Draft National Policy Framework on Alternative Fuels Infrastructure for Transport in Ireland. Natura Impact Statement

Transcription

1 Draft National Policy Framework on Alternative Fuels Infrastructure for Transport in Ireland Natura Impact Statement October 2016

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3 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport TABLE OF CONTENTS 1 INTRODUCTION LEGISLATIVE CONTEXT FOR APPROPRIATE ASSESSMENT PURPOSE OF THE AA PROCESS OVERLAP WITH THE STRATEGIC ENVIRONMENTAL ASSESSMENT OF THE AFF CONSULTATION WORK COMPLETED TO DATE BACKGROUND AND OVERVIEW OF THE AFF ALTERNATIVE FUELS DIRECTIVE WHAT IS AN ALTERNATIVE FUEL? REQUIREMENT FOR THE AFF VISION OF THE AFF APPROACH TO DEVELOPMENT OF THE AFF BARRIERS TO UPTAKE OF ALTERNATIVE FUELS ENERGY AND CLIMATE POLICY CONTENT OF THE AFF ASSESSMENT METHODOLOGY GUIDANCE DOCUMENTS ON AA GUIDING PRINCIPLES AND CASE LAW STAGES OF APPROPRIATE ASSESSMENT INFORMATION SOURCES CONSULTED IMPACT PREDICTION OVERVIEW OF THE RECEIVING ENVIRONMENT IDENTIFICATION OF EUROPEAN SITES CONSERVATION OBJECTIVES CONSERVATION STATUS OF EU PROTECTED HABITATS AND SPECIES EXISTING THREATS AND PRESSURES TO EU PROTECTED HABITATS AND SPECIES RELEVANT BIODIVERSITY POLICY STAGE 1 SCREENING FOR AA POTENTIAL FOR LIKELY SIGNIFICANT EFFECTS SCREENING FOR APPROPRIATE ASSESSMENT CONCLUSION STAGE 2 APPROPRIATE ASSESSMENT INTRODUCTION MDR1224Rp005F01 i

4 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport 6.2 APPROACH TO ASSESSMENT IMPACT PREDICTION ASSESSMENT OF EFFECTS ASSESSMENT OF IN COMBINATION EFFECTS WITH OTHER PLANS OR PROJECTS MITIGATION MEASURES CONSTRUCTION, UPGRADE AND/OR OPERATION OF ALTERNATIVE FUELS RE-FUELLING INFRASTRUCTURE LAND USE CHANGES AS A RESULT OF INDIRECTLY ENCOURAGING THE INCREASED USE OF ALTERNATIVE FUELS EMISSIONS TO AIR AS A RESULT OF INDIRECTLY ENCOURAGING THE INCREASED USE OF ALTERNATIVE FUELS 63 8 CONCLUSIONS NEXT STEPS REFERENCES APPENDICES Appendix A Consultation Responses AA Specific Appendix B Special Areas of Conservation (SACs) Republic of Ireland Appendix C Special Protection Areas (SPAs) Republic of Ireland Appendix D Special Areas of Conservation (SACs) Northern Ireland Appendix E Special Protection Areas (SPAs) Northern Ireland Appendix F Screening for Appropriate Assessment Appendix G EU Condition Assessment Appendix H Generic Threats and Pressures Considered Relevant to the AFF LIST OF FIGURES Figure 2.1 Context of the AFF Figure European Sites MDR1224Rp005F01 ii

5 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport LIST OF TABLES Table 1.1 Statutory Consultees for SEA... 3 Table 1.2 Details of Consultation Responses with Relevance to AA Received by DTTAS... 3 Table 2.1 Alternative Fuels, Infrastructure and Feedstocks... 6 Table 2.2 Content of the AFF Table 4.1 European Sites within the ZoI of the AFF Table 5.1 Potential Likely Significant Effects Electricity and Electric Vehicle Infrastructure Table 5.2 Potential Likely Significant Effects Hydrogen and Hydrogen Fuel Infrastructure Table 5.3 Potential Likely Significant Effects Biofuels and Associated Infrastructure Table 5.4 Potential Likely Significant Effects Synthetic and Paraffinic Fuels and Infrastructure Table 5.5 Potential Likely Significant Effects Natural gas Including Biomethane, in Gaseous Form (Compressed Natural Gas (CNG)) and in Liquefied Form (Liquefied Natural Gas (LNG)) and Associated Infrastructure Table 5.6 Potential Likely Significant Effects Liquefied Petroleum Gas and Refuelling Infrastructure Table 6.1 Main Ecological Impacts Associated with the AFF Table 6.2 Electricity Measures by end Table 6.3 Electricity Measures to be implemented by end Table 6.4 Electricity Measures to be considered by end of Table 6.5 Electricity Measures by end of Table 6.6 Natural Gas (CNG & LNG) Measures to be implemented by end Table 6.7 Natural Gas (CNG & LNG) Measures to be considered by end Table 6.8 Hydrogen Policy Measures by end Table 6.9 LPG Future Policy Measures to be considered by end Table 6.10 Synthetic and Paraffinic Fuels Policy Measures Table 6.11 Policy Measures to Support Move to Low Emissions Vehicles Table 6.12 Air Emission Characteristics for Alternative Fuels Table 6.13 Primary Fuel Inputs for Electricity Generation 2014 and EEA Tier 1 Emission Factor Table 6.14 Habitats experiencing a decline in biodiversity as a result of air pollution (Adapted from NRA, 2011) Table 6.15 Examples of habitat changes as a result of nitrogen deposition for some European ecosystems (summary, adapted from Nordin, et al., 2011) Table 6.16 In-Combination Impacts with Other Plans and Strategies Table 6.17 In-Combination with Environmental Legislation and Policy Table 7.1 AA Mitigation MDR1224Rp005F01 iii

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7 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport 1 INTRODUCTION The Department of Transport, Tourism and Sport (DTTAS) is currently preparing a National Policy Framework on Alternative Fuels Infrastructure for Transport (hereafter referred to as the AFF). This is in response to Council Directive 2014/94/EU on the deployment of alternatives fuels infrastructure which requires Member States to develop national policy frameworks for the market development of alternative fuels and related infrastructure. The preparation of the Natura Impact Statement (NIS) complies with the requirements of Article 6 of the Council Directive 92/43/EEC of 21 May 1992 on the Conservation of Natural Habitats and of Wild Fauna and Flora (as amended) (hereafter referred to as the Habitats Directive). This is transposed in Ireland principally through the Planning and Development Act 2000 (as amended) and the European Communities (Birds and Natural Habitats) Regulations 2011 (as amended). The NIS has been prepared by RPS on behalf of the DTTAS (the Competent Authority). The AFF is a national plan to ensure consistency across Europe on the development of alternative fuels infrastructure. Owing to this, the NIS is focussed at a national strategic level. 1.1 LEGISLATIVE CONTEXT FOR APPROPRIATE ASSESSMENT The Habitats Directive provides legal protection for habitats and species of European importance. Articles 3 to 9 provide the legislative means to protect habitats and species of Community interest through the establishment and conservation of an EU-wide network of sites known as the Natura 2000 network. These are Special Areas of Conservation (SACs) designated under the Habitats Directive and Special Protection Areas (SPAs) designated under the Conservation of Wild Birds Directive (79/409/ECC) as codified by Directive 2009/147/EC (hereafter referred to as the Birds Directive). Articles 6(3) and 6(4) of the Habitats Directive set out the decision-making tests for plans and projects likely to affect European Sites (Annex 1.1). Article 6(3) establishes the requirement for Appropriate Assessment (AA): Any plan or project not directly connected with or necessary to the management of the [European] site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subjected to appropriate assessment of its implications for the site in view of the site s conservation objectives. In 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. Article 6(4) states: If, in spite of a negative assessment of the implications for the [European] site and in the absence of alternative solutions, a plan or project must nevertheless be carried out for imperative reasons of overriding public interest, including those of a social or economic nature, Member States shall take all compensatory measures necessary to ensure that the overall MDR1224Rp005F01 1

8 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport coherence of Natura 2000 is protected. It shall inform the Commission of the compensatory measures adopted. The Habitats Directive has been transposed into Irish law by the Planning and Development Act 2000 (as amended) and the European Communities (Birds and Natural Habitats) Regulations 2011 (as amended). In the context of the AFF, the governing legislation is principally Article 27 of the Birds and Natural Habitats Regulations which sets out the duties of public authorities (in this case the DTTAS) relating to nature conservation; and Article 42 which addresses AA. If screening for AA determines the likelihood for significant effects on a European Site(s), in view of its conservation objectives, then AA must be carried out for the Plan, including the compilation of a NIS to inform the decision making. 1.2 PURPOSE OF THE AA PROCESS The overall purpose of the AA process is to ensure that the AFF does not result in any adverse effects on the integrity of any European Sites in view of its conservation objectives. This NIS has been prepared in support of the AA process having regard for the legislative requirements of EU and national law as outlined previously. The responsibility for carrying out the AA lies with the DTTAS. The NIS will inform the AA determination made by the DTTAS at the time of adoption of the AFF, and the AA decision will be published alongside the adopted AFF. 1.3 OVERLAP WITH THE STRATEGIC ENVIRONMENTAL ASSESSMENT OF THE AFF A Strategic Environmental Assessment (SEA) of the AFF is being carried out concurrently with the preparation of the NIS. The purpose of the SEA is to evaluate at an early stage, the range of environmental consequences that may occur as a result of implementing the AFF and to give interested parties an opportunity to comment upon the perceived or actual environmental impacts of the proposal. There is a degree of overlap between the requirements of the SEA and AA and in accordance with best practice, an integrated process of data sharing has been carried out, such as sharing of baseline data and mapping of European Sites, sharing of potential ecological effects of the AFF on European Sites and clarification on more technical aspects of the AFF. These processes together have informed and shaped the development of the AFF. It is also noted that there are issues relevant to the Habitats Directive that are not strictly related to AA, including Article 10 and 12 of the directive. In these cases, the issues have been brought forward to the biodiversity, flora and fauna section of the SEA and have been addressed in that context as part of the wider environmental assessments informing the AFF. 1.4 CONSULTATION From the outset, consultation is a mandatory requirement in the SEA process and responses often have specific guidance recognising the AA process. In line with the SEA Directive, specific environmental authorities (statutory consultees) were consulted in May 2016, see Table 1.1. It is noted that a number of these departments have recently changed name and some responsibilities MDR1224Rp005F01 2

9 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport have migrated between departments. Table 1.1 therefore also provides clarity on the name changes. The SEA legislation (S.I. 435 and S.I. 436 of 2004, as amended) has not been updated to reflect these recent departmental changes. Table 1.1 Statutory Consultees for SEA Statutory Consultees under National SEA Legislation Environmental Protection Agency (EPA) Department of the Environment, Community and Local Government (DECLG) Department of Arts, Heritage and the Gaeltacht (DAHG) Department of Communications, Energy and Natural Resources (DCENR) Department of Agriculture, Food and the Marine (DAFM) N/A Newly Named Departments Department of the Housing, Planning, Community and Local Government (DHPCLG) Department of Arts, Heritage, Regional, Rural and Gaeltacht Affairs (DAHRRGA) Department of Communications, Climate Action and the Environment (DCCAE) N/A In recognition of the potential for transboundary effects with Northern Ireland, through potential changes relating to air quality, the Northern Ireland Department of Agriculture, Environment and Rural Affairs (DAERA) with responsibility for SEA in Northern Ireland, was also consulted. A number of responses were received during the SEA Scoping phase including the following that had direct bearing upon the AA process. Summary details of these are presented in Table 1.2, while copies of these submissions are included for reference in Appendix A. Table 1.2 Details of Consultation Responses with Relevance to AA Received by DTTAS Consultee Date Summary of AA-specific issues raised DAFM 23 rd June 2016 DAERA (Northern Ireland) 21 st June 2016 EPA 4 th July 2016 Supplied a publication on forestry and biomass, and some background data on forestry biomass. Consideration of SACs and SPAs in Northern Ireland as part of the AA. Submission related specifically to SEA, however the broader response was also useful in informing for the AA process. In addition, an SEA scoping workshop was subsequently held in June 2016, with the AA team also in attendance. Representatives from all statutory consultees were invited to attend this workshop. EPA and the Department of Communications, Climate Action and the Environment (formerly the Department of Communications, Energy and Natural Resources) were represented on the day. All responses received as part of the consultation, as noted in Table 1.1, as well as comments received at the SEA Scoping workshop have been taken into account in the NIS. MDR1224Rp005F01 3

10 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport 1.5 WORK COMPLETED TO DATE Screening for AA of the AFF was compiled by RPS on behalf of the DTTAS in May It was submitted to the Development Applications Unit (DAU) of the DAHG (now the DAHRRGA) on 24 th May 2016, advising that the AFF was proceeding to AA and the production of an NIS (see Section 5 for a summary of the screening stage, while the full Screening for Appropriate Assessment report is included in Appendix F). MDR1224Rp005F01 4

11 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport 2 BACKGROUND AND OVERVIEW OF THE AFF 2.1 ALTERNATIVE FUELS DIRECTIVE As identified, the requirement for a plan for Alternative Fuels is derived from Directive 2014/94/EU. The directive addresses a situation where more than 90% of the energy used in transport within Europe is derived from crude oil, most of which is imported. In 2011, 84% of Europe s oil was imported, costing up to one billion euro per day 1. This supply depends, to a large degree, on politically unstable regions and, as such, raises security of supply concerns. For Ireland, oil dependency levels were the fourth highest in the EU in 2013, at 49% of all energy use and the cost of all energy imports for the same year was 6.7 billion. Of this approximately 3.5 billion was spent on transportation where oil was the dominant fuel. In 2014, 97% of energy used in the transport sector in Ireland was from oil based products. This near total dependence on a single fuel source is unique to the transport sector. The Commission has taken the view that a major obstacle to market uptake of alternative fuels was the slow establishment of supporting infrastructure, along with a lack of associated common technical standards across the EU. Therefore, Directive 2014/92/EC sets out common standards for future technical infrastructure specifications across Europe. As well as specific targets for regional infrastructural coverage, the Directive also includes timelines for implementation. It relies on the Trans-European Transport Network (TEN-T) in order to determine where alternative fuel infrastructure should be provided. This TEN-T includes a network of core corridors (including road, rail, air and water transport) in the European Union and it envisages coordinated improvements to key routes. Within Ireland, the North Sea-Mediterranean Corridor stretches from Belfast to the Irish ports of Cork and Dublin encompassing a number of existing road corridors:, M1, M50, M7, M8, the Cork to Belfast railway line, Dublin and Cork Airport and the ports of Dublin, Cork and Shannon-Foynes. In March 2010, the Commission established an Expert Group on Future Transport Fuels, with the objective of providing advice on specific actions aimed at the long term substitution of oil as a transport fuel. According to the report of the Expert Group 2, the following represents the main alternative fuels for propulsion in transport: Electricity/hydrogen, and biofuels (liquids) as the main options; Synthetic fuels as a technology bridge from fossil to biomass based fuels; Methane (natural gas and biomethane) as complementary fuel; and Liquefied Petroleum Gas (LPG) as supplement. 2.2 WHAT IS AN ALTERNATIVE FUEL? For the purposes of the directive alternative fuels means fuels or power sources which serve, at least partly, as a substitute for fossil oil sources in the energy supply to transport and which have the 1 Clean Power for Transport A European Alternative Fuel Strategy, COM(2013) 2 Report of the European Expert Group on Future Transport Fuels, January 2011 MDR1224Rp005F01 5

12 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport potential to contribute to its decarbonisation and enhance the environmental performance of the transport sector. They include, inter alia: electricity, hydrogen, biofuels as defined in point (i) of Article 2 of Directive 2009/28/EC, synthetic and paraffinic fuels, natural gas, including biomethane, in gaseous form (compressed natural gas (CNG)) and liquefied form (liquefied natural gas (LNG)), and liquefied petroleum gas (LPG). It is important to note that, as stated in the directive, alternative fuels are fuels/ power sources which serve, at least partly, as a substitute for fossil oil sources in the energy supply to transport. They have the potential to contribute to environmental performance and decarbonisation of the transport sector. Table 2.1 provides a summary of the possible feedstocks and the existing and required infrastructure (both for processing and for distribution) for the six alternative fuels. Table 2.1 Alternative Fuels, Infrastructure and Feedstocks Electricity Hydrogen Biofuels Alternative Fuel Infrastructure Feedstock Fossil fuels Synthetic & Paraffinic fuels Natural Gas (LNG and CNG) National Grid Network of city & town charging points Network of fast-charge points on intercity routes Processing facility to generate hydrogen from feedstock Processing facility to convert electricity to hydrogen Network of fuelling stations Liquid biofuel processing facilities Anaerobic digestion facilities Facility to upgrade biogas to biomethane Network of fuelling stations Processing facility to generate fuel from feedstock Network of fuelling stations Network of fuelling stations Biomass Wind Solar Hydroelectric Natural Gas Water Biomass Coal Pure plant oil Used cooking oil Animal By-products Cereal crops Biomass Natural Gas Coal Biomass Plastic waste Natural gas Liquid Petroleum Gas (LPG) Network of fuelling stations Natural Gas Petroleum 2.3 REQUIREMENT FOR THE AFF Directive 2014/92/EC seeks to ensure that member states develop a sustainable alternative fuels strategy, which would support the development of appropriate refuelling infrastructure and associated standards. The Directive requires Member States to develop national policy frameworks for the market development of alternative fuels and related infrastructure. MDR1224Rp005F01 6

13 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport The Department of Transport, Tourism and Sport (DTTAS) is currently preparing the AFF on behalf of the Minister in response to this requirement. As part of the preparation of the AFF, a working group has been established to oversee its development. The working group is comprised of expertise from within both the DTTAS and the divisions of Energy Security, Energy Regulation and Renewables. The AFF contains defined targets and objectives for the deployment of alternative fuels infrastructure in order to support a range of fuels. In tandem with the development of a policy framework, the DTTAS are developing national regulations that will transpose Directive 2014/94/EU on the deployment of alternatives fuels infrastructure into Irish law. The transposition of this Directive must be completed by Ireland and the other Member States by the 18 th November VISION OF THE AFF Ireland has expressed its intention, through national policy position, that it will transition to a low carbon economy by The 2015 White Paper on energy policy has outlined the same commitment for the energy sector whilst Smarter Travel ( ) sets policy commitments for a low carbon transport sector. Reducing reliance on fossil fuels and switching to the use of alternatives will be an integral part of the transport sectors efforts to decarbonise and this will be reflected both in the AFF and in the forthcoming National (Climate) Mitigation Plan. The AFF represents a first step in communicating a longer term vision for transport to Whilst the National (Climate) Mitigation Plan will deal with a multi-faceted set of measures to decarbonise transport, the AFF will focus exclusively on reducing Ireland s dependency on oil through the provision of infrastructure as well as through incentives to support the use of that infrastructure. Targets for infrastructure have been underpinned by assumptions on vehicle uptake, through the use of fleet modelling and investment capacity scenarios. The overall ambition for the transport sector is to transition away from fossil fuels over the next two decades, moving predominantly to electricity for passenger cars, commuter rail and taxis by Natural gas along with some electrification will provide an interim solution for larger vehicles i.e. freight and buses. Biofuels will continue to play a role over this period. Post 2030, it is likely that hydrogen will continue to increase its penetration across the entire fleet spectrum with a correlated decline in the predominance of vehicles run solely on fossil fuels (as stated in Chapter 2 of the AFF). While it is not possible to predict with complete accuracy the exact nature of the technologies that will be deployed, Ireland s ambition is for all new cars and vans sold in Ireland from 2030 to be zero emission (or zero emission capable). The freight and bus sectors will continue on a positive trajectory towards full penetration of Low Emission Vehicles. 2.5 APPROACH TO DEVELOPMENT OF THE AFF The AFF has looked to European developments in order to contextualise any national strategy or framework, e.g. the EU wide consideration of the minimum coverage of refuelling structures for the main alternative fuels and how that will impact on a national strategy. The European alignment of policy and public/private funding and taxation in the areas of alternative fuel infrastructure has been considered in a national context. The AFF has considered the following key aspects in its development: MDR1224Rp005F01 7

14 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Assessment of EU Member States policy on Alternative Fuels Infrastructure and therefore alignment of the AFF to enable national compliance with European and international best practice. Identification and listing of most feasible alternative fuels for Ireland and hence the identification of any potential or possible deficits in the necessary infrastructures to support these fuels in Ireland. Scoping of possible opportunities for national network companies within the requirements of the Alternative Fuels Infrastructure, and hence identification of the opportunities and barriers associated with the infrastructure for the delivery of alternative fuels on a national scale. 2.6 BARRIERS TO UPTAKE OF ALTERNATIVE FUELS The DTTAS considers the development and use of alternative fuel is being held back by four main barriers: The high cost of vehicles, Limited choice in vehicles available to potential buyers; A low level of consumer acceptance of alternative fuels; and The lack of recharging and refuelling stations. DTTAS see these barriers as being mutually dependent. Investors can be reluctant to build infrastructure where a market is in its infancy. In the absence of appropriate levels of infrastructure to support the uptake of alternative fuels, it is unlikely that enough vehicles will be sold to assert the required downward pressure on market price. This generates unwillingness by consumers to buy alternative fuelled vehicles as the price of vehicles remains prohibitive. This lack of demand has an impact, in turn, on the numbers of vehicles being introduced to the market (thereby prohibiting choice to the consumer). Through Directive 2014/94/EU, the Commission is aiming to resolve this cycle of dependence through the introduction of binding targets on Member States for a minimum level of infrastructure for clean fuels such as electricity and natural gas, along with common EU wide standards for the equipment needed. 2.7 ENERGY AND CLIMATE POLICY Energy Policy While Europe has a focus on security of supply, there is also the parallel drive to increase the share of renewable energy in the energy supply mix across Member States. The 2009 Renewables Energy Directive set mandatory targets arising from an overall European target of 20% for all energy to come from renewable energy sources by 2020 (different targets set for each Member State in order to achieve the overall 20%). In line with the Renewable Energy Directive, Ireland is required to achieve 16% of gross final energy consumption from renewable sources by In order to contribute to this goal, Ireland s National Renewable Energy Action Plan proposes a renewable target for transport (known as the RES-T) of 10%. All Member States are required to achieve the same target in transport by Accordingly, the role for transport is very much prescribed. The Bioenergy Plan and the Renewable Electricity Policy and Development Framework which are both under development will contribute towards the goals outlined in the National Renewable Energy Action Plan. MDR1224Rp005F01 8

15 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport The primary mechanism for achieving the RES-T will be the Biofuel Obligation Scheme (BOS). The BOS was introduced with effect from 1 July 2010 and requires large suppliers of road transport fuels to include a certain percentage of biofuels across their fuel mix. The obligation rate rose to 6% in 2013 and a further increase to 8% from 1 January 2017 is anticipated. Electric vehicles (EVs) are not likely to impact on the RES-T, despite a Government target to achieve 50,000 EVs in the transport fleet by However, beyond 2020, the increased deployment of EVs will make a greater contribution towards future targets with a steady upward trend for penetration of renewable electricity in transport by Ireland s recent Energy White Paper 3 outlines that the transition to a Low Carbon Energy Future is a complete energy policy update. It states that a framework is required to guide policy and actions that Ireland intends to take in the energy sector from now up to It aims to transition to a low carbon energy system that will ensure secure energy supplies of competitive and affordable energy. It also states that a low carbon future will involve a number of factors including increasing the use of electricity and bioenergy to heat our homes and fuel our transport. At an EU level and hence subsequently at Member State level, there is a European Strategy on clean and energy efficient vehicles that began in Subsequently, there has been the promotion of clean and energy efficient mobility at EU and national level. Collectively there have been over 40 actions in the areas of legislation, research, standard development, for both conventional engine developments (e.g. CO 2 legislation, multi-fuel engines) as well as for ultra-low carbon electric vehicles and hydrogen fuels Climate Policy In order to limit the increase in global temperature, the EU has set an objective of reducing greenhouse gas emissions by 80-95% by 2050 compared to 1990 in developed countries as a whole. To ensure that Ireland can effectively and equitably contribute to the EU objective as part of joint global mitigation efforts, and for the purposes of compliance with EU law, a low-carbon development strategy is being developed for Ireland to cover the period to The extent of the challenge to reduce greenhouse gas emissions at a national level is well understood and reflected in both the National Policy Position on Climate Action and Low Carbon Development, which was published in April 2014, and the Climate Action and Low Carbon Development Act The National Policy Position, which commits the non-emission Trading Scheme (ETS) in Ireland to collectively reducing emissions by 80% by 2050, provides a high-level policy direction for the adoption and implementation by Government of plans to enable the State to move to a low carbon economy by The transport sector, as the second largest emitter in the non-ets, will have a significant role to play in meeting this policy objective. In order to respond to the climate challenge, changes in technology and travel behaviour will be required on a large scale throughout the transport system. The Climate Action and Low Carbon Development Act 2015 contains provisions relating to the development and approval of successive National Mitigation Plans. The Act creates a statutory 3 The White Paper, Ireland s Transition to a Low Carbon Energy Future DCENR ( ) MDR1224Rp005F01 9

16 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport obligation on a number of sectors, including transport, electricity generation, built environment and agriculture, to develop sectoral climate change mitigation measures for inclusion in these Plans Transport Policy The EU s White Paper on Transport committed to achieving the following key goals by 2050: No more conventionally-fuelled cars in cities; 40% use of sustainable low carbon fuels in aviation; at least 40% cut in shipping emissions; and A 60% cut in transport emissions by the middle of the century. The associated roadmap to the White Paper places a particular emphasis on urban transport and the need to support a shift to cleaner cars and cleaner fuels. It sets a goal of achieving a 50% shift away from conventionally fuelled cars by 2030 with a view to phasing them out in cities by It also seeks to achieve a target of CO 2 -free movement of goods in major urban centres by At a national level, the DTTAS s Smarter Travel policy to 2020 sets out clear goals to reduce reliance on fossil fuels and to reduce transport emissions. The policy gives clear signals that it will support alternative technologies as they develop and become commercially feasible. A commitment has been given to use alternative technologies in public vehicle fleets and to encourage the uptake of alternative fuels in the taxi and private bus/coach fleets. Figure 2.1 provides an overview of the key plans/ policy and legislation of relevance to the AFF. Chapter 6 of this NIS discusses these plans, programmes and policies and their relationship with the AFF. MDR1224Rp005F01 10

17 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Figure 2.1 Context of the AFF 2.8 CONTENT OF THE AFF This AFF sets targets to achieve an appropriate level of alternative fuels infrastructure for transport, which is relative to national policy and Irish market needs. Non-infrastructure based incentives to support the use of the infrastructure and the uptake of alternative fuels are also included within the AFF. The AFF is laid out in the following structure, as outlined in Table 2.2. Table 2.2 Content of the AFF Chapter No. Chapter 1 Chapter 2 Chapter 3 Chapter 4 Chapter 5 Chapter 6 Chapter 7 Chapter 8 Chapter 9 Chapter 10 Chapter 11 Chapter 12 Content Foreward: A note from the Minister for Transport. Executive Summary: Summary details on the National Policy Framework Alternative Fuels Infrastructure for Transport in Ireland Introduction: Outline of the reasons for developing the AFF and the relevant existing policies that will influence or be influenced upon by the AFF Strategic Environmental Assessment and Appropriate Assessment Assessment of the Current Usage of Alternative Fuels in the Transport Sector National Policy Forecasts and Alternative Fuel Options Targets for Alternative Fuel Infrastructure Measures Necessary to Ensure National Targets and Objectives are Reached Designation of Densely Populated Areas to be Equipped with Publicly Accessible Electric Charging Points and CNG Refuelling Points Summary of Implementation Plan Timeline (to be populated post public consultation) Review Provisions Appendices MDR1224Rp005F01 11

18 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport 3 ASSESSMENT METHODOLOGY 3.1 GUIDANCE DOCUMENTS ON AA The AA requirements of Article 6 of the Habitats Directive follow a sequential approach as outlined in the following legislation, guidance documents and Departmental Circulars, namely: European and National Legislation: Council Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora (also known as the Habitats Directive ); Council Directive 2009/147/EC on the conservation of wild birds, codified version, (also known as the Birds Directive ); European Communities (Birds and Natural Habitats) Regulations 2011 to 2015; and Planning and Development Act 2000 to Guidance: Appropriate Assessment of Plans and Projects in Ireland: Guidance for Planning Authorities. DEHLG (2009, revised 10/02/10); 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). Communication from the Commission on the Precautionary Principle. European Commission (2000b) EC study on evaluating and improving permitting procedures related to Natura 2000 requirements under Article 6.3 of the Habitats Directive 92/43/EEC. European Commission (2013). Guidance Document on Article 6(4) of the Habitats Directive 92/43/EEC. Clarification of the concepts of: Alternative Solutions, Imperative Reasons of Overriding Public Interest, Compensatory Measures, Overall Coherence, Opinion of the Commission. European Commission (2007). Managing Natura 2000 sites: the provisions of Article 6 of the Habitats Directive 92/43/EEC 4. European Commission (2000a). Marine Natura Impacts Statements in Irish Special Areas of Conservation. A working Document. DAHG (2012). Departmental/NPWS Circulars: Appropriate Assessment under Article 6 of the Habitats Directive: Guidance for Planning Authorities. Circular NPWS 1/10 and PSSP 2/10. Appropriate Assessment of Land Use Plans. Circular Letter SEA 1/08 & NPWS 1/08. 4 The Commission has notified its intent to revise this guidance and a draft revised document was published in April It would appear that this has not been finalised to date, and no revised guidance document is available on the Commissions official website as of September MDR1224Rp005F01 12

19 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Water Services Investment and Rural Water Programmes Protection of Natural Heritage and National Monuments. Circular L8/08. Guidance on Compliance with Regulation 23 of the Habitats Directive. Circular Letter NPWS 2/07. Compliance Conditions in respect of Developments requiring (1) Environmental Impact Assessment (EIA); or (2) having potential impacts on Natura 2000 sites. Circular Letter PD 2/07 and NPWS 1/ GUIDING PRINCIPLES AND CASE LAW Over time legal interpretation has been sought on the practical application of the legislation concerning AA as some terminology has been found to be unclear. European and National case law has clarified a number of issues and some aspects of the published guidance documents have been superseded by case law. Case law has been considered in the preparation of both the Screening and NIS of the AFF. 3.3 STAGES OF APPROPRIATE ASSESSMENT The AA process progresses through four stages. If at any stage in the process it is determined that there will be no adverse effect on the integrity of a European Site in view of the sites conservation objectives, the process is effectively completed. The four stages are as follows: Stage 1 Screening of the proposed plan or project for AA; Stage 2 An AA of the proposed plan or project; Stage 3 Assessment of alternative solutions; and Stage 4 Imperative Reasons of Overriding Public Interest (IROPI)/ Derogation. Stage 1: Screening for AA The aim of screening is to assess firstly if the plan or project is directly connected with or necessary to the management of European Site(s); or in view of best scientific knowledge, if the plan or project, individually or in combination with other plans or projects, is likely to have a significant effect on a European site. This is done by examining the proposed plan or project and the conservation objectives of any European Sites that might potentially be affected. If screening determines that there is potential for significant effects or there is uncertainty regarding the significance of effects then it will be recommended that the plan is brought forward to the next stage of the AA process. Screening of the AFF was undertaken in May 2016 and it was determined that AA was required. Stage 2: Appropriate Assessment The aim of Stage 2 of the AA process is to identify any adverse impacts that the plan or project might have on the integrity of relevant European Sites. As part of the assessment, a key consideration is in combination effects with other plans or projects. Where adverse impacts are identified, mitigation measures can be proposed that would avoid, reduce or remedy any such negative impacts and the plan or project should then be amended accordingly, thereby avoiding the need to progress to Stage MDR1224Rp005F01 13

20 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport 3. As part of this stage an NIS is prepared to support decision making. This document is the NIS for the AFF. Stage 3: Alternative Solutions If it is not possible during Stage 2 of the AA process to conclude that there will be no adverse effects on site integrity, Stage 3 of the process must be undertaken which is to objectively assess whether alternative solutions exist by which the objectives of the plan or project can be achieved. Explicitly, this means alternative solutions that do not have adverse impacts on the integrity of a European Site. It should also be noted that EU guidance on this stage of the process states that, other assessment criteria, such as economic criteria, cannot be seen as overruling ecological criteria (EC, 2001). In other words, if alternative solutions exist that do not have adverse impacts on European Sites; they should be adopted regardless of economic considerations. This stage of the AA process should result in the identification of the least damaging options for the plan or project. Stage 4: Imperative Reasons of Overriding Public Interest (IROPI) This stage of the AA process is undertaken when it has been determined that a plan or project will have adverse effects on the integrity of a European Site, but that no alternatives exist. At this stage of the AA process, it is the characteristics of the plan or project itself that will determine whether or not the competent authority can allow it to progress. This is the determination of over-riding public interest. It is important to note that in the case of European Sites that include in their qualifying features priority habitats or species, as defined in Annex I and II of the Directive, the demonstration of overriding public interest is not sufficient and it must be demonstrated that the plan or project is necessary for human health or public safety considerations. Where plans or projects meet these criteria, they can be allowed, provided adequate compensatory measures are proposed. Stage 4 of the process defines and describes these compensation measures. 3.4 INFORMATION SOURCES CONSULTED The following general sources of information have been consulted for background environmental information. A detailed reference list can be found in Section 9. Information provided by DTTAS on the AFF; Department of Environment, Community and Local Government online land use mapping GeoHive online mapping Ordnance Survey of Ireland Online mapping and Aerial photography National Parks and Wildlife Service online European Site information Northern Ireland Environment Agency online European Site information National Parks and Wildlife Service Information on the status of EU protected habitats in Ireland (NPWS 2013a & 2013b); Ireland s Article 12 submission to the EU Commission on the Status and Trends of Bird Species ( ); Information on the conservation status of birds in Ireland (Colhoun & Cummins, 2013); MDR1224Rp005F01 14

21 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Environmental Protection Agency EnVision maps Information on River Basin Districts - Geological Survey of Ireland Geology, soils and hydrogeology Format for a Prioritised Action Framework (PAF) for Natura 2000 (DAHG, 2014) and Actions for Biodiversity : Irelands National Biodiversity Plan (DAHG, 2011). 3.5 IMPACT PREDICTION The methodology for the assessment of impacts is derived from the Assessment of Plans and Projects Significantly Affecting Natura 2000 Sites (EC, 2001). When describing changes/activities and impacts on ecosystem structure and function, the types of impacts that are commonly presented include: Direct and indirect effects; Short and long-term effects; Construction, operational and decommissioning effects; and Isolated, interactive and cumulative effects. A source pathway-receptor approach has been applied for this assessment. The source relates to the policy measures outlined in the AFF which have the potential to adversely impact European Sites e.g. infrastructural developments or generation/combustion of alternative fuels. The pathways by which AFF policy measures can impact European Sites include changes in land use, habitat loss/fragmentation, emissions to air and hydrological connections. The receptor in this instance is the Natura 2000 network, potentially including those transboundary sites for which there is a pathway of connectivity as a result of the implementation of the AFF. MDR1224Rp005F01 15

22 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport 4 OVERVIEW OF THE RECEIVING ENVIRONMENT Ireland has obligations under EU law to protect and conserve biodiversity. This relates to habitats and species both within and outside designated sites. Nationally, Ireland has developed a Biodiversity Plan (DAHG, 2011) to address issues and halt the loss of biodiversity, in line with international commitments. The overall target for Ireland s National Biodiversity Plan is that biodiversity loss and degradation are reduced by 2016 and progress is made towards substantial recovery by This follows on from the European Commission EU Biodiversity Strategy to 2020 which has a headline target to halt the loss of biodiversity and ecosystem services by 2020, to restore ecosystems in so far as is feasible and to step up the EU contribution to averting global biodiversity loss. This implements EU commitments under the Convention on Biological Diversity (1992). 4.1 IDENTIFICATION OF EUROPEAN SITES Current guidance on the zone of influence (ZoI) to be considered during the AA process states the following: A distance of 15km is currently recommended in the case of plans, and derives from UK guidance (Scott Wilson et al., 2006). For projects, the distance could be much less than 15km, and in some cases less than 100m, but this must be evaluated on a case-by-case basis with reference to the nature, size and location of the project, and the sensitivities of the ecological receptors, and the potential for in combination effects. The AFF does not detail geographic specificity for the implementation of the AFF measures, so it must be assumed that these measures could be implemented anywhere within the Republic of Ireland. The ZoI of the AFF is therefore considered to include all European Sites within the Republic of Ireland and considers transboundary impacts to SACs and SPAs within 15km of the national border. It is acknowledged that qualifying interest (QIs)/special conservation interests (SCIs) of European Sites have different sensitivities and therefore a set distance of 15km may not be appropriate to assess the potential effects on all QIs/SCIs. For example QI fish species could be affected by changes to water quality at more than 15km distance, SCI bird species might be most significantly affected by disturbance within 1km of their habitat. Therefore whilst a reference distance of 15km has been used for diagrammatic purposes, the impact assessment considers the sensitivities to European Sites in light of their generic Conservation Objectives (COs) (which encompass the spirit of the site specific COs in the context of maintaining and restoring favourable conservation condition) and therefore sensitivities of European Sites outside of 15km are considered. The Natura 2000 Network of sites is designated owing to its ecological importance in a European context. Sites within the Natura 2000 Network are referred to as European Sites and comprise SACs and SPAs. SACs are concerned with the protection of specific QIs and SCIs and the legal basis for their designation is the EU Habitats Directive. In the Republic of Ireland, 430 SACs have been designated covering 59 habitat types recognised in Annex I of the Directive, with 16 habitats designated as priority habitats owing to their ecological vulnerability. In addition, the same Directive, recognises 26 Annex II species. The habitats covered extend across the country and cover a range of ecological features from coastal to grassland to woodland. Priority habitats include Active Bogs, Turloughs and Fixed Dunes. Annex II species include Bats, Otter (Lutra lutra), Freshwater pearl MDR1224Rp005F01 16

23 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport mussel (Margaritifera margaritifera) among others. Through the Birds Directive, SPAs designated for the protection of endangered species of wild birds including listed rare and vulnerable species, regularly occurring migratory species as well as wetland habitats that support such species. Currently there are 165 SPAs designated within the Republic of Ireland. Table 4.1 provides a summary breakdown of the European Sites both in Ireland and those transboundary sites in Northern Ireland which are within 15km of the land boundary shared between Ireland and Northern Ireland and that have been considered in this NIS. Figure 4.1 shows the distribution of the SACs and SPAs listed in Table 4.1. A full listing of the European Sites is included in Appendix B-E. Table 4.1 European Sites within the ZoI of the AFF Ireland* 424 SAC s + 6 offshore SAC s considerably removed from the mainland Northern Ireland 26 SACs 165 SPAs 5 SPAs *Data downloaded from and correct as of September MDR1224Rp005F01 17

24 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Figure European Sites MDR1224Rp005F01 18

25 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport 4.2 CONSERVATION OBJECTIVES Article 6(3) of the Habitats Directive states 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 of the site in view of the site s conservation objectives. QIs/SCIs are annexed habitats and annexed species of community interest for which an SAC or SPA has been designated. The Conservation Objectives (COs) for European Sites are set out to ensure that the QIs/SCIs of that site are maintained or restored to a favourable conservation condition/conservation status. Maintenance of favourable conservation condition of habitats and species at a site level in turn contributes to maintaining or restoring favourable conservation status of habitats and species at a national level and ultimately at the Natura 2000 network level. In Ireland generic COs have been prepared for all European Sites, while site specific COs have been prepared for a number of individual Sites to take account of the specific QIs/SCIs of that Site. Both the generic and site specific COs aim to define favourable conservation condition for habitats and species at the site level. Generic COs which have been developed by NPWS encompass the spirit of site specific COs in the context of maintaining and restoring favourable conservation condition as follows: For SACs: To maintain or restore the favourable conservation condition of the Annex I habitats and/or Annex II species for which the SAC has been selected. For SPAs: To maintain or restore the favourable conservation condition of the bird species listed as Special Conservation Interests for the SPA. Favourable Conservation status of a habitat is achieved when: its natural range, and area it covers within that range, are stable or increasing, and the specific structure and functions which are necessary for its long term maintenance exist and are likely to continue to exist for the foreseeable future, and the conservation status of its typical species is favourable. Favourable Conservation status of a species is achieved when: population dynamics data on the species concerned indicate that it is maintaining itself on a long term basis as a viable component of its natural habitats, and the natural range of the species is neither being reduced nor is likely to be reduced for the foreseeable future, and there is, and will probably continue to be, a sufficiently large habitat to maintain its populations on a long term basis. MDR1224Rp005F01 19

26 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport A full listing of the COs and QIs/SCIs that each European Site is designated for, as well as the attributes and targets to maintain or restore the QIs/SCIs to a favourable conservation condition are available from the NPWS website CONSERVATION STATUS OF EU PROTECTED HABITATS AND SPECIES In 2007 and again in 2013 the National Parks and Wildlife Service (NPWS) published a report detailing the conservation status in Ireland of habitats and species listed in the EU Habitats Directive (92/43/EEC), often referred to as the Article 17 Report 5. Under the Habitats Directive, each member state is obliged to undertake surveillance of the conservation status of the natural habitats and species in the Annexes and under Article 17, to report to the European Commission every six years on their status and on the implementation of the measures taken under the Directive. Appendix G sets out a summary of the conservation status of each habitat and species from both 2007 and In the Article 17 Report for 2013, 9% of habitats were assessed as favourable, 50% as inadequate and 41% as bad. Among the key findings were: Some of the marine habitats are considered to be improving, and to have better prospects, due in part to implementation of other EU environmental Directives. The status of raised bogs in Ireland is Bad ; and the trend is for an ongoing decline as restoration is necessary to cause improvement, notwithstanding the cessation of cutting on SAC bogs. Blanket bog is also assessed as Bad ; the report notes that, as one of the main impacts on this habitat is grazing, an improving trend might be expected due to the implementation of Commonage Framework Plans. However, this improvement appears to be offset and even exceeded by on-going deleterious effects such as peat cutting, erosion, drainage and burning. Although some of our woodlands are rated as Bad because they are patchy and fragmented, improvements have been noted due to afforestation and the planting of native species, removal of alien species and control of overgrazing. Losses of limestone pavement has been recorded outside the SAC network, however the BurrenLIFE and Burren Farming for Conservation Programme have significantly improved the quality of pavement and its associated habitats. From the 2013 report, 52% of species were assessed as favourable, 20% as inadequate, 12% as bad and 16% as unknown or considered to be vagrant species. Among the key findings are: Otter has also been assessed as Favourable with evidence of an expanding range. Salmon (Salmo salar) is showing signs of improvement and the Killarney shad (Alosa killarnensis) is assessed as Favourable, but some other fish remain at Bad status. Freshwater pearl mussel is Bad and declining. Similarly, the requirements for reporting under Article 12 of the Birds Directive (2009/147/EC) are every 6 years. Irelands Article 12 submission to the EU Commission on the Status and trends of bird species ( ) 6 covers 196 species, which includes breeding, wintering and passage species. 5 The Status of EU Protected Habitats and Species in Ireland, NPWS 2007 (Vol 1-3) and 2013 (Vol 1-3) 6 Accessed September 2016 MDR1224Rp005F01 20

27 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport The report details that some species have had significant increases in population over the long term, including Raven (Corvus corax), Collard dove (Streptopelia decaocto), Buzzard (Buteo buteo) and Blackcap (Sylvia atricapilla). However, other species have undergone significant declines in their long-term breeding population trend: Corncrake (Crex crex) (85%), Curlew (Numenius arquata) (98%), Lapwing (Vanellus vanellus) (88%), and Redshank (Tringa totanus) (88%). The Hen harrier (Circus cyaneus) shows a long-term population trend decrease of 27%. The results confirm that there is a need for measures to halt the declines noted above, most of which are due largely to changes in farming practices and intensity, and also the increase of activity in extensively farmed uplands through forestry and wind farm construction. Appendix G sets out a summary of the conservation status of each bird species from both 2007 and EXISTING THREATS AND PRESSURES TO EU PROTECTED HABITATS AND SPECIES Under Article 17 of the Habitats Directive, member states are obliged to identify threats and pressures to QIs/SCIs using a standard set of criteria. A threat is defined as an Activity expected to have an impact on a species/habitat type in the future, and a pressure is defined as an Activity impacting a species/habitat type during the reporting cycle 7. Threats and pressures considered to be most relevantly linked either directly or indirectly to the AFF were extracted from the full list of threats and pressures 8. The headline categories considered relevant to the AFF are presented below, with a more detailed breakdown of the threats and pressures under each headline category presented in Appendix H. Agriculture; Forestry; Mining, quarrying and energy production; Transportation and service infrastructure; Urbanisation, residential and commercial development; Disturbance due to human activities; Pollution; Invasive and introduced species; Modification of natural conditions; and Climate change. A general lack of environmental awareness, especially regarding ecosystem services has also been cited by the EPA in the latest State of the Environment Report 2012 as a pressure on national biodiversity. An updated State of the Environment Report is expected to be published later in 2016 as is an updated National Biodiversity Plan. 7 Reference Portal for reporting under the Article 17 of the Habitats Directive Explanatory Notes & Guidelines for the period Accessed on the Reference Portal for reporting under the Article 17 of the Habitats Directive MDR1224Rp005F01 21

28 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport 4.5 RELEVANT BIODIVERSITY POLICY Ireland's Prioritised Action Framework was published by DAHG in November 2014 and this was based upon the EU Biodiversity Strategy to 2020 (2011). It identified a range of actions needed to help improve the status of Ireland's habitats and species. The key priorities outlined in the framework are outlined below: Restoration of raised bogs; Better protection for blanket bogs and Ireland s uplands generally; Better management of Ireland s dunes and machair systems; Better protection for turloughs; Measures to protect Ireland s remaining Freshwater pearl mussels; and New measures to protect birds in decline such as the Hen harrier, Corncrake and waders. In addition there is a growing awareness and recognition of importance of ecosystem services supported at policy level. Target 2 of the Convention on Biological Diversity (CBD) Strategic Plan requires that: By 2020, at the latest, biodiversity values have been integrated into national and local development and poverty reduction strategies and planning processes and are being incorporated into national accounting, as appropriate, and reporting systems. This is mirrored in both the EU Biodiversity Strategy to 2020 (Target 5) and Irelands National Actions for Biodiversity (Target 3). MDR1224Rp005F01 22

29 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport 5 STAGE 1 SCREENING FOR AA In order to comply with the requirements of Article 6(3) of the EU Habitats Directive, the process of Screening for AA was undertaken at an early stage in the drafting of the AFF. The AA Screening assessed the potential for the AFF to result in likely significant effects on any European Sites within the Natura 2000 network, either alone or in combination with other plans and projects. 5.1 POTENTIAL FOR LIKELY SIGNIFICANT EFFECTS The AA Screening was undertaken before the detailed policy measures were developed and therefore the potential likely significant effects, as presented in column three of Table 5.1 to Table 5.6 below, were inferred, particularly in relation to potential impacts to sensitive habitats e.g. those sensitive to air quality changes. The assessment was largely based on the range of alternative fuels to be considered as part of the AFF. As such, the AA Screening was undertaken in a strategic manner with cognisance of the precautionary principle. The potential likely significant effects identified at the AA Screening stage in relation to each alternative fuel type being considered in the AFF have been extracted from the AA Screening document and are detailed in Table 5.1 to Table 5.6. Table 5.1 Potential Likely Significant Effects Electricity and Electric Vehicle Infrastructure Electricity & Electric Vehicle Infrastructure Aspects of the AFF With Potential for Significant Effects Provision of new infrastructure for electric vehicles e.g. domestic charge points, public access city and town charge points and inter-urban fast charging points; Upgrade of existing infrastructure to provide additional capacity etc.; and Provision of infrastructure for Shore Side Electricity (SSE). Potential Significant Effects Loss or disturbance to habitats or species or their supporting features through: Inappropriate siting of new infrastructure; Construction of new infrastructure or upgrade of existing infrastructure; Inappropriate management of facilities; and Impact to air quality. Table 5.2 Potential Likely Significant Effects Hydrogen and Hydrogen Fuel Infrastructure Hydrogen & Hydrogen Refuelling Network Aspects of the AFF With Potential for Significant Effects Provision of infrastructure for a hydrogen refuelling network; Use of hydrogen supplied fuel cells; and Storage and transport of fuel. Potential Significant Effects Loss or disturbance to habitats or species or their supporting features through: Inappropriate siting of new infrastructure; Construction of new infrastructure; Inappropriate management of fuel or facilities; Impact to air quality; and Potential for spillage in transit. MDR1224Rp005F01 23

30 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Table 5.3 Potential Likely Significant Effects Biofuels and Associated Infrastructure Biofuels & Associated Infrastructure Aspects of the AFF With Potential for Significant Effects Consumption of biomass/ biofuels; Provision of new infrastructure; Upgrade of existing infrastructure; Storage and transport of fuel; and Conversion of fossil-fuel vehicles to dualfuel engines. Potential Significant Effects Loss or disturbance to habitats or species or their supporting features through: Generation of biomass/ biofuels; Inappropriate siting of new infrastructure; Construction of new infrastructure or upgrading of existing infrastructure; Inappropriate management of fuel or facilities; Impact to air quality; and Potential for spillage in transit. Table 5.4 Potential Likely Significant Effects Synthetic and Paraffinic Fuels and Infrastructure Synthetic & Paraffinic Fuels & Infrastructure Aspects of the AFF With Potential for Significant Effects Provision of new infrastructure e.g. Plans by private entities to develop processing plants; Upgrade of existing infrastructure; and Storage and transport of fuel. Potential Significant Effects Loss or disturbance to habitats or species or their supporting features through: Inappropriate siting of new infrastructure; Construction of new infrastructure or upgrading of existing infrastructure; Inappropriate management of fuel or facilities; Impact to air quality; and Potential for spillage in transit. Table 5.5 Potential Likely Significant Effects Natural gas Including Biomethane, in Gaseous Form (Compressed Natural Gas (CNG)) and in Liquefied Form (Liquefied Natural Gas (LNG)) and Associated Infrastructure Natural Gas Including Biomethane (CNG & LNG) & Associated Infrastructure Aspects of the AFF With Potential for Significant Effects Provision of new fuelling infrastructure including refuelling equipment and bunkering (LNG); Supply of LNG by truck or via shuttle from LNG terminal (nearest in Wales) as there is no LNG terminal in Ireland; Development of new CNG Infrastructure Upgrading of existing infrastructure (CNG) e.g. Gas Networks Ireland refuelling station in Cork and temporary station in Dublin; and Storage and transport of fuel. Potential Significant Effects Loss or disturbance to habitats or species or their supporting features through: Inappropriate siting of new infrastructure; Construction of new infrastructure or upgrading of existing infrastructure; Inappropriate management of fuel or facilities; Emissions from transport from nearest LNG terminal and potential risk of spillage in transit; and Impact to air quality. MDR1224Rp005F01 24

31 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Table 5.6 Potential Likely Significant Effects Liquefied Petroleum Gas and Refuelling Infrastructure Liquefied Petroleum Gas & Refuelling Infrastructure Aspects of the AFF With Potential for Significant Effects Provision of new fuelling infrastructure; Upgrading of existing infrastructure; and Storage (pressure containers) and transport of fuel. Potential Significant Effects Loss or disturbance to habitats or species or their supporting features through: Inappropriate siting of new infrastructure; Construction of new infrastructure; Inappropriate management of fuel or facilities; Impact to air quality; and Potential for spillage in transit. 5.2 SCREENING FOR APPROPRIATE ASSESSMENT CONCLUSION On completion of the AA Screening, it was concluded that the potential for likely significant effects on European Sites could not be ruled out and the AFF would undergo AA. The DTTAS recorded their AA Screening determination accordingly. The AA Screening can be found in Appendix F. The Screening for AA was submitted to the DAU of the DAHG (now the DAHRRGA) on 24 th May 2016, advising that the AFF was proceeding to AA. The AA process then proceeded to the preparation of a NIS to inform the AA to be undertaken by DTTAS. MDR1224Rp005F01 25

32 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport 6 STAGE 2 APPROPRIATE ASSESSMENT 6.1 INTRODUCTION The assessment considers the impacts 9 that the AFF will have on the integrity of the European Sites, with respect to the conservation objectives of the sites and to their structure and function. EC guidance (MN2000) states that the integrity of a site involves its ecological functions and the decision as to whether it is adversely affected should focus on, and be limited to, the site s conservation objectives. Following on from the Screening for Appropriate Assessment, (see Section 5), this section considers further and sets out the elements of the AFF that have potential to give rise to likely significant effects on European Sites. The potential effects have been assessed in the absence of any mitigation measures, and taking account of the precautionary principle. It is noted that the Habitats Directive promotes a hierarchy of avoidance, mitigation and compensatory measures. Through iterative discussion during the preparation of the AFF, avoidance of impacts as a result of implementing the AFF has therefore been to the forefront of discussions with the DTTAS. The principle direct effect of the AFF relates to new or upgraded fuel delivery infrastructure e.g. provision of alternative fuel pumps at fuel stations, inclusion of shore-side electricity charging points etc. However, it is acknowledged that by providing the refuelling infrastructure this indirectly encourages the use of alternative fuels and as such the fuel source/feedstock, method of generation and resultant emissions must also be considered in its broadest sense in relation to likely significant effects on European Sites. 6.2 APPROACH TO ASSESSMENT In line with the relevant guidance this stage of the Appropriate Assessment consists of three main steps: Impact Prediction - where the likely impacts of the AFF are examined. A source-pathwayreceptor model has been used to assess potential for impact; Assessment of Effects - where the effects of the AFF are assessed as to whether they have any adverse effects on the integrity of European Sites as defined by conservation objectives; and Mitigation Measures - where mitigation measures are identified to ameliorate any adverse effects on the integrity of any European Site. 6.3 IMPACT PREDICTION As noted in Chapter 3, in considering the potential for impacts from implementation of the AFF, a source pathway-receptor approach has been applied. The source relates to the policy measures outlined in the AFF which have the potential to adversely impact European Sites e.g. infrastructural developments or generation/combustion of alternative fuels. The pathways relates to how the AFF 9 Impacts considered include direct, indirect, short term, long term, temporary, permanent and cumulative. MDR1224Rp005F01 26

33 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport policy measures can impact European Sites e.g. changes in land use, habitat loss/fragmentation, emissions to air, hydrological connections. The receptor is the Natura 2000 network, potentially including those transboundary sites for which there is a pathway of connectivity as a result of the implementation of the AFF Context for Impact Prediction The development and implementation of the AFF itself is considered to be largely positive in terms of its impacts on the environment as it will facilitate a shift from almost complete dependence on oil to a broader cleaner fuel base including opportunities for use of renewable energy fuel sources. This will indirectly contribute to targets in relation to GHG emissions, set to tackle climate change nationally and at an EU level. Climate change is one of the most significant future challenges for the protection of the Natura 2000 network across Europe as habitats and species distribution responds to the changes. The primary objectives of the AFF are to: support the provision of alternative fuels refuelling infrastructure and incentives to support the use of that infrastructure. It is anticipated that the realisation of these objectives would in turn facilitate a modal shift from oil dependent fuel sources to alternative fuels and move the nation closer to a decarbonisation of our transport sector. The development and implementation of the AFF is driven by European Directive and national policy. The AFF does not include explicit geographic context or project specific details of future activities/actions associated with the implementation of the AFF. Rather it provides predictions and assumptions on the alternative fuel targets that are to be achieved and which are supported through other existing plans/programmes. The strategic objectives and actions laid out in the AFF provide a framework for the development of other more specific plans or projects within the planning hierarchy. Therefore, at the strategic level, the main direct impact associated with the AFF is considered to be in relation to siting of alternative fuels infrastructure. It is acknowledged that by providing the refuelling infrastructure and incentivisation envisaged through the AFF, this directly encourages the use of alternative fuels. Thus the fuel source/feedstock, method of generation and resultant emissions must also be considered in relation to indirect likely significant effects on European Sites. For example, an increase in electric vehicle (EV) usage will result in an increase in the demand for electricity. While the EVs themselves have no direct tailpipe emissions and would have no likely significant effect on European Sites, and in fact the shift away from petrol and diesel emissions would be expected to impact positively on some European Sites. However, dependent on the method of electricity generation there could be indirect effects on European Sites as a result of emissions to air where the source of the electricity is from peat/coal burning rather than renewable sources. Similarly, effects on European Sites via land use changes for renewable energy infrastructure/feedstock are also a potential indirect consequence of providing additional infrastructure and encouraging alternative fuels. There is a body of evidence at this stage in relation to impacts to sensitive species, such as hen harrier, from the provision of renewable wind infrastructure in sensitive habitat. Therefore, there is potential for direct and indirect impacts on the Natura 2000 Network arising from the future proposals of the AFF Impact Identification A summary of the main potential ecological impacts that could arise from the implementation of the AFF are presented below and are used in the impact prediction. MDR1224Rp005F01 27

34 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Habitat loss, destruction, fragmentation or degradation: habitat loss or destruction is caused where there is complete removal of a habitat type, for example arising from the development of new infrastructure or a change of land use which alters the existing habitat. Habitat fragmentation results from the incremental loss of small patches of habitat within a larger landscape. Fragmentation can also result from impediments to the natural movements of species. This is relevant where important corridors for movement or migration are disrupted e.g. migration routes for lamprey species or Atlantic Salmon along river corridors are obstructed by hydropower infrastructure. Habitat degradation results in the diminishment of habitat quality and a loss of important habitat functions. It can arise from the introduction of invasive species, toxic contamination or physical alteration (e.g. arising from poor management during construction and subsequent operation of new infrastructure); Alterations to water quality and/or water movement: This is relevant where there could be an impact on the hydrological/hydrogeological connection to a European Site or on water quality. This could be via point source or diffuse pollution from infrastructural developments, changes to water quality via eutrophication/acidification as a result of emissions to air, or via infrastructural developments that alter surface or subsurface water flow. In terms of potential for alteration of water quality, the impact(s) may be in-situ or ex-situ (i.e. downstream and outside the immediate area) and can include the release of suspended solids, increased nutrient run-off from land such as biofuel crops/forestry, increased acidification/eutrophication as a result of emissions to air and siting of infrastructure. Alteration to air quality: The generation and combustion of alternative fuels may give rise to emissions to air. For larger industrial facilities this is regulated through strict licensing procedure with limits set for the protection of human health and the environment. This would be the case for generation plants such as Moneypoint. Disturbance to habitats/species: Disturbance to habitats/species within a European Site is likely to increase where there is an increase in activity or noise levels from developments within or adjacent to those sites. It is particularly important that known sensitive areas, such as those supporting breeding birds, otter, salmonids and others are taken into consideration during the investigation/feasibility or design stage of any infrastructure prior to approval. In-combination impacts: A series of individually modest impacts may in combination produce a significant impact. The underlying intention of this in-combination provision is to take account of combined impacts, and these will often only occur over time. In that context, one must consider plans or projects which are completed; in preparation; or approved but uncompleted. Where there is a series of small, but potentially adverse impacts occurring within or adjacent to a European Site, consideration should be made as to their combined impacts Impact Prediction In line with the methodology for impact prediction outlined in Section 3.4, the main impacts that could arise from the various aspects of the AFF are summarised in Table 6.1 and discussed below. Incombination impacts are assessed separately in Section 6.5. Table 6.1 Main Ecological Impacts Associated with the AFF Impact Source Impact Identification Impact Prediction Construction, upgrade and operation of alternative fuel refuelling infrastructure Habitat loss or destruction; Habitat fragmentation or degradation; Alterations to water quality Land use changes as a result of construction and operation of alternative fuel infrastructure. Direct and permanent in nature. MDR1224Rp005F01 28

35 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Impact Source Impact Identification Impact Prediction Land use changes as a result of indirectly encouraging the increased use of alternative fuels Emissions to air from generation and combustion of alternative fuels a result of indirectly encouraging the increased use of alternative fuels and/or water movement; Disturbance to habitats/species. Habitat loss or destruction; Habitat fragmentation or degradation; Alterations to water quality and/or water movement; Disturbance to habitats/species. Habitat or degradation; Alteration to air quality; Disturbance to habitats/species. Construction related impacts including changes to water quality, disturbance to habitats/species. Indirect and short term in nature. Land use changes as a result of construction and operation of alternative fuel generation facilities e.g. windfarms, hydropower, to meet increased demand on electricity. Indirect and permanent in nature. Landuse changes as a result of requirement for feedstock for alternative fuel e.g. biofuel crops/peat. Indirect and permanent in nature. Barriers to movement of species as a result of land use change e.g. hydropower creating barriers to movement along river corridors. Indirect and long term in nature. Land use changes leading to resultant impacts on water quality e.g. sedimentation and eutrophication as a result of run-off from sites cleared for windfarms or other electricity generating facilities. Indirect and permanent in nature. Land use changes altering water movement or water retention e.g. construction of facilities altering groundwater movement to groundwater dependent habitats. Indirect and permanent in nature. Disturbance to habitats/species as a result of land use changes e.g. roosting/foraging grounds disturbed or altered. Indirect and long term in nature. Combustion of fossil fuels to generate electricity and resultant emissions to air. Indirect and long term in nature. Generation of other alternative fuel and associated emissions to air. Indirect and long term in nature. Combustion of alternative fuel and resultant tail pipe emissions to air. Indirect and long term in nature. Transportation of alternative fuel/feedstock leading to emissions to air dependent on the transport method used. Indirect and long term in nature. MDR1224Rp005F01 29

36 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport 6.4 ASSESSMENT OF EFFECTS Article 6 of the Habitats Directive states 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 of the site in view of the site s conservation objectives. The impact prediction and assessment of potential effects on the Natura 2000 network from the AFF has considered the potential to impact on the achievement of the COs of the European Sites and is presented in the following sections Assessment of Policy Measures to Support Uptake of Electric Vehicles Broadly speaking the AFF proposes to increase the uptake of EV through a combination of policy, research and incentivisation measures. The focus for this alternative fuel (electric vehicles) is not on additional infrastructure to any large degree with a small expansion of the current re-charging network sufficient to support 20,000 EVs by It is noted in the AFF that the number of recharging points required to support 50,000 EVs would not differ significantly from that required to service 20,000 EVs. As such there is limited potential for direct effects on European Sites. The potential for effects stems from increased demand for electricity from both renewable and nonrenewable sources, both of which have potential for significant effects on European Sites and associated species. It is however acknowledged that the existing and future load on the electricity grid is not the subject matter of the AFF. Table 6.2 Electricity Measures by end 2017 Policy Measures Revise regulations, as required, in relation to technical specifications for normal and highpower recharging points and shore-side electricity supplies in line with the development of new EU standards and/or any further changes to Annex II of Directive 2014/94/EU. The current Programme for Government includes a commitment to establish an EV Taskforce to consider the range of measures and options available to Government for the purpose of accelerating the deployment of EVs. It is expected that the work of the Task force will be divided into three areas; 1. market growth stimuli, 2. charging infrastructure, and 3. legislation and planning. Impact Assessment and Mitigation No direct potential likely significant effects to European Sites as this relates to governance and compliance with the Directive. Public authorities (the DTTAS and other) are also obliged to comply with paragraph 27 of the Birds and Natural Habitats regulations in relation to nature conservation. No direct potential likely significant effects to European Sites as this relates to information gathering that will inform future decision making. Although the establishment of a Taskforce is positive, there is potential for indirect effects. The Taskforce, in considering the range of measures and options available to accelerate the deployment of EVs, must consider the potential indirect impacts of these on the Natura 2000 Network. Early consideration of the Natura 2000 Network would have positive effects on European Sites. See Section Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure for discussion and Chapter 7 which outlines mitigation. While the taskforce will also consider other No direct potential likely significant effects to European MDR1224Rp005F01 30

37 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Policy Measures carbon low carbon technologies and fuels, the following reflects some of the market stimulus options to be considered in respect of EVs: o o o o o o o o o o Change to grant and VRT levels (methods, duration and cost); Tolls (reduced charges and exemptions); Benefit in kind (BIK) relief; Motor tax rates; Public parking charges; Supports for leasing arrangements; Supports for car sharing EVs; Potential access to bus lanes; Energy credits and Obligation Schemes; and VAT on purchase of vehicle. Establish a Green Bus Fund, which would support the uptake of electrically powered buses, either hybrids or full electric. Impact Assessment and Mitigation Sites as this relates to incentivisation schemes. It is acknowledged that incentivisation schemes could lead to potential indirect likely significant effects on European Sites through an increased demand for electricity and resultant environmental effects in terms of land use and emissions to air dependent on the method of electricity generation used, albeit licensed and permitted in accordance with the appropriate planning and environmental legislation and regulatory processes. See Section Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure for discussion and Chapter 7 which outlines mitigation. No direct potential likely significant effects to European Sites as this relates to a monetary fund. Table 6.3 Electricity Measures to be implemented by end 2018 Policy Measures Implement any measures recommended by the LEV Taskforce and approved by government. Assess the need for an action package aimed at removing any administrative obstacles related to the deployment of public and private recharging points. In line with the White Paper on Energy Policy, establish a Government-backed scrappage scheme for taxis aged 7 years or older where the car is being replaced by an EV. Consider contribution of building regulations for supporting market uptake of EVs. Revised regulations would ideally provide for the setting of minimum requirements on the number of electric recharging points to be established at new residential or commercial developments Impact Assessment and Mitigation No direct potential likely significant effects to European Sites as this relates to implementing measures recommended by the taskforce. Although the work of the Taskforce is positive, there is potential for indirect effects. The Taskforce, in considering the range of measures and options available to accelerate the deployment of EVs, must consider the potential indirect impacts of these on the Natura 2000 Network. Early consideration of the Natura 2000 Network would have positive effects on European Sites. See Section Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure for discussion and Chapter 7 which outlines mitigation. No potential likely significant effects to European Sites as this relates to streamlining administrative procedures. No direct potential likely significant effects to European Sites as this relates to a monetary scheme. No direct potential likely significant effects to European Sites as this relates to developing specific governance/ procedures. Public authorities (the DTTAS and other) are also obliged to comply with paragraph 27 of the Birds and Natural Habitats regulations in relation to nature MDR1224Rp005F01 31

38 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Policy Measures (where car parking is being provided). Impact Assessment and Mitigation conservation. Table 6.4 Electricity Measures to be considered by end of 2018 Policy Measures In order to monitor and evaluate the operation of the charging points and to estimate the future load on the electricity grid, an assessment methodology and reporting system should be established. Eirgrid are in the process of developing modelling scenarios in this context, which will be informed by the ambition of this Draft AFF. Onshore and offshore interconnectivity should be considered in this regard. Participation in the development and research of new technologies, trials, technical specifications and standards at EU and international level. Address the issue of misuse or icing of charge point spaces through parking and/or road traffic regulations. Undertake a life cycle cost analysis of rolling out Fixed Electrical Ground Power (FEGP) units at all airports not currently using electricity supply for stationary aircraft. Develop a feasibility study on shore-side electricity supply for seagoing ships in TEN-T ports (Dublin, Cork and Shannon-Foynes) taking into account demands, CBA and environmental effects and the level of financial support that Impact Assessment and Mitigation No direct potential likely significant effects to European Sites. This relates to an information gathering exercise that will inform future decision making. No direct potential likely significant effects to European Sites as this relates to input into information gathering that will help inform future decision making. Potential for indirect effects on European Sites if they are not considered at the earliest possible stage. Early consideration of the Natura 2000 Network in any research/studies would have positive effects on European Sites and, where possible, should be integrated into research proposals. See Section Construction, Upgrade and/or Operation of Alternative Fuels Refuelling Infrastructure for discussion research/studies and Chapter 7 which outlines mitigation. No direct potential likely significant effects to European Sites as this relates to developing specific governance/ procedures. Public authorities (the DTTAS and other) are also obliged to comply with paragraph 27 of the Birds and Natural Habitats regulations in relation to nature conservation. No direct potential likely significant effects to European Sites as this relates to information gathering and feasibility studies that will inform future decision making. Potential for indirect effects on European Sites if they are not considered at the earliest possible stage. Early consideration of the Natura 2000 Network in any research/studies would have positive effects on European Sites and, where possible, should be integrated into research proposals. See Section Construction, Upgrade and/or Operation of Alternative Fuels Refuelling Infrastructure for discussion research/studies and Chapter 7 which outlines mitigation No direct potential likely significant effects to European Sites as this measure in the first instance relates to information gathering and feasibility study that will inform future decision making. Potential for indirect potential likely significant effects on European Sites if they are not MDR1224Rp005F01 32

39 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Policy Measures may be required to make the delivery of the infrastructure feasible. Based on the results of the study, targets for shore side electricity supply should be established, as required, with a view to the deployment of any related infrastructure at these core TEN-T ports initially, subject to the requirements of the relevant environmental legislation, including Article 6 of the Habitats Directive. Impact Assessment and Mitigation considered at the earliest possible stage. It is acknowledged that there exists the potential for potential direct and indirect likely significant effects on European Sites as the measure suggests deploying infrastructure in three ports. Shannon-Foynes is located within two European Sites (Lower River Shannon SAC and River Shannon and River Fergus Estuaries SPA), with Dublin and Cork ports and/or shipping lanes located adjacent to or adjoining a number of European Sites. Therefore, any future development of infrastructure at these ports has the potential for likely significant effects e.g. direct habitat loss or disturbance to QI/SCI species as well as incombination/cumulative likely significant effects from other port activities. However, the measure explicitly highlights the requirement for Appropriate Assessment at development application level which would ensure protection of the European Sites. The study on shore-side electricity supply should also investigate the possibility for reducing the rate of electricity tax for shore-side electricity in the short term to stimulate demand, If the reduced rate was below the rate set by the Energy Taxation Directive, authorisation would be required from the EU. See Section Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure for discussion in relation to the potential likely significant effects in relation to investigative and feasibility studies and Chapter 7 which outlines mitigation. No direct potential likely significant effects to European Sites as this relates to short term measures to stimulate demand. It is acknowledged that stimulation schemes could lead to potential indirect likely significant effects on European Sites through an increased demand for electricity and resultant environmental effects in terms of land use and emissions to air dependent on the method of electricity generation used, albeit licensed and permitted in accordance with the appropriate planning and environmental legislation and regulatory processes. See Section Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure for discussion and Chapter 7 which outlines mitigation. Table 6.5 Electricity Measures by end of 2020 Policy Measures Develop, if required, regulatory measures to facilitate the deployment of home/private chargers. Assess the implementation of regulations in relation to user information associated with this Impact Assessment and Mitigation No direct potential likely significant effects to European Sites as this relates to developing specific governance/ procedures. Public authorities (the DTTAS and other) are also obliged to comply with paragraph 27 of the Birds and Natural Habitats Regulations in relation to nature conservation. No direct potential likely significant effects to European Sites as this relates to developing governance/procedures MDR1224Rp005F01 33

40 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Policy Measures Directive 2014/94/EU. Assess and amend (if necessary) regulations and standards in order to ensure appropriate level of use of recharging infrastructure at apartment blocks, parking lots, office and business locations, e.g.: Building Control Act, 1990 (3 of 1190), Building Control Act, 2007, Building Control Regulations , Building Regulations , Road Traffic (Traffic and parking) Regulations, 1997 (S.I. No. 182/1997), Road Traffic (Traffic And Parking) (Car Clubs And Electrically Powered Vehicles) Regulations 2014 (S.I. No. 325 of 2014). Consider the inclusion of any amended regulations, a requirement for recharging points to incorporate, where feasible, renewable sources of energy i.e. solar photovoltaic panels. Ensure development of new National Planning Framework takes account of this draft AFF. Continue to support and foster research on future technologies (e.g. wireless charging and battery swapping). Establish partnerships with public entities and private companies in order to facilitate trials of EVs in public sector and public transport fleets. Impact Assessment and Mitigation in relation to provision of information to the public. No direct potential likely significant effect to European Sites as this relates to review of governance to ensure alternative fuel infrastructure is considered. Public authorities (the DTTAS and other) are also obliged to comply with paragraph 27 of the Birds and Natural Habitats Regulations in relation to nature conservation. No direct potential likely significant effects to European Sites as this relates to consideration of utilisation of solar energy. Public authorities (the DTTAS and other) are also obliged to comply with paragraph 27 of the Birds and Natural Habitats regulations in relation to nature conservation. No direct potential likely significant effects to European Sites as this relates to governance. Indirect positive impacts in the longer term as this will facilitate proper integration with other national plans. No direct potential likely significant effects to European Sites. This is a research and development measure that will inform future decision making. Early consideration of the Natura 2000 Network in any research/studies would have positive effects on European Sites and, where possible, should be integrated into research proposals. See Section Construction, Upgrade and/or Operation of Alternative Fuels Refuelling Infrastructure for discussion research/studies and Chapter 7 which outlines mitigation. No direct potential likely significant effects to European Sites as this relates to forging partnerships with information gatherers that will inform future decision making Assessment of Policy Measures to Support Uptake of Natural Gas (CNG & LNG) The primary constituent of CNG and LNG is methane and as it is a simple hydrocarbon the combustion of methane will generate combustion gases such as NO x, CO and CO 2. Particulates are not a major pollutant from methane as it readily and efficiently combusts with little or no particulate residue. However as a fossil fuel, natural gas combustion generates CO 2 emissions unlike carbon free fuels. The suite of measures developed to support the uptake of natural gas as a fuel for transport include tax incentives to reduce the cost of running vehicles on natural gas and support the conversion to natural gas. MDR1224Rp005F01 34

41 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Table 6.6 Natural Gas (CNG & LNG) Measures to be implemented by end 2017 Policy Measures Installation of 5 CNG publically accessible fast-fill stations at strategic locations including Dublin Port. Complete the assessment on biogas and biomethane, which is currently being undertaken by SEAI and develop appropriate policy options to support the use of biomethane, particularly in the public transport and freight sectors. Introduce a new ACA tax incentive for companies with the aim of encouraging investment in refuelling infrastructure and equipment for natural gas. The ACA would allow companies to write off 100% of the purchase value of qualifying vehicles and refuelling equipment, including CNG compression equipment, against their profit in the year of purchase. It is anticipated that qualifying vehicles will need to demonstrate compliance with, at least, the Euro 6/VI emission standards. Revise regulations, as required, in relation to technical specifications for refuelling points in line with the development of new EU standards and/or any further changes to Annex II of Directive 2014/94/EU. Impact Assessment and Mitigation No direct potential likely significant effects to European Sites as this measure is focused on the development of small fast-fill stations on existing hardstanding areas. Potential for indirect potential likely significant effects on European Sites if appropriate construction measures are not applied at the earliest possible stage to the installation of the stations. Dublin Port is adjacent to European Sites and therefore any future development of infrastructure at these ports has the potential for likely significant effects e.g. disturbance to QI/SCI species. However, Screening for Appropriate Assessment at development application level which would ensure protection of the European Sites. See Section Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure for discussion in relation to the potential likely significant effects in relation to infrastructure and Chapter 7 which outlines mitigation. No direct potential likely significant effects to European Sites as this relates to completion of an investigative study and developing policy. Potential for indirect effects on European Sites if they are not considered at the earliest possible stage in investigative studies and also as a result of a requirement for re-fuelling infrastructure and emissions to air in supporting the use of biomethane. See Section Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure and Emissions to Air as a Result of Indirectly Encouraging the Increased Use of Alternative Fuels for discussion and Chapter 7 which outlines mitigation. No direct potential likely significant effects to European Sites as this relates to incentivisation schemes. It is acknowledged that incentivisation schemes could lead to potential indirect effects on European Sites through an increased demand for natural gas and resultant environmental effects in terms of requirement for refuelling infrastructure and emissions to air. See Section Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure and Emissions to Air as a Result of Indirectly Encouraging the Increased Use of Alternative Fuels for discussion and Chapter 7 which outlines mitigation. No direct potential likely significant effects to European Sites as this relates to developing specific governance/ procedures. Public authorities (the DTTAS and other) are also obliged to comply with paragraph 27 of the Birds and Natural Habitats regulations in relation to nature conservation under MDR1224Rp005F01 35

42 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Policy Measures Utilise the Green Bus Fund to support demonstration projects in public transport fleets. Only vehicles that demonstrate compliance with the Euro 6/VI emission standards will be supported through this fund. Impact Assessment and Mitigation No direct potential likely significant effects to European Sites as this relates to utilisation of funding for trials. Table 6.7 Natural Gas (CNG & LNG) Measures to be considered by end 2018 Policy Measures Include biomethane as a transport fuel in the Biofuel Obligation Scheme. A low carbon vehicle fund to provide first mover backing in commercial fleets. VRT and motor tax treatment to recognise low emission HGVs. Funding for innovation within the Irish transport sector. A Green Transport Certificate for goods transported using low carbon technology. Support measures to encourage captive fleets, maintained by local authorities and public bodies, to move to CNG vehicles, if suitable, by Impact Assessment and Mitigation No direct potential likely significant effects to European Sites as this relates to including biiomethane within the Biofuel Obligation Scheme. It is acknowledged that including biomethane could lead to potential indirect likely significant effects on European Sites through resultant environmental effects in terms of emissions to air. See Section Emissions to Air as a Result of Indirectly Encouraging the Increased Use of Alternative Fuels for discussion and Chapter 7 which outlines mitigation. No direct potential likely significant effects to European Sites as this is a monetary measure. No direct potential likely significant effects to European Sites as this relates to incentivisation schemes. It is acknowledged that incentivisation schemes could lead to potential indirect effects on European Sites through an increased demand for natural gas and resultant environmental effects in terms of requirement for refuelling infrastructure and emissions to air. See Section Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure and Emissions to Air as a Result of Indirectly Encouraging the Increased Use of Alternative Fuels for discussion and Chapter 7 which outlines mitigation. No direct potential likely significant effects to European Sites as this is a monetary measure with no specific target identified. No direct potential likely significant effects to European Sites as this relates to a certification process. No direct potential likely significant effects to European Sites as this relates to incentivisation schemes. It is acknowledged that incentivisation schemes could lead to potential indirect likely significant effects on European Sites through an increased demand for natural gas and resultant environmental effects in terms of requirement for re-fuelling infrastructure and emissions to air. See Section Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure MDR1224Rp005F01 36

43 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Policy Measures Market analysis will be undertaken in relation to demand for LNG (and related refuelling infrastructure) along the TEN-T corridor, to include the motorway between Dublin and Cork and the associated ports of Dublin, Cork and Shannon Foynes. Market analysis of demand for LNG at TEN-T Comprehensive Ports should also be included. Impact Assessment and Mitigation and Emissions to Air as a Result of Indirectly Encouraging the Increased Use of Alternative Fuels for discussion and Chapter 7 which outlines mitigation. No direct potential likely significant effects to European Sites as this relates to information gathering that will inform future decision making. Although market analysis in itself is not an issue, there exists a potential for indirect effects on European Sites from construction of re-fuelling infrastructure. See Section Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure for discussion in relation to the potential likely significant effects in relation to construction of re-fuelling infrastructure, investigative and feasibility studies and Chapter 7 which outlines mitigation Assessment of Policy Measures to Support Uptake of Hydrogen Hydrogen is harnessed for use in transport by fuel cell technology which utilises hydrogen to produce electricity without combustion. In the next few years, a number of major car manufacturers, are planning to start mass-production of fuel cell electric vehicles (FCEVs). While FCEVs produce zero tailpipe emissions, they have most in common with the traditional internal combustion engine in terms of range and refuelling. A tank of hydrogen could support distances of approximately 500km with refuelling times in the order of 3 to 5 minutes. The suite of measures developed to support uptake of hydrogen are principally related to preparatory work to facilitate future uptake. Table 6.8 Hydrogen Policy Measures by end 2020 Policy Measures Facilitate trials on fuel-cell propelled vehicles. Assess the feasibility of establishing a hydrogen refuelling network based on technological development and market uptake. Consider incentives for uptake of hydrogen, including accelerated capital allowances to Impact Assessment and Mitigation No direct potential likely significant effects to European Sites. As such, this is a trial that will help inform future decision making. No direct potential likely significant effects to European Sites as this relates to information gathering and feasibility study that will inform future decision making. Potential for indirect potential likely significant effects on European Sites if they are not considered at the earliest possible stage. See Section Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure and Emissions to Air as a Result of Indirectly Encouraging the Increased Use of Alternative Fuels for discussion in relation to the potential likely significant effects in relation to investigative and feasibility studies and construction of re-fuelling infrastructure and Chapter 7 which outlines mitigation. No direct potential likely significant effects to European Sites as this relates to incentivisation schemes. It is MDR1224Rp005F01 37

44 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Policy Measures support investment in refuelling infrastructure. Impact Assessment and Mitigation acknowledged that incentivisation schemes could lead to potential indirect effects on European Sites through an increased demand for hydrogen and resultant environmental effects in terms of requirement for refuelling infrastructure and emissions to air. See Section Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure and Emissions to Air as a Result of Indirectly Encouraging the Increased Use of Alternative Fuels for discussion in relation to the potential likely significant effects in relation to construction of re-fuelling infrastructure and Chapter 7 which outlines mitigation Assessment of Policy Measures to Support Uptake of LPG Liquefied Petroleum Gas (LPG) is the most widely-used alternative automotive fuel in Europe, fuelling more than 6 million vehicles, mainly passenger cars and buses. LPG is also widely used as a clean fuel for indoor vehicles such as forklift trucks. Due to the flexibility of its supply chain, LPG can be used in remote areas and as a back-up energy for intermittent renewables such as photovoltaic, solar-thermal, wind and small hydro. 10 Tests have shown that LPG autogas produces 20% less in CO 2 emissions when compared with an equivalent petrol vehicle and can have up to a 10% advantage over an equivalent diesel. It is also cleaner than diesel from the perspective of particulates, sulphur content and NO x. The suite of measures developed to support uptake of LPG are principally related to incentivising uptake in the commercial sector. Table 6.9 LPG Future Policy Measures to be considered by end 2018 Policy Measures to be considered by end 2018 Secure commitment to maintain or reduce excise duty rates for a prolonged period (minimum 8 years), taking account of excise levels on other alternative fuels, providing certainty to the market for LPG. Introduce Accelerated Capital Allowance (ACA) tax incentive for companies with the aim of encouraging investment in refuelling infrastructure and equipment for LPG. The ACA would allow companies to write off 100% of the purchase value of qualifying refuelling equipment against their profit in the year of Impact Assessment and Mitigation No direct potential likely significant effects to European Sites as this relates to incentivisation schemes. It is acknowledged that incentivisation schemes could lead to potential indirect likely significant effects on European Sites through an increased demand for LPG and resultant environmental effects in terms of requirement for refuelling infrastructure and emissions to air. See Section Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure and Emissions to Air as a Result of Indirectly Encouraging the Increased Use of Alternative Fuels for discussion and Chapter 7 which outlines mitigation. No direct potential likely significant effects to European Sites as this relates to incentivisation schemes. It is acknowledged that incentivisation schemes could lead to potential indirect likely significant effects on European Sites through an increased demand for LPG and resultant environmental effects in terms of requirement for refuelling infrastructure and emissions to air. 10 European Liquid Petroleum Gas Association - MDR1224Rp005F01 38

45 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Policy Measures to be considered by end 2018 purchase. Examine Vehicle Registration Tax (VRT) rates on factory fitted LPG fuelled vehicles. Impact Assessment and Mitigation See Section Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure and Emissions to Air as a Result of Indirectly Encouraging the Increased Use of Alternative Fuels for discussion and Chapter 7 which outlines mitigation. No direct potential likely significant effects to European Sites as this relates to the examination of the current baseline Assessment of Policy Measures to Support Uptake of Synthetic and Paraffinic Fuels Synthetic and paraffinic fuels can contribute to the improvement of air quality and reduction in CO 2 emissions (depending on fuel type, composition and processing). These fuels do not need new infrastructure since they are blended (25-100%) to traditional fuels. Synthetic fuels can be made from different range of resources: natural gas, biomass, coal, plastic or hydrotreated vegetable oil (HVO). Paraffinic fuels are clean, high quality diesel fuels made from a wide variety of feedstocks, namely BTL (biomass to liquid), GTL (gas to liquid), and HVO (Hydrotreated Vegetable Oil). The measures proposed to support uptake of synthetic and paraffinic fuels are principally related to investigative work to facilitate future uptake. Table 6.10 Synthetic and Paraffinic Fuels Policy Measures Policy Measures Facilitate trials, as required, on synthetic fuels in public transport vehicles (bus and rail). Analyse need for financial incentive to support greater use of synthetic and paraffinic fuels. Impact Assessment and Mitigation No direct potential likely significant effects to European Sites. As such, this is a trial that will help inform future decision making. No direct potential likely significant effects to European Sites as this relates to information gathering Assessment of Other Measures Aimed at Accelerating the Move to Low Emissions Vehicles A number of other measures are included to accelerate the move to low emission vehicles. These include changes to taxation as well as improved education and awareness of the benefits of alternative fuels and the geographic spread of supporting infrastructure. Table 6.11 Policy Measures to Support Move to Low Emissions Vehicles Policy Measures Impact Assessment and Mitigation Taxation Measures to be implemented by end of 2017 Commitment made in Budget 2017 to retain the preferential VRT rates for EVs for a new period of 5 years and for PHEVs for 2 years. No direct potential likely significant effects to European Sites as this relates to incentivisation. It is acknowledged that incentivisation could lead to potential indirect likely significant effects on European Sites through an increased demand for electricity and resultant environmental effects in terms of land use and MDR1224Rp005F01 39

46 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Policy Measures Possible Taxation measures by end 2020 The taxation measures, which are to be considered, and could play a key role in supporting the transition to a low carbon transport system include: Retention of a preferential VRT and motor tax regime for the lowest carbon vehicles. Reviewing the VRT and motor tax regime for light good vehicles (LGVs). Updating and implementing benefit-in-kind taxation for LEVs. Rebalancing of excise duty. VAT rebate for petrol (including hybrids). Removal of Diesel Rebate Scheme. Impact Assessment and Mitigation emissions to air dependent on the method of electricity generation used, albeit licensed and permitted in accordance with the appropriate planning and environmental legislation and regulatory processes. See Section Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure for discussion and Chapter 7 which outlines mitigation. No direct potential likely significant effects to European Sites as this relates to incentivisation schemes. It is acknowledged that incentivisation schemes could lead to potential indirect likely significant effects on European Sites through an increased demand for alternative fuels and resultant environmental effects in terms of requirement for re-fuelling infrastructure, indirect land use changes for electricity generation facilities and feedstock and emissions to air. See Section for discussion in relation to the potential likely significant effects in relation to construction of refuelling infrastructure and land use changes and emissions to air, and Chapter 7 which outlines mitigation. It is also acknowledged that this measure could have indirect positive effects on European Sites by removing the preference for diesel usage due to the price differential, and hence reducing emissions to air from diesel and a shift towards petrol and alternative fuels, which would result in an overall net positive in terms of air quality. Possible Promotional Campaigns by end Advertising Develop a media campaign that will reflect the benefits of alternative fuels (e.g. smoother drive, low noise, positive image). Develop a media campaign that will provide information on the vehicles/infrastructure available. No direct potential likely significant effects to European Sites as this relates to provision of information. No direct potential likely significant effects to European Sites as this relates to provision of information. Possible Promotional Campaigns by end Information Review user-friendliness of existing online data on recharging infrastructure, such as the ecar interactive mapping tool. Develop online tool for accessing information on refuelling stations for CNG. Develop a cost comparator that will provide the capability to examine the total cost of vehicle ownership across a range of alternative fuels (from 2020 onwards). No direct potential likely significant effects to European Sites as this relates to provision of information. No direct potential likely significant effects to European Sites as this relates to provision of information. No direct potential likely significant effects to European Sites as this relates to provision of information. Develop a campaign targeted at dealerships. No direct potential likely significant effects to European Sites as this relates to provision of information. Awareness raising - targeted at fleet managers No direct potential likely significant effects to European MDR1224Rp005F01 40

47 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Policy Measures (private and public) e.g. workshops. Impact Assessment and Mitigation Sites as this relates to provision of information. Regulation Keep abreast of international developments in regulation aimed at curbing emissions in national vehicle fleets, particularly any proposals aimed at limiting the sale of vehicles which are not zero emissions capable. Review any emerging regulations for application in Irish context. No direct potential likely significant effects to European Sites as this relates to provision of information Discussion of Key Issues Associated with the Implementation of the AFF As discussed in Section 6.3.3, there are three key issues associated with the implementation of the AFF. These are discussed under their relevant headings below. Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure Installation of refuelling infrastructure has the potential for likely significant effects on European Sites arising from the construction and operation of same. The main effects on European Sites associated with this would be: Direct habitat loss of European Sites if infrastructure was constructed within the Sites; Direct or indirect habitat fragmentation through loss of small patches of habitat within a larger European Site if infrastructure was sited within the Sites. This could also arise from loss of ecological corridors and connectivity, outside of European Sites but which support the functioning of the European Sites, such as loss of hedgerows, treelines or small wetlands through clearance of sites to construct alternative fuel infrastructure. Indirect disturbance to QI/SCI habitats and/or species of European Sites located in the vicinity during construction and operation of the infrastructure e.g. via noise or human disturbance. Impacts on water quality both ex-situ and in-situ arising from construction works, such as sedimentation and release of pollutants from contaminated land which could impact water dependent habitats and species. This is also relevant to operation of the alternative fuel infrastructure, for example surface water run-off posing a threat to water quality. Electricity: Infrastructure for electric vehicles (EVs) is already established in Ireland, with the Electricity Supply Board (ESB) having rolled out ecars in 2010 including the supporting charging infrastructure. This was further expanded on in 2013 via a cross border project to expand the fast (rapid) charge network. The AFF (Chapter 7, Table 7) illustrates the national targets for EV recharging points up to The increase in the number of recharging points required is relatively low overall due to the existing recharging network, with the exception of private recharging points. The AFF states that a large proportion of residents in Ireland have access to driveways and private car parking spaces capable of installing private chargers, thus reducing overall demand on the public charging network. As such, as this infrastructure would be located within existing developments (i.e. residential dwellings), there would be limited potential for likely significant effects on European Sites. However, as there is no MDR1224Rp005F01 41

48 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport explicit geographic context outlined in the AFF there remains a potential (albeit slight) for likely significant effect on European Sites. Shore-side electricity infrastructure is highlighted in the AFF in relation to TEN-T ports of Dublin, Cork and Shannon-Foynes. Shannon-Foynes is located within two European Sites (Lower River Shannon SAC and River Shannon and River Fergus Estuaries SPA), with Dublin and Cork ports and/or shipping lanes located adjacent to or adjoining a number of European Sites (including South Dublin Bay and River Tolka Estuary SPA, North Bull Island SPA, North Dublin Bay SAC, South Dublin Bay SAC, Cork Harbour SPA and Great Island Channel SAC). Therefore there is potential for likely significant effects on European Sites as a result of installing shore-side electricity infrastructure such as direct habitat loss or disturbance to QI/SCI species during construction/operation. Cumulative effects with existing port operations is also a potential for likely significant effects. Natural Gas (CNG and LNG): It is anticipated that natural gas will form an interim solution as an alternative fuel for larger vehicles i.e. freight and buses. There is no LNG terminal in Ireland [although planning permission was granted previously for Shannon LNG in the Shannon Estuary] therefore LNG would have to be imported into Ireland via truck or shuttle carrier, with the nearest LNG terminal located in Milford Haven, UK. LNG is not used in heavy goods vehicles in Ireland. There are no LNG projects planned for TEN-T ports and LNG is not likely to form a large part of the fuel mix for road transport in Ireland going forward and as such no targets have been set in the AFF for numbers of LNG vehicles. The target for numbers of CNG refuelling stations up to 2030 is outlined in Chapter 7, Table 8 of the AFF. The target for the numbers of CNG refuelling stations to be rolled out by 2030 is relatively low when considered on a national scale. This is to facilitate a skeleton refuelling network across the country. As a separate project, GNI as part of a CER supported initiative, is to build three new CNG refuelling stations in The Alternative Fuels Infrastructure Directive requires a minimum number of CNG stations to be located in strategic urban and suburban locations, with a total of 70 fast fill stations to be deployed nationwide by As there is no explicit geographic context outlined in the AFF there is potential for direct and indirect likely significant effects on European Sites as a result of construction and operation of the re-fuelling infrastructure. LPG: Table 2 in Chapter 5 of the AFF outlines that there are approximately 1,500 LPG vehicles circulating in the Republic of Ireland at present. However, LPG does not offer a long term solution in terms of emissions reductions and decarbonisation. Although the AFF supports LPG propelled vehicles, it does not require targets for LPG infrastructure to be set. As such there is no direct potential likely significant effect on European Sites as a result of construction/operation of LPG refuelling infrastructure. Hydrogen: Hydrogen is not expected to deliver mass market uptake up to 2030 as refuelling infrastructure and vehicles remain prohibitively expensive when compared to the demand. Ireland is therefore not planning to establish a hydrogen refuelling network at present. Therefore, there is no direct potential likely significant effect on European Sites as a result of construction/operation of hydrogen re-fuelling infrastructure. Biofuels: Biofuels are currently in use in Ireland through the Biofuel Obligation Scheme (BOS). The scheme places an obligation on all suppliers of mineral oil to ensure that a proportion of the motor fuels (petrol or diesel) that they place on the market in Ireland is sourced from renewable sources e.g. bioethanol or biodiesel. The Energy (Biofuel Obligation and Miscellaneous Provisions) Act 2010 gives effect to the BOS. The obligation has increased from an initial 4% (by volume) to 6% in 2013 and the National Oil Reserves Agency Act 2007 (Biofuel Obligation Rate) Order 2016 increased the MDR1224Rp005F01 42

49 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport obligation to 8%, effective from 1 st January This will drive a continued increase in the biofuel obligation to reach 10% by As policy on biofuels is already addressed through the implementation of the Renewable Energy Directive and Fuel Quality Directive, with the BOS acting as the mechanism by which a progressive increase in usage will be facilitated, no targets are being set out in the AFF in relation to refuelling infrastructure for biofuels. Also, as these fuels are currently within the fuel mix and utilise the existing petrol/diesel refuelling infrastructure no targets have been set for refuelling infrastructure. Therefore, there is no potential likely significant effect on European Sites as a result of construction/operation of biofuel re-fuelling infrastructure. Synthetic and Paraffinic Fuels: Although the use of these fuels is supported by the AFF, no infrastructure is required. It is most likely that the fuels will be blended into diesel supplies and, similar to that of biofuels, the existing petrol/diesel refuelling infrastructure will be utilised for refuelling. Therefore, there is no potential likely significant effect on European Sites as a result of construction/operation of re-fuelling infrastructure. Land Use Changes as a Result of Indirectly Encouraging the Increased Use of Alternative Fuels It is acknowledged that incentivisation schemes could lead to indirect likely significant effects on European Sites through an increased demand for alternative fuels. This could lead to an increased demand for electricity generation facilities or land required for alternative fuel feedstock and resultant effects on European Sites dependent on the alternative fuel concerned. This is particularly relevant in relation to electricity, biofuels and synthetic and paraffinic fuels 11. As such these are the only alternative fuels considered in this section. Electricity generation plants in Ireland are powered by a number of materials including peat, coal, oil, natural gas and biomass. Currently there are 4 main electricity generation stations that utilise solid fuels in Ireland. Three of these stations - Edenderry, Lough Ree (Lanesborough) and Shannonbridge are peat-fired power plants. The fourth, at Moneypoint, is a coal-fired plant. The Edenderry Power Station in Offaly is owned by Bord na Móna and co-fires with a mixture of peat and biomass. Volumes have increased year-on-year with just over 1,000,000 tonnes of peat and biomass co-fired in 2015, of which 320,000 was biomass. The stations at Lough Ree and Shannonbridge are owned by ESB Group. Almost 890,000 tonnes were combusted at Lough Ree in 2015, which was a 9% increase on the previous year. More than 1.2 million tonnes of peat were combusted at Shannonbridge in 2015, which was an 8% increase on At Moneypoint, almost 1.9 million tonnes of coal was combusted in 2015, which was a 21% increase on Extraction and production of these materials in itself can result in habitat loss/land use changes. In the case of peat extraction, this can directly impact on Annex I peatland habitat types, as defined by the Habitats Directive, both within and outside of European Sites. Biomass production can change land use and has the potential to result in a range of likely significant effects on European Sites such as habitat loss/fragmentation to grow crops and habitat deterioration as a result of water quality changes from run-off of fertilisers or sediment run-off into nearby watercourses impacting downstream European Sites. Construction of electricity generation facilities can result in likely significant effects on European Sites through land use change, similar to those outlined under Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure previously in Section An increased demand on electricity resulting in a requirement for more electricity generation facilities to be 11 which can be produced from biomass MDR1224Rp005F01 43

50 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport constructed across the country also has the potential for cumulative likely significant effects on European Sites. As Ireland transitions to decarbonising the electricity generation sector there will be an increased reliance on renewable electricity infrastructure. Renewable electricity infrastructure, such as wind farms and hydro power facilities, can result in likely significant effects on European Sites through land use change, similar to those outlined in Construction, Upgrade and/or Operation of Alternative Fuels Re-fuelling Infrastructure previously in Section For example, many wind farm sites are located in upland areas of peatland/heathland, which can correspond to Annex I habitats types within and outside of European Sites, resulting in habitat loss. Construction and operation of these sites can also lead to habitat deterioration for example through machinery access, surface water run-off changes resulting in erosion or increased exposure of habitats as a result of vegetation disturbance. During operation, wind farms can have direct impacts on species including SPA birds through collision with turbines resulting in mortality and ex-situ effects by creating barriers to movement such as altering migratory routes of SPA birds to avoid wind farms (which in turn could result in decreased survival rates of the birds on migration due to increased expenditure of energy). There is a body of evidence in relation to impacts on sensitive species, such as hen harrier and some bat species from the provision of renewable wind infrastructure in sensitive habitats. Similarly other renewable electricity infrastructure such as hydro power and tidal power can result in direct impacts to European Sites through habitat loss as they may be located within rivers/estuaries designated as SACs or may result in direct mortality of QI species such as fish as a result of collision with infrastructure e.g. turbines, and can create barriers to movement hindering migration of species such as fish species or marine mammals. Therefore there is potential for indirect likely significant effects on European Sites as a result of the AFF. Emissions to Air as a Result of Indirectly Encouraging the Increased Use of Alternative Fuels In terms of increasing the use of alternative fuels one of the main indirect potential likely significant effects with regard to European Sites is the emissions to air. Each fuel type has varying emissions characteristics dependent on the method of generation of the fuel and also on combustion. A summary of the main characteristics of emissions to air from each alternative fuel type is presented in Table Table 6.12 Air Emission Characteristics for Alternative Fuels Alternative Fuel Electricity 12 Hydrogen Direct Emissions (from combustion) N/A Water vapour, warm air, hydrogen gas. Indirect Emissions (from generation) From power generation sector: Fossil fuel burning to generate electricity emits NO x, SO x, CO, CO 2 and PM10. Production is energy intensive. A number of methods of generation can be used and emissions Comparison to Petrol/Diesel Dependent on fuel type used in powergen sector. If renewable sources used (e.g. wind, hyrdo), zero emissions. If peat, coal, gas etc. used emission levels are similar but not proportional (i.e. net reduction in emissions). At 10% usage of EV's, net reduction in CO 2. Reduced PM, NO x, SO x, VOC's, hydrocarbons, CO, CO 2, PAH's, etc. 12 Brady and O Mahony, (2011). MDR1224Rp005F01 44

51 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Alternative Fuel Direct Emissions (from combustion) Biofuels 13 PM, VOC's, PAH's, NO x, CO, hydrocarbons Synthetic and Parrafinic Fuels 14 Natural (LNG CNG) 15 Gas and Liquid Petroleum Gas (LPG) 16 Typical hydrocarbon emissions (i.e. similar to petrol and diesel): NO x, CO, CO 2, SO 2, PM NO x, CO 2, CO Typical hydrocarbon combustion emissions (NOx, CO, CO 2, SO 2, CH 4, N 2 O etc) but less PM. Indirect Emissions (from generation) would vary accordingly. Production - land use change (decreased carbon sinks). Use/Transport - imported biofuels and feedstock and transporting biofuels internally (CO 2 emissions). From commercial manufacture (i.e. energy production to power processing of feedstock). Extraction leakages - methane (CH 4 ) leaks at extraction points. Importation of fuel. Importation of fuel Comparison to Petrol/Diesel Increased NOx emissions and acetaldehyde and formaldehyde (for E85*). 79% reduction in carbon intensity. E10 has higher NO x emissions than E0 gasoline. Reduced benzene and PM emissions. Higher cetane number so lower emissions and free from sulphur. Reduced emissions of benzene and toluene. Lower NO x, SO x and decreased PM levels. CO 2 emissions can be 40-90% lower than petrol/diesel CO 2 emissions. Road studies showed 40% less PM, 20% less NO x, up to 60% less HC (hydrocarbons) and up to 75% less CO (carbon monoxide). CNG has similar emissions to petrol, but slightly lower PM. Compared to diesel lower NO x and PM than diesel. Higher CO compared to diesel* but lower NOx, and PM than diesel. Lower CO and NOx than petrol. Lower PM emissions. (Note: LPG has higher GHG emissions than LNG and CNG). (*contradictory study showed 8% lower CO emissions compared to diesel). Overall (Table 6.12) it can be seen that in comparison to petrol and diesel run vehicles, alternative fuel run vehicles would result in a net positive in terms of emissions to air. With reference to the targets of the AFF, the main issues in relation to emissions to air associated with each alternative fuel type are discussed below. Electricity: EVs use electricity stored in a battery pack to power an electric motor. Therefore there are no direct tailpipe emissions to air from the EVs themselves, and hence no potential likely significant effects on European Sites from the use of EVs. On comparison with petrol/diesel fuelled vehicles, which accounts for the primary fuel source for vehicles in Ireland currently, EVs would be considered to have a positive impact on European Sites. This is mainly with reference to a reduction in combustion related gases (e.g. NO x, CO, CO 2 ) and PM. 13 Niven, (2005). 14 ASFE, (2016a & 2016b). 15 Cathles, L. M., (2012). 16 USEPA, 1995; Raslavičius, et. al. (2014). MDR1224Rp005F01 45

52 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport However, there exists a potential for indirect potential likely significant effects on European Sites dependent on the method of electricity generation used. Table 6.13 is taken from the SEAI Energy in Ireland (SEAI, 2015) and outlines the primary energy inputs for fuel generation. Also listed in the table are selected Tier 1 emission factors from the European Environment Agency EMEP/EEA air pollutant emission inventory guidebook 2016 (Sector 1.A.1 Energy Industries). These emission factors are European aggregates but are used here as an illustration of the extent of emission of combustion gases associated with each fuel used for electricity generation. Table 6.13 Primary Fuel Inputs for Electricity Generation 2014 and EEA Tier 1 Emission Factor Fuel Total Primary Energy Share 2014 (ktoe) NO x (g/gj) SO x (g/gj) PM 10 (g/gj) Peat (Brown Coal) , Coal (Hard Coal) Natural Gas 1, Oil Wind Hydro Other Renewables* Electricity Imports 185 Not specified *Emission Factors listed for Other Renewables only relate to biomass. It is unknown what proportion of Other Renewables relates to biomass. It can be seen from Table 6.13 that Ireland is currently reliant on fossil fuels for electricity generation with a small proportion of the generation arising from renewable sources; peat (13%), coal (22%), natural gas (45%), oil (1%), wind (10%), hydro (1%), other renewables (3%), electricity imports (4%). The emission factors outlined in the table above illustrate how each source of power compares in terms of emissions to air when combusted and shows that peat has the highest emissions to air followed by coal, oil and natural gas. Biomass has a mixed performance relative to the fossil fuels but emits more PM than any of these fuels. As referenced above, there are four main electricity generation stations in Ireland that utilise solid fuels. Three of these stations - Edenderry, Lough Ree (Lanesborough) and Shannonbridge are peatfired power plants. The fourth, at Moneypoint, is a coal-fired plant. The Edenderry Power Station in Offaly is owned by Bord na Móna and co-fires with a mixture of peat and biomass. By using these sources of fuel to generate the electricity for EVs, there is a potential indirect negative impact on European Sites as a result of ongoing air emissions [albeit controlled by license requirements placed on these energy generators]. This potential for impact will continue in the short-medium term until the mix of fuel sources shifts away from fossil fuels toward renewable sources. The source/production of the feedstock for power generation must also be considered. For example, biomass production in itself has the potential to result in a range of likely significant effects on European Sites such as habitat loss/fragmentation to grow crops and water quality changes as a result of run-off of fertilisers or sediment run-off into nearby watercourses impacting downstream European Sites. The method by which the biomass fuel is then transported to the electricity generation facility, and distance over which it must be transported can also have resultant likely significant effects on European Sites e.g. emissions to air. It is also widely accepted that peatlands MDR1224Rp005F01 46

53 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport act as effective long term carbon sinks and therefore loss of peatlands sites can result in liberation of CO 2 into the atmosphere. In effect, although EVs represent a positive step in decarbonising transport, the source of the electricity generation to service an increased demand for electricity as a result of increased numbers of EVs in the national fleet has the potential for likely significant effects on European Sites. Natural Gas (CNG and LNG): Combustion of natural gas can lead to emissions of CO, CO 2, NO x and PM, however, on comparison with the current diesel and petrol fleet there would be a resultant net positive in terms of reduction in emissions. The introduction of biogas, produced from anaerobic digestion or landfill gas, blended into CNG or on its own would also result in a net positive especially in terms of emissions to air. A biomethane and CNG blend can improve the emissions profile of the CNG. LNG has to be imported to Ireland, with the nearest LNG facility being in the UK, therefore there are associated emissions from the transport of LNG via land or sea. LNG would be envisaged to potentially support maritime ports and heavy goods vehicles in the future. However, at present it is not an entirely feasible option and targets for LNG infrastructure are not being set as part of the AFF, therefore there will be no resultant indirect emissions. Hydrogen: Production of hydrogen is an energy intensive process with a number of methods used in its production e.g. natural gas reforming which generates CO 2 and electrolysis of water. Therefore the extent of the emissions from the generation process is dependent on the method used, and the power source to source that generation process e.g. electricity generated by fossil fuel versus renewable sources. There are no direct tail pipe emissions from hydrogen powered vehicles except water vapour and warm air. If there was a national fleet of hydrogen vehicles it could have the potential to emit amounts of water vapour large enough to affect local or regional distribution of water vapour. There could be potential to affect local or regional humidity levels which could lead to changes in temperate and precipitation patterns which in turn could have likely significant effects on QI/SCI habitats and species of European Sites. Pielke et al. (2003) urge that careful calculations be made to ensure we don't trade one problem for another in terms of diesel/petrol emissions to water vapour emission, but Keith and Farrell (2003) assert the effects of water vapour will be insignificant, since they are not emitted in the stratosphere. The AFF is not promoting hydrogen production plants or hydrogen as a fuel type up to 2030 so as such it is not a concern for the current plan. However, the AFF does support feasibility studies into establishing a hydrogen re-fuelling network. Therefore, there exists potential for likely significant effects on European Sites. Biofuels: The AFF does not outline any policies/targets in relation to the uptake of biofuels. This has already been addressed through the implementation of the Renewable Energy Directive and the Fuel Quality Directive and is facilitated through the BOS. The Bioenergy Plan is currently in preparation and will also support this. Therefore, there is no potential for likely significant effects on European Sites as a result of the AFF in relation to biofuels. LPG: The production and availability of LPG is increasingly becoming worldwide, and there are large storage facilities available in the UK and Europe. LPG is imported into Ireland for use, and distributed by tankers across Ireland, therefore there are associated emissions from the transport of LPG via land and sea. Combustion of LPG leads to emissions of combustion gases similar to that of MDR1224Rp005F01 47

54 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport petrol/diesel combustion such as CO, CO 2, NO x and to a lesser extent PM. The extent of emissions depends on the volatility of the LPG coupled with the efficiency of the engine. However, on comparison with the current diesel and petrol fleet there would be a resultant net positive in terms of reduction in emission. Synthetic and Paraffinic Fuels: Synthetic and paraffinic fuel production and usage is in its infancy in Ireland. Synthetic fuel can be produced from a range of resources including natural gas, biomass, coal, plastic and hydrogenated vegetable oil. Paraffinic fuels are also made from a wide variety of feedstocks, namely biomass to liquid, gas to liquid and hydrogenated vegetable oil. Emissions as a result of generation and combustion of these fuels will greatly depend on the process applied and feedstock used. They are blended with petrol and diesel and therefore will emit similar combustion gases to that of petrol and diesel. However, they burn more efficiently, have a low sulphur content and lack of aromatic content resulting in lower emissions of SO 2, NO x, CO 2 and PM compared to petrol and diesel. On comparison with the current diesel and petrol fleet there would be a resultant net positive in terms of reduction in emissions associated with these fuels. A number of the potential likely significant effects on European Sites as a result of emissions to air by alternative fuels are discussed below. Studies focusing on the impact of alternative fuel emissions on habitats and species protected under the Habitats Directive are limited, especially in Ireland. A number of studies have been carried out in the UK and other European countries which have been consulted in place of Irish studies, owing to the fact that the countries share many common habitats as listed on the Habitats Directive, have similar annual environmental conditions and currently have and are expected to adopt similar alternative fuel usage in line with EU Directive 2014/94/EU on the deployment of alternative fuels infrastructure. The key effects on European Sites associated with fuel combustion are; nitrogen/sulphur deposition leading to acidification and eutrophication of soils/water, deposition of particulate matter leading to vegetation damage and increased atmospheric CO and CO 2 accelerating climate change. A number of habitats have been studied for impacts on biodiversity resulting from air quality impacts and are summarised in Table Table 6.14 Habitats experiencing a decline in biodiversity as a result of air pollution (Adapted from NRA, 2011) Habitat Temperate and boreal forests Artic, alpine and subalpine scrub "U" Calluna dominated wet heath (upland moorland) "L" Erica tetralix dominated wet heath Links with Annex I habitat occurring in Ireland Homology with temperature woodlands (91A0, 91D0, 91E0 & 91J0) Possible homology with Alpine and Boreal heath (4060) Wet heath (Calluna dominated) (3160) Wet heath (Erica tetralix dominated) (3160) Impact on Biodiversity Increased survival of harmful exotic pests and diseases and changes in ground vegetation and mycorrhiza Decline in lichens, mosses and evergreen shrubs* Decreased heather dominance, decline in lichens and mosses Transition from heather to grasses (i.e. loss of species) Cause Nitrogen CL kgn/ha/yr Nitrogen CL 5-15 kgn/ha/yr Nitrogen CL kgn/ha/yr Nitrogen CL kgn/ha/yr MDR1224Rp005F01 48

55 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Habitat Links with Annex I habitat occurring in Ireland Dry heaths Dry heath (4030) Heath (Juncus) meadows and humic (Nardus stricta) swards Inland dune siliceous grasslands Inland dune pioneer grasslands Molinia caerulea meadows Rich fens * Expert Opinion Species-rich Nardus upland grassland (6230) Fixed dunes (grey dunes) (2130) Dune slack (2190) Dunes with creeping willow (2170) Embryonic shifting dunes (2110) Marram dunes (white dunes) (2120) Molinia meadows (6410) Alkaline fens (7230) Cladium fen (7210) Impact on Biodiversity Transition from heather to grasses and decline in lichens Decrease in bryophytes and decreased diversity* Increase in tall grasses and decrease in diversity* Decrease in lichens* Decrease of bryophytes and decreased diversity* Decrease of characteristic mosses and decrease in diversity* Cause Nitrogen CL kgn/ha/yr Nitrogen CL kgn/ha/yr Nitrogen CL kgn/ha/yr Nitrogen CL kgn/ha/yr Nitrogen CL kgn/ha/yr Nitrogen CL kgn/ha/yr Atmospheric deposition of sulphur and nitrogen compounds causes acidification of soil and surface waters. It has also been found that particulate matter (PM) deposition can result in acidification of soils (Bhattacharjee, et al., 1999). In 2010, 7% of land area in the EU-28 (28 EU Member States) exceeded acidification critical loads and this is projected to decrease to 4% by 2020 (EEA, 2015c). Deposition of sulphur and nitrogen compounds also causes eutrophication of freshwater and saltwater systems (EEA, 2015c). A European workshop was conducted between the EU member states in 2009 to assess the impacts of nitrogen deposition on the Natura 2000 network of sites (Bell, 2013). The main findings/outcomes of the workshop were: Nitrogen deposition is a major threat to European biodiversity, including sensitive habitats listed under the Habitats Directive ; The magnitude of the threat to European biodiversity is owning to the naturally occurring low nitrogen supply within many of the Annex I habitats. Therefore fertilisation by increased nitrogen deposition alters the nutrient balance and results in the loss of the most sensitive species and their replacement by invasive species; Nitrogen deposition results in a net loss of overall numbers of species; Exceedance of critical loads for nitrogen is widespread across Europe and there is strong evidence (field and experimental) of the associated impacts. Nitrogen deposition, as a result of NO x emissions, causes many alterations to vegetation communities. It has been found that the number of species at risk within acidic and calcareous grasslands increased at nitrogen deposition rates greater than 5-10 kg N ha-1 yr -1 (JNCC, 2011). Increases of up to 50% in canopy height at N-deposition rates of kg N ha -1 yr -1 (Stevens, et al., 2010) and an increase in the occurrence and abundance of competitive species have also been MDR1224Rp005F01 49

56 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport documented (JNCC, 2011). The JNCC (2011) also found that increased N-deposition on calcareous grasslands resulted in decreased species richness, forb and bryophyte cover and an increase in grass cover. This results in an overall decline in biodiversity. The European Environment Agency (EEA) highlight that NO x emissions contribute to the acidification of soil, lakes and rivers, causing loss of animal and plant life and biodiversity (EEA, 2015a). Similarly the EEA (2014) identified one of the main pressures on grassland ecosystem biodiversity was airborne nitrogen, amongst other pressures such as habitat fragmentation, conversion of land for biofuel crop and afforestation. Airborne nitrogen was identified to encourage the establishment of competitive species, favour species poor communities (i.e. reduced diversity) and reduce the structural density of grasslands through acidification and eutrophication. Nitrogen deposition is known to be affecting acidic and calcareous grasslands, heathlands and bogs (JNCC, 2011). Past studies (Maskell, et al., 2010; Stevens, 2004; Stevens, et al., 2010) of acid grasslands experiencing increased N-deposition showed a clear decline in species richness. This decline has been attributed to a reduction in the cover and occurrence of forb species (Dupré, et al., 2010; Maskell, et al., 2010) as a result of increased nitrogen inputs. Unlike acidic (and calcareous) grasslands, heathland showed both negative and positive relationships of canopy height with increased N-deposition. Therefore, these changes in canopy height are more likely to be due to sitespecific factors. However, there is still a trend of increased grass cover and decreased forbs, lichens, bryophytes and shrub cover (JNCC, 2011) in response to elevated nitrogen. For bog habitats, no evidence of impact on indices of ecological function at N-deposition rates below 10 kg N ha -1 yr -1 was found. At kg N ha -1 yr -1 and kg N ha -1 yr -1 there is also no evidence of an increase in the occurrence of competitive plants or an increase in productivity (JNCC, 2011). This is likely due to the differing natural concentrations of nitrogen in each of these habitats. Payne, et al., (2014) showed that heather moorlands are impacted by nitrogen deposition, with air pollution by sulphur and nitrogen being correlated with lower species richness. A statistically significant negative relationship between total species richness and cumulative nitrogen deposition in all surveys (P<0.05) was found. It was concluded that acidification, rather than eutrophication, was the dominant driver of species composition change (Caporn, et al. 2014). Another study focusing on the impacts of N-deposition on Calluna Moorlands and Scottish Montane habitats was carried out. With increasing nitrogen deposition the species richness of bryophytes declined strongly in the Calluna Moorland Survey (CMS) and showed an increase (together with cover) in the Scottish Montane Survey (SMont). It is possible that the inconsistency between the CMS and SMont results was due to different ranges, as well as differing cumulative doses of N-deposition; the strongest decline in species richness in the CMS occurred at the highest levels of N deposition (RoTAP, 2012). Forests and woodlands have long been identified as a habitat likely to be impacted by nitrogen deposition. Forest decline occurs as a result of acidification of soil (Ulrich, et al., 1979) due to interception of atmospheric pollutants (such as those emitted from biomass combustion). The EEA have stated that acid deposition of S and N compounds played a significant role as predisposing or contributing factors leading to the observed decline in trees (EEA, 2014). Forest damage and decline, resulting in effects to the diversity of the ecosystem, has also been attributed to PM deposition (Rai, 2016). Nitrogen addition experiments have been carried out across Europe (Bobbink, et al., 2010; Nordin, et al., 2011) in grasslands, wetlands, (sub) Arctic and alpine vegetation. A clear negative-log relationship between exceedance of empirical nitrogen critical loads and plant species richness has been found (Bobbink, et al., 2010). Exceedance of critical N-deposition loads has been linked to MDR1224Rp005F01 50

57 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport reduced plant species richness and this trend can be seen occurring across a broad range of European ecosystems (Nordin, et al., 2011, Hicks, et al., 2011). The impacts of nitrogen deposition on biodiversity across a number of European habitats (some of which have links to habitats listed under the Habitats Directive) has been summarised in Table 6.15 (taken from Nordin, et al. (2011)). Table 6.15 Examples of habitat changes as a result of nitrogen deposition for some European ecosystems (summary, adapted from Nordin, et al., 2011). Habitat Artic and Alpine ecosystems Boreal forest Temperate forest Temperate heathlands and grasslands Mediterranean vegetation Effect Decreased abundance of bryophytes and lichens and increased growth of graminoids. Major changes in ground vegetation species composition but no decline in total plant species richness (i.e. decline in bryophyte, lichen and dwarf-shrub species but increase in graminoids and herbs). When combined with deforestation, N-induced impacts will be magnified. Initial increase in plant biomass/cover but an overall decrease in plant species richness and species evenness resulting in a loss of biodiversity. Heathlands: dwarf-shrub growth is increased but bryophyte and lichen growth declines. When heathland is subject to management or increased herbivory, dwarf-shrub dominance declines and is succeeded by grass species. Grasslands: species loss (particularly, rare species) occurs. This is particularly visible in acid grasslands (UK). Increase in invasive grasses and resulting decline in species richness due to loss of native vegetation species. Major shifts in lichen communities occur also. Emissions of PM can have many detrimental effects on vegetation (Beckett, et al., 1998; Rai, 2016). Rai (2016) stated that PM may adversely affect biodiversity, in particular urban forests. Alterations to the physical structure of vegetation have been found to occur as a result of PM deposition; a significant source of damage to trees, by PM pollution, can be the abrasive action of the turbulent deposition of the PM (Das, et al., 2012; Hirano, et al., 1995; Kulshreshtha, et al., 1994). Kulshreshtha, et al., (1994) showed this to have increased callus tissue formation on leaf surfaces. The increased deposition of atmospheric PM has also been shown to result in the occlusion of stomata, thereby decreasing the efficiency of gaseous exchange (Beckett, et al., 1998; Das, et al., 2012; Hirano, et al., 1995). The formation of a crust on leaves and bark surfaces has also been observed due to PM deposition, with the crust disrupting physiological processes, such as bud break, pollination and light absorption/reflectance (Beckett, et al., 1998). Although fine PM deposition has been found to provide nutrients to vegetation, it also changes leaf surface properties, increases the duration of surface wetness and can result in modification of the habitat for epiphytic organisms, which may lead to increased risks from pathogens (Cape, 2008; Manning and Feder, 1980; Shkaraba and Perevedentseva, 1991). Therefore, PM can result in likely significant effects to habitats and species within European Sites. Several pollutants associated with alternative fuels emissions have a high global warming potential (GWP), such as carbon dioxide and nitrous oxide, whereas others act as precursors to greenhouse gases (GHGs). One such example is carbon monoxide (CO). When in the atmosphere CO reacts with hydroxyl radicals (OH - ) to form carbon dioxide (CO 2 ), which has a much higher GWP than CO. Along with this increase in CO 2, concentrations of atmospheric methane also increase when CO concentrations are elevated. This is due to the decreased levels of hydroxyl radicals for the methane MDR1224Rp005F01 51

58 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport to react with, which would typically remove methane from the atmosphere (i.e. the formation of CO 2 leaves fewer OH molecules in the atmosphere for methane to react with, thereby increasing methane s concentration) (ESSEA, 2010). Along with CO, NO x emissions contribute indirectly to global warming. When CO and NO x emissions are elevated in the atmosphere, the photochemical oxidation of CO produces tropospheric ozone (O 3 ). Ozone has an extremely high GWP and therefore contributes to global warming (California Institute of Technology, 2016). Global warming and climate change are recognised threats to biodiversity and hence to European Sites and habitats and species therein. 6.5 ASSESSMENT OF IN COMBINATION EFFECTS WITH OTHER PLANS OR PROJECTS The assessment of in-combination effects with other plans or projects is a crucial and often difficult aspect of Article 6(3) assessment, particularly at the plan level. This step aims to consider the policy and framework within which the AFF is being developed and to identify at this early stage any possible in-combination effects of the proposed AFF with other plans and projects. In theory, there are many other plans / projects that interact with or have the potential to combine pressures and threats to European Sites, however, the in-combination assessment is a matter of applying a practical and realistic approach. In line with MN2000 guidance, a stepwise approach has been taken to consideration of incombination effects as follows: Identify plans / projects that might act in combination; Identify the types of impact that might occur; Define boundaries of the assessment; Identify pathways for impact; and Impact prediction and assessment. While the AFF sits within a larger planning framework and it focuses on alternative fuels usage and direct tailpipe emissions, there are other plans/programmes that deal with the source of the alternative fuels. Therefore the AFF must take account of other plans/programmes and vice versa. The plans considered to hold potential for in-combination effects (positive and negative) are further explored in Table The focus of in-combination impact assessment is directed towards plans where the cumulative impacts have the potential to magnify the impact upon European Sites and their constituent features of interest. Table 6.17 presents a brief summary of the effects arising out of the cumulative impact of principal environmental protection legislation. MDR1224Rp005F01 52

59 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Table 6.16 In-Combination Impacts with Other Plans and Strategies National Planning Framework Plan Key Types of Impacts Potential for In-combination Effects and Mitigation The plan will succeed the National Spatial Strategy. It will provide a framework for national planning and will focus on economic development and investment in housing, water services, transport, communications, energy, health and education infrastructure. National Mitigation Plan The primary objective of this plan will be to monitor implementation of current measures to 2020 and identify additional measures in the longer term to reduce greenhouse gas emissions and progress the overall national low carbon transition agenda to Habitat loss or destruction; Habitat fragmentation or degradation; Alterations to water quality and/or water movement; Alteration to air quality; Disturbance. Habitat loss or destruction; Habitat fragmentation or degradation; Alterations to water quality and/or water movement; Alteration to air quality; Disturbance. The plan will be subject to AA but is not yet completed. The potential for incombination effects are unclear as the plan is not sufficiently developed at this stage, however, would be expected to be in relation to requirement for infrastructure. However, it is a policy of the AFF to ensure the National Planning Framework takes account of the AFF. This plan is undergoing its own AA but it is not yet completed. The potential for in-combination effects are unclear as the plan is not sufficiently developed at this stage, however, the thrust of the plan is positive and would not be expected to conflict with any aspects of the AFF but to positively influence it going forward. National Renewable Electricity Policy and Development Framework The main objective of this plan will be to guide the development of renewable electricity projects to ensure Ireland meets its future needs for renewable electricity in a sustainable manner. Habitat loss or destruction; Habitat fragmentation or degradation; Alterations to water quality and/or water movement; Alteration to air quality; Disturbance. This plan is undergoing its own AA but it is not yet completed. A key issue to be addressed will be the method of renewable electricity generation and associated ecological impacts. The potential for in-combination effects are unclear as the plan is not sufficiently developed at this stage, however, would be expected to be in relation to electricity generation infrastructure. However, the main thrust of the plan is positive and would not be expected to conflict with any aspects of the AFF but to positively influence it going forward. The plan will have to take account of the demands of the AFF. Bioenergy Plan This plan will underpin the development of the sector in the period up to 2020 and lay Habitat loss or destruction; Habitat fragmentation or degradation; The plan is undergoing its own AA but it is not yet completed. The potential for in-combination effects is expected to be in relation to habitat loss and the associated ecological impacts. This plan would not be expected to conflict with MDR1224Rp005F01 53

60 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Plan Key Types of Impacts Potential for In-combination Effects and Mitigation foundations for its longer term growth and in contributing to renewable energy targets. National Renewable Energy Action Plan (NREAP) The NREAP is produced as a requirement of the Renewable Energy Directive, and sets out Ireland s national targets for the share of energy from renewable sources consumed in transport, electricity and heating and cooling in National Climate Change Adaptation Framework 2012 The framework provides strategic focus to ensure adaptation measures are taken across different sectors and levels of government to reduce Ireland's vulnerability to the negative impacts of climate change. Grid25 Implementation Programme The Grid25 Implementation Programme (IP) is a practical strategic overview of how the early stages of Grid25 are intended to be implemented. The IP identifies the best current understanding of those parts of the transmission system that are envisaged as likely to be developed over the next five years. Forests, Products and People. Ireland s Forest Policy - A Renewed Vision Strategic goal is to develop an internationally competitive and sustainable forest sector that Alterations to water quality and/or water movement; Alteration to air quality; Disturbance. Habitat loss or destruction; Habitat fragmentation or degradation; Alterations to water quality; Alteration to air quality; Disturbance Habitat loss or destruction; Habitat fragmentation or degradation. Habitat loss or destruction; Habitat fragmentation or degradation; Disturbance. Habitat loss or destruction; Habitat fragmentation or degradation; Water quality changes; any aspects of the AFF but to positively influence/inform it going forward. This plan was not subject to AA, but some actions arising out of it have since been subject to AA owing to judicial review. The plan is positive in that its aims are to accelerate the uptake on renewable energy, thereby reducing the dependence on fossil fuels and reducing greenhouse gas emissions. Potential for in-combination effects are in relation to habitat loss and the associated ecological impacts. The AFF will contribute to reaching the targets set in the NREAP and as such the plans are complementary. The measures and research as a result of the plan will place a responsibility on all stakeholders to adapt to the severe impacts of predicted climate change. This framework prioritises reducing knowledge gaps through an evidence base and to develop tools to support the adaptation decision-making process. The AFF will contribute towards the plan and as such no significant in-combination effects are envisaged. This Plan was subject to AA. There is potential for in-combination effects with the AFF in terms of infrastructure requirements resulting in habitat loss, fragmentation and degradation and the associated ecological impacts. No significant in-combination impacts are envisaged at plan level. Projects/plans arising from the AFF are required to undergo AA which will ensure no incombination effects further down the planning hierarchy. As a high level policy document, the forestry policy did not undergo AA. Forestry and afforestation are a key element in satisfying the requirement for biomass for electricity generation. There is potential for in-combination effects with the AFF in terms of potential habitat loss, fragmentation and degradation MDR1224Rp005F01 54

61 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Plan Key Types of Impacts Potential for In-combination Effects and Mitigation provides a full range of economic, environmental and social benefits to society and which accords with the Forest Europe definition of sustainable forest management. Forestry Programme Provides Ireland s proposals for 100% state aid funding for a new Forestry Programme for the period. The measures proposed are consistent with Forests, products and people Ireland s forest policy a renewed vision. The Programme identifies the needs of the Forestry sector as: Increase forest cover Increase the production of forest biomass to meet renewable energy targets Support forest holders to actively manage their plantations Disturbance to species. and the associated ecological impacts particularly on sensitive species such as Freshwater Pearl Mussel and Hen Harrier. To address negative effects of forestry: Habitat loss or destruction; Habitat fragmentation or degradation; Alterations to water quality and/or water movement; Disturbance. DAFM are currently developing Catchment Forest Management Plans for eight priority FPM catchments which will contribute to protection of this particular species. The Forest Service s Appropriate Assessment procedures will continue to be applied at project level. Also compliance with the procedures outlined in the updated Forest Service Forestry Schemes Manual underpins this Forestry Strategy. See also mitigation under National Forestry Programme below. The Forestry Programme was subject to its own AA. The programme includes a number of policies for the protection of habitats and species under the Birds and Habitats Directives including: Identifying whether Annex I habitats, Annex I Birds or Annex II species are present in consultation with NPWS and if required, surveys to be carried out before works begin, particularly at sensitive times of year (e.g. breeding season). Forest Management Plan for Priority Freshwater Pearl Mussel Catchments (Forest Service) shall be adhered to once published. There is also a requirement for protection of Freshwater Pearl Mussel catchments through riparian planting and converting coniferous to native woodlands under the Native Woodland Conservation Scheme. Individual forestry proposals will be subject to assessment of their potential impacts prior to consent or licence through the Forest Service Appropriate Assessment Procedure. Provide buffers for afforestation adjacent to areas of wetland Annex I habitats or other water habitats such as blanket mire. Avoid afforestation on high value sites with a high sensitivity in terms of water quality. No significant in-combination impacts are predicted. Rural Development Plan Overgrazing; The Rural Development Plan was subject to its own AA. MDR1224Rp005F01 55

62 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Plan Key Types of Impacts Potential for In-combination Effects and Mitigation Provides a new suite of rural development measures designed to enhance the competitiveness of the agri-food sector, achieve more sustainable management of natural resources and ensure a more balanced development of rural areas. Includes provisions under GLAS; Green Low-Carbon Agri Environment Scheme; Bio-Energy; nutrient management planning; Carbon Navigator software tool Foodwise 2025 Foodwise 2025 strategy identifies significant growth opportunities across all subsectors of the Irish agri-food industry. Growth Projection includes increasing the value added in the agrifood, fisheries and wood products sector by 70% to in excess of 13 billion. Land use change or intensification; Water pollution; Nitrogen deposition; Disturbance to habitats / species; Land use change or intensification Water pollution Nitrogen deposition Disturbance to habitats / species The plan aims to enhance sustainable management of natural resources. Incentives are included to address significant effects on biodiversity, water management and preventing soil erosion. Mitigation in the plan requires that Appropriate Assessment is to be carried out for all individual building, tourism or agricultural reclamation projects, stakeholder engagement and site based monitoring. With the required mitigation in the rural development plan, no significant in-combination impacts are predicted. Foodwise 2025 was subject to its own AA. Growth is to be achieved through sustainable intensification to maximise production efficiency whilst minimising the effects on the environment however there is increased risk of nutrient discharge to receiving waters and in turn a potential risk to biodiversity and Europe Sites if not controlled. With the required mitigation in the Foodwise Plan no significant in-combination impacts are predicted. Green, Low-Carbon, Agri-environment Scheme (GLAS) Agri-environment funding scheme arising from Rural Development Programme Seeks to protect and enhance the rural environment by preserving traditional hay meadows; low-input pastures; minimum tillage; application of agricultural production methods compatible with the protection of the environment. National Peatlands Strategy (NPS) and Raised Bog SAC Management Plan Establishes principles in relation to Irish peatlands in order to guide Government policy. Aims to provide a framework for which all of Land use change Disturbance to habitats / species Habitat loss or destruction; Habitat fragmentation or degradation; Alterations to water quality and/or water movement. The primary purpose of the scheme is to improve environmental quality. No risk of likely significant in-combination effects are foreseen owing to the overarching aim of the scheme in protecting the environment. However, individual plans that are developed in respect of funding are not typically subject to Appropriate Assessment. An Activity Requiring Consent (ARC) system was proposed by NPWS for certain actions under the scheme. Actions outside of the GLAS plan must be notified directly to NPWS. The Raised Bog SAC Management Plan was subject to its own AA. The NPS will ensure protection of peatlands in terms of sustainable peat extraction and land use utilisation e.g. wind farms or forestry. This plan would not be expected to conflict with any aspects of the AFF but to positively interact with it and outline a series of considerations in relation to peatlands. Therefore MDR1224Rp005F01 56

63 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Plan Key Types of Impacts Potential for In-combination Effects and Mitigation the peatlands within the State can be managed responsibly in order to optimise their social, environmental and economic contribution. Aims to meet nature conservation obligations while having regard to national and local economic, social and cultural needs. Regional Planning Guidelines Policy Document which seeks to focus future growth patterns through a strategic planning framework as required under the National Spatial Strategy. River Basin Management Plans Plans to take an integrated approach to the protection, improvement and sustainable management of the water environment. The EPA are responsible for delivery of the 2 nd cycle plans which are currently in prep. Water Services Strategic Plan Overarching strategy for next 25 years in relation to water services planning. National Water Resources Plan (in prep) Framework to deliver a sustainable water supply on a catchment and water resource zone basis, meeting growth and demand requirements and be maintained through drought and critical periods. Habitat loss or destruction; Habitat fragmentation or degradation; Alterations to water quality and/or water movement; Disturbance to habitats/species Provision of new / upgraded infrastructure Land use changes Changes to water quality or quantity [improvements] Habitat loss and disturbance from new / upgraded infrastructure; Species disturbance; Changes to water quality or quantity; Nutrient enrichment /eutrophication. Increased abstractions leading to changes / pressure on existing hydrology / hydrogeological regimes. there is no likely significant in-combination effects foreseen. The Regional Planning Guidelines were subject to Appropriate Assessment. The likely in-combination effects would be expected to be in relation to requirement for infrastructure and associated ecological impacts although no location specific information is presented. No likely significant in-combination effects foreseen due to the fact this plan will help inform where alternative fuel infrastructure may be required moving forward. These strategic plans will be subject to AA and will include a programme of measures which will contribute to achieving objectives set at the local level. These measures will see an improvement of water quality and protection of European Sites and the wider water dependant ecosystems. A strong focus in the second cycle of the RBMP will be on catchment management and stakeholder engagement. Therefore no likely significant in-combination effects are envisaged. The overarching strategy was subject to Appropriate Assessment and highlighted the need for additional plan/project environmental assessments to be carried out at the tier 2 and tier 3 level. Therefore no likely significant in-combination effects are envisaged. The plan will seek to develop sustainable water supplies but must consider particularly critical drought periods when assimilation capacity for diffuse runoff may be reduced. The potential for in-combination impacts are unclear as the plan is not sufficiently developed at this stage. MDR1224Rp005F01 57

64 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Table 6.17 In-Combination with Environmental Legislation and Policy Legislation and Policy Potential for In-combination Impacts Water Framework Directive (2000/60/EC) The primary purpose of this Directive and the various pieces of national legislation that have enacted through the implementation of River Basin Management Plans, is to achieve good status for all water bodies, with no deterioration in water body status. EU Groundwater Directive (2006/118/EC) This Directive establishes a regime, which sets groundwater quality standards and introduces measures to prevent or limit inputs of pollutants into groundwater. Nitrates Directive (91/676/EEC) This Directive has the objective of reducing water pollution caused or induced by nitrates from agricultural sources and preventing further pollution. The Integrated Pollution Prevention Control Directive (96/61/EC) Objective is to achieve a high level of protection of the environment through measures to prevent in the first instance or to reduce emissions to air, water and land from industrial sources. European Union Biodiversity Strategy to 2020 Aims to halt or reverse biodiversity loss and speed up the EU's transition towards a resource efficient and green economy as per the Convention on Biological Diversity. Prioritised Action Framework for Natura 2000 ( ) This plan identifies the range of actions needed to help improve the status of Ireland's habitats and wildlife. The Common Agriculture Policy The Common Agriculture Policy through various iterations is the principal policy that drives agricultural management throughout the European Union. It recognises the economic and rural importance of agriculture through a system subsidies and support programmes. No risk of likely significant in-combination effects will result as the primary purpose of the Directive is to improve environmental quality. The proper management of infrastructural development will contribute to achieving the objectives of the WFD as developed through the RBMP. The second cycle of the River Basin Management Plans are in preparation and are anticipated for completion in No risk of likely significant in-combination effects will result as the primary purpose of the Directive is to improve environmental quality. No risk of likely significant in-combination effects will result as the primary purpose of the Directive is to improve environmental quality. No risk of likely significant in-combination effects will result as the primary purpose of the Directive is to improve environmental quality. No risk of likely significant in-combination effects will result as the primary purpose of the Strategy is to halt the loss of habitat and species. Opportunities may exist in the implementation of the Plan to assist in achieving the objectives of the Strategy through reducing loss of habitat and /or disturbance to species that rely on them. No risk of likely significant in-combination effects as this plan is entirely positive in its actions. Some likely significant impacts are addressed through the Rural Development Plan through the requirement for Appropriate Assessment and Monitoring and introducing several pieces of legislation under the Good Agricultural Practice for Protection of Waters (Regulations 2014, S.I. 31/2014). MDR1224Rp005F01 58

65 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport 7 MITIGATION MEASURES To further improve actions contained within the AFF and to address potential negative effects identified in this NIS, mitigation measures have been included in the AFF through an iterative review process throughout the making of the plan and are outlined in Table 7.1. The AFF is a strategic plan which relies to a significant degree on other policy, strategy and plan initiatives to achieve the targets for alternative fuel infrastructure. Many of these have already undergone AA or are undergoing AA with development of specific mitigation which are or will be implemented. The measures committed to in these other plans will be essential to ensuring that the targets of the AFF are met and that the AFF does not have an adverse effect on any European Sites. Table 7.1 AA Mitigation Reference Amendment Location in AFF Proposed New Policy Measure 1 Proposed New Policy Measure 2 Proposed New Measure 3 Include the following European Site Protection Policy: Ensure that all plans and projects [as defined under Part 1 of the Birds and Natural Habitats Regulations 2011, as amended] arising from the AFF are subject to Screening for Appropriate Assessment and/or Appropriate Assessment, whichever is deemed necessary, to ensure there are no likely significant effects on European Sites and/or no adverse effects to European Site integrity. The requirements of Article 6(3) and, where necessary, Article 6(4) of the Habitats Directive must be fully satisfied. Further detail is provided for in Section 7.1. Include the following European Site Protection Policy: All investigative and feasibility studies to be carried out in relation to alternative fuels and alternative fuels infrastructure must include an environmental appraisal which considers the potential effects on the Natura 2000 Network. Further detail is provided for in Section 7.1. Include Siting Criteria text for the protection of European Sites from infrastructural development as a result of the AFF. Proposed text for inclusion is outlined in Section 7.1. Include the following Protection Policy: All infrastructural development arising from the implementation of the AFF must adhere to the Siting Criteria included in Chapter 7 of the plan. Chapter 4 Chapter 4 Chapter CONSTRUCTION, UPGRADE AND/OR OPERATION OF ALTERNATIVE FUELS RE-FUELLING INFRASTRUCTURE Any alternative fuel re-fuelling infrastructural developments will be subject to the appropriate planning development controls in line with the relevant environmental legislation and regulatory processes, with Screening for Appropriate Assessment is required a minimum as a matter of compliance with legislation. Although investigative/feasibility studies would not be subject to planning development controls, the AFF has anticipated the need for these studies to consider MDR1224Rp005F01 59

66 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport potential effects to European Sites at the earliest possible stage. Together with planning development controls, the protective policies committed to in Chapter 4 of the AFF (Proposed New Policy Measure 1 & 2 from Table 7.1 above) will ensure no likely significant effects to European Sites as they require all plans and projects [as defined under Part 1 of the Birds and Natural Habitats Regulations 2011, as amended] arising from the AFF are subject to Screening for Appropriate Assessment and/or Appropriate Assessment, whichever is deemed necessary, to ensure there are no likely significant effects on European Sites and/or no adverse effects to European Site integrity. The requirements of Article 6(3) and, where necessary, Article 6(4) of the Habitats Directive must be fully satisfied and that all investigative/feasibility studies to be carried out in relation to alternative fuels and alternative fuels infrastructure must include an environmental appraisal which considers the potential effects on the Natura 2000 Network. These protective policies have been incorporated into the AFF following iterative review of the emerging AFF by the AA team throughout the plan making process. The commitment to protection of European Sites and the wider environment is further strengthened by the inclusion of Siting Criteria (see below) in relation to alternative fuels infrastructure in Chapter 9 of the AFF, and a protective policy within the AFF to ensure that all infrastructural development arising from the implementation of the AFF must adhere to the Siting Criteria included in Chapter 9 of the plan. The siting criteria have been incorporated into the AFF following iterative review of the evolving plan by the SEA / AA team and will be applied as part of the site assessment process. The inclusion of siting criteria within the AFF will assist in the proper planning and development of future infrastructure and ensure the impact on European Sites and associated species can be minimised, managed and mitigated. Siting Criteria Existing sites (where appropriate) and brownfield sites should be considered in the first instance for any infrastructural development or expansions. Avoid siting alternative fuel infrastructure immediately adjacent to or adjoining European Sites in order to limit the potential impacts and disturbance to habitats and species therein during construction and/or operation. Where this is unavoidable, all development proposals should be accompanied by an Appropriate Assessment Screening and/or Natura Impact Statement, whichever is deemed necessary, which should include, but not be limited to assessing construction related impacts (e.g. water quality), operational related impact (e.g. such as disturbance from noise and water quality) and ex-situ impacts (e.g. roosting/feeding grounds for SPA birds outside of the SPA). In the case of shore side electricity, which may be located within or immediately adjacent to an SAC/SPA, infrastructure should be located on existing built ground/structures where possible. This is to limit the potential impacts and disturbance to habitats and species during construction and/or operation. All shore side electricity infrastructure development proposals should be accompanied by an Appropriate Assessment Screening Report and/or Natura Impact Statement, whichever is deemed necessary, which should be informed by detailed ecological survey data related to the European Sites concerned. It should include, but not be limited to assessing construction/operational related impacts (e.g. habitat loss, water quality) and disturbance related impacts (e.g. noise impacts to birds or increased footfall of ships/people in a certain location). Avoid siting alternative fuel infrastructure in proposed Natural Heritage Areas (pnhas), Natural Heritage Areas (NHAs), Statutory Nature Reserves, Refuges for Fauna and Annex I Habitats occurring outside of European Sites, but which provide a supporting role to European Sites. Where this is unavoidable, all development proposals should be accompanied MDR1224Rp005F01 60

67 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport by an Appropriate Assessment Screening Report and/or Natura Impact Statement, whichever is deemed necessary. In order to protect habitats which, by virtue of their linear and continuous structure (e.g. rivers and their banks, hedgerows) or their contribution as stepping stones (e.g. ponds or small woods), are essential for the migration, dispersal and genetic exchange of wild species, these features will be protected as far as possible from loss or disruption through good site layout and design. To protect river habitats and water quality (including physical habitat and hydrological processes/regimes), ensure that no alternative fuel facilities takes place within a minimum distance of 25 m measured from each bank of any river, stream or watercourse. To protect river habitats, species and water quality ensure that no infrastructure, including clearance and storage of materials, takes place within a minimum distance of 25m measured from each bank of any river, stream or watercourse. To protect water quality, where alternative fuel infrastructure is being developed at existing refuelling infrastructure, ensure that the appropriate tests for contaminated land are carried out and the appropriate mitigation measures are developed prior to the construction of alternative fuel infrastructure. To protect water quality, ensure Sustainable Drainage Systems (SuDS) is applied to any new facility and that site-specific solutions to surface water drainage systems are developed taking account of the alternative fuel type(s) being deployed on the site, and which meet the requirements of the Water Framework Directive and associated River Basin Management Plans. Avoid development of infrastructure in flood risk areas. Reference should be made to the Planning System and Flood Risk Management for Planning Authorities (DECLG/OPW 2009) and the National Flood Hazard Mapping (OPW) while referring to the relevant Flood Risk Management Plan (FRMP). Ensure sites for alternative fuel infrastructure are surveyed for the presence of invasive species (as listed in the Third Schedule of the Birds and Natural Habitats Regulations) prior to infrastructural development, and that strict protocols are applied to prevent the spread of invasive species. Avoid geologically unsuitable areas including karst where practicable, and areas susceptible to subsidence or landslides. 7.2 LAND USE CHANGES AS A RESULT OF INDIRECTLY ENCOURAGING THE INCREASED USE OF ALTERNATIVE FUELS The focus of the AFF is on supporting alternative fuels re-fuelling infrastructure; however discussion on the potential land use changes from the requirement for increased generation of electricity, biofuels and synthetic or paraffinic fuels has been included as it is indirectly linked to the AFF. In terms of guiding the development of electricity generation infrastructure across the nation, there are a number of policy documents that will set the framework for this. Directive 2009/28/EC on the promotion of the use of energy from renewable sources (the RES Directive) establishes a basis for the achievement of 20% renewable energy target by This legislation is driving the shift on electricity generation from fossil fuels to renewable sources with further targets set of 2030 and 2050 under the EU Climate and Energy Package. In this regard, there will be a predicted increase in the requirement for renewables electricity generation infrastructure with a focus on renewable sources of electricity moving forward. The Department of Housing, Planning, Community and Local MDR1224Rp005F01 61

68 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Government is currently preparing the National Mitigation Plan (NMP) which will add further credence to this Directive, by outlining how Ireland will guide electricity generation to move towards decarbonisation of the sector (i.e. from renewable sources). The Department of Housing, Planning, Community and Local Government (DHPCLG, formerly the DECLG) are preparing the National Planning Framework (NPF) which will provide a framework for national planning and which will address energy amongst other topics. The NPF will be subject to Appropriate Assessment. This will ensure that any potential likely significant effects on European Sites as a result of the NPF are identified. The Department of Communications, Climate Action and Environment (formerly the DCENR) is preparing a Renewable Electricity Policy and Development Framework (REPDF) to guide the development of large scale renewable electricity projects on land. It will contribute towards meeting Ireland s future energy/electricity needs, particularly up to 2030 and beyond. Amongst other policies, it will set out policy in respect of environmental considerations and will seek to broadly identify suitable areas where renewable electricity projects can be developed. The REPDF will itself be subject to Appropriate Assessment and will therefore have to assess the potential for impacts to QI/SCI habitats/species within the Natura 2000 Network in relation to identifying potential renewable energy areas across the State and potential for impacts in the context of the content of the REPDF. The usual planning development controls will remain unchanged, with Screening for Appropriate Assessment and/or Appropriate Assessment being required at a project level, as well as other environmental assessments such as SEA and EIA. Therefore, the REPDF will strategically ensure that renewable electricity generation is guided in a sustainable manner and that likely significant effects on European Sites are minimised. For smaller renewable electricity projects, the majority of County Councils have produced and adopted wind energy strategies or renewable energy strategies. These add a further layer of protection to European Sites as, in general, these strategies outline the types of renewable energy that will be considered within the County and potential suitable areas for development. These will be updated as and when appropriate in accordance with proper planning, and will have to take into account the plans/policies relevant to renewable electricity such as the NMP, NPF and REPDF. In relation to proposed electricity generation facilities in general; the usual planning development controls remain and all infrastructural developments will be subject to the appropriate planning development controls in line with relevant environmental legislation and regulatory processes, with Screening for Appropriate Assessment and/or Appropriate Assessment being required at a project level, as well as other environmental assessments such as SEA and EIA. This will ensure that the potential likely significant effects of any proposal are considered and ensure no adverse effects on the integrity of European Sites. Peat is currently being used as a fuel source for electricity generation, with potential likely significant effects on European Sites if it is being extracted from SACs. The RES Directive will ensure a gradual move away from fossil fuels in the longer term, however in the interim there remains a potential impact. The National Peatland Strategy aims to provide a framework for which all of the peatlands within the State can be managed responsibly in order to optimise their social, environmental and economic contribution while meeting nature conservation obligations. It will ensure protection of peatlands in terms of sustainable peat extraction and land use utilisation e.g. wind farms or forestry. A review of commercial harvesting operations arising out of the objectives listed in the National Peatlands Strategy is currently underway and it is expected to be issued in late Separate to MDR1224Rp005F01 62

69 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport this, Bord na Móna have made a commitment that no new peat harvesting sites will be acquired into the future. Potential land use change as a result of an increase in the requirement for biofuel crops (being used to produce biofuels, synthetic or paraffinic fuels or as a feedstock for electricity generation facilities) will also be addressed through other policy. The Renewable Energy Directive 2009/28/EC has strict sustainability criteria attached to biofuels, transposed into Irish law in the European Union (Biofuel Sustainability Criteria) Regulations 2012 (S.I. 33 of 2012), which require that biofuels shall not be made from raw materials obtained from land with high biodiversity value or land with high carbon stock 17. The Indirect Land Use Change (ILUC) Directive (EU) 2015/1513 amends the Renewable Energy Directive, in particular limiting the contribution from food crops to renewable energy targets to 7%. The implementation of this measure will ensure the extent of land use change for biofuels is limited, with an increased move towards advanced biofuels which are derived from non food crops. The Bioenergy Plan sets out the vision for how the targets for biofuel crops will be met and is also heavily reliant on the Forestry Programme , both of which have been subject to AA and as such the potential likely significant effects on European Sites have been addressed through these plans. All of these control measures will ensure the potential likely significant effects on European Sites are considered throughout the planning process, and ultimately that European Site integrity is not adversely affected as a result of an increased demand on electricity. 7.3 EMISSIONS TO AIR AS A RESULT OF INDIRECTLY ENCOURAGING THE INCREASED USE OF ALTERNATIVE FUELS The focus of the AFF is on supporting alternative fuels infrastructure. However discussion on the potential emissions from the generation or combustion from alternative fuels has been included as it is indirectly linked to the AFF, with the emissions from the generation of electricity currently of particular importance. Although alternative fuels do give rise to emissions to air from generation or combustion, substitution of petrol and diesel with alternative fuels on the whole will result in a net positive in terms of emissions to air. As such any positive changes to air emissions will contribute positively towards maintaining or restoring favourable conservation condition if QI/SCI habitats and species. In relation to electricity generation, generation facilities both existing and proposed, are subject to environmental licensing. Industrial Emissions Licensing (IEL) and Integrated Pollution Control (IPC) licensing is carried out by the EPA, with the requirement for an EPA licence typically being based on a range of conditions with which the operator must comply with in order to ensure no significant environmental impact, including requirements to limit and prevent emissions to air. All licence applications and licence reviews undergo Appropriate Assessment Screening as part of the consent procedure. If it is determined that Appropriate Assessment is required then an NIS can be requested by the EPA. As such, this licensing procedure will capture the potential for likely significant effects on European Sites and ensure no adverse effects to European Site integrity. Although Ireland is currently reliant on fossil fuels for electricity generation, Directive 2009/28/EC on the promotion of the use of energy from renewable sources (the RES Directive) establishes a basis for the achievement of 20% renewable energy target by This legislation is driving the shift on 17 Energy Security in Ireland: A Statistical Overview (SEAI, 2016) MDR1224Rp005F01 63

70 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport electricity generation from fossil fuels to renewable sources with further targets set of 2030 and 2050 under the EU Climate and Energy Package. In this regard, the predicted increase in share of renewables in the electricity generation sector will lead to a reduction in fossil fuel use and hence a net reduction in the emissions to atmosphere associated with these facilities. The Department of Housing, Planning, Community and Local Government is currently preparing the National Mitigation Plan (NMP). The primary objective of this plan will be to bring a clear and strong focus to both challenges and the opportunities of transitioning to a low carbon future, monitor implementation of current measures to 2020 and identify additional measures in the longer term to reduce greenhouse gas emissions and progress the overall national low carbon transition agenda to The NMP will incorporate measures relating to electricity generation that will ensure the sector is guided towards reducing CO2 emissions and, by knock on effect, other emissions associated with the electricity generation sector as outlined previously. The Department of Communications, Climate Action and Environment is preparing a Renewable Electricity Policy and Development Framework (REPDF) to guide the development of large scale renewable electricity projects on land. It will contribute towards meeting Ireland s future energy/electricity needs, particularly up to 2030 and beyond and will be reviewed at five-yearly intervals. Amongst other policies, it will set out policy in respect of environmental considerations and will seek to broadly identify suitable areas where renewable electricity projects can be developed. The usual planning development controls will remain unchanged, with Screening for Appropriate Assessment being required. The REPDF will guide the transition from reliance on fossil fuel in electricity generation and ultimately will facilitate a net reduction in the emissions to air associated with these generation facilities. As such, the AFF is heavily reliant on the REPDF to ensure that the increased demand for electricity as a result of increased usage of EVs can be met by renewable sources of electricity in the longer term to ensure no impacts on European Sites. The DTTAS understands the importance of the REPDF in terms of fulfilling the overall vision of the AFF and in terms of obligations in relation to nature conservation and air quality/climate change. The AFF has included a commitment in Section 11 Review Provisions to undertake meetings twice a year with the DCCAE to ensure that there is coordination between the REPDF and the AFF on electricity supply from renewable sources and that the meetings focus on progress made on implementing the REPDF. This will help inform any subsequent reviews of the AFF. As such, the RES Directive, NMP and REPDF will ensure that Ireland moves away from reliance on fossil fuels in the electricity generation sector which will, in the medium to longer term result in a net positive in terms of emissions to air. Any positive changes to air emissions will contribute positively towards maintaining or restoring favourable conservation condition if QI/SCI habitats and species. It is acknowledged that there remain some knowledge gaps in terms of emission to air and the associated ecological effects as some alternative fuels are still in their infancy (e.g. hydrogen, synthetic and paraffinic fuels). As technology and research moves forward with these fuels, feasibility studies into the potential to roll out for use by the national fleet will have to be undertaken. The protective policy committed to in Chapter 4 of the AFF (Proposed New Policy Measure 2 from Table 7.1 above) will ensure that all investigative/feasibility studies to be carried out in relation to alternative fuels and alternative fuels infrastructure must include an environmental appraisal which considers the potential effects on the Natura 2000 Network. This protective policy has been incorporated into the AFF following iterative review of the emerging AFF by the AA team throughout the plan making process. MDR1224Rp005F01 64

71 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport 8 CONCLUSIONS DTTAS is aware of the importance of protection of European Sites and hence the AFF has been formulated with the intention of avoiding adverse effects on European Sites. The AFF has been assessed in terms of the likely significant effects of the plan and where these would adversely affect the integrity of European Sites. The assessment identified that the majority of policy measures proposed did not give rise to direct effects on European Sites and that, in the main, the effects identified were indirect in nature. The policy measures of the AFF have been influenced to avoid, as appropriate, policy measures that would have an adverse effect upon the integrity of a European Site(s). Any project arising out of policy measures of the AFF shall be required to conform to the mitigation measures contained within this NIS (as transposed into the AFF) and to the relevant regulatory provisions aimed at preventing pollution or other environmental effects likely to adversely affect the integrity of European Sites. In addition, all lower level projects arising from the implementation of the AFF will themselves be subject to Appropriate Assessment when details of location and design become known. The conclusion of the NIS for the AFF is that there will be no adverse effects on the integrity of any European Sites. 8.1 NEXT STEPS This NIS will go on public display together with the draft AFF and the accompanying SEA Environmental Report. Following this period of consultation, the DTTAS will consider all submissions prior to finalising the AFF. Where a submission on the AFF requires further assessment, it will be documented supplementary to the NIS. Thereafter and as part of this process, DTTAS, as the competent authority for the AFF, will undertake an Appropriate Assessment and document their determination. DTTAS will only adopt the AFF if it is satisfied that it will not adversely affect the integrity of any European Site either alone or in-combination with other plans and programmes and in view of the Sites conservation objectives. MDR1224Rp005F01 65

72 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport 9 REFERENCES ASFE (2016a) Air quality. ASFE Paraffinic Fuels for Europe. Retrieved 3 August 2016 from ASFE (2016b) Technical properties. ASFE Paraffinic Fuels for Europe. Retrieved 3 August 2016 from Beckett, K. P., Freer-Smith, P. H. and Taylor, G. (1998) Urban woodlands: their role in reducing the effects of particulate pollution, Environmental Pollution, 99, pp Bell, M. (2013) Nitrogen Deposition and Natura 2000: Science and Practice in Delivering Environmental Impacts, European Journal of Soil Science, 64(2), pp Bhattacharjee, H., Drescher, M., Good, T., Hartley, X., Leza, J. D., Lin, B., Moss, J., Massey, R., Nishino, T., Ryder, S., Sachs, N., Tozan, Y., Taylor, C. and Wu, D. (1999) Particulate Matter in New Jersey. (Unpublished report). Princeton University, Princeton, NJ. Bobbink, R., Hicks, K., Galloway, J. N., Spranger, T., Alkamade, R., Ashmore, M., Bustamante, M., Cinderby, S., Davidson, E., Dentener, F., Emmett, B., Erisman, J.-W., Fenn, M., Gilliam., F., Nordin, A., Pardo, L. and de Vries, W. (2010) Global Assessment of Nitrogen Deposition Effects on Terrestrial Plant Diversity: a synthesis, Ecological Applications, 20, pp Brady, J. and O Mahony, M. (2011). Travel to work in Dublin. The potential impacts of electric vehicles on climate change and urban air quality, Transportation Research Part D: Transport and Environment, 16(2), pp California Institute of Technology (2016) Ozone and its Precursors and Sinks. Tropospheric Emission Spectrometer. Retrieved 8 August 2016 from Cape, J. N. (2008) Interactions of forests with secondary air pollutants: some challenges for future research, Environmental Pollution, 155, pp Caporn, S. J. M., Carroll, J. A., Dise, N. B. and Payne, R. J. (2014) Impacts and indicators of nitrogen deposition in moorlands, Ecological Indicators, 45, pp Cathles, L. M. (2012) Assessing the greenhouse impact of natural gas. (Unpublished research paper). Cornell Engineering, Ithaca, NY. Colhoun, K. & Cummins, S. (2013). Birds of Conservation Concern in Ireland Birdwatch Ireland. Council of the European Communities (1992) Council Directive of 21 May 1992 on the Conservation of Natural Habitats and of Wild Fauna and Flora (92/43/EEC). OJL 206/35, DAHG, (2014). Format for a Prioritised Action Framework (PAF) for Natura MDR1224Rp005F01 66

73 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport DAHG (2012). Marine Natura Impacts Statements in Irish Special Areas of Conservation. A working Document. DAHG (2011). Actions for Biodiversity : Irelands National Biodiversity Plan. Das, C. R., Bhaumik, R. and Mondal, N. K., (2012) Effect of iron dusts on physiological responses of gram seedlings (Cicer arietinum L.) under laboratory conditions, Journal of Stress Physiology & Biochemistry, 8(3), pp DEHLG (2009). Appropriate Assessment of Plans and Projects in Ireland Guidance for Planning Authorities (Department of Environment, Heritage and Local Government, Rev. Feb 2010). DEHLG (2010b) Department of the Environment, Heritage and Local Government Circular NPW1/10 and PSSP 2/10 on Appropriate Assessment under Article 6 of the Habitats Directive Guidance for Planning Authorities. Department of the Environment, Heritage and Local Government, Dublin. DTTAS (2016). Draft National Policy Framework Alternative Fuels Infrastructure for Transport in Ireland. Dupré, C., Stevens, C. J., Ranke, T., Bleeker, A., Peppler-Lisbach, C., Gowing, D. J. G., Disne, N. B., Dorland, E., Bobbink, R. and Diekmann, M. (2010) Changes in species richness and composition in European acidic grasslands over the past 70 years: the contribution of cumulative atmospheric nitrogen deposition, Global Change Biology, 16(1), pp Environmental Protection Agency (2012). Ireland s Environment 2012 An Assessment. ESSEA (December 23 rd 2010) Carbon Monoxide: Its Environmental Impact. Earth Science Education Alliance. Retrieved 4 August 2016 from European Commission (2013). EC study on evaluating and improving permitting procedures related to Natura 2000 requirements under Article 6.3 of the Habitats Directive 92/43/EEC. European Commission (2011). Communication from the Commission to the European Parliament, The Council, The Economic and Social Committee and the Committee of the Regions. Our life insurance, our natural capital: an EU biodiversity strategy to European Commission (2007). Guidance Document on Article 6(4) of the Habitats Directive 92/43/EEC. Clarification of the Concepts of Alternative Solutions, Imperative Reasons of Overriding Public Interest, Compensatory Measures, Overall Coherence. Opinion of the European Commission. European Commission (2001). Assessment of Plans and Projects significantly affecting Natura 2000 sites: Methodological guidance on the provisions of Article 6(3) and 6(4) of the Habitats Directive 92/43/EEC (European Commission Environment Directorate-General). MDR1224Rp005F01 67

74 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport European Commission (2000a). Managing Natura 2000 Sites: the provisions of Article 6 of the Habitats Directive 92/43/EEC. Office for Official Publications of the European Communities, Luxembourg. European Commission (2000b) Communication from the Commission on the Precautionary Principle. Office for Official Publications of the European Communities, Luxembourg. European Environment Agency (2015a). Air quality in Europe 2015 Report (ISSN ). Copenhagen: European Environment Agency. European Environment Agency (2015c) Exposure of ecosystems to acidification, eutrophication and ozone (Indicator Assessment; IND-30-en). Copenhagen: European Environment Agency. European Environment Agency (2014) Effects of Air Pollution on European ecosystems; Past and future exposure of European freshwater and terrestrial habitats to acidifying and eutrophying air pollutants (ISSN ). Copenhagen: European Environment Agency. European Parliament and European Council (2009). Directive 2009/147/EC of 30 th November 2009 on the Conservation of Wild Birds (2009/147/EC). Official Journal L20/7, Hicks, W. K., Whitfield, C. P., Bealey, W. J. and Sutton, M. A. (2011) Nitrogen Deposition and Natura 2000: Science and Practice in Determining Environmental Impacts. UK: COST. Hirano, T., Kiyota, M. and Aiga, I. (1995) Physical effects of dust on leaf physiology of cucumber and kidney bean plants, Environmental Pollution, 89, pp Joint Nature Conservation Committee (2011) Evidence of nitrogen deposition impacts on vegetation: implications for country strategies and UK biodiversity commitments (JNCC Report no 447 and no. 449). Peterborough: Joint Nature Conservation Committee. Keith, D.W., and A.E. Farrell, (2003). Rethinking hydrogen cars - Response. Science, 302, Kulshreshtha, K., Farooqui, A., Srivastava, K., Singh, K. J., Ahmad, K. J. and Behl, H. M. (1994) Effect of diesel exhaust pollution on cuticular and epidermal features of Lantana camara L. and Syzgium cuminii L. (Skeels.), Journal of Environmental Science and Health, A29, pp Lynas, P., Newton, S.F. and Robinson, J.A. (2007). The status of birds in Ireland: an analysis of conservation concern Irish Birds 8: Manning, W. J. and Feder, W. A. (1980) Biomonitoring Air Pollutants with Plants. Applied Science Publishers: London. Maskell, L. C., Smart, S. M. Bullock, J. M., Thompson, K. and Stevens, C. J. (2010) Nitrogen deposition causes widespread loss of species richness in British habitats, Global Change Biology, 16, pp MDR1224Rp005F01 68

75 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Niven, R.K. (2005) Ethanol in gasoline: environmental impacts and sustainability review article, Renewable and Sustainable Energy Reviews, 9, pp Nordin, A., Sheppard, L. J., Strengbom, J., Bobbink, R., Gunnarsson, U., Hicks, W. K. and Sutton, M. A. (n.d.) New science on the effects of nitrogen deposition and concentrations on Natura 2000 sites; In Hicks, W. K., Whitfield, C. P., Bealey, W. J., and Sutton, M. A. Eds.)Nitrogen Deposition and Natura2000: Science and Practice in Determining Environmental Impacts (pp ). UK: COST. NPWS (2013a). The Status of EU Protected Habitats and Species in Ireland. Habitats Assessments Volume 2, Version 1.1. Unpublished Report, National Parks and Wildlife Service. Department of Arts, Heritage and the Gaeltacht, Dublin. NPWS (2013b). The Status of EU Protected Habitats and Species in Ireland. Species Assessments Volume 3, Version 1.0. Unpublished Report, National Parks and Wildlife Service. Department of Arts, Heritage and the Gaeltacht, Dublin. NRA (2011). Guidelines for the Treatment of Air Quality During the Planning and Construction of National Road Schemes. Payne R. J., Caporn, S. J. M., Field, C. D., Carroll, J. A., Edmondson, J. L., Britton, A. and Dise, N. B. (2014) Heather Moorland Vegetation and Air Pollution: A Comparison and Synthesis of Three National Gradient Studies, Water Air Soil Pollution, 225, pp Pielke, R.A., Jr., R. Klein, G. Maricle, and T. Chase, (2003). Letter to the Editor - Hydrogen cars and water vapor. Science, 302, Rai, P. K. (2016) Impacts of particulate matter pollution on plants: Implications for environmental biomonitoring, Ecotoxicology and Environmental Safety, 129, pp Raslavičius, L., Keršys, A., Mockus, S., Keršienė, N., and Starevičius, M. (2014) Liquefied petroleum gas (LPG) as a medium-term option in the transition to sustainable fuels and transport, Renewable and Sustainable Energy Reviews, 32, pp RoTAP (2012) Review of Transboundary Air Pollution: Acidification, Eutrophication, Ground Level Ozone and Heavy Metals in the UK, Contract Report to the Department for Environment, Food and Rural Affairs. Centre for Ecology & Hydrology. Scott Wilson, Levett-Therivel Sustainability Consultants, Treweek Environmental Consultants and Land Use Consultants (2006). Appropriate Assessment of Plans. SEAI (2015). Energy in Ireland Shkaraba, E. M. and Perevedentseva, L. G. (1991) Consortium of forest plants and fungi under conditions of industrial pollution, Soviet Journal of Ecology, 22, pp Stevens, C. J., Dupré, C., Dorland, E., Gaudnik, C., Gowing, D. J. G., Bleeker, A., Diekmann, M., Alard, D., Bobbink, R., Fowler, D., Corcket, E., Mountford, J. O., Vandvik, V., Aarrestad, P. A., Muller, S. and MDR1224Rp005F01 69

76 NIS for the Draft National Policy Framework on Alternative Fuels Infrastructure for Transport Dise, N. B. (2010). Nitrogen deposition threatens species richness of grasslands across Europe, Environmental Pollution, 158, pp Stevens, C. J., Dise, N.B., Mountford, J. O. and Gowing, D. J. (2004) Impact of nitrogen deposition on the species richness of grasslands, Science, 303(5665), pp Ulrich, B., Mayer, R. and Khanna, P. K. (1979) Deposition von Luftverungreinigungen und ihre Auswirkungen in Waldökosystemen im Sollig, Schriften aus der Forstlichen Fakultät der Universität Göttingen und der Niedersächsischen Forstlichen Versuchsanstalt, 58, pp USEPA (1995) Compilation of Air Pollutant Emission factors (Volume 1; 5 th Ed.). North Carolina: Office of Air Quality Planning and Standards. MDR1224Rp005F01 70

77 APPENDIX A Consultation Responses AA Specific

78 Drprr;mcnt of Agriculture, ~!= Food and the Marine ' An R.Uinn Talmhaiochta, Bia agus Mara Denise Keoghan, National Policy Framework on Alternative Fuels Infrastructure for Transport, Climate Change Unit., Department of Transport, Tourism and Sport, Leeson Lane, Dublin 2. 23rd June Re: Alternative Fuels Framework. Dear Ms Keoghan, I refer to your recent correspondence concerning the above. The Department of Agriculture, Food and the Marine wish to make the following comments/observations: In table 2.2 tallow is mentioned as possible feedstock, perhaps it should refer to animal by - products(abp) and not just tallow also relevant to table 4.4. Pg. 24 potential data sources column opposite climatic factors the ref to EPA projections doc is out of date - there is a more recent one. Page 27 On the assessment criteria for SEA Objective, perhaps consideration should also be given to the extent that the AFF will safeguard sustainable food production. I am enclosing a publication on forestry and biomass which may be useful(table 12 in particular). Biomass is rarely considered for use in transport, it is mostly used by timber processors themselves as a source of heat for drying timber. Forestry biomass is also used in combined heat and power installations in industry and it is also burned at Bord na Mona's co firing electricity generating station at Edenderry. In 2013, 34% of the roundwood harvested in the Republic of Ireland was used for energy generation, mainly within the forest products sector. In 2013, the output of the forest-based biomass energy sector grew by 13.8% over Demand for forestry biomass is expected to increase in the coming years in order to meet Ireland's renewable energy target of 16% by Current estimates suggest that demand for this material will increase 2-fold, from 1.6 million cubic metres (m) in 2011 to 3.3milllion

79 m3 in 2020 and that a significant supply gap will emerge in the years to come. Without appropriate action, this supply gap will increase beyond 2020 as fossil fuel prices increase along with EU renewable energy targets. Increased production of biomass is being addressed in the new Forestry Programme This new programme is committed to spending 482 million on establishing 44,000 hectares of new forests during the programme period. This includes a new forestry for fibre scheme which aims to facilitate the planting of 3,300 hectares of fast growing trees such as eucalyptus which has the capacity to produce up to 300m3 of material per hectare, clearfelled at year 15. This alone represents new production of almost 1million m3 of forestry biomass within a relatively short 15 year rotation. Mobilising forestry biomass is also an important aim of the new programme. The forest roads scheme will provide 27million to build 700km of new roads allowing private forest growers to access their plantations and undertake first thinnings. The National Forest Inventory 2012 showed that almost 23% of the national forestry estate had reached thinning stage but had not been thinned. Thinning is essential in order to bring this material to market. A thinning grant for broadleaf forests under the Woodland Improvement Scheme of 750 per hectare is also being provided to encourage forest owners to thin their broadleaf forests on time. This represents funding to thin a total of 6,000 hectares of broadleaf forests during the 6 year programme period, most of which will be sold as firewood. This growing market is worth 33million per annum. The Department is also providing financial support for forest management plans which will allow forest owners to plan for thinning and road building activities. This will help improve the productivity of these forests and ensure that material is brought to market in a manner which will maximise the financial return for owners. Yours sincerely 0 Liz McDonnell Environmental Co-ordination'Unit Climate Change and Bioenergy Division Department of Agriculture Food and the Marine

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84 Ms Denise Keoghan National Policy Framework on Alternative Fuels Infrastructure for Transport Climate Change Unit Department of Transport, Tourism and Sport Leeson Lane Dublin 2 4 th July 2016 Our Ref: SCP Re: National Policy Framework on Alternative Fuels Infrastructure for Transport Dear Ms. Keoghan, I refer to and acknowledge your electronic correspondence, dated 23 rd June, in relation to the Strategic Environmental Assessment Scoping for the National Policy Framework on Alternative Fuels Infrastructure for Transport, referred to hereafter as the AFF. In addition to our SEA Scoping submission issued on the 16/06/16, this submission consists of specific comments on the scoping report to take into account, as described in Attachment I Further comments will be made upon receipt of the Draft AFF and SEA Environmental Report stage of the SEA process. Should you have any queries or require further information in relation to the above please contact the undersigned. I would be grateful if an acknowledgement of receipt of this submission could be sent electronically to the following address: sea@epa.ie. Yours Sincerely, Tadhg O Mahony Senior Scientific Officer SEA Section Office of Evidence and Assessment Environmental Protection Agency Regional Inspectorate Inniscarra, County Cork SCP EPA SEA Scoping Submission AFF

85 Attachment 1: Specific Additional Comments on the AFF SEA Scoping Report Chapter 2 Description of the Framework The AFF and associated SEA should consider including a graphic showing the relationship and hierarchy of the AFF in relation to other climate mitigation/adaptation-related plans/programmes/policies. This would assist in promoting how an integrated and consistent approach to achieve a reduction in greenhouse gas emissions is to be implemented in collaboration with other Plans/Programmes and Government Departments. Table 2.2 Alternative Fuels, Infrastructure and Feedstocks We note the alternative fuel options, infrastructure requirements and feedstock related considerations described in this section. The Plans supporting the infrastructure and feedstock-related aspects should also be described in terms of their ability to fulfil and advance the uptake of non-oil based fuel sources in an environmentally sustainable manner. These aspects should also be described in the AFF. In Section 2.3 Content and Main Objectives of the Framework and Table 2.3 Proposed Structure of the AFF, consideration should also be given to the energy and greenhouse gas emissions savings that will result from developing the AFF and the different alternative fuels that will be deployed. Where percentages are referred to, in terms of specific commitments or contributions to reducing greenhouse gas emissions or energy savings etc., the SEA Environmental Report should provide the associated empirical values (e.g. energy units (joules) or greenhouse gas emissions (CO 2 eq) etc.). Chapter 4 Other Relevant Plans and Programs We acknowledge the comprehensive list of relevant plans, programmes and policies described. The AFF should consider what are the barriers to the uptake of alternative fuels infrastructure over the lifetime of the framework. Consideration should also be given to identifying the key relevant strategic plans/programmes/policies which could be supported (or may be required) in order to help overcome these barriers, in collaboration with relevant stakeholders. In terms of climate change adaptation, the National Adaptation Framework, like the National Mitigation Plan, will form the basis for how Ireland will adapt to climate change. Large scale infrastructure related to the AFF, will have to take into account the possible effects of climate change over its lifetime. There is merit in recognising that the AFF could influence spatial planning at a strategic level, by promoting that commitments are included in the National Planning Framework (NPF) and Regional Spatial Economic Strategies (RSES), (currently being prepared by the Department of the Environment, Community and Local Government) to support the need to provide for adequate and appropriate AFF-related infrastructure in spatial planning. Options to consider could include providing and prioritising Electric Vehicle (EV) parking / charging facilities at strategic / desirable locations within settlements, along road corridors etc. In Table 4.2 European Plans, Programmes, Policy and Legislation, the Environmental Noise Directive might be an additional Directive to consider including. Including an additional column in Table National Plans of Key Significance, summarising the key relevant aspects and relationship with these plans and the AFF would be useful. SCP EPA SEA Scoping Submission AFF

86 In relation to the scoping question posed in this Chapter Based on the plans, policies and programmes outlined in Chapter 4 of this report, are there any other key relevant plans, policies or programmes that should be considered in the SEA Environmental Report? The relationship between electricity / energy grid infrastructure (onshore and offshore interconnectivity) and infrastructure required under the AFF, should be highlighted in the Scoping Report and the AFF. In terms of potential implications on human health / quality of life aspects, the AFF may have potential for social impacts. The relationship and influence of the AFF on fuel poverty-related strategies such as the 2016 Strategy to Combat Energy Poverty (DCENR, 2016) may need to be considered. Chapter 5 Scope of the Strategic Environmental Assessment We note that the Alternative Fuels Directive sets out minimum alternative-fuels infrastructure targets to achieve for 2020, 2025 and 2030 for certain fuels. The AFF should consider including a commitment to formal reviews over its lifetime to coincide with these periods. This will allow reporting on how the AFF is progressing in achieving those targets and whether advances in technology / economic costs etc. need to be reflected and integrated into the AFF. It is also useful to consider linking such reviews to environmental monitoring and performance related aspects of the AFF. While it is likely that minimum requirements to achieve the targets for implementation of the AFF are to be promoted, consideration should also be given to setting out a vision for achieving an increased take-up of non-oil based fuel transport infrastructure, beyond the minimum requirements. The National Transition Objective and the Climate Action and Low Carbon Development Act set out an emissions reduction pathway to We note that the transport sector is currently working on a sectoral plan, to progress this aim, as part of the National Mitigation Plan (as mentioned in Section 4.3). The transport sector (climate change) mitigation-related plan will outline how transport related emissions of carbon dioxide will be reduced by eighty per cent by In this context, moving from oil-based to alternative fuels alone will not be sufficient. This transition must also result in less energy use and less greenhouse gas emissions. A coordinated and integrated effort to achieve a low to zero-carbon path for transport on in the longer term will also be needed and should be promoted in the AFF. Where specific commitments relating to fuel alternatives are being progressed through other plans, such as the National Bioenergy Plan, it would be also useful to describe this aspect in Appendix B. The achievement of the aims of the AFF and other significant and relevant plans should be closely aligned to minimize potential for conflicting objectives. The implications for air quality should also be a key factor in assessing viability / suitability of particular fuel alternatives also. The Plan should recognise the need to de-carbonise the electricity generation infrastructure (provide electricity from renewable energy sources) to support the preferred option for increased use of electric vehicles for private vehicular transport to be strengthened. The relevant aspects of high level related plans should where possible be considered and promoted in this regard. Targets and objectives should not only reflect an awareness of the major transition ahead for transport, it is also important to consider monitoring and evaluating energy and emissions savings delivered through AFF. SCP EPA SEA Scoping Submission AFF

87 The AFF should consider whether a need exists to identify potential regional or demographic constraints for particular alternative fuel infrastructure (e.g. rural / urban / suburban). Outside of the Greater Dublin Area area, integrated regional transport/public transport services are more limited. It would be useful, however, to consider the implications of these differences in identifying additional or replacement alternative fuels infrastructure. We note in Section 5.4 Key Environmental Considerations, the alternative fuels and related infrastructure to be considered in the AFF (Electricity, Hydrogen, Biofuels, Synthetic and paraffinic fuels, Natural Gas and Liquefied Petroleum Gas). We also note that targets will be set for CNG, LNG and EV fuel sources. These should also be captured in the selection and assessment of alternatives. It would also be useful to describe the potential vulnerability of AFF infrastructure to climate change, in terms of flood risk, storm event, and drought conditions considerations. In response to the scoping question Do you agree with the potential significant effects that have been identified in Chapter 5 of this report? Should any be added or removed? a number of additional considerations are included below: - Indirect impacts on human health could be broadened to consider visual amenity and quality of life related aspects. - Is a high level of assessment of infrastructure requirements going to consider aspects such as flood risk / storm events / sea level rise aspects? - The extent to which a high level assessment of infrastructure requirements may consider aspects such as flood risk, storm events and sea level rise considerations Chapter 6 Preliminary Baseline The EPA is currently preparing a new State of the Environment Report for 2016, which is due to publication in Q The European Environment Agency, have also produced a State of the Environment Report for These reports would be useful as high level environmental baseline resources to consider and reference in the preparation of the Plan and SEA Environmental Report. On the scoping question Are there other significant information sources that should be considered?, the EPA has launched for information on Water Framework Directive and River Basin catchment management considerations. The hydrometrics unit of the EPA has also launched Hydronet, for hydrogeological data which may be useful also to consider in terms of monitoring groundwater implications which may arise out of implementing the AFF. Chapter 7 Proposed Framework for Assessing Environmental Effects We note Table 7-1 Draft SEA Alternatives for Discussion, which consider aspects such as strategic, modal, spatial and temporal aspects. Alternatives should consider the various options for private vehicle, public transport and commercial freight transport options in terms of capturing their particular requirements for fuel source infrastructure alternatives. The various alternative fuel options (or combination of options) for achieving the 2020, 2025 and 2030 Alternative Fuel Directive targets could be considered utilising a multi-criteria assessment approach. This approach could provide a clear rationale for determining which sources are most appropriate during short, medium and long term plan review periods. Where SCP EPA SEA Scoping Submission AFF

88 particular fuel sources and related infrastructure are not viable currently, they may become increasingly viable as technology, economic cost, social acceptance improve. From an environmental perspective, ensuring aspects such as protection of European Sites (under the Habitats Directive) and Protected Areas (under the Water Framework Directive) need to be considered in assessing and selecting alternatives. Options which provide for a greater (and sustainable) level of decarbonisation should be prioritised. It would be useful to review the current viability of the various alternative fuel options as described in Appendix B Alternatives Fuels and their Status in Ireland at specific time periods over the lifetime of the Plan. The AFF should be capable of responding to the viability of particular options over its lifetime with advances in technology, while ensuring that environmental sensitivities are appropriately protected. It is also worth clarifying whether aspects such as transport-related infrastructure aspects such as import / export aspects of fuel types used, will be considered in the AFF. In relation to the SEA Scoping Question in this chapter Do you have any suggestions in relation to the overall approach to alternatives? applying a multi-criteria assessment approach, taking into account aspects such as environmental, technical, social and economic may prove a useful method to identify alternatives and associated infrastructure which may be more or less viable over the lifetime of the AFF. Section 7.2 Identification of Objectives, Targets and Indicators The Draft SEA Environmental Objectives of the AFF and the National Mitigation Plan, currently being prepared should be aligned, where relevant. In Table 7.2 Draft SEA Environmental Objectives - For Objective 4, it may be useful to provide examples of water courses for clarity, as follows: Protect the quality and management of water courses (including lakes, rivers and estuaries) and groundwater - Objective 6 Minimise emissions of greenhouse gasses, should be reworded to include a reference to support the National Transition Objective (80% reduction in CO 2 in transport by 2050). This would provide a clear and robust objective and highlight the urgency of developing and implementing a low carbon pathway to Objective 6 (second bullet point ) - While we note that flooding will be considered, the AFF should also consider other aspects such as extreme weather events, warmer temperatures impacts on alternative infrastructure etc. SCP EPA SEA Scoping Submission AFF

89 APPENDIX B Special Areas of Conservation (SACs) Republic of Ireland

90 SAC Site Code SAC Site Code Killyconny Bog (Cloghbally) SAC Great Island Channel SAC Lough Oughter & Associated Loughs Kilkieran Lake & Castlefreke Dunes SAC SAC Ballyallia Lake SAC Myross Wood SAC Ballycullinan Lake SAC Ballyness Bay SAC Ballyogan Lough SAC Coolvoy Bog SAC Black Head-Poulsallagh Complex SAC Dunragh Loughs/Pettigo Plateau SAC Danes Hole, Poulnalecka SAC Gweedore Bay & Islands SAC Dromore Woods & Loughs SAC Kindrum Lough SAC Inagh River Estuary SAC Muckish Mountain SAC Pouladatig Cave SAC Sheephaven SAC Lough Gash Turlough SAC Termon Strand SAC Moneen Mountain SAC Keeper Hill SAC Moyree River System SAC Glenasmole Valley SAC Poulnagordon Cave (Quin) SAC Aughrusbeg Machair &Lake SAC Ballymacoda (Clonpriest & Pillmore) SAC Courtmacsherry Estuary SAC Glengarriff Harbour & Woodland SAC Carrownagappul Bog SAC Clonakilty Bay SAC Cregduff Lough SAC Caha Mountains SAC Dog's Bay SAC Lough Hyne Nature Reserve And Gortnandarragh Limestone Pavement Environs SAC SAC Roaringwater Bay & Islands SAC Inisheer Island SAC Sheep's Head SAC Kiltiernan Turlough SAC St. Gobnet's Wood SAC Omey Island Machair SAC The Gearagh SAC Rusheenduff Lough SAC Three Castle Head To Mizen Head SAC Ross Lake & Woods SAC Aran Island (Donegal) Cliffs SAC Rosturra Wood SAC Ballintra SAC Termon Lough SAC Ballyarr Wood SAC Cloonee & Inchiquin Loughs, Uragh Wood SAC Croaghonagh Bog SAC Mucksna Wood SAC Donegal Bay (Murvagh) SAC Ballynafagh Lake SAC Durnesh Lough SAC Rye Water Valley/Carton SAC Fawnboy Bog/Lough Nacung SAC Arroo Mountain SAC Gannivegil Bog SAC Glen Bog SAC Horn Head & Rinclevan SAC Glenstal Wood SAC Inishtrahull SAC Clogher Head SAC Lough Eske And Ardnamona Wood SAC Clew Bay Complex SAC Lough Nagreany Dunes SAC Doogort Machair/Lough Doo SAC Lough Nillan Bog (Carrickatlieve) SAC Erris Head SAC Magheradrumman Bog SAC Keel Machair/Menaun Cliffs SAC Meenaguse/Ardbane Bog SAC Lough Cahasy, Lough Baun & Roonah Lough SAC Meentygrannagh Bog SAC Mocorha Lough SAC Curraghchase Woods SAC Castletownshend SAC Rathlin O'Birne Island SAC Urlaur Lakes SAC Sessiagh Lough SAC Castlesampson Esker SAC

91 SAC Site Code SAC Site Code Slieve League SAC Annaghmore Lough (Roscommon) SAC Slieve Tooey/Tormore Island/Loughros Beg Bay SAC Four Roads Turlough SAC St. John's Point SAC Bricklieve Mountains & Keishcorran SAC Tranarossan & Melmore Lough SAC Knockalongy & Knockachree Cliffs SAC West Of Ardara/Maas Road SAC Lough Arrow SAC Baldoyle Bay SAC Streedagh Point Dunes SAC Howth Head SAC Liskeenan Fen SAC Lambay Island SAC Kilmuckridge-Tinnaberna Sandhills SAC Malahide Estuary SAC Kilpatrick Sandhills SAC North Dublin Bay SAC Holdenstown Bog SAC Rogerstown Estuary SAC Magherabeg Dunes SAC South Dublin Bay SAC Lough Carra/Mask Complex SAC Inishmaan Island SAC Pilgrim's Road Esker SAC Inishmore Island SAC Kilroosky Lough Cluster SAC River Shannon Callows SAC White Lough, Ben Loughs & Lough Doo SAC Coolcam Turlough SAC Lough Forbes Complex SAC Barroughter Bog SAC Split Hills &Long Hill Esker SAC Caherglassaun Turlough SAC Philipston Marsh SAC Castletaylor Complex SAC Galmoy Fen SAC Cloonmoylan Bog SAC Derryclogher (Knockboy) Bog SAC Coole-Garryland Complex SAC Glanmore Bog SAC Croaghill Turlough SAC Meenaguse Scragh SAC Derrycrag Wood Nature Reserve SAC Maulagowna Bog SAC Galway Bay Complex SAC Mullaghanish Bog SAC Inishbofin & Inishshark SAC Unshin River SAC Kilsallagh Bog SAC Cloonakillina Lough SAC Kiltartan Cave (Coole) SAC Glendree Bog SAC Levally Lough SAC Sonnagh Bog SAC Lisnageeragh Bog & Ballinastack Turlough SAC Glenade Lough SAC Lough Corrib SAC Bellacorick Bog Complex SAC Lough Cutra SAC East Burren Complex SAC Lough Lurgeen Bog/Glenamaddy Mweelrea/Sheeffry/Erriff Complex Turlough SAC SAC Lough Rea SAC Comeragh Mountains SAC Loughatorick South Bog SAC Croaghaun/Slievemore SAC Peterswell Turlough SAC Boyne Coast & Estuary SAC Pollnaknockaun Wood Nature Ballyhoorisky Point To Fanad Head Reserve SAC SAC Rahasane Turlough SAC Lough Gill SAC Rosroe Bog SAC Tamur Bog SAC Shankill West Bog SAC Bellacragher Saltmarsh SAC Slyne Head Islands SAC Ox Mountains Bogs SAC Tully Mountain SAC Maumturk Mountains SAC Akeragh, Banna & Barrow Harbour SAC Old Domestic Building (Keevagh) SAC Ballinskelligs Bay &Inny Estuary SAC North Inishowen Coast SAC

92 SAC Site Code SAC Site Code Castlemaine Harbour SAC The Twelve Bens/Garraun Complex SAC Old Domestic Building, Dromore Wood SAC Boleybrack Mountain SAC Kilgarvan Ice House SAC Connemara Bog Complex SAC Killarney National Park, Macgillycuddy's Reeks & Caragh River Ballyhoura Mountains SAC Catchment SAC Lough Yganavan & Lough Nambrackdarrig SAC Carrigeenamronety Hill SAC Mount Brandon SAC Old Domestic Building, Curraglass Wood SAC Sheheree (Ardagh) Bog SAC Cloghernagore Bog & Glenveagh National Park SAC Ballynafagh Bog SAC Tralee Bay & Magharees Peninsula, West To Cloghane SAC Pollardstown Fen SAC Slyne Head Peninsula SAC Red Bog, Kildare SAC Ballinafad SAC Hugginstown Fen SAC Newhall & Edenvale Complex SAC The Loughans SAC Old Domestic Building, Askive Wood SAC Slieve Bloom Mountains SAC Corliskea/Trien/Cloonfelliv Bog SAC Lough Melvin SAC Kilkieran Bay & Islands SAC Barrigone SAC Ballyseedy Wood SAC Tory Hill SAC Lough Coy SAC Lough Ree SAC Barnahallia Lough SAC Fortwilliam Turlough SAC Lough Nageeron SAC Carlingford Mountain SAC Lough Bane & Lough Glass SAC Dundalk Bay SAC Lough Lene SAC Killala Bay/Moy Estuary SAC Wicklow Mountains SAC Ardkill Turlough SAC Ardmore Head SAC Balla Turlough SAC Bolingbrook Hill SAC Bellacorick Iron Flush SAC Anglesey Road SAC Mullet/Blacksod Bay Complex SAC Pollagoona Bog SAC Brackloon Woods SAC Murvey Machair SAC Broadhaven Bay SAC Tully Lough SAC Ballymaglancy Cave, Cong SAC Lough Nageage SAC Carrowkeel Turlough SAC Lower River Suir SAC Carrowmore Lake Complex SAC Mountmellick SAC Cloughmoyne SAC Newport River SAC Clyard Kettle-Holes SAC Lisduff Fen SAC Cross Lough (Killadoon) SAC Newgrove House SAC Corraun Plateau SAC Kenmare River SAC Doocastle Turlough SAC Mulroy Bay SAC Duvillaun Islands SAC Long Bank SAC Flughany Bog SAC River Barrow & River Nore SAC Glenamoy Bog Complex SAC Lough Golagh & Breesy Hill SAC Greaghans Turlough SAC Lower River Shannon SAC Kilglassan/Caheravoostia Turlough Blackwater River (Cork/Waterford) Complex SAC SAC Inishkea Islands SAC Bandon River SAC Lackan Saltmarsh & Kilcummin Head SAC Blasket Islands SAC

93 SAC Site Code SAC Site Code Lough Gall Bog SAC Blackwater River (Kerry) SAC Shrule Turlough SAC Leannan River SAC Moore Hall (Lough Carra) SAC Lough Dahybaun SAC Oldhead Wood SAC Towerhill House SAC Owenduff/Nephin Complex SAC Gortacarnaun Wood SAC Skealoghan Turlough SAC Drummin Wood SAC Slieve Fyagh Bog SAC Slieve Mish Mountains SAC All Saints Bog & Esker SAC Drongawn Lough SAC Charleville Wood SAC Farranamanagh Lough SAC Clara Bog SAC Ireland's Eye SAC Ferbane Bog SAC Glenloughaun Esker SAC Fin Lough (Offaly) SAC Killeglan Grassland SAC Mongan Bog SAC Island Fen SAC Moyclare Bog SAC Lough Derg, North-East Shore SAC Raheenmore Bog SAC Clare Island Cliffs SAC Cuilcagh - Anierin Uplands SAC Ardrahan Grassland SAC Sharavogue Bog SAC Old Farm Buildings, Ballymacrogan SAC Ballinturly Turlough SAC Ballycullinan, Old Domestic Building SAC Bellanagare Bog SAC Toonagh Estate SAC Callow Bog SAC The Murrough Wetlands SAC Carrowbehy/Caher Bog SAC Carrowmore Dunes SAC Cloonchambers Bog SAC Thomastown Quarry SAC Derrinea Bog SAC Ballyprior Grassland SAC Lough Fingall Complex SAC Moanour Mountain SAC Errit Lough SAC Silvermines Mountains West SAC Lisduff Turlough SAC Tory Island Coast SAC Lough Croan Turlough SAC Magharee Islands SAC Lough Funshinagh SAC Valencia Harbour/Portmagee Channel SAC Mullygollan Turlough SAC Kerry Head Shoal SAC Cloonshanville Bog SAC Kilkee Reefs SAC Ballysadare Bay SAC Kingstown Bay SAC Ben Bulben, Gleniff & Glenade Complex SAC Achill Head SAC Bunduff Lough &Machair/Trawalua/Mullaghmore Carnsore Point SAC SAC Cummeen Strand/Drumcliff Bay (Sligo Bay) SAC Wicklow Reef SAC Lough Hoe Bog SAC Askeaton Fen Complex SAC Lough Nabrickkeagh Bog SAC Dunbeacon Shingle SAC Templehouse And Cloonacleigha Loughs SAC Reen Point Shingle SAC Turloughmore (Sligo) SAC Rutland Island & Sound SAC Union Wood SAC Lough Swilly SAC Ballyduff/Clonfinane Bog SAC Carrowbaun, Newhall And Ballylee Turloughs SAC Galtee Mountains SAC Cahermore Turlough SAC Kilcarren-Firville Bog SAC Ballinduff Turlough SAC Helvick Head SAC Williamstown Turloughs SAC Nier Valley Woodlands SAC River Moy SAC

94 SAC Site Code SAC Site Code Tramore Dunes & Backstrand SAC River Boyne & River Blackwater SAC Garriskil Bog SAC River Finn SAC Lough Ennell SAC Dunmuckrum Turloughs SAC Lough Owel SAC Carlingford Shore SAC Scragh Bog SAC Slieve Bernagh Bog SAC Ballyteige Burrow SAC Ballymore Fen SAC Bannow Bay SAC Old Domestic Buildings, Rylane SAC Cahore Polders & Dunes SAC Glanlough Woods SAC Lady's Island Lake SAC Ratty River Cave SAC Saltee Islands SAC Cregg House Stables, Crusheen SAC Screen Hills SAC Knockanira House SAC Tacumshin Lake SAC Kilkishen House SAC Raven Point Nature Reserve SAC Kildun Souterrain SAC Ballyman Glen SAC Glendine Wood SAC Bray Head SAC Mouds Bog SAC Carriggower Bog SAC Coolrain Bog SAC Deputy's Pass Nature Reserve SAC Knockacoller Bog SAC Glen Of The Downs SAC Carn Park Bog SAC Knocksink Wood SAC Crosswood Bog SAC Buckroney-Brittas Dunes & Fen SAC Drumalough Bog SAC Vale Of Clara (Rathdrum Wood) SAC Ballynamona Bog & Corkip Lough SAC Hook Head SAC Moneybeg & Clareisland Bogs SAC Blackstairs Mountains SAC Ardagullion Bog SAC Slaney River Valley SAC Mount Hevey Bog SAC Cullahill Mountain SAC Tullaher Lough & Bog SAC Spahill & Clomantagh Hill SAC Brown Bog SAC Clonaslee Eskers & Derry Bog SAC Camderry Bog SAC Lisbigney Bog SAC Clooneen Bog SAC Ridge Road, SW Of Rapemills SAC Corbo Bog SAC The Long Derries, Edenderry SAC Curraghlehanagh Bog SAC Clare Glen SAC Moanveanlagh Bog SAC Kilduff, Devilsbit Mountain SAC Monivea Bog SAC Silvermine Mountains SAC Redwood Bog SAC Corratirrim SAC Tullaghanrock Bog SAC Ballyteige (Clare) SAC Ardgraigue Bog SAC Ballyvaughan Turlough SAC Blackwater Bank SAC Glenomra Wood SAC West Connacht Coast SAC Carrowmore Point To Spanish Point & Islands SAC Hemptons Turbot Bank SAC Barley Cove To Ballyrisode Point SAC Rockabill to Dalkey Island SAC Cleanderry Wood SAC Codling Fault Zone SAC Offshore SAC Site Code Offshore SAC Site Code Belgica Mound Province SAC North West Porcupine Bank SAC Hovland Mound Province SAC Porcupine Bank Canyon SAC South-West Porcupine Bank SAC South-East Rockall Bank SAC

95 APPENDIX C Special Protection Areas (SPAs) Republic of Ireland

96 SPA Site Code SPA Site Code Saltee Islands SPA Pettigo Plateau Nature Reserve SPA Puffin Island SPA Inishtrahull SPA Inishkea Islands SPA Ballykenny-Fisherstown Bog SPA Cliffs of Moher SPA Garriskil Bog SPA North Bull Island SPA All Saints Bog SPA Skelligs SPA Bellanagare Bog SPA Blasket Islands SPA Coole-Garryland SPA Lady's Island Lake SPA Eirk Bog SPA Drumcliff Bay SPA The Gearagh SPA Rockabill SPA Lough Nillan Bog SPA Rogerstown Estuary SPA Duvillaun Islands SPA Baldoyle Bay SPA Howth Head Coast SPA Mongan Bog SPA Illaunonearaun SPA The Raven SPA Inishduff SPA Ballyteigue Burrow SPA Inishkeel SPA Old Head of Kinsale SPA Ireland's Eye SPA Ballycotton Bay SPA Keeragh Islands SPA Ballymacoda Bay SPA Loop Head SPA South Dublin Bay and River Tolka Estuary SPA Rathlin O'Birne Island SPA Broadmeadow/Swords Estuary SPA Roaninish SPA Dundalk Bay SPA Skerries Islands SPA Tramore Back Strand SPA Sovereign Islands SPA Blackwater Estuary SPA Magharee Islands SPA Castlemaine Harbour SPA Wicklow Head SPA Cork Harbour SPA Ballysadare Bay SPA Inner Galway Bay SPA Illancrone and Inishkeeragh SPA Dungarvan Harbour SPA Aughris Head SPA Bannow Bay SPA Lough Rea SPA Trawbreaga Bay SPA Ardboline Island and Horse Island SPA Cummeen Strand SPA Clare Island SPA Killala Bay/Moy Estuary SPA Dovegrove Callows SPA Blacksod Bay/Broadhaven SPA Lough Croan Turlough SPA Killarney National Park SPA Four Roads Turlough SPA Derryveagh And Glendowan Mountains SPA Cregganna Marsh SPA Wicklow Mountains SPA Cahore Marshes SPA Ballyallia Lough SPA High Island, Inishshark and Davillaun SPA Lough Corrib SPA Durnesh Lough SPA Lough Derravaragh SPA Malin Head SPA Lough Ennell SPA Fanad Head SPA Glen Lough SPA Falcarragh to Meenlaragh SPA Lough Iron SPA West Donegal Coast SPA Lough Owel SPA Donegal Bay SPA Lough Gara SPA Inishmore SPA Lough Oughter SPA Dingle Peninsula SPA Lough Arrow SPA Iveragh Peninsula SPA Lough Carra SPA Beara Peninsula SPA

97 SPA Site Code SPA Site Code Carrowmore Lake SPA Sheep's Head to Toe Head SPA Lough Cutra SPA River Nanny Estuary and Shore SPA Lough Derg (Donegal) SPA Slyne Head To Ardmore Point Islands SPA Lough Derg (Shannon) SPA Slieve Bloom Mountains SPA Lough Fern SPA Stack's to Mullaghareirk Mountains, West Limerick Hills and Mount Eagle SPA Lough Kinale and Derragh Lough SPA Mullaghanish to Musheramore Mountains SPA Lough Mask SPA Slievefelim to Silvermines Mountains SPA Poulaphouca Reservoir SPA Slieve Beagh SPA Lough Ree SPA Slieve Aughty Mountains SPA Lough Sheelin SPA Cruagh Island SPA The Bull and The Cow Rocks SPA Dalkey Islands SPA Inishmurray SPA Deenish Island and Scariff Island SPA Lambay Island SPA Bills Rocks SPA Stags of Broad Haven SPA Connemara Bog Complex SPA Tory Island SPA Mid-Clare Coast SPA Illanmaster SPA The Murrough SPA Lough Swilly SPA Sligo/Leitrim Uplands SPA Wexford Harbour and Slobs SPA Tralee Bay Complex SPA River Shannon and River Fergus Estuaries SPA Kerry Head SPA Carlingford Lough SPA Galley Head to Duneen Point SPA Boyne Estuary SPA Seven Heads SPA Clonakilty Bay SPA Helvick Head to Ballyquin SPA Greers Isle SPA Mid-Waterford Coast SPA Inishbofin, Inishdooey and Inishbeg SPA Horn Head to Fanad Head SPA Inishglora and Inishkeeragh SPA Cross Lough (Killadoon) SPA River Little Brosna Callows SPA Courtmacsherry Bay SPA Lough Foyle SPA Corofin Wetlands SPA Rahasane Turlough SPA Illaunnanoon SPA Sheskinmore Lough SPA Mullet Peninsula SPA Stabannan-Braganstown SPA Lough Conn and Lough Cullin SPA Tacumshin Lake SPA West Donegal Islands SPA Termoncarragh Lake and Annagh Inishbofin, Omey Island and Turbot Machair SPA Island SPA Blackwater Callows SPA River Boyne and River Blackwater SPA Kilcolman Bog SPA River Nore SPA Middle Shannon Callows SPA Ballintemple and Ballygilgan SPA River Suck Callows SPA Doogort Machair SPA Owenduff/Nephin Complex SPA

98 APPENDIX D Special Areas of Conservation (SAC) Northern Ireland

99 There are a total of 77 SACs currently designated in Northern Ireland. There are five SACs within 15km of the territorial border which overlap with six SACs within the Republic of Ireland. They are indicated with * Special Area of Conservation (SAC) Site Code Special Area of Conservation (SAC) Site Code Cuilcagh Mountain * UK Bann Estuary UK Pettigoe Plateau * UK Binevenagh UK Fairy Water Bogs UK Cladagh (Swanlinbar) River UK Magilligan UK Moneygal Bog UK Upper Lough Erne UK Moninea Bog UK Eastern Mournes UK Owenkillew River UK Monawilkin UK Rostrevor Wood UK Derryleckagh UK Slieve Gullion UK Magheraveely Marl Loughs * UK West Fermanagh Scarplands UK Slieve Beagh UK River Foyle and Tributaries * UK Largalinny UK River Roe and Tributaries UK Lough Melvin * UK River Faughan and Tributaries UK Fardrum and Roosky Turloughs UK Skerries and Causeway UK

100 APPENDIX E Special Protection Areas (SPAs) Northern Ireland

101 There are a total of 16 SPAs currently designated in Northern Ireland (as of January 2016). Of those, five occur within 15km of territorial border with those marked as * straddling the border and subject to separate SPA designation in the Republic of Ireland. Special Protection Area (SPA) Lough Foyle Pettigoe Plateau Upper Lough Erne Slieve Beagh-Mullaghfad-Lisnaskea * Carlingford Lough Site Code UK UK UK UK UK

102 APPENDIX F Screening for Appropriate Assessment

103 National Policy Framework on Alternative Fuels Infrastructure for Transport Screening for Appropriate Assessment May 2016