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.
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) 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.
Related Environmental Protection Measures incorporated into the proposal
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.
Related Environmental Protection Measures incorporated into the proposal
(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).
These measures are all best practice and standard in nature.
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.
These measures are all best practice and standard in nature.
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.
Related Environmental Protection Measures incorporated into the proposal
(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).
These measures are all best practice and standard in nature.
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)
Related Environmental Protection Measures incorporated into the proposal
(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.
These measures are all best practice and standard in nature.
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.
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.
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.
Related Environmental Protection Measures incorporated into the proposal
(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.
Related Environmental Protection Measures incorporated into the proposal
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.
Human Beings, Population and Human Health
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.
Biodiversity. Flora and Fauna
• 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.
Material Assets, landscape and cultural heritage
including architectural aspects
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.
The interrelationship between the environmental
topics
Low level of intensity and none complex in nature
(e) The probability of the
impact.
Human Beings, Population and Human Health
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).
Biodiversity. Flora and Fauna
• 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.
Material Assets, landscape and cultural heritage
including architectural aspects
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).
The interrelationship between the environmental
topics
Low having regard to environmental protection
measures incorporated into the project.
(f) The expected onset,
duration, frequency and
Human Beings, Population and Human Health
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.
Biodiversity. Flora and Fauna
• 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.
Material Assets, landscape and cultural heritage
including architectural aspects
Expected to coincide with the commencement of
works on site. Alteration would be long-term and
not reversible.
The interrelationship between the environmental
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.
Human Beings, Population and Human Health
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.
Biodiversity. Flora and Fauna
None likely
Water
None likely
Air and Climate
None likely
Material Assets, landscape and cultural heritage
including architectural aspects
None envisaged / likely
The interrelationship between the environmental
topics
None likely
(h) The possibility of
effectively reducing the
impact.
Human Beings, Population and Human Health
Standard traffic and construction management
would effectively reduce any such impacts. It is
noted that such measures are incorporated into the
proposal.
Biodiversity. Flora and Fauna
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.
Material Assets, landscape and cultural heritage
including architectural aspects
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.
The interrelationship between the environmental
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.