These works are currently ongoing at Limerick City, and the photos below were taken today. We are very concerned about the possible impacts of these works on water quality in the SAC as they are happening at a very sensitive time of the year with juvenile lampreys, eels and salmon all in this area of the River Shannon in Limerick City at this time of the year. In terms of planning instream works like this, this work could not have been timed for a more sensitive time of the year.
We also concerned that:-
- The works involve infilling of the Annex I habitat ‘Mudflats and sandflats not covered by seawater at low tide ’ – a key conservation interest of the Lower Shannon SAC.
- These instream works are taking place at a time when juveniles of the critically endangered European Eel (elvers) are migrating upstream.
- These instream works are taking place at a time when juvenile Sea lamprey (Petromyzon marinus)  and River lamprey (Lampetra fluviatilis)  – again key conservation interests of the SAC are migrating downstream, and adults of these species are migrating upstream.
- Although moving quicker through the area and less likely to be affected – Salmon (Salmo salar)  smolts are outmigrating.
There are no water quality protection measures being employed (e.g. silt fences). The stone used for infilling Annex I habitat has not been washed of lime. These works could not have happened at a more unsuitable time of the year in terms of fish migration.
If this is a permanent loss of an Annex I habitat in this SAC this would constitute an Integrity level impact on the SAC, if we follow on from the recent European Court of Justice decision on the Galway City Outer Bypass.
Are there not enough places to walk in Limerick City? Is it not time to keep back from the river?