A study of land-use change and present habitats at Marino Point - a coastal brownfield site in Cork Harbour
A thesis submitted to the University College Cork and the National University of Ireland, Galway in partial fulfilment of the requirements for the Degree of M.Sc. in Ecosystem Conservation and Landscape Management Submitted by Kathrin Köpke B.Sc Project Supervisor Dr. Gavin M. Burnell,
August 2005
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Table of Contents
Abstract 1. Introduction 2. Literature review
2.1 Land-use and Conservation 2.2 Brownfield Site Development and Conservation 2.3 Analysis of European, National and Local Policies Relevant to Coastal Brownfield Site Development 2.3.1 EU- Policies 2.3.2. National Policies 2.3.3. Local Policies 2.4 Introduction to Cork Harbour and ICZM 2.5 Introduction to the IFI Brownfield Site on Marino Point in Cork Harbour 15 15 16 21 22 24 4
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7 7 10
3. Materials and Methods
3.1 Historic Land-use Change 3.2 Analysis of Industrial Operations on Marino Point 3.3 Visualisation of Land-use Change 3.4 Habitat Description and Mapping of the Study Site
27 27 27 28 29
4. Results30
4.1 History of the Land-use Change from Rural to Industrial 4.2. Operational Phase of the N.E.T. and Later IFI Company 4.2.1 Cork County Council Records40 4.2.2 Records of the Environmental Protection Agency from 1995 to 2001 41 30 40
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4.3 Marino Point and Land-use Change Maps 4.3.1 Land-use Change and Map Error Build-up 4.3.2 Woodland, Coastline and Contours - 1842, 1902 and 1935 4.3.3 Infrastructure in 1842, 1902 and 1935 4.3.4 Reclaimed Area of Marino Point 4.4 The Habitats and Areas of Interest on the IFI Brownfield Site
44 44 45 46 47 49
5. Discussion
5.1 Land-use Change History 5.2 Operational Phase 5.3 The Habitats on the Marino Point Brownfield Site
57 57 59 63
6. Conclusion References Appendix 1 Appendix 2 Appendix 3 Acknowledgements
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Plate 1 (front cover): The IFI Brownfield Site - view from Carrigaloe Train station
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Abstract
Brownfield sites are often associated as wastelands linked to contamination issues, while their redevelopment is understood to revitalise an area. However, site specific information regarding environmental features and urban wildlife habitats of the site and historical impacts of previous developments on the surrounding environment is often ignored. Knowledge about the history and the contemporary state of these sites is important when considering sustainable future development of such an area. This thesis discusses the coastal brownfield site Marino Point in Cork Harbour. Historical land-use change, the possible impact of previous industrial operation on the natural environment and the presence of semi-natural habitats were assessed to provide site specific information. Data were collected and collated as part of a desk study and from field visits and this output was further analysed using a Geographical Information System (GIS). Historically, the site was mainly used as woodland with few infrastructural features and land-use change was minimal prior to industrial development. The character of the area was altered from rural to industrial, with the industrial development of the site fragmenting the landscape and leading to habitat loss. Monitoring of the industrial operation on the site appeared to improve over time as a result of enhanced legislation. The industry that was established influenced adjacent habitats but owing to insufficient assessment by the authorities the extent of the effects on these habitats cannot be determined. Current habitats on the site provide shelter to flora and fauna, while bringing continuity into the landscape as transition zones between the adjacent environment and the former industrial production zone. Any future development will have to be assessed with regard to it’s influence on the overall landscape and habitats on and adjacent to the site in order to protect the environment from the impacts of such a land-use change.
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1. Introduction
The recent closures of ISPAT (formerly Irish Steel) in Ringaskiddy and the Irish Fertiliser Industry (IFI) at Marino Point have highlighted the issues regarding planning, remediation and the future development of brownfield sites in Cork Harbour (see Figure 1).
Figure 1: An aerial photograph of the IFI brownfield site on Marino Point in Cork Harbour
Contemporary literature suggests that concerns related to coastal brownfield site development and conservation in Cork Harbour is best addressed through Integrated Coastal Zone Management (ICZM) (Cummins and O’Donnell, in press). This is supported by the fact that re-development in Cork Harbour, such as the remediation of the ISPAT and IFI sites, are to be considered as part of the recently funded ICZM project, Corepoint (COastal REsearch and POlicy INTegration). This project, funded by the EU IIIB Interreg Programme, involves twelve partners from five countries across North-west Europe and is coordinated by the Coastal and Marine Resources Centre (CMRC) at University College Cork.
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The aim of the Corepoint project is to bring research centres and local authorities closer together. Under this project it is intended to utilise European and local experience and resources to provide improved information for planners responsible for local coastal areas as part of an ICZM approach. Research in Cork Harbour is focussed on areas of coastal vulnerability, rates of habitat loss, tourism pressures and development options for the brownfield sites (Corepoint, 2005). The objective of this thesis will be the provision of data that concerns the IFI brownfield site on Marino Point in Cork Harbour. The study will examine historical land-use change, document previous industrial operation and possible impact on the natural environment and record the presence of semi-natural habitats on Marino Point for the Corepoint project. The Geographical Information System (GIS) together with a desktop study will be used to collect, provide and analyse data.
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2. Literature review
2.1 Land-use and Conservation The European landscape is a cultural landscape that has developed through the land-use of its inhabitants. Every populated region, neighbourhood and setting, has developed their own distinctive and active environment, to a certain extent in response to the varying environmental conditions. Urban settlements have evolved through adapting to the surrounding environment in order to take advantage of the value of that area for their residents. For example, in coastal areas port towns developed at locations with easy access to inland regions, making their location a natural passage way (Wright, 1996). Most landscapes of the world are subject to some degree of management. Humans are forceful physical instruments influencing the landscape in both constructive and destructive ways (Naveh and Lieberman, 1993). In central Europe, two-thirds of plant and animal species in the agro-ecosystems are dependent on specific types of human land-use for their existence (Duhme et. al, 1997). Burning, grazing and other human involvement with the landscape have shaped many ecosystems of the cultural European landscape, e.g. heath land. The continuation of traditional management methods is essential for the conservation of these ecosystems, as they only evolved through this kind of specific human land-use over time (Naveh and Lieberman, 1993). However, exponential urban-industrial expansion is leading to the growth of monotonous, urban and industrial landscapes. Industrialisation, with increasing waste production and pollution from energy derived from fossil energy, is linked directly to the loss of natural habitats and species. This destabilises natural cycles and decreases the strength and resilience of the natural environment (Naveh and Lieberman, 1993). The World Conservation Union (IUCN) listed habitat loss and fragmentation as a result of changing agricultural practices and increasing urban and transport networks as the primary reasons for the loss of biodiversity in Western Europe (IUCN, 2005). Furthermore, a stakeholder conference held in Ireland on biodiversity and the EU placed the loss, degradation and fragmentation of habitats as the key reasons for the reducing biodiversity values in the country. The main causes of this loss, degradation and fragmentation of habitats were attributed to: intensive and extractive use of our resources such as agriculture and forestry, abandonment of marginal agricultural lands,
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major infrastructure developments for transport and energy and the spread of urban and industrial areas and pollution (Stakeholders Conference, 2004). Jongman (2002) pointed out that the factors controlling the cultural landscape are not just the physical conditions, climate, topography, soil and water availability; but also the economic conditions, technical possibilities, cultural and social features and the planning and policy settings. Processes of homogenisation and fragmentation in the European cultural landscape have socio-economic and landscape ecological consequences. The intensification and specialisation of land-use decreases cultural and natural diversity. An example of these homogenised landscapes can be seen in the agricultural sector where farm numbers are decreasing while farm sizes are increasing. In this way species of fertile environments are gaining competitive advantage through intensified agricultural management, while species adapted to less fertile conditions are declining. Furthermore, growing road and rail networks, expanding urban areas and the intensive use of land are forming barriers in the landscape. This fragmentation of natural habitats is leading to the deterioration of habitat areas and spatial discontinuity of the landscape and many animal and plant species are sensitive to these changes (Jongman, 2002). Changes in land-use in the last number of decades have happened on different time and spatial scale compared to more historical land-use changes. As a result, the impacts of these changes have increased and natural systems and cultural landscape are not readily able to adapt. Rapidly altering land-use in a landscape that has developed its character over a long period of time will negatively affect the number of species and the ecosystem composition, and will also influence the cultural and traditional features of this landscape (Jongman, 2002). As nature influences the form of settlements, and other associated human developments, these settlements and developments in turn have dramatic influences on their surroundings through accelerating population growth, urbanisation and industrialisation. Modern cities have negative impacts on the natural environment, and a co-existence of human settlements and land-use with the natural environment is only possible through sustainable development (Wright, 1996). Sustainable development was defined by the World Commission on Environment and Development (WCED) in the Bruntland Report 1987, as "an approach to progress that meets the needs of the present without 8
compromising the ability of future generations to meet their needs" (Bruntland Report, 1987). Chapman and Donovan (1996) view sustainable development as a challenge to plan and manage human settlements and land-use in a way that allows effective utilisation of the environmental qualities for everybody, enabling each person to obtain environmental welfare, and ensuring that those qualities are still available for future generations. Principles of sustainable development try to minimise potential future damage through either probability principles, where decisions and actions are based on the probability of a beneficial outcome, or precautionary principles, where policies and methods offer prospects of minimisation or reduction of harmful impacts (Chapman and Donovan, 1996). Sustainability on a significant scale requires long-term policies and, financial dedication and requires strategies to be incorporated at a local level. Furthermore, these local strategies have to be integrated into international agreements such as the International Convention on Biodiversity and the Rio Convention, 1992 (Wright, 1996). In the Rio de Janeiro Earth Summit, Agenda 21 addresses the integration of land-use and planning, energy conservation, waste management and other issues and suggests that these be examined at local level in consultation with local people. This public participation is a fundamental notion of sustainable development at all levels of planning to ensure that everyone’s needs are considered (Chapman and Donovan, 1996). However, Clark (2001) criticises the frequent use and promotion of sustainable development as too rhetorical. Economic pressure to maximise the site occupancy and value of a development supports market-directed outcomes and seems to give planners and politicians few prospects to engage in wider objectives of sustainability, such as combating social exclusion effectively. Furthermore, development is widely perceived as the greatest threat to sustainability by the general public and many politicians. Clark stresses that vision must be applied to make sustainable development more than an aspiration and that political mobilisation and mass education on the subject are necessary to change behaviour on all levels of public and private life. Issues regarding land-use not only concern the conservation of the species, ecosystems and traditional features in the landscape, but also reflect the conflict that can result from 9
the different types of utilisation of the limited resource of any landscape. Conservation planning and management strategies have to classify and consider landscapes and their ecosystems according to their ecological and economic potential, the degree of human modification and impact and their resulting conservation planning and management requirements (Naveh and Lieberman, 1993). With regard to the implementation of principles of sustainable development, it is essential that the effects of human behaviour on the ability of the environment to generate and distribute environmental welfare is understood on all levels and by a wide public (Chapman and Donovan, 1996). Clearly landscape care, planning, management and ecology in the cultural landscape with its ecotones of rural and urban areas are all closely interlinked with all other aspects of regional and urban planning (Naveh and Lieberman, 1993). Biodiversity targets that protect and enhance the diversity of species, ecosystems and landscapes have to be implemented into regional land-use planning. This requires nature conservation guidelines and programmes that are specific to the landscapes in question (Duhme et. al, 1997). Sustainable land-use requires a detailed analysis of the land-use itself, and of land-use changes and its impacts. It is the objective of spatial planning for sustainable development to coordinate function and space in a manner that allows the best mutual relationship between human development and natural potential of an area (Jongman, 2002). In the context of urban areas, land-use issues are often related to disturbed or even contaminated areas associated with brownfield sites. These sites are part of the overall landscape influencing its ecological and social functions and their development and conservation values are discussed in Section 2.2. 2.2 Brownfield Site Development and Conservation Investigating industrial land-use, Muir (1996) pointed out that its function from being the main economic drive of cities in the 19th and 20th centuries has fundamentally changed. The decline of heavy industries in developed countries of the western world through the development of new materials, power sources or production processes is reflected in a new industrial location pattern. Areas that are close to or within the cities have become available for infill developments because of the relocation or decline of many heavy industries such as mining and mineral production, the textile and clothing industry and ship and railway building. These newly available sites afford local 10
planning authorities the opportunity for new land-use developments such as the creation of public spaces. However, this land is limited, especially in urban and city locations and therefore tends to be high value. Alternative developments have to be considered in terms of available finances, policies regarding the area and possible impacts of this land-use change on the surrounding natural and human environment (Muir, 1996). These sites, which Muir (1996) described as available for infill development, are also known as brownfield sites. The US Environmental Protection Agency gives the following definition of brownfield sites “…with certain legal exclusions and additions, the term `brownfield site' means real property, the expansion, redevelopment, or reuse of which may be complicated by the presence or potential presence of a hazardous substance, pollutant, or contaminant.” (US EPA, 2005). However, the European Environment Agency gives a definition within a wider context as “Land within the urban area on which development has previously taken place.” (EEA, 2005). Brownfield sites are mostly situated in cities centres and urban areas and can be derelict industrial and railroad amenities or manufacturing plants, and depending on their industrial provenance, these sites may have varying level of pollution. These sites may also be smaller commercial or residential areas and the majority of brownfield sites have low to medium levels of known or assumed contamination resulting from ordinary waste i.e. non-hazardous rubbish (McCarthy, 2002). However, some 400,000 brownfield sites in North America and 750,000 brownfield sites in Europe are assumed to be heavily contaminated from former military or industrial activities (Hough, 2004). Issues concerning the redevelopment of brownfield sites are universal in their character and coverage and there are a large number of sites to consider. For example in Europe alone in 1993, around 100,000 brownfield sites were documented in the United Kingdom, over 200,000 sites were identified in Germany and above 110,000 in the Netherlands (Moore, 2002). Brownfield site remediation and reuse reduces the adverse effects of potential soil and water pollution of these sites. It can help to decrease the conversion of agricultural and rural areas to urban utilisationand therefore reduce the possibility of environmental problems related to urban sprawl, such as fragmention and destruction of wildlife habitats. Furthermore, brownfield redevelopment can potentially promote economic growth of an area. However, many investors withdraw from potentially contaminated sites owing to possible liability costs arising from the clean up under hazardous waste site legislation (Alberinia et al., 2005). 11
Hough (2004) stressed that the inheritance of contaminated areas from the industrial period is a pressing issue. Contamination can be dealt with using several approaches; however contaminated sites, such as contaminated river sediments, are often left undisturbed. Contaminated sites or the contaminant are in many cases excavated and disposed of, which is the traditional remediation technique, shifting the legacy to another site and to another time, for future generations to deal with. Treatment on site could involve bioremediation through enhancing the ability of microrganisms, either found on site or introduced, to decompose the contaminant. It is obvious that the contamination of soils and groundwater has to be tackled on many levels, as biological, technical, jurisdictional, financial and legal issues have to be addressed. Furthermore, issues of human health and safety can arise from the influence of the contaminant on natural systems. For example contaminants can be transferred into the food chain through the uptake by plants on to wild or agricultural animal species (Hough, 2004). Hasselriis (2004) demonstrated in his book review of brownfield sites that dealing with contaminated sites is also a public process. In the remediation process, many factors have to be considered in order for plans to be successfully implemented and adequate finances secured. An analysis of the contamination present is necessary to complete plans for the required remediation and would include, for example, information about the development of the infrastructure needed to implement these plans. Successful projects dedicated substantial parts of their operation to gaining public awareness and participation, thus minimising worries and hesitation towards the projects resulting from a lack of knowledge (Hasselriis, 2004). Land-use policies have to challenge dual concerns regarding brownfield sites as outlined by McCarthy (2002). 1. Liability for contamination, uncertainties regarding clean-up standards and available funding for redevelopment have to be addressed and regulated in a way that reduces obstructions towards private redevelopment of brownfield sites. 2. Furthermore, issues of wider community concern such as incorporating public safety, providing work and training, revitalisation of the area and achieving protection of environmental features of the site and its surrounding area need to be integrated into the redevelopment of brownfield sites.
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Sustainable development issues have to be addressed that are site specific; incorporating marketability of the site, social costs and benefits, environmental cost and benefits and public participation (McCarthy, 2002). De Sousa (2003) showed that sustainable development in urban areas has been given significantly more consideration by policy makers and planners in North America and Europe since the mid-1980s. The often central location of brownfield sites can turn them into key centres for the revitalisation of an urban area. Economic opportunities, which can result from the redevelopment of brownfield sites into valuable industrial, commercial and residential assets, are widely recognised. However, De Sousa (2003) also indicated that fewer planners and developers have considered the potential social, environmental and economic prospects that can arise by using these sites to enhance green spaces in the urban environment. The greening movement has played an important role in the development of sustainable areas in Europe. For example, in Britain over 19% of brownfield sites were restored to green spaces between 1988 and 1993, which is more than any other end use of these areas. Conversely, North America has focused on economic reimbursement from industrial, commercial or residential redevelopment (De Sousa, 2003). Brownfield sites near waterfronts or in the cities have often changed into areas of special plant and animal assemblages, frequently protected by security fences. In many of these areas their greatest conservation value remains intact but ironically redevelopment and reclamation often replaces the natural diversity (Hough, 2004). Brownfield sites are widely seen as wastelands associated with undesirable amenity and social use supporting the view that any development of these sites improves the area (Harrison and Davies, 2002). The perception of brownfield sites as unsightly is linked to the lack of knowledge about these places. These often industrial environments of railways, grain silos or steel mills belong to our industrial heritage, where new life has populated the areas, which is of ecological interest (Hough, 2004). Harrison and Davies (2002) showed that urban areas are ecologically different from rural areas in that non-native and native species have colonized places and live in unusual assemblages. Scientific studies investigated by the authors highlighted the high biological diversity as a transient property of brownfield sites. These sites if left alone become colonised, and in that period of transition it is recognised that these areas show 13
high species diversity. Furthermore, it is also recognised that some species, which are now rare, can be found in these areas, thus supporting the idea of “urban reservoir populations”. The idea suggests that a few individuals of certain species have always lived in that area and survived and adapted to these brownfield sites, while in the wider countryside the same species declined through the intensive use of chemicals. As in other habitats of the cultural landscape such as the orchid rich calcareous grassland, which is protected for the rarity of species and well recognized for its biodiversity value, management is needed to achieve and preserve the desired status of diversity or the protection of rare species and unusual assemblages of species (Harrison and Davies, 2002). Harrison and Davies (2002) pointed out that urban brownfield sites are often not recognised as distinctive habitats in national biodiversity plans or best practice manuals promoting environmentally sound methods of redevelopment. This is a result of the lack of scientific knowledge regarding these sites and the non-existence of methods enabling systematic surveys and evaluations of such habitats. Studies are needed to establish how communities of species colonise and compete within these so-called wastelands to enable the management of these areas in order to enhance and maintain high biodiversity levels. The authors stressed the need for more studies focusing on the processes of forming partnerships across sectors, which enable scientific, local and political knowledge to be collected, used and challenged within redevelopment processes (Harrison and Davies, 2002). The brownfield sites of an area have to be accepted for their ecological and development value. Policies should recognise and determine opportunities to enhance the natural and historical landscape of cities, while providing alternative places to study natural processes and history (Hough, 2004). It is evident from the literature that the following factors need to be considered when sustainably redeveloping brownfield sites: • • • • • Contamination of the site and liability issues regarding the contamination Public safety and clean-up standards of the site Available funding for redevelopment Revitalisation of the area to provide alternative land-use options facilitating work and training Protection of environmental features and urban wildlife habitats of the site and in the surrounding area 14
• •
Protection of the industrial heritage of the site Inclusion of stakeholder interests
This thesis assesses some of these key factors with respect to the IFI brownfield site in Cork Harbour. Emphasis will be given to the study of factors related to the protection of environmental features and urban wildlife habitats within and around the area and to understanding the historical land-use change/industrial heritage, which led to the present status of the brownfield site. 2.3 Analysis of European, National and Local Policies Relevant to Coastal Brownfield Site Development 2.3.1 EU- Policies European policies are of significant importance in relation to coastal brownfield site development. Policies can have value led guidelines and perception led guidelines. Value led guidelines result in detailed regulations based on the prescription of values to be obtained as, for example, in EU Directives. Perception led guidelines are more general and are opinion based such as those in most local planning policies (LOSPAN, 2001). The EU Habitats Directive (CEC, 1992) designates and protects Special Areas of Conservation (SAC). SAC’s are designated on the basis of particular rare or endangered habitats or species, as listed in Annexes I and II of the EU Habitats Directive. The Directive provides for the setting up of an ecological network of protected areas for all EU member states, referred to as Natura 2000. Natura 2000 sites are established as a requirement of the EU Habitats Directive and Birds Directive (1979), and are sites that are considered of importance on a European level (LOSPAN, 2001). The Habitats Directive can be relevant to brownfield site redevelopment in coastal areas because the redevelopments or the site itself in its current state could influence the quality of the designated areas. The EU Birds Directive (79/409/EEC) designates important areas for birds as Special Protection Areas (SPA). Under the European Directive SPA’s are designated in order to develop a network of areas that are protected for birds in Europe (LOSPAN, 2001). The importance of the Birds Directive regarding the redevelopment of coastal brownfield
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sites is similar to the Habitats Directive, but also as many coastal areas are designated to be important for migrating birds. The Water Framework Directive (2000/60/EC) rationalises and updates existing water legislation and provides for water management on the basis of River Basin Districts (RBD's) (Water Framework Directive, 2005). The Directive establishes a framework for the accomplishment of good quality in all waters of the European Community by 2015. Good quality is defined in the Directive as where biological and/or chemical qualities are of only minor variation compared to the natural state of the water. Furthermore, the sustainable use of water resources and the elimination of the discharge of hazardous substances into waters are put forward (Overview of Water Framework Directive, 2005). This European Directive is important concerning the issue of coastal brownfield site contamination and its influence on water quality as well as the impact that possible redevelopment could have on water quality. The European Communities Environmental Impact Assessment Directive (85/337/EEC) governs developments that could affect important international or national conservation sites. Major developments that require mandatory Environmental Impact Assessment (EIA) are listed in Annex I of the Directive and developments for which an EIA is optional are listed in Annex II of the Directive (LOSPAN, 2001). Brownfield site redevelopments are, depending on their nature and locality, mostly associated with major developments and therefore would require an EIA. 2.3.2. National Policies The Local Government Planning and Development Acts from 1963 to 1998 provide the framework for the planned development of cities, towns and other areas, and are therefore applicable to the redevelopment of brownfield sites. The Acts call for the composition of development plans and include control measures for development regarding the environment. The Local Government Planning and Development Regulations 1994 replaced all existing regulations under Local Government Acts 1963 to 1993. These regulations outline planning applications and appeals procedures, categorize developments that are not liable for planning permission, and detail the procedure of public notice and consultation for specific categories of development by State and local authorities. Furthermore, the regulations set up guidelines for Environmental Impact Assessment as a mechanism to control development. The Local 16
Government Bill 2000 established Strategic Policy Committees (SPC) to advise the Councils on policy matters. Under this Bill the local authority must maintain contact and consult with its local community, and promote participation. In addition, County/City Development Boards (CDB) have to prepare strategies for the economic, social and cultural development of their area. Corporate Policy Groups (CPG) have to be established to advise and assist the elected council in the formulation, development and monitoring of policy for local authorities and Section 68 obliges the local authorities to support high environmental standards and sustainable development (LOSPAN, 2001). The European Communities (Environmental Impact Assessment) Regulation 1989 and Amendment Regulation 1994 brings the EC EIA Directive (85/337/EEC), discussed previously, into Irish law for developments (except motorways) and is therefore highly relevant to the redevelopment of brownfield sites. These Regulations from 1989 and 1994 contain statutory procedures, which govern the approval or rejection of a proposed development. If a development requires an EIA the information must be supplied in form of an Environmental Impact Statement (EIS). The Amendment Regulations 1994 adjust the legal framework concerning EIA so that Integrated Pollution Control (IPC), licensed by the EPA (Environmental Protection Agency) can operate (LOSPAN, 2001). The Environment Protection Agency Act, 1992 established provisions for the protection of the environment, the control of pollution and created the Environmental Protection Agency (EPA). The EPA carries out executive functions to provide for the purpose of the act. The act and the EPA have an important bearing on any development of land and therefore the redevelopment of brownfield sites. Perception guidelines related to landuse are the licensing, regulating and control of activities to protect the environment. The EPA prepares guidelines for information needed in an EIS regarding development of land, and identifies and publishes standards and procedures for the selection, management, operation and termination of use of landfill sites for domestic and other waste. Furthermore, the EPA regulates and gives licences for large, complex, industrial or other processes where pollution can be significant on the basis of IPC. IPC licences are granted if the best available technology is used to prevent pollution and classifies the licensable land-use. The EPA also directs the environmental activities of local authorities (LOSPAN, 2001).
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The Waste Management Act, 1996 proposes the establishment of waste management plans by local authorities. The plans should prevent or minimise the production of harmful waste, promote and support the recovery of waste and control the disposal of waste that cannot be prevented or recovered. All these actions should be carried out without causing environmental pollution and should adhere to the polluter pays principle. The EPA and local authorities have to monitor the nature, extent and effects of emission to the environment, deriving from the holding, recovery or disposal of waste. Furthermore the EPA has to compose a national ‘Hazardous Waste Management Plan’. The Act regulates the holding, collection and movement of waste and a waste licence has to be granted before waste is disposed of or recovered from a civic waste facility. Guideline led principles prohibit the holding, transport, recovery or disposal of waste in a way that can cause environmental pollution. Additionally, the transfer of waste to any person other than authorised persons is prohibited and any person engaged in agricultural, commercial, or industrial activities is obliged to take all rational steps to prevent or minimise the production of waste. Value led guidelines include substantial penalties of up to €10 million and/or ten years imprisonment or liability for clean up measures (LOSPAN, 2001). This act is particularly significant for the clean up of brownfield sites and for possible future waste production, if the brownfield site is redeveloped. The Derelict Site Act 1990 replaces the Derelict Site Act from 1961 and directly relates to the issue of brownfield sites and their redevelopment where such sites have become derelict. The Act regulates processes to prevent or control derelict sites, and gives requirements for imposing an annual levy on certain sites. Perception led guidelines include the establishment and maintenance of a register of all derelict sites in each local authority area. Furthermore, every owner and occupier has to take measures necessary to prevent land becoming derelict or continue to be derelict. Value led guidelines state that the annual levy for certain derelict urban areas, was initially set at 3% of the property market value (LOSPAN, 2001). Finance Acts, 1986 to 1998 provide a number of incentives to promote development and reconstruction in certain areas, which could be beneficial to particular redevelopment options regarding brownfield sites. The guidelines are value led. For example, the Finance Act 1991 provides financial incentives for development in designated areas. The Finance Act 1994 provides Urban Renewal Relief for urban designated areas, 18
giving financial incentives such as capital allowance for non-office commercial buildings, accelerated capital allowance for industrial buildings, double rent allowance or residential owner occupier allowance (LOSPAN, 2001). The Wildlife Act 1976 and the Wildlife Amendment Act 2000 provide the legal framework to protect wildlife and places this protection under the responsibility of the National Parks and Wildlife Service (NPWS). The NPWS established Statutory Nature Reserves, which are strictly, protected areas designated for the conservation of plants, animals and their habitats. Furthermore, Areas of Scientific Interest (ASI) were designated owing to their ecological and geological importance. Many of these areas are now designated as Natural Heritage Areas (NHA - areas of special interest because of their fauna and/or flora as individual species or community assemblages or for its geology or topography (LOSPAN, 2001). These areas were given legal status with the amendment of the Wildlife Act 1976 in order to develop a national network of protected areas of natural heritage and geological importance. Other objectives of the Wildlife Amendment Act 2000 include strengthening the protection of Special Areas of Conservation (SAC) and enhancing several existing controls and measures that protect wildlife (Irish Legal Information Initiative, 2005). A perception led guideline relevant to the land development is the Acquisition of Land Regulation 1978 under the Wildlife Act 1976, designed to give published notice under section 55 in the Act, if land is intended to be purchased (LOSPAN, 2001). These Acts have to be considered in conjunction, when contemplating brownfield site redevelopment, so that activities related to any development or the development itself does not contradict the protection of wildlife and designated areas. The European Communities (Natural Habitats) Regulation 1997 brings the EU Habitats Directive (CEC, 1992), discussed previously, into Irish law and deals with designation and protection of Special Areas of Conservation (SAC). Ireland has submitted 241 candidate SAC sites to be designated as Natura 2000 sites. The EU, referring to the classification from January 2000 (LOSPAN, 2001), has deemed the submission of SACs, which should be designated as Sites of Community Importance (SCI), as insufficient. Article 18 of the Regulation is particularly important in relation to brownfield site development. The article relates to operations or activities that are conducted, or proposed to be conducted, outside the protected site that could have adverse effects on the integrity of a protected site of European importance. The 19
implication of these operations or activities for the site needs to be assessed and can be prohibited if they show that the objectives and the integrity of the site is in breach (Irish Statute Book, 2005). The European Communities (Conservation Of Wild Birds) Regulation 1985 and Amendment Regulations 1986, 1994, 1994 (number 2) and 1995 bring the EU Birds Directive (79/409/EEC) into Irish law, designating important areas for birds as Special Protection Areas (SPA). Under the European Directive, SPA’s are designated in order to develop a network of areas that are protected for birds in Europe (LOSPAN, 2001). Again it is important that the development of a brownfield site will not contradict the protection of birds and their designated areas. The Heritage Act, 1995 establishes the Chomhlaire Oidhreachta, the Heritage Council, which has been given the task of increasing the public awareness of and interest in national heritage. Through perception led guidelines the Heritage Council recommends policies and priorities that identify, protect, preserve and enhance national heritage. The Heritage Council consults or advises public authorities regarding the maintenance, preservation, restoration and improvement of heritage building owned by such authorities (LOSPAN, 2001). The Heritage Act influences the development of land and brownfield sites in a similar way to the European Communities (Natural Habitats) Regulation, the European Communities (Conservation Of wild Birds) Regulation, the Wildlife Act 1976 and the Wildlife Amendment Act 2000, in that development should not conflict with the objectives of this act but, rather, consider these and work towards their success. The National Development Plan (NDP) 2000-2006 is a development strategy promoting infrastructural development, education and training, production and social inclusion. The plan includes a framework for more balanced regional developments in these sectors. Brownfield site redevelopment can have a considerable influence on the sectors mentioned above, owing to their often central location in urban and city areas and any redevelopment should correspond to the strategy of the NDP. Perception led guidelines of the plan concentrate on the development of social and economic infrastructure to enhance the potential of less developed areas, and sustain levels of infrastructure that are seen as satisfactory and beneficial for development of areas (LOSPAN, 2001).
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2.3.3. Local Policies County Development Plans, which are reviewed every five years, state local authority policies for land-use and development control and promotion in each county. The Cork County Development Plan, 2003 outlines the objectives for land-use planning and management in County Cork. These objectives state that development proposals should indicate their suitability and compatibility to the primary uses of a proposed development area and identify problems that are caused by intensification or expansion of an existing land-use, which is not the primary use. Overall, the County Development Plan encourages the best use of land through the application of appropriate planning objectives in order to protect and enhance the overall character of the county. The Plan tries to avoid concentration of planning policies for development of green field sites because this can be unsustainable, requires additional services and transport, and consumes land at the edges of settlements thus causing urban sprawl. In relation to brownfield sites the Plan encourages redevelopment with sound management proposing mixed uses of areas, conversion of industrial and warehouse buildings, refurbishment of derelict buildings, new housing and other uses. The Plan also declares that Cork County Council maintains a list of derelict sites and owners of these sites can be levied an annual tax of 3% to 10% of their value. The objectives for brownfield land (Zones 2-4) include the promotion of development in a considerable amount of browfield sites within the lifetime of the Plan (Cork County Council, 2003). The Port of Cork Strategic Development Plan (2002) is the result of the Port of Cork Strategic Development Studies: Stage one, two and three covers 1999, 2000/2001 and 2002. This series of reports assisted the Port of Cork to develop a strategic development plan for the Port and its surrounding area (LOSPAN, 2001). The studies particularly focussed on future developments required to accommodate the displaced City Quay berths and a new container terminal. Several locations have been studied including the brownfield sites of Cork Harbour. Marino Point, the former IFI brownfield site, (the focus of this research), was examined as a potential option for a new container terminal. The interest in this site was as a result of its adjacent deep-water port and existing rail connection. However, issues regarding navigation, poor road access and environmental designation in the proximity of this location were noted and the site is currently not considered for Port of Cork redevelopment interests (Port of Cork, 2002).
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2.4 Introduction to Cork Harbour and ICZM The coastline of County Cork is approximately 1,094 km long and makes up one-fifth of the Irish national coastline. About 65% of County Cork’s population live in close proximity to the coast. This coastline contains areas of important economic activity such as the Port of Cork (Cork County Council, 2003). Cork Harbour is situated in a gently undulating landscape consisting of built infrastructure, shallow cliffs, intertidal mudflats, reed beds, shingle and rocky foreshores. This natural harbour provides a sheltered environment with deep water channels attracting shipping and boating activities. The area contains many man-made and natural features that give the harbour its unique and historic character (Cummins and O’Donnell, in press). The large expansive Harbour can be divided into the City Harbour and the greater Harbour area, which can be described as an estuary landscape character type with mixed rural and urban areas. In Cork City the docks, cranes, warehouses, silos and ships portray the working face of the harbour. The overall Harbour includes industrial, residential and recreational areas and encompasses islands and shorelines with fertile farmland and wildlife habitats. At the harbour mouth, two historical hilltop forts, Camden and Carlisle, are landmarks in this landscape (Lyons and O’Suilleabhain, 2004). Cork Harbour is the key seaport in the south of Ireland with public port facilities at the City Quays, Tivoli industrial and dock estate, Ringaskiddy deepwater and ferry terminal and Cobh cruise terminal (Port of Cork, 2004). Cork Harbour and Port form the largest industrial area on the south coast of Ireland, providing employment for large numbers of the local population. Chemical and pharmaceutical industries are concentrated in Little Island and Ringaskiddy and Ireland’s only oil refinery is situated at the harbour in Whitegate (Cummins and O’Donnell, in press). The area is one of the largest natural harbours in the world and contains important wildlife habitats such as the extensive mudflats around Lough Mahon, the Douglas Estuary, the North Channel, Lough Beg, Saleen, Rostellan and Whitegate (Cummins and O’Donnell, in press). A number of river estuaries are situated within this sheltered sea bay. Areas of salt marsh and some small freshwater or brackish lagoons can be found around the extensive intertidal mudflats. The two large areas of open water,
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Lough Mahon and the lower Harbour, are separated by Great Island (BirdLife International, 2005). Cork Harbour gives shelter to the largest number of wintering birds on the east and south-east Irish coast and is of international importance for approximately 20,000 waders and 5,000 wildfowl (Cummins and O’ Donnell, in press). The area is an important site in Ireland for breeding Common Tern (Sterna hirundo) and for wintering Great Crested Grebe (Podiceps cristatus), Red-breasted Merganser (Mergus serrator), Oystercatcher (Haematopus ostralegus) and Lapwing (Vanellus vanellus). Furthermore, the Harbour supports Whimbrel (Numenius phaeopus) and other species of national importance, including Cormorant (Phalacrocorax carbo), Common Shelduck (Tadorna tadorna), Wigeon (Anas penelope), Teal (Anas crecca) and Golden Plover (Pluvialis apricaria). Due to its importance for birds, the area is designated as Special Protection Area (SPA) and Ramsar Site for wetland protection with 1,436ha of designated area (BirdLife International, 2005). Other Cork Harbour and estuary designations exist to protect wildlife habitats such as salt marshes, reed beds and intertidal mudflats of national and international importance. National Heritage Areas (NHA) are designated in Douglas Estuary, Great Island Channel, Lough Beg, Rostellan Lough/ Aghada Shore/ Poulnabibe inlet, Whitegate Bay and Cuskinny Marsh (Cummins and O’ Donnell, in press). These areas are designated to protect nationally important wildlife habitats, landforms and geomorphologic features and the flora and fauna living in theses areas (Lyons and O’Suilleabhain, 2004). The candidate Special Area of Conservation (cSAC), the Great Island Channel, is designated to protect habitats and associated flora and fauna that are rare or threatened in Europe (Lyons and O’Suilleabhain, 2004). Furthermore, the EU Freshwater Fish Directive designates the River Lee as a Salmanoid river from its source to the Cork City Waterworks. Specific water quality standards and pollution control are an obligation to maintain a certain water quality (Cummins and O’Donnell, in press). The quality of the habitats and the overall condition of Cork Harbour is affected by many human activities. These activities include coastal development, waste disposal, coastal agriculture, transport, increased recreational use of the area, and overexploitation of the harbour’s natural resources (Cummins and O’Donnell, in press). For example, urban and industrial developments have already led to the loss of intertidal 23
habitat including mudflats. Furthermore, the quality of some mudflat habitats is decreasing due to the invasion of non-native cord grass Spartina sp., intertidal shellfish cultivation, and pressure from recreation and amenity interests. Additionally, the intensive industrialisation of Cork Harbour could be a potential pollution threat to the wildlife habitats as well as the overall quality of Cork Harbour (BirdLife International, 2005). Issues in the area of Cork Harbour can arise owing to divergent stakeholder interests and increasing human pressures on the natural environment and these issues can lead to potential conflict. Different stakeholder interests in the area include established landuses, deep water utilisation, environmental protection, infrastructure, recreation, heritage, amenity, waste management and tourism (Lyons and O’Suilleabhain, 2004). In coastal areas the concept of Integrated Coastal Zone Management (ICZM) as outlined by Cummins et al. (2004), has the aim of reducing problems arising from such conflicts and pressures, while creating ethical and economic benefits. ICZM aims to achieve these goals with an integrated management approach by: • • • • • adopting a wide ranging view of inter-related problems, making decisions based on good data, working with natural resources, involving all stakeholders and relevant parties of administration and using a range of instruments for coastal management (i.e. laws, plans, economic instruments and local Agenda 21s etc.). ICZM is concerned with the sustainable use of the world’s marine and coastal resources and has achieved international and political legitimacy through the acknowledgement by Agenda 21 at the Earth Summit in Rio de Janeiro, 1992 (Cummins et al., 2004). Issues in Cork Harbour related to development, conservation of the natural environment and different stakeholder interests should be addressed through the ICZM approach in order to facilitate the sustainable use of the area. 2.5 Introduction to the IFI brownfield site on Marino Point in Cork Harbour The IFI brownfield site is located on Marino Point, Cobh County Cork in Cork Harbour (see Figure 2). The area is situated on Great Island approximately 5km from the adjacent town of Cobh. The eastern boundary is formed by the Cork-Cobh railway and main road from Cork to Cobh. As Marino Point projects out into the river, it has aquatic boundaries to the south and west. Passage West is approximately 1.6 km away on the 24
opposite bank of the river (EPA, 1998). On its northern boundary the site is adjacent to intertidal mudflats that form part of Natura 2000 site, the Great Island Channel (Natura 2000 code IE 0001058, 2000). The site has an area of 45.09 hectares with and incorporates 25.73 hectares held under lease from Cork Harbour Commissioners under a 99 year term with 7-year rent reviews (from 24th April 1975 onwards). The area is advertised by as an outstanding waterfront location and includes a jetty suitable for ships up to 15,000 tons, railway siding and national connections, offices, workshops, canteen and sundry buildings (Hamilton Osborne King Ltd, 2005). The geology of the site consists of a mixture of substrata including soft mudstone and sand stone units, marine silt and construction fill material with a combination of subsoil of marine muds, silt and made ground from rubble and fill. The hydrology of the site is strongly influenced by the nature of the subsurface material and the proximity to the sea harbour. Groundwater can show various degrees of saline intrusion. The groundwater is migrating along a number of flow axes with principle direction from south-east to northwest and east to west (EPA, 1998). The Natura 2000 site bordering the IFI brownfield site consists of 1484 ha. The area (code IE 0001058) includes Special Areas of Conservation (SAC) designated under the European Habitats Directive (92/43/EEC) and Special Protection Areas designated under the European Birds Directive (79/409/EEC). The site is of ecologically importance owing to the habitats of intertidal mud and sand flats and Atlantic salt meadows listed in the Annex I of the Habitats Directive. Furthermore the area supports 50% of the wintering waterfowl in Cork harbour including a significant proportion of internationally important populations of Black-tailed Godwit (Limosa limosa) and Common Redshank (Tringa totanus) (Natura 2000 code IE 0001058, 2000). The IFI plant was built in the mid 1970’s to manufacture ammonia and urea and commenced operation in 1979 as the state owned Nitrigin Eireann Teoranta (N.E.T.). The company was a 51% into a joint National venture with Imperial Chemical Industries Ltd. (ICI) owning 49% and became Irish Fertilizer Industries (IFI) in 1987. IFI produced ammonia, urea and liquid carbon dioxide (EPA, 1998). The company ceased to operate in 2002 and the site is currently in possession of Klynveld Peat 25
Marwick Goerdeler (KMPG) in Ireland. KMPG is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms, where each member firm is a separate and independent legal entity (KMPG, 2005). The area is currently zoned as agricultural area A1 for any purpose in the metropolitan greenbelt (pers. com. Elaine Walsh) (details for pers. com. in Appendix 2). During the lifespan of IFI the area was zoned under the Seveso Directive (Council Directive 82/501/EEC) concerning industrial accidents and emergency responses. The Directive was introduced in 1976 and later amended in 1987 and 1988. Companies working under the Directive must satisfy the national competent authority that they have identified major accident hazards, adopted the relevant safety measures and provided all persons working on the site with information, training and equipment so as to ensure their safety (EU Environmental Information and Legislation Database, 2005). The site is still under Seveso zoning because Dynea Ireland a Manufacturer of Resin for Timber Industry operates a factory in the north-western part of Marino Point (Businessworld, 2005).
Figure 2
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3. Materials and Methods
Data collection, processing and analyses for this project were conducted in three different phases, a desktop study, a field element and the production of a dedicated Geographical Information System (GIS). For the desktop study, Cork County Council and EPA data were reviewed and analysed with respect to Marino Point area and it’s industrial history. Data collected was harnessed within the GIS (Arc GIS, ESRI) to produce maps showing historic land-use and land-use change. Additional material from contemporary field visits to the site in the form of habitat maps was incorporated in the GIS. Interviews were also conducted in an attempt to establish potential reasons for any changes recorded at the site. 3.1 Historic Land-use Change To establish the historic land-use and land-use change on Marino Point, records from the Cork County Council planning department were reviewed and summarised as part of the desktop study. Files available on microfilm in the planning department of Cork County Council and all files relevant to the area were considered. Any events or incidents associated with land-use and/or land-use change of the area was recorded. This output was then placed in chronological order and subsequently summarised to describe the historic land-use and outlines land-use change over time. 3.2 Analysis of Industrial Operations on Marino Point Cork County Council records and EPA files were reviewed during the desktop study in order to document the industrial operations on Marino Point. The files from Cork County Council were available on microfilm in the planning department of the authority and EPA files from 1995 onwards were requested from the head office for subsequent review. EPA files prior 1995 are available from the archives of the Agency but were not considered due to the limited time available for this project. The files were reviewed in the local EPA office in Inniscarra and relevant references to the site recorded. These included incidents of non-compliances, licences the factory was operating under, complaints and emergency procedures. Further communications between the factory and the Cork County Council and/or the EPA were also recorded. Further documentation that provided information on the potential impact the industry had on its natural environment was also reviewed. The data were then arranged in chronological order and summarised in tabular form to document the operational phase of the IFI (and 27
former N.E.T.) plant on Marino Point. The summarised tables do not provide technical details but give an overview view of operations at the site. More detailed information obtained from the EPA files can be viewed in Appendix 1. 3.3 Visualisation of Land-use Change Historic maps, aerial photography, recent Ordnance Survey of Ireland (OSI) vector mapping, a map showing the outline of Cork Harbour and other relevant features of interest were digitised and included in the GIS database. Features were digitised from the historic maps were these maps were also utilised as base maps for final comparison (see Figure 3 and 4). Digitising in the context of GIS refers to the extraction of coordinates from secondary sources such as maps to create vector data. Vector data allocates the position on the surface of the earth as points, lines or polygons (Gregory, 2002). The Coastal Marine Research Centre (CMRC) provided the aerial photograph, vector map, Cork Harbour outline map and the 6-inch OSI map from 1935 in digital format, all these maps are owned by OSI. Historic base maps were overlain to illustrate the historic land-use and land-use change. Two 6-inch OSI maps of the area of interest were available on microfilm in University College Cork special collection library. Copies were made from microfilm of the two maps, dated 1842 and 1902. These copies were rectified to the Irish National Grid in Arc GIS. A third 6-inch OSI map was already available in Irish National Grid. Features showing land-use boundaries, and other important landmarks, were identified and digitised on all three maps. The features digitised were the coastline, the escarpment on the coast, contour lines, woodland areas, buildings, the road, the railway line and the quay. These features were digitised as points, polygons or lines. Land-use was compared (Figure 3) by overlaying the woodland areas, digitised as polygons, from each time period. Coastlines and contours, digitised as lines, were included to place the map into context. Areas of woodland were portrayed in different colours and different transparencies and any differences were highlighted. Infrastructural features such as road, rail, buildings and quay were evaluated (Figure 4); with each feature allocated a unique colour according to its time period in order to facilitate comparison. For both maps (Figure 3 and 4) the OSI vector map was used as a base layer under the features to place the historical land-use change in context with the contemporary site layout. Both maps (Figure 3 and 4) represent only a portion of the 28
contemporary site and a second layer frame was introduced to show the entire site at a lower scale. Figure 5 visualises the extent of the reclaimed area. The map was produced using the OSI 6-inch map from 1935 overlain on a modern aerial photograph. The coastline of the historic map and the coastline from the aerial photograph were digitised. The difference between the coastlines was then digitised as a polygon to highlight the area of reclaimed of land. A second layer frame was introduced to indicate the location of the site within Cork Harbour. 3.4 Habitat Description and Mapping of the Study Site The IFI brownfield site was divided into eight different areas of interest to facilitate the descriptive phase of the study. The habitats on the IFI brownfield site were described and mapped during two site visits. The Guide to Habitats in Ireland (Fossitt, 2000) (summary of code classification for the habitats in Appendix 3) was used to identify the general habitats, which were marked in a general field map of the area. The Wild Flowers of Britain and Northern Europe (Fitter et al.1996) was used to identify plants on the site. Interviews with Jim Wilson of Birdwatch Ireland and a former employee of the site, Peter Desmond, gave an indication of the birds that utilise the area for the description of the habitats. Figure 5 was produced from an aerial photograph and field observation using the OSI vector map of the area as a base map, utilising the. As before a second layer frame was incorporated to indicate the location of the site within Cork Harbour.
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4. Results
4.1 History of the Land-use Change from Rural to Industrial The objective of this section is to establish the historic land-use of the coastal brownfield site at Marino Point in Cork Harbour. The site, indicated in Figure 2, has been subject to land-use change over the last 30 years. Nitrigin Eireann Teoranta (N.E.T.) (Cork County Council, 1974-7) described Marino Point as a partly wooded headland of rural character extending into Cork Harbour as part of a landscape proposal for the site. In a copy of the Cork County Council Forestry Inspectors advisory report (Cork County Council, 1974-17) dated March 12, 1974, Marino Point was observed as a distinct landmark in Cork Harbour The site was gradually rising from the south and western shoreline to the “Leading Light Point” and then gradually falling to the northern shoreline. Beyond the northern shoreline was mud, a railway to the east, and the south and west were bordered by water. Marino House and grounds were perceived as an idyllic setting on the southern shore, with an area of old woodland of around 11 acres (4.45 ha) containing large Beech, Oak and Elm trees. The wider enclosing area of around 15 acres (6.07 ha) was compared to parkland with mature Beech, Oak, Sycamore and Horse Chestnut trees. Overall, the site was evaluated as being of high amenity value (Cork County Council, 1974-17). Marino Point, Cobh, County Cork was originally owned by Colonel Stuart French, who lived in an adjoining estate. Cork County Council granted him planning permission in 1966, for a road alignment north of Marino Farm adjacent to the site and possible residential development of the site (Cork County Council, 1966-1). Stuart French indicated his intention to dispose of the land and at the same time his concern that future development would not disturb the “attractiveness of the situation” (Cork County Council, 1966-2). Eleven years later on October 12, 1972, the county council refused planning permission to Mr. J. Barry for a bungalow on the site next to Marino House. The County Council gave as a reason that the entire area was zoned for port-related industrial development in the draft of the Cork County Development Plan. Mr Barry stated that he purchased the area from Mr. French because of the mature gardens in the surrounding area and the “panoramic view of Cork Harbour” (Cork County Council, 1972).
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Several applicants, for example Mr. N. O’Driscoll, applied for planning permission for residential development in the area around Marino Pont in 1973, and were refused. The refusals were justified because of the zoning of the entire area as industrial and the absence of a public sewer and public water facilities (Cork County Council, 1973-1). In the same year, Cork County Council stated in a notice to Mr. G. Farrell of Farrell Industrial Development that permission would be granted for industrial development at Marino Point (Cork County Council, 1973-2). Mr. Farrell had applied through Mc Delany, Mac Veight and Pike, Architects, Civil Engineers and Planning Consultants on October 13, 1972. However, it was also recorded that the application did not indicate any type of proposed industry but looked for assurance that industrial development was possible in principle at this location. Furthermore, Cork County Council stated that the applicant was referring to the Harbour Commissioner’s plans to reclaim land adjoining Marino Point with regard to alternative access possibilities. The proposed development is indicated on a map in the County Council file and with the exception of the area around Marino House prior to land reclamation includes the entire Marino Point peninsula. Mr. Farrell purchased the site from Mr. J. Donnelly, Mr. J. Barry and Mr. R. Power (Cork County Council, 19732). The County Council schedule concerning the application stated that any proposed development at this location had to be port-orientated and with limited noise levels, as specified by planning authority. The development had to be of a character where processes or effluents would not pollute the atmosphere or water at levels unacceptable to the planning authority. Furthermore, proposals for water supply, access, road safety and structures on site would have to be submitted. In the schedule, it is again noted that the actual nature of the proposed development was not stated in the application and that public water supply would not be available for some years to come (Cork County Council, 1973-3). The first documentation to indicate that Nitrigin Eireann Teoranta (N.E.T.) purchased the Marino Point site to produce ammonia and urea is a Cork County Council document dated November 1973. The site was acquired before any planning permission was obtained. The intended plant was proposed to have the capacity to produce around 1,350 tonnes of ammonia per day using natural gas as feedstock, while the by-product carbon dioxide would be used to produce around 1,000 tonnes of urea per day. The opportunity to utilise the adjacent railway line to the west and the deep-water channel to the 31
southeast made the site an attractive location for development (Cork County Council, 1973-4). On November 21, 1973, Mr. J. H. Audley of the Anti-Corruption Association Ireland requested a list of substances, which would be involved in the processes of the plant. The list and acknowledgement of the letter is recorded on November 24, 1973 (Cork County Council, 1973-5). A County Council document from March 1974 recorded that N.E.T. had applied for planning permission. The document included plans by the company with regard to noise and emission control and site plans of Marino Point. A site plan included shows the proposed reclaimed area and the trees, that bordered the water to the south side of Marino Point, that were to be retained. . The N.E.T. property shown on these maps includes the area of Old Court on the west side of the Cork-Cobh road (Cork County Council, 1974-1). Copies of the plans for the proposed development were available for public inspection at the Cork County Council planning department from June 1974 (Cork County Council, 1974-2). Documentation by N.E.T. regarding a meeting with the Forestry Inspector Mr. Vealing dated February 05, 1974 stated that most of the Beech trees on the Marino Point site were diseased with the honey fungus (Armillaria sp.). It is further stated that Mr. Vealing would give a tree removal permit with regards to the proposed development but that he also would expect objection from An Taisce, the National Trust for Ireland (Cork County Council, 197416). Over 60 residents objected in writing against the proposed development in June and July of 1974. All of the objections cite the effects of such industry on the flora, fauna and marine life of the area. The objections were made by the residents of the surrounding areas of Marino Point, Cobh and Passage West (Cork County Council, 1974-3). On July 10, 1974, residents of Marino Villas, Carrigaloe and Cobh protested formally against the N.E.T. proposal. The residents demanded that issues such as noise, emission, effluent, road congestion, view and right of way should be taken into account in the planning decision (Cork County Council, 1974-6). The Chief Planning Assistant of County Cork commented in a document dated July 17, 1974, that the future expansion of the factory was not clear from the N.E.T. plans. Furthermore, he remarked that the zoning of the area in the County Development Plan 32
did not mean that unacceptable industry with implications for the Fota and Belvelly areas could not be refused. He advised that the adjoining areas to the north and east of the site were designated for their scenic and recreational amenity value in themselves and in association with Foaty Island. He further reasoned that the N.E.T. proposal would have direct impacts on the inherent environmental quality of the region and would lower the visual and recreational amenities in the area. In addition, he stated that the extension of industrial uses by N.E.T. or others on the proposed reclaimed land could have a damaging effect on the scenic amenities of Fota. The vicinity of the project to Passage West homes was recorded as a potential problem regarding visual amenities. The Chief Planning Assistant referred further to the N.E.T. proposal to retain some trees at the edge of the site, but noted that most trees would be removed as a consequence of the development. He also emphasised that there was no proposal on how to minimise the visual impact to the north side of the reclaimed area. The Chief Planning Assistant recommended more extensive studies into the impact on noise levels that might arise from the development (Cork County Council, 1974-4). In a letter of July 1974, An Taisce requested more detail on air emission, an explanation for the absence of screening towards the north side of the development and further specification regarding run-off and consequential eutrophication threat for the adjacent waters in relation to the N.E.T. proposal. Furthermore, An Taisce wanted to know the implications of the development on the Fota arboretum (Cork County Council, 1974-5). In the revised planning application of August 1974, N.E.T. stated that the processes the company intended to use for their production were modern and intrinsically clean and, therefore, showed that their proposal was environmentally acceptable. N.E.T. acquired the approximately 60 acres (24.29 ha) of Marino Point and approximately 20 acres (8.09 ha) of adjoining town land at Belvelly. The company further referred to an area of another 60 acres (24.29 ha) that was going to be progressively reclaimed to the north of Marino Point, starting with 16 acres (6.48 ha) protected by a wall along the western edge (Cork County Council, 1974-7). The revised planning application showed the following four areas of proposed development: • • the manufacturing plants the bagged production storage for collection by road and rail 33
• •
the central services area and the marine facilities for export products.
The surroundings of the central service area were proposed to be landscaped to complement the existing gardens. Of the environmental considerations mentioned on the planning application, two main factors were described to contribute to the factory being environmentally acceptable. These were the use of natural gas as feedstock for the ammonia process and the intake of seawater for the cooling system. The use of natural gas was an alternative to the conventional use of sulphur components for the production of ammonia, which is associated with serious environmental damage. The intake of seawater substituted the use of fresh water-cooling towers, which are related to moist air plumes. It is, however, also stated that the processes would produce slightly contaminated liquid effluent. As a consequence, an effluent treatment unit was proposed, which would have to be in compliance with European regulations on liquid effluent discharges. Furthermore, the gaseous emissions from the ammonia and urea plants were proposed to be treated to reduce the flow and concentration of the pollutants. It was also admitted that there would be occasional discharge of back washings, including acidic and alkaline rinses from the boiler feed water treatment plant. All effluent was proposed to be collected in an effluent pond prior to being discharged with seawater to improve dispersion and minimise the local effects on the estuary. The effluent would be analysed to monitor whether it is within acceptable limits (Cork County Council, 1974-7). As a result of the proposed development by N.E.T., the character of the area would change from rural to industrial. Landscaping of the site was proposed in the planning application to lessen the visual impact of the factory on the area. In the proposal, plans were made to level the central area of the existing site from ca. 70 ft (21.3m) to 22ft (6.7m) above sea level. Existing trees to the south and southwestern edge of the development were supposed to be retained, and if necessary, diseased trees would be replaced. All of the processing plants were to be situated in the lower south level of the site, in order to keep them out of the view from adjoining areas. The more attractive buildings, such as the office building in the retained Marino House and the staff facilities, would be closest to the water. The buildings of the plant were to be painted in dark blue green receding colours, while the high towers would have an aluminium or white concrete colour. Planting was considered for the area around the laboratory to form a continuation of the existing planting around the edge of the site and around 34
Marino House. Furthermore, a continuous screen planting was designed around the car park, the ESB and gas station and a screen of evergreen coniferous was proposed around the Belvelly area consisting of three rows of Cupressus species. Around Marino House, the ornamental planting was intended to be retained and supplemented if necessary and the area around the staff facilities was proposed to be landscaped to provide an attractive setting (Cork County Council, 1974-7). A report by Dr. T. Mc Manus of the Institute for Industrial Research and Standards to the Council concluded that the absence of sulphur dioxide and the use of natural gas in the production process of ammonia were the reasons that no serious environmental problems would arise from the proposed N.E.T. development. The report judged the proposed plant as “in consequence one of the cleanest” (Cork County Council, 1974-8). In a letter from August 02, 1974, N.E.T urged the planning department to speed up the decision for their proposal (Cork County Council, 1974-9). Mr. Audley informed the county council on August 09, 1974, that a consultant biologist had been employed to look at the proposed project (Cork County Council, 1974-10). On August 13, 1974, Mr. T. J. B. Kelleher refused the N.E.T. planning application as the acting Chief Planning Assistant because of visual and landscape criteria and suggested the investigation of alternative sites near Belvelly or on the Great Island Valley. He also stated that this could mean that agricultural land might be lost but that the alternative site might screen the buildings better (Cork County Council, 1974-13). On the same day, a letter by Mr. Audley to the Planning department reminded the council that the company purchased the site without applying for planning permission beforehand. He stated that decision of granting planning permission should be independent from the fact that the company had already obtained the site. Furthermore, he advised the council that the area was used as picnic and bathing site by residents of the region and fishermen earned their living in the waters surrounding the site (Cork County Council, 1974-14). On August 19, 1974, the County Manager stated in a note to N.E.T. that in principle permission was granted for the development (Cork County Council, 1974-11). In a report dated to August 20, 1974, from the County Council Medical Officer it was noted that he saw two health hazards regarding the proposed development. The first was the effect of noise, dust and heat on employees of the plant and the second concerned the consequence of emission of ammonia, carbon dioxide and other gases for residents in 35
surrounding areas. He also referred to a recent disaster at the N.E.T. Arklow plant, where Mr. D. A. Murphy described the company to be careless, the Cork County Council Development Officer (Cork County Council, 1974-12). On August 26, 1974 Cork County Council granted planning permission to the N.E.T. proposal on Marino Point under an additional set of conditions. These conditions included that, the feedstock and boiler fuel would always use sulphur free natural gas, the production capacity of ammonia would not go above 1350 tonnes per day, the free discharge of hydrogen only applied if noise emission was within set limits and that carbon dioxide discharge was vented via surface condensers (Cork County Council, 1974-15). In correspondence from the County Council to the Minister of Transport dated September 12, 1974 it is stated that the Cork Harbour Commissioners applied for a lease of foreshore comprising of 29ha (11.74 ha) in connection with the N.E.T. project (Cork County Council, 1974-22). By September 1974, the County Council had received over 100 appeals against the planning permission for the development at Marino Point by residents of the surrounding area and organisations such as An Taisce (Cork County Council, 1974-18). While most of the residents referred in their appeals to their concern of the effects on the flora, fauna and marine life of such an industry, Barry C. Calvin & Son appealed on behalf of Mrs. N. Federow as her solicitors on September 06, 1974. In this appeal it was stated that Mrs. Federow owned land in Carrigaloe that was purchased from Mr. French because of the planning permission for residential development that was granted in 1966. However, any residential development would now be contrary to the planning permission granted for industrial development (Cork County Council, 1974-19). An Taisce stated in their appeal that the development was environmentally undesirable and contrary to good planning on September 13, 1974 (Cork County Council, 1974-20). A draft document by N.E.T. from November 13, 1974 discussed the appeals and gave justification for the development. N.E.T. stated that the use of natural gas and acceptable standards for gas and effluent emission were no hazard to flora, fauna and marine life. Furthermore, the company remarked that discharge into the Harbour would be cooling water and a relatively small wastewater stream, which contain trace components of the chemicals used in the process. Therefore, the effluent discharge would not be any hazard to marine life. Regarding visual impacts, the company 36
commented that the complex would look neat and tidy and would be landscaped to minimise the visual impact. Additionally N.E.T. stated that other industries were also present in the area. Concerning the amenity value and recreational use of the site, the company observed that the property was always private, while the muddy and debris strewn foreshore could only be of limited amenity value. On the subject of appeals because of residential development in the area N.E.T. referred to the industrial zoning of the site in the County Development Plan (Cork County Council, 1974-21). The Minister of the Local Government granted permission for the N.E.T. development in a document dated April 23, 1975 after revising all the conditions for the permission with regard to the An Taisce appeal. In this document Condition 34 clarified that the developer and owner of the site should furnish a bond or other security measures before the development commenced. This referred to the taking down and removal of the plant, equipment and installation if the plant ceased to function. The site would have to be reinstated to agricultural, rural or other uses agreed with planning authority (Cork County Council, 1975-1). The council wrote to Cork Harbour Commissioners on June 13, 1975 that they were concerned regarding a dislocation of silt from the foreshore, which resulted in a rise of silt immediately north of the reclamation area on Marino Point. This could have consequences for navigation in the main channel and N.E.T. was advised to build a material construction from east to west parallel to the reclamation line to cut off the embankment (Cork County Council, 1975-2). On February 13, N.E.T. entered into a Bond with Cork County Council with some £500,000 being put aside for the council to take down and remove all plant equipment and installations connected or formed part of the plant in the event that the ammonia and urea complex ceased to function in the opinion of the council. The land should be reinstated to uses agreed with the Council, according to the Bond (Cork County Council, 1976-3). A document of a conference held in London between N.E.T. and the Council dated May 13, 1976 discussed further landscaping issues (Cork County Council, 1976-4). The county architect stated in correspondence with the Council from July 14, 1976 that the landscape proposal was in line with the project and urged the Council to support 37
mounding of areas to screen the Cork-Cobh road. The 1976 landscape proposal recorded that the well-wooded foreland would be retained completely as a basic screen, and that additional screening was needed to the road in the east and Passage West to the west. Major screen planting was proposed to the Belvelly side of the development, along the railway line and around the car park. It was also stated that the Belvelly sidings were already partly reclaimed and that an embankment on the northern edge prevented flooding. The embankment was subject to erosion and Spartina townsendii was proposed to be replanted on the embankment from the channel (Cork County Council, 1976-5). Cork County Council gave notice to N.E.T. on March 02, 1976 that planning permission was granted for a two-storey administration and office building with a flat roof at Marino Point, on the grounds that the building would be in the proximity of the ammonia/urea production plant. On a map, these buildings were indicated to be next to the old quay (Cork County Council, 1976-1). The County Council granted planning permission to Bord Gáis Eireann on October 26, 1976, for the erection of an aboveground installation at Marino Point. The application was granted in consultation with the fire department and outlined conditions regarding noise levels and minimisation of noise impact on air intake and exhaust gas outlets and pipe work. Additional conditions were given concerning the disposal of waste to safeguard the environment. Furthermore, the site had to be landscaped for visual amenity, with a mixture of fast growing coniferous trees such as Cupressocyparis leylandii and Cupressus macrocarpa and a variety of deciduous Populus and Salix species. The detail for the shrub and decorative tree species within the landscaping strip had to be submitted to; and agreed with; the planning department as well as plans for the colour treatment of the buildings in the interest of visual amenity (Cork County Council, 19762). On January 17, 1977 Mr. Audley send a letter to the Taoiseach on the violation of planning permission by N.E.T., which stated that the company was erecting a second ammonia storage tank but had only got planning permission for one (Cork County Council, 1977-1). He also registered his objection on February 08, 1977 (Cork County Council, 1977-2). Several residents of the areas around Marino Point, mainly of Passage West, objected to the building of two ammonia storage tanks at Marino Point on the
38
grounds of health and safety in February and March 1977 (Cork County Council, 19773). In April 1977, Mr. Audley and Mr. M. F. O’Connell appealed to An Bord Pleanála against the Cork County Council decision of March 31, 1977 to grant permission to N.E.T. for the building of two 15,000-tonne storage tanks for ammonia. The appeal was made on the grounds that storing 30,000 tonnes of ammonia within 650 yards of a residential area with schools accommodating up to 700 children was a health and safety hazard (Cork County Council, 1977-4). Additional appeals by Mr. Audley were recorded on May 06, September 17 and December 05, 1977 (Cork County Council, 1977-5). However, in the County Council schedule of the permission, it was stated that these retention tanks were not contrary to the planning and development of the area and An Bord Pleanála granted permission with approval of the fire officer. N.E.T had applied for planning permission of a 30,000-tonne storage tank for ammonia on January 02, 1977 (Cork County Council, 1977-6). In a document from the County Secretary to the department of the environment dated August 03, 1978, it was stated that noise from Marino Point was a result of testing the plant (Cork County Council, 1978). In the 1979 N.E.T. report on accounts and directors regarding the Marino Point complex, it was stated that the plant was finally commissioned and working satisfactorily since the second half of the year (Cork County Council, 1979-1). On March 09, 1987, N.E.T. informed in a letter to Cork County Council that they were entering a joint venture with the United Kingdom based company Imperial Chemical Industries plc. (I.C.I.) (Cork County Council, 1987-1). The company registered and became Irish Fertiliser Industries (I.F.I.) on October 06, 1987 (Cork County Council, 1987-2). On May 23, 1997 Cork County Council granted permission to Dynochem Ireland, Lough Mahon Technology Park, Blackrock, Cobh for a construction of a methanol loading bay, a powder store, a lump grinding housing unit and a compressor room at Marino Point, Cobh under registration number S/97/1183. The conditions that were given for the permission included that the business had to operate so as not to give rise to public health and safety nuisance through air borne emission or emissions of 39
substances to the ground water (Cork County Council, 1997-1). On June 26, 1997 the Cork County Council granted permission to Dynochem Ireland for a packaging retention building at Marino Point. Certain conditions applied to this permission such as the colour scheme and landscaping plan to lessen the visual impact. The company were asked for a maintenance operation plan of regarding the impact of dust and noise, as well as payments for the improvement of the road and for water supply before the development (Cork County Council, 1997-2). 4.2. Operational Phase of the N.E.T. and Later IFI Company IFI (former N.E.T.) operated from 1979 to 1992 under the control of Cork County Council with regard to licences for emission and discharges and any breaches of these licences. From 1992 onwards, as part the EPA Act 1992, the Environmental Protection Agency (EPA) held IFI responsible for breaches of these licences. IFI was granted an Integrated Pollution Control licence in December 1996 that incorporated all discharges and emissions and implied stricter control for non compliances by the company. Instances of non-compliance, licensing applications and incidents associated with the operation of the site by IFI are detailed below. Documentation was obtained from two different sources the Cork County Council Files from 1979 to 1991 and the EPA Files from 1995 to 2002. 4.2.1 Cork County Council Records Table 1 summarises Cork County Council records concerning the history of non compliances, incidents and licensing in chronological order gleaned from an analysis of council records.
Table 1 Cork County Council records
Date January 29, to February 04, 1979 May 05, 1979 June 28, 1979 July 02, 1979
Issue Noise complaints Ammonia leak Ammonia release
Notice Reference Request of information by Cork County Council, 1979Council 2 Odour nuisance
Cork County Council, 19793 Medical treatment of Cork County Council, 1979schoolchildren on a bus at 3 and 1979-4 public road Ammonia Scorching of vegetation in Cork County Council, 1979release at adjoining wood and at public 3 and jetty road 1979-4
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August, 1979 January 08, 1980 Letter July 03, 1980 Letter August 13, 1980 March 10, 1981 April, 1981 July 03, 1991
Unprocessed gas flares Emergency Procedure Ammonia emission Ammonia flaring Plant shut down Emergency Procedures Licence regarding emission to air
Council concern regarding visibility for low flying aircraft N.E.T. submitted an Emergency Procedure Manual for the County Council Correspondence between Gardai and council regarding non-notification of incidents High Court Order requesting equipment for flaring Gas burned to atmosphere
Cork County Council, 19795 Cork County Council, 19801 Cork County Council, 19802 Cork County Council, 19803
Cork County Council, 19811 N.E.T updated the Cork County Council, 1981Emergency Procedures 2 Cork County Council grants a EPA, 1995 licence to IFI under the Air Pollution Act, 1987
4.2.2 Records of the Environmental Protection Agency from 1995 to 2001 The EPA files are condensed in Table 2 with further details available in Appendix 1. Records are summarised for this study and therefore non-compliances reports are given in numbers per year and do not include information concerning the quantity, location of incident or the substance involved. Included in the non compliance counts are monthly reports of non compliances given by the IFI to the EPA, monthly reports by the EPA, if detected non compliances were not identical with IFI results and independent reports of other bodies stating non compliances. Public complaints are counted separately as are plant shutdowns as these are sometimes, but not always, correlated with detected non compliances. Public complaints and recorded shut down of the plant can be an indicator for non compliances. Bord na Mona reports are counted separately because these reports dealt specifically with groundwater quality and occasionally air quality. The section under “Other records” mentions incidents, reports and records that were not stated as non compliances but are of importance when documenting the operational phase of IFI. Monitoring and detection of non compliances improved over time with the incorporation of the Integrated Pollution Control (IPC) licence and subsequent improved recording of non-compliances.
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Table 2 Environmental Protection Agency records
EPA file
Public Complaints of that year
1995 June Three odour to complaints; December One noise complaint
Plant shut down/ per year Two
Reports of non compliance to licences/ per year Seven
Bord na Mona reports / per year
Other records of that year
1996 January to December
Two odour complaints; One complaint regarding bird kill in the area
Five
Ten
1997 January to December
16 odour Nine complaints; Ten noise complaints; Ongoing complaints regarding brown/yellow fumes
Fifteen
• Two reports verify • August 15, Groundwater derailment contaminated by incident; nitrogen components; • August 24, IFI • One report isolating apply for IPC the prill tower and the licence granulator of the Urea plant as major sources air pollution • One report verifying • May 17, Cork Groundwater County contaminated by Council air nitrogen components laboratory documents emission brown/yellow fumes; • December 20, EPA grants IPC licence • Three reports • July 24, IFI is verifying summons to Groundwater Court by EPA contaminated by regarding the nitrogen components; breaching of Ammonia • Two reports emission; concerning odour aldehydes, amines and • August 11, ammonia responsible dust dissolving for odour nuisance tank overflow; • August 18, Toxicity report “The acute toxicity of two IFI samples to selected aquatic species” by Fobairt
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1998 January to December
38 odour complaints; 18 noise complaints
Ten
Twelve
1999 January to December 2000 January to December
2001 January to December 2002 None January to July
Two odour complaints; 19 noise complaints One odour complaint and five noise complaints None
Three
Eleven
Six
Ten
• February 24, • Two reports on release of 80 Groundwater to 100 kg contamination ammonia to air document that during plant additional boreholes shut down; showed some levels nitrate exceed • April 04, Cork European standards County and migration of Council letter groundwater in northto EPA ask if western direction there is a study on vegetation damage in the area; • August, EPA letter to Environmental Alliance Ltd. EPA performed no independent monitoring and study of natural environment after plant shut down None • Two reports verify Groundwater contaminated by nitrogen components None None
Three
Four
None
None
Three
Five
None
None
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4.3 Marino Point and Land-use Change Maps This section discusses land-use change over time and the current land-use on the maps produced from the GIS. 4.3.1 Land-use change and Map Error Build-up The occurrence of an error build-up between all different layers of information has to be understood to correctly interpret the produced maps and obtain a more realistic view of the current and historic situation. Information layers include historic maps, a recent vector map and a recent aerial photograph of the area. Some of the land-use changes shown using the historic base maps are caused by the poor quality of the 1842 and 1902 base maps. Both of these maps used in this study are copies from microfilm, which were photographed from a book; where unfortunately, the area of interest was located in the book crease. Only half of the 1842 map was visible owing to the book crease and therefore features, such as areas of woodland, could not be shown in the eastern part of Marino Point. Furthermore, some features, such as roads were not readily identifiable on the 1842 map. This could mean that these features were not there or were simply not recognisable. The rectifying process, to the Irish National Grid, further distorted actual areas and lines. As the photographs were sourced from a book, the maps would never have been flat but offset out at certain points on the page. Therefore for both the 1842 and 1902 maps, some areas would have been partially adjusted to fit into the grid. Another reason for differences in areas or lines lies in the accuracy of the historic maps themselves. Precision in mapping itself was, and is, constantly improving. The methods available at the time when these historic maps were produced would not have been as precise as contemporary methods. Also, the mapping methods between the different time individual periods may have varied, leading to maps of differing precision between maps for the same area. Throughout the process of digitising, error can build up owing to indistinct symbology in some parts of the historic maps. Furthermore, even with present improved methods of mapping and high quality digitising equipment there will always be human error involved because digitising itself requires that decisions are based on human judgement.
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4.3.2 Woodland, Coastline and Contours - 1842, 1902 and 1935 The map in Figure 3 shows that from 1842 to 1935 the site was predominantly woodland. The area of woodland changed in the time period from 1842 to 1935. Woodland was reduced in some sections and increased in others. Some areas of woodland were overlapping for all three time periods. Other parts show that woodland was only present during one or two time periods. All three coastlines differ from each other at discrete points, indicating that the coastline has changed over time. The coastline moved back to the east by about 10 meters between 1842 and 1902 and regressed a further 30 meters to the east to 1935. The coastline may have changed between the three different time periods as a result of natural accretion and erosion. The coastlines of 1842 and 1902 show more similarities compared to the coastline from 1935. This may be the result of increased erosion and accretions between 1902 and 1935. However, the shape of the digitised coastlines is very similar, suggesting that any changes were minor.
Figure 3: The woodland, coastlines and contours on Marino Point historic maps from 1842, 1902 and 1935
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The variation of coastline can be seen more in actual placement than the overall shape also showing the build-up of error. The difference of the coastlines puts the change of the woodland area over time into context, also suggesting the build-up of error regarding the accuracy of the base maps. The contour lines were only shown on the base map from 1902 and were not included for the other two time periods. These show that the elevated area was situated in the mid-western part of Marino Point. The use of contour lines in just one of the base maps indicates that during different time periods emphasis was given to different features of the area. Under consideration of all the possible build-up of inaccuracy, the map shows woodland area change over time took place and coastline changed over time in the western part of the peninsula, but all changes are not as definite as shown in the map. 4.3.3 Infrastructure in 1842, 1902 and 1935 The map in Figure 4 shows buildings, roads, rail and the quay as recorded on the historical maps. In all three historic maps, Marino House and the glasshouse building in the garden were mapped, while the maps from 1902 and 1935 also show a third building behind the garden area. The quay was present in all three-time periods and differences between locations of the quay are evidence of the inaccuracy of the maps. Roads could only be identified on the more recent maps, indicating that they were more recent features of that area. The railway line could not be identified on the oldest map because the eastern part of Marino Point is not visible on this map. The difference between the road from 1902 and 1935 provides evidence of the build-up of error. However, around the area of the garden the road is differently aligned between the two time periods. Infrastructural change of the area is illustrated in Figure 4 where the road was aligned between 1902 and 1935 and the missing features such as one building and the road on the oldest map from 1842.
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Figure 4: Infrastructure on Marino Point historic maps from 1842, 1902 and 1935
4.3.4 Reclaimed Area of Marino Point The map in Figure 5 shows the reclaimed area as part of the land-use change on Marino Point. The area of Marino Point increased in nearly double its original size from approximately 25 ha to approximately 45 ha. The map shows how the shape of the peninsula changed physically and further shows the difference between the natural and artificial coastline. The artificial coastline around the reclaimed area is more even when compared to the section of the coastline around the original part of Marino Point. Error build-up has to be considered regarding the historic coastline from 1935. The reclaimed area, in the western part of the present brownfield site and the north western part of the historic peninsula might not be as definite as shown on the map. The map shows further that part of the previous encarpment to the north west of the historical peninsula was altered and became part of the reclaimed area for industrial use.
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Figure 5: Historic and current Coastlines and the reclaimed Area on Marino Point
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4.4 The Habitats and Areas of Interest on the IFI Brownfield Site Overall, the area of the former IFI plant on Marino Point can be classified as recolonised bare ground (ED3) showing the typical qualities and plant communities for these areas according to the Guide to Habitats in Ireland (Fossit, 2000) (Table of Classification in Appendix 2). Owing to different qualities of various parts of this derelict site, Map 5 shows eight different areas of interest. Each area can hold different habitats as classified by Fossit, 2000. These areas and habitats are described in the following part of this section. The habitat code and title is indicated in the description and on the habitat map after Fossit, 2000.
The area of Marino House and the garden holds mixed habitats as indicated on the map (Figure 6). The garden is surrounded by a stonewall (BL1) (Plate 2) and contains two glasshouses separated by a brick stone building (Plate 3). Around this area, several amenity grassland (GA2) areas can be seen. Management of these areas has ceased and herbs such as Marsh Willowherb (Epilobium palustre), Great Willowherb (Epilobium hirsutum), Kidney Vetch (Anthyllis vulneraria), Creeping Buttercup (Ranunculus repens), Common Ragwort (Senecio jacobae) and Butterfly-bush (Buddleja davidii) have invaded the grassland from the already overgrown gravel pathways. Cinnebar (Tyria jacobaeae) caterpillars are found on Ragwort (Senecio sp.), growing in abundance on the pathway. Evidence of animal faeces on the pathway in the garden and a European Rabbit (Oryctolagus cuniculus) sighting indicate the presence of several of this species on the site. At the stonewall along the edges of the garden, ornamental shrub (WS3) was present, and exotic trees such as a fig tree (Ficus carica) were present between the shrubs. An ornamental flowerbed (BC4) was noted between the grassland areas. Herbal plants, mainly Marsh Willowherb (Epilobium palustre), Great Willowherb (Epilobium hirsutum) and Thistles (Cirsium sp.), were seen occupying the pathways to the north gate of the garden and behind the canteen, growing between stone tiles.
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Plate 2: Stonewall with Butterfly-bush (location Marino House and Garden area; Figure 6)
Plate 3 Glasshouses in Garden with Amenity Grassland (location Marino House and Garden area; Figure 6)
Scentless Mayweed (Matricaria perforata), Docks (Rumex sp.) and Willoherb (Epilobium sp.) have invaded the pathway (Plate 4) that leads form the south gate of the garden to Marino House along the water. Palm trees and Butterfly-bush (Buddleja davidii) were situated opposite of the fence, along the stonewall, (Plate 2). Marino House (Plate 5), a Georgian building, was surrounded by more amenity grassland (GA2). Mature Scots Pine (Pinus Sylvestris) (Plate 2) was found on the southernmost grassland. At the southern fence to the water of the area, more wild invading herbs were found as well as Nettle (Urtica dioica). The courtyard (Plate 6) of the house was overgrown with mainly Ragwort (Senecio sp.), Docks (Rumex sp.), Willoherb (Epilobium sp.) and different grass species. In the area to the south of the house, more plant species were present, including European Mountain Ash (Sorbus aucuparia), Great Mullein (Verbascum thapsus) and Common Selfheal (Prunella vulgaris). At the west side of the house, Ox-eyedDaisy (Chrysanthemum leucanthemum) was found between other, already mentioned, plants such as Willoherb (Epilobium). Lime (Tilia vulgaris) and Oak trees (Quercus sp.) and form a border to area 2 to the west. To the north side of the house, the pathway has been invaded by Bramble (Rubus fruticosus) coming from the elevated area 2 and patchy wet areas populated with rushes and moss species were present.
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Plate 4: Pathway south of garden invaded by Scentless Mayweed (location Marino House and Garden area; Figure 6)
Plate 5: Marino House (Marino House and Garden area; Figure 6)
Plate 6: Marino House Courtyard (location Marino House and Garden area; Figure 6)
Area 2 (Figure 6) was also a mixed habitat area, containing two areas of amenity grasslands (GA2), situated between areas of scattered trees (WD5), including Chestnut, Holly, Cypress as well as Fuchsia shrub. The grasslands are currently not managed. The third significant habitat noted in that area was the mixed broadleaved/conifer woodland (WD2) (Plate 7). The area of WD2 seemed more natural and less managed, compared to the habitats as described previously. At this location, plants like Herb Robert (Geranium robertianum) and Ivy (Hedera helix) were growing in between the mixed tree stand and many birds were present. Two Spoonbills (Platalea leucorodia) were sighted in this area and at the southern border of Marino Point during the field visit. The woodland area borders a coniferous tree line (WL2) to the north (Plate 8). This coniferous tree line led into a mixed broadleaved tree line (WL2), including Horse-chestnut (Aesculus hippocastanum), Sycamore (Acer pseudoplatanus) and Holly (Ilex aquifolium) to the east. Further east a hedgerow (WL1) was following. Both tree lines and the hedgerow 51
are situated on elevated ground and screen the area of Marino House and garden as well as the canteen from the industrial buildings on the site.
Plate 7: Mixed broadleaved/conifer woodland (WD2) (location area 2; Figure 6)
Plate 8: Coniferous treeline (WL2) (location area 2; Figure 6)
The part of the site that corresponds most to the description of the ED3-Recolonising bare ground (Fossit, 2000) is indicated on Figure 6 as area 3 derelict site. This area occupies most of the brownfield site and plants such as Dandelion (Taraxacum officinale), Butterfly-bush (Buddleja davidii), Docks (Rumex sp.), Willoherb (Epilobium sp.), Ragwort (Senecio sp.), Nettle (Urtica dioica) and Bramble (Rubus fruticosus) were typically invading many edges of pathways and buildings (Plate 9 and 10). The Ringed Plover (Charadrius hiaticula) was observed utilizing the gravel of the site (pers. com. Jim Wilson) and Peregrine Falcon (Falco peregrinus) used to be sighted around this area (pers. com. Peter Desmond). Tree lines (WL2) and Hedgerows (WL1), indicated on the habitat map, were mostly found around the edges of the site. These habitats from part of the area but do not dominate. Other areas of interest belonging to area 3 are indicated in Figure 6 as area 4a, area 7 and area 6. These areas show all the characteristics of recolonised bare ground but contain some interesting features or have different plant species to those previously observed.
Plate 9: Plants invading derelict site (location area 3; Figure 6)
Plate 10: Ragwort and Butterfly-bush at the edges of pathways (location area 3; in Figure 6)
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An elevated rock face (Plate 11) is situated on the western part of the brownfield site, as shown in Figure 6, area 4. The habitat on the rockface was dominated by mixed broadleaved woodland (WD1) (Plate 12). Trees such as Sycamore (Acer pseudoplatanus) and Oak (Quercus sp.) were mixed with Eucalyptus (Eucalyptus sp.) (Plate 13). Goarse (Ulex parviflorus), Holly (Ilex aquifolium) and fern species build the under storey of this woodland
Plate 11: Elevated rockface (location area 4; Figure 6)
Plate 12: Mixed broadleaved woodland (WD1) on elevated rockface (location area 4; Figure 6)
The area 4a, in front of the rock face in common with area 3 belongs to the habitat category ED3. This area is highlighted in Figure 6, due to its strong degree of invasion by plants that have been described for this type of habitat (Plate 13 and 14) and because additionally St. Johns Wort (Hypericum perforatum) is present in high abundance.
Plate 13: Strong degree of plant invasion at derelict site (location area 4a; Figure 6)
Plate 14: Plants take over derelict site and presence of St. Johns Wort (location 4a; Figure 6)
The beach to the west, Figure 6, area 5, faces Passage West and the jetty of the site. Sea thrift (Armeria maritime) (Plate 15) was growing on the lower part of the rock facing the west, while Bladderwrack (Fucus vesiculosus) (Plate 16) and mussel shells (Mytilus edulis) was present on the lower shore.
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Plate 15: Sea thrift at beach (location area 5; Figure 6)
Plate 16: Beach (location area 5; Figure 6)
The pathway (Plate 17) shown as area 6 (Figure 6) was characterised as habitat ED3 but is highlighted as the area appeared to be more natural than the majority of area 3 with plants such as Scarlet Pimpernel (Anagallis avensis) and Rosebay Willowherb (Epilobium angustifolium) in addition to previously mentioned invasive plants. Sighting of a Heron (Ardea herodias) fishing in this area suggests the presence of suitable prey species at this site.
Plate 17: Pathway (location area 6; Figure 6)
Area 7 is a typical example of ED3 habitat but is highlighted on the map because of the body of water (Plate 18) that was used to hold the wastewater of the siteand may have influenced the local flora and fauna assemblages. The most abundant plants are Ragwort (Senecio sp.), Butterfly-bush (Buddleja davidii), Scentless Mayweed (Matricaria perforata) and Docks (Rumex sp.). This location, next to the garden area, also revealed a high abundance of Cinnebar (Tyria jacobaeae) caterpillars on Ragwort (Senecio sp.) and a Pied Wagtail (Motacilla alba) was sighted at the edge of the water.
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Plate 18: Retention Pond (location area 7; Figure 6)
The tidal pond area, Figure 6, Area 8, contains amenity grassland (GA2) and a water body (Plate 19). This area is adjacent to the SAC designated mudflats of the Great Island Channel. The area had most of the previously mentioned flora but was less managed and had a more natural feel (Plate 20). Additional species present included Ground elder (Aegopodium podograria), Yellow Hawkweed (Asteraceae Hieracium pratense), Hedge Bindweed (Convolvulus sepium), Creeping Thistle (Cirsium arvense), Woody Nightshade (Solanum dulcamara). Common Tern (Sterna hirundo) were sighted at this location.
Plate 19: Tidal Pond (location area 8; Figure 6)
Plate 20: Grassland around tidal pond (location area 8; Figure 6)
Although the Dynea factory is not part of the IFI brownfield site, this currently operating factory has to be mentioned here because it is located in the northwestern part of Marino Point. The factory is another industrial landmark that is in contrast with the surrounding rural landscape. Furthermore, owing to the location of the factory its operations influence the site by utilising the former urea storage building of IFI and transport of urea through the brownfield site from the jetty area (pers. com. Peter Desmond). Urea granules were sited by the author on pathways in area 3 during one of the field visits. 55
Figure 6: The habitats and areas of interest on the Marino Point Brownfield site
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5. Discussion
The results of this study show clearly that there has been a significant land-use change at Marino Point over the last 30 years. The site had been changed from a woodland dominated peninsula of approximately 24.29 ha to the present industrial brownfield site of approximately 45.09 ha. 5.1 Land-use change history The land-use change maps (Figures 2 and 3), produced from historic maps of 1842, 1902 and 1935, show that land-use changed minimally during those 93 years, compared to the major changes of the last 30 years. Woodland areas changed to a small degree and infrastructure such as roads and railway line came into the area and a single building was added between 1842 and 1902. Descriptions of the site prior to the N.E.T. development, detailed in 4.1, indicate that the overall character of the site remained constant until 1975, when the N.E.T. started to reclaim land to the north of Marino Point, as shown in Figure 5. Marino Point was a natural landmark in Cork Harbour that included elevated areas and woodland, and the only infrastructural features present were three buildings, the road and the rail connection. Residents of the adjoining areas used the site for recreation. Overall land-use changed slowly in the area during the 133 years from 1842 to 1975 while the rural character of the overall landscape was maintained. Section 4.1 shows that despite the fact that adjoining areas to the north and east of Marino Point were designated for their scenic and recreational amenity value and numerous objections from residents and An Taisce regarding the direct impacts of an industrial development in the area on the natural environment, an industrial plant was still developed at the site. The proposed development was first refused on grounds of visual and landscape criteria on August 13, 1974 but this decision was reversed within six days and officially the application was granted by the end of that same month (section 4.1). The development went ahead without records of an independent assessment regarding the impact of the development on the overall landscape and the direct impacts on flora and fauna of the area. Assessments and reports routinely referred to the proposed development as clean and modern because sulphur dioxide was not used. However, it was not shown how the actual processes, emissions and discharges could impact on the natural environment.
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The development of the area started under the framework of the Local Planning and Development Act from 1963 and was supported by the zoning of the area for industrial, port orientated use in the County Development Plan from 1973. The N.E.T. Company showed in their planning application provisions for noise and emission control as well as landscape plans to minimise the visual impact. The company went into a Bond with Cork County Council as a guarantee to reinstate the land to uses agreed with the authority after the plant would cease operation (section 4.1). However, the documented land-use change from rural to industrial shows that legislation of that time did not emphasise the aspects of the development that would impact on the natural environment. A similar contemporary development would have to undergo an Environmental Impact Assessment (EIA), as part of Irish legislation that came into force in 1989 under the EIA Regulation and the Amendment of 1994, which contains statutory procedures and rules to assess the impact of a development on the natural environment. In the case of the N.E.T. development, Cork County Council was responsible for the impact the development would have in a physical and landscape aesthetic characteristics of the area as well as overseeing the licensing of emissions and discharges. Under the EPA Act from 1992 a company planning a development similar to N.E.T. would have to apply to the EPA for licences for emissions and discharges and an EIA would be requested by the Agency. The EPA would be responsible to put in place provisions for the protection of the environment. Furthermore, planning permission would have to be gained from Cork County Council for issues, other than environmental quality, such as infrastructure e.g. traffic congestion and visual impact of the overall development. The history of the land-use change from rural to industrial in the area (section 4.1) suggests that the legislation of that time was not sufficient enough to assess impacts of such a development on the natural environment. In the context of the current legal situation, it can be stated that the legal framework provides more protection to the environment with regard to change of land-use. Overall with the N.E.T. development the character of the landscape and the site itself was altered. Marino Point became bigger through the land reclamation (Figure 5) and elevated areas were reduced, thus changing the physical characteristics of the area significantly. Infrastructure developed dramatically from one of the least obvious landuses (Figure 4) to the most visible feature of the site with the construction of more 58
roads, artificial surfaces and industrial buildings. These large-scale changes to the environment at Marino Point took place within only four years between 1975 and 1979, when the company commenced operation. Although flora and fauna can adapt to certain changes of human land-use, the land-use change on Marino Point happened quickly and dramatically compared to previous environmental changes in the area. Animal and plants living in adjacent areas of Marino Point would have been disturbed by the fragmentation of the landscape, as well as the noise impact resulting from the activities associated with the construction development of the site. Owing to the land reclamation, parts of the mudflats, which are now designated as cSACs and are part of a Natura 2000 site, were removed and this habitat was lost, hence it can be assumed that species living in these habitats were lost. On the former peninsula of Marino Point, habitats were lost due to the removal of woodland as well as flattening of the area. Both habitat fragmentation and habitat loss have the consequence of reducing biodiversity on different levels such as the landscape, the species and the genetic level. 5.2 Operational phase The Cork County Council records (Table 1) document the operational phase of N.E.T. (later IFI) up until 1992, when the EPA took control over the licensing and environmental impacts of IFI. The council records were viewed on microfilm and some notes were not legible owing to the age of the records and/or because some records were hand written. However, the records show only occasional evidence of incidents and do not show any regular recording of emissions and discharges or non-compliances to licences under which the company operated. Most incidents were recorded in 1979, the year the company commenced operation. The incidents recorded in June, July and August of that year were serious, resulting in the medical treatment of children on a bus, scorching of vegetation and low visibility for aircrafts above the plant. Nevertheless, no records of follow up studies regarding the impact of these incidents on the surrounding environment were available in the files. Furthermore, recording became more and more infrequent. This could be to a very small extent the result of non-readable records but the chances that all possible assessments of environmental impacts of company incidents were not decipherable are highly unlikely. The EPA files of 1995 documented that Cork County Council granted a licence under 59
the Air Pollution Act, 1987 in the year of 1991, which was not shown in the County Council’s own files. This could indicate that over the years recordings related to the operational phase of the company have been filed elsewhere or misplaced. It also raises the question why the licence was only granted in 1991 even though the legislation was in place since 1987. Overall, the records by Cork County Council from 1979 to 1992 (Table 1) show that incidents were only documented occasionally and without follow up studies on their impacts on the environment. Furthermore, the records show that a methodology for monitoring and recording of incidents and non compliances was lacking, and that a separate body for controlling industry was required. The reported incidents are, nonetheless, evidence that the operational phase of the company impacted on the surrounding environment. However it is not possible to establish from these reports to which extent incidents would have influenced habitats that were in the surrounding area. Under the EPA Act, 1992 the EPA was formally established in 1993. The Agency took over the responsibility for licensing and regulation of industrial processes with significant polluting potential. Licensing takes place on the basis of Integrated Pollution Control (IPC) and the application of best available technologies for this purpose. Further duties of the agency include the monitoring of environmental quality and the promotion and co-ordination of environmental research (Macken, 1996). The EPA records from 1995 to 2002 (section 4.3) show that monitoring and recording of incidents and non-compliances happened on a regular basis. Environmental reports were given by the IFI to the EPA on a monthly basis and the agency also checked these reports with their own monitoring. The records also show that other bodies such as Bord na Mona, Forbairt and different consultancies carried out studies to examine specific issues related to IFI discharges and emissions. Fobairt Enterprise Ireland is comparable to the former Industrial Development Authority (IDA) in Ireland and is responsible for national industrial development in the country (pers. com. Brendan Kelleher). Bord na Mona is mostly associated with products and services involving peat but consists of four main companies. One of these companies, Bord na Mona Limited, is an environmental management company, which takes on environmental monitoring services, wastewater treatment and air pollution control. Table 2 demonstrates that in comparison to Table 1 newer legislation provided for increased control, monitoring and recording of the IFI discharges and emissions. 60
Table 2 shows that the IFI was granted an IPC licence in December 1996. Stricter guidelines for the emissions and discharges as well as increased monitoring were applied, which is reflected in the increased recording of non-compliances. It was not stated why the IFI was not granted the IPC licence prior to 1996 but it could be that the company had to improve their operations to higher standards regarding emissions and discharges. The two years, after the licence had been granted, show an increased number of non-compliance reports, complaints, plant shut downs and incident reports. This indicates that IFI was having problems adapting to the higher standards requested by the EPA. Furthermore, IFI was summoned to court regarding the breaching of ammonia emission in 1997, showing that the company had difficulties to stay within the limits of certain aspects of its licence. Non compliances were recorded nearly every month; however it is important to take into consideration that the quantity, location and substances involved in those recordings are not necessarily the same. The IFI was a large factory and noncompliances were recorded for many different issues. Nevertheless, certain problems were reoccurring in most non-compliance reports (more details in Appendix 1). The reviewed EPA files showed no recordings or studies regarding the impacts that certain incidents or non-compliances had on the surrounding environments. However, in 1998 Cork County Council inquired if there were any studies on the surrounding vegetation damage and in a letter of the same year to the Environmental Alliance Ltd. the Agency acknowledged that, regarding a specific plant shut down, no independent monitoring or environmental studies had been undertaken. The only report that places the incidents of leakage and non compliance to discharge limits in context of effects on the environment is the Fobairt report that investigated the toxicity of IFI effluents on aquatic species. The details of which species were affected and to what extent are provided in Appendix 1. This report only shows results but did not provide either an introduction or a conclusion. It was not recorded, what conclusions and consequences the EPA and IFI took from the report. The report clearly shows (Appendix 1) that aquatic species were affected by these liquid effluent samples. The Bord na Mona reports (Table 2) on groundwater quality showed that the groundwater flowing in a north-western direction beneath the IFI site contained nitrogenous compounds. Contaminated groundwater flowing from the IFI into the 61
direction of the designated mudflats and western waters could have possibly influenced the designated habitats as well as other aquatic life to the west of the IFI. With regard to the designated areas north of the site, it is possible that, with the regular occurrence of non compliances and contaminated groundwater beneath the site, that these habitats would have been affected adversely over time. Possible habitat changes are difficult to determine because the National Parks and Wildlife Service (NPWS) only visually assessed cSACs (pers. com. Patrick Smiddy). EPA studies to investigate how non compliances or the groundwater contamination and flow affected the natural environment of the IFI were either not undertaken or not recorded. In addition, the NPWS stated that there had been no consultation between the EPA and the NPWS regarding the designated habitats and effects of non compliances (pers. com. Patrick Smiddy). Visual assessments undertaken by the NPWS did not confirm any signs of habitat change (pers. com. Patrick Smiddy) but visual assessments might not be sufficient enough to detect habitat quality changes. For any effective assessment it would have been important to correlate non-compliances and possible effects on the habitats, which would only have been possible in cooperation with the EPA. Therefore it is impossible to determine if, and to what extent, the mudflat habitat quality was affected by the IFI operational phase, because no pre-assessment of the habitats was undertaken prior to the N.E.T. and later IFI operational phase. The mudflat habitats, adjacent to the site, were designated after the European Communities Habitats Regulation, 1997. Article 18 of this Regulation prohibits activities outside the designated area that could have adverse effects on the integrity of the designated area. It is difficult to establish if the industrial activity at the site had adverse effect on the integrity of the area because the data documenting the original state of the designated site prior operation is missing. This difficulty is compounded by the fact that additional data showing how non-compliances, incidents and groundwater contamination affected the surrounding environments is also not available. Therefore, it is essential for future developments that the designated habitats are assessed and that indicators for the integrity of the site are measured against possible adverse influences. Overall, it can be stated that the operational phase of the company would have influenced surrounding habitats but owing to missing data the extent and how these habitats were influenced cannot be determined and is subject to speculation.
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5.3 The Habitats on the Marino Point Brownfield site Figure 6, which details the habitat descriptions of Marino Point (section 4.4), show that new life is colonising the area, taking over pathways, formerly managed amenity areas and the industrial part of the site. The majority of plant assemblages found on the site are typical for brownfield sites, where non-native plants like butterfly-bush (Buddleja davidii) grow next to native weeds such as common ragwort (Seneco jacobae). However, the former IFI site on Marino Point contains several different habitats. Recolonising bare ground ED3 (Fossit, 2000) is the largest habitat on the site but other areas of interest and habitats, shown in Figure 6 and described in section 4.4, are features of the site that have value as habitats in themselves. The area of Marino House and garden, Figure 6, is exceptional owing to features such as the Georgian House, the glasshouse buildings and the historic stonewall. This area includes previously managed amenity grassland areas, mature trees and an established garden and is a rather surprising idyllic setting, contrasting strongly to the former production area of the site. Area 2, Figure 6, also includes mixed habitats of amenity grassland in between areas of scattered trees and the mixed broadleaved/conifer woodland WD2. This woodland gives a more natural experience and provides shelter to birds. Animals from adjacent areas could be utilising this woodland. The whole area softens the ecotone between the environment adjacent to the site and the production area of the site, also working as a screen between Marino House and garden and area 3. The elevated rock face with the mixed broadleaved woodland WD1, Figure 6, area 4, is another more natural habitat giving possible shelter to animals and includes many mature trees and a mixed under storey. This area also screens the production area of the IFI from Passage West. The beach to the west of Marino Point, Figure 6, area 5, forms a natural boundary between the terrestrial habitats of the woodland rock face and the aquatic habitat adjacent to the site. The area around the tidal pond, Figure 6, area 8, is the closest habitat to the designated mudflats and seems more natural than most of the brownfield site. Birds utilising the mudflats can find shelter in this grassland dominated area, which again softens the ecotone of the production site towards the mudflats forming a transition zone. The main production parts of the ammonia and urea plant have been removed from the site to South America to rebuild the factory there (pers. com. Peter Desmond). However, there are still many buildings and features of the former production site 63
present and some of these are not in good condition and show evidence of corrosion. Furthermore, the former urea storage building is still used to store urea that is transported from the jetty to the adjacent the Dynea factory (pers. com. Peter Desmond). During transport urea spillage can still occur and evidence of this was noted close to the jetty during one of field visits. Corroding features and urea storage and transport could still adversely influence the groundwater and the surrounding habitats of the brownfield site and any future development of the site should include a clean-up of the site and control measures for the ongoing urea transport. Section 4.4 and Figure 6 indicate that new life has invaded the site and already established areas of amenity and semi-natural habitats have increased and become overgrown. It is evident through sighting during the field visits and from personal communication that birds utilise the area. Areas that should be taken into account, when future development is considered, are Marino House, its garden and surroundings, the woodlands, the beach and the area surrounding the tidal pond. These areas have intrinsic value owing to their historic features and/or they provide habitat for flora and fauna. Furthermore these areas would soften the ecotone between the adjacent environment and any future development of the site, bringing more continuity into the landscape as transition zones.
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6. Conclusion • The development on Marino Point between 1975-79 changed the land-use of the
site from rural to industrial, fragmenting the landscape and leading to rapid habitat loss in comparison to land-use change during the previous 133 years.
• Under current legislation, any new development on this site would have to be
assessed with respect to both the impacts during construction and of the final development itself with regard to the overall landscape character and habitats on and adjacent to the site.
• Cork County Council and EPA records show that with improved legislation, the
monitoring, assessment and control over discharges and emissions to the environment has definitely improved. Furthermore, the records confirm that the production phase by NET and subsequently IFI could have affected surrounding habitats of the site adversely. However, the records also demonstrate that this aspect of the development was not adequately assessed in order to determine if, how and to what extent habitats were affected. • Under the current legislation any similar new development at this site should assess the impacts of non-compliances and incidents on the surrounding habitat, especially regarding the designated mudflats north to Marino Point. It is necessary to determine the current status (baseline data) of the designated areas regarding habitat quality to make sure any new development would not adversely affect the integrity of these habitats. Therefore, communication and coordination of environmental assessments between the EPA and the NPWS is essential. • Prior to any new development on Marino Point the groundwater quality has to be tested to determine if clean-up measures are required. Furthermore, any new development should not adversely affect the groundwater quality to avoid health and safety issues for both persons utilising the site and to minimise possible negative effects on the surrounding habitats. • Historic features and the habitats on Marino Point that provide shelter for flora and fauna and soften ecotones to any new development should be preserved. 65
These habitats act as transient zones to the adjacent environment and should be maintained and supported to improve the continuity of the landscape.
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References:
Alberinia, A., Longoc, A., Tonind, S., Trombettad, F., and Turvanid M., 2005. The role of liability, regulation and economic incentives in brownfield remediation and redevelopment: evidence from surveys of developers. Regional Science and Urban Economics 35, 327– 351. BirdLife International, 2005. BirdLife IBA Factsheet. IE088. http://www.birdlife.org/datazone/sites/?action=SitHTMDetails.asp&sid=599& m=0. Date: 15.05.2005. Bruntland Report (Our Common Future), 1987. The findings of the World Commission on Environment and Development (WCED). http://www.worldsummit2002.org/index.htm?http://www.worldsummit2002.or/ guide/brundtland.htm Date: 17.05.2005. Businessworld, 2005.http://www.businessworld.ie/coys/details.htm?u=2030. Date: 08.08.2005. Chapman, D. and Donovan, J., 1996. Equity and Access. In: David Chapman (Editor). Creating Neighbourhoods and Places in the Built Environment, London; New York: E&FN Spon, 248 pages. Clark, M., 2001. Domestic futures and sustainable residential development. Futures 33, 817–836. Corepoint, 2005. COREPOINT - Coastal Research Policy Integration. http://corepoint.ucc.ie/index.php. Date: 15.05.2005. Cork County Council, 1966-1. County Council Planning Permission to Steward French, 23.11.1966. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1966-2. Letter on behalf of Mr. S. French by Chillingworth & Lewis, 26.11.1966. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1972. Cork County Council refuses Planning Permission to Mr. J. Barry, 07.12.1972. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department.
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Cork County Council, 1974-16. Document by N.E.T. regarding meeting with the Forestry Inspector, 05.02.1974. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1974-17. Copy of Inspectors advisory report to Cork County Council, 12.03.1974. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1974-18. Appeals against Planning Permission, September 1974. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1974-19. Appeal by Barry C. Calvin & Son on behalf of Mrs. Nora Federow, 06.09.1974. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1974-20. An Taisce appeal of Planning Permission 13.09.1974. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1974-21. Draft Document by N.E.T. concerning Appeals, 13.11.1974. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1974-22. Correspondence of Cork County Council with Minister for Transport, 12.09.1974. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1975-1. Minister for the local government grants Planning Permission, 23.04.1975. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1975-2. Letter to Cork Harbour Commissioners from Cork County Council, 13.06.1975. Files regarding Marino Point, Cobh, County Cork Microfilm in Cork County Council Planning department. Cork County Council, 1976-1. Cork County Council Planning Permission to Nitrigin Eireann Teoranta (N.E.T.), 02.03.1976. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1976-2. Cork County Council Planning Permission to Bord Gais Eirann, 26.10.1976. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. 70 on
Cork County Council, 1976-3. Cork County Council Bond with N.E.T., 13.02.1976. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1976-4. Conference between N.E.T. and Cork County Council, 13.05.1976. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1976-5. Correspondence between the Cork County Council Architect and Cork County Coucil, 14.07.1976. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1977-1. Letter by Mr. J. H. Audley to the Taoiseach, 17.01.1977. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1977-2. Mr. J. H. Audley registers objection against N.E.T. Ammonia Storage Tanks, 08.02.1977. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1977-3. Appeals against the Nitrigin Eireann Teoranta (N.E.T.) Planning Application, February and March 1977. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1977-4. Mr. J. H. Audley and Mr. M. F. O’ Connell appeal Cork County Council Planning Permission, 05.04.1977. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1977-5. Mr. J. H. Audley additional appeals against Cork County Council Planning Permission, 06.05.1977, 17.09.1977, and 05.12.1977. regarding Marino Point, Cobh, County Cork on Microfilm in Council Planning department. Cork County Council, 1977-6. Schedule of Cork County Council Planning Permission to Nitrigin Eireann Teoranta (N.E.T.), 31.03.1977. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1978. Letter from the Cork County Council Secretary to the Department of the Environment, 03.08.1978. Files regarding Marino Point, 71 Cork Files County
Cobh, County Cork on Microfilm in Cork County Council Planning department Cork County Council, 1979-1. N.E.T. report to Cork County Council, 1979. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1979-2. Letter from the Cork County Council to Cork County Council Planning department. Cork County Council, 1979-3. Letter from the Chief Environmental Officer to the Planning Department, 27.07 1979. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1979-4. Letter from the Chief Medical Officer to the Planning Department, 16.07.1979. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1979-5. Document by Planning Department, 15.08.1979. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1980-1. Emergency Procedure Manual, 08.01.1980. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1980-2. Letter from the Chief Superintendent to the County Manager, 03.07.1980. Files regarding Marino Point, Cobh, County Microfilm in Cork County Council Planning department. Cork County Council, 1980-3. Correspondence between Pearts Solicitors and Cork County Council, 13.08 1980. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1980-4. Record of meeting between Cork County Council and N.E.T., 02.09.1980. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1981-1. Meeting record of the planning department, 23.03.1981. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1981-2. Update of Emergency Procedures, April 1981. 72 Cork on N.E.T., 16.02.1979. Files regarding Marino Point, Cobh, County Cork on Microfilm in
Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1987-1. Letter from N.E.T. to Cork County Council, 09.03.1987. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1987-2. N.E.T. register as Irish fertilizer Industries (I.F.I.), 06.10.1987. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1997-1. Cork County Council Grant Planning Permission, 23.05.1997, Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 1997-2. Cork County Council Grant Planning Permission, 26.06.1997. Files regarding Marino Point, Cobh, County Cork on Microfilm in Cork County Council Planning department. Cork County Council, 2003. Planning Policy Unit. Cork County Development Plan 2003. Cummins, V., O’Mahony, C. and Connolly N., 2004. Review of Integrated Coastal Zone Management & Principles of Best Practice. Prepared for the Heritage Council by the Coastal and Marine Resources Centre. Cummins, V. and O’Donnell, V., in press. The challenge of Change – Contemporary Marine Geography of Cork Harbour. Atlas of Cork city – Section VI – The Challenge of Change. De Sousa, C. A., 2003. Turning brownfields into green space in the City of Toronto. Landscape and Urban Planning 62, 181–198. Duhme, F., Pauleit, S. and Baier, H., 1997. Quantifying targets for nature conservation in future European Landscapes. Landscape und Urban Planning 37, 73-84. EEA (European Environment Agency), 2005. Brownfield Site Definition. European Environment Agency Homepage Glossary. http://glossary.eea.eu.int/EEAGlossary/B/brownfield_site. Date: 01.05.2005. EPA, 1995. Irish Fertilizer Industry, Marino Point, Cobh, County Cork. Environmental Protection Agency File 1995. EPA, 1996. Irish Fertilizer Industry, Marino Point, Cobh, County Cork. Environmental Protection Agency File 1996. EPA, 1997. Irish Fertilizer Industry, Marino Point, Cobh, County Cork. Environmental Protection Agency File 1997. 73
EPA, 1998. Irish Fertilizer Industry, Marino Point, Cobh, County Cork. Environmental Protection Agency File 1998. EPA, 1999. Irish Fertilizer Industry, Marino Point, Cobh, County Cork. Environmental Protection Agency File 1999. EPA, 2000. Irish Fertilizer Industry, Marino Point, Cobh, County Cork. Environmental Protection Agency File 2000. EPA, 2001. Irish Fertilizer Industry, Marino Point, Cobh, County Cork. Environmental Protection Agency File 2001. EPA, 2002. Irish Fertilizer Industry, Marino Point, Cobh, County Cork. Environmental Protection Agency File 2002. EU Environmental Information and Legislation Database, 2005. http://www.ncte.ie/environ/chemical.htm. Date: 08.08.2005. Fitter, R., Fitter, A. and Blamey, M., 1996. Wild Flowers of Britain and Northern Europe. Harper Collins Publishers, 352 pages. Fossit, J. A., 2000. A Guide to Habitats in Ireland. The Heritage Council, 114 pages. Gregory, I., 2002. A Place in History-A Guide to Using GIS in Historical Research. http://hds.essex.ac.uk/g2gp/gis/index.asp. Date: 16.08.2005. Hamilton Osborne King Ltd, 2005. Hamilton Osborne King Ltd 12 South Mall, Cork. http://www.hok.ie/images/commercial/10005019/10005019_brochure.pdf. Date: 25.06.2005. Harrison, C. and Davies, G., 2002. Conserving biodiversity that matters: practitioners' perspectives on brownfield development and urban nature conservation in London. Journal of Environmental Management (2002) 65, 95-108. Hasselriis, F., 2004. Book reviews: Brownfield Sites, Assessment, Rehabilitation and Development, Editors: Brebbia, C.A., Almorza, D. and Klapperich, H., WIT Press, September 2002. Waste Management 24, 429–430. Hough, M., 2004. Cities & Natural Processes: A basis for sustainability. 2nd Edition, Routledge Taylor & Francis Group, London and New York, 292 pages. IE 0001058, 2000. Natura 2000 Standard Data Form, 2000. Irish Legal Information Initiative, 2005. WILDLIFE (AMENDMENT) ACT, 2000. http://www.ucc.ie/law/irlii/statutes/2000_38.htm. Date: 09.05.2005. Irish Statute Book, 2005. EUROPEAN COMMUNITIES (NATURAL HABITATS) REGULATIONS, Date: 09.05.2005. http://www.esri.com. Date: 25.06.2005. 74 1997. http://www.irishstatutebook.ie/ZZSI94Y1997.html.
IUCN (World Conservation Union), 2005. European Programme 2005-2008. Regional Office for Europe. http://www.iucn.org/places/europe/rofe/documents/IUCN%20European%20Pr ogramme%202005-2008%20final.pdf. Date: 17. 05. 2005. Jongman, R. H. G., 2002. Homogenisation and fragmentation of the European landscape: ecological consequences and solutions. Landscape and Urban Planning 58, 211-221. KMPG, 2005. KMPG in Ireland Homepage. http://www.kpmg.ie/. Date: 08.08.2005. LOSPAN, 2001. Local Spatial Planning: The Identification of Spatial Policies and Activities in Coastal Areas. INTERREG ||c Programme. Phase 1 Report. Appendix 3. Lyons P. and O’Suilleabhain D., 2004. Introduction to Cork County Council and Planning in Cork. Presentation by the Planning Policy Unit / Cork County Council / 25th November 2004. Macken, K., 1996. BATNEEC Chemical Note. Integrated Pollution Control Licensing. Batneec 8, Guidance Note For The Chemical Sector. www.epa.ie/Licensing/IPPCLicensing/BATNEECGuidanceNotes/FileUpload,57 en. DOC. Date: 17.08.2005. to private redevelopment while connecting reuse to broader community goals. Land Use Policy 19, 287–296. Moore, N. M., 2002. From indigenous industry to foreign finance: the changing face of Dublin Docklands. Land Use Policy 19, 325–331. Muir, T., 1996. Modern Urban Places. In: David Chapman (Editor). Creating Neighbourhoods and Places in the Built Environment, London; New York: E&FN Spon, 248 pages. Natura 2000 code IE 0001058, 2000. Natura 2000 Standard Data Form, 2000. Naveh, Z. and Lieberman, A., 1993. Landscape Ecology: Theory and Application, Second Edition, Springer Verlag, New York, Inc, 360 pages. Oireachtas, 2005. LOCAL GOVERNMENT ACT 2003. http://www.oireachtas.ie/documents/bills28/acts/2003/a803.pdf. Date: 17. 05. 2005. Overview of Water Framework Directive, 2005. http://www.epa.ie/PublicAuthorityServices/WaterFrameworkDirective/. Date: 17. 05. 2005. 75 McCarthy, L., 2002. The brownfield dual land-use policy challenge: reducing barriers
Port of Cork, 2002. Strategic Development Plan: Non-technical summary. Port of Cork Company, February 2002. Port of Cork, 2004. Port of Cork Yearbook 2003/2004. Published by Hillgate Publishing Ltd., Dublin. Stakeholders Conference, 2005. Biodiversity and the EU – Sustaining Life, Sustaining Livelihoods. Grand Hotel, Malahide, Ireland 25-27 May 2004. MALAHIDE/WGP/Towards2010/1.Background Paper for Working Group 1 TOWARDS 2010 no.1 (ECBS/BAP-NR). www.eu2004.ie/templates/documentfile.asp?id=17071. Date: 17. 05. 2005. US EPA (United States Environmental Protection Agency), 2005. Brownfields Definition. US EPA Brownfields Homepage. http://www.epa.gov/brownfields/glossary.htm. Date: 01.05.2005. Water Framework Directive, 2005. http://www.wfdireland.ie. Date: 01.05.2005 Wright, L. J., 1996. Nature and Settlement. In: David Chapman (Editor). Creating Neighbourhoods and Places in the Built Environment, London; New York: E&FN Spon, 248pages.
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Appendix 1
77
In non-compliance records BOD refers to Biological Oxygen Demand. The BOD test is an estimate of organic matter available in samples used by aerobic bacteria in the presence of free oxygen. The more organic matter is present in waste the more Dissolved Oxygen (DO) will be required. The BOD test is used to measure efficiency regarding BOD removal, control plant processes and to determine the effects of discharges on receiving waters. Methanol levels are associated with the BOD levels in the liquid effluent treatment because Methanol can act as a food source for bacteria reducing nitrate to nitrogen. Date June 12, 1995 Notice Reference EPA reminds the EPA, 1995 company that with section 89(2) of the EPA Act 1992, the company has to forward all monitoring results to the EPA. July, 1995 Non compliance: IFI environmental report EPA, 1995 • Total nitrogen and BOD in to EPA liquid effluent • Ammonia emission to air July, 1995 Odour complaints EPA, 1995 July 12, 1995 Groundwater aquifers Bord Na Mona on EPA, 1995 beneath the IFI site are groundwater analysis contaminated to some extent by nitrogen components August, 1995 Non compliance: IFI environmental report EPA, 1995 • Total nitrogen, BOD and to EPA oil in liquid effluent • Ammonia emission to air August 03, and Odour complaints EPA, 1995 28, 1995 August 15, Derailment incident EPA, 1995 1995 August 24, IPC licence IFI apply for IPC licence EPA, 1995 1995 September 28, Non compliance Letter EPA to IFI request EPA, 1995 1995 • Total nitrogen, BOD and information concerning the inadequate response oil in liquid effluent in monitoring and work programmes for non compliances September 28, Odour complaint EPA, 1995 1995 September and Ambient air monitor Monitor in Passage West EPA, 1995 October, 1995 problems to record ammonia emission 78 Issue Monitoring results
October, 1995
Non compliance: IFI environmental report • Ammonia emission and to EPA BOD in liquid effluent • Urea and total nitrogen over limit at certain locations in storm water and • Ammonia emission to air October, 1995 Noise complaints Evidence of explosion, ground shook, yellow fumes October 13, Discharge Benfield solution No apparent damage to 1995 to atmosphere; increased vegetation or change in noise levels land and aquatic life noted after visual inspection October 05, Factory shutdown Nitrogen levels and 18, 1995 fluctuated November 02, Discharge of nitrogen above 1995 the licence limit and substantial quantities of oil in liquid effluent, in the wastewater; main contaminants in effluent are ammonia and urea; other contaminants are oil, alkalis and acids. November, Non compliances: 1995 • Total nitrogen and BOD levels in liquid effluent. November 21, Factory shutdown 1995 November 24, Groundwater aquifers 1995 beneath the IFI site are contaminated to some extent by nitrogen components December 04, The prill tower and the 1995 granulator of the urea plant are major sources of air pollution. December Non compliance: 1995 • Total nitrogen and BOD in the liquid effluent • Forbairt were not able to carry out some tests on air emission but found ammonia levels at the urea plant were above limits.
EPA, 1995
EPA, 1995 EPA, 1995
EPA, 1995
Report from F.T.A. EPA, 1995 Weston Ltd. Consultancies regarding IFI wastewater recommends wastewater maintenance and minimisation programmes IFI environmental report EPA, 1995 to EPA No unusual emission EPA, 1995 noted Bord Na Mona on EPA, 1995 Groundwater analysis Bord Na Mona Emission report Air EPA 1995
IFI environmental report EPA 1995 to EPA
79
Date January 1996
Issue No non compliances recorded February 1996 Non compliance: • Total nitrogen levels, BOD and oil in the liquid effluent • Nitrogen in stormwater Non compliance: • Total nitrogen, BOD and oil in the liquid effluent • Forbairt were not able to carry out some tests on air emission but found ammonia levels at the urea plant were above limits. March 01, Groundwater aquifers 1996 beneath the IFI site are contaminated to some extent by nitrogen components April 1996 Non compliance: • Total nitrogen and BOD in the liquid effluent • Urea overflow and spillage April 19, 1996 • Nitrogen emission to harbour 2,000 kg per day during start-up and shutdown of plant • Contaminated groundwater with nitrates May 01, 1996 March 1996
Notice Reference IFI environmental report EPA, 1996 to EPA IFI environmental report EPA 1996 to EPA
IFI environmental report EPA 1996 to EPA
Bord Na Mona on EPA, 1996 groundwater analysis IFI environmental report EPA 1996 to EPA
May 1996
May 10, 1996
Letter from Belvelly EPA 1996 District Community to EPA request strict guidelines regarding atmospheric emissions and water discharges with IPC licence Main source nitrogen Letter from IFI to EPA; EPA 1996 contamination from urea put procedures in place to plant and environment minimise leaks and spillages Non compliance: IFI environmental report EPA 1996 • Total nitrogen, ph and to EPA BOD in the liquid effluent • Nitrogen in stormwater • Urea dust level and ammonia level higher than normal for air emission Odour complaints EPA 1996
80
May 17, 1996
June 05, 1996 June 1996
June 16 and 17, 1996 July 1996
August 1996
August 31, 1996 September 1996
September 26, 1996 October 1996 21,
Ongoing emission of Cork County Council air brown/yellow fumes from laboratory documents; IFI concern regarding the breach of licences, visual impacts and impacts on human health; Witnessed by members of the staff on 09.05.1996 and 16.05.1996 Plant shut down Problem cooling water flow Non compliance: IFI environmental report • Nitrogen and urea in the to EPA liquid effluent • Ammonia emission to air Release of Urea Higher levels of urea and nitrogen in liquid effluent Non compliance: IFI environmental report • Nitrogen and BOD in the to EPA liquid effluent and • Ammonia emission to air Non compliance: IFI environmental report • Nitrogen and BOD in the to EPA liquid effluent • Nitrogen level in storm water • Ammonia emission to air Odour complaints Reason given by IFI are high ammonia levels Non compliance: IFI environmental report • Nitrogen (two nitrogen to EPA excursions during spillage) and BOD in the liquid effluent • Ammonia emission to air and odour complaints IPC licence EPA grants the IPC licence to IFI according to the EPA Act, 1992 Elevated levels ammonia EPA requests full reports emission to air regarding the failure of NH3/CO2 ratio instrument
EPA 1996
EPA 1996 EPA 1996
EPA 1996 EPA 1996
EPA 1996
EPA 1996 EPA 1996
EPA 1996 EPA 1996
81
• Plant shut down since the 04.10.1996 • Bio Unit not performing to its design and • Presence liquid effluent because of cleaning the plant November 19, Total nitrogen discharge 1996 through surface water drains and main sources; not effectively contained wash water for the turnaround and cleaning of the plant. November Non compliance: 1996 • High nitrogen level in the liquid effluent since completion of turnaround of the plant November 17, Ammonia plant shut down 1996 October 1996 December 02, 1996 December 06, 1996 December 08, 1996 December 09, 1996 December 23, 1996
IFI environmental report EPA 1996 to EPA
EPA requested EPA 1996 explanation from IFI
IFI environmental report EPA 1996 to EPA
Reason given by IFI is the failure in the waste heat boiler Urea deposits on the IFI informs EPA roadway and possible leakage during the shutdown of the plant Plant shut down and Result of gas leak due to Ammonia releases Failure syngas line Plant shut down Incident at Urea plant reactor valve Telephone complaint Maureen Devlet regarding bird kill in the complained to the EPA environment of the plant IPC licence had been EPA communication granted to the IFI from the with resident of Passage 20.12.1996. West Issue Notice
EPA 1996 EPA 1996
EPA 1996
EPA 1996 EPA 1996
Date January 1997
Reference
No non compliances recorded February 1997 Non compliance: • Nitrogen and BOD level in the liquid effluent • Urea excursion from dissolved urea dust • Plant shut down • Noise complaints February 17, Ongoing complaints since 1997 1995 regarding brownyellow fumes from IFI
IFI environmental report EPA 1997 to EPA IFI environmental report EPA 1997 to EPA
EPA informs IFI
EPA 1997
82
February 1997
24, Amines detected in off gas collection from waste gas vent March 1997 Non compliance: • Nitrate, BOD, phenol, oil/fat/greases in the liquid effluent • NOx, CO, ammonia and urea in air emmission March 07, Plant shut down 1997 March 14, Syngas system failure and 1997 leaking on 18.02.1997 March 1997 April 1997 24,
Bord na Mona monitored EPA 1997 air emission as required by IPC licence IFI environmental report EPA 1997 to EPA
April 22, 1997
April 24, 1997
April 24, 1997
April 30, 1997
Two odour and noise complaints IFI report on syngas failure 1996 upgrade of the system increased pressure on the system Brown colour emission IFI report to EPA and owing to the presence of proposal to continuation NO2 of their investigation Non compliance: IFI environmental report • Nitrate, BOD, total to EPA nitrogen, ph and urea excursion in the liquid effluent • CO, ammonia in air emission • Two odour complaints non compliance for EPA notification of non to IFI • BOD, total nitrogen, CO, compliance to their urea dust, noise, phenol, according nitrate, suspended solids, measurements flow, ammonia and ph Groundwater aquifers Bord Na Mona on beneath the IFI site are Groundwater analysis as contaminated to some extent required by IPC licence by nitrogen components Noise levels on feed Environmental noise compressor, urea prill tower report from EPA; discharge fans, urea plant • require noise forced draught fan reductions Odour nuisance; Bord na Mona Odour • Chemicals associated with assessment report as odour are ammonia, required by IPC licence aldehydes and amines; • Ammonia has the largest emission but aldehydes and amines contribute significantly to odour nuisance
EPA 1997 EPA 1997
EPA 1997 EPA 1997
EPA 1997
EPA 1997
EPA 1997
EPA 1997
83
May 1997
May 07, 1997
May 26, 1997
Non compliance: • BOD, total nitrogen and ph in the liquid effluent • Ammonia and urea dust in air emission • Plant shut down on 04.05.1997 • Four noise complaints when plant shut down Syngas leak ca 100kg syngas escape containing ammonia Plant shut down Noise complaint Non compliance for • BOD, nitrate, ammonia, CO and urea
IFI environmental report EPA 1997 to EPA
EPA 1997
June 1997
June 25, 1997
July 1997
July 03, 1997
July 23, 1997
EPA notification of non EPA 1997 compliance to IFI according to their measurements Non compliance: IFI environmental report EPA 1997 • BOD, nitrate, ph and to EPA temperature in the liquid effluent • Ammonia and urea dust in air emission • one odour complaint Non compliance for EPA notification of non EPA 1997 to IFI • BOD, ammonia, CO and compliance according to their urea dust measurements Non compliance: IFI environmental report EPA 1997 to EPA • BOD in the liquid effluent • CO2, ammonia and urea dust in air emission • Plant shut down on 20.07. to 27.07.1997 • One noise complaint and two odour complaints • Release of hot gas Incident report of IFI to EPA 1997 containing potassium EPA from 10.07.1997 regarding Rupture and carbonate solution; • Discharge towards east disc failure of CO2 direction Marino Farm stripper scorching and discolouring of the vegetation Groundwater aquifers Bord Na Mona on EPA, 1996 beneath the IFI site are groundwater analysis contaminated to some extent by nitrogen components
84
July 24, 1997
Offence breaching of Summons to Court EPA ammonia emission licence is the prosecutor and IFI the accused July 24, 1997 complaint Cloud of smoke and dust August 1997 Non compliance: IFI environmental report • BOD, total nitrogen, ph and to EPA higher flow at some locations in the liquid effluent • Urea dust in air emission • One noise complaint, one odour complaint August 1997 Non compliance for EPA notification of non to IFI • BOD, total nitrogen, ph, compliance according to their urea dust and ammonia measurements August 11, Dust dissolving tank Incident report of IFI to 1997 overflow EPA August 18, • Scophthalmus maximus Toxicity report regarding 1997 (Black Sea Turbot), 20% bonna pipe effluent and mortality at 100% vol/vol final effluent “The acute of the bonna pipe effluent toxicity of two IFI to selected and no mortality at samples aquatic species” by 56%vol/vol • Tigriopus brevicornis Fobairt Enterprise Ireland (copepod specie), no mortality against the bonna pipe effluent • Skeletonema costatum (Diatom), growth inhibition against the bonna pipe effluent • Vibrio fischeri (marine bacterium), no light inhibition against the bonna pipe effluent • Salmo gairdneri (rainbow trout), showed 100% mortality at 100%vol/vol and 56%vol/vol against bonna pipe effluent and no mortality against final effluent • Crango crangon (Common shrimp), 100% mortality at 100%vol/vol and 56%vol/vol against bonna pipe effluent and no mortality against final effluent • Lemna minor (Lesser
EPA 1997 EPA 1997 EPA 1997
EPA 1997
EPA 1997 EPA 1997
85
Duckweed), growth inhibition against the final effluent September Non compliance: 1997 • BOD, total nitrogen and higher flow at some locations in the liquid effluent • Urea dust and ammonia content in air emission October 1997 Non compliance: • BOD, total nitrogen and higher flow and seawater leakage in the liquid effluent • Leak at Urea Plant and shutdown 04.10. And 05.10. 1997 • Ammonia content in air emission • One noise complaint, two odour complaints November Non compliance: 1997 • BOD, total Nitrogen, ph, Nitrate and higher flow in the liquid effluent • Ammonia content in air emission • One noise complaint, eight odour complaints November 03, Plant shut down 1997
IFI environmental report to EPA
IFI environmental report EPA 1997 to EPA
IFI environmental report EPA 1997 to EPA
Odour complaints EPA 1997 because of nitrate concentration in liquid effluent November 27, Groundwater aquifers Bord Na Mona on EPA 1997 1997 beneath the IFI site are Groundwater analysis as contaminated to some extent required by IPC licence by nitrogen components December Non compliance: IFI environmental report EPA 1997 1997 • BOD, total nitrogen, to EPA oil/fat/greases ph, nitrate and higher flow in the liquid effluent • Ammonia content in air emission
86
Date January 1998
Issue
Notice
Reference
Non compliance: • BOD, total nitrogen, ph and higher flow in the liquid effluent • Unplanned plant shut down • One noise complaint and twelve odour complaints February 1998 Non compliance: • Breaches of flow rate and BOD in the liquid effluent • Ammonia emission to air • Three noise complaint and three odour complaints February 12, • Additional boreholes 1998 showed elevated nitrate levels in domestic groundwater supply • Possible intrusion of contaminated plume along discrete subsurface layers • Some levels nitrate exceed European standards • General migration groundwater in northwestern direction February 24, Plant shut down 1998 March 1998 Non compliance: • Total Nitrogen and methanol (associated with BOD) in the liquid effluent • Dust resolving unit for air April 1998 Non compliance: • One noise complaint and four odour complaints April 04, 1998 Vegetation damage in Belvelly and Marino Point area-includes browning of leaves and shoots to complete withering of plants
IFI environmental report EPA 1998 to EPA
IFI environmental report EPA 1998 to EPA
Bord Na Mona on EPA 1998 Groundwater analysis as required by IPC licence; • Follow up regarding results from domestic wells
Release of ca 80 to EPA 1998 100kg ammonia to air IFI environmental report EPA 1998 to EPA
IFI environmental report EPA 1998 to EPA Letter from county EPA 1998 council to EPA; • Want to know if EPA are aware and if study is requested regarding air quality and floral health
87
May 1998
May 18, 1998
June 1998
July 1998
August 1998
August 1998
Non compliance: • Total nitrogen, flow and BOD in the liquid effluent • Plant shut down Changing groundwater gradients may influence groundwater flow and may result in transient flow of contaminants into the western direction Non compliance: • Total nitrogen, flow, ph BOD in the liquid effluent • One noise complaint and three odour complaints Non compliance: • Total nitrogen, flow, nitrate, urea and BOD in the liquid effluent • Plant shut down 05.06.1997 • Current gas leak into water circuit resulting in higher flow rates in final effluent Non compliance: • Total nitrogen, flow, urea, BOD/methanol in the liquid effluent • Ammonia emission to air • One noise complaint and one odour complaints Emergency shutdown and flaring of gases on 05.07. 1998
IFI environmental report EPA 1998 to EPA
Bord Na Mona on EPA 1998 Groundwater analysis as required by IPC licence; • Follow up regarding results from domestic wells IFI environmental report EPA 1998 to EPA
IFI environmental report EPA 1998 to EPA
IFI environmental report EPA 1998 to EPA
Letter from EPA to EPA 1998 Environmental Alliance Ltd.; Informing that EPA • Has not monitored independently after the incident • Have not investigated the impact on the natural environment
88
September 1998
October 1998
November 1998
December 1998
Non compliance: • Total nitrogen, flow, ph urea, BOD/methanol in the liquid effluent • Plant shut down 13. and 28.09.1998 • Twelve noise complaints and three odour complaints Non compliance: • Total nitrogen, flow, ph urea, BOD/methanol in the liquid effluent • Ammonia emission to air • One noise complaint and two odour complaints Non compliance: • Flow, ph, urea, BOD/methanol in the liquid effluent • Plant shut down 07. and 08.10.1998 Non compliance: • Total nitrogen, flow, ph urea, BOD/methanol in the liquid effluent • Ammonia emission to air • Plant shut down 26.12.1998 Issue
IFI environmental report EPA 1998 to EPA
IFI environmental report EPA 1998 to EPA
IFI environmental report EPA 1998 to EPA
IFI environmental report EPA 1998 to EPA
Date January 1999
Notice
Reference
Non compliance: • Total nitrogen, ph, urea, in the liquid effluent • Ammonia emission to air • One odour complaints February 1999 Non compliance: • Total nitrogen, ph, urea, BOD/methanol in the liquid effluent • Ammonia emission to air • One noise complaint
IFI environmental report EPA, 1999 to EPA
IFI environmental report EPA, 1999 to EPA
89
February 1999
26, Groundwater aquifers beneath the IFI site are contaminated to some extent by nitrogen components March 1999 Non compliance: • Total nitrogen, nitrate, ph, BOD/methanol in the liquid effluent • CO emission to air • One noise complaint and one odour complaints April 1999 Non compliance: • Total nitrogen, oil, ph, urea, BOD/methanol, suspended solids in the liquid effluent • CO2 emission to air owing to emergency shut down on 25. 04.1999 • Increased noise levels May 1999 Non compliance: • Total nitrogen, ph, BOD/methanol in the liquid effluent • Plant shut down • Seven noise complaint May 19, 1999 Groundwater aquifers beneath the IFI site are contaminated to some extent by nitrogen components June 1999 Non compliance: • Ph, BOD/methanol, suspended solids in the liquid effluent • Ammonia emission to air • One noise complaint July 1999 Non compliance: • Ph, BOD/methanol in the liquid effluent • Two noise complaint August 1999 Non compliance: • Total nitrogen, ph, BOD/methanol in the liquid effluent September Non compliance: 1999 • Two plant shut downs
Bord Na Mona on EPA, 1999 Groundwater analysis IFI environmental report EPA, 1999 to EPA
IFI environmental report EPA, 1999 to EPA
IFI environmental report EPA, 1999 to EPA
Bord Na Mona on EPA, 1999 Groundwater analysis IFI environmental report EPA, 1999 to EPA
IFI environmental report EPA, 1999 to EPA
IFI environmental report EPA, 1999 to EPA IFI environmental report EPA, 1999 to EPA
90
October 1999
November 1999 December 1999
Non compliance: IFI environmental report EPA, 1999 • Total nitrogen, flow, ph, to EPA BOD/methanol, suspended solids in the liquid effluent • Six noise complaints No records found IFI environmental report EPA, 1999 to EPA Non compliance: IFI environmental report EPA, 1999 • Occasional BOD/methanol to EPA levels over limit for liquid effluent Issue Notice Reference
Date January 2000
Non compliance: • One high discharge in flow in the liquid effluent owing to shut down of plant on 14. and 21.01.2000 • One noise complaint and one odour complaint February 2000 Non compliance: • Total nitrogen, ph and flow in the liquid effluent • Plant shut down on 25.02.2000 March 2000 Non compliance: • Plant shut down April 2000 • Non compliance: • Ammonia emission to air May 2000 Non compliance: • Ammonia emission to air • Plant shut down 12.05.2000 June 2000 Non compliance: • Suspended solids in the liquid effluent result of oil leak • Plant shut down 15.06.2000 July 2000 Non compliance: • None August 2000 Non compliance: • Ammonia emission to air • Plant shut down 14.08.2000 September Non compliance: 2000 • Plant shut down 06. and 08. and 26.09.2000
IFI environmental report EPA,2000 to EPA
IFI environmental report EPA, 2000 to EPA
IFI environmental report EPA, 2000 to EPA IFI environmental report EPA, 2000 to EPA IFI environmental report EPA, 2000 to EPA
IFI environmental report EPA, 2000 to EPA
IFI environmental report EPA, 2000 to EPA IFI environmental report EPA, 2000 to EPA
IFI environmental report EPA, 2000 to EPA
91
October 2000 November 2000
December 2000
Non compliance: • Total nitrogen in the liquid effluent Non compliance: • Total nitrogen in the liquid effluent • Plant shut down 11. and 30.11.2000 • One noise complaint Non compliance: • Three noise complaints
IFI environmental report EPA, 2000 to EPA IFI environmental report EPA, 2000 to EPA
IFI environmental report EPA, 2000 to EPA
Date
Issue
Notice
Reference EPA,2001
January 23, Plant shut down 2001 February 2001 Non compliance: • Nitrogen discharge improved six month in a row, only occasional over limit March to No major non compliances September 2001 October 2001 Non compliance: • Nitrate and ph in the liquid effluent owing to leak in a pump • Plant shut down 14.10.2001 November Non compliance: 2001 • Plant shut down 24.11.2001 December Non compliance: 2001 • Total nitrogen in liquid effluent • Urea plant tripped twice January 2002 Non compliance: • Plant shut down on 14.01.2002 February 2002 Non compliance: • Total nitrogen in liquid effluent March 2002 Non compliance: • Total nitrogen in liquid effluent
IFI environmental report EPA, 2001 to EPA
IFI environmental report EPA, 2001 to EPA IFI environmental report EPA, 2001 to EPA
IFI environmental report EPA, 2001 to EPA IFI environmental report EPA, 2001 to EPA
IFI environmental report EPA,2002 to EPA IFI environmental report EPA, 2002 to EPA IFI environmental report EPA, 2002 to EPA
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April 2002
Non compliance: IFI environmental report EPA, 2002 • Total nitrogen in liquid to EPA effluent • Leak in melt system 07. and 08.04.2002 • Plant shut down 24.04.2002 May and June No major non compliances IFI environmental report EPA, 2002 2002 to EPA July 2002 Non compliance: IFI environmental report EPA, 2002 • Plant shut down for most of to EPA the month
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Appendix 2
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Personal communication: • Elaine Walsh Planning Policy Unit / Cork County Council / Bishopstown House / Model Farm Road / Cork City / Ireland • Jim Wilson Birdwatch Ireland • Peter Desmond Former Laboratory Manager of IFI / current employee of KPMG / 5 George’s Dock / IFSC / Dublin 2 / Ireland • Patrick Smiddy NPWS (National Parks and Wildlife Service) / Location South East Cork / Contact Number: 024 982826 • Brendan Kelleher Retired Chief Planning Officer / Cork County Council
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Appendix 3
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Summary of the Code Classification for the habitats (Fossit, 2000) Non-Marine F Freshwater FL Lakes and Ponds FL1 Dystrophic lakes FL2 Acic oligotrophic lakes FL3 Limestone/marl lakes FL4 Mesotrophic lakes FL5 Eutrophic lakes FL6 Turloughs FL7 Reservoirs FL8 Other artificial lakes and ponds FW Watercourses FW1 Eroding/upland rivers FW2 Depositing/lowland rivers FW3 Canals FW4 Drainage ditches FP Springs FS Swamps FP1 Calcareous springs FP2 Non-Calcareous springs FS1 Reed and large sedge swamps FS2 Tall herb swamps GA Improved grassland GA1 Improved agricultural grassland GA2 Amenity grassland (improved) GS Semi-natural grassland GS1 Dry calcareous and neutral grassland GS2 Dry meadows and grassy verges GS3 Dry-humid acid grassland GS4 Wet grassland GM Freshwater marsh GM1 Marsh
G Grassland and Marsh
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H Heath and dense bracken
HH Heath
HH1 Dry siliceous heath HH2 Dry calcareous heath HH3 Wet heath HH4 Montane heath
HD Dense bracken HD1 Dense bracken P Peatlands PB Bogs PB1 Raised bogs PB2 Upland blanket bog PB3 Lowland blanket bog PB4 Cutover bog PB5 Eroding blanket bog PF Fens and Flushes PF1 Rich fen and flush PF2 Poor fen and flush PF3 Transition mire and quaking bog
W Woodland and scrub
WN Semi-natural woodland
WN1 Oak-birch-holly woodland WN2 Oak-ash-hazel woodland WN3 Yew woodland WN4 Wet pedunculate oak-ash woodland WN5 Riparian woodland WN6 Wet willow-alder-ash woodland WN7 Bog woodland
WD Highly modified/nonnative woodland
WD1 (Mixed) broadleaved woodland WD2 Mixed broadleaved/conifer woodland WD3 Yew woodland WD4 Conifer plantation WD5 Scattered trees and parkland
WS Scrub/transitional woodland
WS1 Scrub
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WS2 Immature woodland WS3 Ornamental/non-native shrub WS4 Short rotation coppice WS5 Recently-felled woodland WL Linear woodland/scrub WL1 Hedgerows WL2 Treelines
E Exposed rock and disturbed ER Exposed rock ground
ER1 Exposed siliceous rock ER2 Exposed calcareous rock ER3 Siliceous scree and loose rock ER4 Calcareous scree and loose rock
EU Underground rock and caves
EU1 Non-marine caves EU2 Artificial underground habitats
ED Disturbed ground
ED1 Exposed sand, gravel or till ED2 Spoil and bare ground ED3 Recolonising bare ground ED4 Active quarries and mines ED5 Refuse and other waste
B Cultivated and built land
BC Cultivated land BC1 Arable crops BC2 Horticultural land BC3 Tilled land BC4 Flower beds and borders BL Built land BL1 Stone walls and other stonework BL2 Earth banks BL3 Buildings and artificial surfaces CS Sea cliffs amd islets
C Coastland
CS1 Rocky sea cliffs CS2 Sea stacks and islets 99
CS3 Sedimentary sea cliffs CW Brackish waters CM Salt marshes CB Shingle and gravel banks CD Sand dune systems CW1 Lagoons and saline lakes CW2 Tidal rivers CM1 Lower salt marsh CM2 Upper salt march CB1 Shingle and gravel banks CD1 Embryonic dunes CD2 Marram dunes CD3 Fixed dunes CD4 Dune scrub and woodland CD5 Dune slacks CD6 Machair CC Coastal constructions Marine L Littoral (intertidal) LR Littoral rock LR1 Exposed rocky shores LR2 Moderately exposed rocky shores LR3 Sheltered rocky shores LR4 Mixed substrata shores LR5 Sea caves LS Littoral sediment LS1 Shingle and gravel shores LS2 Sand shores LS3 Muddy sand shores LS4 Mud shores LS5 Mixed sediment shores SR Sublittoral rock CC1 Sea walls, piers and jetties CC2 Fish cages and rafts
S Sublittoral shores (subtital)
SR1 Exposed infralittoral rock SR2 Moderately exposed infralittoral rock SR3 Sheltered infralittoral rock SR4 Exposed circalittoral rock SR5 Moderately exposed 100
circalittoral rock SR6 Sheltered circalittoral rock SS Sublittoral sediment SS1 Infralittoral gravels and sands SS2 Infralittoral muddy sands SS3 Infralittoral muds SS4 Infralittoral mixed sediments SS5 Circalittoral gravels and sands SS6 Circalittoral muddy sands SS7 Circalittoral muds SS8 Circalittoral mixed sediments M Marine water body MW1 Open marine water MW2 Sea inlets and bays MW3 Straits and sounds MW4 Estuaries
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Acknowledgements
I would like to specially thank Valerie Cummins and Jeremy Gault from the Coastal Marine and Research Centre (CMRC) for guiding me through this project with their support, help and advice. Furthermore, I would like to thank Dr. Gavin Burnell for taking on the supervision of this thesis on short notice and for assistance and advice to complete this project. I also would like to show my appreciation to everyone at CMRC for their support and company. I would like to specially mention Vicki O’Donnell for the help with GIS queries and Kristel Coutel for assistance during the field visits. I would like to further acknowledge Elaine Walsh, Jim Wilson, Peter Desmond, Patrick Smiddy and Brendan Kelleher who took time to answer my questions. I also want to thank Kevin for his support and patients, all my friends in Cork for their encouragement, Kevin’s parents for the weekend food supplies and particular credit goes to Percy for taking the time to read through parts of this project and give his opinion and advice. Finally, I would like to thank my parents, who were and are always there for me.
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