EIA Screening Reportdocstore.kerrycoco.ie/KCCWebsite/part8/brackaharagh... · This Environmental Impact Assessment (EIA) Screening Report has been prepared to ... in terms of deciding

Environmental Impact Assessment

Screening Report

for the

proposed

N70 Brackaharagh Road Project

Eoin Kelleher

Executive Planner and Ecologist

Environmental Assessment Unit

Kerry County Council

October 2017

Executive Summary

This Environmental Impact Assessment (EIA) Screening Report has been prepared to

consider the requirement or otherwise of carrying out an EIA in respect of the N70

Brackaharagh Road Project, at Brackaharagh, Caherdaniel, Co Kerry.

This screening exercise was undertaken in two stages. The first stage considered the

requirement for a mandatory EIA, while the second stage considered the requirement

or need for a sub-threshold EIA. As part of the sub-threshold screening exercise, the

potential for impacts on environmental sensitivities was considered in addition to the

interrelationship between those environmental sensitivities. Following on from this,

the formal EIA Screening Exercise was completed, having regard to the criteria set out

in the Roads Act, as amended and in the EIA Directive (2014/52EU). The findings of

other reports prepared in relation to this report were also taken into account

(Preliminary Cultural Heritage Impact Assessment, Landscape and Visual Impact

Assessment, Strictly Protected Species Report, Habitats Directive Assessment Report).

This report concludes that this is a sub-threshold type project which is not likely to

have a significant effect on the environment, either by itself or in combination with

other plans or projects, and that an Environmental Impact Assessment (EIA) is not

required in this instance.

1. Introduction

The Environmental Assessment Unit (Planning and Sustainable Development

Department) has been requested by the Kerry National Road Design Office to assist in

forming an opinion as to whether or not the proposed road project, at Brackaharagh,

Caherdaniel, Co Kerry should be subject to Environmental Impact Assessment (EIA).

Experience and rulings by the European Court of Justice have shown that, in certain

circumstances, small-scale projects can have significant effects on the environment.

This report comprises an Environmental Impact Assessment Screening Report and will

be taken into consideration by the Competent Authority in its determination as to

whether EIA is required in this instance.

1.3 Legislative context

EIA legislation sets down the types of projects that may require an EIA. Annex I of

Directive 2011/92/EU, as amended by Directive 2014/52/EU’defines mandatory

projects that require an EIAR / EIS and Annex II lists projects which can be subject to

case by case analysis or thresholds to be determined by member states. The relevant

threshold summaries of legislative requirements for EIA Screening for road type

developments (in Ireland) are set out in Table 1 below.

Table 1 Summary of Legislative Requirements for EIA Screening – From the Roads

Act (1993–2016); based on the original format in the NRA Guidelines on EIA (2008).

Mandatory Regulatory Reference

(1) Construction of a motorway S. 50.—(1) (a)(i) of the

Roads Act, 1993-2016.

(2) Construction of a busway S. 50.—(1) (a)(ii) of the

Roads Act, 1993-2016.

(3) Construction of a service area S. 50.—(1) (a)(iii) of the

Roads Act, 1993-2016.

(4) Any

prescribed

type of

proposed

road

development

consisting of

the

construction

of a proposed

public road or

the

improvement

of an existing

public road,

namely:

The construction of a new road of

four or more lanes, or the

realignment or widening of an

existing road so as to provide

four or more lanes, where such

new, realigned or widened road

would be eight kilometres or

more in length in a rural area, or

500m or more in length in an

urban area;

The construction of a new bridge

or tunnel which would be 100

metres or more in length.

Article 8 of the Roads

Regulations, 1994 (Part V

Environmental Impact

Assessment)

Article 8 of the Roads

Regulations, 1994 (Part V

Environmental Impact

Assessment)

Sub-Threshold Regulatory Reference

(4) Where An Bord Pleanála considers that any

proposed road development (other than

development to which mandatory requirement

applies) consisting of the construction of a

proposed public road or the improvement of an

existing public road would be likely to have

significant effects on the environment, he shall

direct the road authority to prepare an

environmental impact statement in respect of

such proposed road development and the

authority shall comply with such direction.

S. 50.—(1) (b) of the

Roads Act, 1993 - 2016.

(5) Where a road authority considers that any

proposed road development (other than

development to which mandatory requirement

applies) consisting of the construction of a

proposed public road or the improvement of an

existing public road would be likely to have

significant effects on the environment, it shall

S. 50.—(1) (c) of the

Roads Act, 1993 - 2016.

inform the Board in writing and where the Board

concurs with the road authority he shall give a

direction to the road authority (as above).

(i) a European Site,

meaning

(I) a candidate site of

Community importance,

(II) a site of Community

importance,

(III) a candidate special

area of conservation,

(IV) a special area of

conservation,

(V) a candidate special

protection area, or

(VI) a special protection

area

(v) Land established or

recognised as a nature

reserve within the

meaning of section 15 or

16 of the Wildlife Act,

1976 (No. 39 of 1976)

(6) Where a proposed

road development

(other than

development to which

mandatory

requirement applies)

consisting of the

construction of a

proposed public road

or the improvement of

an existing public road

would be located on

certain environmental

sites, the road

authority concerned

shall decide whether

the proposed road

development would or

would not be likely to

have significant

effects on the

environment. The

sites concerned are:

(vi) Land designated as a

refuge for fauna under

section 17 of the Wildlife

Act, 1976 (No. 39 of

1976)

If the authority decides that the proposed road

development would be likely to have significant

effects, it shall inform An Bord Pleanála in writing

(as outlined in (6) above).

S. 50.—(1) (d) of the

Roads Act, 1993 – 2016.

1.4 Methodology

Following on from an outline of a project as described in Section 2 of this report, the

screening exercise will be outlined in two main stages. The first stage, which is

contained within Section 3 of this report considered the requirement for a mandatory

EIA. The second stage considered the requirement or need for a sub-threshold EIA

and is outlined within Section 4 of this report.

2. Project Description

The N70 is a National Secondary roadway. It is a busy route, particularly in the

summer season as it forms part of the ‘Ring of Kerry’ and ‘Wild Atlantic Way’, which

are tourist routes of international renown. The proposed development site is located

on a stretch between Carroll’s Cove and Castle Cove, Caherdaniel, Co Kerry on the

southern side of the Iveragh Peninsula to the north of the Kenmare River Estuary.

The existing carriageway at this location is in poor condition and of restricted width.

This proposal involves the widening/realignment of 1.2 km of the existing road to

provide a 7m wide carriageway. A cycleway is also proposed along with verges and

drainage channels. Typical cross-section varies from 13m to 14m excluding

earthworks and workspace. The proposed widening will require contour re-profiling

works – particularly to the west of the scheme where a rock outcrop adjoins the road.

Boundary treatment / fencing, mammal underpass(s), water quality protection

measures and invasive species management / landscaping, will be provided along the

route, in line with best practice NRA (TII) Guidelines. Other project details are as

follows:-

• The total land take for the project will be 2.77Ha

• The maximum cut height is 10.5m

• The maximum fill height is 2m

• The approximate earthworks quantities are:-

Preliminary Earthworks Quantities

Item Quantity (m3)

Cut 35,217

Fill (Including capping) 6,082

Topsoil 1,357

• The road pavement quantities are:

Preliminary Pavement Quantities

Item Quantity (m3)

Pavement Material – Clause 804 1,901

Pavement Material – Asphalt/Bituminous Macadam 2,139

• The will be a surplus of 27,777m3 of earthworks materials (soil /rock).

• There will be the excavation of 20,756m3 of rock.

Above: Proposed project location – Regional Context

Above: Proposed project location

Above: Proposed Development Chainage 0 to 625m (drawing not to scale)

Above: Proposed Development Chainage 625 to 1184m (drawing not to scale)

Above:Typical Cross Section Chainage 0 to 550m (not to scale)

Above: Typical Cross Section Chainage 550 to 1183m (not to scale).

3. Mandatory requirement for an Environmental Impact Assessment Report (EIAR) /

Environmental Impact Statement (EIS)

3.1 Mandatory requirements

The proposed scheme has been assessed in terms of the mandatory requirement for

an EIA based on the nature or scale of the development, as addressed in the EU

Directive 2014/52/EU and also the Roads Act 1993 - 2016. It is considered that the

proposed road scheme is not one which falls within the scope of this category. As part

of this the requirements laid out in Table 1 have been taken into account.

In particular it is noted that a roadway of 4 or more lanes is not proposed as part of

this proposal. It should be noted that mandatory EIA requirements for non-road type

development have also been considered and discounted in this instance. As part of

this infrastructure type projects listed in the Planning and Development Regulations

2001, as amended and in Annex I and II of the EIA Directive as amended were taken

into account.

4. Sub-threshold requirement for an Environmental Impact Statement

4.1 legislative context and screening methodology

Where a proposed road development would be located on certain environmental

sites (see Table 1), the road authority shall decide whether the proposed road

development would be likely to have significant effects on the environment. The key

issue, in the context of the possible need for EIA of sub-threshold development, is

whether or not such development is likely to have significant effects on the

environment.

The 2014 amending EIA Directive (2014/52/EU) contains guidance for Member States

in terms of deciding whether or not a development is likely to have “significant effects

on the environment”. The guidance is provided by way of criteria set out in Annex III

of the Directive. The criteria are grouped under three headings and are used to help

in the screening process to determine whether a development is likely to have a

significant effect on the environment. The criteria for determining whether a

development would or would not be likely to have significant effects on the

environment are taken from Annex III of the Directive and are grouped under the

following three headings:-

1. Characteristics of the projects

2. Location of the projects

3. Type and Characteristics of the potential Impact

This EIA Screening was prepared having regard to the following guidance documents;

• 2001 European Commission. Guidance on EIA – Screening;

• 2003 Government Publications. Environmental Impact Assessment (EIA) Guidance

for Consent Authorities regarding Sub-threshold Development;

• 2002 Environmental Protection Agency. Guideline on the Information to be

contained in Environmental Impact Statements; and

• 2008 National Roads Authority. Environmental Impact Assessment of National

Road Schemes – A Practical Guide.

• EPA (Draft) Guidelines on the information to have contained in Environmental

Impact Assessment Reports (May 2017).

• Department of Housing, Planning, Community and Local Government, Key issues

consultation paper ' Transposition of 2014 EIA Directive (2014/52/EU) in the Land

Use Planning and EPA Licensing Systems' (May 2017).

• EU Commission Draft Guidance documents on the implementation of the EIA

Directive (April 2017).

Having regard to the above and in order to inform screening evaluation, consideration

was firstly given to environmental sensitivities in the area and to the potential for

impacts on particular aspects of the environment (Section 4.2). This section describes

the aspects of the environment likely to be significantly impacted by the project and

has regard to the Environmental Topics as set out in the EIA Directive as follows:-

• Human beings, Population, and Human Health,

• Biodiversity (inc flora and fauna),

• Land and Soil,

• Water,

• Air and Climate,

• Material Assets, Landscape and Cultural heritage, including architectural and

archaeological aspects, and

• The interrelationship between the environmental topics.

Following on from this, the formal EIA Screening Exercise was completed, in line with

the criteria set out in the EIA Directive. This is contained within Section 4.3 of this

report.

4.2 Overview of potential impacts on environmental sensitivities

4.2.1 Human beings, Population and Human Health

It is expected that this proposal will have a positive impact on human beings,

population and human health by relieving traffic congestion and improving road

safety and the accessibility of the area. Pathways and cycleways can also be used for

recreational purposes and for healthy commuting movements. This proposal would

facilitate sustainable rural and urban development along the roadway and would be a

driver for employment, which is a factor in maintenance of health. In general the

material well being and sense of purpose that a job provides are beneficial to health.

Potential exists, particularly at the construction stage for an amount of nuisance

associated with traffic disruption, dust, noise and vibration. However, any such

impacts would be temporary in nature.

Related Environmental Protection Measures incorporated into the proposal

(i) Construction to be undertaken in accordance with the TII Guidelines for the

Treatment of Air Quality during the Planning and Construction of National Road

Schemes.

(ii) Installation of Road Restraint Systems, comprising of steel safety barriers and in

accordance with the TII's Specification for Road Works Series 400.

(iii) Construction to be undertaken in accordance with the TII Guidelines for the

Treatment of Noise and Vibration in National Road Schemes. As part of this

limits for noise and vibration have been set out in the ‘preliminary project

details and particulars’ report. In addition these outline that a Structural

Engineer will be engaged through the design stage to ensure that the design

and construction of the proposed project does not adversely affect residential

properties and to ensure that appropriate mitigation measures, including a pre-

construction survey and vibration monitoring are implemented.

These measures are all best practice and standard in nature.

4.2.2 Biodiversity (inc Flora and Fauna)

As with any road development project, the proposal will result in habitat loss along

the footprint of the works area. However it is noted that the works will not encroach

on protected sites in this instance. The extent of the required works is also reduced in

this instance given that it is a road widening as opposed to a new road build proposal.

Use of the existing road corridor will ensure that any risks to biodiversity interests are

minimised. No non-native invasive plant species were found to be growing within or

adjoining the site when visited in 2017. Nonetheless it si noted that standard

safeguards are provided for in this regard so as to ensure against the introduction /

spread of same.

It is noted that the works area is located outside of but in close proximity to Natura

2000 designations. The project does not encroach on habitats or areas of importance

outlined in conservation objectives for Natura 2000 sites in the vicinity. As part of this

the Kenmare River SAC (Site Code 002158) conservation objective Report, which was

published by the National Parks and Wildlife Service (NPWS) on the 25th

of April 2013

and the accompanying maps which outline the known location of qualifying habitats

within the SAC, were reviewed. It is noted that the proposal provides for standard

mammal crossings in line with NRA (TII) guidelines so as to ensure mammal

connectivity between designated sites and the wider countryside. It is noted that a

Habitats Directive Assessment has been prepared in support of the proposal which

has concluded that significant effects on Natura 2000 sites are not likely in this

instance.

Above: Kenmare River SAC

Above: Location of N70 in relation SAC boundaries

It is noted that a ecological / strictly protected species report has been prepared in

support of the proposal. As part of this the site was surveyed for the Kerry Lily

Simethis mattiazzii (Simethis planifolia), Kerry Spotted Slug Geomalacus maculosus

and European Otter Lutra lutra, the results of which are summarised as follows:-

Kerry Lily Simethis mattiazzii (Simethis planifolia)

The survey located a population of the protected plant species along the sandstone

ridges on the lower slopes of Coad Mountain to the north of the N70 Ring of Kerry

roadway. For the most part these are located outside of the land take area associated

with the proposed roadway. Notwithstanding this a review of the extent of the

project was undertaken and the land take line amended so as to ensure that where

possible Kerry Lily plants and supporting habitat remained outside of the proposed

land take area. 1 no. Kerry Lily plant remains within the revised land take area.




Schemes.

(ii) Kerry Lily plant which remains within the revised land take area to be

translocated to suitable habitat in the surroundings in agreement with NPWS

and subject to the requirements of a NPWS derogation license.

(iii) Kerry Lily habitat located outside of the land take area to be suitably screened

from dust arising from the proposed construction works as follows:- Rock

outcrop habitat to be fenced and screened from the adjacent road widening

works. This shall consist of the following or similar:- 2.00m high, 200mm x

50mm steel mesh on 70mm x 70mm x 5mm RHS steel posts bedded in concrete

at 2.40 metre centres and covered with a fine synthetic mesh. Standard 60mm

x 60mm posts may be used instead provided adequate additional bracing is

provided. This fence shall be kept in place for the course of the adjoining

construction works and removed thereafter and replaced with a standard

fence. The construction of the fence(s) and its removal to be adequately

supervised by appropriately qualified individuals.

Measure (i) is a best practice and standard type measure. Measures (ii) and (iii) are

Mitigation Measures specific to the project. Measure (iii) has been used in the past at

a similar type road project along the N70 at Glanlough, Castlecove.

Kerry Spotted Slug Geomalacus maculosus

No Kerry Slugs were found on or in the vicinity of the site either by way of the metric

trap surveys undertaken or by way incidental observations.


None.

European Otter Lutra lutra

The coast at this location showed signs of otter activity. Vegetation within the

proposed site was thoroughly searched and no couches or holts were identified.

Sprinting sites and tracks in the vegetation suggested that otters cross the road at two

locations within the site area and another to the northeast of the site (outside of the

site). All of these crossing locations are associated with stream / drainage crossings,

however the culvert of one is currently inaccessible to Otters which results in

hazardous ‘at grade’ crossing movements at that location.


(iv) A Pre-Construction Mammal Survey to take place in line with best practice TII

Guidelines.

(v) Mammal underpasses and mammal resistant fencing to be installed at 2 no.

locations along the scheme as follows:-

• At approximate Chainage 60m a mammal underpass to be installed and a track

provided on the north side of the carriageway to allow mammals to travel up

the otherwise steep rock face. Mammal resistant fencing as per

CC/SCD/00319 to be installed both sides of the mammal underpass where

required. In areas where there is steep rock face mammal fencing will not be

installed.

• Adjacent to the culvert at approximate Ch900m a mammal underpass to be

installed. Mammal resistant fencing as per CC/SCD/00319 to be installed for

50m on both sides of the mammal underpass.

• Mammal underpasses to consist of 600mm pipes extending under the

carriageway, and to be constructed above water level and accessible from

both sites. This is in accordance with the NRA / TII Guidelines for the

Treatment of Otters prior to the Construction of National Road Schemes

(2008).

(vi) Construction management (no work to be undertaken in the vicinity of

identified crossing locations at night to avoid contact with otters and to reduce

the need for light).


Other standard Biodiversity, Flora and Fauna related Environmental Protection

Measures incorporated into the proposal

(vii) Site clearance to be in accordance with Section 40 of the Wildlife Act 1976, as

amended by Section 46 of the Wildlife (Amendment) Act 2000.

(viii) Standard environmental protection measure for invasive non-native plant

species management as follows:-

• All proposed works to comply with the NRA guidelines on the Management of

Noxious Weeds and Non-Native Invasive Plant Species on National Road

Schemes (Revision 1, December 2010 –

www.nra.ie/Environment/EnvironementalConstructionGuidelines/)

(ix) Standard environmental protection measures for bats to be undertaken during

the project development as follows:-

• Any trees and hedgerows that are shown to have bat activity will be felled in

accordance with TII Guidelines for the Treatment of Bats during the

Construction of National Road Schemes. Additionally:

• Mature trees which are to be removed, should be felled in the period late

August to late October, or early November, in order to avoid the disturbance

of any roosting bats.

• Tree felling should be completed by Mid-November at the latest because bats

roosting in trees are very vulnerable to disturbance during their hibernation

period (November - April). Felling at this time also avoids the bird breeding

seasons.

• Ivy-covered trees, once felled, should be left intact on-site for 24 hours prior

to disposal to allow any bats beneath the foliage to escape overnight.


4.2.3 Land and Soil

The total land take required for the project is in the order of 2.77Ha including 0.90Ha

of existing road. Soil in the area is generally of limited productive quality, with much

of the vegetation in a semi-natural state. Loss of organic matter soil resource is likely

to be minimal and there will be opportunities for re-use of any such soil elsewhere

within the proposal. Additional soil sealing will occur in light of the increased road

corridor width. Proposal will not result in or exacerbate soil erosion elsewhere.

Lands in the vicinity have not been classified as susceptible to landslides in the GSI

landslide susceptibility viewer and there are no geologically protected areas located

in the area. Construction materials would be sourced from authorized sources and

excess fill (approx 27,777 m3) will be disposed of at authorized locations. It is noted

that a large amount of local excavation will be required, particularly to the west of the

proposed scheme, where a rock outcrop exists. Rock unit name in the area is part of

the Valentia Slate Formation (VS) and consists of purple mudstone and siltstone.

These form part of the Devonian Old Red Sandstone Rock Unit Group.


(i) Construction to be undertaken in accordance with TII Guidelines on Procedures

for Assessment and Treatment of Geology, Hydrology and Hydrogeology for

National Road Schemes

(ii) Project to be constructed in compliance with the TII Guidelines for the

Management of Waste from National Road Construction Projects.

(iii)It is intended to maximise the re-use of earthworks material won on-site

elsewhere within the proposal, including topsoil.

(iv) Imported earthworks material is not expected to be significant (in quantity) and

will be sourced from local authorised quarries.

(v) Surplus earthworks materials will be removed to authorised sites (e.g sites for

which the local authority has granted a licence/certificate of registration as

appropriate in accordance with the conditions attached to any such

licence/certificate of registration).


4.2.4 Water aspects

As would be expected at a coastal location such as this, a number of culverts are

located under the roadway conveying water to the coast from the surrounding

countryside. The only river which crosses the roadway in the vicinity of the works is

the Illaunleagh (EPA naming system). This river is located to the east of the scheme

and outside of the proposed works area. The Brackaharagh stream (EPA name), abuts

the roadway and passes underneath the road via a stone culvert. This area has a poor

aquifer - generally unproductive except for local zones (Source GSI.ie). The inner

Kenmare River Estuary is designated as a Shellfish Area. The nearest boundary of

same is over 2.5Km from the nearest surface water discharge point associated with

the proposed works area. The current shellfish pollution reduction program for the

designation lists no key pressures affecting shellfish water quality (Shellfish Pollution

Reduction Programme Characterisation Report Number 2, Kenmare

River/Sneem/Ardgroom shellfish area County Kerry and County Cork).

Key impacts during any construction works project relate to the potential for siltation

and pollution of watercourses / groundwater from works and or spillages. No loss of

river corridors, river or riparian habitats or potential spawning beds are likely to arise

in this instance. The area which requires the most significant groundworks discharges

directly to the estuary. Estuaries are generally less susceptible to sediment input than

river systems. Shellfish production / designated areas can be impacted by same. The

nearest such area in this instance is over 2.5Km away. No watercourse within,

adjoining or in the vicinity of the proposed site or works areas discharges to a

designated shellfish area.

Above: Outer limits of the Kenmare Shellfish Designated Area in relation to project

area

Operational stage impacts will be similar in nature to existing. Run-off rates will be

increased as a result of the increased sealed area but potential for any resulting

impact is reduced by its coastal location. It is noted that controlled drainage is

proposed taking into account anticipated run-off rates. This proposal is not in itself a

particularly flood vulnerable one and is not located within a known flood risk area.

Above: Streams and rivers located in the area (source EPA Envision viewer)

Above: Streams and rivers located in the area (source EPA Envision viewer)


(i) Construction to be undertaken in accordance with the TII Guidelines on

Procedures for Assessment and Treatment of Geology, Hydrology and

Hydrogeology for National Road Schemes

(ii) Construction to be undertaken in accordance with Guidelines for the Crossing

of Watercourses during the Construction of National Road Schemes and with

‘Control of Water Pollution from Construction Sites – Guidance for Consultants

and Contractors’ published by CIRIA (2001) and NRA Guidelines (2006).

(iii) Construction stage environmental protection measures will include positive

control of runoff from earthworks with controlled discharge points, which will

include provision for sediment control including settlement ponds and filtration

mechanisms.

(iv) Consultation will take place with Inland Fisheries Ireland (IFI). Any specific

requirements that are outlined by IFI will be adhered to.


4.2.5 Air and Climate

Road improvement type projects such as this can impact on air quality at the

construction stage by way of dust deposition. Construction projects by their nature

are also likely to release Co2 into the atmosphere. However any such impacts would

be temporary and localised in nature. In this instance, it is noted that standard dust

control measures have been incorporated into the proposal to safeguard against

same and that the number of dwelling units / businesses in the area is low.

Operational air quality impacts are likely to be similar to existing. However, improved

alignments can be associated with reduced energy demand and emissions as both

journey times and the need to break and accelerate is reduced. It is considered that

this proposal is also likely to have a long term beneficial impacts on air and climatic

factors as a consequence of facilitating sustainable modes of transport (cycling and

walking). This proposal will offer an alternative more sustainable, family friendly

means of movement at this location, to the private car.




Schemes.

This measure is best practice and standard in nature.

4.2.6 Material Assets, landscape and cultural heritage including architectural

aspects

It is considered that material assets in the area will be significantly improved by way

of the provision of enhanced public transport infrastructure, while losses to

agricultural and residential properties will be minimal.

From a landscape point of view, this proposal is located adjacent to an area zoned for

Prime Special Amenity Purposes and within an area zoned for Secondary Special

Amenity Purposes in the current Development Plan for the area (Kerry CDP 2015-

2021). Listed protected views are also located in the area. There are no Protected

Structures or Architectural Conservation Areas in the vicinity. A cycleway is proposed

but it is noted that this will be finished in a black top finish. It is noted that a

landscape and visual impact assessment was carried out in support of this proposal,

the results of which are summarised as follows:-

• The predicted magnitude of change in landscape resource is low consistent with

minor alterations to character. The predicted significance of landscape impact

for the LCA is therefore moderate change i.e. there will be a partial or noticeable

loss of elements of the landscape character and / or medium term change.

• No significant visual impacts are considered to be likely.

• The proposed road improvement development will maintain protected views.

Above: landscape designations in the area.

The proposed route passes through the zone of archaeological potential (RMP)/zone

of notification (SMR) around recorded monuments Ke106 121001-003 listed as a

rectangular house, souterrain and field boundary. It is noted that a preliminary

Cultural Heritage Assessment has been undertaken in support of this proposal. As

would be expected for a proposal of this nature, potential exists for sub-surface

archaeological features or strata in this area and further archaeological assessment is

required. Thin soil covering for much of the site reduces archaeological potential. The

preliminary assessment identified 11 cultural heritage sites in the environs of the

proposed scheme. Of these, only CHS 8 (possible mass rock) is likely to be directly

impacted. No other known cultural features of significance are likely to be impacted

upon by the proposal. Any mass rock at this location would be likely to have predated

the roadway in its current form and accordingly its setting has already been

compromised both by this and by a more recent housing development.

Notwithstanding this there will be opportunities for relocation of said rock as well as

more in depth examination. Relocation, if required / desirable, to an area under

public control could facilitate access, interpretation and appreciation.


(i) To backplant field boundaries, to the east of the scheme with native willow

slips, or similar (approx ch600-1184m). This is considered to be acceptable and

desirable from a landscape point of view. In line with the ‘NRA Guide to

Landscape Treatments of National Road Schemes in Ireland’ native plants and

seed from indigenous sources should be used.

(ii) Existing seaward stone walls to be retained to the west of the scheme (as

outlined in the proposal).

(iii) All proposed works to comply with the NRA guidelines on the Management of

Noxious Weeds and Non-Native Invasive Plant Species on National Road

Schemes (Revision 1, December 2010 –

www.nra.ie/Environment/EnvironementalConstructionGuidelines/)

(iv) Archaeological test excavations be carried out in all greenfield areas in advance

of construction.

(v) Targeted archaeological test excavations be carried out in the vicinity of CHS 4

in advance of construction in order to determine the presence or otherwise of

archaeological remains within the scheme footprint.

(vi) All archaeological test excavations to be carried out under licence by a

competent archaeologist. Any archaeological remains uncovered during such

investigations will require either preservation in situ or preservation by record

(i.e. archaeological excavation and recording), as appropriate.

(vii) Archaeological assessment to be undertaken in accordance with the Guidelines

for the Assessment of Archaeological Heritage Impacts of National Road

Schemes (2005) and Guidelines for the Assessment of Architectural Heritage

Impacts of National Road Schemes (2005). As part of this, consultation will be

required with the National Monuments Service of the Department of Arts,

Heritage, Regional, Rural and Gaeltacht Affairs.

(viii) The form, condition, folklore associations and significance of the potential mass

rock feature to be more thoroughly examined through further desk-based

research combined with field inspection.

With the exception of measure (viii), these measures are all best practice and

standard in nature. Measure (viii) is specific to the project

4.2.8 The interrelationship between the environmental topics

The greater the number of different aspects of the environment which are likely to be

affected and the greater the links between the effects, the more likely significant

effects may occur. Impact inter-relationships/interactions relate to the reactions

between impacts within a project and the inter-relationship between impacts

identified under one topic with impacts identified under another topic.

The consideration of impact inter-relationships and interactions provides an

opportunity to consider the overall impacts of a scheme that might not be

immediately apparent. All above receptors contribute to the distinctive character of

the area. Cumulative impacts on the suite of these features may be significant in

scale, nature and duration.

In this instance, potential water quality impact aspects have potential to interact with

and impact on ecology by way of water pollution and air quality aspects (dust

deposition) has the potential to impact on Kerry lily habitat.


Refer to Water and Biodiversity, Flora and Fauna sections for related measures. No

(additional) measures incorporated.

4.3. Sub threshold development assessment

The aim of the following section is to address likely impacts, if any on the

environment by the implementation of the proposed development having regard to

the criteria set out in the EIA Directive, as amended.

Criteria for determining whether the project would or would not be likely to have a

significant effect on the environment

1. Characteristics of projects

(a) The size and design of the

whole project

Project design is set out in more detail within the

‘Preliminary project details report’ and in section 2

of this report. In essence this is a road widening and

realignment development. It seeks to increase the

paved road width from approx 4.7m to 7m. With

the incorporation or a cycleway, boundary

treatment, verges etc the typical cross section

excluding earthworks and workspace will extend to

approx 14m. The length of the scheme is approx

1.2Km. The total land take for the project will be

2.77Ha Environmental Protection Measures are also

provided for as part of the project.

(b) Cumulation with other

existing and/or approved

projects

It is noted that there are a number of existing and

proposed rural type developments in the area. The

N70 roadway has been upgraded at other locations

in recent years.

Potential for cumulative impacts in relation to

landscape, habitat loss and road safety.

(c) The use of natural

resources, in particular land,

soil, water and biodiversity.

Natural resources will be required for the

construction of the roadway. However it is noted

that in this instance there will be opportunities to

source required fill on-site. An area of semi-natural

habitat located within the proposed land take line

would be lost. There will be no requirement for

water abstraction for the proposed development.

(d) The production of waste. The project includes an area of cut which will

produce approx 35,217m3 of material. Of this the

rock cut excavation will be approx 20,756m3. No

large-scale wastes will be generated.

(e) Pollution and nuisances. The construction of an infrastructure proposal such

as this could give rise to particular nuisances or

instances of pollution. During the construction

stage, there will be a risk of associated water

pollution via silt or hydrocarbons. There may also

be temporary disruption to existing traffic at certain

locations as would cause nuisance. Additional noise,

dust and vibration from temporary construction

works may be experienced in the vicinity.

(f) The risk of major accidents

and/or disasters which are

relevant to the project

concerned, including those

caused by climate change, in

accordance with scientific

knowledge.

The risk of accidents associated with the

development would not cause unusual, significant

or adverse effects. Complex technologies or

substance use are not considered to be likely.

Standard health and safety precautions will be

required at design, construction and operation

stages. The implementation of best practice

construction methodology will manage risks of

water pollution.

No risks of major accidents and/or disasters which

are relevant to the project concerned, including

those caused by climate change have been

identified. As part of this the potential for

landslides, flood risk and wildfires were taken into

account.

No hazardous activities are proposed which would

pose a significant risk to a habitats or the

environment.

(g) The risks to human health

(for example due to water

contamination or air

pollution).

Temporary low level localised risks due to air

pollution and nuisances associated with the

construction aspects of the proposal. Positive

impacts on human health are likely to arise at

operational stage as a result of improved

connectivity and the facilitation of active modes of

travel (walking and cycling) at this location.

2. Location of projects

(a) The existing and approved

land use.

Existing: Transport and Agriculture

Approved land use: Rural Development (Secondary

Special Amenity landscape designation).

(b) The relative abundance,

availability, quality and

regenerative capacity of

natural resources (including

soil, land, water and

biodiversity) in the area and

its underground.

Soil to be removed generally of limited quality, rock

to be removed mudstone / siltstone in nature. Both

are abundant in the area and will be used

elsewhere within the project and or disposed of at

authorised sites.

Regenerative capacity minimal as the surface of the

widened roadway will be sealed. Area affected

considered to be insignificant within the context of

the relative abundance of the soil, water, rock and

biodiversity resources in the area.

(c) The absorption capacity of

the natural environment,

paying particular attention to

the following areas:

Wetlands are located within the site including an

area of heath supporting a population of Kerry Lily.

Wetlands are also located in the surrounding area,

including Coad Bog located 1km to the east.

(i) wetlands, riparian areas,

river mouths;

(ii) coastal zones and the

marine environment;

(iii)mountain and forest

areas;

(iv) nature reserves and parks;

(v) areas classified or

protected under national

legislation; Natura 2000

areas designated by

Member States pursuant

to Directive 92/43/EEC

and Directive

2009/147/EC;

(vi) areas in which there has

already been a failure to

meet the environmental

quality standards, laid

down in Union legislation

and relevant to the

project, or in which it is

considered that there is

such a failure;

(vii) densely populated

areas;

(viii) landscapes and sites of

historical, cultural or

archaeological

significance.

This proposal is located in the coastal zone

associated with Kenmare Bay, which is a designated

SAC (Kenmare River SAC). The SAC is largely an

estuarine system. Such systems tend to have

greater absorption capacities for water pollution as

compared with freshwater systems. Sediment

distribution naturally occurs in such systems and

they generally have greater flushing and dilution

capacities. There are other Natura 2000 sites

located in the wider area including Killarney

National Park, MacGillycuddy Reeks and Caragh

River Catchment SAC.

Inner Kenmare Bay is designated as a shellfish

protected area. Such areas can be impacted by

water pollution including alterations to suspended

sediment concentrations. The shellfish designation

is located over 2.5km from watercourses located in

the catchment of the works area. The current

shellfish pollution reduction program for the

designation lists no key pressures affecting shellfish

water quality.

This proposal is located on relatively low lying land

at the foot of a Mountainous area with a degree of

forestry also present in the wider area.

The landscape at this location is of historical and

cultural significance, located along the Ring of Kerry

and the Wild Atlantic Way, both of which are

amongst the Country’s top tourist routes. The

proposal would also be located within Special

Amenity designations and along listed protected

views. The proposed route passes through the zone

of archaeological potential (RMP)/zone of

notification (SMR) around recorded monuments

Ke106 121001-003 listed as a rectangular house,

souterrain and field boundary. KE106-121 is listed

as a ringfort –cashel, (though it is reported that

there is no trace of an enclosing wall and no

evidence to suggest the former presence of one).

Proposal would directly impact on a boulder which

may be a ‘Mass Rock’ of cultural value.

Notwithstanding this the landscape has absorption

capacities at this location and has successfully

accommodated other developments including road

projects in the vicinity in recent times.

3. Type and characteristics of Potential Impact

The potential significant effects of the projects on the environment must be

considered in relation to the criteria set out in 1 & 2 above and having regard to the

factors specified in Article 3(1) (of the EIA Directive) taking into account aspects of

the impact as outlined in (a) to (h) below.

Article 3(1) Factors

a) population and human health;

b) biodiversity, with particular attention to species and habitats protected under

Directive 92/43/EEC and Directive 2009/147/EC;

c) land, soil, water, air and climate;

d) material assets, cultural heritage and the landscape;

e) the interaction between the factors referred to in points (a) to (d).

(a) The magnitude and spatial

extent of the impact (for

example geographical area

and size of the population

likely to be affected).

The magnitude and spatial extent of impacts is

limited to the development site itself, its immediate

vicinity and road users in the area.

(b) The nature of the impact.

Human Beings, Population and Human Health

• Construction stage related nuisance associated

with traffic disruption, dust, noise and vibration.

• On completion, increased accessibility of the

area to a number of different road users is likely

to have positive implications for the population

of the wider area (reduced journey times and

safer journeys, driver for employment).

Facilitation of walking and cycling is likely to

impact positively on human health.

Biodiversity. Flora and Fauna

• Habitat loss along the footprint of the works

area associated with site clearance /

construction works. As part of this undesignated

heath habitat supporting a Red Data listed Kerry

Lily plant will be directly impacted as this plant

is located within the proposed land take area.

Potential also exists for Kerry lily impact / heath

habitat degradation outside of the works area

by way of dust deposition associated with the

construction stage.

• Alteration to existing mammal / otter

commuting corridors across the existing N70

roadway from the coast inland associated with

the construction stage.

• Potential for impact on nesting birds / roosting

bats associated with site clearance works.

Land and Soil

None identified / likely

Water

• Construction stage water pollution by way of

sediment input and or hydrocarbon spillages

Air and Climate

Dust deposition and carbon emissions associated

with the construction stage.

Reduced carbon emissions associated with reduced

journey times and the facilitation of sustainable

modes of transport.

Material Assets, landscape and cultural heritage

including architectural aspects

• Landscape alteration and visual impact

associated with both construction and

operational aspects. In particular a significant

amount of rock extraction is proposed to the

west of the scheme where a siltstone /

mudstone rock outcrop exists.

• Archaeological impact associated with

construction aspects (potential exists for sub-

surface unknown archaeological features within

the works area).

• Cultural heritage impact associated with impact

on potential ‘Mass Rock’ located within the land

take area.

• Significantly improved road infrastructure

(Material Assets)

The interrelationship between the environmental

topics

• Potential water impact aspects have potential

to interact with and impact on ecology by way

of water pollution.

• Potential air quality impact aspects have

potential to interact with and impact on

biodiversity and flora (heath /Kerry lily habitat)

by way of dust deposition.

(c) The transboundary nature

of the impact.

None. No cross border implications.

(d) The intensity and

complexity of the impact.


Negative impacts are associated with the

construction stage only and will have a low intensity

type impact ameliorated by standard traffic and

construction management measures.

Positive impacts thereafter will have an intensely

positive impact on the population using the

roadway, cycleway and improved junctions.


• Habitat loss. Habitat is of local importance

(higher value).

• Otter / nesting birds / bat impact – low in

intensity and none complex in nature.

Water

Water quality impacts associated with the proposal

are non complex in nature and similar to those

encountered by any infrastructure / development

type proposal (sediment and hydrocarbon

management). Intensity (without environmental

protection measure safeguards) could be high given

the scale of the earthworks proposed. However

having regard to the water quality protection

measures incorporated into the proposal intensity

is likely to be low.

Air and Climate

Identified air and climate negative impacts would

commence with site clearance works and would be

temporary in nature coinciding with the

construction phase of the project. Potential impacts

non-complex in nature.



High degrees of intensity or complexity of impacts

are not envisaged. The predicted magnitude of

change in landscape resource is low consistent with

minor alterations to character. Archaeological and

cultural heritage impacts are not fully known but

are unlikely to be intense or complex in nature.


topics

Low level of intensity and none complex in nature

(e) The probability of the

impact.


Nuisance type impacts (e.g. traffic disruption) are –

probable / near certain but are low level in

intensity. Negative impacts are associated with the

construction stage only. Positive impacts thereafter

have a high probability (reduced journey times and

safer journeys).


• Habitat loss impact – high / near certain

probability

• Otter / nesting bird / bat impact – low / unlikely

probability having regard to the standard

environmental protection measures

incorporated into the project, which provide for

pre-construction surveying and the provision of

mammal underpasses and fencing. Otters are

expected to continue to access their territory

and would be at a reduced risk of road traffic

related mortality as a result of this proposal.

Water

Water impacts are – probable / near certain but are

low level in intensity.

Air and Climate

Probable / near certain but are low level in

intensity. Negative impacts are associated with the

construction stage only. Positive impacts thereafter.



This proposal will alter the landscape at this

location. Probability of slight to moderate impact

near certain. Further testing and examination is

required in order to determine impact on

Archaeology and on the possible mass rock which

may be of cultural value. Probability of impact is

reduced by thin soil covering and previous

alterations to the landscape setting of the potential

mass rock (historical road works, more recent

dwelling house project).


topics

Low having regard to environmental protection

measures incorporated into the project.

(f) The expected onset,

duration, frequency and


Construction stage traffic impact and nuisances will

reversibility of the impact. be temporary in nature coinciding with the

construction phase of the project. Operation stage

traffic impact will be long-term associated with the

operation of the roadway. Neither would be readily

reversible.


• Habitat loss – this will occur during the early

stages of construction and will not be reversible.

• Otter / nesting bird / bat impact – expected to

coincide with the commencement of works /;

site clearance. Otter impact would be

temporary and reversible in nature. Loss of bat /

nesting bird habitat would be permanent.

However this is unlikely to occur given

environmental protection safeguards

incorporated into the proposal.

Water

Water quality impacts would commence with site

clearance works and would be temporary in nature

coinciding with the construction phase of the

project.

Air and Climate

Dust deposition impacts are associated with the

construction stage only and would commence with

site clearance works. The steep face of the rock

outcrop along with the separation distance from

the carriageway are likely to ensure that

operational impacts on Kerry Lily / heath habitat by

way of emissions and or dust are not likely to arise.

Carbon emissions would result from construction

works but long term reduction in carbon emissions

are expected associated with the operation of the

improved road infrastructure.



Expected to coincide with the commencement of

works on site. Alteration would be long-term and

not reversible.


topics

Negative impacts identified relate to construction

phase, commencing with site clearance works.

(g) The cumulation of the

impact with the impact of

other existing and/or

approved projects.


Other road improvement works have occurred

along the N70 Ring of Kerry roadway. Cumulatively

these will improve the transport infrastructure and

impact positively on the population in the area.

Negative impacts are not considered to be likely.


None likely

Water

None likely

Air and Climate

None likely



None envisaged / likely


topics

None likely

(h) The possibility of

effectively reducing the

impact.


Standard traffic and construction management

would effectively reduce any such impacts. It is

noted that such measures are incorporated into the

proposal.


Dust protection measures and translocation of the

Kerry lily plant located within the proposed land

take area to suitable location outside of same will

reduce impact. Elsewhere, standard environmental

protection measures would effectively reduce

impacts. It is noted that such measures are

incorporated into the proposal (pre-construction

surveying, dust control, provision of mammal

underpasses and fencing, construction

management).

Water

Standard construction management would

effectively reduce any such impacts. It is noted that

such measures are incorporated into the proposal.

Air and Climate

Standard construction management would

effectively reduce air quality related impacts. It is

noted that such measures are incorporated into the

proposal.



Natural weathering and vegetation will effectively

reduce landscape and visual impact over time. Rock

outcrops can form visual features of interest and

this is likely in this instance given the aesthetic

qualities of the local geology at this location

(Valentia Slate Formation). The predicted

significance of landscape impact for the LCA is

therefore slight to moderate i.e. there will be a

partial or noticeable loss of elements of the

landscape character and / or medium term change.

It is considered that archaeological test excavations

along with additional archaeological and cultural

heritage assessment will effectively reduce impact

on same. These are provided for as part of the

project.


topics

Environmental protection measures outlined as

part of the project including water quality and dust

control measures would effectively reduce impacts

identified.

4. Screening Decision

Having regard to the above, and in particular to the nature, scale and location of the

proposed project, by itself and in combination with other plans and projects, it is

considered that an EIA is not required in this instance.

5. Reasoned conclusion / explanatory statement outlining reasons for decision

with reference to the relevant criteria listed above (1 to 3) and to any influential

measures incorporated into the project envisaged to avoid or prevent what might

otherwise have been significant adverse effects on the environment.

The proposal is below the mandatory thresholds for EIA but is located in an

environmentally sensitive area, with landscape, biodiversity and cultural heritage

interests. Potential for impacts have been identified, both positive and negative –

but none as would be likely to have significant effects on the environment.

The incorporation of dust management measures so as to protect the quality of

adjoining heath habitat which contains a population of the Red Listed ‘Kerry Lily’ has

been influential in avoiding what might otherwise have been significant adverse

effects on the environment. Similarly the incorporation of mammal / otter

underpasses and fencing are influential, as these will ensure safe (and improved)

mammal access across the roadway. The incorporation of standard construction

management water, air, noise and vibration environmental protection measures is

also influential in ensuring the prevention of environmental impacts.

It is noted that a preliminary Cultural Heritage Impact Assessment has been

undertaken. Based on this assessment and having regard to the characteristics and

location of the project and to the type and characteristics of the potential impact,

significant adverse effects on Cultural Heritage are not considered likely. In line with

best practice, the proposal provides for pre development test excavations along with

additional cultural heritage assessment, which is considered to be appropriate.

Documents

EIA Screening Reportdocstore.kerrycoco.ie/KCCWebsite/part8/brackaharagh... · This Environmental Impact Assessment (EIA) Screening Report has been prepared to ... in terms of deciding