Last summer we reported that Mulkear LIFE had removed Ballyclough weir on the River Mukear during the peak of the sea lamprey spawning season. These works had significant impacts on spawning lampreys due to the release of massive quantities of suspended solids into the river at a critical time. Major weir removal works would not be authorised in Ireland to take place during the salmon and trout spawning seasons. Why were they allowed to take place during the lamprey spawning season? As we pointed out previously these works were undertaken in the absence of an Appropriate Assessment.
There has been an ongoing release of suspended solids into the river from these destabilised banks over the winter period as the banks and river corridor adjust to the change in water levels
Lamprey spawn in the same areas as salmon and trout, and their ova and larvae are just as vulnerable to suspended solids pollution during their early development stages as salmonids. Mulkear LIFE boasted last summer about a “month of major instream works” taking place in the Lower River Shannon SAC when lampreys were spawning. Unlike the damage that occurred to sea lamprey ova in their redds at Annacotty last summer which was essentially invisible, the erosion and destabilisation of the banks of the River Mulkear upstream of Ballyclough are clearly visible in the photos provided below which we took during mid-March 2014; some 8 months after the weir removal works were completed.
Mulkear LIFE’s “month of major instream works“, and most importantly the removal of Ballyclough weir, was completed without preparing an Appropriate Assessment of the likely significance of effects on the Lower River Shannon Special Area of Conservation. An Appropriate Assessment is required when a proposed project (either alone or in combination with others) is likely to have a significant effect on a Natura 2000 site. The works completed by Mulkear LIFE were located within the Lower River Shannon SAC, took place upstream of the main spawning areas of sea, river and brook lampreys (all key conservation interests) in the SAC, and occurred during the sea lamprey spawning season. Significant impacts on the Lower River Shannon SAC occurred as a result of these works. Mulkear LIFE said that there was no potential for the works to have any significant adverse effects on the SAC. They mislead the public, and the EU who partially fund them, and have caused significant damage to lamprey populations in this SAC. The works are also likely to have impacted on salmonids in the SAC and from the photos presented here these impacts are ongoing.
As we have said before there will be long-term benefits of removing this weir. There did not however have to be significant negative short to medium-term impacts. The works could have been planned properly and undertaken at a suitable time to minimise damage. Other mitigation measures could also have been included to reduce the severity of the impacts.
Mulkear LIFE said that there was no potential for them to have any significant adverse effects on the SAC. They mislead the public, and the EU who partially fund them, and have caused significant damage to lamprey populations in this SAC.
An Appropriate Assessment is not just a report and is not just a ‘red tape’ exercise . It is an important procedure which provides a check on activities planned for SACs to ensure that these activities do not cause significant impacts. The Appropriate Assessment process is there to protect SACs from damaging works and it is essential, and a legal requirement, that it is followed. Mulkear LIFE are not exempt from the requirements of the EU Habitats Directive. If a project or plan has no potential for significant impacts then it can proceed. This is established though the preparation of an Appropriate Assessment Screening report. Mulkear LIFE prepared a Screening Report but did not follow the relevant guidance ‘Appropriate Assessment of Plans and Projects in Ireland: Guidance for Planning Authorities‘.
Mulkear LIFE also deliberately (or due to incompetence) provided misleading statements in this report so they could avoid the requirement of preparing a full Appropriate Assessment. Mulkear LIFE said, for example, that all the lampreys would have passed upstream before the works commenced; ignoring the fact that the main lamprey spawning area (all three species) in the River Mulkear is located a short distance downstream of Ballyclogh Weir (at Annacotty and below). This part of the river was clearly within the zone of influence of suspended solids pollution which occurred at the peak of the sea lamprey spawning season. It is noted that due to very high water temperatures at the time of the works lamprey ova were even more vulnerable to suffocation by suspended solids.
There are ongoing indirect significant adverse impacts occurring as result of the removal of Ballyclogh weir, which include suspended solids pollution, extending over 8 months after the completion of the project.
If Mulkear LIFE had completed their Screening Assessment correctly, following the relevant guidance, the process would have concluded that there was potential for significant adverse impacts on the Lower Shannon SAC (particularly on lampreys) and that mitigation would be necessary. Mulkear LIFE provided no mitigation and caused a massive release of suspended solids into the River Mulkear immediately upstream of the main spawning area for river, brook and sea lampreys in the river. It is not good enough that some benefit will come out of this. The impacts on lampreys and their spawning areas were unnecessary and could have been avoided if the works were timed to take place outside the sea lamprey spawning season.
Ballyclough Weir was over 200 years old and we pointed out last year that there were perhaps thousands of tonnes of silt deposited upstream of this obstacle for a kilometre or more. We said that much of this silt was mobilised and transported downstream, and resulted in acute negative impacts on sea lampreys and sea lamprey spawning areas. The two other lamprey species would also have been affected and river lampreys only occur downstream of Annacotty weir on the River Mulkear. We also pointed out last August that the river banks upstream of Ballyclough weir were likely to become destabilised as a result of the drop in water levels that occurred after the weir removal and were likely to slew off into the river causing ongoing effects.
We believe that it is in the public interest to raise these issues and it is hoped that criticism like this will help raise the standards of projects like this in the future, and help the cause for protecting lampreys and other non-fisheries interests in the rivers of Ireland.
We visited the site today (16th March 2014) and from the photos provided here it is clear that this effect is still ongoing in the river upstream of Ballyclogh weir some 8 months after the weir removal works were completed. There has been an ongoing release of suspended solids into the river from these destabilised banks over the winter period as the banks and river corridor adjust to the change in water levels. As this bank and sediment reorganisation has continued over the winter it is clear that there are ongoing indirect impacts and these were likely to have had significant impacts on salmon (also a key conservation interest) spawning habitats between this stretch of river and the River Shannon. None of this was predicted in Mulkear LIFE’s Screening Report.
We believe that the Mulkear LIFE project is in significant breach of the requirements of the EU Habitats Directive. The Mulkear LIFE project has caused significant damage to lamprey populations in this SAC. There are ongoing indirect significant adverse impacts occurring as result of the removal of Ballyclogh weir, which include suspended solids pollution, extending over 8 months after the completion of the project. It is noted that, according to the Limerick and District Anglers Association, the removal of Ballyclogh Weir also facilitated the non-native invasive fish species Dace to colonise upstream. This species was formerly confined to below Ballyclough weir. This again was a significant adverse impact on the SAC that was not considered in Mulkear LIFE’s Screening Report.
Mulkear LIFE have never produced any credible scientific evidence that their lamprey passes offer any significant benefits to lampreys. The short-cuts they took with the science behind these lamprey passes is also apparent in the cavalier approach they took during the planning and implementation of the Ballyclogh Weir removal project. From the pictures we have provided here these badly planned works are still having significant adverse effects on the Lower Shannon SAC some 8 months after completion. Remember when you look at these photographs that Mulkear LIFE said in their Screening report that there was no potential whatsoever for any significant adverse effects to occur as a result of the Ballyclough weir removal project. Also remember that Mulkear LIFE were funded by the EU to do this, and received an Environmental Award for this work from the Chartered Institute of Water and Environmental Management (CIWEM) – did they deserve this?
For more on the topic of Mulkear LIFE see our following posts:-
- Mulkear LIFE are in breach of the requirements of the Habitats Directive
- Is anyone really protecting lampreys in Ireland
- Major instream works without Appropriate Assessment
- Mulkear LIFE’s lamprey pass – where is the evidence that it works?
- Further comment on Mulkear LIFE’s lamprey pass
The Old River Shannon Research Group is a voluntary organisation and, unlike Mulkear LIFE, has no income. We are raising these issues, not because we have some agenda against Mulkear LIFE, but because we genuinely believe that lampreys are being significantly short-changed by the Mulkear LIFE project, and indeed in Ireland overall. We are very disappointed by the missed opportunity that the Mulkear LIFE project represents. We believe that if something is worth doing then it is worth doing right. We also don’t believe that the Appropriate Assessment process is just ‘red tape’. We believe it serves an important purpose and failing to follow this procedure resulted in significant and avoidable impacts occurring in the Lower Shannon SAC as a result of the Ballyclough weir removal. Mulkear LIFE are supposed to be leading by example, and just because they received an award from an engineering organisation does not mean that they are. Mulkear LIFE has, with the Ballycough weir removal and the design of their lampreys passes, taken short-cuts that have damaged the project and reduced the benefits for lampreys that were promised and paid for by the EU. We believe that it is in the public interest to raise these issues and it is hoped that criticism like this will help raise the standards of projects like this in the future, and help the cause for protecting lampreys and other non-fisheries interests in the rivers of Ireland.