ECOLOGICAL IMPACT ASSESSMENT (ECIA) FOR THE GREEN ACRES DEVELOPMENT AT KILMACUD ROAD UPPER, DUBLIN 14.
←
→
Page content transcription
If your browser does not render page correctly, please read the page content below
Ecological Impact Assessment (EcIA) for the Green Acres
Development at Kilmacud Road Upper, Dublin 14.
14th May 2019
Prepared by:
Bryan Deegan MSc., BSc..(MCIEEM) of Altemar Ltd.
On behalf of:
Crekav Trading GP Limited.
Altemar Ltd., 50 Templecarrig Upper, Delgany, Co. Wicklow. 00-353-1-2010713. info@altemar.ie
Directors: Bryan Deegan and Sara Corcoran
Company No.427560 VAT No. 9649832U
www.altemar.ie
i
Document Control Sheet
Client Crekav Trading GP Limited
Project Ecological Impact Assessment (EcIA) for the Green Acres
Development at Kilmacud Road Upper, Dublin 14.
Report Ecological Impact Assessment
Date 14th May 2019
Project No: Document Reference: EcIA_CL15/01
Version Author Reviewed Date
Draft 01 Bryan Deegan SC/PB 4th February 2019
Draft 02 Bryan Deegan CTGP 6th February 2019
Draft 03 Bryan Deegan 1st May 2019
Draft 04 Bryan Deegan 14th May 2019
ii
CONTENTS
Introduction ............................................................................................................................................................................ 1
BACKGROUND................................................................................................................................................. 1
STUDY OBJECTIVES ......................................................................................................................................... 1
Background to Altemar Ltd. ......................................................................................................................................... 1
1) Project description ......................................................................................................................................................... 2
A. DESCRIPTION OF THE PROPOSED PROJECT .............................................................................................. 2
The development for which permission is being sought can be summarised as follows: ................................... 2
Foul Water Drainage...................................................................................................................................................... 6
Surface Water Drainage................................................................................................................................................. 6
Landscape ........................................................................................................................................................................ 6
2) Ecological Assessment Methodology ............................................................................................................................. 9
2.1 DESK STUDY.............................................................................................................................................. 9
2.2 FIELD SURVEY ........................................................................................................................................... 9
Survey Limitations.......................................................................................................................................................... 9
2.3 CONSULTATION ......................................................................................................................................... 9
2.4 SPATIAL SCOPE AND ZONE OF INFLUENCE ................................................................................................ 9
2.4 ECOLOGICAL EVALUATION CRITERIA ........................................................................................................ 9
2.5 IMPACT ASSESSMENT SIGNIFICANCE CRITERIA ........................................................................................ 10
3) Results................................................................................................................................................................................ 12
3.1 PROXIMITY TO DESIGNATED CONSERVATION SITES ................................................................................. 12
3.2 HABITATS AND SPECIES .......................................................................................................................... 16
4 Analysis of the Potential Impacts ................................................................................................................................... 25
CONSTRUCTION PHASE ................................................................................................................................. 25
OPERATIONAL PHASE ................................................................................................................................... 26
INDIRECT IMPACTS ........................................................................................................................................ 28
AVOIDANCE AND REMEDIAL MEASURES ...................................................................................................... 28
CUMULATIVE IMPACTS ................................................................................................................................. 28
Residual Impacts and Conclusion ...................................................................................................................................... 29
References.............................................................................................................................................................................. 30
iii
INTRODUCTION
Background
Ecological Impact Assessment (EcIA) has been defined as ‘the process of identifying, quantifying and
evaluating the potential impacts of defined actions on ecosystems or their components’ (Treweek, 1999).
“The purpose of EcIA is to provide decision-makers with clear and concise information about the likely ecological effects
associated with a project and their significance both directly and in a wider context. Protecting and enhancing biodiversity and
landscapes and maintaining natural processes depends upon input from ecologists and other specialists at all stages in the
decision-making and planning process; from the early design of a project through implementation to its decommissioning”
(IEEM, 2010). The following EcIA has been prepared by Altemar Ltd. at the request of Crekav Trading
GP, as part of the planning process for the development at the former convent at Green Acres, in addition
to Drumahill House, and the Long Acre, Kilmacud Road Upper, Dublin 14. The project will comprise of
the demolition of the former Green Acres Convent and Drumahill House and the construction of 253 no.
apartments in 3 no. blocks ranging in height from 4 to 6 storeys, over single level basement parking.
Study objectives
The objectives of this EcIA are to:
1. Outline the project and any alternatives assessed;
2. Undertake a baseline ecological feature, resource and function assessment of the site and zone of
influence;
3. Assess and define significance of the direct, indirect and cumulative ecological impacts of the
project during its construction, lifetime and decommissioning stages;
4. Refine, where necessary, the project and propose mitigation measures to remove or reduce impacts
through sustainable design and ecological planning; and
5. Suggest monitoring measures to follow up the implementation and success of mitigation measures
and ecological outcomes.
The following guidelines have been used in preparation of this EcIA:
• Guidelines on the information to be contained in Environmental Impact Statements (EPA, 2002);
• Advice Notes on current practice in the preparation of EIS’s (EPA, 2003);
• Institute of Ecology and Environmental Management Guidelines for EIA (IEEM, 2005).
A separate Appropriate Assessment Screening, in accordance with the requirements of Article 6(3) of the
EU Habitats Directive, has been produced by Altemar to identify potential impacts of the development on
Natura 2000 sites, Annex species or Annex habitats. In summary, there is no possibility of significant
impacts on Natura 2000 sites, features of interest or site specific conservation objectives. A Natura Impact
Statement is not required for the proposed development.
Background to Altemar Ltd.
Since its inception in 2001, Altemar has been delivering ecological and environmental services to a broad
range of clients. Operational areas include residential, infrastructural, renewable, oil & gas, private industry,
local authorities, EC projects and State/semi-State Departments. Bryan Deegan is the managing director
of Altemar, is an environmental scientist and marine biologist with 20 years’ experience working in Irish
terrestrial and aquatic environments, providing services to the State, Semi-State and industry. He is
currently contracted to Inland Fisheries Ireland as the sole “External Expert” to environmentally assess
internal and external projects. He is also chair an internal IFI working group on environmental assessment.
Bryan Deegan (MCIEEM) holds a MSc in Environmental Science, BSc (Hons.) in Applied Marine Biology,
NCEA National Diploma in Applied Aquatic Science and a NCEA National Certificate in Science
(Aquaculture).
1
1) PROJECT DESCRIPTION
A. Description of the Proposed Project
Crekav Trading GP Ltd. is proposing to develop a site that comprises the three parcels of land of, Green
Acres Convent (1.23ha), Drumahill House (0.26ha), and the Long Acre (0.27ha), all at Upper Kilmacud
Road, Dundrum (Figure 1). It is a site of approx. 1.76 hectares. The site is bound by Upper Kilmacud
Road to the north, Drumahill and Holywell residential development to the east, and Eden Farm (part of
Airfield Estate) and Airfield Estate to the west and south of the site.
The development for which permission is being sought can be summarised as follows:
1. the demolition of the former Green Acres Convent (c. 425sqm), and Drumahill House (c. 378 sqm),
and associated out-buildings
2. the construction of 253 no. apartments in 3 no. blocks ranging in height from 4 to 6 storeys, over single
level basement parking (Figures 2 & 3), all on a site of 1.76 hectares at Kilmacud Road Upper comprising:
• Block A – 4 to 6 storey building, with a total floor area of approx. 11,362 sqm (excl. basement),
over basement parking, comprising 118 no. apartments with 47 no. 1 bedroom apartments, 61 no.
2 bedroom apartments, and 10 no. 3 bedroom apartments, including balconies on all elevations;
• Block B – 4 to 6 storey building of approx. 8,244 sqm, (excl. basement), part over basement
parking, comprising 94 no. apartments with 53 no. 1 bedroom apartments, 32 no. 2 bedroom
apartments, and 9 no. 3 bedroom apartments, with balconies on all elevations.
• Block C – 4 to 6 storey building of approx. 3,624 sqm, (excl. basement), over basement parking,
comprising 41 no. apartments with 15 no. 1 bedroom apartments, 22 no. 2 bedroom apartments,
and 4 no. 3 bedroom apartments, with balconies on all elevations.
• Basement area of 5,620 sqm below Blocks A-C.
• Residential amenity space is provided at ground floor of Block A and Block C amounting to a total
floor area of approx. 387 sqm.
• Communal open space area of approx. 3,833 sqm.
3. A crèche of approx. 236 sqm is provided within Block A with associated external play space.
4. Car parking is provided on site with 212 no. car parking spaces (198 at basement level), and 348
no. bicycle spaces at basement level plus 52 visitor bicycle spaces at ground level (totalling 400 bicycle
spaces). 7 No. motorbike spaces.
5. The principal vehicular access is provided via a relocated new entrance off Kilmacud Road Upper
proximate to the current Greenacres entrance. Visitor vehicular entrance and services entrance is at the
existing Drumahill House entrance. A cycle path is provided along Kilmacud Road Upper.
6. Site development and landscape works, including a sub-station, provision of bin stores at basement level,
boundary treatment, hard and soft landscaping, provision of green roofs, and provision of foul, surface
water and water services on site with connections to existing.
The potential Zone of Influence (ZoI) of the proposed project would be seen to be restricted to the site
outline with potential for minor localised noise and light impacts during construction. Drainage from site,
both foul and surface water, would be seen as the external output form the site during operation. In
addition to the proposed landscape strategy would be seen as the important to the proposed biodiversity
value of the site during operation. Additional information in relation to drainage and landscape are
provided.
2
Figure 1. Site Outline on satellite imagery (Bing Jul 2011-Jul2013)
3
Figure 2. Proposed building layout (groundfloor).
4
Figure 3. Proposed Site Layout (Front elevation).
5
Foul Water Drainage
As outlined in the OCSC Engineering Services Report “As outlined in the OCSC Engineering Services Report
(April 2019) “ There is no existing foul sewer adjacent to the site boundary on Upper Kilmacud Road. The foul water
currently drains to a percolation areas on site. It is proposed to construct a new foul drainage network in accordance with Irish
Water Code of Practice for Wastewater Infrastructure, The Building Regulations ‘Part H’ & the Regional Code of Practice
for Drainage Works..” “A new public foul water sewer will be laid along Upper Kilmacud Road and discharge to the public
network on Eden Park Avenue. The discharge point is located to the east of the site approximately 180m from the sites
northeast boundary” (Figure 4)’ Based on discussions with OCSC, the foul sewer terminates at Ringsend
Waste Water Treatment Plant.
Surface Water Drainage
As outlined in the OCSC Engineering Services Report “The surface water design strategy is focused on reducing
impermeable surfaces across the developed site, creating green spaces and utilising above-ground SuDS, where practicable,
including blue roofs with downpipes directed to the permeable paving sub-base or basin and raingarden. Only limited
infiltration is possible due clay overlaying rock on site. SuDS designed primarily to attenuate surface water runoff, rather than
to encourage infiltration.” “The proposed main drainage network will consist integrated SuDs components designed in
accordance with CIRIA C753-SuDS Manual (C753). The drainage network will have branch and conveyance pipes with
the diameter of 150mm-300mm. All pipes outside of the site to be taken in charge will be compliant with the requirements
of the Greater Dublin Regional Code of Practice for Drainage Works and full bore self-cleansing velocities of 1.0m/s.”
“The proposed finished floor levels within the site will be above the adjacent ground levels with access ramping up to the
threshold level. The finished floor levels for the lower ground floor apartments will, likewise be above the adjacent ground levels
and be stepped in alignment with the existing fall in ground levels in this part of the site. For the southern part of the site
(where existing ground levels drop relatively steeply), it is proposed to drain the roofs in this area with siphonic drainage which
will discharge to the buried drainage network to the north. The soft landscaping to the rear of the site will drain as per
existing.” During construction only clean water will be discharged from site into the DLRCC drainage
system.
Landscape
As outlined in the Brady Shipman Martin Landscape Design Rationale Report and Outline Specification
“The planting design will include new tree planting, shrubs, groundcover, ornamental grasses and perennials (Figure 5). It is
proposed to use the following:
• Four Semi-mature trees will be planted within Courtyard B, D and E to create impact and
maturity and enhance the scheme. These will be 40-45cm girth trees.
• Ornamental shrubs will be mass planted for visual effect.
• Perennial planting and ornamental grasses at key locations for visual interest.
• Multi-stemmed trees in areas close to the building appropriate in height and scale and to
provide seasonal interest.
• Extra heavy standard trees and semi-mature trees will be planted around the site perimeter
for screening direct views into the site from adjoining properties and to create a ‘parkland
character”
Outline Development Program
As the development is subject to the planning application process, it is not possible to put exact dates
against a timeline at this stage. However, key project milestones are considered as follows:
• Receipt of a Grant of Planning Permission;
• Progression through detailed design stage;
• Issue of tender documents to shortlisted main contractors followed by period for tender returns,
assessment and award of contract;
• Mobilisation of contractor;
• Completion of works.
The above is a very high level estimate of the key project milestones. Associated durations of the respective
stages are also dependent on a number of factors but a high level, preliminary estimate would suggest the
actual construction works will take approximately 24 months upon commencement. A more detailed
programme will be developed by the Contractor once appointed and included in the updated version of
this plan.
6
Figure 4. Site Surface Water Drainage.
7Figure 5. Proposed landscape masterplan.
82) ECOLOGICAL ASSESSMENT METHODOLOGY
2.1 Desk study
A desk study was undertaken to gather and assess ecological data prior to undertaking fieldwork elements.
Sources of datasets and information included:
• The National Parks and Wildlife Service
• National Biological Data Centre
• Satellite, aerial and 6” map imagery
• Bing Maps (ArcGIS)
A provisional desk based assessment of the potential species and habitats of conservation importance was
carried out which took place in early March 2015 and was updated in October 2018.
2.2 Field survey
A field survey (terrestrial flora and fauna and avian) of Green Acres was carried out by Altemar Ltd. on the
5th & 13th March 2015, following completion of the desk based assessment and an additional site visit and
bat survey were carried out on April 21st 2015. Additional surveys were carried out on the entire site subject
of this application on the 20th August and the 28th September 2018. A second bat survey was carried out on
the 28th of September 2018 and assessed the houses and trees on site for roosting potential. An additional
site visit was carried out on the 7th November 2018 to assess terrestrial mammal activity. The surveys were
carried out in mild sunny/overcast conditions and covered the lands within the site outline and the land
immediately outside the site, where there was evidence of mammal activity. The purpose of the field survey
was to identify habitat types according to the Fossitt (2000) habitat classification and map their extent. In
addition, more detailed information on the species composition and structure of habitats, conservation value
and other data were gathered.
Survey Limitations
Numerous surveys were carried out in site and covered appropriate seasons for terrestrial mammal, bird
flora and bat assessments. No survey limitations are foreseen. The site comprises of two gardens good access
to all areas.
2.3 Consultation
The National Parks and Wildlife Service (NPWS) were consulted in relation to species and sites of
conservation interest. Data of rare and threatened species were acquired from NPWS. The National
Biological Data Centre records were consulted for species of conservation significance.
2.4 Spatial Scope and Zone of Influence
IEEM (2006) defined the zone of influence as “the areas/resources that may be affected by the biophysical
changes caused by activities associated with a project”. In order to define the extent of the study area for
ecological assessment, all elements of the project were assessed and reviewed in order to identify the spatial
scale at which ecological features could be impacted. Due to the limited temporal and geographical scale of
the project, within an urban/suburban environment, it is considered that the impacts of the proposed works
would not extend beyond the treeline, with the exception of foul water connection to Kilmacud Road which
takes place on the existing road network. The project would involve significant excavations and
construction, which may impact locally beyond the treelines through minor noise and light impacts.
Operational impacts would not be expected beyond the site outline.
2.4 Ecological evaluation criteria
The ecological significance of the potential zone of influence was determined using the site evaluation
scheme provided by the National Roads Authority (NRA) Ecological Assessment Guidelines (Table 1) and
Impact Matrix (Table 2).
9Table 1. Site Evaluation Scheme (NRA, 2006)
Rating Qualifying Criteria
A Internationally important
Sites designated (or qualifying for designation) as SAC* or SPA* under the EU Habitats or
Birds Directives.
Undesignated sites containing good examples of Annex I priority habitats under the EU
Habitats Directive.
Major salmon river fisheries.
B Nationally important
Sites or waters designated or proposed as an NHA* or statutory Nature Reserves.
Undesignated sites containing good examples of Annex I habitats (EU Habitats Directive).
Undesignated sites containing significant numbers of resident or regularly occurring
populations of Annex II species under the EU Habitats Directive or Annex I species under
the EU Birds Directive or species protected under the Wildlife (Amendment) Act 2000.
Water bodies with major amenity fishery value.
C High value, locally important (Regional, County & River Basin District)
Sites containing semi‐natural habitat types with high biodiversity in a local context and a high
degree of naturalness, or significant populations of locally rare species.
Small water bodies with known salmonid populations or with good potential salmonid
habitat.
Sites containing any resident or regularly occurring populations of Annex II species under the
EU Habitats Directive or Annex I species under the EU Birds Directive.
D Moderate value, locally important (Regional, County & River Basin District)
Sites containing some semi‐natural habitat or locally important for wildlife.
Small water bodies with some coarse fisheries value or some potential salmonid habitat.
Any water body with unpolluted water (Q‐value rating 4‐5).
E Low value, locally important (Regional, County & River Basin District)
Artificial or highly modified habitats with low species diversity and low wildlife value.
Water bodies with no current fisheries value and no significant potential fisheries value.
*SAC = Special Area of Conservation SPA= Special Protection Area NHA= Natural Heritage Area
2.5 Impact assessment significance criteria
As outlined in IEEM (2010) “assessment of impacts should be undertaken in relation to the baseline
conditions within the zone of influence of the proposed development.” Impacts during site preparation,
construction and occupation upon ecological receptors were quantified and characterised based on IEEM
impact characterisation (IEEM, 2010) (Table 3) Following an evaluation of ecological receptors, the
potential impact (positive, neutral or adverse) of the project on the ecological receptors was carried out
based on the criteria in an impact significance matrix (based on NRA, 2009)(Table 4).
Table 3: Characterisation of the impacts
Direction of impact Whether the impact benefits (beneficial or positive) or detracts (adverse or
negative) from net biodiversity value of the receptor;
Magnitude level of severity of influence on the receptor; fragmentation and isolation of
habitats; disturbance to species from noise, light or other visual stimuli
Extent Area affected and percent of total area of the receptor; direct loss of wildlife
habitats
Complexity direct or indirect effect
Reversibility reversible or irreversible
Timing/ constant or intermittent and impact on critical life stages
Frequency
Duration measured time interval for the activity and predicted duration of the impact on
receptor
Confidence certain/near certain, probably, unlikely or extremely unlikely
10Table 2: Impact Matrix
Impact level Site Category
A sites B sites C Sites D sites E Sites
Internationally Nationally High value, Moderate Low value,
important important Locally value, locally
important locally important
important
Severe Any permanent Permanent
adverse impacts impacts on a
large part of a
site
Major Temporary Permanent Permanent
adverse impacts on a impacts on a impacts on a
large part of a small part of a large part of a
site site site
Moderate Temporary Temporary Permanent Permanent
adverse impacts on a impacts on a impacts on a impacts on a
small part of a large part of a small part of a large part of a
site site site site
Minor Temporary Temporary Permanent Permanent
adverse impacts on a impacts on a impacts on a impacts on a
small part of a large part of a small part of a large part of a
site site site site
Negligible No impacts No impacts No impacts No impacts Permanent
impacts on a
small part of a
site
Minor Permanent Permanent
beneficial beneficial beneficial
impacts on a impacts on a
small part of a large part of a
site site
Moderate Permanent Permanent
beneficial beneficial beneficial
impacts on a impacts on a
small part of a large part of a
site site
Major Permanent Permanent
beneficial beneficial beneficial
impacts on a impacts on a
small part of a large part of a
site site
113) RESULTS
3.1 Proximity to designated conservation sites
Designated conservation sites (National and international) within 1km, 5km, 10km and 5km of the proposed
development are seen in Figures (4-6). It should be noted that the proposed development site is not within
a designated conservation area. The closest conservation site is Fitzsimon's Wood (pNHA) 1.8km from the
proposed development (Figure 6). Internationally designated sites (SAC and SPA) are located at minimum,
3.5km from the site (Figures 4 & 5). The nearest NHA (Blackwood at Robertstown is 37km from the site.
The closest RAMSAR Site is Sandymount Strand/Tolka Estuary, 3.5km from the site. Details of
international conservation sites within 15km and pNHA within 10km of the proposed site are seen in Table
3.
Table 3. Conservation sites within 15km (pNHA 10km) of the proposed site.
Name Distance (km) Type
South Dublin Bay 3.5 SAC
Rockabill to Dalkey Islands 9.2 SAC
North Dublin Bay 8.2 SAC
Glenasmole Valley 9.2 SAC/pNHA
South Dublin Bay and River Tolka Estuary 3.5 SPA
Dalkey Island 9.0 SPA
North Bull Island 7.0 SPA/RAMSAR
Howth Head Coast 14.5 SPA
Wicklow Mountains 6.8 SPA
Fitzsimon’s Wood 1.8 pNHA
Dodder Valley 6.8 pNHA
Dingle Glen 5.9 pNHA
Loughlinstown Woods 8.7 pNHA
Booterstown Marsh & South Dublin Bay 3.5 pNHAs
Dalkey Coastal Zone and Killiney Hill 7.3 pNHA
Ballybetagh Bog 7.1 pNHA
Grand Canal 5.2 pNHA
Royal Canal 6.8 pNHA
Knocksink Wood 8.4 pNHA
Ballyman Glen 9.6 pNHA
Sandymount Strand/Tolka Estuary 3.5 RAMSAR
Baldoyle Bay 13.8 RAMSAR/SPA/SAC
12Figure 4. Special Areas of Conservation within 15km of the proposed development.
13Figure 5. Special Protection Areas within 15km of the proposed development.
14Figure 6. Natural Heritage Areas within 15km of the proposed development.
153.2 Habitats and Species
A site assessment was carried out on the 5th and 13th March, April 21st 2015 and 20th August and the 28th
September 2018. Habitats within the proposed site were classified according to Fossitt (2000) (Figure 7)
based on the 2018 survey.
A
B
A
I
G
H
J
D
E
F
C
L
K
Figure 7. Habitats within the proposed development site classified according to Fossitt (2000).
(Letters correspond to subareas and are detailed in the habitat descriptions and images below.)
16WD5- Scattered Trees and Parkland
B
A
C
Scattered trees and parkland form a substantial portion (30-40%) of the proposed site as seen in Figure 7.
In 2015, this habitat appeared to regularly mown and the use of herbicide was evident around trees, paths
and driveways. However, by 2018 the grass in Green Acres was no longer maintained and the site had a
mote neglected appearance. In Drumahill the site was well maintained. A paucity of vegetation was also
noted under coniferous tree species and under laurel (Prunus laurocerasus 'Rotundifolia') and large conifers at
the edges of this area. As would be expected species diversity in this area was poor, typical of amenity
grassland areas. Trees and shrubs within this habitat include a weeping Ash (Fraxinus excelsior) (“A” above),
Cotoneaster sp and Lawsons cypress cultivar (Cupressus lawsoniana) (“B” above), Ash (Fraxinus excelsior),
Sycamore (Acer pseudoplatanus), Chamaecyparis 'Boulevard', Hawthorn (Crataegus monogyna) (“C” above).
GA2- Amenity Grassland (Improved)
A large area of amenity grassland was
present at the back of the convent in
Green Acres. This area was bisected by a
gravel path which had become overgrown
in 2018. Herbicide was used within this
area in 2015 and species diversity in this
area was also poor. Species included
dandelion (Taraxacum spp.), daisy (Bellis
perennis), clovers (Trifolium spp.) and
plantains (Plantago spp.)
D
17E F
WL1 (Hedgerow)
Hedgerows were present in three locations in the site (Figure 7). These comprised mainly of laurel, with a
dearth of ground flora (Areas D and F). Area E also contained laurel and formed a boundary barrier to the
property next door. However, it had overgrown due to neglect and encroached into the main garden area.
In areas where the laurel thinned dense bramble (Rubus fructicosus) and un-kept box hedging (Buxus sp) were
to be found.
ED3- Recolonising Bare Ground
In 2018 recolonising bare ground was noted in the front garden of Green Acres where species such as
purple-loosestrife (Lythrum salicaria), oil seed rape (Brassica napus), scarlet pimpernel (Anagallis arvensis),
Montbretia (Crocosmia x crocosmiiflora), cat’s-ear (Hypochaeris radicata), ground-elder (Aegopodium podagraria),
primrose (Primula vulgaris), hedge bindweed (Calystegia sepium) and white clover (Trifolium repens) wre noted.
BL3-Buildings and Artificial Surfaces
Green Acres
G
18Drumahill House
H
Drumahill Attic 2018
In 2015, the convent and paths were well maintained and herbicide use was evident but by 2018 much
of the area was overgrown. Drumahill was well maintained and is currently inhabited. There was a
paucity of flora and fauna in these areas of the site. In 2015 a bat survey was carried out within the
Green Acres by Conor Kelleher and Bryan Deegan (Appendix I), and in Drumahill and Green Acres
in 2018 by Bryan Deegan. No evidence of the presence of bats, or the use of the buildings by bats,
was noted within the houses or other buildings/sheds. It should be noted that at the time of the survey
was mild and bats were observed foraging within the proposed site during both surveys.
BC4- Flower Beds and Borders
I J
In Green Acres the flower beds and borders (left) were in poor condition with cultured flower varieties such
as daffodil (Narcissus pseudonarcissus), Rose (Rosa sp). Moss (Sphagnum sp.) and seedlings of creeping buttercup
(Ranunculus repens) and dandelion (Taraxacum officinale) were also seen. In Drumahill House the flowerbeds
were well maintained with non native shrubs and ornamental flowers.
19K
WL2- Treelines
A dominant feature of the site is the perimeter treelines of tall conifers and native trees (Figure 1). As
outlined in the 2015 tree survey report “the trees present are combination of native species and exotics
planted for ornamentation and screening. The majority of the trees are located on the boundaries with the
most significant trees located within the tree group adjacent to the public road as they provide screening
and shelter to and from the site. With a small number of exceptions they are not of major significance as
individual trees but do have high landscape value as a group. A screen planting of Monterey cypress is
located on the eastern boundary with a neighbouring property. These are poor specimens overall and must
cause concern to the residents of this property are they are very large and intimidating. This species has a
tendency to succumb to storm damage and is very unsuitable for this type of location. They would not be
recommended for retention within any proposed redevelopment of the site. The southern boundary also
contains a number of mature ash within a hedgerow. The primary structure of the hedgerow was probably
hawthorn but, a lack of appropriate management has reduced the quality of the trees on this boundary and
most are in poor condition overall. The same applies to the southern boundary where a number of large
mature ash are located adjacent to the Airfield estate.” “On the western boundary the most prominent trees
are a planting of beech. It is effectively an overgrown hedge and many are poor specimens drawn up for
light however there is potential for the retention of the better quality specimens.”
The native species within the treelines would be seen as the most important ecological elements of the site
and would form bird nesting resource and part of an ecological corridor linked to the Airfield Estate.
However, in 2015 construction activity in the estate has resulted in the reduction of the importance of the
treeline on the southern boundary and may have had resulted in negative impacts on the row of Ash. In
2018, all numbered trees were inspected for bat roosting potential.
20L
WS1- Scrub
Bramble (Rubus fruticosus agg.) scrub dominated Long Acre with additional species including ivy (Hedera helix),
honeysuckle (Lonicera periclymenum), traveller's-joy (Clematis vitalba), in addition to elder (Sambucus nigra), ash
(Fraxinus excelsior), snowberry (Symphoricarpos albus), hedge bindweed (Calystegia sepium), holly (Ilex aquifolium),
dog-rose (Rosa canina), cleavers (Galium aparine), fuchsia (Fuchsia magellanica), butterfly-bush (Buddleja davidii),
foxglove (Digitalis purpurea) and docks (Rumex spp.). On the south eastern side of Green Acres a large area
of scrub was present. This consisted primarily of overgrown Laurel with a poor understory and where this
ended an area of bramble scrub was present, with similar species to those seen in Long Acre above.
Evaluation of Habitats
The proposed development site is typical of large suburban gardens with substantial areas of amenity
grassland and scattered trees and parkland. Neglected areas were dominated by bramble, conifers or laurel
with a poor ground flora or recolonising bare ground, in disturbed areas. There were no watercourses but
an ornamental pond was located at the rear of Drumahill. Mammal activity was restricted to fox activity
but, a long disused and small badger sett was noted in 2015. This was absent in 2018. Two bat surveys were
carried out. No evidence of bats was seen in the houses including all roof spaces and bats were observed
foraging outside. Besides the foraging pipistrelle bats, no protected flora of fauna were noted on site. The
treelines may form part of an ecological corridor connected with the boundaries and hedgerows of Airfield
Estate.
21Plant Species
The plant species encountered at the various locations on site are detailed above. No rare or plant
species of conservation value were noted during the field assessment. The proposed site are large
suburban gardens with approximately 75% ground cover of amenity grassland with little or no ground
flora in areas under conifers or laurel. Records of rare and threatened species from NPWS were
examined. No rare or threatened plant species were recorded in the vicinity of the proposed site. It
should be noted that no invasive plant species, that could hinder removal of soil from the site during
groundworks, such as Japanese knotweed, giant rhubarb, Himalayan balsam or giant hogweed were
noted on site.
Amphibians
The common frog (Rana temporaria) was not observed on site and there watercourses, drainage ditches
or streams on site. A small ornamental pond is present at the rear of Drumahill. Frogs have been
recorded by the NBDC within the 10km square grid, but not at finer resolution. NPWS have records
for the common frog in Airfield from 2003. Given the lack of water on site, and the fact that the
property is surrounded by roads, walled gardens and recent agricultural buildings and associated hard
stand area, it would not be expected to be an important frog habitat. However, the common frog may
be seen on the site/
Terrestrial Mammals
The small abandoned badger (Meles meles) sett that was observed on site in 2015 had commapsed and
was no longer present. No other large burrows were noted on site. Badgers have been noted within
the 10km2 grid by the NBDC but not at a finer resolution within 1km of the site. In 2018, foxes (two
cubs) were seen during the site visit. Numerous trails are seen within the site in addition to scats and
hair on the barbed wire in the SE corner of the site. Records from the NBDC indicate a fox siting
within 100m of the entrance, across the Kilmacud Road Upper in the vicinity of Eden Park Avenue.
Hedgehogs have been recorded by NBDC within the 10km square but not within 2km at a finer
resolution. No hedgehogs were seen during the site visit.
Bats
Based on NBDC records, bats have not been seen on site. The only bat species that have been
recorded in the vicinity of the site are pipistrelle (2001 & 2004) and Leisler’s bats (2001). They have
been recorded in the 1km square immediately to the west of the site. Based on the proximity of the
treelines to farmed land it would be expected that the existing treelines could form a habitat for
foraging bat species. A bat survey was undertaken within the proposed development area, on 21st
April 2015, by Conor Kelleher (Aardwolf Surveys). All internal and external areas of Green Acres,
including each of the roof spaces within the main building, were inspected for bats in addition to the
grounds of the proposed development site. The report is seen in Appendix I.
“No evidence of past or current use by bats of any of the onsite structures or trees was found during
the present survey. At dusk, a pipistrelle Pipistrelle spp. was seen hunting along the western site
boundary at the rear of the main building but this bat did not originate from any of the onsite buildings.
Due to the high boundary treelines and hedgerows surrounding the site, the grounds are well vegetated
and very sheltered and so are favourable for swarming insects which then attract bats and, during the
summer months, one or two bats may be expected to hunt onsite occasionally.
In 2015 the onsite trees were inspected for their potential to harbour bats and any evidence of the
presence of a roost. The ivy-covered trees along the site boundaries have limited potential for roosting
bats as they are mostly tall, thin specimens and, in some cases, multi-stemmed and have no features
such as hollows or crevices that might be used by bats. Individual bats may occasionally rest behind
ivy-cover but, in the absence of hollows within the tree beneath, large roosts would not be present.
One onsite ash tree has suffered severe storm damage and does have some crevices present that may
be used by bats on occasion but no evidence of a roost was noted in the tree during the present survey.
No evidence of a bat roost was found in any of the onsite trees.”
22Between 2015 and 2018 a significant portion of the tiles on the roof of Greenacres have been removed
allowing for intrusion of water and making the house less favourable to bat species. In September
2018 an additional site assessment was carried out which included a dusk emergence survey on the
grounds of Green Acres and Drumahill. An internal and external visual inspection of Drumahill
House and an external inspection of Greenacres was also carried out. Onsite trees were also inspected
for roosting potential. No evidence of past or current use by bats of any of the onsite structures or
trees was found during the 2018 site visit. After dusk, a single pipistrelle Pipistrelle spp. was detected
and seen foraging in the front garden of Drumahill House. No bats were observed in Long Acre.
A 2018 tree inspection survey of bat roosts or roosting potential was carried out. No bat roost was
identified in any of the onsite trees. However, as a small number of bats are active onsite and mature
trees onsite have potential for bat use (Table 4). Mitigation measures to safeguard these animals are
needed during vegetation clearance and tree removal. As seen in table 4 there several trees (in bold)
that are proposed to be removed and have roosting potential. This is primarily as a result of the trees
being covered in ivy rather than crevices being present, with the exception of the ash (320) which had
cracks, broken limbs and ivy present.
A derogation licence is not required to fell the trees of roosting potential as no actual bat roosts were
observed. However, it recommended that a pre-construction survey is carried out and these trees are
studied in detail to ensure that roosts are not present at the time of felling. If a bat roost is found to
be present during the pre-construction survey the tree must not be felled until a derogation licence
had been granted.
Table 4. Bat roosting potential tree assessment (2018) (trees > low potential) and Arborist Impact
Tag Common Scientific name Description Bat Potential Arborist
No. name impact
234 Ash Fraxinus excelsior Heavy Ivy Growth Medium Removed
243 Ash Fraxinus excelsior Broken limbs and hollows Medium Removed
(weeping)
247 Sycamore Acer pseudoplatanus Very heavy ivy growth Medium to high Removed
257 Lawsons Cupressus lawsoniana Heavy ivy growth Medium Removed
cypress
267 Ash Fraxinus excelsior Heavy Ivy Growth Medium Removed
315 Cherry Prunus avium Heavy Ivy Growth Medium Removed
320 Ash Fraxinus excelsior Cracks and broken limbs Medium to high Removed
321 Hawthorn Crataegus momogyna Ivy Growth Low to Medium Removed
327 Ash Fraxinus excelsior Heavy Ivy Growth Medium Removed
328 Ash Fraxinus excelsior Heavy Ivy Growth Medium Removed
334 Ash Fraxinus excelsior Heavy Ivy Growth Medium Removed
335 Ash Fraxinus excelsior Heavy Ivy Growth Medium Retained
336 Ash Fraxinus excelsior Heavy Ivy Growth Medium Retained
337 Ash Fraxinus excelsior Heavy Ivy Growth Medium Retained
338 Ash Fraxinus excelsior Heavy Ivy Growth Medium Retained
339 Ash Fraxinus excelsior Heavy Ivy Growth Medium Retained
340 Ash Fraxinus excelsior Heavy Ivy Growth Medium Retained
341 Horse Aesculus Heavy Ivy Growth Low-Medium Retained
Chestnut hippocastanum
353 Sycamore Acer pseudoplatanus Very heavy ivy growth Medium to high Removed
354 Ash Fraxinus excelsior Heavy Ivy Growth Medium Removed
378 Beech Fagus sylvatica Ivy growth Low to medium Retained
379 Beech Fagus sylvatica Ivy growth Low to medium Retained
380 Beech Fagus sylvatica Ivy growth Low to medium Retained
395 Beech Fagus sylvatica Ivy growth Low to medium Removed
398 Beech Fagus sylvatica Ivy growth Low to medium Removed
402 Elm Ulmus procera Ivy growth Low to medium Retained
23Birds
No rare or bird species of conservation value were noted during the field assessment. Species seen
were as follows:
Woodpigeon Columba palumbus The proposed development site is located within 3.5
Wren Troglodytes troglodytes km of South Dublin SPA a feeding ground for Brent
Robin Erithacus rubecula geese. Initial surveys were carried out during the
Blackbird Turdus merula overwintering period when Brent geese were present
in this SPA. During high tide they move inland to feed
Blue tit Parus caeruleus
on open grassy areas such as football pitched and
Great tit Parus major parks. No Brent geese were observed on site. The
Starling Sturnus vulgaris enclosed nature of the site with tall trees and dense
Magpie Pica pica scrub, in addition to the close proximity to more
Jackdaw Corvus monedula optimal grassland such as St Tiernan’s Community
Rook Corvus frugilegus School, Ballawley Park and Deer Park, would indicate
House sparrow Passer domesticus that this is not a feeding ground for Brent geese.
Goldfinch Carduelis carduelis
Chaffinch Fringilla coelebs
244 ANALYSIS OF THE POTENTIAL IMPACTS
Construction Phase
The proposed development will involve the removal of the majority of existing habitats on site and
boundaries, with the exception of unimpacted trees around the perimeter of the site (Figure 2). The
overall development of the site is likely to have direct negative impacts upon the existing habitats,
fauna and flora (Table 5). Direct negative effects will be manifested in terms of the removal of the
existing houses, amenity grassland, scrub and hedgerows and many of the existing perimeter trees. As
can be seen in Figure 1 the site is currently enclosed by a perimeter of trees including a mix of conifers
and native species. During the planning of the proposal several meetings took place in relation to the
retention of trees on site. Considerable constraints were envisaged in relation to construction access,
tree quality, construction of buildings, soil excavations and levelling, width of the site, aesthetic value
and the potential impacts on the existing trees. As a result a substantial element of the treeline will be
removed. The removal of these habitats will result in a loss of nesting sites for garden bird species and
in foraging areas for foxes and bats as well as a part of the biodiversity corridor linking the site to the
Airfiled Estate. However, it should be noted that the existing treeline contains a significant number
of large conifers, which would be of low biodiversity value. The arborist’s report contains details of
all trees on site.
The demolition and construction phases could potentially impact on the existing ecology of the site
and the surrounding area. These potential impacts would include impacts that may arise during the
demolition, site clearance, re-profiling of the site and the building phases of the proposed
development. The proposed demolition of existing structures and development of the new onsite
structures will entail the loss of the majority of habitats within the site, as well as sections of the
treelines. Potential Impacts are assessed below for each of the ecological components.
Designated Conservation sites within 15km
Due to the distance from designated conservation sites i.e. a minimum of 1.8 km pNHA and 3.5km
from a Natura 2000 site, with no watercourse or intact biodiversity corridor, the principle vector for
potential impact to conservation sites lies with on-site drainage. There is no direct hydrological
pathway from the proposed development site to designated conservation sites. The indirect pathway
would be in the form of runoff from the site which would enter the public drainage network and to
the Ringsend WWTP for treatment. Having taking into consideration the effluent discharge from
the proposed development works, the scale of the development, the distance between the proposed
development site to designated conservation sites (min 1.8km), lack of direct hydrological pathway or
biodiversity corridor link to conservation sites and the dilution effect with other effluent, it is
concluded that this development that would not give rise to any significant effect on any designated
sites.
No impact is foreseen in relation to designated conservation sites from the proposed development.
Impacts: Neutral/Imperceptible/Temporary/localised/unlikely.
Terrestrial and avian Ecology
The impact of the development during the demolition and construction phases will be a loss of
existing habitats and species. It would be expected that the avian or mammalian fauna associated with
these habitats would also be displaced. During the site visits no flora, bird or terrestrial mammal
species of conservation importance were recorded on site or in NPWS or NBDC records.
Loss of habitat and habitat fragmentation may affect some common mammalian species and there is
expected to be mortality during construction. Small mammals such as long-tailed field mouse, house
mouse, brown rat, and protected species such as pygmy shrew and hedgehog may be directly impacted.
A fox (not-protected) was noted on site. There are limited ways to protect such species and these
species are common in Ireland.
In relation to amphibians and reptiles, frogs and reptiles were not observed on site. There are no
ponds / wet ditch areas within the study area. However, frogs may occur on site and have been
25recorded by NPWS within the 1km grid. The common lizard may occur on site but was not observed.
The proposed development will remove some potential foraging habitats on site. Some mortality may
occur during construction.
Impact: Neutral/ Slight to Moderate/ Short-term, localised, unlikely.
Bats
As outlined in the bat survey reports no roosts were found on site. A pre-construction survey will be
carried out as a precaution.
Impacts: Neutral/Imperceptible/Temporary/localised/unlikely.
Operational Phase
All onsite drainage will be connected to separate foul and surface water systems. The biodiversity value
of the site would be expected to improve as the landscaping matures. The green roofs would be seen
as a positive increasing biodiversity while assisting in attenuation of water on site.
Once developed, the site would be seen as a stable ecological environment. It would be expected that
there will be no significant ecological impact arising from the day to day operation of the proposed
residential development. However, the incorporation of native species planting and areas specifically
for native biodiversity within the landscaping proposals would of benefit to the long term ecology and
residents of the site. Positive impacts would be achieved by landscaping including planting a range of
flora in open spaces the overall abundance and diversity of vegetation on the site.
Designated Conservation sites within 15km
There are no watercourses in the vicinity of the application area. There is no direct pathway to
designated conservation sites. The indirect pathway would be in the form of runoff and effluent from
the site which would enter the public drainage network and to the Ringsend WWTP for treatment.
Having taking into consideration the effluent discharge from the proposed development works,
the scale of the proposed development, the distance between the proposed development site to
designated conservation sites (min 1.8 km), lack of direct hydrological pathway or biodiversity corridor
link to conservation sites and the dilution effect with other effluent, it is concluded that this
development that would not give rise to any significant effects to designated sites. As a result, no
negative impact on conservation sites is foreseen due to the operation of the proposed development.
The AA Screening report that accompanies this application under separate cover found that there is
no possibility of significant effects for all Natura 2000 sites within 15km. There is no possibility of
significant impact to designated conservation sites.
Impact: None foreseen (possibly beneficial long-term)
Terrestrial and avian ecology
As the landscaping elements improve with maturity it would be expected that the biodiversity value
of the site to birds and flora would also increase, particularly in the vicinity of the green roofs and
wildflower meadows. Landscape plans will be important to overall impact of the operational phase.
Impact: Neutral, localised, Slight to Moderate; Permanent.
Bat Fauna
Operational impacts of the development may also arise from the placement and design of artificial
lighting within the proposed development. Due to the current levels of light spill from adjacent public
road lighting and low levels of bat activity recorded during surveys, it is expected that lighting
associated with the proposed development will not significantly impact the local bat population.
Operational Impact: Slight; Temporary, localised.
26Table 5a. Construction Impacts on habitats
Habitat Fossitt Habitats Rating Construction Impact Impact Significance
Directive
Flower beds and BC4 E Construction will result in the direct removal of this habitat. However, post Negligible
borders construction landscaping will result in substantial areas of BC4 being developed.
Buildings and BL3 E Construction will result in the complete removal of this habitat. No evidence of Negligible
artificial surfaces bats inhabiting using this building was noted.
Re-colonising bare ED3 E Construction will result in the removal of this habitat. Negligible
ground
Amenity grassland GA2 E Construction will result in the complete removal of this habitat. Negligible
(improved)
Scattered trees and WD5 E Construction will result in the removal of much of this habitat. Several feature Negligible
parkland trees will be retained.
Hedgerows WL1 D Construction will result the removal of part of this habitat in the centre of the Minor Adverse
plot. Additional work will be carried out on the perimeter to tidy up the
hedgerows. Hedgerows mainly consist of Laurel hedging which would be of poor
conservation significance.
Treelines WL2 D An arborist has been consulted in relation to the condition and safe distances Minor-Moderate
from which construction works can take place. Short term disturbance may occur Adverse
of bird species particularly during removal of the onsite building, ground
clearance and soil removal operations.
Scrub WS1 E Construction will result in the complete removal of this habitat. Negligible
Table 5b. Construction Impacts on species
Species Rating Construction Impact Impact Significance
Mammal-Bats A No evidence of bats using the houses for a breeding or roosting site was seen on site. Foraging activity was Minor Adverse/
observed. localised/short-term
Mammal-Badger A Evidence of a disused badger sett was noted on site in 2015. This was not present in 2018. No active setts or Negligible
evidence of badger activity was noted. Recent construction on two sides of the property may have caused
disturbance of the badgers that were present and have restricted access to the site.
Mammals-Terrestrial A-D No terrestrial mammals of conservation importance were noted on site. The site may form part of the foraging Minor Adverse/
range of foxes from Airfield, no evidence of a den was noted. localised
Birds D Clearance of the site will result in the loss of nesting habitat. Subsequent planting, particularly of native hedgerows, Minor Adverse/
could result in a positive impact. . localised/short-term
Amphibians-Frogs B The site did not appear to be a habitat for frogs. A small pond is present in Drumahill but no frogs were noted. Negligible
Terrestrial Flora - No flora of conservation significance were found on the site. Negligible
27Indirect Impacts
Soil removed from the site during ground works would also have to comply with DLR policies and would
need to be disposed of in an appropriate manner. No invasive species were observed on site that could
impact on soil removal from the site. Appropriate measures should be taken to prevent movement of
dust into adjacent habitats during demolition.
The construction of new drainage networks will have to comply with SUDS and DLR requirements and
as a result would have negligible impact on habitats and species surrounding proposed development site.
Avoidance and Remedial Measures
Mitigation by Avoidance
Direct negative impacts upon the existing vegetation and house within the site are not regarded as being
significant due to the absence of species of conservation importance and as a result do not require
mitigation.
The avoidance of impacts on bats and potential roost sites will be avoided by undertaking bat surveys
during to the removal of key trees. This survey will need to be undertaken at appropriate times during
the year to address different stages of bat activity. Appropriate relocation procedures will be instigated
under licence from the Department of Environment, Heritage and Local Government should any bats
be found.
Sufficient consultation should take place with an arborist during site clearance to ensure that the trees to
be retained will not be impacted negatively.
Relevant guidelines and legislation (Section 40 of the Wildlife Acts, 1976 to 2012) in relation to the
removal of trees and timing of nesting birds needs to be followed e.g. do not remove trees or shrubs
during the nesting season (1st March to 31st August).
Mitigation by Remedy
Materials excavated for basement levels will have to be exported off-site. Dewatering of excavations
may be necessary. Appropriate monitoring of groundwater levels during site works should be
undertaken. In order to prevent “downstream impacts” appropriate mitigation measures should be
developed including filtering of excess water for suspended solids prior to discharge, if required.
Replanting of the perimeter treelines should be carried out with native trees, that would afford the
appropriate feeding and potential roosting sites for bat species. It would also assist in reinstating, if not
improving, the natural wildlife corridor that connects the site with Airfield Estate. These trees should be
allowed to grow to their maximum size to provide suitable roosting and foraging conditions for birds
and bat species. Lighting of treelines should be carried out sympathetically with due consideration for
bat species. In order to reinstate resource loss and promote biodiversity on site bird and bat boxes should
be included as part of the reinstatement of the site following construction.
Native Hedgerow planting should be included in planting schemes within the site, to reinstate nesting
resource lost during site clearance.
Cumulative Impacts
The proposed development site is outside of any designated conservation area, within a surburban
environment. The Airfield Estate which borders the proposed development site has undergone
significant remodelling in recent years. A request for planning permission for additional educational,
recreational and associated service facilities within Airfield House, Estate, Farm and Gardens increasing
the overall gross floor area of existing facilities within the estate from 2,421.78 sq.m to 3,766.48 sq.m
and creation of a new vehicular access to the site from Overend Way via adjoining Dudley's Field lands
was submitted in July 2010 and approved in February 2011.This site is proximal to the proposed
development on the southern and western boundaries. Within the site the demolition of the former
Green Acres Convent (425 sqm) was granted permission on the 11/09/2017. Other developments in
28You can also read
