Notice from CRA - Dublin Port Dumping at Sea

The following information is a notice from the Clontarf Resident's Association regarding the Dublin Port Dumping at Sea Application - Reference No. S0024-01;

A lot of concern has been expressed locally about the current application by Dublin Port to the Environmental Protection Agency (EPA) for a licence to dump 5.9 million cubic meters of dredged material on the Burford Bank.  To give an idea of the size of 5.9 cubic meters (10 – 12 million tonnes), it would fill Croke Park to the roof top 11 times or O’Connell Street to the roof tops 24 times ! ! !

The Burford Bank is a shallow bank sloping inwards towards the bay, situated not far from the Baily Lighthouse and it is more than likely that within a very short time the spoil will wash back into the bay and onto and surrounding Bull Island.  This could have serious implications for the continued existence of tidal flow in the inner bay at the Clontarf Promenade.  We believe that any dumping such as has been applied for should take place well out in the Irish Sea where it is not likely to be washed back in or damage fish stocks.

There have been a number of meetings with concerned groups over the past week and the main issue is the timing of the ‘Notice’ for these works.  With an application such as this, the applicant is obliged to issue a public notice in a newspaper and from that date the public have one month to lodge any submission they wish to make to the EPA. This Notice was published in ‘The Independent’ on Friday 31^st of July, (the Bank Holiday weekend when so many people were heading away on holidays !), so the final date for any submissions is Sunday 30th August. 

At this stage the quickest way to make your submission is to log on to www.Uplift.ie, click on ‘Campaigns’ and fill in the template which they have already prepared. It will only take a few minutes and it will go directly to the EPA.

To assist, we are attaching a document drawn up following the recent meetings and also a statement from the Brendan Price of the Seal Sanctuary which was presented to the Oral Hearing for the original Port application.  These contain several points which you could use in your submission.

We urge you to take a short time between now and Monday afternoon to make a submission. 

The CRA have also included two documents for your attention;

Points for Environmental Protection Agency Submission 

• The World’s 11th largest cruise ship has visited Dublin Port this year without any complications which raises questions in relation to the need for the proposed ABR (Dublin Port) project and extensive dredging.
• On leaving Dublin Port this Cruise ship caused a huge wake which poured over the Southern wall, soaking the walkers there.  Had the Cruise ship moved a little faster it may have washed the people off the wall itself.  There are two problems here: (1) For safety, might this wall need to be closed down when large ships enter and leave the Port. (2) This huge wave will certainly, in time, take its toll on the integrity of the wall itself, a wall that appears to have some structural problems already.  See a video of the wakw here: http://www.thejournal.ie/splendida-wake-2100731-May2015/ 
• Dun Laoghaire Harbour is now devoid of all shipping and this is the perfect location for the cruise business compared to the industrialised Dublin Port. With the new (10M) deeper depth of the Port is will be mostly used by larger commercial vessels that daily would come into the port.

• The Cruise Business is the “Poster boy “of the trade.  In the Bord Pleanala Oral hearing it was stated that ships in general in the last 20 year had nearly doubled in size and it is these that the Port wishes to have come up the Liffey.

• The quantity of material to be dumped is stated at 5.9 Million cubic Meters this weighs between to 10 to 12 Million tons.  Dumping is planned at 2 million tons a year for 6 years. To have an idea of scale of the material - take O Connell Street Dublin.   The amount planned to dump would fill O Connell Street Dublin up to the roof level 24 times. Or another example the playing pitch at Croke Park filled up to the roof 11 times. It is an enormous quantity.

• The Dumpsite (the Burford Bank) is sloping back in towards the city. It is in relatively shallow water so the waves break over it in Easterly storms washing the dumped material back into the Bay and the shore.

• In 2012 Dublin Port did maintenance dredging and dumped 1 million tons there. They checked the site in 2013 and only 15% of the material remained there, 850,000 had been swept off by wave and tide.  How much of this ended up inside the blue lagoon / Sutton creek no one knows. Virtually none of the 6.9 million Cubic Meters - 10 to 12 Million tons will remain on the dumpsite.  It is properly called a dump/dispersal site.

• The planned Fairway ( Sea Lane) is much longer that the previous one as is has to achieve 10 m in Depth. Thus there is a lot of new Sea bed being excavated which has not been excavated before. The planned new sea lane goes out almost to the Bailey light.It is a given that all life on the Sea floor for the 10.32 Km of the Fairway / sea lane would be killed/wiped out. Similarly at the dumpsite all life would be wiped out and all re colonisation killed off again each year when dumping recommenced. Recovery time is all that is discussed none of the dead animals will recover!
• The materials to be dumped are called Sands and Muds. The mud will form a plume and envelope the entire bay as the dumping is planned for all states of the Tide and all weathers 24/7 there will no recovery time at all. There has been no study, no research; no consideration on how much of the material planned to dump will end up inside the Bull Island and possibly blocking up Sutton Creek and the channel itself.  The channel called the Blue Lagoon/ Sutton Creek between Bull Island and the roadway Clontarf Rd to James Larkin road and finally Dublin Rd. is silting up at an alarming rate.  It is only now that people are beginning to see the relationship of the dumping in the Bay and this silting up.  It is possible that the dumping of such a massive amount of material could close in the Lagoon from the sea altogether.  It is obvious that all sand or excess sands in Dublin Bay builds up on the Bull Island and it is also building up inside the Blue Lagoon. It is a given that some of the contaminated materials dumped plus some the heavily contaminated material being excavated for land fill will end up on the silt beds inside the Blue lagoon / creek. This area is one of the most important winter bird feeding grounds in all of Europe.

• The dumping is planned for day and night in all weathers.  The best practice for dumping at sea is to dump only in winds of less than force 4 and in daylight.  The reason for this is that a Mammal observer on the barge would spot Seals, Dolphins or Porpoise at the dump site which is a recognised foraging ground for them.

• Each barge is likely to hold about 3,000 tons of material when fully laden.  To dump, the floor of the barge drops away in the middle and the entire contents leave the barge very rapidly falling down to the sea floor.  It is a given that all life in the water including passing shoals of fish will be wiped out.
• Divers using Dublin bay will be greatly affected by amount of Mud and material in the water reducing the visibility.  This would have the effect of making the water dangerous to dive in. It also affects all seaweed and plants in the water that need sunlight to grow.
• Not only is the water “muddied” during dumping but also for the following year while the dumped material is swept off the dumpsite and displaced all over Dublin Bay.

• Dublin bay has six protected European sites that Bord Pleanala admits will be significantly affected.  

• Rockabill to Dalkey            SAC               EU code        003000

• Lambay Island                     SAC              EU code        000204

• North Dublin Bay                SAC              EU code        000206

• South Dublin Bay                SAC              EU code        000210

• North Bull Island                 SPA              EU code        004006

• South Dublin Bay & Tolka  SPA              EU code        004024
• Dublin Bay is also a Natura 2000 site
• Dublin Bay is also a UNESCO Biosphere reserve site

• The protection offered appears to be useless if Dublin Port can come along and dump their unwanted materials there and have it distributed all over Dublin Bay.

• If the dumping took place outside the Burford Bank (that encloses the bay in effect from the Irish Sea) it would have little effect on the Bay or its environment.

 Seal Sanctuary Statement

For Whom it Concerns,

I'd appreciate this presentation, below being read into the record, by Clontarf Residents Association. I was surprised at such late stage to be asked for advice by stakeholders in current ABR, Bord Pleanala, Oral Hearing and RFI and further concerned to be advised the Irish Seal Sanctuary (ISS) was cited as though giving credence to “non-facts" and impression that seals were a passing presence, merely using the Bay as haul-out and were at no significant or adverse risk by ABR. Nothing could be further from the “facts" and this is at variance with the consultants and NPWS own limited findings on very limited data and observation and wholly at variance with what the ISS or myself representing it, would contend. Indeed we'd heartily concur and even add to their monitoring recommendations on the further information we are happy to provide.

Indeed , were we contacted, we would have been pleased to provide this earlier, identify and address the data deficits and advise on mitigation measures..... We still would! 

However this hearing is at such a crucial stage, and with no disrespect to the company and it's consultants, it is most important the ISS is not perceived to mislead or give false comfort to any party and most especially Bord Pleanala on the threats/impacts for seals and the ecosystem supporting their presence in the Bay. The ISS is grateful to the Clontarf Residents Association for their RFI response to correct misleadingly attributable advices, unsupported by ISS. A summary response for RFI follows, I thank the stakeholders, who responded and trust this of assistance to all.

ABR and RFI.....Dublin Port Development ...Impact on seals and other creatures???   Data deficits?????

The NIS, EIS, Avian Impact Assessment, Marine Mammal Impact Assessment et al are extremely confined by their scoping (Dublin Port, Shipping Channel and Dredge Disposal Site), as though a line could be drawn around the development and beyond it unaffected by plume, sediment transportation, silting, accretion, turbidity and light dilution with knock on effects for re-colonisation, recovery of benthos, fish nurseries and up the ecosystem. The experts consulted as much as agree with this and point to the limited survey data and timeline throughout. For the marine mammals this is greatly understated.  If a line indeed was to be drawn, it should encompass the UNESCO site, SPAs (Special Protected Areas) and proposed MPA (Marine Protected Area).  Bord Pleanala (BP) are correct to seek further information and indeed the responses still fail to address data deficits. This development is not confined by the Liffey Walls and spoil site but at the heart of the 3 estauries and Bay, all of which will be affected by the outfall and limited mitigation measures.

As to the seals, the Irish Seal Sanctuary (ISS) though cited, was not invited by the developer to contribute. Statements such as, "There are only a relatively small number of seals that regularly use Bull Island as a haul -out" and development "will have no long term, significant adverse effects" on seals et al. can not be cited as "fact" when in the 1st instance both species are observed all year round and with pups present and in the latter ongoing observations of disturbance demonstrate how flighty they can be.  It would be highly significant, were they to disappear from the Bay or any part of it. As for so many species cited in the UN Global Biodiversity Outlook 4 they are holding to all remaining habitat and all remaining is important. 

City residents and visitors also hold these wild neighbours and hold them in great affection and esteem. Their ongoing presence, of inestimable value in conservation terms, can only be a point of interest and engagement for cruise visitors entering the Bay and Port. The snap shot sightings and observations cited in the studies are no substitute for long sought, year round monitoring and at variance with the experience of year round observers. This is reflected in the consultant’s recommendations for ongoing monitoring and a pre-works baseline needs be established in first instance. 

The presence and activity of seals in the Bay is year round and they are a highly significant, mixed colony, recorded from the time of the Rotschild reports a century ago. Dalkey Island holds the first recorded remains of Grey Seals (World's 1st Protected Species) for Ireland. The seals are a year round, long recorded presence....feeding, breeding and hauling out, very vulnerable to disturbance and further loss of habitat. They are highly significant residents of UNESCO site, only one of it's kind within confines of capital city and linked to the greater Dublin Bay community. Any disturbance must be regarded with concern, closely monitored and subject to review and mitigation. It is significant the dredging schedule fails to note their October to March breeding season and presence of growing pups, whose mortality is highest in this period. Sea going smolts are noted but not returning salmon or presence of lampreys. It is incorrect to dismiss the seals as a small, part time presence in the Bay arising from insufficient survey and monitoring.....absence of evidence is not evidence of absence and you will find the experts and NPWS agree with me on data deficiency and I heartily concur with them on their recommendation for Marine Mammal Observers (MMOs) and would propose this be increased year round (not just during works but for recovery periods also) to extend to a full time ecologist for the lifetime of the project with additional conservation rangers in each L.A. area. Seal observations are better undertaken by human recording network than technology. In budgetary terms this is minuscule and is the least acceptable level of monitoring and mitigation....far preferable to "professionals differ, good projects (or seals etc.) die!"

I have addressed my observations largely at the seals, in some ways perceived as robust and resilient residents of the Bay, fragile in others....and as indicator species of benthos, water quality, disturbance etc., they certainly merit closer consideration and monitoring. The risks they highlight and adequacy of mitigation measures to be tested, further underline their importance.

The EIS, NIS and associated wildlife "studies" are disjointed, stand alone, expert opinions......informed and valuable in their own right but the report fails to adopt an ecosystem approach to ABR or respond adequately to BP's RFI or mine. The Precautionary approach would indicate further information and better mitigation/contingency planning required. The consultants reports reflect the scientific literature on the local seals and the paucity of information entered it. Indeed how were they to know of the wealth of information with the Irish Seal Sanctuary, Dublin City Council, Sutton Dinghy Club, Clontarf and other residents. The ISS and Bull Island manager have rescued orphaned and injured pups (mostly whitecoats or weaned greys) almost every other year for 30 years from the island, a succession of three hydrocephalus common seals, a common seal only last month etc. The Island has been the venue for many seal releases over the years engaging and educating the public. The Port Company has assisted in rescues on the river and indeed mainly pups taking up temporary residence have been kept under surveillance and monitored for us by Garda cameras. There appears to have been a disconnect between the Company and other stakeholders, depriving the consultants of information and giving rise to An Bord Pleanala’s RFI, which Clontarf Residents Association have corrected to benefit of all and proposed development. It is most important adequate conditions attach all developments potentially impacting the seals and other wildlife.