Comhairle Contae Thiobraid Arann Thuaidh North Tipperary County ...

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Comhairle Contae Thiobraid Arann Thuaidh 

Water Services Section 

Civic Offices, North Tipperary County Council A 

Limerick Road, 

Nenagh 

CO. Tipperary 

Civic Offices, Limerick Road, Nenagh, Co. Tipperary. 

Oifigi Cathartha, B6thar Luimnigh, An t-Aonach, Contae Thiobraid Arann. 

Ms. Karen Creed. 

Senior Inspector, 

Office of Climate Licensing & Resource Use, 

EPA, 

Headquarters P.O. Box 3000 

Johnstown Castle Estate, 

Co. Wexford. 

25fh September, 2009 

Dear Ms. Creed, 

RE: Discharge Licence Application No: D0026/01 

Thurles Waste Water Treatment Plant. 

Attached find hard copy of appropriate Assessment carried out by Ecofact, 

Environmental Consultants, Dominic Street, Limerick. This report was requested by 

E.P.A. to support Discharge Licence application by North Tipperary County Council 

for Thurles Waste Water Treatment Plant. 

Electronic version of report already emailed to you. 

If you require any further information please let me know. 

Yours sincerely 

Water Services 

F6n/phone: 067-44500 

‘ag obair leis an bpobal’ 

For inspection purposes only. 

Consent of copyright owner required for any other use. 

Facs/Fax: 067-33134 Cr&asdn/Web: www.tipperarynorth.ie 

Aertel Leathanach/Aertel Page: 622 ‘working with the community’ 

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Thurles Wastewater Treatment Plant 

Lower River Suir candidate Special Area of Conservation 

(site code 002137) 

Article 6 Appropriate Assessment Report 

Version: 25'h September 2009 

Prepared on behalf of 

North Tipperary County Council 



ecofact 

Environmental Consultants 

Tait Business Centre, Dominic Street, Limerick City, Ireland. 

t. +353 61 313519, f. +353 61 414315 

e. info@ecofact.ie 

w. www.ecofact.ie 

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‘. Ecofact Environmental Consultants Ltd. Thurles WwTP Appropriate Assessment 

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I. INTRODUCTION 

The current document assesses the likely significant effects of the ongoing operation of the 

Thurles Waste Water Treatment Plant (WwTP) upon the Lower River Suir Special Area of 

Conservation (SAC). Effects upon both habitats and species within the SAC are considered. 

The Thurles WwTP discharges directly into the SAC so could potentially be having direct 

effects on this area. 

This document draws upon the information supplied by North Tipperary County Council. A 

range of other desk study sources were utilised in this assessment including scientific reports 

produced by and information on the websites of the EPA, NPWS, North Tipperary County 

Council and other agencies were also reviewed. 

The site synopsis for the affected SAC is included as Appendix I to this report. 

The current report was prepared by Ecofact Environmental Consultants Ltd. on behalf of 

Tipperary North County Council over two consultancy days in September 2009. This is 

considered to be a relatively short time to complete an assessment of this type. No site visit 

was carried out for the preparation of the current screening assessment. 

1 .I Legislative context 

Council Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and 

flora - ‘The Habitats Directive’, has been transposed into Irish law by The European 

Community (Natural Habitats) Regulations 1997 (S.I. No. 94/1997). 

The 1997 Regulations were updated in 1998 by The European Communities (Natural 

Habitats) (Amendment) Regulations 1998 (S.I. No. 233/1998) to include Council Directive 

97/62/EC which served to update Council Directive 92/43/EEC, adapting it to technical and 

scientific progress made in the intervening years. 

The 1997 Regulations were again updated in 2005, by The European Communities (Natural 

Habitats) (Amendment) Regulations 2005 (S.I. No. 37812005). This amendment served to 

consolidate the main nature conservation legislation enacted in Ireland, meaning The Wildlife 

Act 1976, The Wildlife (Amendment) Act 2000, The European Communities (Natural Habitats) 

Regulations 1997, The European Communities (Natural Habitats) (Amendment) Regulations 

1998, and to draw direct reference upon Council Directive 79/4091EC on the conservation of 

wild birds - ‘The Birds Directive’. 



The Birds Directive seeks to protect birds of special importance by the designation of Special 

Protection Areas (SPAs) whereas the Habitats Directive does the same for habitats and other 

species groups with Special Areas of Conservation (SACs). It lists certain rare habitats (Annex 

I) and species (Annex II) whose conservation is of community interest. It is the responsibility 

of each member state to designate SPAs and SACs, both of which will form part of Natura 

2000, a network of protected areas throughout the European Community. 

Article 6, paragraphs 3 and 4 of the Habitats Directive state that: 

6(3) Any plan or project not directly connected with or necessary to the management of the 

site but likely to have a significant effect thereon, either individually or in combination with 

other plans or projects, shall be subject to appropriate assessment of its implications for the 

site in view of the site’s conservation objectives. In the light of the conclusions of the 

assessment of the implications for the site and subject to the provisions of paragraph 4, the 

competent national authorities shall agree to the plan or project only after having ascertained 

that it will not adversely affect the integrity of the site concerned and, if appropriate, after 

having obtained the opinion of the general public. 

6(4) If, in spite of a negative assessment of the implications for the site and in the absence 

of alternative solutions, a plan or project must nevertheless be carried out for imperative 

reasons of overriding public interest, including those of a social or economic nature, the 

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Member State shall take all compensatory measures necessary to ensure that the overall 

coherence of Natura 2000 is protected. It shall inform the Commission of the compensatory 

measures adopted. 

Where the site concerned hosts a priority natural habitat type and/or a priority species, the 

only considerations which may be raised are those relating to human health or public safety, 

to beneficial consequences of primary importance for the environment or, further to an opinion 

from the Commission, to other imperative reasons of overriding public interest. 

I .2 Consultation 

The following bodies provided information for this report: 

0 National Parks and Wildlife Service (NPWS); 

0 Southern Regional Fisheries Board (SRFB); 

0 North Tipperary County Council (KCC); 

0 Office of Public Works (OPW). 

0 Environmental Protection Agency (EPA). 



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/I 2. METHODOLOGY 

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2.1 Desktop Review 

A review of areas designated (or being considered for designation) for nature conservation 

was carried out by consulting the National Parks and Wildlife Service (NPWS). These included 

Special Areas of Conservation, Special Protection Areas for birds (both internationally 

important) and proposed Natural Heritage Areas (of national importance). Technical files and 

previous reports prepared for the WwTP were supplied by Tipperary County Council for 

review in the current assessment. A review of the published literature was undertaken in order 

to collate data on the receiving environment, including aquatic species and habitats of 

conservation concern in the study area. A range of additional sources of information including 

scientific reports produced by, and information on the websites of the EPA, NPWS, Tipperary 

County Council and other agencies were also reviewed. A full bibliography of information 

sources reviewed is given in the references section. Ordinance Survey Maps and OS aerial 

photographs were'also reviewed during the desk assessment. 

I 2.2 Assessment Methodology 

The Department of the Environment, Heritage and Local Government has not published 

guidelines for undertaking Appropriate Assessment in Ireland. This Appropriate Assessment 

has been carried out using the following guidance: 

0 Managing Natura 2000 Sites: the provisions of Article 6 of the 'Habitats' Directive 

92/43/EEC, Office for Official Publications of the European Communities, Luxembourg 

(EC 2000); 

Assessment of Plans and Projects Significantly Affecting Natura 2000 Sites: 

Methodological guidance on the provisions of Article 6(3) and (4) of the Habitats 

Directive 92/43/EEC, Office for Official Publications of the European Communities, 

Luxembourg (EC 2001); 

The Habitats Regulations: A guide for competent authorities, Environment and 

Heritage Service, Belfast (EHS, 2002); 

0 Guidance for Competent Authorities when dealing with proposals affecting SAC 

freshwater sites, Scottish Natural Heritage, Perth (SNH, 2006); and 

0 Guidance document on Article 6(4) of the 'Habitats Directive' 92/43/EEC - 

Clarification of the concepts of: alternative solutions, imperative reasons of overriding 

public interest, compensatory measures, overall coherence, opinion of the 

commission. Office for Official Publications of the European Communities, 

Luxembourg (EC 2007). 

Based on these guidelines, the assessment is a four staged approach described below and 

illustrated in Figure 1. 

0 Stage One: Screening / Test of Significance - the process which identifies the likely 

impacts upon a Natura 2000 site of a project or plan, either alone or in combination 

with other projects or plans, and considers whether these impacts are likely to be 

significant; 

0 



Stage Two: Appropriate Assessment - the consideration of the impact of the project or 

plan on the integrity of the Natura 2000 site, either alone or in combination with other 

projects or plans, with respect to the site's structure and function and its conservation 

objectives. Additionally, where there are adverse impacts, an assessment of the 

potential mitigation of those impacts; 

Stage Three: Assessment of Alternative Solutions - the process which examines 

alternative ways of achieving the objectives of the project or plan that avoid adverse 

impacts on the integrity of the Natura 2000 site; and 

0 Stage Four: Assessment Where Adverse Impacts Remain - an assessment of 

compensatory measures where, in the light of an assessment of Imperative Reasons 

of Overriding Public Interest (IROPI), it is deemed that the project or plan should 

proceed. 

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Figure 1 Flowchart outlining the appropriate assessment process (Adapted from EC, 2001). 

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I 3. STAGE 1 : SCREENING / TEST OF SIGNIFICANCE 

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This stage examines whether or not likely effects upon a Natura 2000 site will be significant. 

The screening process in this report follows the matrix outlined in the EC Environment DG 

(2001) report. The headings to be covered by this matrix are outlined below and are 

discussed further in the following text. 

0 

0 

Brief description of the project or plan. 

Brief description of the Natura 2000 site. 

3.1 Assessment criteria 

Describe the individual elements of the project (either alone or in combination with other plans 

or projects) likely to give rise to impacts on the Natura 2000 site. 

Describe any likely direct, indirect or secondary impacts of the project (either alone or in 

combination with other plans or projects) on the Natura 2000 site by virtue of: 

size and scale; 

land-take; 

distance from the Natura 2000 site or key features of the site; 

resource requirements (water abstraction etc.); 

emissions (disposal to land, water or air); 

excavation requirements; 

trans porta tion require men ts; 

duration of construction, operation, decommissioning, etc.; 

other. 

Describe any likely changes to the site arising as a result of: 

reduction of habitat area: 

0 disturbance to key species; 

0 habitat or species fragmentation; 

0 reduction in species density; 

0 changes in key indicators of conservation value (water quality etc.); 

0 climate change. 

Describe any likely impacts on the Natura 2000 site as a whole in terms of: 

0 

interference with the key relationships that define the structure of the site; 

interference with key relationships that define the function of the site. 

Provide indicators of significance as a result of the identification of effects set out above in 

terms of: 

loss; 

0 fragmentation; 

0 disruption; 

0 disturbance; 



0 change to key elements of the site (e.g. water quality etc.). 

Describe from the above those elements of the project or plan, or combination of elements, 

where the above impacts are likely to be significant or where the scale or magnitude of 

impacts is not known. 

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3.2 Description of the project 

3.2.7 lnfroducfion 

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Thurles is a residential and commercial centre in the southern portion of North Tipperary. The 

town is expected to grow in population and according to the 2006 census the population in the 

town was 6,831. 

The Thurles WwTP has a design capacity of 15,000 population equivalent (P.E.) and consists 

of inlet works with screens, storm water retention tank, two rectangular aeration basins, one 

clarifier, drying beds for sludge and associated pump sumps, control and administration 

house. There is a single discharge point to the River Suir at the WwTP site. Table I presents 

the current design capacity and loading to the Thurles WwTP. 

Table 1 Thurles Wastewater treatment plant loadings (North Tipperary Co. Co. data) 

Plant 2 . 3 , e . I ,Design Capacity . I Loading (PE) ’ 1 . 7 ,‘I Additional PE fiquired. . I 

Thurles WwTP 1 15,000 I 14,140* I 365 

*This loading has recently been reduced by 6,000 p.e (see text below). 

The combined sewer network within Thurles town includes one storm water overflow which 

discharges to the River Suir in the centre of the town. There is no current monitoring data for 

the operation of the storm water outfall in the town. 

Three pumping stations within the combined sewer network also contain emergency overflow 

systems, while the Thurles WwTP contains an emergency overflow pipe which discharges to 

the River Suir via the main discharge. There is limited data available currently for the 

frequency or scale of the storm and emergency overflow systems within the Thurles 

combined sewerage network. 

3.2.2 Thurles WwTP upgrade works 

Recent works were undertaken at Thurles WWTP to improve the efficiency and the quality of 

the final effluent although the capacity of the plant was not increased. Quality improvements 

included the provision of phosphate reduction facilities by Ferric sulphate dosage was 

commissioned in November 2008. 



The recent upgrade also included the provision of a diffused aeration system to oxygenate the 

aeration tanks to replace the existing surface aerators. This has made the plant more efficient 

in terms of oxygenation of the mixed liquor in the aeration tank and has produced a higher 

quality final effluent. The new diffused aeration system was completed on the 30 September 

2008. 

In 2008 the Thurles WwTP was approaching capacity, however, a food processing plant 

which was previously discharging to the WwTP has now been taken off-line to a private 

treatment plant, allowing for the availability of ca. 6,000 P.E. equivalent at the Thurles WwTP. 

Recently completed upgrades to the Thurles WwTP will have a direct impact on the current 

ecological status of the Lower River Suir SAC, resulting in an improvement in phosphate 

levels in the river downstream of the plant. It is considered that monitoring data is required to 

establish this over the longer term. 

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3.3 Description of the receiving environment 

3.3.1 Introduction 

The Thurles WwTP discharges into the River Suir downstream of Thurles town, in the 

townland of Commons, downstream of Cabragh Bridge. This discharge point downstream of 

Cabragh Bridge discharges directly into the Lower River Suir Special Area of Conservation 

(site code 002137). No other Natura 2000 sites are directly or indirectly affected by the 

Thurles WwTP discharge. 

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The River Suir meanders through the region from the north to the southwest. The River Suir is 

one of the major rivers of Ireland, one of the “Three Sisters” comprising the rivers Barrow, 

Nore & Suir which enter the sea via Waterford Harbour. The Drish River, a tributary of the 

River Suir, rises in the Slieveardagh Hills near Ballysloe, to the east of the study area, and 

enters the main channel ca. 3 river kilometres upstream of the discharge, i.e. upstream of the 

SAC designation. 

3.3.2 The Lower River Suir SAC 

3.3.2.1 Overview of the conservation interests of the Lower River Suir SAC 

The Lower River Suir cSAC (site code: 002137) is a large site, extending from Cabragh 

Bridge south of Thurles, with tidal stretches as far as the confluence with the Barrow / Nore 

immediately east of Cheekpoint in Co. Waterford. It includes many tributaries; the Clodiagh in 

Co. Waterford, the Lingaun, Anner, Drish, Nier, Tar, Aherlow, Multeen and Clodiagh in Co. 

Tipperary. It is selected as a cSAC for the presence of a priority habitat on Annex I of the E.U. 

Habitats Directive, alluvial wet woodlands. The site is also selected as a candidate SAC for 

floating river vegetation, Atlantic salt meadows, Mediterranean salt meadows, old oak 

woodlands and eutrophic tall herbs, all habitats listed on Annex I of the E.U. Habitats 

Directive. The site is also selected for the following species listed on Annex I1 of the same 

directive - Sea Lamprey, Peteromyzon marinus, River Lamprey Lampetra fluviatilis, Brook 

Lamprey Lampetra planeri, Freshwater Pearl Mussel Margaritifera margaritifera, Crayfish 

Austropotamobius pallipes, Twaite Shad Alosa fallax, Atlantic salmon Salmo salar, and Otter 

Lutra lutra. 

Floating river vegetation is evident in the freshwater stretches of the River Suir and along 

many of its tributaries. Typical species found include Canadian Pondweed Elodea 

canadensis, Milfoil Myriophyllum spp., Fennel Pondweed Potamogeton pectinatus, Curled 

Pondweed P. crispus, Perfoliate Pondweed P. perfoliatus), Pond Water-crowfoot Ranunculus 

peltatus, other Crowfoots Ranunculus spp. and the moss Fontinalis antipyretica. Oppositeleaved 

Pondweed Groenlandia densa, a species protected under the Flora (Protection) Order, 

1999, is known from the lower reaches of the Suir around Clonmel and Carrick-on-Suir. 

Cabragh marshes, just below Thurles, lie in a low-lying tributary valley into which the main 

river floods in winter. Although part of this SAC, it is also a separately listed pNHA (site code 

1934), which is described in detail below. 



The Suir cSAC also supports populations of several animal species. Those which are listed in 

the Irish Red Data Book include Daubenton’s Bat Myotis daubentonii, .Nattererer’s Bat M. 

nattereri, Pipistrelle Pipistrellus pipistrellus, Pine Marten Martes martes, Badger Meles meles, 

the Irish Hare Lepus timidus hibernicus, Smelt Osmerus eperlanus and the Frog Rana 

temporaria. 

Kingfisher, a species that is listed on Annex I of the EU Birds Directive, occurs along some of 

the many tributaries throughout the site. Notable populations of other bird species are 

recorded from the Lower reaches of the site, as well as at Cabragh marshes where there is 

abundant food for surface feeding wildfowl. Widgeon, Teal and Mallard are numerous and the 

latter has a large breeding population - with up to 400 in summer. In addition, less frequent 

species like Shoveler and Pintail occur and there are records for both Whooper and Bewick‘s 

swans. The legally protected species Meadow Barley (Hordeum secalinum) occurs in the Suir 

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estuary near Waterford. The full site synopsis for this conservation site is presented in 

Appendix 1. 

The faunal conservation interests of this SAC are directly dependant on the aquatic 

environment and as the Thurles WwTP discharges to the River Suir within the SAC 

designation, there is a connection between this facility and the ecological receptors in the 

River Suir. 

In Table 2 the qualifying interests for the River Suir SAC are listed, and it is indicated whether 

these habitats and species would be present in the River Suir in the general vicinity of the 

Thurles WwTP. Some of the species listed in Table 2 would occur only in the lower reaches of 

the river (i.e. twaite shad and sea lamprey). Other species are non-aquatic so would not be 

affected directly or indirectly by the operation of a sewage treatment plant at Thurles. 

Freshwater pearl mussels recorded as a qualifying interests of the River Suir SAC 

downstream of the WwTP. This species is recorded in the River Clodiagh catchment and is 

not affected by the Thurles WwTP discharge. 



Fig1 

Bridge is delineated at the bottom left of the figure (North Tipperary COCO Licence). 

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Table 2 Qualifying Interests for the Lower River Suir SAC and their potential to occur within the study 

area. 

3.3.2.2 Conservation Obiectives for Lower River Suir cSAC 

The Conservation Management Plan for the Lower River Suir SAC is currently not available 

for consultation and is to be prepared by the National Parks and Wildlife Service (NPWS) of 

the Department of the Environment, Heritage and Local Government. 

In the absence of a completed management plan for any designated site, the conservation 

objectives are taken to include maintaining or restoring the ‘favourable conservation status’ 

(defined in the EU Habitats Directive for habitats and species) of habitats and species for 

which the site has been selected, including the habitats of the annexed species. The 

conservation objectives of the Lower River Suir SAC have been summarised in Table 3. 



European and national legislation places a collective obligation on Ireland and its citizens to 

maintain at favourable conservation status areas designated as candidate Special Areas of 

Conservation. The Government and its agencies (i.e. the NPWS, local authorities and other 

statutory bodies) are responsible for the implementation and enforcement of regulations that 

will ensure the ecological integrity of these sites. According to the EU Habitats Directive, 

favourable conservation status of a habitat is achieved when “its natural range, and area it 

covers within that range, is stable or increasing, and the ecological factors that are necessary 

for its long-term maintenance exist and are likely to continue to exist for the foreseeable 

future, and the conservation status of its typical species is favourable”. The favourable 

conservation status of a species is achieved when “population data on the species concerned 

indicate that it is maintaining itself, and the natural range of the species is neither being 

reduced or likely to be reduced for the foreseeable future, and there is, and will probably 

continue to be, a sufficiently large habitat to maintain its.populations on a long-term basis”. 

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Table 3 The conservation objectives of the Lower River Suir SAC, in relation to the qualifying interests 

of the site. 

3.3.3 River Suir catchment 

The River Suir (EPA hydrometric Area: 16) rises in the Devils Bit Mountain in North Tipperary 

and flows south and then north and enters the sea at Waterford Harbour. The Suir is normally 

referred to in the context of the “Three Sister” catchments (Barrow, Nore and Suir) which join 

together in their estuarine reaches. The combined catchment area of the ‘three sisters’ is 

more than 9,000 Km’. The Suir at 182 km long is the largest of the three sisters and has a 

catchment area of 3,610km2. The river is tidal to a point above Carrick-on-Suir and has a 

mean discharge of 47 m3/sec (Lucey, 1998). The river has a total of 34 tributaries, the largest 

of which are the Drish, Clodiagh (Tipperary), Multeen, Aherlow/Ara, Anner, Clodiagh 

(Waterford) and Blackwater (Kilmacow). 

The Suir catchment overlies limestone in the upper reaches of the catchment and at 

Newcastle it crosses Old Red Sandstone. Despite this, most of the rivers in the catchment are 

influenced by Carboniferous limestone. The purer limestone formations are extensively 

karstified, particularly south of Cashel. Such karst areas are characterised by swallow holes, 

sinking streams, caves, and large karst springs. The Suir River and the bulk of its tributaries 

exhibit relatively hard waters. This is best exemplified by the waters of the Anner subcatchment 

which are limestone streams. However, some Suir tributaries display less 

calcareous features. The Nier, for example, runs off the Silurian slates and Old Red 

sandstones of the Galtee, Knockmealdown and Comeragh Mountains and has low alkalinity 

and hardness levels (Lucey, 1998). 

As is commonly found in Ireland, the rivers of the Suir catchment have been used extensively 

for water supply, .waste disposal, fishing, agricultural, recreational and to limited extent 

navigation (Lucy, 1998). A large number of mills were built in the catchment during the 

1800’s and many of these mills continue to be operated today as small hydroelectric stations. 

Agriculture and related agri-based industries comprise one of the main activities in the 

catchment and the organic waste resulting from these has a negative impact on water quality 

in some areas. 



Most of the fish species present in Irish river catchments, such as the River Suir, have 

colonized from the sea or have been artificially introduced. Native fish species in the Suir 

catchment include the three Irish lamprey species (brook lamprey Lampetra planeri, river 

lamprey Lampetra fluviafilis, and sea lamprey Petrornyzon marinus) (Kurz & Costello, 1999), 

the Atlantic salmon Salmo salar, (O’Grady & Caffrey, 1987) and the rare Twaite Shad Alos 

fallax, (Lucey, 1998) all of which are listed under Annex II of the EU Habitats Directive. The 

European eel Anguilla anguilla, brown trout Salmo trutta, and three-spined stickleback 

Gasterosfeous aculeatus, are other common native species present in the Suir catchment, 

while introduced fish species in the catchment include northern pike €sox lucius, stone loach 

Barbatula barbafula, dace Leuciscus leuciscus, and minnow Phoxinus phoxinus (Lucey, 

1998). The smelt Osmerous eperlanus, a species listed as vulnerable in the red data list 

(Whilde, 1993), is common in the Suir estuary (King, 2002). 

The Suir River is one of Ireland’s premier game fisheries (O’Reilly, 2002). The river produced 

Ireland’s record rod caught salmon of 571bs in 1874, and is widely recognized as being the 

most important river for brown trout angling in Ireland (O’Reilly, 2002). However, despite its 

importance as a fishery, relatively little quantitative information on fish stocks in the catchment 

is available. A fisheries survey of the catchment was carried out during the period 1983 to 

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1985 by the Central Fisheries Board (Lucey, 1998). This survey showed that fish stocks in the 

Suir catchment at this time were dominated by salmonids, with salmon chiefly occupying the 

main channels and trout the tributaries. One of the conclusions of this report was that the Suir 

was of national significance in terms salmon and trout production. This report also described 

the lower Suir main channel as 'probably the single largest and most valuable trout angling 

riverine fishery in Ireland'. Important salmonid sub-catchments mentioned in the report were 

the Multeen, Aherlow, Tar, Anner and Lingaun. However, In line with many other Irish rivers, 

the quality of the Suir as a salmon fishery is reported to have diminished in recent years 

(O'Reilly, 2002). 

According to O'Connor (2006) lampreys are widely distributed in the Suir catchment, and all 

three of the Irish species occur. Sea lampreys have however only been recorded on the main 

channel of the Suir downstream of Caher, CO Tipperary. During the 2006 survey no lampreys 

were recorded at Turtulla Bridge, downstream of Thurles. Pollution and drainage maintenance 

works were suggested by O'Connor (2006) as possible reasons for their absence at this site 

and it was stated that "extensive mats of dead filamentous algae were observed at sites 

throughout the upper Suir and there is evidence of past or ongoing drainage works". 

Upstream of Thurles sites investigated at Rossestown Bridge and Knocknageragh Bridge had 

brook lampreys present, with a density of 13.43 per m2 recorded at the latter site. 

3.3.4 Receiving Water Quality 

3.3.4.1 EPA bioloqical water quality monitorinq in the River Suir 

The EPA monitors both chemical and biological water quality in the River Suir. An explanation 

of the EPA biological water quality monitoring system, the Q-rating system, is presented in 

Appendix 3. In the 2005 monitoring report (2001-2003 data, Toner et a/, 2005) the River Suir 

is rated as being 'Q3 - Moderately Polluted' at Thurles and 'Q3-4 - Slightly Polluted' at 

Holycross. Further monitoring data from 2005, presented on the EPA online 'Envision 

mapping tool', shows a decrease in water quality downstream of Thurles, with the Q3 rating in 

the town being recorded at both the Cabragh Bridge monitoring station (station no. 0900) 

downstream of the River Drish confluence and also at the Holycross monitoring station 

(station no. 1 100) downstream of the WwTP discharge. 

A summary of the overall results for the Suir catchment during the period 2004-2006 are 

presented in Table 4. In relation to nitrates in the River Suir, the EPA data shows that while 

annual average median concentrations in the River Suir have not exceeded EU Guideline 

limit values at any time the recorded maxima have exceeded this limit on several occasions in 

the 2004-2006 period. 



Table 4 Summary of biological water quality results from EPA Hydrometric Area 16 showing overall 

results for the Suir catchment (adapted from Clabby et a/, 2008). 

1 Hydrometric Area 76 (km) 1 457.5 I 142.5 I 90.0 I 1.5 I 691.5 

Table 5 presents the historical biological water quality monitoring data for the River Suir 

upstream and downstream of the Thurles WwTP for the past 20 years. 

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Table 5 Historical EPA biological water quality monitoring data in the River Suir (16S02) upstream and 

downstream of the Thurles WwTP discharge for the years 1988 to 2008. 

1 1200 1 Twoford Bridges I 3 3-4 I 3-4 I 4 

The EPA also recorded the same Q3 biological water quality status at these monitoring 

stations during the 2008 monitoring round. This unsatisfactory water quality was commented 

upon in the monitoring notes, where the polluted status of the river was observed to extend 

from Thurles town downstream to Holycross. No direct cause of the pollution at this stretch of 

the river was referred to in the monitoring report (Neill, 2009). 

Overall the EPA biological monitoring data indicates that the town of Thurles is having a direct 

negative impact on the water quality of the River Suir with a rating of Q4 recorded by the EPA 

upstream of the town in 2008 (Rossestown Bridge Station 0500) and also a Q4 rating 

recorded Twofords Bridge (Station 1200) ca. 6 river kilometres downstream of the WwTP 

discharge. A rating of Q4 was also recorded in the River Drish during 2008, directly upstream 

of its confluence with the River Suir. 

The discharge from the WwTP at Cabragh Bridge cannot be defined as causing a direct 

impact on the river at the discharge point as there is no further deterioration in water quality 

between Thurles town and the downstream monitoring station at Holycross. However, there is 

additional dilution in the river from the Drish tributary without an associated increase in 

biological water quality indicating a continuation in pollution above the assimilation capacity of 

the watercourse. Furthermore storm water discharges to the river associated with the 



combined sewerage network could potentially result in impacts on biological water quality 

within Thurles town, affecting both the assimilation, capacity of the river and the aquatic 

ecological communities downstream of Thurles. 

3.3.4.2 EPA chemical water auality monitorinq in the River Suir 

The EPA carries out chemical water quality monitoring in the River Suir, with a number of 

samples taken in a given year. The chemical water quality monitoring data for the EPA 

stations upstream and downstream of the Thurles WwTP are presented in Tables 6 and 7 

below. 

Table 6 EPA chemical monitoring data for 2008 at the Cabragh Bridge (Station 0900), upstream of the 

Thurles WwTP discharge point. Elevated parameters are highlighted in bold. 

*The Orthophosphate result of 04.02.08 has been identified as being elevated, as this sample was 

unlikely to have been taken below 95%ile flows in February, thus breaching good status requirements. 

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Table 7 EPA chemical monitoring data for 2008 at the Holycross Bridge (Station 1 IOO), downstream of 

the Thurles WwTP discharge point. Elevated parameters are highlighted in bold. 

3.3.4.3 North Tipperarv Countv Council chemical water quality monitorinq data 

North Tipperary County Council carry out regular chemical water quality monitoring of the 

receiving water i.e. the River Suir, upstream and downstream of the discharge point at the 

Thurles WwTP. The treated effluent from the Thurles WwTP is also subject to regular 

monitoring by the County Council. A summary of the results of the 2009 sampling exercise 

are presented in Tables 8 and 9 below. This data provides the most up to date results for 

water quality in the River Suir upstream and downstream of the Thurles WwTP, as significant 

changes have been put in place in the form of upgrades and effluent loading at the treatment 

plant over the period 2008 to 2009.From the upstream and downstream data in Table 8 it can 

be seen that the downstream monitoring station records mean values that are below the 

mean upstream values for a number of parameters including: BOD, Nitrates, Total 

Phosphorous and Total Oxidised Nitrogen. Other parameters including Temperature, 

Suspended Solids and Sulphates also display this discrepancy in the monitoring data. The 

detailed water quality monitoring results from the North Tipperary sampling data at Thurles 

WwTP is presented in Appendix 4. 

At the time of finalising the current report, the data presented in Table 10 was supplied by 

North Tipperary County Council. This shows the discharge from the plant being complaint 

with the requirements of the Urban wastewater treatment Directive for sensitive catchments in 

terms if orthophosphate. This is also the case for all other parameters (see Appendix 4). The 

River Suir upstream and downstream of the plant is also Compliant with "Good Status" 

Standard as per EC Environmental Objectives (Surface Water) Regulations 2009. 

Table 8 North Tipperary Co. Co. water quality monitoring data for the River Suir. Mean upstream and 

downstream values for the Thurles WwTP during the period January to August 2009. The % change in 

the values for each parameter between the sites is also given. 



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Table 9 Summary of North Tipperary Co. Co. water quality monitoring data for the treated effluent 

emission from the Thurles WwTP during the period January to August 2009. 

Table 10 Summary of North Tipperary Co. Co. water quality monitoring data for the treated effluent 

emission and River Suir upstream and downstream of the Thurles WwTP during the period January to 

September 2009. The mean discharge level is Compliant with UWW Regs. The River Suir upstream and 

downstream of the plant are Compliant with "Good Status" Standard as per EC Env. Objectives (Surface 

Water) Regulations 2009. 

Thurles STP upstream 

Average 

Thurles STP downstream 



24/09/2009 0.02 AR 

10 0.03 

15/01/2009 0.04 0.1 

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3.3.5 Assimilation capacities 

Please note that the current assimilation capacity assessment was prepared based on an 

estimate of the flow from the plant (back calculated from mg/l and kg/day figures supplied in 

the discharge licence. The actual flow from the plant may be less than the figure used. The 

models were also prepared using background data for the River Suir from Neil (1999), which 

included only three observations. Thus is insufficient data so the results need to be 

interpreted with caution. In particular the reader should consider the results presented in 

Table 10, which were supplied after the following assessment had been completed. It is 

recommended that updated assimilation capacity assessment be prepared when more data is 

available as a result of monitoring the newly upgraded plant. 

The primary regulatory guideline for effluent standards is the EU Urban Wastewater 

Treatment Regulations, 2001 which is implemented in Ireland through S.I. 254 of 2001 and 

the Water Quality Standards for Phosphorus (S.I. 258 of 1998) and the European 

Communities Environmental Objectives (Surface Waters) Regulations 2009 (SI 272 of 2009). 

The Urban Wastewater Treatment Regulations requires the provision of secondary treatment 

for all discharges to freshwaters and estuaries from towns with a population equivalent of 

between 2,000 and 10,000. While the requirements of the Urban Wastewater Treatment 

Regulations are set, water quality requirements are dependent on the background values and 

flow in the river (i.e. assimilation capacity). A worked example for BOD assimilation capacity 

is provided as follows. The BOD Waste Assimilation Capacity (WAC) is defined as: 



WAC = (Cmax- Cback)X Fg5 X 86.4 kg BOD/day 

Where: Cmax = maximum permissible BOD concentration 

Cback = background (upstream) BOD concentration 

Fg5 = 95 percentile flow (m3/s) 

86.4 = conversion factor 

The Waste Assimilation Capacity of the River Suir at Thurles is assessed for the parameters 

Biological Oxygen Demand (BOD) and orthophosphate. These parameters were assessed 

due to their key importance in biological systems, particularly in relation to eutrophication. The 

standards applied in the current case are those given in the European Communities 

Environmental Objectives (Surface Waters) Regulations 2009 (SI 272 of 2009). This is a 

preliminary WAC assessment only carried out as part of the current screening assessment. 

The catchment area of the River Suir at Thurles is 228.8 km2 while the catchment area at 

Cabragh Bridge is 442.6 km2. The mean flow of the River Suir at Thurles (station No. 16004) 

is 3.02m3/s and the 95%ile flow is 0.36 m3/s. By extrapolation, the mean flow of the River Suir 

at Cabragh Bridge was found to be 4.63 m3/s and the 95%ile flow was 0.55 m3/s. The rate of 

discharge from the plant, as provided by North Tipperary Co. Co. is 7,308 m3/day. This rate of 

discharge was used to derive the rate of discharge of BOD and Ortho-phosphate from the 

plant using the average values of these parameters in the effluent between January and 

August 2009 (N=9). The calculated rate of BOD discharged to the river is 38.9kgIday. 

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The mean background BOD concentration is based on results from Neil (2009) between 

February and July 2008 (N=3). The BOD input from the plant (kglday) is the product of the 

flow (7,308 m3/day) and the mean BOD concentration between January and August 2009 

(5.333 mg/l). Table 10 presents the results of the preliminary BOD waste assimilation capacity 

assessment. This probably overestimates the situation and will need to be updated when 

more data is available in the future. 

Even with this model however, there is WAC in the River Suir at the discharge point for BOD 

under a suite of different circumstances. The addition of 38.9 kg BOD/day as a result of the 

operation of the plant (amount derived from mean concentrations of BOD in the effluent 

between January and August 2009 and derived flow from plant) does not result in the river 

being overloaded with BOD downstream of the discharge point. Indeed, there is compliance 

with even the strict mean flow High WFD status of 1.3 mg BODll where 29% of the available 

WAC for this parameter is used by the discharge. The mean background Ortho-phosphate 

concentration is based on results from Neil (2009) between February and July 2008 (N=3 

only). The Ortho-phosphate input from the plant (kglday) is the product of the flow (7,308 

m3/day) and the mean Ortho-phosphate concentration between January and August 2009 

(1.491 mg/l). The results of the Orthophosphate WAC are presented in Table 12 (Neil1 

background) and table 13 (for a hypothetical situation where there was no background levels 

of this parameter). These models probably overestimate the contribution from the plant and 

three data points is insufficient to base these analyses on. These models will need to be 

updated when more data is available in the future. 

Table I1 Waste Assimilation Capacity (WAC) of the River Suir at Thurles in terms of Biological Oxygen 

Demand (BOD) and WAC usage by the WwTP. Based on an adjusted mean flow of 4.63 m3/s and a 

95%ile flow of 0.55 m3/s at Cabragh Bridge. 

BOD usage by plant (%) 

Result 

I 

29 I 18 66 50 

Compliant I Compliant Compliant Compliant 



Table 12 Waste Assimilation Capacity (WAC) of the River Suir at Thurles in terms of Ortho-phosphate 

as P and WAC usage by the WwTP. Based on an adjusted mean flow of 4.63 m3/s and a 95%11e flow of 

0.55 m3/s at Cabragh Bridge. The mean background Ortho-phosphate concentration is based on results 

from Neil (2009) between February and July 2008 (N=3) as there were no Ortho-phosphate as P results 

given. The Ortho-phosphate as P input from the plant (kg/day) is the product of the flow (7 305 m3/day) 

and the mean Ortho-phosphate as P concentration between January and August 2009 (0 488 mg/l). 

1 cornpliant 1 compliant 1 compliant 1 compliant 1 compliant 

WfD GS=Good status, WfD HS=High status, from the European Communities Environmental 

Objectives (Surface Waters) Regulations-2009 (SI 272 of 2009). 

PR = Phosphorous Regulations (0.03 = Q4 = satisfactory water quality from €PA, 2001) or Local 

Government (Water Pollution) Act, 1977(Water Quality Standards for Phosphorous) Regulations, 1978 

(S.I. No. 258 of 1998). 

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Table 13 Waste Assimilation Capacity (WAC) of the River Suir at Thurles in terms of Ortho-phosphate 

as P and WAC usage by the WwTP. Based on an adjusted mean flow of 4.63 m3/s and a 95%ile flow of 

0.55 m3/s at Cabragh Bridge. Zero background levels of Ortho-phosphate have been assumed to show 

the effect of the discharge on WAC in isolation of other environmental constraints. The Ortho-phosphate 

as P input from the plant (kg/day) is the product of the flow (7.305 m3/day) and the mean Ortho- 

phosphate as P concentration between January and August 2009 (0.488 mg/l). 

WFD GS=Good status, WFD HS=High status, from the European Communities Environmental 

Objectives (Surface Waters) Regulations 2009 (SI 272 of 2009). PR = Phosphorous Regulations (0.03 = 

Q4 = satisfactory water quality from €PA, 2001) or Local Government (Water Pollution) Act, 1977(Water 

Quality Standards for Phosphorous) Regulations, 1978 (S.I. No. 258 of 1998). 

3.4 Description of effects and potential effects 

This section provides a screening exercise to establish the likelihood of the effects and 

potential effects of the existing Thurles WwTP plant on the Lower River Suir being significant. 

According to the EPA (2008), a discharge from a WwTP would be considered to have a 

significant adverse effect on the receiving waters if it were to:- 

* 

0 

Cause a deterioration in the chemical status or ecological status (or ecological 

potential as the case may be) in the receiving body of surface water; 

Cause a deterioration in the chemical status in the receiving body of groundwater; 

Cause the input into groundwater of hazardous substances, except where it is 

established that the input concerned is in a quantity and concentration so small as to 

obviate any present or future danger of deterioration in the quality of the receiving 

groundwater; 

Cause deterioration or result in significant and sustained upward trends in the 

concentrations of pollutants in groundwater in the case of pollutants that are not 

hazardous; 

Permanently exclude or compromise the achievement of the objectives established 

for protected species and natural habitats in the case of European sites where the 

maintenance or improvement of the status of water is an important factor in their 

protection or which is inconsistent with the achievement of environmental quality 

standards established under national Regulations in relation to designated bathing 

waters, designated shellfish waters, areas designated for the protection of freshwater 

fish and designated nutrient sensitive areas. 

3.4.1 Direct impacts 



The existing and proposed discharges from the Thurles WwTP are directly into the Lower 

River Suir Special Area of Conservation’ (site code 002137). Furthermore the storm water 

overflow and pumping station emergency overflows for Thurles town also discharge into the 

River Suir upstream of the Therefore there would be the potential for direct effects on the 

designated site as a result of the operation of the WwTP. 

The current biological water quality monitoring data from the EPA shows a decrease in water 

quality from Q4 upstream of Thurles town, to a consistent Q3 rating in Thurles town, 

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downstream to Holycross Bridge. Downstream of Holycross Bridge the next EPA monitoring 

station at Twoford Bridges shows an increase to Q4 i.e. a ‘Good Status’ rating. 

The Q3 rating in Thurles town cannot be directly associated with impacts arising from the 

storm water outfall and emergency overflow of the combined network in the town. However, 

the Q3 rating downstream of the River Drish confluence at Cabragh Bridge and also at 

Holycross Bridge indicates that there are inputs to the river between Thurles town and 

Holycross Bridge which affect biological water quality over and above the dilution capacity 

contributed by the River Drish tributary. 

The EPA chemical water quality monitoring data for 2008 does indicate that a number of 

important water quality parameters were found to be increased downstream of the Thurles 

WwTP, where monitoring was carried out at Holycross Bridge, downstream of the discharge. 

From the EPA data Orthophosphate, BOD, Ammonia and Un-ionised Ammonia were found to 

be elevated downstream at the Holycross monitoring station, when compared to the Cabragh 

Bridge monitoring station, upstream of the WwTP discharge. However, it must be noted that 

the EPA biological water quality monitoring data does not account for the most recent 

improvements and upgrades to the Thurles WwTP that were undertaken in late 2008. Long 

term monitoring data will be required to establish the benefits of these upgrades. Furthermore 

the improvement in effluent discharge from the Dew Valley plant to the Thurles WwTP will 

reduce the loading on the plant by ca. 6, 000 PE. However, it will take time to identify the 

positive or negative impacts on the treatment of this waste on the River Suir receiving water, 

the cumulative impact of which must be accounted for in relation to the conservation interests 

of the designated site. 

When the North Tipperary County Council water quality monitoring data is examined it can be 

seen that on occasion the results from downstream of the WwTP discharge are significantly 

better that the upstream monitoring results. The frequency of this occurrence and the overall 

percentage difference highlights a potential issue with the sampling methodology at the 

Thurles WwTP. It is accepted that there are some p[practical issues due to the presence of 

other nearby discharges. The sampling programme would however benefit from review. 

The WAC modelling indicates that there is a potential impact to the river with respect to 

Orthophosphates. This is directly related to the high background concentration of 

Orthophosphate in the River Suir upstream of the discharge point. However, the most recent 

data provided by the council (see Table 10) suggests that there is compliance both upstream 

and downstream of the plant. It is clear that a new assimilation capacity assessment will have 

to be completed when more data is available. 

3.4.2 Indirect impacts 

Indirect (or secondary) impacts are defined as effects that are “caused by and result from the 

activity although they are later in time or further removed in distance, but still reasonably 

foreseeable” (Bowers-Marriott, 1997). 

There are no indirect impacts from the WwTP at Thurles that may be impacting on the River 

Suir SAC. Impacts to the receiving water i.e. the SAC are limited to the direct impact of the 

treated wastewater discharge and storm overflow dishcharges associated with the network. 

3.4.3 Cumulative impacts 



Cumulative impacts or effects are changes in the environment that result from numerous 

human-induced, small-scale alterations. Cumulative impacts can be thought of as occurring 

through two main pathways: first, through persistent additions or losses of the same materials 

or resource, and second, through the compounding effects as a result of the coming together 

of two or more effects (Bowers-Marriott, 1997). 

Meat processing plant (Dew Valley Meats) accounted for ca. 33% of the Thurles WwTP 

capacity, this has now been decreased as the industrial plant now provides effluent treatment 

on site and discharges treated effluent to the Thurles WwTP. 

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The EPA biological and chemical monitoring data for the River Suir upstream and 

downstream of Thurles town for 2008 do not reflect the change in effluent treatment effected 

by the cumulative impact of improvementshpgrades to the wwTP and the further 

improvements at the Dew Valley Plant in the town. 

However, the North Tipperary County Council monitoring data for 2009 reflects the current 

situation with a significant reduction in BOD loading (in the order of 60%) from the Dew Valley 

plant and upgrades at the Thurles plant resulting in improvements in discharge from the 

Thurles WwTP. 

3.5 Significance of effects 

From the North Tipperary County Council monitoring data it can be seen that there has been 

a significant improvement in Phosphate levels at the downstream monitoring station, when 

compared to historical monitoring data. This has come about as a result of the upgrading 

completed at the plant which includes Phosphate reduction. The plant is operating well within 

the requirements of the provision of the UWD provision for discharges into sensitive 

catchments. There has also been a decrease in the loadings to the plant. It is clear however 

that all the data required to make the current assessment is not available at present. New 

updated assimilation capacity assessments will be required. The assessment would also 

benefit from a field visit by an ecologist and an upstream and downstream biological 

assessment. 

Despite the improvements in Orthophosphate treatment during 2008/2009, the preliminary 

WAC models for the current screening assessment found that the River Suir at the discharge 

point has limited assimilation capacity for Orthophosphates. This is because of elevated 

background levels. However, the most recent data supplied by the council shows compliance 

both upstream and downstream of the plant with WFD Good status. This will require further 

study and clarification. 

In addition to the discharge from the Thurles WwTP there are further storm water outfalls and 

emergency overflows associated with the combined network in Thurles town which may 

contribute to poor water quality recorded in the town (from EPA monitoring data upstream of 

the WwTP discharge). It is suggested that a further detailed study is carried out to assess the 

overall impact of the sewerage network and water quality management in terms of existing 

emissions from the main drainage network and in-combinations effects. 



Actions should be undertaken in consultation with EPA (through its discharge licensing 

process) to address and reduce background phosphate concentrations in the River Suir 

upstream of the waste water treatment plant. These actions should aim to ensure 

achievement of Good Status of the river within the required timeframe of the WFD. In this 

regard, the position may be helped by new waste water treatment plant which is under 

construction in Templemore (upstream of Thurles). This plant will be commissioned in the 

new few months and it includes phosphate reduction facilities. 

Consultation with the NPWS and EPA is now recommended at this time to assess the need to 

proceed to Stage 2 of the Appropriate Assessment process. 

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REFERENCES 

General references 

Armitage, P. D.; Moss, D.; Wright, J. F. and Furse, M. T. (1983) The performance of a new 

biological water quality score system based on macroinvertebrates over a wide range of 

unpolluted running-water sites. Water Res., 17 (3), 333-347. 

Barbour, M.T. and J.B. Stribling. 1991. Use of Habitat Assessment in Evaluating the 

Biological Integrity of StreamCommunities. Biological Criteria: Research and Regulation: 25- 

38. EPA-44015-91-005. Washington, DC: Office of Water, US EPA 

Bowers Marriott, B. (1 997) Practical Guide to Environmental Impact Assessment: A Practical 

Guide. Published by McGraw-Hill Professional, 1997, 320 pp. 

Chandler, J.R. (1970) A Biological Approach to water Quality Management. Water Poll. Cont. 

69:4 1 5-42 1. 

Clabby, K.J., Bradley, C., Craig, M., Daly, D., Lucey, J., McGarrigle, M., O’Boyle, S., Tierney, 

D. and Bowman, J., (2008). Water Quality in Ireland 2004 - 2006. Environmental Protection 

Agency, Johnstown Castle, Co. Wexford, Ireland 

Curtis, T.G.F. & McGough, H.N. (1988) 1 Vascular plants. The Irish Red Data Book. The 

Stationery Office, Dublin. 

Colhoun, K. (2001). Irish Wetland Bird Survey 1998-99. Birdwatch Ireland, Dublin. 

Curtis, T. G. F. and McGough, H. N. (1988). The Irish Red Data Book. ,l. Vascular 

plants. The Stationery Office, Dublin. 

CFB (1993) Game Angling. Central Fisheries Board Irish Angling Guides. Gill and MacMillan. 

EPA (2001) Parameters of Water Quality - Interpretation and Standards. Environmental 

Protection Agency, Ireland. 

European Commission (1999) Interpretation manual of European Union Habitats Eur 1512. 

EC DG Environment, Brussels 

Flora (Protection) Order 1999. Statutory Instrument No. 94 of 1999. The Stationery 

Office, Dublin. 



Fossitt, J. (2000) A guide to habitats in Ireland. The Heritage Council, Kilkenny. 

Hayden and Harrington (2000) Exploring Irish Mammals. Duchas The Heritage Service. 

Lucy, J. (1998) The Barrow, The Nore and The Suir. In: Studies of Irish Rivers and lakes Ed. 

Christopher Moriarty. Essays on the occasion of the XXVll Congress of Societas 

Internationalis Limnologias (SIL). Marine Institute. Dublin. 

Lucey, J., 2007. Water Quality in Ireland 2006 - Key Indicators of the Aquatic Environment. 

EPA, Wexford 

MacCarthaigh (1997) Hydrological data. A listing of water recorders and summary statistics at 

selected gauging stations. Environmental Protection Agency, Ireland. 

McGarrigle, M.L., Bowman, J.J., Clabby, K.J., Lucy, P., Cunningham, M.,MacCarthaigh, M., 

Keegan, M., Cantrell, B., Lehane, M., Clenaghan, C., Toner, P.F. (2002) Water Quality in 

Ireland 1998-2000. Second (Revised) Edition. Environmental Protection Agency. 

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Neill, M. (2009). River water quality in Southeast Ireland, 2008. EPA Regional Water 

laboratory, Kilkenny 

Nelson, B., & Thompson, R., (2004) The Natural History of lrelands Dragonflies. Ulster 

Museum. 454pp. 

NRA (2004) Environmental Impact Assessment of National Road Schemes - A Practical 

Guide, National Roads Authority, Dublin 

O’Reilly, P. (2004) Rivers of Ireland - a flyfisher’s Guide. 5‘h Ed. Merlin Unwin Books, 

Preston, C. D., Pearman, D. A. and Dines, T. D., eds (2002). New Atlas of the British and lrish 

Flora. Oxford University Press, Oxford 

Rabenil, C.F.,, Doisy, K.E. and Zweig, L.D. (2005) Stream invertebrate community functional 

responses to deposited sediment Journal of Aquatic Sciences. 67(4):395-402. 

Toner, P., Bowman, K., Clabby, K., Lucey, J., McGarrigle, M, Concannon, C., Clenaghan, C., 

Cunningham, P., Delaney, J., O’Boyle, S., MaCarthaigh, M., Craig, M., and Quinn, R. 2005. 

Water Quality in Ireland 2001 -2003. Environmental Protection Agency, Wexford. 

Whilde, A. (1993) Threatened mammals, birds, amphibians and fish in Ireland. Irish red data 

book 2: vertebrates. Belfast: HMSO. 

Walley W.J. and Hawkes H.A. (1997) A computer-based development of the Biological 

Monitoring Working Party score system incorporating abundance rating, biotope type and 

indicator value. Water Research, 31 (2), 201 -21 0. 

Woodiwiss, F. (1960) Trent Biotic Index of Pollution. Second Quinquennial Abstract of 

Statistics Relating to the Trent Watershed. Trent River Authority. England. 

Information sources on protected species 

King, J.J. (2006) The status and distribution of lamprey in the River Barrow SAC. lrish Wildlife 

Manuals No. 21. National Parks and Wildlife Service, Department of Environment, Heritage 

and Local Government, Dublin, Ireland. 



Kelly & King (2001) A review of the ecology and distribution of three lamprey species, 

Lampetra fluviatilis (L.), Lampetra planeri (Bloch), and Petromyzon marinus (L.): A context for 

conservation and biodiversity considerations in Ireland. Biology and the Environment. 

101B(3):165-185. 

Kurz, I. and Costello, M. J. (1999). An outline of the biology, distribution and conservation of 

lampreys in Ireland. lrish Wildlife Manuals No. 5. Duchas, the Heritage Service, Dublin. 

Lucey, J., and McGarrigle, M.L.( 1987) The distribution of the crayfish Austropotamobius 

pallipes (Lereboullet) in Ireland. lrish Fisheries lnvestigations Series A (29): 1-1 3. 

Moorkens, E. A. (1999). Conservation management of the freshwater pearl mussel 

Margaritifera margaritifera. Part 1: Biology of the species and its present situation in Ireland. 

lrish Wildlife Manuals No. 8. Duchas, the Heritage Service, Dublin. 

O’Connor, W. (2006) A Survey of Juvenile Lamprey Populations in the Corrib and Suir 

Catchments. lrish Wildlife Manuals. National Parks and Wildlife Service, Department of 

Environment, Heritage and Local Government, Dublin, Ireland. 

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APPENDIX 1 NPWS Site Synopsis 

SITE NAME : LOWER RIVER SUlR SAC 

SITE CODE : 002137 

This site consists of the freshwater stretches of the River Suir immediately south of Thurles, 

the tidal stretches as far as the confluence with the BarrowINore immediately east of 

Cheekpoint in Co. Waterford and many tributaries including the Clodiagh in Co. Waterford, 

the Lingaun, Anner, Nier, Tar, Aherlow, Multeen and Clodiagh in Co. Tipperary. The Suir and 

its tributaries flows through the counties of Tipperary, Kilkenny and Waterford. Upstream of 

Waterford city, the swinging meanders of the Suir crisscross the Devonian sandstone rim of 

hard rocks no less than three times as they leave the limestone-floored downfold below 

Carrick In the vicinity of Carrick-on-Suir the river follows the limestone floor of the Carrick 

Syncline. Upstream of Clonmel the river and its tributaries traverse 

Upper Palaeozoic Rocks, mainly the Lower Carboniferous Visean and Tournaisian. The 

freshwater stretches of the Clodiagh River in Co. Waterford traverse Silurian rocks, through 

narrow bands of Old Red Sandstone and Lower Avonian Shales before reaching the 

carboniferous limestone close to its confluence with the Suir. 

The Aherlow River flows through a Carboniferous limestone valley, with outcrops of Old Red 

Sandstone forming the Galtee Mountains to the south and the Slievenamuck range to the 

north. Glacial deposits of sands and gravels are common along the valley bottom, flanking the 

present-day river course. 

The site is a candidate SAC selected for the presence of the priority habitats on Annex I of the 

E.U. Habitats Directive - alluvial wet woodlands and Yew Wood. The site is also selected as a 

candidate SAC for floating river vegetation, Atlantic salt meadows, Mediterranean salt 

meadows, old oak woodlands and eutrophic tall herbs, all habitats listed on Annex I of the 

E.U. Habitats Directive. The site is also selected for the following species listed on Annex II of 

the same directive - Sea Lamprey, River Lamprey, Brook Lamprey, Freshwater Pearl Mussel, 

Crayfish, Twaite Shad, Atlantic Salmon and Otter. 

Alluvial wet woodland is declining habitat in Europe as a result of drainage and reclamation. 

The best examples of this type of woodland in the site are found on the islands just below 

Carrick-on-Suir and at Fiddown Island. Species occurring here include Almond Willow (Salix 

triandra), White Willow (S. alba), Grey Willow (S. cinerea), Osier (S. viminalis), with Iris (Iris 

pseudacorus), Hemlock Water-dropwort (Oenanfhe crocata), Angelica (Angelica sylvestris), 

Pendulus Sedge (Carex pendula), Meadowsweet (Filipendula ulmaria) and Valerian 

(Valeriana officinalis). The terrain is littered with dead trunks and branches and intersected 

with small channels which carry small streams to the river. The bryophyte and lichen floras 

appear to be rich and require further investigation. A small plot is currently being coppiced 

and managed by National Parks and Wildlife. 



In the drier areas the wet woodland species merge with other tree and shrub species 

including Ash (Fraxinus excelsior), Hazel (Corylus avellana), Hawthorn (Crafaegus 

monogyna) and Blackthorn (Prunus spinosa). This adds further to the ecological interest of 

this site. Eutrophic tall herb vegetation occurs in association with the various areas of alluvial 

forest and elsewhere where the flood-plain of the river is intact. Characteristic species of the 

habitat include Meadowsweet (Filipendula ulmaria), Purple Loosestrife (Lyfhrurn salicaria), 

Marsh Ragwort (Senecio aquaticus), Ground Ivy (Glechoma hederacea) and Hedge 

Bindweed (Calystegia sepiurn). Old oak woodlands are also of importance at the site. The 

best examples are seen in Portlaw Wood which lies on both sides of the Clodiagh River. On 

the south-facing side the stand is more open and the Oaks (mainly Quercus robur) are well 

grown and spreading. Ivy (Hedera helix) and Bramble (Rubus fruficosus) are common on the 

ground, indicating relatively high light conditions. Oak regeneration is dense, varying in age 

from 0-40 years and Holly (Ilex aquifolium) is fairly common but mostly quite young. 

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.......................................................................................................................................... 

Across the valley, by contrast, the trees are much more closely spaced and though taller are 

poorly grown on average. There are no clearings; large Oaks extend to the boundary wall. In 

the darker conditions, Ivy is much rarer and Holly much more frequent, forming a closed 

canopy in places. Oak regeneration is uncommon since there are as yet few natural clearings. 

The shallowness of the soil on the north-facing slope probably contributes to the poor tree 

growth there. The acid nature of the substrate has induced a “mountain” type Oakwood 

community to develop. There is an extensive species list present throughout including an 

abundance of mosses, liveworts and lichens. The rare lichen Lobaria pulmonaria, an 

indicator of ancient woodlands, is found. 

lnchinsquillib Wood consists of three small separate sloping blocks of woodland in a valley cut 

by the young Multeen River and its tributaries through acidic Old Red Sandstone, and Silurian 

rocks. Two blocks, both with an eastern aspect, located to the north of the road, are 

predominantly of Sessile oak (Quercus petraea) and Hazel, with Downy Birch (Betula 

pubescens), Ash and Holly. The ground flora is quite mixed with for example Wood sedge 

(Carex sylvatica), Bluebell (Hyacinthoides non-scriptus), Primrose (Primula vulgaris), Wood- 

sorrel (Oxalis acetosella), Pignut (Conopodium majus) and Hard fern (Blechnum spicant). The 

base poor nature of the underlying rock is, to some extent masked by the overlying drift. The 

third block, to the south of the road, and with a northern aspect, is a similar although less 

mature mixture of Sessile Oak, Birch and Holly, the influence of the drift is more marked, with 

the occurrence of Wood anemone (Anemone nemorosa) amongst the ground flora. 

Floating river vegetation is evident in the freshwater stretches of the River Suir and along 

many of its tributaries. Typical species found include Canadian Pondweed (Elodea 

canadensis), Milfoil (Myriophyllum spp.), Fennel Pondweed (Potamogeton pectinatus), Curled 

Pondweed (P. crispus), Perfoliate Pondweed (P. perfoliatus), Pond Water-crowfoot 

(Ranunculus peltatus), other Crowfoots (Ranunculus spp.) and the moss Fontinalis 

antipyretica. At a couple of locations along the river, Oppositeleaved Pondweed (Groenlandia 

densa) occurs. This species is protected under the Flora (Protection) Order, 1999. 

The Aherlow River is fast-flowing and mostly follows a natural unmodified river channel. 

Submerged vegetation includes the aquatic moss Fontinalis antipyretica and Stream Water- 

crowfoot (Ranunculus pencillatus), while shallow areas support species such as Reed 

Canary-grass (Phalaris arundinacea), Brooklime (Veronica beccabunga) and Water Mint 

(Mentha aquatica). The river bank is fringed in places with Alder (Alnus glutinosa) and 

Willows (Salix spp.). 



The Multeen River is fast flowing, mostly gravel-bottomed and appears to follow a natural 

unmodified river channel. Water Crowfoots occur in abundance and the aquatic moss 

Fontinalis antipyretica is also common. In sheltered shallows, species such as Water-cress 

(Rorippa nasturtium-aquaticum) and Water-staworts (Callitriche spp.) occur. The river 

channel is fringed for most of its length with Alder, Willow and a narrow strip of marshy 

vegetation. 

Salt meadows occur below Waterford City in old meadows where the embankment is absent, 

or has been breached, and along the tidal stretches of some of the in-flowing rivers below 

Little Island. There are very narrow, non-continuous bands of this habitat along both banks. 

More extensive areas are also seen along the south bank at Ballynakill, the east side of Little 

Island, and in three large salt meadows between Ballynakill and Cheekpoint. The Atlantic and 

Mediterranean sub types are generally intermixed. The species list is extensive and includes 

Red Fescue (Festuca rubra), Oraches (Atriplex spp.), Sea Aster (Aster tripolium), Sea Couch 

Grass (Elymus pycnanthus), frequent Sea Milkwort (Glaux maritima), occasional Wild Celery 

(Apium graveolens), Parsley Water-dropwort (Oenanthe lachenah), English Scurvygrass 

(Cochlearia anglica) and Sea Arrowgrass ( Triglochin maritima). These species are more 

representative of the Atlantic sub-type of the habitat. Common Cord-grass (Sparfina anglica), 

is rather frequent along the main channel edge and up the internal channels. The legally 

protected (Flora (Protection) Order, 1999) Meadow Barley (Hordeum secalinum) grows at the 

landward transition of the saltmarsh. Sea Rush (Juncus maritimus), an indicator of the 

Mediterranean salt meadows, also occurs. 

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--


Other habitats at the site include wet and dry grassland, marsh, reed swamp, improved 

grassland, coniferous plantations, deciduous woodland, scrub, tidal river, stony shore and 

mudflats. The most dominant habitat adjoining the river is improved grassland, although there 

are wet fields with species such as Yellow Flag (Iris pseudacorus), Meadow Sweet 

(Filipendula ulmaria), Rushes (Juncus spp.), Meadow Buttercup (Ranunculus acris) and 

Cuckoo Flower (Cardamine prafensis). Cabragh marshes, just below Thurles, lie in a low- 

lying tributary valley into which the main river floods in winter. Here there is an extensive area 

of Common Reed (Phragmifes australis) with associated marshland and peaty fen. The 

transition between vegetation types is often well displayed. A number of wetland plants of 

interest occur, in particular the Narrow-leaved Bulrush (Typha angustifolia), Bottle Sedge 

(Carex rosfrafa) and Blunt-flowered Rush (Juncus subnodulosus). The marsh is naturally 

eutrophic but it has also the nutritional legacy of the former sugar factory which discharged 

into it through a number of holding lagoons, now removed. Production is high which is seen in 

the size of such species as Celery-leaved Buttercup (Ranunculus scelerafus) as well as in the 

reeds themselves. 

Throughout the Lower River Suir site are small areas of woodland other than those described 

above. These tend to be a mixture of native and non-native species, although there are some 

areas of semi-natural wet woodland with species such as Ash and Willow. Cahir Park 

Woodlands is a narrow tract of mixed deciduous woodland lying on the flatlying floodplain of 

the River Suir. This estate woodland was planted over one hundred years ago and it contains 

a large component of exotic tree species. However, due to original planting and natural 

regeneration there is now a good mix of native and exotic species. About 5km north west of 

Cashel, Ardmayle pond is a long, possibly artificial water body running parallel to the River 

Suir. It is partly shaded by planted Lime (Tilia hybrids), Sycamore (Acer pseudoplatanus) and 

the native Alder. Growing beneath the trees are shade tolerant species such as Remote 

sedge (Carex remota). The site is of particular conservation interest for the presence of a 

number of Annex II animal species, including Freshwater Pearl Mussel ( Margaritifera 

margaritifera and M. m. durrovensis), Freshwater Crayfish (Austropofamobius pallipes), 

Salmon (Salmo salar), Twaite Shad (Alosa fallax fallax), three species of Lampreys - Sea 

Lamprey (Pefromyzon marinus), Brook Lamprey (Lampetra planer/) and River Lamprey 

(Lampetra fluviatilis) and Otter (Lutra lutra). This is one of only three known spawning 

grounds in the country for Twaite Shad. 

The site also supports populations of several other animal species. Those which are listed in 

the Irish Red Data Book include Daubenton's Bat (Myotis daubentono, Nattererer's Bat (M, 

natterer/), Pipistrelle (Pipistrellus pipistrellus), Pine Marten (Marfes marfes), Badger (Meles 

meles), the Irish Hare (Lepus timidus hibernicus), Smelt (Osmerus eperlanus) and the Frog 

(Rana temporaria). Breeding stocks of Carp are found in Kilsheelan Lake. This is one of only 

two lakes in the country which is known to have supported breeding Carp. Carp require 

unusually high summer water temperatures to breed in Ireland and the site may therefore 

support interesting invertebrate populations. 



Parts of the site have also been identified as of ornithological importance for a number of 

Annex I (EU Birds Directive) bird species, including Greenland White-fronted Goose (IO), 

Golden Plover (1490), Whooper Swan (7) and Kingfisher. Figures given in brackets are the 

average maximum counts from 4 count areas within the site for the three winters between 

1994 and 1997. Wintering populations of migratory birds use the site. Flocks are seen in 

Coolfinn Marsh and also along the reedbeds and saltmarsh areas of the Suir. Coolfinn 

supports nationally important numbers of Greylag Geese on a regular basis. Numbers 

between 600 and 700 are recorded. Other species occurring include Mallard (21), Teal (159), 

Wigeon (26), Tufted Duck (60), Pintail (4), Pochard (2), Little Grebe (2), Black-tailed Godwit 

(20), Oystercatcher (16), Lapwing (993), Dunlin (lOl), Curlew (195), Redshank (28), 

Greenshank (4) and Green Sandpiper (1). Nationally important numbers of Lapwing (2750) 

were recorded at Faithlegg in the winter of 1996/97. In Cabragh marshes there is abundant 

food for surface feeding wildfowl which total at 1,000 or so in winter. Widgeon, Teal and 

Mallard are numerous and the latter has a large breeding population - with up to 400 in 

summer. In addition, less frequent species like Shoveler and Pintail occur and there are 

records for both Whooper and Bewick's swans. Kingfisher, a species that is listed on Annex I 

of the EU Birds Directive, occurs along some of the many tributaries throughout the site. 

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Landuse at the site consists mainly of agricultural activities including grazing, silage 

production, fertilising and land reclamation. The grassland is intensively managed and the 

rivers are therefore vulnerable to pollution from run-off of fertilisers and slurry. Arable crops 

are also grown. Fishing is a main tourist attraction on stretches of the Suir and some of its 

tributaries and there are a number of Angler Associations, some with a number of beats. 

Fishing stands and styles have been erected in places. Both commercial and leisure fishing 

takes place on the rivers. The Aherlow River is a designated Salmonid Water under the EU 

Freshwater Fish Directive. Other recreational activities such as boating, golfing and walking 

are also popular. Several industrial developments, which discharge into the river, border the 

site including three dairy related operations and a tannery. 

The Lower River Suir contains excellent examples of a number of Annex I habitats, including 

the priority habitat Alluvial Forest. The site also supports populations of several Annex II 

animal species and a number of Red Data Book animal species. The presence of two legally 

protected plants (Flora (Protection) Order, 1999) and the ornithological importance of the river 

adds further to the ecological interest of this site. 



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l l 


.......................................................................................................................................... 

Appendix 2 Evaluation of Ecological Importance and Assessment of 

Impact Significance 

Evaluation of Ecological Importance 

Table A2.1 Criteria for Assessing Ecological Importance 

l - County 

1 

High Local Importance 

2 

Sites which hold Red DataBook (Curtis and McGough, 1988) plant species 

Sites which hold nationally rare invertebrate species, subject to an evaluation as to whether their 

known status may be largely due to under-recording 

Sites which hold nationally rare vertebrate species (as defined by Whilde, 1993) 

Sites which hold nationally important bird populations (defined as 1% of the national population,; 

S heppard, 1993) 

Sites which hold nationally scarce plant species (recorded from less than 65 10 km squares'), 

unless they are locally abundant 

Sites which hold nationally scarce invertebrate species (recorded from less than 65 10 km 

squares'), unless they are locally abundant and subject to an evaluation as to whether their 

known status may be largely due to under-recording 

Sites which hold regionally scarce vertebrate species 

Sites which hold semi-natural habitats likely to be of rare occurrence within the county 

Sites which hold the best examples of a semi-natural habitat type within the county 

Sites which hold semi-natural habitats andlor species likely to be of rare occurrence within the 

local area 

Sites which hold the best examples of a high quality semi-natural habitat type within the local area 

Sites which hold high quality semi-natural habitats 

Any semi-natural habitat 

the island of Irelanc 

based pro-rata on the British criteria of 100 10 km squares (JNCC, 1995). 

Assessment of Impact Type and Magnitude 

Criteria for assessing impact type and magnitude are presented in Tables B and C, 

respectively. 

Table A2.2 Criteria for Assessing Impact Type 

Table A2.3 Criteria for Assessing Impact Magnitude 



No discernible change in the ecology of the affected feature. 

A change in the ecology of the affected site, the consequences of which are strictly limited to within the 

development boundaries. 

A change in the ecology of the affected site which has noticeable ecological consequences outside the 

development boundary, but these consequences are not considered to significantly affect the 

distribution andlor abundance of species or habitats of conservation importance'. 

Moderate Impact: A change in the ecology of the affected site, which has noticeable ecological consequences outside the 1 development boundaty. These consequences are considered to significantly affect the distribution 

andlor abundance of species or habitats of conservation importance. 

A change in the ecology of the affected site, which has noticeable ecological consequences outside the 

Impact: 

development boundary. These consequences are considered to significantly affect species or habitats 

of high conservation importance and to potentially affect the overall viability of those species or habitats 

in the wider area'. 

A change in the ecology of the affected site, which has noticeable ecological consequences outside the 

development boundary. These consequences are considered to be such that the overall viability of 

species or habitats of high conservation importance in the wider area' is under a vety high degree of 

threat (negative impact) or is likely to increase markedly (positive impact). 

to define specific numerical thresholds, as different specieshabitat have 

varying degrees of resilience to ecological peturbation. 

2 . 

1. e., the area relevant to the assessed importance of the feature. 

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1 

_. 

* 9 ; 

1 Ecofact Environmental Consultants Ltd. Thurles WwTP Appropriate Assessment 

APPENDIX 3 Biotic Indices 

EPA River Quality Classification Scheme 

The Q values are a measure of the EPA’s Biological River Quality classification system. The 

EPA conducts a rolling programme of biological surveys of selected rivers. The higher the 

biological diversity and the greater the abundance of invertebrate species sensitive to organic 

pollution, the higher the water quality is assumed to be, and the higher the ‘Q value’ assigned 

to that sampling station. The EPAs water quality classification systems are summarized 

below: 

Table A3.1 Biological River Quality Classification and River Water Quality Class System (McGarrigle et a/ 2002) 

‘Condition’ refers to the likelihood of interference with beneficial or potential beneficial use 

Class A waters are those in which problems relating to existing or potential uses are unlikely 

to arise. They are therefore regarded as being in a ‘satisfactory’ condition. Classes B, C and 

D are to a lesser or greater extent ‘unsatisfactory’ in this regard. For example, the main 

characteristics of Class B and C waters is eutrophication, which may interfere with the 

amenity, abstraction or fisheries uses of such waters. The general characteristics of waters of 

the various Biological Quality Classes are provided in Table A2.2. 

Table A3.2 The general characteristics of waters of the various Biological Quality Classes 



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Appendix 4 North Tipperary 'County Council chemical water quality 

monitoring data, Thurles W TP (2009) 

Table A4.1 Monitoring data for the River Suir upstream of the Thurles WwTP during the period January 

to August 2009 

Table A4.2 Monitoring data for the final treated effluent from the Thurles WwTP during the period 

January to August 2009. 

Total Phosphorus (as P) 



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.......................................................................................................................................... 

Table A4.3 Monitoring data for the River Suir downstream of the Thurles WwTP during the period 

January to August 2009 



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Comhairle Contae Thiobraid Arann Thuaidh North Tipperary County ...

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