Consolidated Prescribed Body Observations
NPWS Archaeology
Your ref: FS6467
Re: Dredging of commercial bertha and manoeuvring area at Fenit Harbour and disposal of dredge material at agreed dumpsite within Tralee Bay.
A Chara,
On behalf of the Department of Arts, Heritage and the Gaeltacht, I refer to correspondence received in relation to the above.
Outlined below are heritage-related observations/recommendations of the Department under the stated heading(s).
Underwater Archaeology
The Underwater Archaeology Unit (UAU) has no objections to the dredging or dumping proceeding once the following is included as a condition of any foreshore licence issued for the dredging within Fenit Harbour. This Deprtment have responded separately to the application to dump the dredging spoil at sea, through the EPA Permit process and the UAU has no objection to this and no further requirements with regard to the dumpsite.
Archaeological monitoring:
- All works for the dredging at Fenit Harbour to be subject to archaeological monitoring. This to be carried out by a suitably qualified underwater archaeologist experienced in such monitoring of marine dredging works.
- The monitoring shall be licensed under the National Monuments Acts 1930-2004.
- A detailed method statement shall accompany all licence applications to this Department.
- The MS shall include a finds retrieval strategy and the applicant shall ensure that full communication is in place to allow for the cessation immediately of dredging works in a particular area should potential archaeology be encountered and until the archaeology has been fully resolved. The Underwater Archaeology Unit shall be contacted immediately in this event.
- It is advised that a dive survey licence also be in place to allow for any potential archaeological inspection dives to take place should cultural material need to be assessed during the course of the works. A dive survey licence can take up to 4 weeks to process and this should be allowed for in advance.
NPWS Nature
Your Ref: FS6474
A Chara
On behalf of the Department of Arts, Heritage and the Gaeltacht, I refer to the above.
Outlined below please find the Nature Conservation observations.
The Department of Arts, Heritage and the Gaeltacht would note that the operation is unlikely to have a negative interaction with Natura 2000 nature conservation sites provided that mitigation noted in Section 5.7 of the NIS are applied in full.
In addition it should be noted that dredging operations must be compliant with “Guidance to Manage the Risk to Marine Mammals from Man-made Sound Sources in Irish Waters”. The latest version of this document was published in January 2014 and is available to download from
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Marine Institute
Kerry County Council has submitted an application for a Foreshore Licence to facilitate dredging within Fenit Harbour, Co. Kerry and the disposal of the dredged material to a dump site in outer Tralee Bay.
It is estimated that approximately 63,000m3 of sediments in total will be dredged from the commercial berth, in the vicinity of the mouth of the harbour covering an area of 11,820m2, and the ship manoeuvring area, east of the mouth of the harbour covering an area of 14,000m2 as shown in the Drawings submitted by the applicant and also shown in the document entitled “Fenit harbour Foreshore Licence Application: Further Information” dated April 2015 submitted by the applicant. The dredging would be carried out using a suction hopper dredger and it is anticipated that the dredging would be completed within a 3 - 6 week period. It is intended that all the dredged material will be disposed of at a dump site located approximately 8Km northwest of the harbour area in outer Tralee Bay, subject to the granting of a Dumping at Sea Permit by the EPA. An application for a Dumping at Sea Permit was submitted to the EPA in March 2015 is currently under consideration.
The purpose of the dredging is to ensure safe navigational depths, in particular for commercial shipping, but also for fishing vessels and yachts, using the harbour. The commercial shipping quays is actively used by LiebherrContainerCranesLtd. and facilitates 15,000 tonne ships of container cranes with a frequency of approximately 15 to 20 per annum.
Dredging in this area has been undertaken previously and the commercial berth was last dredged in 2011. The proposed dump site overlaps with the location of the previous dumping at sea site used under the previous permit.
On the basis of the results of chemical analysis of sediment samples taken from the dredge area the sediments to be dredged are considered essentially clean. The only elements established to be in concentrations exceeding their lower action levels are Arsenic and Nickel, both of which can be considered as low category 2. Similar results were found in 2006 and are believed to reflect the natural geology in the area.
Considering the nature, location and scale of the proposed works and the fact that the material to be dredged can be considered to be essentially clean the Marine Institute is of the view that they are unlikely to have a significant adverse impact on the marine environment or on other legitimate uses / users of the area and has no objections to a licence being granted.
IT is recommended that the following Conditions should be attached to any licence that may issue.
- The Licensee shall use that part of the Foreshore the subject matter of this licence for the purposes as outlined in the application and for no other purposes whatsoever.
- The Licensee shall notify the Department of the Environment, Community and Local Government at least 14 days in advance of the commencement of the works on the foreshore.
The Licensee shall keep and maintain in the State for inspection on demand by the Minister, records of all dredging operations, including quantities of material dredged. These records shall be produced by the Licensee on demand by the Minister.
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Department of Agriculture Food and the Marine
Your Ref: FS6474
Our Ref: FW/9/11
Re: Foreshore Licence Application on behalf of Fenit Harbour Master, Fenit, Co.Kerry for the dredging of the commercial berth and manoeuvring area within Fenit Harbour and the disposal of dredge material to a dump site in Tralee Bay.
Further to your email dated 19th August 2015, below please find observations from this Department.
The proposed works have potential for conflicts with other harbour users, such a recreational users, fishing and commercial interests and The Tralee Bay Oysters Fishery.
Section 5.6 of the Natural Impact Statement, Assessment of Potentially Significant Cumulative Effects, and Section 5.7 Mitigation, identifies a number of possible conflicts and also recommends measures to mitigate against their impact and cumulative impact. It is proposed to undertake a Water Quality Management Plan incorporating fixed monitoring stations, mobile monitoring station, visual monitoring and laboratory monitoring. It is proposed to time the dredging works to reduce the probability of conflicts, i.e. no dredging during the Bathing Season or during the Oyster Spatting Season.
The Natura Impact Statement also outlines Additional Water Quality Measures (5.7.2.2) including consultations with relevant stakeholders, incorporating the requirements of all licences, consents and agreements in the contracts and fully briefing the contractor on the sensitivities of the site.
On the basis of the results of chemical analysis of sediment samples taken from the dredge area, these sediments are considered essentially clean and the quality of the material would not preclude dumping at sea, in the absence of a feasible alternative. The only elements established to be in concentrations exceeding their lower action levels are Arsenic and Nickel, both of which can be considered as low category 2. Similar results were found in 2006 and are believed to reflect the natural geology in the area.
There are no licensed aquaculture sites in the vicinity of the proposed dump site and therefore significant impacts on aquaculture activities in the area are not considered likely.
Based on the above, the Department would not have any objection to the granting of a Foreshore Licence for this project, based on the recommendations in Section 5.7 (Mitigation) of the Natura Impact Statement being implemented. The fact that no dredging should take place during Bathing season or during the Oyster Spatting and Harvest season should however be included as a specific condition in any licence granted.
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Inland Fisheries Ireland
Overview:
This application is to undertake maintenance dredging in the commercial berth and manoeuvring area at Fenit Pier.
The application also refers to dumping of the dredge spoil. However, that action is licenced separately under the EPA Dumping-at-sea legislation.
The preferred operational periods for dredging are October – November or February-March. Section 6.1 of the Application Form indicates that the preferred time of works is March (2016?) – before the tourism season starts, in the context of works impact on leisure craft.
A typical dredge campaign can take 3 – 6 weeks, depending on weather and on volumes of material to be removed.
The issue of sediment re-suspension and of elevated suspended solids during dredging is identified by the applicant.
Mitigations proposed by applicant:
Deployment of turbidity meters in areas adjacent to dredging is proposed. This is welcome. IFI suggest that an additional turbidity monitor be located within Tralee bay but at a distance from the dredge area to act as a control or monitor of background levels. These background levels may, potentially, be high during storm events. Comparison of such natural background levels with data from meters adjacent to the dredge area would be of value in identifying the range of natural and man-made suspended solids levels in Tralee Bay.
The applicant also proposes that dredging be undertaken in periods of good weather conditions and suitable tides.
IFI view on mitigation requirements:
The mitigations proposed by the applicant in regard to turbidity meters and timing of works in regard to weather are positive and welcome.
The turbidity issue is particularly relevant in Tralee Bay in regard to the range of important marine sport fish and sea angling resource present in the bay.
IN view of potential advere impacts of sediment disturbance and movement, IFI considers that a baseline survey to determine locations of breeding areas and potential impacts of spoil deposition on the key marine fish species using this area be undertaken prior to any dredging campaign. Such a survey would also assess the impact of the campaign on the angling community that shares this area and its surrounds, i.e. will the spoil impact on the ability of anglers to catch fish in the area or its surrounds or will the target species move into deeper water away from the dumping. Timing and format of any fishery survey should be agreed between DECLG, the applicant and IFI as a licence condition. Outcomes would be relevant to both foreshore and dumping-at-sea issues, currently and into the future.
IFI comment:
IFI has since noted that the Dumping-at-sea licence has been granted by EPA on 15.9.2015 and that trailer-suction-hopper dredger is the only authorised means to be used to load vessel(s).
Timing of the proposed maintenance is significant for IFI. Tralee Bay is a very important location for leisure angling for marine sport fish. In particular, the bay is noted for its diverse range of elasmobranch species (rays, skates and sharks), including several vulnerable species. Two species, both considered to be critically endangered in the IUCN Red Listing (International Union for Conservation of Nature), are found in Tralee Bay – the angel shark (Squatina squatina) and the Undulate ray (Raja undulata). Adult Angel shark can reach a size of 2.4 m in length (240 cm). Young sharks are born in July in England and are up to 30 cm in length. The reproduction time of Undulate ray is less well-known but occurs in spring and early summer in some areas. Timing is considered to be linked to water temperature.
A proposed dredging campaign to occur in February – March 2016 would be appropriate in reducing adverse impact of works on the reproduction period of the two endangered fish species listed above.
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Marine Survey Office
- This office has no objection from a navigational viewpoint.
- In order for charts and nautical publications to be updated the applicant is required to notify the British Admiralty Hydrographic Office at Taunton UK, of the location and nature of the proposed works (0044 1823 284077, email )
- The applicant is required to arrange the publication of a local marine notice. This local marine notice should give a general description of operations and approximate dates of commencement and completion. An advertisement in a locally read newspaper will suffice.
- The views of the divisional engineer should be sought.
- The applicant is required to apply to the Commissioners of Irish Lights (web site: Fax 01 6618094, email: ) for sanction of new aids to navigation and/or alteration of existing aids to navigation as appropriate.
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