with all relevant legislation. The Stages in an Appropriate Assessment There are 4 stages in an Appropriate Assessment as outlined in the European Commission Guidance document (2001). The following is a brief summary of these steps

4 Stage 1 - Screening: This stage examines the likely effects of a project either alone or in combination with other projects upon a Natura 2000 Site and considers whether it can be objectively concluded that these effects will not be significant Stage 2 - Appropriate Assessment: In this stage, the impact of the project on the integrity of the Natura 2000 site is considered with respect to the conservation objectives of the site and to its structure and function. Stage 3 - Assessment of Alternative Solutions: Should the Appropriate Assessment determine that adverse impacts are likely upon a Natura 2000 site, this stage examines alternative ways of implementing the project that, where possible, avoid these adverse impacts. Stage 4 - Assessment where no alternative solutions exist and where adverse impacts remain: Where imperative reasons of overriding public interest (IROPI) exist, an assessment to consider whether compensatory measures will or will not effectively offset the damage to the Natura site will be necessary. 3 METHODOLOGY 3.1 Desk study and consultations A desk study was carried out to collate the available information on the ecological environment. The Environmental Protection Agency website ( was reviewed for water quality rating at sampling points upstream and downstream of the wastewater treatment plant. The National Parks and Wildlife Service (NPWS) database was consulted concerning designated conservation areas and records of rare and protected plant and animal species in the vicinity of the existing WWTPs. The Development Applications Unit (DAU) of the NPWS was also consulted. The Eastern Regional Fisheries Board (ERFB) was consulted in relation to the fisheries potential of receiving waters and asked to comment on any existing issues in relation to the existing WWTP. This assessment was carried out with reference to the relevant guidance, in particular: Assessment of Plans and Projects significantly affecting Natura 2000 Sites: Methodological guidance on the provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC, European Commission 2001 Managing Natura 2000 Sites: The Provisions of Article 6 of the Habitats Directive 92/43/EEC, European Commission, 2000 Circular L8/08 Water Services Investment and Rural Water Programmes Protection of Natural Heritage and National Monuments. 2 September Appropriate Assessment of Plans and Projects in Ireland: Guidance for Planning Authorities. National Parks and Wildlife Service, Department of the Environment, Heritage and Local Government. Dublin. 4 RESULTS OF HABITATS DIRECTIVE ASSESSMENT See Appendix 1 for the results of Stage 1 - Screening Matrix. 5 CONCLUSION Treated effluent discharging from both Kilcoole and Newcastle WWTPs is in compliance with current regulations. Sampling results 30m downstream of the Kilcoole WWTP primary discharge point show that the levels of BOD, ammonium and phosphorous in the receiving waters of the Knickitty River are in exceedance of the stringent limits set in the Surface Water Regulations (S.I. No. 272/2009). Levels of BOD and phosphorus in the Knickitty River are in exceedance of these limits upstream of the treatment plant indicating that there are other factors influencing the quality of water in the river, including discharges from the smaller Kilpedder WWTP upstream. Sampling results 25m downstream of the Newcastle WWTP primary discharge point show that levels of ammonia and phosphorous are in exceedance of the Surface Water Regulations by nearly twice the limit. The main reason for the excess nutrient levels is most likely due to the assimilative capacity of the receiving waters of the Knickitty and Newcastle Rivers, which - 2 -

5 may not be adequate at times (ERFB Consultation 2009). Nutrient levels will decrease due to dilution further downstream of the discharge point. Despite the current levels of nutrients in the receiving waters results from the screening matrix in Appendix I show that neither Kilcoole nor Newcastle WWTPs are having significant negative impacts on the qualifying interests of the Murrough csac and SPA (see Appendix I). The Knickitty River, into which the Kilcoole WWTP discharges, passes along the boundary of the csac before entering the Kilcoole Marshes and eventually the sea. The river is not impacting on any Annex I habitats within the csac boundary. The Newcastle River reaches the boundary of the Murrough csac approx. 1.4km downstream of the Newcastle WWTP. The Newcastle River flows through an area within the csac boundary know as Blackditch south of Sea Road, this area comprises mostly flooded wet grassland but also contains areas of Annex I habitat fen. The levels of ammonium (NH4) and phosphorous (P) found in fen habitat is between mg/L for NH4 and mg/L for P. The levels of these nutrients within the Newcastle River at the sampling point 1.4km upstream were similar with phosphorous levels slightly higher at 0.125mg/L. Ammonium levels were 0.068mg/L. The concentration of these nutrients would also decrease by the time the river reaches the csac boundary. At the present concentrations it is assumed that the discharge from Newcastle WWTP is not having a negative impact on the annex I fen habitat. From Blackditch the river flows through agricultural and wet grassland and some areas of reed swamp before entering the Kilcoole Marshes and discharging to the sea via the Breaches. There are no significant negative impacts to the qualifying interests of the Murrough csac as a result of the discharge from the Newcastle WWTP. The levels of nutrients entering the Kilcoole Marshes, a feeding area for a number of the birds species for which the SPA was designated, are believe not to be substantial enough to have a significant impact on fish and invertebrates on which some of the birds feed. Nearly all of the bird species listed under the conservation objectives of the SPA have been noted feeding on a number of coastal habitats, including the open sea and wet grassland areas showing that they are not restricted to feeding with the Kilcoole Marshes. It is concluded that there are no significant impacts on the qualifying interests of the designated sites or the integrity of the sites arising from the discharges from the existing WWTP developments at Kilcoole and Newcastle. Therefore a Stage 2 appropriate assessment is not required. 6 REFERENCES Curtis, T., Downes, S. and Ni Chathain B. (2009) The ecological requirements of waterdependent habitats and species designated under the habitats directive. Biology and Environment: Proceedings of the Royal Irish Academy, Vo. 109B, No. 3, Deegan, L. A., Bowen, J. L., Drake, D., Fleeger, J. W., Friedrichs, C.T., Galván, K. A., Hobbie, J.E., Hopkinson, C., Johnson, D.S., Johnson, J.M., LeMay, L.E., Miller, E., Peterson, B.J., Picard, C., Sheldon, S., Sutherland, M., Vallino, J., Warren, R. (2007) Susceptibility of salt marshes to nutrient enrichment and predator removal. Ecological Applications: Vol. 17, Supplement: Eutrophication, pp. S42-S63. DoEHLG (2008) Circular L8/08 Water Services Investment and Rural Water Programmes Protection of Natural Heritage and National Monuments. Department of the Environment, Heritage and Local Government, Dublin. European Commission (2001) Assessment of Plans and Projects significantly affecting Natura 2000 Sites: Methodological guidance on the provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC. European Commission (2000) Managing Natura 2000 Sites: The Provisions of Article 6 of the Habitats Directive 92/43/EEC. European Union Habitats Directive, (1992). Council Directives 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and flora

6 European Union Birds Directive (1979) Council Directive 79/209/EEC of 2 April 1979 on the conservation of wild birds. Brussels: The Council of the European Communities. Phalan, B The diet and early growth of Little Terns (Sterna albifrons) at Kilcoole, Co. Wicklow in BirdWatch Ireland Conservation Report No. 00/1 NPWS (2009) Appropriate Assessment of Plans and Projects in Ireland: Guidance for Planning Authorities. National Parks and Wildlife Service, Department of the Environment, Heritage and Local Government. Dublin. S.I. No. 254 of Urban Waste Water Treatment Regulations. Published by the Government Supplies Agency, Dublin. S.I. No. 864 of Waste Water Discharge (Authorisation) Regulations. Published by the Government Supplies Agency, Dublin. S.I. No. 12 of Water Quality (Dangerous Substances) Regulations. Published by the Government Supplies Agency, Dublin. S.I. No. 272/ Environmental Objectives (Surface Water) Regulations. Published by the Government Supplies Agency, Dublin

7 APPENDIX 1: SCREENING MATRIX Stage 1. Screening 1. Description of the project or plan Location The existing Waste Water Treatment Plants (WWTP) are located within the towns of Kilcoole and Newcastle in County Wicklow. Distance designated site from Brief Description of the project or plan Is the plan directly connected with or necessary to the Natura 2000 site management for nature conservation? The primary discharge point from the existing WWTP at Kilcoole is located 300m and 400m from the SPA and csac site boundaries respectively. The primary discharge point from the existing WWTP at Newcastle is located 600m and 1.4km from the SPA and csac site boundaries respectively. Kilcoole Waste Water Treatment Plant There is no development proposed at the WWTP at Kilcoole. The existing waste water treatment plant processes comprise preliminary, secondary and some tertiary treatment. Kilcoole WWTP was designed to treat a PE (Population Equivalent) of There is one primary point of discharge from the treatment plant SW1. Treated effluent discharges to the Knickitty River, which is not designated for nature conservation. The wastewater (influent, effluent and mixed liquor) and receiving water (upstream and downstream river samples) are sampled at designated sampling points. A storm water overflow (SWOP1) facility is used when flows exceed 4.3DWF (30l/s). Newcastle Waste Water Treatment Plant Newcastle WWTP is located on Sea Road. The treatment plant is designed to provide secondary treatment via an activated sludge, extended aeration process. The current capacity of the treatment plant is 1000 population equivalent (PE). Under normal working conditions Newcastle WWTP discharges all of its effluent through a single primary discharge point to the main channel of the Newcastle River. This river supports populations of resident Brown trout and migratory Sea trout (both Salmo trutta) and other fish species (ERFB consultation 2009). There are no storm water overflows built into the system. During storm conditions, the chamber housing the screen, floods. Flooding within the screen chamber is removed by sludge tanker to Enniskerry WWTP. The wastewater (influent, effluent and mixed liquor) and receiving water (upstream and downstream river samples) are sampled at designated sampling points along the Newcastle stream. No 2. Brief Description of the Natura 2000 sites Name The Murrough SPA (Site Code ) Site designation status Basis Natura 2000 Site description Special Protection Area (SPA) EU Birds Directive (79/409/EEC) The Murrough SPA comprises a coastal wetland complex that stretches for 13km from Kilcool Station, east of Kilcoole village in the north of Wicklow Town in the south, and extends inland for up to 1km in places. The site includes an area of marine water to a - 5 -

8 Unit size Condition Qualifying (Species) Interests Additional species of conservation interest: Qualifying (Habitats) Interests Conservation Objectives distance of 200m from the low water mark. The SPA is an important site for wintering waterbirds, being both internationally and nationally important for a number of bird species. It is probably the most important site in the country for nesting Little Tern, which breeds on the beach between Kilcoole and Newcastle within the SPA. The site is also of considerable importance for the wide range of coastal and freshwater habitats that it supports, including several that are listed on Annex I of the E.U. Habitats Directive. Approximately 931.3ha Recent farming and drainage practices and afforestation have greatly reduced the area and quality of the wetland habitats within the csac and SPA boundaries. The area between Kilcoole and Newcastle is particularly affected. Some levelling of the sand hills near Killoughter has also occurred. Pollution, reclamation and further drainage would adversely affect this site. Internationally important numbers of light-bellied brent geese Nationally important numbers of little tern The SPA is nationally important for red-throated diver, greylag goose, wigeon, teal, black-headed gull and herring gull. The rare bearded tit has been recorded breeding in the past. None To maintain the special conservation interests for this SPA at favourable conservation status: light-bellied brent goose, little tern, red-throated diver, greylag goose, wigeon, teal, black-headed gull and herring gull. Name The Murrough Wetlands SAC (Site Code ) Site designation status Basis Natura 2000 Site description Unit size Qualifying (Species) Interests Additional species of interest: Candidate Special Area of Conservation EU Habitats Directive (92/43/EEC) The Murrough Wetlands csac is a coastal wetland complex which stretches for 15km from Ballygannon to north of Wicklow Town, and in parts, extends inland for up to 1km. This site is of importance as it is the largest coastal wetland complex on the east coast of Ireland. The site contains a wide range of coastal and freshwater habitats including five listed on Annex I of the EU Habitats Directive. Areas within the site contain a rich invertebrate fauna, including several rarities. It is an important site for both wintering and breeding birds and supports a wide variety of species listed on Annex I of the EU Birds Directive. Approximately 606.0ha None The Irish Red Data Book species marsh pea (Lathyrus palustris) is found within the csac. The rare and legally protected oyster plant (Mertensia maritima) (Flora (Protection) Order, 1999) (RDB) has been recorded in the past but is now considered to be extinct. Fauna species of interest are: Otter (Annex II, Habitats Directive) - 6 -

9 Qualifying Interests (Habitats) Conservation Objectives Atlantic salt meadows (Glauco-Puccinellietalia maritimae) Annual vegetation of drift lines Perennial vegetation of stony banks Alkaline fens Mediterranean salt meadows (Juncetalia maritimi) Calcareous fens with Cladium mariscus and species of the Caricion davallianae Objective 1: To maintain the Annex I habitats for which the csac has been selected at favourable conservation status: Annual vegetation of drift lines; Perennial vegetation of stony banks; Atlantic salt meadows (Glauco-Puccinellietalia maritimae); Mediterranean salt meadows (Juncetalia maritimi); Calcareous fens with Cladium mariscus and species of the Caricion davallianae; Alkaline fens. Objective 2: To maintain the extent, species richness and biodiversity of the entire site. Objective 4: To establish effective liaison and cooperation with landowners, legal users and relevant authorities. 3. Describe the individual elements of the plan (either alone or in combination with other plans or projects) likely to give rise to impacts on the Natura 2000 sites. Kilcoole WWTP Data from 2009 sampling results show that the treated effluent from the Kilcoole WWTP is in compliance with concentration limits set for non sensitive waters as given by: S.I. No. 254/ Urban Waste Water Treatment Regulations Water quality sampling data from the Knickitty River in 2009 show that upstream of the primary discharge point BOD and phosphorous are in exceedance of the stringent limits set in S.I. No. 272/ Environmental Objectives (Surface Water) Regulations 30m downstream of the primary discharge point BOD, ammonia and phosphorous limits are all in exceedance of these limits. The assimilative capacity of the receiving waters of the Knickitty River may not be adequate at times due to, firstly, low flows during dry periods, and secondly, a smaller WWTP in Kilpedder discharges to this stream approximately 5km upstream. Newcastle WWTP Data from 2009 sampling results show that the treated effluent from the Kilcoole WWTP is in compliance with concentration limits set for non sensitive waters as given by: S.I. No. 254/ Urban Waste Water Treatment Regulations Water quality sampling data from the Newcastle River in 2009 show that upstream of the primary discharge point BOD, ammonia and phosphorous levels are all within the stringent limits set in S.I. No. 272/ Environmental Objectives (Surface Water) Regulations 25m downstream of the primary discharge point levels of ammonia and phosphorous are in exceedance of these limits by nearly twice the amount

10 4. Describe any likely direct, indirect or secondary impacts of the project (either alone or in combination with other plans or projects) on the Natura 2000 site by virtue of: Size and scale; Land-take; Distance from Natura 2000 site or key features of the site; Resource requirements; Emissions; Excavation requirements; Transportation requirements; Duration of construction, operation etc.; Others. 5. Describe any likely changes to the site arising as a result of: Reduction of habitat area; Disturbance of key species; Habitat or species fragmentation; Reduction in species density; Changes in key indicators of conservation value; Climate change. 6. Describe any likely impacts on the Natura 2000 site as a whole in Discharge of treated effluent from the WWTPs has resulted in a change in water quality in the Knickitty and Newcastle Rivers. These rivers pass through the Murrough csac and SPA before entering the sea through the Breaches. There is potential for the increase in nutrients within the receiving rivers to impact on the habitats and species for which the Murrough csac/spa has been designated. Of the six Annex I habitats for which the Murrough csac is designated calcareous and alkaline fens and salt marshes are the habitats most vulnerable to eutrophication. Eutrophication of water within the area known as Kilcoole Marshes could result in a change in invertebrate communities and plant growth (algal blooms), reduced levels of dissolved oxygen, increased biological oxygen demand and increased water temperature. Shallow sandy sediments within the Kilcoole Marshes provide a diverse macro-invertebrate community, which is a valuable source of food for wild birds and wintering water birds. Salt marsh and other estuarine habitats are also important nursery areas for fish, and feeding grounds for seabirds. Moderate increases in the availability of nutrients and organic matter in sediments could be of benefit to invertebrates and birds. Transitional waters such as those found in estuaries are usually nitrogen limited. Eutrophication of water dependent habitats could lead to a change in plant species composition. An increase in levels of nitrogen can lead to increased marsh grass production (primarily Spartina spp., cordgrass). High levels of nutrients can lead to increased algal growth on salt marshes (Deegan et al., 2007) 1. According to an EPA report Climate Change Scenarios and Impacts for Ireland Environmental RTDI Programme , a sea level rise of 0.5 metres is expected during the period , i.e. an average rise of 0.45 cm per year. This may gradually influence many coastal habitats. The Natura 2000 sites form part of the extensive coastal habitat along the Wicklow coastline. Water quality, tidal regime and salinity are the key environmental conditions that support the integrity of the sites. Interference or deterioration of any of these 1 Deegan, L. A., Bowen, J. L., Drake, D., Fleeger, J. W., Friedrichs, C.T., Galván, K. A., Hobbie, J.E., Hopkinson, C., Johnson, D.S., Johnson, J.M., LeMay, L.E., Miller, E., Peterson, B.J., Picard, C., Sheldon, S., Sutherland, M., Vallino, J., Warren, R. (2007) Susceptibility of salt marshes to nutrient enrichment and predator removal. Ecological Applications: Vol. 17, Supplement: Eutrophication, pp. S42-S

11 terms of: Interference with the key relationships that define the structure of the site; Interference with key relationships that define the function of the site. 7. Describe from the above those elements of the project or plan, or combination of elements, where the above impacts are likely to be significant or where the scale of magnitude of impacts is not known. factors could alter the structure and function of the sites and could potentially negatively impact on the habitats and species for which the sites are designated. A significant contamination event during the operation phases of the WWTP could result in a negative impact on structure and function of the Natura 2000 site. The Murrough csac The Knickitty River runs along the boundary of the Murrough csac approximately 400m downstream of the primary discharge point before entering the Kilcoole Marshes, where the estuarine water eventually enters the sea through an area known as the Breaches. No Annex I habitats for which the Murrough csac has been designated are impacted by the water from the Knickitty River. There are no significant negative impacts to the qualifying interests of the Murrough csac as a result of the discharge from the Kilcoole WWTP. The Newcastle River reaches the boundary of the Murrough csac approx. 1.4km downstream of the Newcastle WWTP. The Newcastle River flows through an area within the csac boundary know as Blackditch south of the Sea Road, this area comprises mostly flooded wet grassland but also contains areas of fen. The levels of ammonium (NH4) and phosphorous (P) found in alkaline fens is between mg/L for NH4 and mg/L for P (Curtis et al., 2009) 2. The levels of these nutrients within the Newcastle River at the sampling point 1.4km upstream were similar with phosphorous levels slightly higher at 0.125mg/L. Ammonium levels were The concentration of these nutrients would also decrease by the time the river reaches the csac boundary. At the present concentrations it is assumed that the discharge from Newcastle WWTP is not having a negative impact on the annex I fen habitat. From Blackditch the river flows through agricultural and wet grassland and some areas of reed swamp before entering the Kilcoole Marshes and discharging to the sea via the Breaches. There are no significant negative impacts to the qualifying interests of the Murrough csac as a result of the discharge from the Newcastle WWTP. The Murrough SPA All of the bird species identified within the conservation objectives of the SPA are known to use a variety of coastal habitats. Many of the herbivorous species were recorded feeding on wet grassland areas within the Kilcoole Marshes and brent geese are known to feed on grassland areas, including playing fields. Much of the grassland surrounding the Marshes has been improved for agricultural purposes. An increase in nutrient levels in the receiving waters would not have a significant impact on grassland areas such as these. Gulls and terns feed within the brackish waters of the 2 Curtis, T., Downes, S. and Ni Chathain B. (2009) The ecological requirements of waterdependent habitats and species designated under the habitats directive. Biology and Environment: Proceedings of the Royal Irish Academy, Vo. 109B, No. 3,

12 lagoon/estuary but also in the open sea. The little tern, which is a qualifying interest of the site, has been monitored closely by BirdWatch Ireland at Kilcoole. A study of the diet of the little terns was undertaken in 1999 by (Phalan 2000) 3. This showed that terns feed their young on prey items which are caught both in the open sea and in the brackish water lagoons west of the railway at Kilcoole-Newcastle marshes. The main brackish water prey species of the little terns was common goby (Pomatomschistus microps). These comprised about half of the items brought to the young terns, although the common goby also occurs in the open marine environment. The terns are not dependent on the lagoons as they also feed in the open sea although it is likely that they feed preferentially in the lagoons when bad weather at sea prevents them foraging in the marine environment. Fish species, which form the prey items of many birds within the estuary, including the goby are likely to be sensitive to gross water pollution but are unlikely to be negatively affected by a moderate enrichment of freshwater entering their habitat, provided that this is flushed through the brackish water system and out to sea. This takes place at Kilcoole except for short periods in winter when the Breaches opening in the shingle beach is closed off by marine sediments. However, the beach is porous and water can pass through when levels are high. Therefore, under normal conditions, the waste water treatment works at Kilcoole and Newcastle, do not pose a threat to the qualifying interests or species of conservation interest within the Murrough SPA. 3 Phalan, B The diet and early growth of Little Terns (Sterna albifrons) at Kilcoole, Co. Wicklow in BirdWatch Ireland Conservation Report No. 00/1-10 -