Panther Environmental Solutions Ltd

Units 3 & 4, Innovation Centre

Institute of Technology
Green Road, Carlow
Rep. of Ireland
R93 W248

Telephone /Fax: 059-9134222

Email: [email protected]
Website: www.pantherwms.com

CONSTRUCTION ENVIRONMENTAL
MANAGEMENT PLAN

RIVER BARROW ACTIVITY CENTRE,

CARLOW TOWN PARK,
CARLOW

2021

DATE: 23rd September 2021 AUTHOR: Ross Donnelly-Swift, PhD

REPORT NO: PES_CEMP_21034 REVIEWED: Mike Fraher, BSc.
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TABLE OF CONTENTS

1 INTRODUCTION................................................................................................................... 5
1.1 PURPOSE OF THE CEMP ............................................................................................... 5
1.2 LIVE DOCUMENT .......................................................................................................... 5
1.3 COMMUNICATION ......................................................................................................... 5

2 PROJECT DESCRIPTION...................................................................................................... 6
2.1 LOCATION .................................................................................................................... 6
2.2 PLANNING CONTEXT .................................................................................................... 6
2.3 ENVIRONMENTAL BASELINE ...................................................................................... 10
2.4 CONSTRUCTION PROJECT DESCRIPTION ..................................................................... 15

3 ENVIRONMENTAL MANAGEMENT ................................................................................... 20

3.1 ENVIRONMENTAL MANAGEMENT SYSTEMS ............................................................... 20
3.2 ROLES AND RESPONSIBILITIES ................................................................................... 20
3.3 REGULATIONS AND REQUIREMENTS ........................................................................... 22
3.4 ENVIRONMENTAL AWARENESS AND TRAINING .......................................................... 24
3.5 DOCUMENT REVIEW AND UPDATES ........................................................................... 25
3.6 ENVIRONMENTAL COMMITMENTS .............................................................................. 25
3.7 COORDINATION WITH EXTERNAL ENTITIES ................................................................ 26

4 ENVIRONMENTAL IMPACTS ............................................................................................. 27

4.1 AIR QUALITY IMPACTS............................................................................................... 27
4.2 SURFACE WATER, GROUNDWATER AND SOIL IMPACTS ............................................. 28
4.3 TERRESTRIAL BIODIVERSITY IMPACTS ....................................................................... 28
4.4 NOISE IMPACTS .......................................................................................................... 30
4.5 TRAFFIC IMPACTS....................................................................................................... 30
4.6 WASTE MANAGEMENT IMPACTS ................................................................................ 31

5 ENVIRONMENTAL MITIGATION MEASURES .................................................................... 33

5.1 DUST MANAGEMENT.................................................................................................. 33
5.2 SURFACE WATER, GROUNDWATER AND SOIL CONTAMINATION CONTROL ................ 33
5.3 TERRESTRIAL BIODIVERSITY PROTECTION PROTOCOL ............................................... 35
5.4 INVASIVE SPECIES CONTROL ...................................................................................... 36
5.5 NOISE AND VIBRATION CONTROL .............................................................................. 36
5.6 TRAFFIC CONTROL ..................................................................................................... 37
5.7 WASTE MANAGEMENT CONTROL .............................................................................. 38
5.8 CHEMICAL AND HAZARDOUS MATERIALS MANAGEMENT ......................................... 42

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5.9 EMERGENCY MANAGEMENT PLAN ............................................................................. 43

6 MONITORING AND AUDITING .......................................................................................... 44

6.1 REPORTING AND RECORD KEEPING ............................................................................ 44
6.2 ENVIRONMENTAL PERFORMANCE MONITORING ........................................................ 44
6.3 MONITORING COMPLIANCE REPORTS......................................................................... 45
6.4 PROCEDURES TO REVIEW INSPECTIONS AND STEPS TO ADDRESS NON-COMPLIANCE 45

7 CONCLUSION .................................................................................................................... 46

8 REFERENCES .................................................................................................................... 47

APPENDIX A PROPOSED DEVELOPMENT LAYOUT ................................................................ 49

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LIST OF TABLES
TABLE PAGE

Table 2.1 Regional Policies Relevant to the Protection of the Environment

8
and the Proposed Development
Table 2.2 Summary of Local Policies Relevant to the Protection of the
9
Environment and the Proposed Development
Table 2.3 Summary of Habitats Identified at and adjacent the Proposed
11
Development Site
Table 2.4 Summary of Protected European and National Sites 13
Table 2.5 Active Monitoring Stations of the Barrow River 14
Table 2.6 Likely Construction Plant and Equipment Required 18

Table 4.1 NRA Acceptable Noise Levels 30

Table 4.2 Categories of Waste Generated During Construction 31

LIST OF FIGURES
FIGURE PAGE

Figure 2.1 Site Location at Carlow Town Park 6

Figure 2.2 Proposed Development Relative to Protected Sites 7
Figure 2.3 EPA Ecological Monitoring of the Barrow River from 2000 –
14
2018

Figure 4.1 The Waste Hierarchy 32

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1. INTRODUCTION

Panther Environmental Solutions Ltd. was commissioned by Kenneth Hennessy Architects on

behalf of Carlow County Council, to compile a Construction Environmental Management Plan
(CEMP) for the proposed development of a River Barrow Activity Centre with all associated
works at People's Park, Carlow, Co. Carlow.

1.1 PURPOSE OF THE CEMP

The purpose of this CEMP is to communicate key environmental obligations that apply to all
site personnel, sub-contractors and visitors to the site, while carrying out construction activities
as part of the proposed development. The CEMP defines the approach to environmental
management at the proposed development site, outlining the work practices, construction
procedures and responsibilities to be undertaken during the construction phase. Compliance
with the CEMP, the procedures, work practices and controls would be mandatory and must be
adhered to by all personnel and sub-contractors employed during the construction phase. The
CEMP outlines, where necessary, the control measures that are required to avoid, minimise or
mitigate potential effects on the environment and surrounding area.

This document has been prepared based upon the information provided during the planning
stage, supplied by the applicants and their representatives, with respect to the proposed
development.

1.2 LIVE DOCUMENT

The CEMP is a “live” document and would be reviewed and updated as necessary throughout
the construction phase.

1.3 COMMUNICATION

Upon planning approval, the applicants would appoint a construction works contractor to the
proposed development. This CEMP would be communicated to all site personnel during site
inductions and briefings. All site personnel would be responsible for undertaking their work in
an environmentally sustainable manner and would be encouraged to provide feedback and
comments on environmental performance at the site and suggestions for improvement.

The construction works contractor would appoint a Project Manager to the proposed
development. Any environmental issues, accidents or incidents would be reported to the Project
Manager as soon as possible, who in turn would inform the applicants.

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2. PROJECT DESCRIPTION

2.1 LOCATION

The proposed development would comprise of the construction of a River Barrow Activity
Centre at Carlow Town Park as shown in Figure 2.1 below. The development will include the
construction of boat storage areas measuring 310m2, kitchen, canteen, outdoor terraced seating,
function rooms, gym, showers and changing rooms over two floors. The total floor area of the
development is 805m2. Additional ancillary car parking with 14 spaces will be located
approximately 65m to the north west of the main building with a total area of approximately
0.096Ha. The main access to the site is via Barrow Street which connects to Maryborough
Street and then Bridge Street to the south The River Barrow and River Nore Special Area of
Conservation (SAC) site (Site Code: 002162), is located partly within the north eastern
boundary and adjacent the south eastern boundary of the proposed site, as shown in Figure 2.2.

Proposed
Car Park

Site Location

Figure 2.1: Site Location at Carlow Town Park

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Location of
proposed
development

River Barrow and

River Nore SAC

Figure 2.2: Proposed Development Relative to Protected Sites

2.2 PLANNING CONTEXT

The proposed development will provide a base for current facilities already taking place within
Carlow Town such as the park run, cycling, rowing, canoeing, kayaking, dragon boats and
similar water-based activities already in place on the River Barrow at Carlow Town. The main
building will be in operational use for training facilities, community meetings, cafe and
recreational use. Activities on the River Barrow will be initially confined to the existing water-
based sports and recreational use already in place by the clubs within Carlow Town such as
Carlow Rowing Club, Carlow Triathlon Club, Cliff Reid Boat Trips, Carlow Scout Group and
Graham Wall Kayaking. The proposed development will act as a base to existing events on the
River Barrow such as Carlow Rowing Regatta, The Dragon Run, Carlow Triathlon and Barrow
Dragon Boat Regatta

As good environmental practice, this CEMP has been prepared, to ensure construction works
would be undertaken in an environmentally sensitive manner.

The following sections outline the planning policies relevant to the proposed development and
the protection of the environment.

National Policies

A number of documents have been published in relation to the Government’s commitment to

sustainable development, including the National Spatial Strategy 2002-2020 and the
Sustainable Development: A Strategy for Ireland 1997.

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Regional Policies

The Regional Planning Guidelines for the Southeast Region 2010-2022, which includes the
counties of Carlow, Kilkenny, Waterford, Wexford and South Tipperary, outlines the long-
term spatial planning strategy for the area. As part of the guidelines, a number of policies
relating to the protection of the environment were outlined, as per Table 2.1 below.

Table 2.1: Regional Policies Relevant to the Protection of the Environment and the
Proposed Development
POLICY
POLICY
REFERENCE
Planning Authorities should develop policies that identify clearly:
- Environmental and Heritage resources that are to be maintained, conserved and
enhanced and integrated into any development proposals involving the sites as
PPO 8.1 discussed in the RPG for the area;
- Proposals for environmental enhancement in towns and villages and in rural areas;
- The means by which potential impacts on environmental resources are to be
avoided or mitigated.
Planning Authorities should ensure that all development plans take a holistic and
PPO 8.2 integrated approach to heritage and protect all relevant aspects of national heritage,
including archaeological, built, cultural, natural and linguistic heritage.
Planning Authorities should devise strategies for managing development and other
activities in order to achieve the objectives of the South East and South west River Basin
Management Plans and associated Programme of Measures. Local authorities should
ensure that common approaches are taken to the protection of surface, ground, coastal
and estuarine water bodies. These approaches should, inter alia, ensure that:
- The impact of developments on water bodies outside as well as inside the
PPO 8.5
jurisdiction of the individual authorities is considered when decisions on
discharges and water extraction are being made;
- Developments do not interfere with the attainment of the standards required by the
Water Framework Directive;
- Joint actions are taken to positively address the attainment of the standards required
by the Water Framework Directive.
Planning Authorities should provide for the following biodiversity objectives through
County and City Development Plans and Local Area Plans:
- Protect natural heritage sites designated or proposed for designation in National
and European legislation, and in other relevant International Conventions,
Agreements and Processes;
- Ensure that development does not have a significant adverse impact, incapable of
satisfactory mitigation, on plant, animal and bird species and habitats protected by
PPO 8.6 law and that developments affecting Natura 2000 sites are assessed in compliance
with Article 6 of the Habitats Directive;
- Maintenance and restoration of water quality in areas listed on the Register of
Protected Areas under the Water Framework Directive including Freshwater Pearl
Mussel Catchments;
- Protection of Fisheries and Shellfisheries;
- Identify and protect sites of local biodiversity interest that act as ecological
corridors linking sites of conservation importance.
It is an objective of the Regional Authority to encourage and support a co-ordinated
PPO 8.7 approach for protection and enhancement of the region’s flood plains, wetlands and
watercourses for their biodiversity and flood protection values.

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POLICY
POLICY
REFERENCE
Planning Authorities should ensure that River Management Policies should be an
integral part of Development Plans and cover all waterways considered as a natural
resource requiring protection and sustainable development. The following mechanisms
for protection of the aquatic environment could be considered for inclusion in
development plans:
PPO 8.9 - River Corridor Management Areas which provide for the protection and
sustainable development of the aquatic environment (particularly within towns and
cities);
- The identification and creation of linear parks along waterways incorporating
preservation of the Riparian Zone along waterways and subject to compliance with
Articles 6 and 10 of the EU Habitats Directive.
Local authorities should, where possible, promote awareness of invasive species in
PPO 8.10 collaboration with other relevant agencies and take appropriate measures for their
management and control.

Local Policies

Local planning policies are detailed in the Carlow County Development Plan, 2015-2021. A
number of policies relate to the protection of the environment and are relevant to the proposed
development, summarised as follows:

Table 2.2: Summary of Local Policies Relevant to the Protection of the Environment and
the Proposed Development
POLICY
AREA
REFERENCE
Heritage –
Protection of biodiversity: wildlife, habitats, species and designated sites
Policy 1
Heritage – Protection of all-natural heritage sites designated or proposed for designation in
Policy 2 accordance with European and National legislation. Screening of all projects and plans
for the need to undertake Appropriate Assessment under Article 6 of the Habitats
Directive.
Env. – Policy 1 Management of wastes, the “polluter pays” principle and the preparation of construction
and demolition waste management plans for significant construction / demolition
projects.
Env. – Policy 2 Protection of soil quality. Requirement on developments to carry out land contamination
surveys where lands may have been at risk.
Env. – Policy 4 Ensuring developments do not cause unacceptable increases in noise emissions.
Env. – Policy 5 Ensuring developments do not cause significant light pollution.
Env. – Policy 6 Protection of groundwater quality. Compliance with the Urban Waste Water Treatment
Regulations and the Waste Water Discharge (Authorisation) Regulations.
Env. – Policy 7 Protection of surface water quality and drinking water quality. Implementation of the
Water Framework Directive.

Biodiversity Plans

Ireland’s third National Biodiversity Plan 2017–2021, identifies actions towards understanding
and protecting biodiversity with a vision that, “biodiversity and ecosystems in Ireland are
conserved and restored, delivering benefits essential for all sectors of society and that Ireland
contributes to efforts to halt the loss of biodiversity and the degradation of ecosystems in the
EU and globally”. A number of Local Biodiversity Action Plans have been prepared, and it is

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noted that the Carlow County Development Plan (CDP) includes a policy to promote increased
understanding and awareness of the natural heritage and biodiversity of the county and aim to
carry out a Biodiversity Plan during the lifetime of the plan

All-Ireland Pollinator Plan

In 2015, Ireland joined a number of other European countries in developing a strategy to

address pollinator decline and protect pollination services. 68 governmental and non-
governmental organisations agreed a shared plan, the “All-Ireland Pollinator Plan”, which
identifies 81 actions to make Ireland pollinator friendly. The plan provides recommendations
for six different sectors, including farmers, county councils, communities, businesses,
homeowners and schools.

2.3 ENVIRONMENTAL BASELINE

The proposed main development site, measuring approximately 0.0236 hectares and the
existing site is within Carlow Town. The land use of the area is mainly urban with the River
Barrow along the north-east boundary which is designated as part of the River Barrow and
River Nore SAC. There are commercial buildings along Maryborough Street and historic sites
such as Carlow Castle within the vicinity of the proposed site.

2.3.1 Biodiversity

As part of the preparation of this CEMP, a site characterisation assessment was undertaken on
the 10th March 2021 to examine the ecological context of the development site, by
systematically walking the site and boundaries and determining the habitats present. The
habitat survey was undertaken in accordance with the standard methodologies outlined in
Fossitt’s “A Guide to Habitats in Ireland”, and the Heritage Council guidelines, “Best Practice
Guidance for Habitat Survey and Mapping”, (Smith et al., 2011).

Bird species and any signs of fauna activity and dwellings were also noted. Particular attention
was given to the possible presence of habitats and/or species, which are legally protected under
Irish and European legislation. No evidence of fauna was found on site during the survey.

The majority of the development sites, comprising of buildings and artificial surfaces,
ornamental/non-native shrubs, scrub, recolonising bare ground and improved amenity
grassland can be considered as modified and of low biodiversity value. No plant species of
conservation significance or invasive plant species of concern were noted during the site
assessment.

See accompanying Natura Impact Statement (Report No PES_NIS_21034) for complete

ecological assessment of the site. The identified habitats at the proposed development site and
within the vicinity of the site, as per the Fossitt habitat classification scheme, are summarised
in Table 2.3 below.

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Table 2.3: Summary of Habitats Identified at and adjacent the Proposed Development Site
HABITAT CLASSIFICATION HIERARCHY
LEVEL 1 LEVEL 2 LEVEL 3
B – Cultivated and built land BL – Built land BL3 - Buildings and artificial
surfaces
E – Exposed rock and ED – Disturbed ground ED3 – Recolonising bare
disturbed ground ground
F – Freshwater FW – Watercourses FW2 – Depositing/lowland
rivers
G – Grassland and marsh GA – Improved grassland GA2 – Amenity grassland
(improved)
WN - Semi natural WN5 - Riparian woodland
woodland
WD – Highly modified/non- WD5 – Scattered trees and
native woodland parkland
W – Woodland and scrub
WS – Scrub/transitional WS1 – Scrub
woodland
WS3 – Ornamental/non-
native shrubs
WL – Linear woodland / WL1 - Hedgerows
scrub

Invasive Species

Under Regulation 49(2) of the European Communities (Birds and Natural Habitats)
Regulations 2011, save in accordance with a licence granted under paragraph (7), any person
who plants, disperses, allows or causes to disperse, spreads or otherwise causes to grow in any
place specified in relation to any plant which is included in Part 1 of the Third Schedule shall
be guilty of an offence.

Materials containing invasive species such as Japanese Knotweed are considered “controlled
waste” and, as such, there are legal restrictions on their handling and disposal. Under
Regulation 49(7) of the European Communities (Birds and Natural Habitats) Regulations
2011, it is a legal requirement to obtain a license to move “vector materials” listed in the Third
Schedule, Part 3.

Six invasive flora species listed in the Third Schedule of the European Communities (Birds
and Natural Habitats) Regulations 2011 have been recorded by the NBDC within the 10km
square (Tetrad - S77) in which the proposed development site is located; Canadian Waterweed
(Elodea canadensis), Indian Balsam (Impatiens glandulifera), Giant Hogweed (Heracleum
mantegazzianum), Japanese Knotweed (Fallopia japonica), Nuttall's Waterweed (Elodea
nuttallii) and Water Fern (Azolla filiculoides). However, no invasive species of concern were
noted as present during the site walkover.

The risk of invasive species being introduced onto the site during the construction phase of the
project is considered to be low, with no import of materials with the potential to contain
invasive flora species. Soils excavated during construction works would be stockpiled and re-

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used for site levelling, therefore no importation of topsoil or subsoil would be required as part
of the development works.

Therefore, it is considered that there would be no significant risk to protected habitats and
species as a result of invasive species from the site.

Fauna

Given the urban land use of the surrounding area, it would be expected that common garden
and hedgerow bird species in addition to waterfowl would be present in the area. Bird species
noted during the site walkover included, Cormorant (Phalacrocorax carbo), Grey Heron
(Ardea cinerea), Mallard (Anas platyrhynchos), Mute Swan (Cyngus olor), Grey Wagtail
(Motacilla cinera), Goldfinch (Carduelis carduelis), Blackbird (Turdus merula), Chaffinch
(Fringilla coelebs), Magpie (Pica pica), Great Tit (Parus major), Dunnock (Prunella
modularis), Starling (Sturnus vulgaris), Feral pigeons (Columba livia domestica), House
Sparrow (Passer domesticus), Rook (Corvus frugilegus), Song Thrush (Turdus philomelos),
Jackdaw (Corvus monedula), and Woodpigeon (Columba palumbus). No species are red listed
under the BoCCI classification, however, four species, Cormorant, Mute Swan, Starling, House
Sparrow are amber listed. None of the bird species recorded are listed under Annex I of the
E.U. Birds Directive

No other fauna, or evidence of other fauna, were noted during the survey. There was no
evidence of Badger (including setts or latrines), or Otter (including spraints, holts or slides) at
the proposed development site. See accompanying Natura Impact Statement (Report No
PES_NIS_21034) for ecological assessment of the habitats at the proposed site.

Bats

It is possible that bats are present within the area of the proposed development, given the
presence of woodlands along the River Barrow which may provide suitable foraging and
commuting habitats. There are no trees/shrubs within the development sites that would offer
suitable roosting potential for bats.

National Biodiversity Data Centre (NBDC) records for the previous thirty years for bats within
the 10km square (Tetrad - S77) in which the proposed development is located Brown Long-
eared Bat (Plecotus auritus), Daubenton's Bat (Myotis daubentonii), Lesser Noctule (Nyctalus
leisleri), Natterer's Bat (Myotis nattereri), Pipistrelle (Pipistrellus pipistrellus) and Soprano
Pipistrelle (Pipistrellus pygmaeus).

Designated Sites

In assessing the zone of influence of this project upon National/European sites, the following
factors must be considered:
• Potential impacts arising from the project
• The location and nature of National/European sites
• Pathways between the development and National/European sites

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There is no standard radius that can be used to select which European/National sites are to be
analysed. This can only be determined by looking at the zone of influence of the project at
hand. A rule of thumb often used is to include all European/National sites within a distance of
15km. No Special Protection Area (SPA) or Nature Reserves sites occur within 15km of the
proposed development. Two Special Area of Conservation (SAC) sites occur within 15km of
the proposed development and are shown in Table 2.4 below. In addition, there is one National
Heritage Area (NHA) and seven proposed National Heritage Areas (pNHA) within 15km of
the proposed site.

Table 2.4: Summary of Protected European and National Sites

APPROX. DISTANCE
SITE NAME DESIGNATION SITE CODE
FROM PROPOSED SITE
River Barrow and River Nore SAC 002162 Within/Adjacent
Slaney River Valley SAC 000781 10.70km E
Coan Bogs NHA 001757 10.8km SW
Oakpark pNHA 000810 3.6km NE
Cloghristick Wood pNHA 000806 6.5km SW
Barrow Valley at Tankardstown
pNHA 000858 10.5km N
Bridge
Ballylynan pNHA 000857 11.6 km NW
Ardristan Fen pNHA 000788 12.5km SE
Ballymoon Esker pNHA 000797 14.1km S
Corballis Hill pNHA 001389 14.8km NE

To determine an impact on a protected site there must be a source-pathway-receptor

relationship. The site does not have a direct hydrological connection to the Slaney River Valley
SAC, Coan Bogs NHA, Ballylynan pNHA, Ardristan Fen pNHA Ballymoon Esker pNHA and
Corballis Hill pNHA and Oakpark pNHA. The Barrow Valley at Tankardstown Bridge pNHA
is located upstream of the proposed site.

Cloghristick Wood pNHA has been designated for woodland flora such as Oak (Quercus spp.),
Beech (Fagus sylvatica), Hazel (Corylus avellana) with Willows (Salix spp.) as the dominant
species. The ground flora comprises a range of wetland and woodland species. Oak woodlands
are not impacted by river water quality as they are a terrestrial habitat. Alluvial and Oak
woodlands habitats are assessed for potential impacts in the accompany NIS (Document Ref:
PES_NIS_21034) as both habitats are qualifying interests of the River Barrow and River Nore
SAC.

For this assessment, the site considered to be within the potential zone of influence of the
proposed development was the River Barrow and River Nore SAC (Site Code: 002162), due
to the hydrological connection and the distance. For a complete assessment of the River Barrow
and River Nore SAC and its qualifying interests see the accompanying NIS (Document Ref:
PES_NIS_21034).

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2.3.2 Water Quality

The proposed development is located within the Barrow Catchment (Barrow sub-catchment,
SC_090). As noted above, the River Barrow passes along the western boundary of the
development site. The current WFD status of the River Barrow within proximity of the
proposed development is “At Risk”.

The River Barrow is designated as part of the River Barrow and River Nore Special Area of
Conservation (SAC) (Site Code: 002162). The Conservation Objectives document for the
River Barrow and River Nore SAC shows that water quality objectives have been set for
White-clawed Crayfish (Austropotamobius pallipes) and Atlantic Salmon (Salmo salar), with
a Q3-4 (moderate status) and Q4 (good status) values set as objectives in freshwater. Water
quality objectives have also been set for Twaite Shad, with a target of oxygen levels no lower
than 5mg/l.

Table 2.5: Active Monitoring Stations of the Barrow River

APPROX. LOCATION
STATION NO. STATION LOCATION EASTING NORTHING RELATIVE TO PROPOSED
SITE
New Br 1km u/s Carlow
RS14B012200 272007 177778 1.14m Upstream
Br
Footbridge, Dolmen
RS14B012450 270653 174173 4.95km Downstream
Hotel
RS14B012600 Milford Br 269975 170430 9.38km Downstream

EPA Monitoring on the River Barrow within the Vicinity of the

Proposed Development
5

4
Biotic Index (Q-Rating)

0
2000 2003 2006 2009 2011 2014 2018

RS14B012200 RS14B012450 RS14B012600

Good Status Moderate Status Poor Status

Figure 2.3: EPA Ecological Monitoring of the Barrow River from 2000 – 2018

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The Environmental Protection Agency (EPA) undertake surface water monitoring along the
River Barrow. The results for the nearest monitoring stations (as per Table 2.5) with available
monitoring results for the period 2000 – 2018 are summarised in Figure 2.3 for indicative
purposes.

As can be seen in Figure 2.3 above, the Barrow River is mainly achieving a water quality status
of between Q4 (good) and Q3-4 (moderate) at the monitoring locations (Table 2.5), with the
status of all stations declining to Q3-4 (moderate) from 2009. EPA comments on the most
recent monitoring results for the Barrow River are as follows; “The Barrow was sampled
across 2017 and 2018 due to the outbreak of crayfish plague, with several additional surveys
in 2019. Of the 12 stations sampled along the Barrow in 2017, stations 0200, 0780, 1300, 1500,
2900 were in Good ecological condition, while the two uppermost stations maintained High
ecological quality (0050 & 0100). A decline to unsatisfactory Moderate quality occurred at
Station 1000 (Pass Bridge) and the lowermost station at Graiguenamanagh (3500). In 2018,
station 0300 (Twomile Br) improved to High ecological quality, while station 1900
(Tankardstown Br) declined to unsatisfactory Poor quality. The latter site had an
overabundance of Potamopyrgus snails and too much instream algae. Station 0700
(Kilnahown Br) retained Good ecological quality and stations 0500, 2200, 2455, 2600 and
2680 all remained at unsatisfactory Moderate ecological quality. In July 2019, despite
increases in the diversity of sensitive taxa, pollution tolerant groups still dominated and
filamentous algae was excessive at Ford S. of Trascan (0900) which remained moderate.
Ballyteigelea Bridge (3300) also remained Moderate, while Tankerstown (1900) improved
slightly to Moderate ecological status.”

2.4 CONSTRUCTION PROJECT DESCRIPTION

The construction of proposed development would be undertaken by the construction

contractors, hereafter referred to as “the construction works contractor”, on behalf of Carlow
County Council, hereafter referred to as “the clients”.

The proposed development would comprise of the construction of a River Barrow Activity
Centre at Carlow Town Park. See Appendix A for proposed site layout. The development will
include the construction of boat storage areas measuring 310m2, kitchen, canteen, outdoor
terraced seating, function rooms, gym, showers and changing rooms over two floors. The total
floor area of the development is 805m2. Additional ancillary car parking with 14 spaces will
be located approximately 65m to the north west of the main building with a total area of
approximately 0.096Ha. The proposed site drawings are included in Appendix A.

The expected construction timeframe would be approximately eighteen months, with hours of
operation from 8am to 6pm Monday to Friday, and 8am to 2pm on Saturdays. A designated
waste area and designated area of any waste materials located away from the River Barrow and
any drainage system would be established by the construction works contractor within the
development site boundary, appropriate measures must be taken to prevent any runoff into the
River Barrow during construction works.

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2.4.1 Construction Schedule

The approximate construction period for the proposed development is estimated to be eighteen
months. Upon approval of the CEMP by development authority, the construction schedule
would be finalised at a detailed design stage. The proposed development would include the
following main construction activities:

General

• Mobilisation of personnel and equipment to site;

• Site inductions and relevant training;
• Erection of health and safety / construction works signage;
• Installation of external lighting if required;
• Site clearance, including any vegetation removal.

Remediation Works at Proposed Site and Associated Works

• Excavations and earth moving activity;

• Stockpiling of material for use in site reinstatement activities;
• There should be no storage of materials or construction works of any kind to take place
within the construction exclusion zone of the River Barrow;
• Installation of silt control features where appropriate, such as silt fencing;
• Cover of drainage network with silt mats;
• Pouring of concrete;
• Works to facilitate access to the site.

Reinstatement

• Finishing of proposed development site;

• Removal from site of any excess materials remaining following reinstatement works;
• Removal of any silt control features once stabilisation has taken place / temporary
storage of excavated materials has been removed.

2.4.2 Main Stages of Construction

Site Clearance and Excavations

During site clearance works, any excess material at the site will be either stored for re-use in
construction activities at the development site or removed to a licenced waste facility. During
excavation works, subsoil and topsoil would be temporarily stored for re-use in reinstatement
where possible. Any excess materials would be transported offsite by a licenced contractor for
disposal at a suitably licenced facility. Alternatively, should excess excavated materials/soils
be classified as a by-product under Article 27 of the Waste Directive Regulations, 2011, and if

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the proposed end use meets the requirements of the Article 27 regulations, excavated soils
could be directed for local use. The storage of excavated material on site would be temporary,
until the completion of site reinstatement activities.

Provision / Upgrade of Services

Following site clearance and excavations, works would commence on the installation / upgrade
of underground utilities to the site required for water supply, wastewater, electricity and
telecommunications.

Stormwater comprised of rainwater run-off from the roof areas and hard surfaces will connect
with a new drainage system with a hydrocarbon interceptor before connecting to the existing
stormwater drainage system within the vicinity of the development.

Construction of Development

Following site clearance, excavations and works for the provision of services, works would
commence on the construction of the development. The pouring of concrete foundations would
be supervised at all times.

Site Reinstatement and Landscaping

Landscaping works will take place at the proposed site would include the removal of any
hardcore surfaces, removal of any stockpiled material from excavations, the removal of
construction plant, equipment and signage, the reseeding/replanting of exposed soil where
required and the planting of trees and shrubs. Reinstatement and landscaping activities would
also include the removal of silt control features, once there is no risk to the River Barrow.

2.4.3 Construction Working Hours

It is anticipated that construction works would be undertaken during standard construction

hours, as follows:

Start Finish Days

8am 6pm Monday – Friday
8am 2pm Saturday

No works would take place on Sundays or Bank Holidays. It should be noted that there may be
times where it is necessary to undertake construction works outside of the times mentioned
above, for example concrete pours. In such cases, notification would be given where necessary
to the relevant bodies (i.e. local council) and any potentially effected local residents in good
time and prior to specified works commencing.

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2.4.4 Construction Plant and Equipment

The construction plant and equipment likely to be used during the construction phase of the
project are included in the table below. It should be noted that this list is not exhaustive.

Table 2.6: Likely Construction Plant and Equipment Required

ACTIVITY POSSIBLE PLANT / EQUIPMENT REQUIRED
Excavator
Dumper trucks
Site Clearance and Excavations Bulldozer
Graders
Rollers
Tracked Excavator
JCB
Construction of Building Site Dumper
Cement Mixer
Crane Piling
Tracked Excavator
Site Reinstatement and Landscaping Site Dumper
Bulldozer

2.4.5 Security Arrangements

The construction works contractor would ensure the proposed development site is secured, so
as to provide the safety of all potentially affected parties, including staff, contractors, traffic
and pedestrians. Only authorised personnel would be allowed onto the development site. The
site would be secured by a fence, hoarding or another suitable site barrier system to protect
against unauthorised entry. The construction works contractor would implement the
appropriate security arrangements, including signing in / out procedures, signage and out-of-
hours security.

2.4.6 Health and Safety

All activities undertaken at the proposed development site during the construction phase shall
be in accordance with the requirements of the Safety, Health and Welfare at Work Act 2005,
as amended, and the Safety, Health and Welfare at Work (Construction) Regulations, 2013. As
required by the 2013 regulations, a Health and Safety Plan would be prepared by the
construction works contractor, which would address health and safety issues from the design
stages through to the completion of construction works. This plan would be updated and
reviewed as required as the proposed development progresses.

Prior to works commencing onsite, all site personnel, including sub-contractors, would receive
induction training that would incorporate health and safety requirements and good practice.
Site induction would be mandatory for all employees, sub-contractors and visitors to the
development site. Specific training would be provided, where necessary.

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All construction personnel, contractors and visitors to the site would wear the following
appropriate Personnel Protective Equipment as a minimum at all times:

• Safety helmet;
• Hi-visibility clothing (coat or vest);
• Safety boots;
• Eye protection where identified for specific activities.

Regular site safety audits would be undertaken throughout the construction phase to ensure the
rules and regulations established for the site are complied with at all times.

2.4.7 Construction Signage and Labelling

Environmental signage and labelling would be used to inform site personnel of environmental
requirements and restrictions with regards construction activities, in addition to promoting
environmental good practice at the development site. The construction works contractor would
erect the appropriate signage and label all relevant areas and receptacles. Examples would
include designated storage areas for potentially polluting materials and waste and site
environmental rules.

2.4.8 Construction Method Statement

Prior to works commencing, the construction works contractor would prepare and provide to
the clients a detailed Construction Method Statement, which would address all construction
works required for the proposed development. The construction works contractor would
maintain a register of all method statements for the project, in addition to a register of all site
personnel trained on the method statements.

2.4.9 Potential for Historic Contamination

As per the O’Callaghan Moran & Associates soil assessment of the site from samples collected
by IGSL Ltd the site contains contaminated material. If additional contaminated material is
encountered during construction works, appropriate measures would be undertaken in
compliance with relevant waste legislation, and as outlined in Section 5.7 below. The relevant
authorities would be notified where required.

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3 ENVIRONMENTAL MANAGEMENT

3.1 ENVIRONMENTAL MANAGEMENT SYSTEMS

An Environmental Management System (EMS) would be put in place by the construction

contractor. The EMS would take into account any comments or recommendations received by
Carlow County Council and, in accordance with the relevant guidelines, would be appropriate
to the scale of the operation.

The construction works contractor would implement a number of environmental management

procedures, including but not limited to the following:

• Awareness and Training;

• Environmental Emergency Response;
• Record Keeping, Auditing and Monitoring;
• Environmental Complaints Procedure;
• Protection of Flora and Fauna;
• Protection of Soil, Groundwater and Surface Water Quality;
• Chemical and Hazardous Material Management;
• Noise Management;
• Dust Management;
• Waste Management.

The CEMP would be updated as necessary to ensure that all measures detailed within the
environmental management procedures have been addressed within the CEMP.

3.2 ROLES AND RESPONSIBILITIES

The construction works contractor (CWC) would put an experienced construction management
team in place. The Project Manager would have overall responsibility for environmental
management at the proposed development site. The indicative roles and responsibilities for the
relevant site personnel are detailed below.

Project Manager

The Project Manager’s responsibilities are as follows:

• Management of the project;

• Implementing the Construction Environmental Management Plan;
• Monitoring the performance of the CEMP and maintaining records to demonstrate
compliance with the CEMP and Construction Method Statement;
• Updating the Construction Environmental Management Plan as required;

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• Ensuring no deterioration of the environment occurs as a result of the project;

• Co-ordinating the construction team;
• Implementing the Health and Safety Plan and associated responsibilities;
• Production of construction programmes;
• Maintaining of relevant records and registers;
• Ensuring site personnel receive induction and are provided with the relevant
information relating to the protection of the environment during works;
• Dealing with any queries or complaints from the public.
• Maintaining a project diary.

Quality Manager

The Quality Manager would report to the Project Manager. Their responsibilities are as
follows:

• Implementing the Construction Environmental Management Plan;

• Management of quality issues relating to the project;
• Co-ordinating the construction teams;
• Ensuring that method statements are in place;
• Implementing the Health and Safety Plan.

Site Engineer

The Site Engineer would report to the Project Manager. Their responsibilities are as follows:

• Ensuring that all aspects of the project comply with the Construction Environmental
Management Plan;
• Materials procurement;
• Design of Temporary Works;
• Administration;
• Programming and planning;
• Implementing the Health and Safety Plan;
• Maintaining a project diary.

EHS Officer

The EHS Officer would report to the Project Manager. Their responsibilities are as follows:

• Ensuring the Health and Safety Plan is implemented;

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• Ensuring the Construction Environmental Management Plan is being implemented and

followed at all times;
• Updating the Construction Environmental Management Plan as required;
• Ensuring all personnel have received safety inductions;
• Investigating any accidents, incidents or near misses;
• Ensuring relevant personnel have received training in environmental issues;
• Undertaking site audits on a regular basis.

All Staff and Sub-contractors

All site personnel and sub-contractors have the following responsibilities:

• Ensuring the requirements of the Construction Environmental Management Plan are

followed;
• Co-operate with the Project Manager and EHS Officer in the implementation and
development of the CEMP;
• Co-operate as required with site inspections and audits;
• Report all incidents, accidents and near misses to the Project Manager and/or EHS
Officer.

3.3 REGULATIONS AND REQUIREMENTS

3.3.1 Legislative Context

The following list of acts and regulations, which is not exhaustive, would be complied with by
the construction works contractor throughout the proposed project:

• The Wildlife Act, 1976 and Wildlife (Amendment) Act, 2000;

• European Communities (Birds and Natural Habitats) Regulations, 2011 (S.I. No. 477
of 2011) and (Amendment) Regulations, 2015 (S.I. No. 355 of 2015), transposing the
Habitats Directive 92/43/EEC (as amended) and Birds Directive 2009/147/EC;
• The Flora (Protection) Order, 2015 (S.I. No. 356 of 2015);
• Planning and Development Regulations, 2001 to 2018;
• The Local Government (Water Pollution) Act, 1977, as amended;
• The Fisheries (Consolidation) Act, 1959, as amended;
• Fisheries (Amendment) Act, 1999;
• European Communities (Quality of Salmonid Waters) Regulations, 1988 (S.I. No. 293
of 1988);
• European Communities Environmental Objectives (Surface Waters) Regulations, 2009
(S.I. No. 272 of 2009);

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• Water Framework Directive (2000/60/EC);

• European Communities Environmental Objectives (Groundwater) Regulations, 2010
(S.I. No. 9 of 2010) and 2016 (S.I. No. 366 of 2016);
• Air Pollution Act, 1987;
• Air Quality Standards Regulations, 2011 (S.I. No. 180 of 2011), transposing the
Ambient Air Quality and Cleaner Air for Europe (CAFE) Directive (2008/50/EC);
• Planning and Development Act 2000 (S.I. No. 30 of 2000), as amended;
• The EPA Act (Noise) Regulations 1994 (S.I. No. 179 of 1994);
• European Communities (Construction Plant and Equipment) Permissible Noise Levels
Regulations, 1988 (S.I. No. 320 of 1988), as amended;
• European Communities (Noise Emission by Equipment for Use Outdoors) Regulations,
2001 (S.I. No. 632 of 2001);
• Council Directive 1999/31/EC on the Landfilling of Waste and Council Directive
2003/33/EC establishing criteria and procedures for the acceptance of waste at landfills;
• Waste Framework Directive 2008/98/EC;
• WEEE Directive 2012/19/EU;
• Waste Management Act 1996 as amended;
• Waste Management (Hazardous Waste) Regulations 1998 (S.I. 163 of 1998) and
(Amendment) Regulations 2000 (S.I. 73 of 2000);
• Waste Management (Food Waste) Regulations 2009 (S.I. 508 of 2009);
• European Union (Waste Electrical and Electronic Equipment) Regulations 2014
(WEEE) (S.I. 149 of 2014);
• Litter Pollution Act 1997 and Litter Pollution Regulations 1999 (S.I. 359 of 1999);
• Waste Management (Prohibition of Waste Disposal by Burning) Regulations 2009 (S.I.
286 of 2009), as amended;
• European Communities (Waste Directive) Regulations 2011 (S.I. 126 of 2011),
(Amendment) Regulations 2016 (S.I. 315 of 2016), and European Union (Properties of
Waste which Render it Hazardous) Regulations 2015 (S.I. 223 of 2015), European
Union (Waste Directive) (Recovery Operations) Regulations 2016 (S.I. 372 of 2016).

3.3.2 Relevant Guidelines

The following list guidance documents, which is not exhaustive, would be consulted as relevant
by the construction works contractor throughout the proposed project:

• Environmental Good Practice on Site (CIRIA, 2015);

• Control of Water Pollution from Construction Sites; guidance for consultants and
contractors (CIRIA, 2001);
• Control of Water Pollution from Construction Sites – Guide to Good Practice (CIRIA,
2002);

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• Guidelines on Protection of Fisheries During Construction Works in and adjacent to

Waters (IFI, 2016);
• The Management of Noxious Weeds and Non-Native Invasive Plant Species on National
Roads (National Roads Authority (NRA), 2010);
• Guidelines for the Treatment of Badgers prior to the Construction of National Road
Schemes (NRA, 2006a);
• Guidelines for the Treatment of Otters prior to the Construction of National Road
Schemes (NRA, 2006b);
• Guidelines for the Treatment of Bats during the Construction of National Road Schemes
(NRA, 2006c);
• Bat Mitigation Guidelines for Ireland (Kelleher and Marnell, 2006);
• Bats & Lighting: Guidance Notes for Planners, Engineers, Architects and Developers
(Bat Conservation Ireland, 2010);
• Assessment of dust from demolition and construction 2014 (Institute of Air Quality
Management, 2014);
• Guidelines for the Treatment of Noise and Vibration in National Road Schemes (NRA,
2004);
• Code of practice for noise and vibration control on construction and open sites (British
Standard 5228-1, 2009);
• Best Practice Guidelines on the Preparation of Waste Management Plans for
Construction and Demolition Projects (DoEHLG, 2006);
• Southern Region Waste Management Plan 2015-2021 and Associated Reports.

3.4 ENVIRONMENTAL AWARENESS AND TRAINING

Prior to works commencing onsite, this CEMP and its contents would be communicated to all
site personnel, including sub-contractors, as part of induction training. Site induction would be
mandatory for all employees, sub-contractors and visitors to the development site.

Specific training would be provided, where necessary, to nominated personnel to address any
incidents or emergencies that could have a potential to cause environmental pollution. This
training would be provided to staff via toolbox talks, and may address issues such as the
following:

• Water Pollution;
• Spill Control;
• Noise Pollution;
• Dust Pollution;
• Waste Management.

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3.5 DOCUMENT REVIEW AND UPDATES

To ensure the CEMP remains “fit for purpose”, it would be reviewed and updated as necessary
throughout the construction phase to ensure that it continues to facilitate efficient and effective
delivery of the project environmental commitments for the protection of the environment.

The CEMP would be reviewed to address, for example, the following;

• Any recommendations, comments or observations received by Carlow County Council

following the submission of the CEMP for approval;
• Any requirements or issues highlighted by prescribed bodies such as Inland Fisheries
Ireland and the NPWS;
• To ensure it reflects best practice at the time of construction;
• To ensure it incorporates findings from previous inspections and audits undertaken by
the construction works contractor;
• To ensure it incorporates findings and/or recommendations arising from the site
meetings between the construction works contractor and clients.

The Project Manager and EHS Officer would be responsible for the review of the CEMP and
would ensure that any revisions to the CEMP are effectively communicated as appropriate to
onsite personnel and sub-contractors.

3.6 ENVIRONMENTAL COMMITMENTS

The clients recognise that construction works have the potential to adversely impact upon the
environment and would therefore ensure that the construction works contractor is committed
to the effective implementation of the CEMP. Compliance with the CEMP, including all
procedures, work practices and controls, would be mandatory by all personnel and sub-
contractors employed during the construction phase. The CEMP outlines the necessary control
measures that are required to avoid, minimise or mitigate potential effects on the environment.

The construction works contractor would be committed to the implementation of the controls
/ mitigation measures specified within the following sections:

• Dust Management – Section 5.1;

• Surface Water, Groundwater and Soil Contamination Control – Section 5.2;
• Terrestrial Biodiversity Protection Protocol – Section 5.3;
• Invasive Species Control – Section 5.4;
• Noise and Vibration Control – Section 5.5;
• Traffic Control – Section 5.6;
• Waste Management Control – Section 5.7;
• Chemicals and Hazardous Materials Management – Section 5.8.

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The Project Manager, Quality Manager and EHS Officer would be responsible for the
implementation of the CEMP throughout construction works. The Project Manager would be
responsible for monitoring the performance of the CEMP and maintaining records to
demonstrate compliance with the CEMP and would be assisted by the EHS Officer.

3.7 COORDINATION WITH EXTERNAL ENTITIES

In the event of an environmental incident at the site, the construction works contractor would
follow the Emergency Management Plan as appropriate. The construction works contractor
would liaise with the relevant third parties as appropriate, which may include the following:

• Emergency Services;
• Carlow County Council;
• National Parks and Wildlife Service;
• Inland Fisheries Ireland;
• Environmental Protection Agency

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4. ENVIRONMENTAL IMPACTS

4.1 AIR QUALITY IMPACTS

Generally, the primary potential air quality impact or nuisance associated with construction
activities is dust. Excavations and earth moving operations may generate quantities of
construction dust, particularly in drier weather conditions. The extent of any construction dust
generation depends on the nature of the construction dust (soils, sands, gravels, silts etc.) and
the construction activity. The potential for construction dust dispersion depends on the local
meteorological conditions such as rainfall, wind speed and wind direction.

Particulate Matter (PM10 and PM2.5) is measured at Carlow Town Air Monitoring Site
approximately 412m north east of the proposed development and has a Current Index: 1
(Good). The proposed development is located in the Air Zone C (Other Cities and Large
Towns) and has a current Air Quality Index status of “2-Good”.

The issue of construction dust dispersion may be exaggerated with vehicles transporting
sand/gravels/concrete/etc. to and from the site, having the potential to cause an environmental
nuisance to use of the local road.

Dust is normally defined as particulate matter in the size range of 1 - 75µm in diameter, with
particles less than 1µm being classified as smoke or fumes. Particles greater than 10µm are
associated with public perception and nuisance. Dusts are normally present in the atmosphere
at varying levels of concentration and can have a wide variety of man-made and natural origins
including:

• Products of combustion from e.g. fires, power stations and motor vehicles;
• Mechanical handling of minerals and allied materials;
• Industrial activities.

Dust particles are dispersed by their suspension and entrainment in airflow. Dispersal is
affected by the particle size, shape and density, as well as wind speed and other climatic effects.
Smaller dust particles remain airborne for longer, dispersing widely and depositing more
slowly over a wider area.

The main potential sources of air borne dust from construction activities are as follows:

• Construction vehicles, construction traffic and haulage routes;

• Excavation works and earth-moving activities;
• Materials (particularly excavated soils) handling, storage and stockpiling.

Construction dust control is a common part of construction management practices. The effect
of construction activities on air quality, in particular construction dust, would not be significant
following the implementation of standard working practices and the proposed mitigation
measures outlined in Section 5.1.

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4.2 SURFACE WATER, GROUNDWATER AND SOIL IMPACTS

During construction works, the main potential impacts upon surface water quality, groundwater
quality and soils would be the release of suspended solids during soil disturbance works and
the release of potentially polluting substances, such as hydrocarbons (fuels and oils) and
uncured concrete.

Suspended solids could become entrained in surface water run-off and could affect aquatic
habitats through deposition. An increase in sediments has the potential to impact upon fish by
damaging gravel beds required for spawning, smothering fish eggs and in extreme cases, by
interfering with the gills of fish. An increase in suspended solids has the potential to reduce
water clarity, which can impact the light penetration of water and may also affect certain
behaviours of aquatic fauna such as foraging success. Aquatic flora and fauna could also be
impacted upon by an increase in nutrients which are bound to suspended solids. A significant
increase in nutrients can result in excessive eutrophication, leading to deoxygenation of waters
and subsequent asphyxia of aquatic species.

Another potential source of contamination to surface water quality during construction works
would be the potential release of uncured concrete. In the event of uncured concrete entering
surface water, the pH would be altered locally, potentially causing an adverse impact upon
aquatic flora and fauna and causing an alteration to the waterbody substrate.

As the site is at the banks of the River Barrow the potential for construction works to impact
upon surface water quality would be greatly reduced if guidelines and regulations where strictly
adhered to.

A potential source of chemical contamination would be from the release of hydrocarbons from
construction plant and equipment. Hydrocarbons can affect water quality, potentially resulting
in toxic and / or de-oxygenating conditions for aquatic flora and fauna. Pollution could occur
in a number of ways, such as neglected spillages, the storage handling and transfer of oil and
chemicals and refuelling of vehicles.

With regards the stripping of soils and subsoils at the development site, excavated subsoils and
soils would be reused in the reinstatement process where possible. Therefore, there would be
no significant impact upon soils due to excavation activities. Specialist machinery would be
used during construction works to minimise the potential compaction of soils and subsoils.

Control measures would be put in place to ensure that no deterioration in the River Barrow
arises as a result of the construction of the proposed development.

4.3 TERRESTRIAL BIODIVERSITY IMPACTS

Construction activities have the potential to impact upon terrestrial biodiversity through
destruction and loss of habitat, disturbance due to noise and dust, the potential introduction of
invasive species and light pollution.

The construction phase of the development would not result in a direct and permanent loss of
any habitat of significance. The main development site will see the loss of amenity grassland
(GA2) and scattered trees and park (WD5) habitats. With the car park area to cover amenity

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grassland (GA2), recolonising bare ground (ED3) and scrub (WS1) habitats. These habitats
would be considered as having been modified and of low ecological value. Therefore, the loss
of this habitat would not be considered significant.

The construction phase of the development would not result in a direct and permanent loss of
ecologically valuable habitats. The majority of the flora found within the site are ornamental
and recolonising species and are not of conservation status or of high ecological value.

Dust emissions may arise during construction activities, in particular during earth-moving
works, which may have the potential to impact upon photosynthesis, respiration and
transpiration processes of flora due to the blocking of leaf stomata and have the potential to
cause nuisance to fauna. Given the transient nature of construction works, and the scale of the
development, the potential impact to flora and fauna would not be considered significant.

Construction work has the potential to disturb fauna due to the generation of construction noise.
However, construction noise would not be considered to pose a significant risk to fauna owing
to the small scale of the proposed development, the transient nature of works and given that all
vehicles where possible would be equipped with mufflers to suppress noise, as is standard
practice. Where possible, no construction works would be conducted outside of normal
working hours, therefore there would be no disturbance to nocturnal species.

During construction works, there is potential for invasive species to be introduced to the site
through the movement of materials, such as soil and stone, and the arrival of construction plant
and equipment from an area with invasive species. Materials containing invasive species such
as Japanese Knotweed (Fallopia japonica) or Himalayan Balsam (Impatiens glandulifera) are
considered “controlled waste” and, as such, there are legal restrictions on their handling and
disposal. Under Regulation 49(7) of the European Communities (Birds and Natural Habitats)
Regulations 2011 (S.I. No. 477 of 2011), it is a legal requirement to obtain a license to move
“vector materials” listed in the Third Schedule, Part 3. Under Regulation 49(2) of the
aforementioned regulations, it is an offence to plant, disperse, allow or cause to disperse, spread
or otherwise cause to grow in any place any plant which is included in Part 1 of the Third
Schedule.

Artificial lighting has the potential to negatively impact upon nocturnal species, particularly
bat species, as illumination can impact upon their roosting sites, commuting routes and foraging
areas. While some bat species, such as Leisler’s bats (Nyctalus leisleri), may take advantage of
prey concentrating around light sources, other bat species are sensitive to lighting and will
avoid artificially lit up areas. Measures, as outlined in Section 5.3, would therefore be
implemented by the construction works contractor to reduce the potential impact of light
pollution.

The potential impacts of construction works upon aquatic flora and fauna due to a potential
deterioration in water quality are discussed in Section 4.2 above.

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4.4 NOISE IMPACTS

Construction noise, while inherently noisy and disruptive, is temporary in duration. It is

anticipated that the construction of the proposed development would take approximately
eighteen months to complete. The works involving heavy machinery for the purposes of
excavation, the preparation of building foundations and passing construction traffic usually
cause the most disturbances to nearby residents.

Generally, the type of works involved at this development site would include the following:

• Excavation/Levelling: Excavator, dump truck & dozer.

• Foundations: Excavations, cement mixers & concrete vibrators and piling.
• General Construction: Masonry construction, services, drainage and surfacing etc.

There are currently no published Irish guidance documents relating to permissible noise levels
that may be generated during the construction phase of a project. However, the National Road
Authority (NRA) has published the document “Guidelines for the Treatment of Noise and
Vibration in National Road Schemes”, 2004. This document provides a useful reference for
assessing construction noise of the proposed development. The NRA considers that the noise
levels provided in the table below are typically deemed acceptable.

Table 4.1: NRA Acceptable Noise Levels

Days / Times LAeq (1hr) dB LpA (max)slow dB
Monday to Friday (07:00 to 19:00hrs) 70 80
Monday to Friday (07:00 to 22:00hrs) 60 65
Saturday (08:00 to 16:30hrs) 65 75
Sundays and Bank Holidays
60 65
(08:00 to 16:30hrs)

4.5 TRAFFIC IMPACTS

Accessed to the site is from Barrow Street which connects to Maryborough Street. The R430
is approximately 160m to the south of the Barrow Street intersection with Maryborough Street.
The N80 national road is 1.5km via Castlecomer Road and 1.3km via Chapel Street. The N80
connects with the M9 motorway approximately 9km to the southeast.

Construction works have the potential to impact upon traffic volumes in the area, which may
subsequently impact upon the generation of noise and dust emissions.

Traffic impacts may arise via the following:

• Delivery of construction plant and equipment to the site;

• Delivery of raw materials to the site;
• Vehicle movements from staff, sub-contractors and site visitors travelling to and from
the site;

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• Vehicle movements associated with waste removal at the site.

4.6 WASTE MANAGEMENT IMPACTS

It is anticipated that the following categories of waste may be generated during the construction
of the project:

Table 4.2: Categories of Waste Generated During Construction

EWC
WASTE TYPE ORIGIN
CODE
Waste concrete may arise due to surplus concrete from
Concrete 17 01 01
pouring activities.
Wood waste may arise during construction works, including
Wood 17 02 01 building and shuttering works, due to damaged / defected
wood, off-cuts and surplus wood.
Glass waste may arise due to damaged / defected glass and
Glass 17 02 02
accidental breakages.
Plastic 17 02 03 Plastic waste may arise due to damaged / defected products.
Metals (including 17 04 01 - Waste metal may arise due to damaged / defected metal, off-
alloys) 07 cuts and surplus metal.
Excavated soils and stones waste would arise during site
Soils and Stones 17 05 04
excavations and earth-moving activities.
Insulation
materials and
Waste may arise due to damaged / defected insulation panels
asbestos containing 17 06
and off-cuts.
construction
materials
Biodegradable Green waste would arise during site clearance works, with
20 02 01
waste the removal of existing vegetation at the site.

Other waste materials which may arise during construction works in small volumes include:

• Waste Oils and Liquid Fuels – EWC 13 02 and EWC 13 07;

• Waste from Electrical and Electronic Equipment – EWC 16 02;
• Cables – EWC 17 04 11;
• Paints – EWC 20 01 28;
• Wood Preservatives – EWC 03 02;
• Batteries – EWC 16 06.

Wastes from EWC fractions EWC 03 02, EWC 13 02, EWC 13 07, EWC 16 02 and EWC 16
06 may be hazardous.

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Throughout the construction phase, wastes generated would be managed by the construction
works contractor in order of priority in accordance with Section 21A of the Waste Management
Act 1996, as amended, as per the waste hierarchy below.

Figure 4.1: The Waste Hierarchy

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5. ENVIRONMENTAL MITIGATION MEASURES

5.1 DUST MANAGEMENT

The following dust control measures would be implemented by the construction works
contractor for the duration of the construction of the proposed development:

• Cognisance would be taken of the guidelines published by the Institute of Air Quality
Management (IAQM), “Assessment of dust from demolition and construction 2014”;
• Material handling systems and site stockpiling of materials would be designed and laid
out to minimise exposure to wind;
• Prolonged storage of materials onsite would be avoided;
• When transporting materials to and from the site, vehicles would be fitted with covers
where possible to prevent material loss;
• Public roads outside the site would be regularly inspected for cleanliness and cleaned
as necessary. A road sweeper would be used if required;
• While the natural recolonization of exposed areas of soil during reinstatement activities
is preferred, re-seeding would be undertaken where required to promote the rapid
stabilisation of soils;
• Regular visual inspections would be undertaken around the proposed site boundary to
monitor the effectiveness of dust control measures.

Should additional dust control measures be required, for instance during particularly dry
weather, dust suppression measures would be undertaken, including the following:

• Water misting plant, such as bowsers and sprays would be used as required and where
necessary;
• Where practicable, stockpiles of excavated soils and exposed surfaces would be
dampened down via misting plant.

5.2 SURFACE WATER, GROUNDWATER AND SOIL CONTAMINATION CONTROL

The implementation of control measures for dust and materials storage and handling would
reduce the potential for a deterioration in water quality. These measures are outlined in Sections
5.1 above and 5.8 below. The following control measures shall be implemented by the
construction works contractor for the protection of surface water quality and groundwater
quality:

• The construction works contractor would adhere to standard construction best practice,
taking cognisance of the Construction Industry Research and Information Association
(CIRIA) guidelines “Control of Water Pollution from Construction Sites; guidance for
consultants and contractors” 2001 and “Control of Water Pollution from Construction
Sites – Guide to Good Practice”, 2002;

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• Cognisance would be taken of the 2016 guidelines published by Inland Fisheries

Ireland, “Guidelines on Protection of Fisheries During Construction Works in and
adjacent to Waters”;
• Daily visual inspections would be undertaken of the site access road to ensure no silt-
laden surface water runoff leaves the site, with the potential to either join with any
adjacent surface water drainage systems within the vicinity or travel to along the road
network to the road network to the River Barrow;
• Where spoil is generated, this would only be stored temporarily. A designated spoil area
would be established by the construction works contractor within site footprint at the
site. Where possible, spoil would be covered or alternatively, graded to avoid ponding
or water saturation;
• Manhole covers and stormwater gullies will be protected by silt blankets/mats;
• Silt fencing (comprising of a porous filter fabric which detains sediment, or other
similar methods) would be provided along the site boundary with the River Barrow.
Silt fencing would remain in place until the completion of construction works;
• Additional sandbags should be placed along Bachelors Walk to prevent any material
going into the River Barrow;
• Silt control features would be inspected on a daily basis and maintained as appropriate;
• Should water be encountered during excavation works, water would be pumped to a
constructed silt control feature, such as a settlement pond. A filter would be provided
at the pump inlet and, where required, dewatering bags or silt fences would be used at
the outlet to retain any potential silt entrained in the water. Pumping operations would
be supervised at all times;
• Works at the flood defence wall should only be carried out when there is no risk of
flood waters;
• Excavations and earth-moving activities would be planned outside periods of heavy
rainfall, to limit the potential for suspended solids to become entrained within surface
water run-off;
• All construction plant machinery and equipment would be maintained in good working
order and regularly inspected;
• A designated area for the storage of hydrocarbons would be established by the
construction works contractor and inspected on a regular basis;
• Spill kits, adequately stocked with spill clean-up materials such as booms and absorbent
pads, would be readily available onsite;
• The construction works contractor would ensure the relevant site personnel are trained
in spillage control;
• In the unlikely event of a suspected deterioration in water quality within the River
Barrow, due to construction works at the development site, works would immediately
cease, an investigation into the cause undertaken and the relevant NPWS and Inland
Fisheries Ireland personnel informed.

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Additional controls to reduce the potential impact upon soils include the following:

• Specialist machinery (such as tracked machinery) would be used to minimise the

potential compaction of soils;
• Excavated materials would be stockpiled onsite, segregated into topsoil and subsoils,
and reused in reinstatement activities where possible;
• Any fill and aggregate material required onsite would be sourced from reputable, local
quarries.

5.3 BIODIVERSITY PROTECTION PROTOCOL

It is considered that the implementation of the controls and measures outlined in Sections 5.1
– 5.8 would reduce any potential adverse impacts upon the biodiversity in the area. The
following control measures are also recommended to ensure that the proposed construction
works would not have any significant impact upon biodiversity:

• All construction works would be confined as far as possible to the development

footprint;
• Where possible, no construction works would be conducted outside of normal working
hours, to reduce potential noise disturbance to nocturnal species;
• Should a protected fauna species such as Bat species or Otter (Lutra lutra) be found
during the construction works, an officer of the NPWS would be notified prior to the
resumption of construction works;
• Where possible, any vegetation removal works would be scheduled outside of the 1st of
March to the 31st of August period, so as not to disturb nesting bird species;

Construction works have the potential to impact upon bat species due to lighting disturbance
on commuting and foraging habitat. Therefore, the following measures would be implemented
by the construction works contractor:

• Construction works in the hours of darkness, when bats are active (April – October),
would be kept to a minimum;
• Should lighting be required during construction works, it would be of a low height
(without compromising safe working conditions) to ensure minimal light spill. Where
possible and where practicable to do so, timers or motion sensors would be used;
• Directional lighting would be used where possible, by use of louvres or shields fitted to
the lighting;
• White light emitting diode (LED) would be used where possible, which is considered
to be a low impact in comparison to other lighting types.

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5.4 INVASIVE SPECIES CONTROL

The following controls for the prevention / treatment of invasive flora species would be
implemented throughout the construction phase of the development:

• Regular site inspections would be undertaken to ensure that no growth of invasive

species has taken place;
• All relevant construction personnel would be trained in invasive flora species (main
species of concern) identification and control measures;
• If found an invasive species of flora is found growing at the site then an invasive species
management plan must be put in place such as Best Practice Management Guidelines
on Himalayan Balsam (Kelly, Maguire, and Cosgrove, 2008);
• The construction works contractor would ensure that all equipment and plant is
inspected for the presence of invasive species and thoroughly washed prior to arriving
to, and leaving from, the development site;
• In the event of an invasive species listed under the Third Schedule of the European
Communities (Birds and Natural Habitats) Regulations 2011 appearing onsite, works
within the immediate vicinity would cease until the invasive plant has been
appropriately treated and disposed of to a suitably licenced facility, in accordance with
Regulation 49 of the 2011 Regulations;
• Only suitably licenced and trained personnel should use herbicides, following
guidelines and instructions on correct use;
• Herbicides should not be used in or adjacent to watercourses unless application is
targeted in the control of invasive species such as giant hogweed (Heracleum
mantegazzianum).
• Cognisance would be taken of National Roads Authority’s Guidelines on “The
Management of Noxious Weeds and Non-Native Invasive Plant Species on National
Roads”.

5.5 NOISE AND VIBRATION CONTROL

The following noise control measures would be implemented by the construction works
contractor for the duration of the construction of the proposed development:

• Cognisance would be taken of the National Roads Authority’s “Guidelines for the
Treatment of Noise and Vibration in National Road Schemes”, the British Standard
5228: Part 1 “Code of practice for Noise Control on Construction and Open Sites” and
the CIRIA 2015 “Environmental Good Practice on Site”;
• Plant and machinery used on-site would comply with the EC (Construction Plant and
Equipment) Permissible Noise Levels Regulations, 1988 (S.I. No. 320 of 1988). All
noise producing equipment would comply with S.I. No 632 of 2001 European
Communities (Noise Emission by Equipment for Use Outdoors) Regulations 2001;
• All construction activities would take place between 8:00am and 7:00pm, Monday to
Friday, and 8:00am to 2:00pm on Saturdays. Any works which, by necessity, are

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required to be carried out outside of these times would be notified to the relevant bodies
and any potentially effected local residents in good time and prior to specified works
commencing;
• No plant used on site would be permitted to cause an ongoing public nuisance due to
noise;
• Where required, screens or barriers would be installed to shield particularly noisy
activities;
• Deliveries would be organised to arrive during daytime hours (between 8:00am and
7:00pm, Monday to Friday, and 8:00am to 2:00pm on Saturdays);
• Care would be taken when unloading vehicles to minimise noise disturbance. Materials
should be lowered, not dropped, insofar as practicable and safe;
• Regular maintenance would be carried out on all construction equipment, machinery
and vehicles;
• Construction plant would be operated in accordance with the operator’s instructions;
• Engine and machinery covers would be maintained in good working order and would
remain closed whenever machinery is in use;
• Where practicable, all mechanical plant would be fitted with effective exhaust silences
and pneumatic tools fitted with mufflers or silencers;
• Any compressors required would be silenced or of sound reduced models fitted with
acoustic enclosures;
• Construction plant would be selected, where possible, with low inherent potential for
the generation of noise;
• Construction plant would be switched off or throttled back to a minimum when not in
use;
• Staff personnel would be instructed to avoid unnecessary revving of machinery;
• Site personnel would notify the Project Manager in the event equipment or plant
becomes defective, resulting in high noise emissions. Any defective plant would be kept
out of service until the necessary repairs are undertaken.

5.6 TRAFFIC CONTROL

The construction works contractor would undertake site entrance works to facilitate the access
of traffic associated with the proposed development. The construction works contractor would
ensure the following:

• Deliveries to the site would be via suitably contained vehicles, with sheeting and covers
where required;
• Deliveries to the site would be scheduled during the construction hours of 8:00am to
7:00pm Monday to Friday, and 8:00am to 2:00pm on Saturdays;
• Deliveries and removals would be coordinated and scheduled to the site to avoid
congestion on Maryborough Street and Barrow Street;

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• Where possible, large-scale vehicle movements would be timed outside peak hours on
the local road network.
• The contractor shall provide for the safe passage of pedestrian and vehicular traffic and
measures to keep the impact of the works on local roads, and local communities to a
minimum;
• Local roads would be inspected and cleaned as necessary to ensure that access roads
are kept clear of mud and debris;
• Advise haulage contractors on the appropriate routes to and from the site and to adhere
to good traffic management principles;
• Materials would not be delivered to the site until required.

5.7 WASTE MANAGEMENT CONTROL

5.7.1 Waste Storage Area

A designated waste storage area located away from the River Barrow, would be established by
the construction works contractor. Suitable waste receptacles / skips would be provided by the
appointed waste contractor(s) during the construction phase, with skips / bins allocated to
specific waste streams to avoid contamination. The number and size of waste receptacles / skips
would be determined following the appointment of the waste contractor(s). Waste receptacles
would be appropriately labelled.

Where waste fuels and oils are generated, they would be stored within a bunded container
within the designated waste storage area. Any hazardous materials would be stored separately
from non-hazardous waste, and would be stored within bunded containers / upon a bund where
appropriate.

The removal of waste from the site would be undertaken on a regular basis, preventing large
volumes of waste accumulating onsite.

5.7.2 Waste Contractors

The collection of wastes from the site would be undertaken by suitably authorised waste
hauliers, and would only be recycled / recovered or disposed of at suitably licenced waste
facilities.

The construction works contractor would appoint a waste contractor(s) for the construction
phase. The waste contractor(s) appointed for the project would have experience in construction
waste management and would be appropriately licenced, holding the relevant waste collection
permit and/or waste licences for the types of waste anticipated to be generated during
construction works.
The waste contractor(s) would be appropriately licenced in compliance with the following
regulations:

• Waste Management (Collection Permit) Regulations 2007 (S.I. No. 820 of 2007);

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• Waste Management (Collection Permit) Amendment Regulations 2008 (S.I. No. 87 of

2008);
• Waste Management (Facility Permit and Registration) Regulations 2007 (S.I. No. 821
of 2007);
• Waste Management (Facility Permit and Regulations) Amendment Regulations 2008
(S.I. No. 86 of 2008).

The construction works contractor would ensure that copies of all waste contractors’ collection
permits and licences would be available for inspection, as discussed in the “Record Keeping”
section below.

5.7.3 Waste Minimisation

Waste minimisation and prevention would be the responsibilities of the construction works
contractor, who would ensure the following:

• The efficient ordering and purchasing of materials to reduce surplus materials;

• Materials would be ordered in appropriate sequence to minimise materials stored on
site;
• The correct storage of materials to minimise the generation of damaged materials, for
example keeping materials packaged until they are ready to be used and storing
materials which are vulnerable to water damage via precipitation under cover and raised
above the ground;
• The handling of materials with care, to avoid undue damage;
• The return of uncured concrete to the batching plant where possible;
• The re-use of shutters for concrete works;
• Where possible, excavated subsoil and topsoil would be reused for the reinstatement of
the development site.

The construction works contractor would reuse materials onsite where possible. In particular,
inert wastes (such as concrete (EWC 17 01 01), bricks (EWC 17 01 02) and soils and stones
(EWC 17 05 04)) would be used for infilling activities where suitable (and where required).

5.7.4 Management of Waste Streams

As mentioned in Section 4.6 above, wastes generated would be managed by the construction
works contractor in order of priority in accordance with Section 21A of the Waste Management
Act 1996, as amended.

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Excavated Soils and Stones:

O’Callaghan Moran & Associates (OCM) undertook a waste characterisation assessment of
samples from the of made ground and natural soils collected by IGSL Ltd. (Document Ref:
23016). The samples were tested for Total Heavy Metals, Total Organic Carbon (TOC), BTEX
(benzene, toluene, ethylbenzene and xylene) aliphatic and aromatic hydrocarbons,
Polychlorinated Biphenyls (PCB), Mineral Oil, Polyaromatic Hydrocarbons (PAH) and
asbestos. Leachate generated from the samples was tested for arsenic, barium, cadmium,
chromium, copper, mercury, molybdenum, nickel, lead, antimony, selenium and zinc, chloride,
fluoride, soluble sulphate, phenols, dissolved organic carbon (DOC), total dissolved solids
(TDS). See report for detailed analysis of samples and results from Bore Holes (BH) 1-3 and
Trial Pits (TP) 1-5.

Samples from BH1 (1.0m and 2.0m), BH3 (1.0m), TP1 (1.0m), TP2 (1.0m and 2.0m), TP4
(1.0m), TP5 (0.5m and 1.5m) meet the inert WAC they do not meet the soil recovery criteria
for PAHs. The samples have been classified as B-1 suitable for recovery/disposal to inert waste
landfill with increased limits. The samples from BH1 (1.0m) and BH3 (1.0m) meet the inert
Waste Acceptance Criteria (WAC) but do not meet the soil recovery criteria for metal
concentrations. Both samples exceed the 1.5 times trigger level for Copper. The samples have
been classified as B-1 suitable for recovery/disposal to inert waste landfill with increased
limits. See OCM report for waste management options.

Soils and stones arising from excavations would be reused in the reinstatement where possible.
This would be investigated by the construction works contractor and would be subject to
appropriate testing to ensure the material is suitable for its proposed end use.

Any excess excavated soils would be collected by a licenced waste contractor and either reused
for reinstatement activities at other sites if suitable or disposed of as appropriate. Alternatively,
the construction works contractor would investigate if excavated soils can be classified as a by-
product under Article 27 of the Waste Directive Regulations, 2011. If a local use for the
material is identified, and if the proposed end use meets the requirements of the Article 27
regulations, there would be no requirement to send this material to a waste facility.

In the event of any evidence of additional soil contamination being found during work on site,
the appropriate remediation measures would be employed. Areas of potentially contaminated
soil would be isolated and tested for contamination in accordance with the 2002 Landfill
Directive (2003/33/EC). Any work of this nature would be carried out in consultation with, and
with the approval of, the EPA and the Environmental Department of Carlow County Council.
Pending the results of laboratory testing, this material would be excavated and exported off-
site, by an appropriately Permitted Waste Contractor holding an appropriate Waste Collection
permit for this hazardous material, and would be sent for appropriate treatment / disposal to an
appropriately Permitted / Licenced Waste Facility.

Concrete, Bricks, Tiles and Ceramics:

Surplus concrete would be returned to the batching plant where possible. Where concrete,
blocks and bricks arise from construction activities, they would be crushed and used for
ground-fill material where deemed suitable (should infill activities be required). Where these
materials cannot be reused onsite, they would be diverted for recycling if possible.

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Wood:
Waste wood would be reused for shuttering where suitable. Wood that is uncontaminated (free
from preservatives and paints) would be segregated and recycled. Any wood not deemed
suitable for recycling would be disposed of as appropriate.

Metal:
Metal is highly recyclable and has a considerable rebate value. Where metal cannot be reused
onsite, the majority would be recycled.

Other Recyclables:
These include plastic, cardboard and paper. Where possible, the different recyclables would be
segregated onsite and sent for recycling. With regards packaging waste, the construction works
contractor would investigate the possibility of returning the packaging to the supplier.

Mixed Municipal Waste and Other Non-Recyclable Waste:

Wastes not suitable for reuse or recycling would be stored in separate waste receptacles. Prior
to removal from site, the construction works contractor would inspect the receptacles / skips to
ensure they contain no recyclable material or materials which can be reused.

Glass:
Small volumes of waste glass may be generated during the construction phase. As glass can
contaminate other segregated waste streams, it would be collected separately where possible.
The majority of glass would be recycled.

Green Waste:
Green waste may be sent for composting if not possible to reuse onsite during landscaping / re-
instatement activities, or for disposal as deemed appropriate by the waste contractor.

Hazardous Materials:
Hazardous waste would be managed in accordance with the Waste Management (Hazardous
Waste) Regulations 1998 and 2000. Small quantities of hazardous waste may be generated
onsite. Examples of potentially hazardous wastes include fuels and oils, batteries, paints,
adhesives and sealants. Hazardous waste would be stored separately from non-hazardous
waste, would be appropriately labelled and would be stored upon bunds where appropriate. The
construction works contractor would ensure that the appointed waste contractor is licenced to
transport / accept hazardous waste prior to the waste leaving the site. Depending on the type of
hazardous material, the waste may be recovered, recycled or disposed of appropriately.

Waste Electrical and Electronic Equipment (WEEE):

This waste, if generated, would be stored separately from other waste streams and would be
covered pending collection. WEEE can contain hazardous components such as batteries. All
hazardous wastes would be stored in appropriate secure bunded containers prior to removal
from site. Some hazardous wastes may not be stored with other wastes. This would be
determined by the contractor and appropriate precautions taken.

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5.7.5 Records

For each waste movement and for each type of waste, the construction works contractor would
obtain a signed waste docket from the waste contractor, detailing the weight, type of material,
destination of material and whether the material is going for recycling, recovery or disposal.
The construction works contractor would retain copies of the waste contractors’ relevant waste
collection permits and waste licences on file throughout the construction phase.

5.8 CHEMICAL AND HAZARDOUS MATERIALS MANAGEMENT

5.8.1 Concrete

The following controls would be implemented throughout the construction phase:

• The use of pre-cast concrete where possible;

• The delivery and pouring of concrete would be supervised at all times;
• The pouring of concrete would be avoided during periods of expected heavy rainfall;
• Concrete would be poured directly into the shuttered formwork from the Ready-Mix
Truck, reducing the risk of spillage;
• The wash-out of Ready-Mix Truck drums would not be permitted onsite, in the environs
of the site, or at a location which could result in a discharge to surface water;
• Surplus uncured concrete would be returned to the batching plant where possible.

5.8.2 Hydrocarbons

The following controls for the handling and storage of hydrocarbons would be implemented
throughout the construction phase:

• All construction plant machinery and equipment would be maintained in good working
order and regularly inspected;
• Any fuels, oils or chemicals would be stored in accordance with the EPA guidance on
the storage of materials, in a designated bunded area, with adequate bund provision to
contain 110% of the largest drum volume or 25% of the total volume of containers;
• A designated area for the storage of hydrocarbons would be established by the
construction works contractor and inspected on a regular basis;
• Deliveries of fuels and oils to the site would be supervised;
• Fuels / oils would be handled and stored with care to avoid spillage or leakage;
• Where appropriate, small construction plant equipment would be placed on drip trays;
• Any waste fuel / oils would be collected in bunded containers at the designated waste
area and properly disposed of to an authorised waste contractor;
• Spill kits, adequately stocked with spill clean-up materials such as booms and absorbent
pads, would be readily available onsite;

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• In the unlikely event of a hydrocarbon spillage, contaminated spill clean-up material

would be properly disposed of to an authorised waste contractor;
• The construction works contractor would ensure the relevant site personnel are trained
in spillage control;
• Where construction plant shows signs of hydrocarbon leakage, site personnel would
cease the operation of the item in plant in question and notify the Project Manager. Any
defective plant would be kept out of service until the necessary repairs are undertaken.

5.8.3 Excavated Materials

This section should be read in conjunction with the dust control measures relating to the storage
and handling of spoil outlined in Section 5.1. The following controls for the handling and
storage of excavated materials would be implemented throughout the construction phase:

• Spoil would only be stored at the proposed development site temporarily. A designated
spoil area would be established by the construction works contractor away from the
River Barrow and drainage system within Carlow Town Park.
• Spoil would be covered or alternatively, graded, to avoid ponding and water saturation,
in addition to minimising exposure to wind;
• Where required, silt fencing would be placed around spoil areas until such time as the
excavated soil has been used in re-instatement works or removed offsite by a licenced
waste contractor;
• Spoil would be used in the reinstatement process where possible;
• Reinstatement would be undertaken as soon as possible after excavation and earth-
moving works.

5.9 EMERGENCY MANAGEMENT PLAN

An Emergency Response Plan would be prepared for the proposed development by the
construction works contractor, which would cover all potential risks, including environmental
risks, such as fire, explosion, accidents, spillage and leaks. Designated site personnel would be
trained as first aiders and fire marshals, with additional site personnel trained in environmental
emergencies such as spill response procedures.

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6. MONITORING AND AUDITING

6.1 REPORTING AND RECORD KEEPING

The Project Manager, in conjunction with the EHS Officer, would ensure that appropriate,
detailed records are maintained during the construction phase of the development. Records of
all works associated with the proposed development would be completed by the construction
works contractor throughout the construction phase. Environmental records would include
waste and site inspection records and where relevant, environmental incident and complaints
records. Other records may include Safety Data Sheet records and a copy of the Safety File.
Where relevant to the associated works, statutory inspection records would be maintained for
such activities as excavations and lifting gear.

Where necessary and as requested by the local authority, copies of relevant construction
activity records can be made available.

In the event of an environmental incident occurring at the site with the potential to cause
environmental pollution, the Project Manager would notify the clients and the relevant third
parties, as outlined in Section 3.7, as soon as practicable. Such environmental incidents may
include:

• Fire;
• Water pollution event;
• Hydrocarbon or chemical spill;
• Excessive noise;
• Excessive dust.

Any complaints and/or incidents would be reported to the Project Manager. The Project
Manager would be responsible for developing and maintaining a register of complaints and a
register of incidents, with details on follow-up actions. The Project Manager would notify the
clients as soon as practicable of any environmental complaint or incident.

6.2 ENVIRONMENTAL PERFORMANCE MONITORING

6.2.1 Safety Monitoring

The EHS Officer would be present at the development site during working hours, to ensure
activities are undertaken in a safe manner.

6.2.2 Environmental Monitoring

The EHS Officer would be present at the development site during working hours, to ensure
activities are undertaken in an environmentally sensitive manner. The EHS Officer would
undertake regular site inspections and audits, at least weekly, to monitor the environmental
performance of the site and address any potential environmental issues such as dust, litter and
noise. Site inspections and audits would include the following:

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• Assessment of public access roads;

• Assessment of neighbouring properties;
• Chemical and hydrocarbon storage area;
• Waste storage area;
• Spoil area.

The EHS Officer would be responsible for maintaining a register of all environmental
monitoring and would communicate the site’s environmental performance during site
meetings.

6.3 MONITORING COMPLIANCE REPORTS

As noted in Section 6.2 above, site inspections and audits would be undertaken by the EHS
Officer on a regular basis, at least weekly. These site inspections and audits would monitor the
environmental performance of the site.

Where works are determined to be in breach of any specifications outlined within the CEMP,
the EHS Officer shall notify the Project Manager, who would raise a non-compliance report
and notify the clients as soon as practicable. Non-compliance reports may also be raised as a
result of an incident or potential incident, the receipt of a complaint or as a result of a regulatory
inspection or audit.

The non-compliance report would include details on the nature of the non-compliance, the
proposed corrective action required, action taken to prevent recurrence and verification that the
corrective actions have been undertaken and the non-compliance has been closed out. Any non-
compliances would be discussed at the fortnightly meetings between the construction works
contractor and clients.

6.4 PROCEDURES TO REVIEW INSPECTIONS AND STEPS TO ADDRESS NON-COMPLIANCE

The Project Manager would be responsible for reviewing inspections, audits and any arising
non-compliances. A review schedule would be decided upon between the construction
contractors and the clients upon the approval of the CEMP by Carlow County Council.

The Project Manager would notify the clients as soon as practicable of any non-compliances
arising during the construction of the proposed development. The Project Manager would be
responsible for notifying the relevant third parties where required of non-compliances at the
site and would liaise with third parties as necessary as to the outcome of the non-compliance.
All non-compliances would be investigated immediately, and the construction works
contractor would aim to close out non-compliances as soon as possible. As discussed in Section
6.3, the statuses of any non-compliances would be discussed at the fortnightly meetings
between the construction works contractor and clients.

Where it has been determined that revisions to the CEMP are required to ensure recurrence of
a non-compliance does not take place, the Project Manager and EHS Officer would make the
necessary changes to the CEMP and would ensure that the revisions are effectively
communicated as appropriate to onsite personnel and sub-contractors.

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7. CONCLUSION

This CEMP has been prepared to demonstrate the commitment of the clients to environmental
management at the proposed development site, and outlines the work practices and control
measures that would be implemented by the construction works contractor throughout the
construction period to ensure that potential environmental impacts are effectively managed,
reduced or eliminated.

The CEMP is considered a “live” document and would be reviewed and updated as appropriate
upon approval by Carlow County Council and as necessary as construction works progress.

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8. REFERENCES

Bat Conservation Ireland (2010) Bats & Lighting: Guidance Notes for Planners, Engineers,
Architects and Developers

CIRIA (2015) C741 Environmental Good Practice on Site. (Fourth Edition).

CIRIA (2002) Control of Water Pollution from Construction Sites – Guide to Good Practice.

Department of Culture, Heritage and the Gaeltacht (2017) National Biodiversity Action Plan
2017-2021.

Department of Environment, Heritage and Local Government (2006) Best Practice Guidelines
on the Preparation of Waste Management Plans for Construction and Demolition Projects.

EN BS 5228-1:2009 “Code of practice for noise and vibration control on construction and
open sites”.

Environmental Protection Agency (2002) European Waste Catalogue and Hazardous Waste
List.

Carlow County Council (2015) Carlow County Development Plan 2015 – 2021. Available at:
http://www.carlow.ie/wp-content/documents/uploads/carlow-county-dev-plan-2015-2021.pdf

Fossitt, J.A. (2000) A Guide to Habitats in Ireland. Kilkenny: The Heritage Council.

Institute of Air Quality Management (2014) Assessment of dust from demolition and
construction 2014.

Inland Fisheries Ireland (2016) Guidelines on Protection of Fisheries During Construction

Works in and adjacent to Waters.

Kelleher, C. and Marnell, F. (2006) Bat Mitigation Guidelines for Ireland. Irish Wildlife
Manuals, No. 25. National Parks and Wildlife Service, Department of Environment, Heritage
and Local Government, Dublin, Ireland.

Kelly, J., Maguire, C.M. and Cosgrove, P.J. (2008). Best Practice Management Guidelines
Himalayan balsam Impatiens glandulifera. Prepared for NIEA and NPWS as part of Invasive
Species Ireland.

Masters-Williams H., Heap, A., Kitts, H., Greenshaw, L., Davis, S., Fisher, P., Hendrie, M.
and Owens, D. (2001) “Control of Water Pollution from Construction Sites; guidance for
consultants and contractors”.

National Parks & Wildlife Service, Available at: http://www.npws.ie/protected-sites

National Roads Authority (2010) The Management of Noxious Weeds and Non-Native Invasive
Plant Species on National Roads.

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National Roads Authority (2006a) Guidelines for the Treatment of Badgers prior to the
Construction of National Road Schemes.

National Roads Authority (2006b) Guidelines for the Treatment of Otters prior to the
Construction of National Road Schemes.

National Roads Authority (2006c) Guidelines for the Treatment of Bats during the
Construction of National Road Schemes.

National Roads Authority (2006d) Guidelines for the Protection and Preservation of Trees,
Hedgerows and Scrub Prior to, During and Post Construction of National Road Schemes.

National Roads Authority (2004) Guidelines for the Treatment of Noise and Vibration in
National Road Schemes.

Smith, G.F., O’Donoghue, P., O’Hora, K. and Delaney, E. (2011) Best Practice Guidance for
habitat survey and mapping. The Heritage Council, Kilkenny.

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APPENDIX A

PROPOSED DEVELOPMENT LAYOUT

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