Effluent Outfalls An Board Pleanala June 2009 Moville-G/castle Sewerage Scheme

2 Background to this Proposal 1990 Members of DCC Unanimously Agreed: Discharge of effluent & Plant would be sited outside the Lough regardless of level of treatment Modelling Study: DCC stated that the sewage loading must receive a high standard of treatment & that the outfall must lie outside the entrance to Lough Foyle.

3 The Comparison Site A Northwest of Moville Site B Carnagarve Site C East of Greencastle

Potential Outfalls Considered A B C

B C

6 Relevant Reports The Nov Preliminary Outfall Report Compared 2 outfall site; Carnagarve & Portavela January 2005 Site Selection Report Compared 3 sites; Breda Glen, Carnagarve & East of Greencastle

Relationship Between 04&05 Reports 2004 Outfall Report 2005 Site Selection Report EIS Conclusions INPUT

8 How Reports Influenced Each Other Authors of 2004 Outfall Report were made aware that... Site A at Moville had been eliminated on economic grounds. (And more importantly) That JB Barry would be recommending Site B at Carnagarve in their forthcoming 2005 Site Selection Report..

Outfall Report “Following a detailed technical, environmental and economic evaluation of these sites JBB recommended site B, approximately midway between Moville and Greencastle as the preferred site for the new wastewater treatment works”

10 Other Influences on the Outfall Report “Donegal County Council has indicated that they consider the beaches around the Golf Course to be important recreational assets…” Photo Input of DCC into Outfall Selection Report is significant and inappropriate

12 Other Influences on the Outfall Report “Donegal County Council has indicated that they consider the beaches around the Golf Course to be important recreational assets…” “The potential impacts on the small pocket beaches around both of the outfall locations under consideration are likely to be similar therefore any preference between the two locations will depend on the relative significance DCC attaches to the two beaches”. Run Input of DCC into Outfall Selection Report is significant and inappropriate

Outfall Report – Water Quality (Outfall at Carnagarve) Have insignificant impact on southern coastline

Outfall Report – Water Quality A short outfall discharging secondary treated effluent at Carnagarve poses “a significant risk that the guideline limits of the bathing waters directive could be exceeded along the shore where there is a public car park and costal walkway”.

15 Water Quality in 2004 Outfall Report “There is significant potential for sewage discharge in this area to impact on shellfish operations in Lough Foyle if the process and outfall are not designed correctly” However this impact “is likely to be less than that of the present untreated wastewater discharges from Moville”

16 Conclusion of the 2004 Outfall Report “…there is very little to differentiate between the two sites in terms of either marine construction or water quality issues. The slight advantage of site C in terms of potential impact on shellfish operations is balanced by slight advantage in terms of construction afforded to site B due to its more sheltered nature”. Run One of the final statements in the conclusions of this report states that…

Proposed Outfall Location B B1

18 Outfall B1 at Greencastle No outfall outside the Lough included in EIS EIS has no real outfall alternatives The two outfall locations in EIS driven by plant location. Finding the optimum outfall was never a priority

19 Why Include Outfall B1 It is accessible from the Carnagarve site To give the EIS the facade of completeness B1 is closer to sites outside the Lough B1 adds an additional €.5m to the Carnagarve costs Carnagarve more expensive than processing and discharging outside Lough Inappropriate alternatives to present to ABP

20 Carnagarve Outfall Restriction Current outfall location is restricted to 300m Same restriction doesn’t apply elsewhere Previous modelling outside Lough at 600m Previous modelling off Moville at 600m Mixing zone at end of outfall pipe Carnagarve mixing zone near beach & over shellfish beds Carnagarve has onshore drift Whatever is in mixing zone will come ashore

21 Residue of Seaweed on Beach

22 Slick Edging Ashore at Carnagarve

23 Ammonia Modelling Ammonia is detrimental to fish life. No modelling for ammonia undertaken. So why was ammonia ignored in the EIS?

24 Previous Modelling Previous studies included ammonia modelling “Total ammonia concentrations are expected to exceed the guideline level for salmonid fish in the area between the outfall and the coast”

25 Outcome of this Analysis Long term strategy not evident No attempt to find the optimum outfall No real consideration for the Lough as the most important resource in this area Openness & partnership not widely displayed No realisation of the effects this project had

Effluent Outfalls An Board Pleanala June 2009 Moville-G/castle Sewerage Scheme