Proposed 38kV Underground Electric Grid Connection to permitted wind farm at Cullenagh, Co. Laois. Appropriate Assessment Screening

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5 Proposed 38kV Underground Electric Grid Connection to permitted wind farm at Cullenagh, Co. Laois Appropriate Assessment Screening July 2016

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9 Proposed 38kV Underground Electric Grid Connection to permitted wind farm at Cullenagh, Co. Laois - Screening for Appropriate Assessment TABLE OF CONTENTS 1 INTRODUCTION BACKGROUND LEGISLATIVE BACKGROUND FOR APPROPRIATE ASSESSMENT BRIEF DESCRIPTION OF THE RECEIVING ENVIRONMENT DESCRIPTION OF THE PROJECT Proposed Grid Connection Route METHODOLOGY GUIDANCE DOCUMENTS ON APPROPRIATE ASSESSMENT STAGES OF APPROPRIATE ASSESSMENT INFORMATION CONSULTED FOR THIS REPORT SCREENING PROTOCOL Screening Sequence Screening Determination SCREENING OF EUROPEAN SITES BRIEF DESCRIPTION OF THE EUROPEAN SITES WITHIN THE ZONE OF INFLUENCE Qualifying Interests Conservation Objectives Documented Threats to European Sites ASSESSMENT CRITERIA IS THE GRID CONNECTION NECESSARY TO THE MANAGEMENT OF NATURA 2000 SITES? DIRECT, INDIRECT OR SECONDARY IMPACTS OF THE GRID CONNECTION CUMULATIVE IMPACTS WITH THE CULLENAGH WIND FARM Methodology Cumulative - Cullenagh Wind Farm IN COMBINATION - OTHER PLANS AND DEVELOPMENT PROJECTS Methodology In- Combination Other Plans and Projects Cumulative and In-combination Impact Assessment Conclusion SUMMARY OF SCREENING ASSESSMENT LIKELY CHANGES TO THE EUROPEAN SITE(S) SCREENING CONCLUSIONS AND STATEMENT FINDING OF NO SIGNIFICANT EFFECTS REPORT MATRIX REFERENCES i

10 Proposed 38kV Underground Electric Grid Connection to permitted wind farm at Cullenagh, Co. Laois - Screening for Appropriate Assessment APPENDICES Appendix A Appendix B Appendix C SAC Conservation Objectives SPA Special Conservation Interests Cullenagh Wind Farm NIS LIST OF FIGURES Figure 1-1: Overview map of Proposed Grid Connection Cable Route... 2 Figure 1-2: Watercourses and Margaritifera Sensitive Areas Catchments... 3 Figure 3-1: European Sites within 15 km of proposed Grid Connection LIST OF TABLES Table 3-1: European Sites within 15km Zone of Influence of the Proposed Grid Connection Table 3-2: Special Area of Conservation (SACs) within 15km zone of influence of Proposed Cullenagh Grid Connection Table 3-3: Special Protection Areas (SPAs) within 15km zone of influence of Proposed Cullenagh Grid Connection Table 4-1: Potential Cumulative Impacts with Cullenagh Wind Farm Table 4-2: List of Projects which may Contribute to in combination Impacts Table 4-3: List of Potential Plans which may Contribute to In-combination Impacts Table 4-4: Potential Significant Effects on European Sites from the Proposed Cullenagh Grid Connection cumulatively with the permitted windfarm and in-combination with other plans and projects Table 4-5: Likely Changes to European Sites iii

11 Proposed 38kV Underground Electric Grid Connection to permitted wind farm at Cullenagh, Co. Laois - Screening for Appropriate Assessment 1 INTRODUCTION This report contains information in support of the Appropriate Assessment (AA) screening, undertaken by RPS on behalf of Coillte, in respect of the proposed grid connection cable at Cullenagh, County Laois. This report is prepared in accordance with the requirements of the European Communities (Birds and Natural Habitats) Regulations 2011 (S.I. No. 477/2011). 1.1 BACKGROUND Planning permission for an 18 turbine wind farm located in the environs of Cullenagh Mountain to the east of Ballyroan in County Laois was granted by An Bórd Pleanála in June 2014 (ABP Reference No: ). The scheme is situated within the administrative boundary of Laois County Council. A grid connection from the proposed wind farm on Cullenagh Mountain to the ESB Sub Station in Portlaoise is required. The proposed route of the grid connection is illustrated in Figure LEGISLATIVE BACKGROUND FOR APPROPRIATE ASSESSMENT The Council Directive 92/43/EEC on the Conservation of Natural Habitats and of Wild Fauna and Flora, better known as 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 Natura 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. Articles 6(3) and 6(4) of the Habitats Directive set out the decision-making tests for plans and projects likely to have a significant effect on or to adversely affect the integrity of European Sites (Annex 1.1). Article 6(3) establishes the requirement for 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. If any plan or project is not likely to have a significant effect, either individually or in combination with other plans or projects, there is no requirement for an appropriate assessment. 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 coherence of Natura 2000 is protected. It shall inform the Commission of the compensatory measures adopted. 1

12 Proposed 38kV Underground Electric Grid Connection to permitted wind farm at Cullenagh, Co. Laois - Screening for Appropriate Assessment The Habitats Directive has been transposed into Irish law by Part XAB of the Planning and Development Act, and the European Communities (Birds and Natural Habitats) Regulations 2011 (S.I. 477/2011) as amended. The relevant Competent Authority is obliged to examine the likely significant effects, individually or in combination with other plans and projects (including the Cullenagh Windfarm itself), of the proposal on European Sites in light of their specific qualifying interests and conservation objectives. If screening determines that there is likely to be significant effects on a European Site, then full AA must be carried out for the grid connection works, including the compilation of a Natura Impact Statement to inform the decision making process. The grid connection works will not be exempted development if an AA is required. 1.3 BRIEF DESCRIPTION OF THE RECEIVING ENVIRONMENT Walkover surveys were carried out on 17 th December 2015 and 14 th January For the most part the proposed grid connection will be located within the public road corridor (78% of the length in total). The predominant land use in the area surrounding the grid connection is agriculture, with fields of agriculturally improved grassland bound by hedgerows a common feature of the area. Other land use in the area includes forestry. The northern part of Cullenagh Wind Farm site encompasses Cullenagh Mountain with two peaks of 317mOD and 305mOD. The ground elevation reduces to 170mOD at the northern and southern site boundaries. Land cover at the Cullenagh Mountain site is primarily coniferous forestry with a relatively extensive forest road and track network and a number of access points to public roads. An aquatic ecology survey was conducted on 4 th May 2016 in order to assess water quality and the presence or absence of Freshwater Pearl Mussel at the grid connection route watercourse crossing locations. The survey also included an assessment of the suitability of the watercourse crossing locations to support Kingfisher. The proposed grid connection route crosses the Ballyroan Stream, which is a tributary of the River Nore (Nore River Catchment), at one location along its length, and tributaries of the River Barrow at seven locations along its length (the Triogue River and its tributaries, Barrow River Catchment), with a total of eight EPA mapped watercourse crossings ( These watercourses are illustrated in Figure 1.1, which also shows a further four small drains that are present along the proposed grid connection route, making a total of 12 water crossings associated with bridges and culverts. It should be noted that there was no evidence on site of one of the mapped watercourses at the mapped location. The route intersects two Margaritifera or Freshwater Pearl Mussel sensitive areas catchments. The southernmost part of the proposed grid connection route is situated within the Upper Nore Catchments of SAC Populations Listed in S.I. 296 of 2009, with the remainder of the proposed route located in the Barrow Catchments with previous records of Margaritifera (Freshwater Pearl Mussel) but current status unknown (for the Upper Nore Margaritifera catchment area please see Figure 1.2). No invasive non-native species were observed along the route during the walkover surveys on 17 th December 2015 and 14 th January

13 CLONMINAM Crooked [Stradbally]!?!.!.!.!.!.!O!.!.!.!.!.!.! Honey stream Kilometers Owveg [Nore] Clogh BLACKHILLS [Laois] Stradbally TIMAHOE FOSSY_LOWER Aghoney stream KNOCKACRIN Ratheven Triogue Portlaoise Substation Little Borris M7 Rathleague Overbridge CURRIERSBOG MEELICK Togher South stream Pass of the plumes str Pass stream Substation Legend Client Title Drawn By: H. Flynn Checked By: S. Khan Approved By: Scale: Date: NOTE:!? Portlaoise Substation!O!. Cullenagh Wind Farm Proposed Grid Connection Route Issue Details M7 Rathleague Overbridge Bridge/culvert crossings associated with watercourses/drains Proposed Route River * Floating Road Site Boundary - Permitted Windfarm Substation * EPA mapped watercourses (river networks and streams) ( C. Plant 1: A4 06/07/2016 Cullenagh Wind Farm 38kV Grid Connection Route West Pier Business Campus, Dun Laoghaire, Co Dublin, Ireland. 1. This drawing is the property of RPS Group Ltd. It is a confidential document and must not be copied, used, or its contents divulged without prior written consent. 2. Ordnance Survey Ireland Licence EN Copyright Government of Ireland. T F E W Project No. File Ref: Projection: MDR0686A MDR0686Aarc1025F01 ITM (IRENET95) +353 (0) (0) ireland@rpsgroup.com rpsgroup.com/ireland PASS Cremorgan stream CULLENAGH Foyle (Laois) Ballinclogh lower stream CLONCULLANE BALLYROAN DOOARY CLONTYCOE Ballyroan CLARBARRACUM BALLYKING stream Golf club Togher North stream CRUBEEN PALLAS_BIG BALLYRUIN Kylegrove stream CLONROOSK_LITTLE RAHEENABROGUE Pallas stream stream Coolnamona ROSS COOLNAMONA FATHARNAGH BALLYNAMUDDAGH Stream Clonawoolan COLT CLONDOUGLAS CLONAWOOLAN Ballytarsna DERRYKEARN stream Iry Cappanacloghy TRUMRA DERRAUGH ROSSKELTON BAWNAREE FOXBURROW DOON CROMOGE Nore

14 ROSS Legend Iry stream Kylegrove stream Golf clu b stream!?!. Little Borris Ratheven Portlaoise Substation!? Portlaoise Substation!O!. M7 Rathleague Overbridge Bridge/culvert crossings associated with watercourses/drains Proposed Route CLONEN AGH Togher CURRIERSBOG North stream Triogue!.!.!.!. MEELICK!O M7 Rathleague Overbridge Salmonid Waters River * Nore FWPM Catchment ** TRUMRA FATHARNAGH Togher South stream!.!.!. Pass Pass stream of the plumes str Stradbally [Laois] Crooked [Stradbally] Honey stream Floating Road Site Boundary - Permitted Windfarm Substation * EPA mapped watercourses (river networks and streams) ( ** Freshwater Pearl Mussel Catchments of SAC Populations Listed in S.I. 296/2009 DERRAU GH BAWNAREE Cappanacloghy CLONDOUGLAS C O LT P ASS!.!. Foyle (Laois ) CULLENAGH Substation Cremorgan strea m COOLNABACKY Client Kilometers DERRA U GH DOON CROMOGE FOXBURROW Clonawoolan Stream BALLYRUIN Ballyro an CRUBEEN B ALLYROA N!.!. CLONCULLANE Ballinclogh lower stream Aghoney T IMA HOE FOSSY_L OWER Title Cullenagh Wind Farm 38kV Grid Connection Route EPA Mapped Watercourse Crossings and Margaritifera Catchment Nore Ballytarsna RAHEENABROGUE BLACKHILLS D OO ARY BALLYKING CLONTYCOE CLARBARRACUM stream Owveg [Nore] KNOCKAC RIN Issue Details Drawn By: H. Flynn Checked By: S. Khan Approved By: K. Banks Scale: Date: West Pier Business Campus, Dun Laoghaire, Co Dublin, Ireland. 1: A3 06/07/2016 T +353 (0) F +353 (0) E ireland@rpsgroup.com W rpsgroup.com/ireland Project No. File Ref: Projection: MDR0686A MDR0686Aarc1024F01 ITM (IRENET95) NOTE: 1. This drawing is the property of RPS Group Ltd. It is a confidential document and must not be copied, used, or its contents divulged without prior written consent. 2. Ordnance Survey Ireland Licence EN Copyright Government of Ireland.

15 Proposed 38kV Underground Electric Grid Connection to permitted wind farm at Cullenagh, Co. Laois - Screening for Appropriate Assessment 1.4 DESCRIPTION OF THE PROJECT It is fully acknowledged that the current proposal for a grid connection to the Cullenagh Windfarm is part of a much larger wind farm development. As such the project description must take account of both the wind turbines and the supporting infrastructure as well as the necessary grid connection. To avoid duplication, the detailed description of the wind farm project is not repeated here however the associated NIS is included as an appendix for full reference. The current proposed development is for the installation of a 38kV underground electricity cable to enable a grid connection of approximately 15 km between the permitted windfarm substation at Cullenagh and the existing substation on the Abbleyleix Road in Portlaoise. The permitted Cullenagh substation will connect to a transmission substation at the existing ESB Substation on the Abbeyleix Road in Portlaoise using 38kV underground cable. The cable routes will for the most part be laid along public roads in accordance with the system operator s Specification for the Installation of Ducts 1 or appropriate industry standard for medium voltage cable; and in accordance with best practice guidelines for environmental protection and the protective measures as set out in the outline Construction Methodology prepared for the proposed development (see the Outline Construction Methodology and associated Outline Surface Water Management Plan which is provided under a separate cover). The 38kV underground cable will be provided in ducting; joint bays, chamber bays and sheath link boxes will be installed underground; and inspection chambers, marker posts and marker plates will be placed above ground, along with all other ancillary works (for example specified bridge works, temporary construction/traffic management, environmental protection works). The underground cables will be installed within ducting in excavated trenches of approximately 1.2m depth. Cables will be pulled through in sections of approximately m. This is the typical maximum for the length of cabling that can be pulled between joint bays and therefore influences the location of the joint bays. These joint bays will be approximately 6m in length, 2.5m wide and approx. 2.5m deep. Chamber bays (for communications chambers) and sheath link boxes will be provided adjacent to each joint bay. The communications chambers will be approx. 1.1m wide, 1.52m long and 1.5m deep. The works will predominantly be carried out within the public road and adjacent verges other than at Cullenagh Mountain, where the development will be carried out within Coillte land connected to the proposed wind farm substation and also within private lands where the route exits the permitted wind farm site. The route may also leave the public road for a short section between Cashel and Ballycarnan, where it may run through Coillte lands at the floating road section. There are no in-stream works proposed as part of the grid connection construction. All road excavations will be carried out on a phased basis, with a 2-3km separation between crews operating simultaneously. 1 ESBN Specification for the Installation of Ducts and Structures for Underground 38kV Power Cables and Communication Cables (2009) 3

16 Proposed 38kV Underground Electric Grid Connection to permitted wind farm at Cullenagh, Co. Laois - Screening for Appropriate Assessment The trenches will then be backfilled and all of the areas that were excavated will be reinstated. Inspection covers will be provided as necessary within the reinstated areas. The grid connection will be tested and commissioned for use prior to final reinstatement Proposed Grid Connection Route The proposed grid connection entails the connection of energy generated from the Cullenagh Wind Farm to the existing grid infrastructure at Portlaoise via an underground cable along the route illustrated in Figure 1.1. The choice and selection of route has taken into account environmental considerations as well as land availability. The route starts on the northern side of Cullenagh Mountain and travels in a southerly direction towards Ballyroan, where it traverses Banny s Bridge before travelling along Chapel Street until the route meets the R425. From there the route changes direction and will travel along the R425 in a northern direction along the main street. Further along the R425, the grid connection route passes through the townlands of Crubeen, Ballyrun and Cashel. The route continues along the R425 towards the Ballycarnan Cross roads along a straight stretch of road whereupon the route travels into Cappoley (Sheffield Cross Roads), to the south of the M7 (and R425/R426). The route travels along the R425 crossing the M7 whereupon it changes direction (westwards) along the R426 (Well Road). The route follows the R426 for a short stretch before turning east along a third class road, before turning north along the Abbeyleix Road to the east of the Parkside shopping centre before connecting with the existing ESB substation which is located to the north of Cherrygarth residential estate. The methodology for the ducting installation will be finalised subject to further site investigation works. The potential installation methodologies are described in the following sections so that the impacts of all methods that may be adopted are assessed Open Country The proposed grid connection cable route will traverse approximately 1.2km of improved grassland as the route leaves Cullenagh Mountain and runs down towards Ballyroan. The proposed grid connection may also traverse approximately 700m adjacent to the floating road section. Power ducts will be placed within a trench approximately 1.2m deep and 0.6m wide with a minimum cover of 0.95m from the top of the ducts. All trenching works are to be undertaken using a cut and fill procedure to ensure that only short sections of the trench are open at any one time. Where topsoil is removed it will be stored separately for reinstatement later. Grass will be reinstated by either seeding or by replacing grass turves. 4

17 Proposed 38kV Underground Electric Grid Connection to permitted wind farm at Cullenagh, Co. Laois - Screening for Appropriate Assessment An assessment of all areas of natural drainage from the area of works has been carried out, and protective measures have been built into the programme design to prevent any material draining from the trenching works into adjacent drainage ditches or streams (see Outline Construction Methodology and associated Outline Surface Water Management Plan which is provided under a separate cover). The proposed sequence of works is as follows: Excavate the trench to the required dimensions, approximately 1.2m deep and 0.6m wide; Place a level 65mm blinding layer with semi-dry leanmix concrete at the base of the trench; Place and joint the cable trefoil 110mm HDPE power ducts using cable ties at 3m intervals; Lay in and compact a 300mm layer of leanmix concrete CBM4 around and above ducts; Place an additional 90mm of CBM4 and install the 400mm wide red marker strips above the duct positions; Install a single 110mm HPDE communications cable duct, or two where required spaced a clear 200mm apart using appropriate spacers; Lay in and compact an additional 185mm of CBM4, and place another 400mm wide red marker strip above; Final backfill layer to include a 500mm wide yellow warning tape 300mm below the finished surface In Road It is proposed to install the majority of the grid connection cable route ducting in the body of public roads (78% of its length in total). The proposed route will also run along approximately 1450m of forestry tracks at Cullenagh Mountain in order to connect to the proposed substation. No in-stream works are proposed for the duct installation. The 38kV grid connection will be installed either directly within the road or in the roadside verge. This will depend primarily on the available verge width, presence of existing utilities and the nature of the road and adjoining terrain. In some instances it may not be permitted to excavate trenches within the verge if there is a risk that the edge of the road may be destabilised. This is a particular risk on raised embankments. In such scenarios it would be preferable to excavate a trench within the middle of the lane, or the middle of the roadway. Additional stabilising measures may be required to reinforce the verge and edge of the road. The cable power ducts shall be placed in accordance with the ESBN Specification, within a trench approximately 1.2m deep and 0.6m wide with a minimum cover of 0.95m from top of trefoil group of ducts. ESB communications ducts should be placed with a minimum cover of 0.75m. All trenching works shall be undertaken using a cut and fill procedure, to ensure that only short sections of the trench are open... The footprint of the works shall be kept to a minimum. An assessment of all areas of natural drainage from the area of works has been carried out and protective measures have been built into the programme design to prevent material draining from the trenching works into adjacent drainage ditches or streams (see Outline Construction Methodology and associated Outline Surface Water Management Plan which is provided under a separate cover). The proposed sequence of works is as detailed in Section

18 Proposed 38kV Underground Electric Grid Connection to permitted wind farm at Cullenagh, Co. Laois - Screening for Appropriate Assessment Bridge and Culvert Crossings As stated, there is no in-stream works proposed as part of the grid connection construction. An initial assessment of all bridge and culvert crossings has been undertaken and further detailed assessments of bridges and culverts will be conducted as part of the detailed design of the grid connection. These detailed assessments shall involve survey of the structural dimensions to establish the available depth below the road surface for the cable crossing. Existing utility crossings will also be identified. Where there is sufficient depth of cover in the road or roadside verge at a given bridge crossing, the 38kV grid connection cable ducting will be installed in the roadside verge across the bridge, or within the road itself where there is no verge or the verge is too narrow. If there is a risk to the stability of the parapet or spandrel walls the ducting may be placed in a trench towards the centre of the lane or the road itself, maintaining a greater separation distance from the parapets. If there is insufficient depth within the road base, then an alternative method may be required such as directional drilling below the bridge foundations (see Section ). In certain scenarios where insufficient depth is available it may be possible to create a raised verge to encase the cables within galvanised steel plates and concrete. Alternatively, a less preferred option is to attach the cables externally along the spandrel wall. No instream works are required as part of the proposed scope of works. In addition to the bridge and culvert crossing associated with water course/ drain crossing there is a crossing of the M7 motorway via the Rathleague overbridge on the R425. The works to the bridge that are required to facilitate the grid connection works will include, inter alia, the removal of bridge surfacing and waterproofing and bridge joints, the provision of raised verges of concrete construction to house service ducts, the provision of access chambers, the taking down of the existing 1.0m high bridge parapet, the modification of the existing reinforced concrete parapet plinth, the provision of a new parapet system that will be 1.25m high in accordance with current TII standards, the replacement of bridge deck surfacing and waterproofing and bridge joints, the replacement of road lining, marks and studs. The works will require motorway traffic management to assist with the erection of specialist access formwork for parapet replacement. Protective measures have been built into the programme design (such as silt traps, check dams and bunds - see Outline Construction Methodology and associated Outline Surface Water Management Plan which is provided under a separate cover) to prevent deleterious substances entering watercourses Directional Drilling As stated in Section , the grid connection ducting will be placed in the body of the road wherever possible. Should it not be possible to cross watercourses in the body of the road, then directional drilling will be used. No in-stream works are proposed for the duct installation. Directional drilling is the preferred option at the floating road section, which includes the crossing of three drains (crossings 4, 5 and 6, Figure 1.1). 6

19 Proposed 38kV Underground Electric Grid Connection to permitted wind farm at Cullenagh, Co. Laois - Screening for Appropriate Assessment Protective measures have been built into the programme design (see Outline Construction Methodology and associated Outline Surface Water Management Plan which is provided under a separate cover) to prevent deleterious substances arising from directional drilling from entering watercourses Floating Road It is intended that the grid route within the floating road section is to be located within Coillte lands. A 5m wide temporary track (plus suitable access and egress) will be constructed within Coillte lands. This will require the felling of trees within its 5m boundary and will allow for access by construction traffic. Suitable drainage features will be installed, where necessary, in order to avoid ponding of surface water resulting from the construction of the track. Protective measures for the floating road section and associated drainage features have been built into the works methodology, as detailed in the Outline Construction Methodology (the Outline Construction Methodology and associated Outline Surface Water Management Plan is provided under a separate cover). Other options to construct the grid connection at this location include directional drilling for the entire length or the construction of a floating trench in the road. 7

20 Proposed 38kV Underground Electric Grid Connection to permitted wind farm at Cullenagh, Co. Laois - Screening for Appropriate Assessment 2 METHODOLOGY 2.1 GUIDANCE DOCUMENTS ON APPROPRIATE ASSESSMENT Where an AA is necessary, the AA requirements of Article 6(3) of the Habitats Directive 92/43/EEC (European Communities 2001) follow a sequential approach as outlined in the following guidance documents and memoranda, namely: Appropriate Assessment of Plans and Projects in Ireland Guidance for Planning Authorities. Department of Environment, Heritage and Local Government, 2010 revision. Appropriate Assessment under Article 6 of the Habitats Directive: Guidance for Planning Authorities. Circular NPWS 1/10 and PSSP 2/10. 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/EEE (European Commission Environment Directorate-General, 2002). Managing Natura 2000 Sites: The provisions of Article 6 of the Habitat s Directive 92/43/EEC (European Commission Environment Directorate-General, 2000). Guidance Document on Article 6(4) of the Habitat s 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 January 2007). Guidelines for Good Practice Appropriate Assessment of Plans Under Article 6(3) Habitats Directive (International Workshop on Assessment of Plans under the Habitats Directive, 2011). 2.2 STAGES OF APPROPRIATE ASSESSMENT The AA process consists of four potential stages. If at the first stage in the process it is determined that there will be no significant effect on a European Site, 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 relates to Regulation 42 (1) of the Birds and Natural Habitats Regulations; and Stage 2 relates to Article 6(3) of the Habitats Directive; and Stages 3 and 4 to Article 6(4) of the Habitats Directive. Stage 1: Screening 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 in light of its conservation objectives. 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 likely to be significant effects or there 8

21 Proposed 38kV Underground Electric Grid Connection to permitted wind farm at Cullenagh, Co. Laois - Screening for Appropriate Assessment is uncertainty regarding the significance of effects then it will be recommended that a project is brought forward to full AA. 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 3. Stage 3: Assessment of Alternative Solutions If it is not possible during the stage 2 to reduce impacts to acceptable, non-significant levels by avoidance and/or mitigation, 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 negative 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, 2002). In other words, if alternative solutions exist that do not have negative impacts on European Sites; they should be adopted regardless of economic considerations. Stage 4: Imperative Reasons of Overriding Public Interest (IROPI)/Derogation This stage of the AA process is undertaken when it has been determined that negative impacts on the integrity of a European Site will result from a plan or project, 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 overriding 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 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. 2.3 INFORMATION CONSULTED FOR THIS REPORT Sources of data reviewed as part of the Screening process for this project included: Information on the location, nature and design of the proposed project supplied by the RPS design team; Department of Environment, Community and Local Government online land use mapping Environmental Protection Agency Water Quality ESRI Ireland - Mapping Themes 9

22 Proposed 38kV Underground Electric Grid Connection to permitted wind farm at Cullenagh, Co. Laois - Screening for Appropriate Assessment Geological Survey of Ireland Geology, soils and Hydrogeology Information on the conservation status of birds in Ireland (Colhoun & Cummins 2014); Information on the eastern river basin district Water Framework Directive website National Parks and Wildlife Service online Natura 2000 site network information, including site conservation objectives National Parks and Wildlife Service Information on the status of EU protected habitats in Ireland (NPWS 2013a, 2013b); National Biodiversity Data Centre and Ordnance Survey of Ireland Mapping and Aerial photography SCREENING PROTOCOL Screening Sequence Definition of the zone of influence for the proposed works; Identification of the European Sites that are situated (in their entirety or partially) within the zone of influence of the proposed works; Identification of the most up-to-date Qualifying Interests (QIs) for each European Site occurring either wholly or partially within the zone of influence; Identification of the environmental conditions that maintain the QIs at the desired target of Favourable Conservation Status; Identification of the threats/impacts actual or potential that could negatively impact the environmental conditions of the QIs within the European Sites; Highlighting the activities of the proposed works that could give rise to significant negative impacts; and Identification of other plans or projects, for which in-combination impacts would likely have significant effects Screening Determination In accordance with Regulation 42 (6) and 42 (7) of the Birds and Natural Habitats Regulations 2011 (S.I. No. 477/2011) as amended: (6) The public authority shall determine that an Appropriate Assessment of a plan or project is required where the plan or project is not directly connected with or necessary to the management of the site as a European Site and if it cannot be excluded, on the basis of objective scientific information following screening under this Regulation, that the plan or project, individually or in combination with other plans or projects, will have a significant effect on a European site. (7)The public authority shall determine that an Appropriate Assessment of a plan or project is not required where the plan or project is not directly connected with or necessary to the management of the site as a European Site and if it can be excluded on the basis of objective scientific information following screening under this Regulation, that the plan or project, individually or in combination with other plans or projects, will have a significant effect on a European site. 10

23 Proposed 38kV Underground Electric Grid Connection to permitted wind farm at Cullenagh, Co. Laois - Screening for Appropriate Assessment 3 SCREENING OF EUROPEAN SITES 3.1 BRIEF DESCRIPTION OF THE EUROPEAN SITES WITHIN THE ZONE OF INFLUENCE A buffer of 15km is typically taken as the initial zone of influence (ZoI) extending beyond the reach of the footprint of a plan or project, as per Ministerial guidance (DoEHLG 2010), although there may be scientifically appropriate reasons for extending this ZoI further afield depending on the pathway of potential impacts e.g. in the case of sites with water dependent habitats or species, and a plan or project that could affect water quality or quantity, for example, it may be necessary to consider the full extent of the upstream and/or downstream catchment. In regard to the current proposal, the 15 kilometre distance is considered acceptable to screen all likely significant effects that might impact upon the European Sites. The European Sites are shown in Table 3.1, while Figure 3.1 is a cartographic representation of the same data. The spatial boundary data for the European Sites shown in Figure 3.1 was the most recent available at the time of writing. Table 3-1: European Sites within 15km Zone of Influence of the Proposed Grid Connection European Site River Barrow and River Nore SAC Site Code Approximate Distance (km s) from the Proposed Grid Connection Ballyprior Grassland SAC Lisbigney Bog SAC Slieve Bloom Mountains SAC Mountmellick SAC River Nore SPA Connectivity Remote, indirect connectivity via the Ballyroan Stream, which confluences with the River Nore approximately 12km downstream from the proposed grid route at its closest point and also via the Triogue River and its tributaries, which confluence with the River Barrow approximately 16km downstream from the proposed grid route at its closest point. There is no connectivity, direct or indirect between the proposed works and the SAC There is no connectivity, direct or indirect between the proposed works and the SAC There is no connectivity, direct or indirect between the proposed works and the SAC There is no connectivity, direct or indirect between the proposed works and the SAC Remote, indirect connectivity via the Ballyroan Stream, which confluences 2 Measured as the crow flies 11

24 Proposed 38kV Underground Electric Grid Connection to permitted wind farm at Cullenagh, Co. Laois - Screening for Appropriate Assessment European Site Slieve Bloom Mountains SPA Site Code Approximate Distance (km s) from the Proposed Grid Connection Connectivity with the River Nore approximately 12km downstream. There is no connectivity, direct or indirect between the proposed works and the SPA Whilst the European Sites within the zone of influence have been identified, the assessment cannot be carried out without an idea of the ecological conditions and hence scientific parameters that led to its designation. In this regard the Qualifying Interests (QIs) and Special Conservation Interests (SCIs) for Special Protection Areas are described further Qualifying Interests Under the Habitats Directive, a number of species and habitats have been prioritised for conservation purposes. For an SAC, the specific Annex I Habitats and Annex II Species for which a specific site has been formally designated for are referred to as Qualifying Interests (QIs), whilst the selected Annex I bird species of an SPA are known as Special Conservation Interests (SCIs). The Qualifying Interest for SACs and Special Conservation Interests for SPAs of the European Sites potentially impacted by the plan were downloaded from the NPWS website. The data is shown in Table 3.2 and Table

25 Clonaslee Eskers And Derry Bog SAC River Barrow And River Nore SAC River Barrow And River Nore SAC Legend!? Portlaoise Substation River Barrow And River Nore SAC River Barrow And River Nore SAC Mountmellick SAC River Barrow And River Nore SAC!O M7 Rathleague Overbridge Proposed Route Ballyroan River Triogue River Slieve Bloom Mountains SPA Slieve Bloom Mountains SAC Slieve Bloom Mountains SPA Slieve Bloom Mountains SAC European Sites within a 15km Buffer Special Area of Conservation Special Protection Areas Floating Road Portlaoise Substation Site Boundary - Permitted Windfarm River Barrow And River Nore SAC Substation!? M7 Rathleague Overbridge!O Substation Ballyprior Grassland SAC Ballyprior Grassland SAC River Barrow And River Nore SAC Coolrain Bog SAC Knockacoller Bog SAC Kilometers Client River Barrow And River Nore SAC Cullenagh Wind Farm 38kV Grid Connection Route River Barrow And River Nore SAC Title River Barrow And River Nore SAC European Sites within a 15km Buffer River Nore SPA Lisbigney Bog SAC River Nore SPA River Nore SPA River Barrow And River Nore SAC Issue Details Drawn By: H. Flynn Checked By: S. Khan West Pier Business Campus, Dun Laoghaire, Co Dublin, Ireland. T +353 (0) F +353 (0) E ireland@rpsgroup.com W rpsgroup.com/ireland Project No. File Ref: MDR0686A Galmoy Fen SAC River Nore SPA River Nore SPA River Barrow And River Nore SAC River Barrow And River Nore SAC River Barrow And River Nore SAC River Barrow And River Nore SAC River Barrow And River Nore SAC Approved By: K. Banks Scale: Date: A3 06/07/2016 MDR0686Aarc1023F01 Projection: ITM (IRENET95) NOTE: 1. This drawing is the property of RPS Group Ltd. It is a confidential document and must not be copied, used, or its contents divulged without prior written consent. 2. Ordnance Survey Ireland Licence EN Copyright Government of Ireland.

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27 Proposed 38kV Underground Electric Grid Connection to permitted wind farm at Cullenagh, Co. Laois - Screening for Appropriate Assessment Conservation Objectives The integrity of a European Site (referred to in Article 6.3 of the Habitats Directive) whether it be a Special Area of Conservation (SAC) or Special Protection Area (SPA) is determined based on the conservation status of the individual qualifying features (QIs or SCIs) of the designated site. The overarching aim of the Natura 2000 network is to achieve Favourable Conservation Status of conservation worthy habitats listed in Annex I and the habitats of species listed in Annex II of the Habitats Directive and/or of regularly occurring migratory bird species as well as those species defined in Annex I of the Birds Directive. It should be noted that in some situations that there is overlap in extent between certain SACs and SPAs and indeed SAC and SAC. In that regard, the COs should be jointly used as appropriate. The qualifying features for each site have been obtained through a review of the Conservation Objectives available from the NPWS: The dates of the latest Conservation Objectives (COs) are included in Appendix A and B. Given the number of European Sites that could potentially be impacted by the proposed grid connection works, there is a considerable amount of data contained therein. For brevity, the site specific COs are summarised thus: To maintain or restore the favourable conservation condition of Annex I habitats and Annex II species for which the SAC has been selected; and To maintain or restore the favourable conservation condition of the bird species listed as Special Conservation Interests for the SPA Documented Threats to European Sites The threats and pressures for the various QIs have been extracted primarily from a number of NPWS authored reports, namely Natura 2000 site datasheets and site synopses ( Other key source material is from the recently available statutory assessments on the conservation status of habitats and species in Ireland namely; The status of EU protected Habitats and Species in Ireland (NPWS 2013 a, b &c) and on information contained in Ireland s most recent Article 12 submission to the EU on the Status and trends of Birds species ( ). A summary list of all documented threats to the European Sites within the zone of influence are shown in Table 3.2 and Table

28 Proposed 38kV Underground Electric Grid Connection to permitted wind farm at Cullenagh, Co. Laois - Screening for Appropriate Assessment Table 3-2: Special Area of Conservation (SACs) within 15km zone of influence of Proposed Cullenagh Grid Connection Site Name Site Code Qualifying Interest Documented Threats and Pressures * River Barrow and River Nore SAC Annex I Habitats Estuaries [1130] Mudflats and sandflats not covered by seawater at low tide [1140] Salicornia and other annuals colonizing mud and sand [1310] Atlantic salt meadows (Glauco-Puccinellietalia maritimae) [1330] Mediterranean salt meadows (Juncetalia maritimi) [1410] Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho- Batrachion vegetation [3260] European dry heaths [4030] Hydrophilous tall herb fringe communities of plains and of the montane to alpine levels [6430] Petrifying springs with tufa formation (Cratoneurion) [7220] Old sessile oak woods with Ilex and Blechnum in British Isles [91A0] Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-Padion, Alnion incanae, Salicion albae) [91E0] Annex II Species Desmoulin's Whorl Snail (Vertigo moulinsiana) [1016] Freshwater pearl mussel (Margaritifera margaritifera) [1029] White-clawed crayfish (Austropotamobius pallipes) [1092] The SAC is under threat/pressure from: hunting, leisure fishing, urbanised areas/human habitation, sylviculture/forestry, landfill, land reclamation and drying out, sand and gravel extraction, industrial or commercial areas, port areas, sand and gravel quarries, discharges, fertilisation, grazing, marine and freshwater aquaculture, cultivation, and restructuring agricultural land holding. 14

29 Proposed 38kV Underground Electric Grid Connection to permitted wind farm at Cullenagh, Co. Laois - Screening for Appropriate Assessment Site Name Site Code Qualifying Interest Documented Threats and Pressures * Ballyprior Grassland SAC Sea lamprey (Petromyzon marinus) [1095] Brook lamprey (Lampetra planeri) [1096] River lamprey (Lampetra fluviatilis) [1099] Allis shad (Alosa alosa) [1102] Twaite shad (Alosa fallax fallax) [1103] Salmon (Salmo salar) [1106] Otter (Lutra lutra) [1355] Nore Freshwater Pearl mussel (Margaritifera durrovensis) [1990] Killarney fern (Trichomanes speciosum) [1421] Annex I Habitats Semi-natural dry grasslands and scrubland facies on calcareous substrates (Festuco Brometalia) (*important orchid sites) [6210] The SAC is under threat/pressure from: fertilisation, paths/tracks/cycling tracks, forest replanting, grazing, restructuring agricultural land holding, removal of hedges and copses or scrub, and mowing/cutting of grassland. Lisbigney Bog SAC Annex I Habitats Calcareous fens with Cladium mariscus and species of the Caricion davallianae [7210] The SAC is under threat/pressure from: fertilisation, sylviculture/forestry, and grazing. Slieve Bloom Mountains SAC Annex I Habitats Northern Atlantic wet heaths with Erica tetralix [4010] Blanket bogs (* if active bog) [7130] Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-Padion, Alnion incanae, Salicion albae) [91E0] Specific threats/ pressures not listed for the SAC. The primary threats to Irish blanket bogs in general are afforestation, drainage and over-grazing. Mountmellick SAC Annex II Species Desmoulin's Whorl Snail (Vertigo moulinsiana) [1016] No threats or pressures listed. *Information primarily based on NPWS Data Sheets & Site Synopses; and Status of EU protected Habitats and Species in Ireland (NPWS 2013a, b & c) and Ireland s Article 12 submission to EU commission on the Status and trends of bird species ( 15

30 Proposed 38kV Underground Electric Grid Connection to permitted wind farm at Cullenagh, Co. Laois - Screening for Appropriate Assessment Table 3-3: Special Protection Areas (SPAs) within 15km zone of influence of Proposed Cullenagh Grid Connection Site Name Site Code Special Conservation Interest s Documented threats and Pressures * River Nore SPA Kingfisher (Alcedo atthis) [A229] Slieve Bloom Mountains SPA Hen Harrier (Circus cyaneus) [A082] The SPA is under threat/pressure from: landfill, land reclamation and drying out, and port areas. The SPA is under threat/pressure from: roads, motorways, sylviculture, forestry, grazing, dispersed habitation, paths/tracks/cycling tracks, and peat extraction. * Information primarily based on NPWS Data Sheets & Site Synopses; and Status of EU protected Habitats and Species in Ireland (NPWS 2013a, b & c) and Ireland s Article 12 submission to EU commission on the Status and trends of bird species ( 16

31 Proposed 38kV Underground Electric Grid Connection to permitted wind farm at Cullenagh, Co. Laois - Screening for Appropriate Assessment 4 ASSESSMENT CRITERIA 4.1 IS THE GRID CONNECTION NECESSARY TO THE MANAGEMENT OF NATURA 2000 SITES? The proposal is not directly connected with or necessary to the management of any European Site. 4.2 DIRECT, INDIRECT OR SECONDARY IMPACTS OF THE GRID CONNECTION Table 3.2 and Table 3.3 list the European Sites within 15km of the proposed Grid Connection, Cullenagh. There are seven sites in all, five SACs and two SPAs. The proposed works are not situated within any SACs or SPAs, therefore no direct impacts will occur through landtake or fragmentation of habitats. There is no hydrological connectivity between the proposed works and Ballyprior Grassland SAC, Lisbigney Bog SAC, Slieve Bloom Mountains SAC and Mountmellick SAC. Furthermore, these sites are situated a significant distance from the proposed works and will not be impacted either directly or indirectly. Therefore potential impacts to these sites are no longer considered as part of this assessment. Likewise, there is no hydrological connectivity to the Slieve Bloom Mountains SPA and the site is situated a significant distance from the proposed works (8 km from the closest point of the SPA to the closest point of the proposed grid connection). A good population of hen harriers exists in the Slieve Bloom Mountains SPA but the home range of the species is normally 3-7km² with exceptional feeding by males at 10km from nesting site. The predominant habitat adjoining the proposed grid connection route (the majority of which is located in the public road corridor) is improved grassland, with a small area of cutover bog and closed canopy conifer plantation. These habitats are not favoured for nesting by Hen Harrier, and improved grassland does not constitute good foraging habitat for this species. No Hen Harriers were observed during any of the ornithological surveys conducted as part of the EIS conducted for the Cullenagh Wind Farm 3. In consideration of the aforementioned factors and the nature of the proposed work (predominantly in road trenching and ducting works for the purpose of laying an underground cable), it is considered that any disturbance to Hen Harrier within this European Site as a result of the proposed works is extremely unlikely. Furthermore, any potential disturbances, although extremely unlikely, would be temporary and confined to the construction phase of the works only. Therefore, it is not anticipated that the proposed works will have a significant effect on the Slieve Bloom Mountains SPA with regards to Hen Harrier. The potential impacts on European Sites as a result of the proposed works are limited to impacts primarily related to changes in water quality at watercourse crossings and noise related activity to the River Barrow and River Nore SAC and the River Nore SPA, as discussed below. The proposed cable works cross a tributary of the River Nore at one location along its length (the Ballyroan Stream, Nore River Catchment), and tributaries of the River Barrow at seven locations along its length (the Triogue River and its tributaries, Barrow River Catchment). The proposed works therefore have an indirect, although remote, connectivity to the River Barrow and River Nore SAC. 3 Coillte (2013) Cullenagh Wind Farm Environmental Impact Statement. 17