FS006917 Irish Water

Site Investigation – Outfall at Tirroddy, Ramelton, Co. Donegal

Contents

Consolidated Prescribed Bodies Observations ............................................................................... 2

Water Marine Advisor ......................................................................................................................... 2

Marine Institute .................................................................................................................................. 6

Marine Survey Office .......................................................................................................................... 7

Department of Agriculture, Food and the Marine (DAFM) ................................................................ 8

Department of Culture, Heritage and the Gaeltacht (DCHG) ............................................................. 9

Inland Fisheries Ireland ..................................................................................................................... 11

Sea Fisheries Protection Agency (SFPA) ............................................................................................ 13

Public Submission(s) .................................................................................................................. 14

Consolidated Prescribed Bodies Observations

Water Marine Advisor

Re – Site Investigations re proposed Ramelton–Milford–Rathmullan (RMR) WWTP outfall alignment

to Lough Swilly at Browneknowe Islet, Ramelton in Lough Swilly – Irish Water – FS6917 (your email

of 15/05/2019 and attachments refer)

In relation to the above, Irish Water have submitted a Section 3.3 Foreshore Licence Application to

undertake Site Investigations (SI) in connection with the County Donegal Towns and Villages Sewerage

Schemes, (Rathmullan Sewerage Scheme) to provide information on ground conditions for the

proposed outfall pipe from the RMR WWTP at Browneknowe Islet, Tirroddy, Ramelton within Lough

Swilly. A parallel S3.3 application for Site Investigations in relation to the proposed Rising Main

Crossing at Rossreagh, Ramelton has also been made by Irish Water (Ref FS6918). While a separate

technical report is provided regarding that application, these two SI are being undertaken in

connection with the one overarching Sewerage Scheme, and are for the same type of SI and IW intend

to undertake all of these SI works under the same contract consecutively each lasting app 2 weeks

within the same waterbody and so the submitted Method Statements and AA Screening Reports deal

with both within the one document. I would recommend that both of these applications should be

processed at the same time. I comment as follows:

SUBMITTED DOCUMENTATION

The following documentation was submitted in support of this application:

Completed Section 3.3 Foreshore Licence Application Form dated 3/4/2019

Construction Stage Safety and Health Plan Additional overwater Works prepared by Causeway

Geotech Ltd on behalf of Irish Water dated 18/12/2018 (Method Statements are in Appendix

B)

Appropriate Assessment Screening Report prepared by Irish Water (undated)

Completed “Pre-Application Consultation Require Form” – dated 31/10/2018

Drawings/Maps as follows:

Drawing No 4940/RMR/FS/03 Rev A “RMR Outfall, Foreshore Application for Outfall Site

Investigation Works” at scale of 1:2000 on A3 (proposed SI area outlined in red)

PROPOSED WORKS

The proposed works include four overwater boreholes drilled using a shell and auger technique within

the survey area of 0.6761 Ha as per drawing (indicative locations for four boreholes are shown within

this area). The boreholes are scheduled to investigate to a depth between 10 to 20 m. The drilling

apparatus will be mounted on a jack up barge deployed using a push boat.

Location for mobilisation/demobilisation for the overwater plant is proposed as “The Quays area in

Ramelton”. Access to these SI works will be by water or via the foreshore utilising a farm gate and

access track at the outfall location and there will be no direct trampling on the foreshore. More details

are provided with reference to Method Statement (ref Appendix B of “Construction Stage Safety and

Health Plan”)

All work will be completed as per the relevant Method Statements and Risk Assessments

The works include the sinking of boreholes with sampling and in-situ testing and will include:

Ovewater cable percussion boring

Rotary follow-on drilling (if required)

In situ and laboratory testing and reporting

The boreholes will be drilled from a Combifloat Jack up barge. The platform will be certified and

registered as “Ocean Crest: OCM 50”. Personnel transfers will be via small outboard vessel and there

will be a push tug-boat in attendance to manoeuvre the jack up. The cable percussion boring will be

undertaken by a “Dando 3000” light cable percussion boring rig. Rotary follow on drilling will be

carried out by a “Comacchio MC405” rotary drilling rig. All boreholes will be located using GPS

technology. All plant and equipment when not in use (e.g. transit between exploratory borehole

locations) on the “OCM50” barge will be securely fastened or sea stored.

The jack up will be manoeuvred into location by means of a tug boat (OCM Fortress). Another tugboat

(safety boat) (OCM Supporter) will be provided in case of emergencies. The vessel will have the correct

shape and lights for static underwater works as required.

If required a notice to mariners will be issued prior to commencement of the site works. The notice

will be updated daily and communicated to all relevant organisations if required. When working at

hours of darkness, navigation lights will be deployed on vessels.

Any surplus spoils will be bagged and removed and disposed of in line with company waste disposal

procedures.

These SI Works are expected to take app 2 weeks to complete. Access to the Quays may be restricted

when the boreholes are being carried out. Each borehole will take app 12 hours to complete.

The proposed survey is located within the Lough Swilly SAC (site code 004075) and the Lough Swilly

SPA (site code 002287). The Applicants have submitted an Appropriate Assessment Screening Report

(undated) which concludes that ‘’given the scale of the proposed works, the short timescale, and the

availability of dilution and dissemination of any localised impact, in addition to the character of the

baseline environment, it has been evaluated that the potential for significant effects on any designated

European Site can be excluded, having regard to their conservation objectives occurring within the

zone of influence of the works’’ and so concludes that ‘’the proposed SI Works will not have a significant

effect on any European Site’’

This Department’s independent ‘’Appropriate Assessment Report‘’ has now been prepared and also

concludes that the proposed SI would not have any significant impact on the conservation objectives

of the Lough Swilly SAC and SPA. (This will be forwarded to MFPU as separate document in due course)

While there is no Geophysical Surveys proposed if relevant to any of the Site Investigations it is

recommended that the proposed SI Works should conform to the current DAHG Guidelines “Guidance

to Manage the Risk to Marine Mammals from Man-Made Sound Sources in Irish Waters ‘’(DAHG-

2014).’’ This can be made a condition of Foreshore Licence when/if granted.

CONCLUSION/RECCOMENDATIONS

Engineering Inspectorate is satisfied that the proposed Site Investigations will not impact on

navigation, fisheries or the Marine Environment and has no objection to the granting of a Section 3.3

Foreshore Licence subject to the following conditions:

1. The Applicant should notify this Department of the date of commencement of the Site

Investigation operations at least 2 weeks prior to commencement.

2. The Site Investigations will be carried out within the area delineated on Drawing No

4940/RMR/FS/03 Rev A and shall be conducted in accordance with the application

submitted to and approved by the Minister.

3. The Licensee shall use that part of the foreshore in Lough Swilly, the subject area (as shown

on submitted drawings) of this Licence for the purposes as outlined in the application and

for no other purpose whatsoever. Only those Site Investigation Works the subject of this

foreshore licence application and in particular as outlined in the Application Documents

shall be undertaken.

4. During the course of the Site Investigation the Applicants shall ensure that,

(a) All necessary precautions are put in place to protect the public in accordance with

relevant Health and Safety Legislation;

(b) Existing public access arrangements to the general foreshore area are not impeded

by any vessels, plant or materials used in connection with the site investigations,

and where relevant this access should be made safe and guaranteed by the

provision of appropriate signage/notices/barriers et cetera to the satisfaction of the

Department of Housing, Planning and Local Government;

(c) Procedures are adopted to ensure that the Site Investigations operations are not

injurious to fishing, navigation, adjacent lands or the public interests

5. The Licensee shall furnish the names/registered number of all vessels involved in the Site

Investigations operations to the Marine Survey Office in Dublin to ensure compliance with

respect to Irish Load line and other relevant vessel certification.

6. The Licensee shall arrange the publication of a marine Notice through the Maritime Safety

Directorate giving a general description of operation and approximate dates of

commencement and completion of the works.

7. Where applicable relevant Site Investigation works shall comply with DAHG’s document

entitled “Guidance to manage the risk to Marine Mammals from man-made sound in Irish

waters” dated 2014 as appropriate.

8. All Site Investigation works shall be implemented in accordance with the relevant Method

Statements as set out in Appendix B of the “Construction Stage Safety and Health Plan”

document dated 18/12/2019.

9. Where relevant Site Control Measures, as specified in the “Construction Stage Safety and

Health Plan Additional Overwater Works” dated 18/12/2018, shall be implemented during

the Site Investigations.

10. All Site Investigations and Marine surveys shall be completed by no later than September

2019.

P.J. Shaw

Water Advisor

D.H.P.L.G

Custom House

Dublin 1

24/05/2019

Marine Institute

Marine Institute Comments on Foreshore Licence Application by Irish Water – Site Investigations at Tirroddy, Ramelton, Co. Donegal (FS006917)

Irish Water has submitted an application for a Foreshore Licence to carry out site investigation works

on the foreshore at Tirroddy, Ramelton, Co. Donegal. The works, which involve the drilling of 4 No.

boreholes to a depth of 10 m, is part of a project involving the proposed installation of a marine outfall

from the Ramelton-Milford-Rathmullan (RMR) WWTP.

The location and details of the proposed works are shown in the following drawing submitted by the

application:

Drawing No. 4940/RMR/FS/03, “RMR Outfall: Foreshore Application for Outfall: Site Investigation Works”, Rev A, dated March 2019.

The works will be carried out from a jack-up barge and it is anticipated that the works would be

completed within a 2 week period.

The area of foreshore involved is circa 0.67 Ha.

Considering the nature, location and duration of the proposed works significant impacts on the Marine

environment or on other legitimate uses / users of the areas are not considered likely. There are no

licenced aquaculture sites in the area of the proposed works. The nearest licenced aquaculture site is

located circa 3 Km to the east of the area of the proposed works and significant impacts on aquaculture

in the area are not considered likely.

The Marine Institute has no objections to a licence being granted. It is recommended that the

following conditions should be attached to any licence that may issue.

1. The Licensee shall use that part of the Foreshore the subject matter of this licence for the

purposes as outlined in the application and for no other purposes whatsoever.

2. The Licensee shall ensure that appropriate methods of operation are adopted in order to

ensure that no spillages of fuel, hydrocarbons, or other leakages to the foreshore occur during

the works.

3. On completion of the works the Licensee shall ensure that all equipment and materials are

removed and the foreshore is reinstated to its original condition.

Dr. Terry McMahon

Marine Institute and Food Safety Services

Marine Institute

21 May 2019

Marine Survey Office

Marine Survey Office, Tel: 353-071-9822400

Abbey View House,

Ballyshannon T.C.

Donegal,

Ireland.

Fax: 6783409

Memorandum to CZMD – Foreshore Section

Attention Lorraine Walshe

Fax No 6782159

From Nick Cantwell

No of Pages 1

Date 30 July 2019

Reference FS006917 Irish Water Site Investigations -

Tirroddy, Ramelton, Co. Donegal

CC

In the absence of any adverse impact on navigational safety, this office has no objections from a

navigational viewpoint to the above application.

The applicant is required to arrange the publication of a Marine Notice in a local newspaper. This

marine notice should give a general description of operations and approximate dates of

commencement and completion.

The divisional engineer should be informed prior to commencement of works.

Yours faithfully

____________________

Nick Cantwell (Capt.)

Nautical Surveyor

Department of Agriculture, Food and the Marine (DAFM)

From: Tokay, Louise [mailto:Louise.Tokay@agriculture.gov.ie]

Sent: 02 July 2019 16:03

To: Lorraine Walsh <Lorraine.Walsh@housing.gov.ie>

Cc: Foreshore <Foreshore@agriculture.gov.ie>

Subject: RE: FS006917 Irish Water Site Investigations - Tirroddy, Ramelton, Co. Donegal

Dear Lorraine,

Your Ref: FS 006917

Our Ref: FW/15/17

Re: Irish Water Site Investigations - Tirroddy, Ramelton, Co. Donegal

Further to your e-mail below.

On the basis of the information provided, the Department has no objections however please note

the following recommendations from our Marine Engineering Division:

Rotary coring operations may generate small amounts of suspended solids local to the borehole sites

however the impact of these works are likely to be negligible. The following best practice

recommendations should be adhered to:-

Refuelling activities taking place over water should be kept to a minimum and should follow

best practice (use of drip trays, avoiding refuelling during bad weather etc.).

A spill kit should be kept available on the JUB and staff should be appropriately trained in its

deployment and operation.

A Marine Notice should be put in place for the duration of the proposed site investigation

works.

Regards,

Louise

Aquaculture & Foreshore Management Division

Department of Agriculture, Food and the Marine

National Seafood Centre, Clonakilty, Co. Cork, P85 TX47

Email: louise.tokay@agriculture.gov.ie

Tel: +353 23 8859576

Department of Culture, Heritage and the Gaeltacht (DCHG)

From: Fem Dau [mailto:Fem.Dau@chg.gov.ie]

Sent: 24 June 2019 14:39

To: Lorraine Walsh <Lorraine.Walsh@housing.gov.ie>

Subject: RE: FS006917 Irish Water Site Investigations - Tirroddy, Ramelton, Co. Donegal

A chara,

Please find the underwater archaeology recommendations of the Department of Culture, Heritage, and

the Gaeltacht for the above mentioned foreshore application.

It is noted that the proposed development site is located in an area of high archaeological potential. The

Wreck Inventory of Ireland Database lists a number of wrecks for the Ramelton and Lough Swilly area

which are subject to statutory protection under section 3 of the 1987 National Monuments (Amendment)

Act. Given the location of the proposed development and the nature of the works it is possible that

underwater and terrestrial archaeology may be impacted by the proposed works. It is therefore

recommended that an Underwater Archaeological Impact Assessment as described below, shall be

undertaken to assess the impact of the development on known or potential archaeology. The

Underwater Archaeological Impact Assessment should be submitted as further information. This will

enable this Department to formulate an informed archaeological recommendation before a planning

decision on the proposed development is taken.

It should be borne in mind, that if significant archaeological remains are found, refusal might still be

recommended, and/or further monitoring or excavation required.

Underwater Archaeological Impact Assessment shall be compiled as follows;

1. The applicant is required to engage the services of a suitably qualified archaeologist to carry out an

archaeological assessment of the potential impacts of the development/proposed works.

2. The assessment shall comprise of a detailed desktop study, with the archaeologist carrying out any

relevant documentary research including consulting with the Wreck Inventory of Ireland, the

Record of Monuments and Places all of which are held by this Department. The Topographical Files

held by the National Museum of Ireland should also be consulted. The assessment should also

include a detailed archaeological impact statement including a detailed description of the

proposed works and the impact they will have on known and/or potential archaeology.

3. The archaeologist shall carry out an intertidal and dive survey of all areas that may be impacted

both directly and indirectly by the proposed works. The dive survey shall be accompanied by a

hand held metal detection survey and the area to be covered shall be agreed with the NMS in

advance of the surveys taking place.

4. The dive and metal detection surveys should be carried out under licence granted under sections 2

& 3 of the National Monuments Act 1987. It is advised that all diving be undertaken in accordance

to the Rules and Regulations as specified by the Health and Safety Authority’s Safety in Industry

(Diving Operations) Regulations 1981, SI 422.

5. Having completed the work, the archaeologist shall submit a written report to this Department for

review.

6. Where archaeological material/features are shown to be present, preservation in situ, avoidance,

preservation by record (archaeological excavation) or archaeological monitoring may be required.

The applicant shall be prepared to be advised by the Department of Culture, Heritage and the

Gaeltacht in this regard.

If any clarification is required on any of the above do not hesitate to contact this Department. An officer

from this Department would also be available to meet to discuss the above.

It should be borne in mind, that if significant archaeological remains are found, further archaeological

mitigation might be required.

Mise le meas,

Connor Rooney

Executive Officer

__

An Roinn Cultúir, Oidhreachta agus Gaeltachta

Department of Culture, Heritage and the Gaeltacht

Aonad na nIarratas ar Fhorbairt

Development Applications Unit

Bóthar an Bhaile Nua, Loch Garman, Contae Loch Garman, Y35 AP90

Newtown Road, Wexford, County Wexford, Y35 AP90

__

T +353 (0)53 911 7464

manager.dau@chg.gov.ie

www.chg.gov.ie

__

Inland Fisheries Ireland

MARINE LICENCE VETTING COMMITTEE:

Re: DECLG file ref FS 006917 Foreshore Application by Irish Water – Overwater boreholes as part of

site investigative works for proposed outfall pipe from the RMR Wastewater Treatment Plant,

Tirroddy, Ramelton, Co. Donegal

Request for observations from Ms. Lorraine Walsh (DECLG) dated 15.5.2019

Applicant information:

This application is in respect of overwater boreholes as part of site investigative works for proposed

outfall pipe from the RMR Wastewater Treatment Plant. Borehole locations are indicative, only,

locations may vary within licenced area.

Applicant proposed approximate start date 1st August 2019 with a works duration of 2 weeks.

The boreholes are scheduled to investigate to a depth of 10 to 20 m. For the marine site investigations,

the drilling apparatus/rig will be mounted on a jack-up barge deployed using a push boat. It is

anticipated that the site investigation period for the rising main crossing at Ramelton (FS 6918) and at

the outfall (FS 6917) will total approximately 4 weeks in duration. Contractor estimates ca. 2 weeks

at each site.

Ramelton Rising Main (FS 6918): Proposed works include four overwater boreholes drilled

suing a shell and augur technique will be undertaken within the Lough Swilly SAC And SPA

complex (4 X boreholes)

Marine Outfall (FS 6917): Ground investigation works will include four overwater boreholes

drilled using the shell and auger technique, located within the Lough Swilly SAC and SPA

complex (4 X boreholes)

IFI comment and queries:

The Appropriate Assessment process indicates that the proposal would not impact on the qualifying

interests of the SAC and SPA in which the works areas are situated.

The Screening Report contains a comprehensive Method Statement outlining the construction

proposal as well as a series of detailed mitigations to offset any adverse impact of the works – in regard

to any release of cements, oils/greases et cetera.

An concern of IFI relates to passage of migratory fish species – particularly Atlantic salmon and sea

trout into and out of the Leannan system. While the salmon is not listed as a qualifying interest in this

SAC it would be necessary to ensure that noise and general disturbance at the outfall and river crossing

site environs during works do not have localised and temporary impacts on fish movements. This can

be avoided if the timing of the works is planned in advance. IFI would recommend that a condition of

foreshore licence approval would require that detailed method statement and timing of works be

agreed with IFI Ballyshannon Office IN ADVANCE of any works commencing.

James J. King (IFI R&D); Brendan Maguire and Gerry McCaferty (IFI Ballyshannon)

Inland Fisheries Ireland

01.07.2019

Sea Fisheries Protection Agency (SFPA)

From: Lorraine Walsh

Sent: 16 July 2019 12:26

To: Declan McGabhann SFPA <declan.mcgabhann@sfpa.ie>

Subject: FW: FS006917 Irish Water Site Investigations - Tirroddy, Ramelton, Co. Donegal

Hi Declan

Your observations on the below application are outstanding. Should we not receive a response

within 10 days, we will assume you have no comments to make.

Kind regards

Lorraine

Public Submission(s)

Ref: FS006917

Further to the application by Irish Water – notice contained in the Irish Independent of the 24th May

- for a Foreshore Licence for overwater boreholes as part of site investigative works for the proposed

outfall pipe from the RMR Wastewater Treatment Plant, Tirroddy, Ramelton, Co. Donegal; we, the

below named members of Ray Action Group, object to the proposal of several boarholes being made

at Tiroddy on the basis of environmental impact on the foreshore, particularly given that the area is

a special area of conservation got Shellfish populations. The environmental impact of boarholes is

unknown as the Environmental Impact statement for the wider RMR Treatment Plant proposal has

not yet been made public. Because this information has been held back we are concerned that even

exploratory boarholes would have a negative impact on the foreshore environment and therefore

must object as a result of the lack of clarity on this issue.”

References:

a. Lough Swilly Special Protection Area 004075 https://www.npws.ie/protected-

sites/spa/004075

b. Lough Swilly Special Area of Conservation 002287 https://www.npws.ie/protected-

sites/sac/002287

Due to their involvement with the SAC, we would also respectfully request that the Department of

Culture, Heritage and the Gaeltacht be consulted in relation to this application.

Yours sincerely,

Liam McFadden

Sara Martin

Bridgena McFadden

Declan Meehan

Eddie McFadden

PJ Sweeney

Eileen Borland