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Home My WebLink About2660018 - F.I. Received Doc. - EIAR Appendix 10.1 NRA/TII Rating Criteria AUGUST 2026 VOLUME III APPENDICES TO ENVIRONMENTAL IMPACT ASSESSMENT REPORT APPENDIX 10.1 NRA/TII RATING CRITERIA: HYDROLOGICAL & HYDROGEOLOGICAL Stream BioEnergy Ireland Limited RECEIVED: 28/08/2026 Anaerobic Digester-Monaghan / 247501.0350 AWN Consulting Ltd 1 APPENDIX 10.1 NRA/TII Criteria for Rating the Magnitude and Significance of Impacts at EIA Stage National Roads Authority. (NRA/TII, 2009). RECEIVED: 28/08/2026 Anaerobic Digester-Monaghan / 247501.0350 AWN Consulting Ltd 2 Table 1 Criteria for Rating Site Attributes – Estimation of Importance of Hydrological Attributes (NRA) Importance Criteria Typical Examples Extremely High Attribute has a high quality or value on an international scale River, wetland or surface water body ecosystem protected by EU legislation e.g. ’European sites’ designated under the Habitats Regulations or ‘Salmonid waters’ designated pursuant to the European Communities (Quality of Salmonid Waters) Regulations, 1988. Very High Attribute has a high quality or value on a regional or national scale River, wetland or surface water body ecosystem protected by national legislation – NHA status. Regionally important potable water source supplying >2500 homes. Quality Class A (Biotic Index Q4, Q5). Flood plain protecting more than 50 residential or commercial properties from flooding. Nationally important amenity site for wide range of leisure activities. High Attribute has a high quality or value on a local scale Salmon fishery. Locally important potable water source supplying >1000 homes. Quality Class B (Biotic Index Q3-4). Flood plain protecting between 5 and 50 residential or commercial properties from flooding. Locally important amenity site for wide range of leisure activities. Medium Attribute has a medium quality or value on a local scale Coarse fishery. Local potable water source supplying >50 homes. Quality Class C (Biotic Index Q3, Q2- 3). Flood plain protecting between 1 and 5 residential or commercial properties from flooding. RECEIVED: 28/08/2026 Anaerobic Digester-Monaghan / 247501.0350 AWN Consulting Ltd 3 Importance Criteria Typical Examples Low Attribute has a low quality or value on a local scale Locally important amenity site for small range of leisure activities. Local potable water source supplying <50 homes Quality Class D (Biotic Index Q2, Q1). Flood plain protecting 1 residential or commercial property from flooding. Amenity site used by small numbers of local people. Table 2 Criteria for Rating Site Attributes – Estimation of Magnitude of Impact on Hydrological Attribute (NRA) Magnitude of Impact Criteria Typical Examples Large Adverse Results in loss of attribute Loss or extensive change to a waterbody or water dependent habitat. Increase in predicted peak flood level >100mm. Extensive loss of fishery. Calculated risk of serious pollution incident >2% annually. Extensive reduction in amenity value. Moderate Adverse Results in impact on integrity of attribute or loss of part of attribute Increase in predicted peak flood level >50mm. Partial loss of fishery. Calculated risk of serious pollution incident >1% annually. Partial reduction in amenity value. Small Adverse Results in minor impact on integrity of attribute or loss of small part of attribute Increase in predicted peak flood level >10mm. Minor loss of fishery. Calculated risk of serious pollution incident >0.5% annually. RECEIVED: 28/08/2026 Anaerobic Digester-Monaghan / 247501.0350 AWN Consulting Ltd 4 Magnitude of Impact Criteria Typical Examples Slight reduction in amenity value. Negligible Results in an impact on attribute but of insufficient magnitude to affect either use or integrity Negligible change in predicted peak flood level. Calculated risk of serious pollution incident <0.5% annually. Minor Beneficial Results in minor improvement of attribute quality Reduction in predicted peak flood level >10mm. Calculated reduction in pollution risk of 50% or more where existing risk is <1% annually. Moderate Beneficial Results in moderate improvement of attribute quality Reduction in predicted peak flood level >50mm. Calculated reduction in pollution risk of 50% or more where existing risk is >1% annually. Major Beneficial Results in major improvement of attribute quality Reduction in predicted peak flood level >100mm Table 3 Criteria for rating Site Attributes - Estimation of Importance of Hydrogeology Attributes (NRA) Magnitude of Impact Criteria Typical Examples Extremely High Attribute has a high quality or value on an international scale Groundwater supports river, wetland or surface water body ecosystem protected by EU legislation e.g. SAC or SPA status Very High Attribute has a high quality or value on a regional or national scale Regionally Important Aquifer with multiple well fields Groundwater supports river, wetland or surface water body ecosystem protected by national legislation – NHA status Regionally important potable water source supplying >2500 homes RECEIVED: 28/08/2026 Anaerobic Digester-Monaghan / 247501.0350 AWN Consulting Ltd 5 Magnitude of Impact Criteria Typical Examples Inner source protection area for High Attribute has a high quality or value on a local scale Regionally Important Aquifer Groundwater provides large proportion of baseflow to local rivers Locally important potable water source supplying >1000 homes Outer source protection area for regionally important water source Inner source protection area for locally important water source Medium Attribute has a medium quality or value on a local scale Locally Important Aquifer Potable water source supplying >50 homes Outer source protection area for locally important water source Low Attribute has a low quality or value on a local scale Poor Bedrock Aquifer Potable water source supplying <50 homes Source: Box 4.3: ‘Guidelines on Procedures for Assessment and Treatment of Geology, Hydrology and Hydrogeology for National Road Schemes’ by the National Roads Authority (NRA, 2009) RECEIVED: 28/08/2026 Anaerobic Digester-Monaghan / 247501.0350 AWN Consulting Ltd 6 Table 4 Criteria for Rating Impact Significance at EIS Stage – Estimation of Magnitude of Impact on Hydrogeology Attribute (NRA) Magnitude of Impact Criteria Typical Examples Large Adverse Results in loss of attribute and /or quality and integrity of attribute Removal of large proportion of aquifer. Changes to aquifer or unsaturated zone resulting in extensive change to existing water supply springs and wells, river baseflow or ecosystems. Potential high risk of pollution to groundwater from routine run- off. 1 Calculated risk of serious pollution incident >2% annually. 2 Moderate Adverse Results in impact on integrity of attribute or loss of part of attribute Removal of moderate proportion of aquifer. Changes to aquifer or unsaturated zone resulting in moderate change to existing water supply springs and wells, river baseflow or ecosystems. Potential medium risk of pollution to groundwater from routine run-off. 1 Calculated risk of serious pollution incident >1% annually. 2 Small Adverse Results in minor impact on integrity of attribute or loss of small part of attribute Removal of small proportion of aquifer. Changes to aquifer or unsaturated zone resulting in minor change to water supply springs and wells, river baseflow or ecosystems. Potential low risk of pollution to groundwater from routine run- off. 1 Calculated risk of serious pollution incident >0.5% annually. 2 Negligible Results in an impact on attribute but of insufficient magnitude to affect either use or integrity Calculated risk of serious pollution incident <0.5% annually. 2 1 refer to Annex 1, Method C, Annex 1 of HA216/06 2 refer to Appendix B3 / Annex 1, Method D, Annex 1 of HA216/06 Source: Box 5.3: ‘Guidelines on Procedures for Assessment and Treatment of Geology, Hydrology and Hydrogeology for National Road Schemes’ by the National Roads Authority (NRA, 2009) RECEIVED: 28/08/2026 Anaerobic Digester-Monaghan / 247501.0350 AWN Consulting Ltd 7 Table 5 Rating of Significant Environmental Impacts at EIA Stage (NRA) Importance of Attribute Magnitude of Importance Negligible Small Adverse Moderate Adverse Large Adverse Extremely High Imperceptible Significant Profound Profound Very High Imperceptible Significant/moderate Profound/Significant Profound High Imperceptible Moderate/Slight Significant/moderate Profound/Significant Medium Imperceptible Slight Moderate Significant Low Imperceptible Imperceptible Slight Slight/Moderate Source: Box 5.4: ‘Guidelines on Procedures for Assessment and Treatment of Geology, Hydrology and Hydrogeology for National Road Schemes’ by the National Roads Authority (NRA, 2009) RECEIVED: 28/08/2026 AUGUST 2026 VOLUME III APPENDICES TO ENVIRONMENTAL IMPACT ASSESSMENT REPORT APPENDIX 10.2 FLOOD RISK ASSESSMENT Stream BioEnergy Ireland Limited RECEIVED: 28/08/2026 SSESSMENT awn CONSULTING A Chapter 6 Appendix 6.2 – Flood Risk Assessment AWN Consulting Ltd, The Tecpro Building, IDA Business & Technology Park, Clonshaugh, Dublin 17, D17 XD90 FRA Renewable Biogas Plant, RECEIVED: 28/08/2026 FRA Renewable Biogas Plant, / 257501.0350EIAR AWN Consulting Ltd TABLE OF CONTENTS 1. FLOOD RISK ASSESSMENT 1-3 1.1 Introduction ......................................................................................................... 1-3 1.1.1 Renewable Biogas Plant Site ............................................................................... 1-3 1.1.2 Linear Gas Grid Connection ................................................................................. 1-3 1.1.3 Planning Context ................................................................................................ 1-4 1.1.4 Purpose of a Site Specific Flood Risk Assessment .................................................. 1-4 1.1.5 The Planning System and Flood Risk Management Guidelines ................................. 1-4 1.2 Experience of Authors .......................................................................................... 1-8 1.3 Methodology ........................................................................................................ 1-9 1.4 Climate change .................................................................................................. 1-11 2. BASELINE CONDITIONS 2-13 2.1.1 Receiving environment ..................................................................................... 2-13 3. DEVELOPMENT CHARACTERISTICS 3-17 3.1.1 Renewable Biogas Plant Site ............................................................................. 3-17 4. STAGE 1- FLOOD RISK IDENTIFICATION 4-19 4.1.1 Historical Flooding Records ............................................................................... 4-19 4.1.2 Fluvial Flooding ................................................................................................ 4-20 4.1.3 Pluvial Flooding ................................................................................................ 4-22 4.1.4 Groundwater Flooding ...................................................................................... 4-23 4.1.5 Other Sources of Flooding ................................................................................. 4-23 4.1.6 Overview of Flood Risk Identification.................................................................. 4-23 4.1.7 Flood Mitigation Measures ................................................................................. 4-23 4.1.8 Residual Risk ................................................................................................... 4-24 5. CONCLUSIONS 5-25 6. REFERENCES 6-26 RECEIVED: 28/08/2026 FRA Renewable Biogas Plant, / 257501.0350EIAR AWN Consulting Ltd i LIST OF TABLES Table 1-1. Classification of vulnerability of different types of developments. 1-10 Table 1-2: Matrix of vulnerability versus flood zone to illustrate appropriate development and that required to meet the Justification Test. 1-11 Table 1-3. Allowances in Flood Parameters for the Mid‐Range and High‐End Future Scenarios for Fluvial and Tidal Sources 1-11 RECEIVED: 28/08/2026 FRA Renewable Biogas Plant, / 257501.0350EIAR AWN Consulting Ltd ii LIST OF FIGURES Figure 1-1. Site Location Map 1-4 Figure 1-2. Flood Zones. 1-6 Figure 2-1. Regional Hydrological environment 2-13 Figure 2-2. Local Hydrological Environment 2-14 Figure 2-3. Designated Sites and Hydrological Connections 2-15 Figure 4-1. Historic Flood Events 4-20 Figure 4-2. CFRAM River Flood Probability (OPW, 2025) 4-21 Figure 4-3.Strategic Flood Risk Assessment Monaghan County 4-22 Figure 4-4. Extract from CFRAM MRFS and HEFS Pluvial Flooding Map for the Site Area (CFRAM, 2025). 4-24 RECEIVED: 28/08/2026 FRA Renewable Biogas Plant, / 257501.0350EIAR AWN Consulting Ltd 1-3 1. FLOOD RISK ASSESSMENT 1.1 Introduction AWN Consulting Ltd (AWN) has been appointed by Stream Bioenergy to undertake a Flood Risk Assessment (“FRA”) to support an application for permission for a Renewable Biogas Plant at Maghernakelly, Drum, County Monaghan. The flood risk assessment is carried out for the Renewable Biogas site as described below. The proposed development will utilise Anaerobic Digestion (AD) technology to generate renewable energy in the form of biomethane from organic waste materials. AD is a sustainable form of renewable energy production through a naturally occurring process in which micro-organisms break down biodegradable material in the absence of oxygen in an enclosed system to produce renewable biogas. Biogas generated by the proposed development will be upgraded to biomethane and exported to the gas grid network to replace fossil fuel derived natural gas. This will be directly injected into the gas grid which will be delivered by Gas Networks Ireland under a separate consenting process. 1.1.1 Renewable Biogas Plant Site The site of the Proposed Development is located in Maghernakelly, Drum, Co. Monaghan, covering a total area of approximately 6.2 hectares. It is c.4km north of Cootehill and 17.5km southwest of Monaghan town. The site is comprised of two fields which are divided by a hedgerow. It is bounded to the north by L2280 Drumcall Road, to the east by the R189 regional road, and to the west by Maghernakelly Road. To the south, the site adjoins New Park Farm and an existing residential property. The site is undulating with substantial elevation from approximately 109mOD in the southern section to around 93mOD at the northern boundary. 1.1.2 Linear Gas Grid Connection A gas transmission pipeline will provide a physical connection between the Renewable Biogas Plant and the existing national gas network in Dromore West, Co. Monaghan. While the development of the gas grid is not part of the planning application, as Gas Networks Ireland will deliver it, it is included in the EIAR for assessment purposes, as it forms part of the overall project for the EIA Directive. The works comprise the laying of an underground pipeline over approximately 3.5 km within the public road corridor. As the construction is a shallow trench in a roadway there is minimal potential for impact on receiving waterways. There are 3no. water crossing associated with the installation of the pipeline. However, it is proposed that horizontal directional drilling methodology will be implemented at all water crossing. Hence eliminating any interaction with the stream. The design will be required to ensure the contractor manages collection and disposal of water during open trench cuts and soil disposal in an environmentally responsible manner. During operation there is no potential for impact on receiving waterways. This site-specific FRA assesses flood risk in relation to the Renewable Biogas Plant site. The hydrological and hydrogeological effects associated with construction and operation of the Linear Gas Grid Connection are assessed in Chapter 10 of the EIAR. RECEIVED: 28/08/2026 FRA Renewable Biogas Plant, / 257501.0350EIAR AWN Consulting Ltd 1-4 Figure 1-1. Site Location Map 1.1.3 Planning Context The following planning policy documents are relevant to the assessment of the proposed development: ► The National Planning Guidelines published by the OPW and the Department of the Environment, Heritage and Local Government in November 2009 entitled ‘The Planning System and Flood Risk Management Guidelines for Planning Authorities’ ► Monaghan County Development Plan 2025-2031; ► National Development Plan 2018-2027. 1.1.4 Purpose of a Site Specific Flood Risk Assessment In line with the Guidelines, a Site Specific Flood Risk Assessment (SSFRA) should be undertaken for a scale of individual site planning applications. The purpose of this FRA is to assess all types of flood risk for a new development. A FRA identifies the sources of flood risk, the effects of climate change on this, the impact of the development, the effectiveness of flood mitigation and management measures and the residual risks that remain after those measures are put in place. 1.1.5 The Planning System and Flood Risk Management Guidelines This assessment was undertaken in accordance with the Department of the Environment, Heritage and Local Government (DoEHLG) Flood Risk Management Guidelines for Planning Authorities published by the OPW in 2009 (hereafter referred to as the FRM Guidelines) in order to introduce comprehensive RECEIVED: 28/08/2026 FRA Renewable Biogas Plant, / 257501.0350EIAR AWN Consulting Ltd 1-5 mechanisms for the incorporation of flood risk identification, assessment and management into the planning process. For carrying out a Site-specific Flood Risk Assessment (SSFRA), the OPW Guidelines recommend using Source-Path-Receptor (S-P-R) concept model to identify where the flood originates from, what the floodwaters path is and the areas in which assets and people might be affected by such flooding (Section 2.18 of the OPW Guidelines, 2009). Figure 2 below shows a schematic representation of S -P-R model. Figure 2: Schematic Representation of S-P-R model. A Flood Risk Assessment (FRA) is undertaken over several stages with the need for progression to a more detailed stage dependent on the outcomes of the former stage. As per the Flood Risk Management (FRM) Guidelines a tiered approach has been taken. This usually begins with a Stage 1 Assessment which aims to quantify the risk posed to the development and to the surrounding environment by this development. The main aim of this FRA is to determine the risk of flooding to the site, and the impact development will have on the floodplain, developments off site, upstream and downstream levels and any mitigation measures necessary. This hierarchy of assessment ensures that flood risk is taken into account at all levels of the planning system but also that the right level of detail is considered. This avoids the need for detailed and costly assessments prior to making strategic decisions. In terms of the Flood Risk Assessment and Management Study the scope of this work incorporates three stages: ► Stage 1: Flood Risk Identification - to identify whether there may be any flooding or plan issues related to a plan area or proposed development site that may warrant further investigation. ► Stage 2: Initial Flood Risk Assessment - to confirm sources of flooding that may affect a plan area or proposed development site, to appraise the adequacy of existing information and to determine what surveys and modelling approach is appropriate to match the spatial resolution required and complexity of the flood risk issues. The extent of the risk of flooding should be assessed which may involve preparing indicative flood zone maps. Where existing river or coastal models exist, these should be used broadly to assess the extent of the risk of flooding and potential impact of a development on flooding elsewhere and of the scope of possible mitigation measures; and, ► Stage 3: Detailed Flood Risk Assessment - to assess flood risk issues in sufficient detail and to provide a quantitative appraisal of potential flood risk to a proposed or existing development, of its potential impact on flood risk elsewhere and of the effectiveness of any proposed mitigation measures. This will typically involve use of an existing or construction of a hydraulic model of the river or coastal cell across a wide enough area to appreciate the catchment wide impacts and hydrological processes involved. RECEIVED: 28/08/2026 FRA Renewable Biogas Plant, / 257501.0350EIAR AWN Consulting Ltd 1-6 As described in the FRM guidelines flood risk is a combination of the likelihood of flooding and the potential consequences arising. This is normally expressed in terms of the following relationship: Flood risk = Probability of flooding x Consequences of flooding The likelihood of flooding is normally expressed as the percentage probability based on the average frequency measured or extrapolated from records over a large number of years. A 1% probability indicates the flood level that is expected to be reached on average once in 100 years, i.e. it has a 1% chance of occurring in any one year. Therefore: ► 100-year flood = 1% Annual Exceedance Probability (AEP). ► 1000-year flood = 0.1% AEP. In the FRM Guidelines, the likelihood of a flood occurring is established through the identification of Flood Zones which indicate a high, moderate, or low risk of flooding from fluvial or tidal sources as shown in Figure 1-2, as defined as follows: ► Flood Zone A - Where the probability of flooding is highest (greater than 1% AEP or 1 in 100 for river flooding and 0.5% AEP or 1 in 200 for coastal flooding) and where a wide range of receptors would be vulnerable. ► Flood Zone B - Where the probability of flooding is moderate (between 0.1% AEP or 1 in 1000 and 1% AEP or 1 in 100 for river flooding and between 0.1% AEP or 1 in 1000 year and 0.5% AEP or 1 in 200 for coastal flooding); and ► Flood Zone C - Where the probability of flooding is low (less than 0.1% AEP or 1 in 1000 for both river and coastal flooding). The Flood Zones shown on Figure 1-2 are for illustrative purposes to demonstrate typical demarcation of flood risk areas. They bear no connection to project and should not be used to determine the risk of flooding at the proposed development site. Figure 1-2. Flood Zones. According to the OPW Guidelines, the planning implication of each of the zones mentioned above are: RECEIVED: 28/08/2026 FRA Renewable Biogas Plant, / 257501.0350EIAR AWN Consulting Ltd 1-7 ► Zone A - High probability of flooding. Most types of development would be considered inappropriate in this zone. ► Zone B - Moderate probability of flooding. Highly vulnerable development, such as hospitals, residential care homes, Garda, fire and ambulance stations, dwelling houses and primary strategic transport and utilities infrastructure, would generally be considered inappropriate in this zone ► Zone C - Low probability of flooding. Development in this zone is appropriate from a flood risk perspective (subject to assessment of flood hazard from sources other than rivers and the coast) but would need to meet the normal range of other proper planning and sustainable development considerations. Potential impacts of the proposed development were considered within the study area. This is defined as the area within the proposed development site boundary (i.e. the proposed development site), and the wider hydrological setting of the area (refer to Table 1-1 and 1-2 below). A sequential plan approach was undertaken for this risk assessment under guidance from the local planning authorities (2009). Specifically, a sequential approach is first and foremost directed towards land that is at low risk of flooding. The underpinning philosophy of the sequential approach is highlighted in the illustration below. It should be noted that the above guidance is applicable in the layout and design of the specific subject site at the development management stage. Based on the CFRAM (Catchment Flood Risk Assessment and Management) PRFA (Preliminary Flood Risk Assessment) and Monaghan County Development Plan 2025-2031, the subject site resides in Flood Zone C (refer to Section 4 below). This report contains the first stage of the flood risk assessment. RECEIVED: 28/08/2026 FRA Renewable Biogas Plant, / 257501.0350EIAR AWN Consulting Ltd 1-8 1.2 Experience of Authors Rashaqat Ali Siddiqui (BSc, MSc, MIT). Ali is a hydrogeologist with over 7 years’ experience in water resource management and impact assessment. He has a Masters in Hydrogeology and is a former Education Secretary of the Irish chapter for the Association of Hydrogeologists (IAH). Ali’s specialist area of expertise is water resource management, Site investigation and monitoring, Contaminated land Assessment, hydrological assessment, site specific flood risk assessment and environmental impact assessment. Marcelo Allende (BSc, BEng) is a Principal Environmental Consultant (Hydrologist) at AWN with over 20 years of experience water resources technical studies, conceptual and numerical modelling and environmental consultancy. Marcelo holds a degree in Water Resource Civil Engineering (BEng, Hons) from the University of Chile and a Bachelor of Science in Engineering (BSc, Hons). He has worked on a wide of range of projects including multi-aspect environmental investigations, geo-environmental impact assessments, surface and groundwater resource management, hydrological and hydrogeological conceptual and numerical modelling, strategic and site specific flood risk assessments (Stage 1, 2 and 3), Due Diligence reporting, baselines studies, soils, surface water and groundwater monitoring and field sampling programmes on a variety of brownfield and greenfield sites throughout Ireland as well as overseas in Chile, Argentina, Peru and Panama. He also has detailed knowledge of environmental guidance, legislation, regulations & standards and expertise in GIS (expert level) and MATTE studies at COMAH establishments. He is currently a member of the International Association of Hydrogeologists (IAH, Irish Group) and a member of Engineers Ireland (MIEI. RECEIVED: 28/08/2026 FRA Renewable Biogas Plant, / 257501.0350EIAR AWN Consulting Ltd 1-9 1.3 Methodology This assessment follows the FRM Guidelines; the methodology involves researching the following data sources: ► Base maps – Ordnance Survey of Ireland; ► Flood Hazard Maps and flooding information for Ireland, www.floodinfo.ie Office of Public Works (OPW); ► Geological Survey of Ireland (GSI) maps on superficial deposits; ► EPA hydrology maps; ► National River Basin Management Plan 2018-2021; ► Water Action Plan 2024 ► Monaghan County Development Plan 2025-2031; ► Geological Survey of Ireland (GSI) maps on superficial deposits (current and historical); ► Circular PL2/2014 Flooding Guidelines; ► The National Development Plan 2018 – 2027. The proposed development and its component parts have been assessed against the FRM Guidelines Classification of Vulnerability. It is considered that the proposed development would reside within the warehousing, commercial, industrial and waste treatment categories; as such it is classified as ‘Less Vulnerable Development’ (see Table 1-1 below). According to the FRM Guidance, a Less Vulnerable Development requires a Justification test for Flood Zone A and is appropriate for Flood Zones B and C (see Table 1-2 below). RECEIVED: 28/08/2026 FRA Renewable Biogas Plant, / 257501.0350EIAR AWN Consulting Ltd 1-10 Table 1-1. Classification of vulnerability of different types of developments. RECEIVED: 28/08/2026 FRA Renewable Biogas Plant, / 257501.0350EIAR AWN Consulting Ltd 1-11 Table 1-2: Matrix of vulnerability versus flood zone to illustrate appropriate development and that required to meet the Justification Test. 1.4 Climate change Flood risk is anticipated to increase as a result of climate change. Projected impacts for Ireland include: ► Sea level rise of between 18cm and 59cm this century; ► More intense storms and rainfall events; ► Increased likelihood and magnitude of river and coastal flooding; and ► Increased storm surges. With respect to this assessment and the development area, only changes in the intensity of rainfall events and the magnitude of river flooding are of direct relevance. In all developments, climate change should be considered when assessing flood risk and in particular residual flood risk. Consideration of climate change is particularly important where flood alleviation measures are proposed, as the design standard of the proposal may reduce significantly in future years due to increased rainfall, river flows and sea levels. The Guidelines recommend that a precautionary approach to climate change is adopted due to the level of uncertainty involved in the potential effects. A significant amount of research into climate change has been undertaken on both a national and international front, and updates are ongoing. Based on these two scenarios the OPW recommended allowances for climate change are given in Table 1-3 below. These climate change allowances are particularly important at the development management stage of planning and will ensure that proposed development is designed and constructed to take into account best current knowledge. Table 1-3. Allowances in Flood Parameters for the Mid‐Range and High‐End Future Scenarios for Fluvial and Tidal Sources Parameter MRFS HEFS Extreme Rainfall Depths +20% +30% Peak Flood Flows +20% +30% Mean Sea Level Rise +500 mm +1,000 mm RECEIVED: 28/08/2026 FRA Renewable Biogas Plant, / 257501.0350EIAR AWN Consulting Ltd 1-12 Parameter MRFS HEFS Land Movement -0.5 mm/year 1 -0.5 mm/year 1 Urbanisation No General Allowance – Review on a Case by Case Basis No General Allowance – Review on a Case by Case Basis Forestation -1/6 Tp 2 -1/3 Tp 2 +10% SPR 3 Note 1: Applicable to the southern part of the country only (Dublin – Galway and south of this) Note 2: Reduction in the time to peak (Tp) to allow for potential accelerated runoff that may arise as a result of drainage of afforested land Note 3: Add 10% to the Standard Percentage Runoff (SPR) rate: This allows for temporary increased runoff rates that may arise following felling of forestry. For most development, including residential, nursing homes, shops and offices, the medium -range future scenario (20% increase in flows) is an appropriate consideration. This should be applied in all areas that are at risk of flooding (i.e. within Flood Zone A and B) and will be considered for sites which are in Flood Zone C but are adjacent to Flood Zone A or B. This is because land which is currently not at risk may become vulnerable to flooding when climate change is taken into account. Where the risk associated with inundation of a development is low and the design life of the development is short (typically less than 30 years) the allowance provided for climate change may be less than the 20% / 0.5m level. In general, climate change will be accounted for by the setting of finished floor levels to a height which includes an allowance for climate change. However, climate change may also reveal additional flow paths which need to be protected or give rise to flows which exceed culvert capacity or overtop defences. These outcomes will need to be specifically investigated for each site, and an appropriate response provided. RECEIVED: 28/08/2026 FRA Renewable Biogas Plant, / 257501.0350EIAR AWN Consulting Ltd 2-13 2. BASELINE CONDITIONS 2.1.1 Receiving environment 2.1.1.1 Hydrological features The Renewable Biogas site is located within the Erne WFD Catchment (Catchment ID: 36) and the Dromore_sc_20 WFD sub-catchment (Dromore_070 WFD River Sub Basin; EPA, 2026). The project site is located within the Dromore_sc_20 WFD sub -catchment (Dromore 60 WFD River Sub Basin; EPA, 2025). According to the EPA online mapping (EPA, 2026) there are no watercourses that traverse the site grounds. The nearest waterbody Coolkill Lough Stream (EPA Code: IE_NW_36D020700) is located approximately 350 metres east from the Renewable Biogas site (395m from the point of discharge) which discharges to Coolkill Lough c.300 east. The Rockcorry Stream (EPA Code: IE_NW_36D020700) originates from Coolkill Lough and flows in a north westerly direction before passing through Drumgole Lough (EPA Code: IE_NW_36_415). It then continues in a southerly direction before ultimately discharging into the Dromore River (EPA Code: IE_NW_36D020900), approximately 3 km from the proposed development site. According to EPA mapping no watercourses traverse the proposed development site, refer to figure 2-1 for regional hydrological environment. Figure 2-1. Regional Hydrological environment A site walkover was carried out on 1st October 2024 by AWN to establish site conditions of the Renewable Biogas site. During the walkover it was identified that the Renewable Biogas site elevation substantially RECEIVED: 28/08/2026 FRA Renewable Biogas Plant, / 257501.0350EIAR AWN Consulting Ltd 2-14 decreases from south to north. Two field drains were noted along the western and eastern boundary flowing in a northernly direction and discharging into an existing drain on the northern boundary of the site parallel to L2280. The drain was observed to have very low volume with areas of dry drain, making it difficult to confirm flow direction. However, based on the local topography and on site observations it was determined that the drainage ditch discharges via a culvert under the R189 into another drainag e ditch, which is hydrologically connected to the Coolkill Lough Stream (EPA Code: IE_NW_36D020700), located approximately 350 metres east of the renewable biogas site/395m from the point of discharge. Figure 2-2. Local Hydrological Environment According to EPA (2025), Coolkill Lough stream has a WFD status (2019-2024) of ‘Poor’ and a WFD risk score of ‘At Risk’ of Not achieving Good Status by 2027 and DROMORE_070 waterbody (EPA Code: IE_NW_36D020900) is currently classified a by the EPA as having ‘Poor’ WFD water quality status (2019- 2024 period) and is WFD risk score of ‘At Risk’ of Not achieving Good Status by 2027. This ‘Poor’ status assigned is due to its poor biological (invertebrate) status or potential. According to NPWS (2024), the designated sites in closest proximity of the proposed development site are as follows: ➢ the Kilroosky Lough Cluster SAC (Site Code 001786), located c. 12km northeast (linear distance). ➢ Dromore Lakes pNHA (Site Code 000001), located c.2km south (linear distance). RECEIVED: 28/08/2026 FRA Renewable Biogas Plant, / 257501.0350EIAR AWN Consulting Ltd 2-15 However, the site has no hydrological pathway/connection to the Kilroosky Lough Cluster SAC or the Dromore lakes pNHA. Other designated sites which have hydrological connectivity to the proposed site are as follows: ➢ The Drumgole Lough pNHA ((Site Code 001601), located c. 930m north (linear distance) and c.9km (hydrological distance). ➢ The Lough Oughter and Associated Loughs SAC (Site Code: 000007), located c.14km west (linear distance) and c. 38km (hydrological distance). Refer to Figure 2-3 below for the location of Drumgole Lough pNHA ((Site Code 001601) Dromore Lakes pNHA (Site Code 000001 the Kilroosky Lough Cluster SAC (Site Code 001786) and The Lough Oughter and Associated Loughs SAC (Site Code: 000007). As Stated above, the site does have an indirect hydrological connection to the Drumgole pNHA and Lough Oughter and Associated Loughs. However, the connection is a long hydrological pathway allowing significant time for settlement and dilution and as such there is no potential for change in water quality of this receiving habitat. Figure 2-3. Designated Sites and Hydrological Connections 2.1.1.2 Existing site geology and hydrogeology Based on a review of GSI online mapping, the proposed development including the Renewable Biogas site is underlain by tills derived from Paleozoic Sandstones and Shales which are of low permeability. There are no recorded bedrock outcrops within the site boundary (GSI, 2025). RECEIVED: 28/08/2026 FRA Renewable Biogas Plant, / 257501.0350EIAR AWN Consulting Ltd 2-16 The proposed development is underlain by Red Island formation which comprises of Greywacke, microconglomerate & argillite. The landslide susceptibility classification within the site boundary ranges from ‘Low’ to ‘Moderate’ (GSI, 2025). The proposed development lies within the Rockcorry-Cootehill Ribbed Moraines geological heritage site. These moraines form part of the largest field of ribbed moraines found anywhere in the world (which also includes the Scotshouse-Redhills cross cutting ribbed moraines). The entire field includes over 3,000 features and this subset, covering an area of 18 by 10 kilometres, contains approximately 160 individual features. It includes the largest individual ribbed moraines found anywhere in the world and therefore one of the most important geological terrains in Ireland. According to GSI (2025), the bedrock aquifer underlying the proposed development site including the Renewable Biogas site is a classified as Poor Aquifer (PI), i.e. Bedrock which is Generally Unproductive except for Local Zones. The potential for vertical or horizontal migration within this type of aquifer is poor as fractures will be disconnected. As such the aquifer is not a significant pathway for off-site migration. No karst features have been identified with a 20km radius of the proposed development (GSI 2025). According to GSI regional mapping, the groundwater vulnerability rating is classified as ‘Low’ for the proposed development site (GSI, 2025). The groundwater body in the region of the site (Cavan GWB) is classified under the WFD Status 2019- 2024 (EPA, 2025) as having ‘Good Status’. The WFD Risk Score is ‘Not at Risk’ of not achieving good status by 2027. RECEIVED: 28/08/2026 FRA Renewable Biogas Plant, / 257501.0350EIAR AWN Consulting Ltd 3-17 3. DEVELOPMENT CHARACTERISTICS 3.1.1 Renewable Biogas Plant Site The development consists of the construction and operation of a Renewable Biogas Plant and associated infrastructure. The principal elements of the plant comprise a main process building where the feedstock for the anaerobic digestion (AD) process is received. An odour control system with a dispersion stack will treat the air from the building. The feedstock passes to the AD tanks located within a bunded tank farm. There is a combined heat and power (CHP) building where the electricity for the plant’s energy needs will be generated from the biogas produced in the AD process. A Biogas Upgrade and Treatment Plant will be installed to produce biomethane (a renewable natural gas) that will be exported via a Gas Grid Entry Unity to the national gas grid. A CO2 Liquefaction plant will be installed to capture the carbon dioxide in the biogas, turning it into liquid CO₂. A Dryer Building is proposed, where the digestate will be dried, and a Pellet Hall will be constructed, where the digestate pellets will be stored prior to removal from the site for use as a natural fertiliser product. Ancillary elements include a gas dome, tanks to store incoming liquid feedstock, freshwater, firewater, and fuel, a backup gas flare, a backup generator, a plant building, and a control building. A new site entrance, weighbridges, wheel washes, parking facilities, and all ancillary development works and services also form part of the development. A high-level process flow follows. 3.1.1.1 Surface Water Drainage Strategy The drainage strategy for the proposed development consists of a number of surface water drainage networks that collect run-off from the proposed building and plant roofs, and external hardstanding areas, provides appropriate levels of attenuation, with an objective to reuse within the process the maximum amount of surface water generated from the operational extents of the site as possible. RECEIVED: 28/08/2026 FRA Renewable Biogas Plant, / 257501.0350EIAR AWN Consulting Ltd 3-18 Run-off will enter the drainage network via gullies, rainwater downpipes, or linear drains and travel through a network of pipes to underground attenuation tanks. The tanks will attenuate flows up to and including the 100-year plus 30% climate change allowance and discharge surface water to the downstream network at a restricted flowrate. A water treatment system comprising of SDS Aquaswirl Vortex Pollutant Separation System Chambers and SDS AquaFilter Surface Water Filtration Units will be installed on the inlet pipework to the attenuation tanks, to reduce the overall amount of total suspended solids and other potential compounds within the surface water run-off. Any harvested surface water used in the plant process or discharged from the site will have undergone treatment via these units. As noted above, the proposed development will be utilising rainwater within the AD process as part of daily operations. This will significantly reduce the volume of water that would potentially be discharged from the site. As a result, it shall provide betterment over existing greenfield run-off rates that would typically be generated from the site. It is noted that the proposed development site does include large permeable areas that are typically associated with landscaping (i.e. earthworks berm). In general, any run-off from these areas shall follow the existing drainage regime, directed to and utilising existing drainage ditches that shall remain along the boundary of the site, with flow directed to the existing discharge point on the north-east site boundary. As a worst-case scenario, should onsite water re-use be halted, the proposed development will discharge water at a rate equivalent to the greenfield run-off currently experienced with attenuation being provided. The maximum design discharge flow from the site will be 83.5l/s, the calculated greenfield runoff rate for the site for a 1-in-100-year event. If run-off does leave the site, it will discharge into an existing culvert which sends flows to a ditch located on the opposite side of the R189 to the site, on the north-east site boundary. This is subject to gaining the necessary discharge consent/approvals. This ditch conveys water to the nearest watercourse (Coolkill Lough Stream) to the east of the site. 3.1.1.2 Foul Water Foul water flows generated from the proposed development will be directed to a private foul water treatment plant via a network of pipes and manholes. Effluent will discharge to a Foul Water Pumping Station. Occasional removal of solids (c.0.5 tonnes / annum) from the treatment plant off-site to an appropriate facility will be required (likely the McBreen facility c.20km southwest of the site in Lismagratty, Cootehil Road, Cavan). The Foul Water Pumping Station will pump to be used on site as part of the AD process. As such, there will be no trade effluent (waste waters) or domestic type wastewater discharging from the proposed development. The Foul Water Pumping Station will be sized to provide 24 hours of storage for the foul flows generated by the site as a contingency should there be a pump or power failure. It will also afford some flexibility to the plant operator with respect to sending the treated water to the AD process RECEIVED: 28/08/2026 FRA Renewable Biogas Plant, / 257501.0350EIAR AWN Consulting Ltd 4-19 4. STAGE 1- FLOOD RISK IDENTIFICATION In broad terms, the potential sources of flooding at the site can be categorised as: ► Fluvial (River) Flooding: The main risk of fluvial flooding is from the local hydrological environment. Fluvial or river flooding occurs when the capacity of a watercourse is exceeded or the channel is blocked or restricted, and excess water spills out from the channel onto adjacent low-lying area. ► Tidal/Coastal Flooding: There is no potential for tidal/coastal flooding based on the location of the site. ► Pluvial Flooding: Pluvial flooding occurs when the capacity of the local drainage network is exceeded during periods of intense rainfall. At these times, water can collect at low points in the topography and cause flooding. ► Groundwater Flooding: Groundwater Flooding can occur during lengthy periods of heavy rainfall, typically during late winter/early spring when the groundwater table is already high. If the groundwater level rises above ground level, it can pond at local low points and cause periods of flooding. Groundwater flood is usually associated with areas of high karstification i.e. the west of Ireland. Each of these potential sources of flooding are considered in this FRA. 4.1.1 Historical Flooding Records According to the OPW records, there are no previous flood events recorded within the proposed development site. However, a recurring flooding event area has been identified as ‘Drumgole Lough’, located c. 970 m north of the subject site as shown in Figure 4-1. As this recurring flooding area is local, it is not considered to represent a flood risk for the subject site. RECEIVED: 28/08/2026 FRA Renewable Biogas Plant, / 257501.0350EIAR AWN Consulting Ltd 4-20 Figure 4-1. Historic Flood Events 4.1.2 Fluvial Flooding 4.1.2.1.1 CFRAM Preliminary Flood Risk Assessment (PFRA) The EU Floods Directive (2007/60/EC) required Member States to undertake a national preliminary flood risk assessment by 2011 to identify areas where significant flood risk exists or might be considered likely to occur. Members States were also required to prepare catchment-based Flood Risk Management Plans by 2018 that will set out flood risk management objectives, actions and measures. The OPW in co- operation with various Local Authorities produced a number of PFRAs which aimed to map out current and possible future flood risk areas and develop risk assessment plans. These have been used to form the Draft Flood Risk Management Plans aimed at identifying possible structural and non-structural measures to improve the flood risk. As part of the CFRAM programme provisional flood maps had been produced by the OPW which have been used in this assessment. The PFRA flood maps do not indicate flooding risk throughout the proposed development site as shown in Figure 4-2. RECEIVED: 28/08/2026 FRA Renewable Biogas Plant, / 257501.0350EIAR AWN Consulting Ltd 4-21 Figure 4-2. CFRAM River Flood Probability (OPW, 2025) 4.1.2.1.2 Strategic Flood Risk Assessment (SFRA) – Monaghan County Development Plan A Strategic Flood Risk Assessment (SFRA) for the Monaghan County Development Plan 2025-2031 was developed by McCloy Consulting and published in March 2025 Flood Risk Maps have been produced as part of this assessment based on desk and field studies including predictive and historical indicators of flood risk, documented Council knowledge of lands, etc. A Flood Risk Assessment mapping was developed by the Monaghan County Council, and an extract is shown in Figure 4-3 below. The site boundary is indicated with a red outline in the northwest corner of the map. This shows the proposed development site was outside any defined flood risk zone (source: https://monaghan.ie/wp-content/uploads/2024/10/Appendix-19-SFRA-Appendix-A.pdf). RECEIVED: 28/08/2026 FRA Renewable Biogas Plant, / 257501.0350EIAR AWN Consulting Ltd 4-22 Figure 4-3.Strategic Flood Risk Assessment Monaghan County From reviewing Figure 4-1 to 4-3 (above), it is shown that the proposed development site is within Flood Zone C i.e. the probability of flooding is low (less than 0.1% AEP or in 1 in 1000 year) for Fluvial flooding. The proposed development may be categorised as “Appropriate” as per the FRA Guidel ines (OPW, 2009) as the development is “Less Vulnerable Development” As indicated in Table 1-1 above, the OPW Guidelines state that ‘Less Vulnerable Developments’ are deemed ‘appropriate’ within Flood Zone C, therefore a Justification Test for Development Management is not required in this case. 4.1.3 Pluvial Flooding Flooding of land from surface water runoff is usually caused by intense rainfall that may only last a few hours. The resulting water follows along natural valley lines, creating flow paths along roads and through and around developments and ponding in low spots, which often coincide with fluvial floodplains. Any areas at risk from fluvial flooding will almost certainly be at risk from surface water flooding. Surface water discharge from all areas will be collected and directed to an attenuation/rainwater harvesting system. Collected rainwater will be stored on site and reused in the AD process. All captured surface water within the site will pass through a sequence of Aqua Swirl Vortex and Aqua Filter Unit at least once prior to use in the AD process or discharge from site. Attenuation will be provided on site for flows up to and including the 100-year plus 30% climate change allowance and discharge surface water to the downstream network is managed with a restricted flowrate. RECEIVED: 28/08/2026 FRA Renewable Biogas Plant, / 257501.0350EIAR AWN Consulting Ltd 4-23 As a worst-case scenario, should onsite water re-use be halted, the proposal development will discharge water at a rate equivalent to the greenfield run-off currently experienced with attenuation being provided. The maximum design discharge flow from the site will be 83.5l/s which is the calculated greenfield runoff rate for the site for a 1-in-100-year event. This will ensure that any discharges from site will not cause any flooding in the receiving watercourses. 4.1.4 Groundwater Flooding Groundwater flooding can be due to high water tables and increased recharge following extended periods of wet weather and usually associated with the karst areas of the west of Ireland. According to the OPW and GSI records, there have been no reported instances of groundwater flooding in the area of study. An analysis of datasets available online through GSI Mapping was undertaken to determine the potential for groundwater flooding. Groundwater flooding is most common in Karst areas. The GSI Groundwater Data Viewer shows no indication of any Karst features in the area. This indicates that the proposed site has a low risk from groundwater flooding. 4.1.5 Other Sources of Flooding There are no reservoirs, canals or other significant artificial sources in the vicinity of the development site. As such flooding from this source is not considered a risk to the site and therefore is not discussed further within this FRA. 4.1.6 Overview of Flood Risk Identification The OPW Historical records show that there is no evidence of flooding at the site. The desktop review shows the proposed development site is not at risk from coastal, pluvial, fluvial or groundwater flooding. Therefore, the proposed development is located within Flood Zone C. Based on the 2009 Guidelines, it is concluded that this type of development (proposed Renewable Biogas Plant) is appropriate for this flood zonation. Therefore, based on the nature of the development and the results presented above, it is considered that it is not necessary to proceed to Stages 2 and 3. 4.1.7 Flood Mitigation Measures Surface water discharge from all areas will be collected and directed to an attenuation/rainwater harvesting system. Collected rainwater and storm water will be utilised in the wheel washing and AD processes. Excess surface water will be attenuated in underground tanks via silt traps and oil interceptors prior to discharge from the site to an approved location at greenfield runoff rates. The network will be designed to cater for a 1 in 100-year event with a 30% addition to account for climate change. Surface water runoff from hardstanding areas, the tank farm and buildings will be collected via a network of pipes. Surface water captured in bunded areas, such as the tank farm, will be assessed for potential contaminants prior to discharge to the drainage system. If unsuitable to be discharged to the drainage system this water will be pumped from a sump in the bund, to ensure there is no inadvertent discharge to the surface water drainage system. All surface water which is discharged to the attenuation/rainwater harvesting system shall pass through Aqua Swirl Vortex and Aqua Filter units, to improve the quality of the runoff from the proposed development. The attenuation/rainwater harvesting system has a dual purpose of: RECEIVED: 28/08/2026 FRA Renewable Biogas Plant, / 257501.0350EIAR AWN Consulting Ltd 4-24 ► reducing the peak quantity of discharge from the site by attenuating the volume and restricting the flow and; ► providing permanent storage for reuse of collected rainwater in the operation of the proposed facility. The management of surface water for the proposed development has been designed to comply with the policies of the Monaghan County Council Development Plan (refer to Engineering Services Report, McAdam, 2025). The overall objective is to minimise stormwater runoff and to collect and treat this minimised amount of runoff as close to the source as possible. 4.1.8 Residual Risk According to the 2009 Guidelines, the residual risk remains after all risk avoidance, substitution and mitigation measures have been implemented, on the basis that such measures only reduce risk, not eliminate it. The residual risk associated to climate change is considered to be low, based on CFRAM Mid-Range and High-End future models (refer to Section 1.5 above). Figure 4-4 below show that the site is located within Flood Zone C for both cases. Figure 4-4. Extract from CFRAM MRFS and HEFS Pluvial Flooding Map for the Site Area (CFRAM, 2025). In addition, the development includes drainage and attenuation strategy that have been designed with an allowance 30% increase in flows as suggested per 2009 Guidelines. RECEIVED: 28/08/2026 FRA Renewable Biogas Plant, / 257501.0350EIAR AWN Consulting Ltd 5-25 5. CONCLUSIONS This Stage 1 Flood Risk Assessment has been undertaken in accordance with the FRM guidelines. The main aim of this FRA is to determine the risk of flooding to the site and the impact the development will have on the floodplain; upstream and downstream levels and any mitigation measures necessary. The OPW CFRAM online mapping and associated Maps were used to consider the risk of flooding to the proposed site. Based on the nature of the development and the results presented above, it is considered that it is not necessary to proceed to Stages 2 and 3. The review of the available data on fluvial, pluvial and groundwater flooding shows that the proposed development site has no historical flood hazard identified in the vicinity; the entire site falls within Flood Zone C and no further justification test is required. No residual risk is foreseen as the development is located outside any flooding zones associated with future scenarios (MRFS and HEFS). The development includes a drainage and attenuation strategy that have been designed with an allowance 30% increase in flows as suggested per 2009 Guidelines. Based on this information the proposed development complies with the appropriate policy guidelines for the area which include the Monaghan County Development Plan 2025-2031. Overall, it is concluded that this proposed development, and the surrounding area is not at risk from flooding since the proposed development is located in Flood Zone C. The type of development is classed as a ‘Less Vulnerable Development’. This type of development is deemed appropriate for this flood zonation. RECEIVED: 28/08/2026 FRA Renewable Biogas Plant, / 257501.0350EIAR AWN Consulting Ltd 6-26 6. REFERENCES ► The Planning System and Flood Risk Management Guidelines for Planning Authorities, DoEHLG, 2009. ► Base maps, Ordnance Survey Ireland. ► Flood Hazard Maps and flooding information for Ireland, www.floodinfo.ie ► GSI Bedrock Geology, Subsoils, Aquifers, Groundwater vulnerability online mapping, www.gsi.ie ► Monaghan County Council Development Plan 2025-2031 (https://monaghan.ie/planning/wp- content/uploads/sites/4/2024/09/Written-Statement-Draft-Monaghan-County-Development-Plan- 2025-2031.pdf ) ► The National Development Plan 2018 – 2027 ► Monaghan AD Plant, Engineering Services Report. McAdam, October 2025. RECEIVED: 28/08/2026 AUGUST 2026 VOLUME III APPENDICES TO ENVIRONMENTAL IMPACT ASSESSMENT REPORT APPENDIX 10.3 WATER FRAMEWORK DIRECTIVE ASSESSMENT Stream BioEnergy Ireland Limited RECEIVED: 28/08/2026 Appendix 10.3 Water Framework Directive (WFD) Screening Assessment for Monaghan Renewable Biogas Plant AWN Consulting Ltd, The Tecpro Building, IDA Business & Technology Park, Clonshaugh, Dublin 17, D17 XD90 Monaghan Renewable Biogas Plant RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd TABLE OF CONTENTS 1 WATER FRAMEWORK DIRECTIVE SCREENING ASSESSMENT 4 1.1 Introduction ............................................................................................................. 4 1.2 Site Setting and History ........................................................................................... 4 1.2.1 Renewable Biogas Plant Site .................................................................................. 4 1.2.2 Linear Gas Grid Connection .................................................................................... 4 1.2.3 Site History........................................................................................................... 5 1.3 Experience of Authors .............................................................................................. 5 1.4 Legislation and Guidance ......................................................................................... 5 1.5 Methodology ............................................................................................................ 6 1.5.1 WFD Risk Status ................................................................................................... 6 1.5.2 WFD Water Body Status ........................................................................................ 7 1.5.3 Methodology for Determination of No Deterioration Assessment ................................ 7 1.5.4 Assessment against Future Status Objectives ........................................................... 9 1.6 Sources of Information ............................................................................................ 9 2 DESCRIPTION OF EXISTING HYDROLOGICAL AND HYDROGEOLOGICAL ENVIRONMENT 11 2.1 Hydrology .............................................................................................................. 11 2.1.1 Regional Hydrological Environment ....................................................................... 11 2.1.2 Local Hydrological Environment ............................................................................ 12 2.1.3 Designated Sites ................................................................................................. 13 2.1.4 Bathing Waters and Recreational Waterbodies ....................................................... 14 2.1.5 Water Supplies ................................................................................................... 15 3 HYDROGEOLOGY 16 3.1.1 Groundwater Bodies ............................................................................................ 16 3.1.2 Groundwater Quality ........................................................................................... 16 3.1.3 Source Protection Areas ....................................................................................... 17 3.1.4 Aquifer Classification & Vulnerability ..................................................................... 17 4 WATER BODY IDENTIFICATION & STATUS 20 4.1 The DROMORE_070 WFD River Waterbody ............................................................ 21 4.2 The DROMORE_080 WFD River Waterbody ............................................................ 21 4.3 The Drumgole WFD Lake Waterbody ...................................................................... 22 4.4 The Cavan Groundwater Body (GWB) .................................................................... 22 5 DESCRIPTION OF THE PROJECT 24 5.1 Construction Phase ................................................................................................ 25 5.2 Operational Phase .................................................................................................. 25 6 ASSESSMENT OF SOURCE-PATHWAY-RECEPTOR (SPR) MODEL 27 6.1 Assessment of Potential Sources of Impact ........................................................... 27 7 NO DETERIORATION ASSESSMENT 7-28 7.1 HYDROLOGICAL ENVIRONMENT ........................................................................ 7-28 7.2 HYDROGEOLOGICAL ENVIRONMENT ................................................................. 7-28 7.3 ASSESSMENT IN TERMS OF FUTURE GOOD STATUS ........................................... 7-29 8 CONCLUSIONS 8-31 APPENDIX A. 8-32 RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd i APPENDIX B. 8-34 RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd ii LIST OF TABLES Table 1-1 Surface Water Assessment Matrix 7 Table 1-2 Groundwater Assessment Matrix 8 Table 4-1 WFD Waterbodies Located Within the Study Area 20 RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd iii LIST OF FIGURES Figure 2-1. Regional Hydrological environment 11 Figure 2-2. Drainage Ditches and Flow Directions (McAdam, 2025) 13 Figure 2-3. Designated Sites and Hydrological Connections 14 Figure 3-1. WFD Groundwater Bodies 16 Figure 3-2. Aquifer Classification 18 Figure 3-3. Groundwater Vulnerability Rating 19 Figure 4-1. Surface Water Quality for Dromore_070 WFD Surface Waterbody 21 Figure 4-2. Surface Water Quality for Dromore_080 WFD Surface Waterbody 22 Figure 4-3. Surface Water Quality for Drumgole WFD Surface Waterbody 22 Figure 4-4.Groundwater Quality for Cavan Groundwater Body 23 Figure 5-1. Proposed Layout (McAdam, 2025) 24 RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 4 1 WATER FRAMEWORK DIRECTIVE SCREENING ASSESSMENT 1.1 Introduction AWN Consulting Limited (AWN) has prepared this Water Framework Directive (WFD) Assessment to support the competent authority in determining whether the Proposed Project has the potential to cause deterioration in the status of any relevant surface water or groundwater body, deterioration of any relevant WFD quality element, or prevent the achievement of the applicable WFD environmental objectives. The Proposed Development for which planning permission is sought comprises the Renewable Biogas Plant at Maghernakelly, Drum, Co. Monaghan. The Linear Gas Grid Connection will be delivered separately by Gas Networks Ireland under the applicable statutory consenting process; however, it forms part of the overall Proposed Project for the purposes of EIA and is considered in this assessment where relevant to WFD receptors and pathways. The objective of the assessment is to address the following: • Does this development cause deterioration of a water body from its current status or potential for reaching “Good” status? • Does this development impact on any water dependent protected areas, priority species, habitats etc.? • Does this development support the achievement of water body objectives and programme of measures? The surface water assessment and groundwater assessment both examine potential effects of the proposed development, which includes the construction and operation of the proposed development. 1.2 Site Setting and History 1.2.1 Renewable Biogas Plant Site The site of the Proposed Development is located in Maghernakelly, Drum, Co. Monaghan, covering a total area of approximately 6.2 hectares. It is c.4km north of Cootehill and 17.5km southwest of Monaghan town. The site is comprised of two fields which are divided by tree lined hedgerows. It is bounded to the north by L2280 Drumcal Road, to the east by the R189 regional road, and to the west by Maghernakelly Road. To the south, the site adjoins New Park Farm and an existing residential property. The site is undulating with substantial elevation from approximately 109mOD in the southern section to around 93mOD at the northern boundary. 1.2.2 Linear Gas Grid Connection A gas transmission pipeline will provide a physical connection between the Renewable Biogas Plant and the existing national gas network in Dromore West. Co. Monaghan. While the development of the gas grid is not part of the planning application, as Gas Networks Ireland will deliver it, it is included in the EIAR for assessment purposes, as it forms part of the overall project for the EIA Directive. The works comprise the laying of an underground pipeline over approximately 3.5 km within the public road corridor. As the construction is a shallow trench in a roadway there is minimal potential for impact on receiving waterways. The design will be required to ensure the contractor manages collection and disposal of water during open trench cuts and soil disposal in an environmentally responsible manner. There are 3no. of water crossings on Crosslea 36 Stream along the pipeline route. It is proposed recommended that directional drilling (trenchless drilling) methodology will be RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 5 implemented along these water crossings. So, no potential for any significant surface water or groundwater disturbance. During operational Phase, there is no potential for impact on receiving waterways. 1.2.3 Site History The Renewable Biogas Plant site is presently undeveloped and is predominantly in pastoral agricultural use. Historical Ordnance Survey mapping indicates that the site has remained largely agricultural and has not been occupied by significant built development. The southern boundary adjoins New Park Farm and an existing residential property. Existing drainage features and the hydrological setting of the site are described in Section 2.1.2. 1.3 Experience of Authors Rashaqat Ali Siddiqui (BSc, Msc, MIT). Ali is a hydrogeologist with over 7 years’ experience in water resource management and impact assessment. He has a Masters in Hydrogeology and is a former Education Secretary of the Irish chapter for the Association of Hydrogeologists (IAH). Ali’s specialist area of expertise is water resource management, Site investigation and monitoring, Contaminated land Assessment, hydrological assessment, Water Framework Directive Assessment and environmental impact assessment. Teri Hayes (BSc MSc PGeol EurGeol, Dip Planning & Environmental Law) is a Director and Hydrogeologist with AWN Consulting with 30 years of experience in water resource management, environmental assessment and environmental licensing. Teri is a former President of The International Association of Hydrogeologists (IAH, Irish Group) and is a professional member of the Institute of Geologists of Ireland (IGI) and European Federation of Geologists (EurGeol). She has qualified as a competent person for contaminated land assessment as required by the IGI and EPA. Her project experience includes managing Environmental Impact Statements, Environmental Licences and environmental reports for Industry, Infrastructure and residential developments. Teri has written and provided technical review and training on environmental programmes for both the public and private sector and has considerable experience in public presentations, stakeholder liaison and acting as a legal witness. 1.4 Legislation and Guidance The Water Framework Directive (WFD) 2000/60/EC aims to protect and enhance the quality of the water environment (both surface water and groundwater) across all European Union member states. The WFD was transposed into Irish law by the European Communities (Water Policy) regulations 2003 (S.I. No 722 of 2003). The WFD requires that EU Member States achieve at least “Good” status for all water bodies by the year of 2027 at the latest. Additionally, where Member States assign “High” status objectives to water bodies, the “High” status must be achieved or maintained by 2027. The concept of ‘deterioration of the status’ of a body of surface water in Article 4(1)(a)(i) of Directive 2000/60 must be interpreted as meaning that there is deterioration as soon as the status of at least one of the quality elements, within the meaning of Annex V to the directive, falls by one class, even if that fall does not result in a fall in classification of the body of the surface water as a whole. However, if the quality element concerned, within the meaning of that annex, is already in the lowest class, any deterioration of that element constitutes a ‘deterioration of the status’ of a body of surface water, within the meaning of Article 4(1)(a)(i). The primary aim of the RBMP is that water bodies identified as being ‘At Risk’ of not achieving their WFD environmental objectives need to have targeted measures implemented to achieve objectives under this Plan. The EPA determines the significant pressures that are placing the water RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 6 body at risk of meeting its status objective. This determination focuses the programme of Measures for the relevant subcatchment(s). As part of its role, the EPA and other stakeholders such as local authorities must consider whether proposals for new developments (other than where exemptions apply Article 4.4 - 4.7 of the WFD) have the potential to: ➢ Cause a deterioration of a water body from its current status or potential; and/ or ➢ Prevent future attainment of good status or potential where not already achieved. As a result, new developments that have the potential to impact on current or predicted WFD status are required to assess their compliance against the WFD objectives of the potentially affected water bodies. The WFD is implemented through River Basin Management Plans (RBMPs) in six year cycles. We are currently in WFD third cycle 2022-2027 i.e. Water Action Plan 2024 - A River Basin Management Plan for Ireland, (Department of Housing Local Government & Heritage, Sept 2024). 1.5 Methodology This WFD assessment was based on a desktop review of the Environmental Protection Agency (EPA) dataset which was obtained from the portal www.catchments.ie (accessed May 2025). The water bodies identified for this assessment are related to the vicinity of the proposed construction area and its direct or indirect hydrological or hydrogeological connection. From the aforementioned source of information, the WFD Status classification and Risk score was obtained for the identified water bodies. Besides the status classification of water bodies, the WFD also requires that ‘designated sites’ meet their environmental requirements and conservation objectives. Designated sites are Natura 2000 sites (Special Areas of Conservation, SACs, with water-dependent habitats, and Special Protection Areas for species listed in the EU Habitats Directive); drinking water protected areas; bathing waters; shellfish waters; salmonid waters; and nutrient sensitive waters. Environmental requirements and conservation objectives for designated sites are stipulated in existing regulations or are being developed by the relevant public bodies (e.g., National Parks and Wildlife Service for SACs). 1.5.1 WFD Risk Status The WFD Risk score is the risk for each waterbody of failing to meet their WFD objectives by 2027. The risk of not meeting WFD objectives has been determined by assessment of monitoring data, data on the pressures and data on the measures that have been implemented. Waterbodies that are At Risk are prioritised for implementation of measures. This assessment was completed in 2020 by the EPA Catchments Unit in conjunction with other public bodies and was primarily based on monitoring data up the end of 2018. The three risk categories are: ➢ Waterbodies that are ‘At Risk’ of not meeting their Water Framework Directive objectives. For these waterbodies an evidence-based process was undertaken to identify the significant pressures; once a pressure is designated as ‘significant’, measures and accompanying resources are needed to mitigate the impact(s) from this pressure. These ‘At Risk’ waterbodies require not only implementation of the existing measures described in the various regulations, e.g., the Good Agricultural Practices Regulations, but also in many instances more targeted supplementary measures. RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 7 ➢ Waterbodies that are categorised as ‘Review’ either because additional information is needed to determine their status before resources and more targeted measures are initiated or the measures have been undertaken, e.g., a wastewater treatment plant upgrade, but the outcome hasn’t yet been measured/monitored. ➢ Waterbodies that are ‘Not at Risk’ and therefore are meeting their Water Framework Directive objectives. These require maintenance of existing measures to protect the satisfactory status of the water bodies. 1.5.2 WFD Water Body Status Surface water body status is classified on the basis of chemical and ecological status or potential. This system is summarised in Appendix A Table 1 and Table 2. Under the WFD, surface water body and groundwater body status is classified on the basis of quantitative and chemical status. This system is summarised in Appendix B. 1.5.3 Methodology for Determination of No Deterioration Assessment Projects that have the potential to impact on current or predicted WFD status are required to assess their compliance against the objectives defined for potentially affected water bodies. 1.5.3.1 Surface Water No Deterioration Assessment Table 1.1 below presents the matrix used to assess the effect of the Project on surface water status or potential class. It ranges from a major beneficial effect (i.e., a positive change in overall WFD status) through no effect to deterioration in overall status class. The colour coding used in Table 2.1 is applied to the No Deterioration Assessment’ spreadsheet provided in Appendix A of this report. Table 1-1 Surface Water Assessment Matrix Effect Description/ Criteria Outcome Major Beneficial Impacts that taken on their own or in combination with others have the potential to lead to the improvement in the ecological status or potential of a WFD quality element for the entire waterbody Increase in status of one or more WFD element giving rise to a predicted rise in status class for that waterbody. Minor/ localised beneficial Impacts when taken on their own or in combination with others have the potential to lead to a minor localised or temporary improvement that does not affect the overall WFD status of the waterbody or any quality elements Localised improvement, no change in status of WFD element No Impact No measurable change to any quality elements. No change Localised / temporary adverse effect Impacts when taken on their own or in combination with others have the potential to lead to a minor localised or temporary deterioration that does not affect the overall WFD status of the waterbody or any quality elements. Consideration will be given to habitat creation measures. Localised deterioration, no change in status of WFD element when balanced against mitigation measures embedded in the project. RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 8 Adverse effect on class of WFD element Impacts when taken on their own or in combination with others have the potential to lead to the deterioration in the WFD status class of one or more biological quality elements, but not in the overall status of the waterbody. Consideration will be given to habitat creation measures. Decrease in status of WFD element when balanced against positive measures embedded in the project. Adverse effect on overall WFD class of waterbody Impacts when taken on their own or in combination with others have the potential to lead to the deterioration in the ecological status or potential of a WFD quality element, which then lead to a deterioration of status/potential of waterbody. Decrease in status of overall WFD waterbody status when balanced against positive measures embedded in the project. 1.5.3.2 Groundwater No Deterioration Assessment Table 1.2 below presents the matrix used to assess the effect of the Project on groundwater status class. It ranges from a beneficial effect but no change in status to deterioration in overall status class. The colour coding used in Table 2.2 is applied to the final ‘No Deterioration Assessment’ spreadsheet in Appendix A of this report. Table 1-2 Groundwater Assessment Matrix Magnitude of Impact of the Project on WFD Element Effect on WFD Element within the assessment boundary Effect on Status of WFD element at the Groundwater Body Scale Impacts lead to beneficial effect Combined impacts have the potential to have a beneficial effect on the WFD element. Improvement but no change to status of WFD element No measurable change to groundwater levels or quality. No measurable change to WFD elements. No change and no deterioration in status of WFD element Impacts when taken on their own have the potential to lead to a minor localised or temporary effect Combined impacts have the potential to lead to a minor localised or temporary adverse effect on the WFD element. Combined impacts have the potential to lead to a minor localised or temporary effect on the WFD element. No change to status of WFD element and no significant deterioration at groundwater body scale. Impacts when taken on their own have the potential to lead to a widespread or prolonged effect. Combined impacts have the potential to have an adverse effect on the WFD element. Combined impacts have the potential to have an adverse effect on the WFD element, resulting in significant deterioration but no change in status class at groundwater body scale. RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 9 Magnitude of Impact of the Project on WFD Element Effect on WFD Element within the assessment boundary Effect on Status of WFD element at the Groundwater Body Scale Impacts when taken on their own have the potential to lead to a significant effect. Combined impacts in combination with others have the potential to have a significant adverse effect on the WFD element. Combined impacts in combination with others have the potential to have an adverse effect on the WFD element AND change its status at the groundwater body scale 1.5.4 Assessment against Future Status Objectives River Basin Management Plans are used to outline water body pressures and the actions that are required to address them. The future status objective assessment considers the ecological potential of a surface water body and the mitigation measures that defined the ecological potential. Assessments are based on the project (including mitigation measures) risks (construction and operation) with regard to the objectives for achieving good status as set out in the 3rd Cycle RBMP 2022-2027 i.e. Water Action Plan 2024. The assessment considers whether the Project has the potential to prevent the implementation or impact the effectiveness of the defined measures in these plans. 1.6 Sources of Information Desk-based hydrological and hydrogeological information in the vicinity of the site was obtained through accessing databases and other archives where available. Data was sourced from the following: • Geological Survey of Ireland- online mapping (GSI, 2025). • GSI - Geological Heritage Sites & Sites of Special Scientific Interest. • Ordnance Survey of Ireland (OSI). • Teagasc subsoil database. • Catchments.ie • National Parks and Wildlife services (NPWS, 2025). • Environmental Protection Agency (EPA) – website mapping and database information. Envision water quality monitoring data for watercourses in the area. • Water Action Plan 2024 - A River Basin Management Plan for Ireland, (Department of Housing Local Government & Heritage, Sept 2024). • The Planning System and Flood Risk Management, Guidelines for Planning Authorities (Department of the Environment, Heritage and Local Government (DoEHLG) and the Office of Public Works (OPW). • Office of Public Works (OPW) flood mapping data (www.floodmaps.ie) • ‘Control of Water Pollution from Construction Sites, Guidance for Consultants and Contractors’ (CIRIA 532, 2001). Site specific data was derived from the following sources: • Monaghan AD Plant-Engineering Services Report (McAdam, 2025) Relevant legislation and guidance is as follows: • European Communities 920030, Common Implementation Strategy for the Water Framework Directives (2000/60/EC) Guidance Document No.2. • EPA (May 2015), An approach to characterisation as part of the Water Framework Directive V2 revised. RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 10 • EPA (2010) Methodology for Establishing Groundwater Threshold Values, the Assessment of Chemical and Quantitative Status for Groundwater and Groundwater Trends. • Common Implementation Strategy (CIS) (2017) Guidance Document No. 36 'Exemptions to the environmental objectives according to Article 4(7) provides comprehensive guidance on the application of Article 4(7). • Joint Assistance to Support Projects in European Regions (JASPERS) (2018) Water Framework Directive Project assessment checklist tool. • UKTAG (2012) Groundwater Chemical Classification for the Water Framework Directive. Paper 11b(i). • UK Technical Advisory Group on the Water Framework Directive. • UKTAG (2012) Groundwater Quantitative Classification for the Water Framework Directive. Paper 11b(ii), UK Technical Advisory Group on the Water Framework Directive. • Control of Water Pollution from Construction Sites, Guidance for Consultants and Contractors’ (CIRIA 532, 2001). This WFD assessment was based on desktop review of the Environmental Protection agency (EPA) and Local Authority Waters Programme water quality records which were obtained from the portal www.catchments.ie (accessed November 2025). From the aforementioned source of information, the WFD Status classification and Risk score was obtained for the identified water bodies. RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 11 2 DESCRIPTION OF EXISTING HYDROLOGICAL AND HYDROGEOLOGICAL ENVIRONMENT 2.1 Hydrology 2.1.1 Regional Hydrological Environment The Renewable Biogas site is located within the Erne WFD Catchment (Catchment ID: 36) and the Dromore_sc_20 WFD sub-catchment (Dromore_070 WFD River Sub Basin; EPA, 2026). The Erne catchment is divided into 28 Sub-Catchments with 129 river waterbodies, 132 lake waterbodies, five transitional waterbodies, 39 groundwater bodies and no coastal waterbodies. The project development including the Renewable Biogas site is located within the Dromore_sc_20 WFD sub-catchment (Dromore 60 WFD River Sub Basin; EPA, 2026). According to the EPA online mapping (EPA, 2025) there are no watercourses that traverse the site grounds. The nearest waterbody is Coolkill Lough Stream (EPA Code: IE_NW_36D020700) is located approximately 350 metres east from the Renewable Biogas site/395m from the point of discharge. Coolkill Lough Stream discharges into Coolkill Lough c.300 meters east. The Rockcorry Stream (EPA Code: IE_NW_36D020700) originates from Coolkill Lough and flows in a north westerly direction before passing through Drumgole Lough (EPA Code: IE_NW_36_415). It then continues in a southerly direction before ultimately discharging into the Dromore River (EPA Code: IE_NW_36D020900), approximately 3 km from the proposed development site. Figure 2-1. Regional Hydrological environment The nearest active surface waterbody EPA monitoring station is ‘Br.W. of Clementstown’ (StationCode: RS36D020700) located in the DROMORE_070 waterbody adjacent to Cootehill town c. 3.5km birds eye distance of the proposed development site. The most recent water quality RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 12 status recorded by the EPA (2022) at this monitoring station (EPA Code: RS36D020700) is classified as Q3 Poor, which denotes moderately polluted waterbody. This Value is based primarily on the relative proportions of pollution sensitive to tolerant macroinvertebrates (the young stages of insects primarily but also snails, worms, shrimps etc.) resident at a river site. According to EPA (2026), Coolkill Lough stream has a WFD status (2019-2024) of ‘Poor’ and a WFD risk score of ‘At Risk’ of Not achieving Good Status by 2027 and DROMORE_070 waterbody (EPA Code: IE_NW_36D020900) is currently classified a by the EPA as having ‘Poor’ WFD water quality status (2019-2024 period) and is WFD risk score of ‘At Risk’ of Not achieving Good Status by 2027. This ‘Poor’ status assigned to the is due to its poor biological (invertebrate) status or potential. Drumgole Lough (WFD Code: IE_NW_36_415) is assigned a WFD status (2019-2024) of ‘Poor’ and a WFD risk score is under review. The Coolkill Lough and Rockcorry Streams are located within the WFD surface waterbody ‘DROMORE_070’ (WFD Code: IE_NW_36D020700). The Dromore River is located within the ‘DROMORE_080’ WFD surface waterbody. 2.1.2 Local Hydrological Environment A site walkover was carried out on 1st October 2024 by AWN to establish site conditions of the Renewable Biogas site. During the walkover it was identified that the Renewable Biogas site elevation substantially decreases from south to north. Two field drains were noted along the western and eastern boundary flowing in a northernly direction and discharging into an existing drain on the northern boundary of the site parallel to L2280. The drain was observed to have very low volume with areas of dry drain, making it difficult to confirm flow direction. However, based on the local topography and on site observations it was determined that the drainage ditch discharges via a culvert under the R189 into another drainage ditch, which is hydrologically connected to the Coolkill Lough Stream (EPA Code: IE_NW_36D020700), located approximately 350 metres east of the renewable biogas site/395m from the point of discharge. RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 13 Figure 2-2. Drainage Ditches and Flow Directions (McAdam, 2025) A review of the Geological Survey Ireland (GSI) online mapping tool and historical mapping resources indicates that there are no recorded historical features or structures within the local environment of the proposed development site. This suggests that the area has no identified historical or archaeological significance based on available mapping data. 2.1.3 Designated Sites The NPWS (2026) on-line database have been reviewed to determine the location of areas of conservation within the Proposed Development site, and there are no Special Protected Areas (SPA) established under the EU Birds Directive (79/409/EEC), or Special Areas of Conserv ation (SAC) established under the Habitats Directive within the boundary of the Proposed Development site. Furthermore, there are no Natural Heritage Areas (NHA), or proposed Natural Heritage Areas (pNHA) established under the Wildlife Acts, 1976 and 2000 (as amended) within the boundary of the Proposed Development site. The designated sites in closest proximity of the site are as follows: ➢ the Kilroosky Lough Cluster SAC (Site Code 001786), located c. 12km northeast (linear distance). ➢ Dromore Lakes pNHA (Site Code 000001), located c.2km south (linear distance). However, the site has no hydrological pathway/connection to the Kilroosky Lough Cluster SAC or the Dromore lakes pNHA. RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 14 Other designated sites which have hydrological connectivity to the proposed site are as follows: ➢ The Drumgole Lough pNHA ((Site Code 001601), located c. 930m north (linear distance) and c.9km (hydrological distance). ➢ The Lough Oughter and Associated Loughs SAC (Site Code: 000007), located c.14km west (linear distance) and c. 38km (hydrological distance). The site does have an indirect hydrological connection to the Drumgole pNHA and Lough Oughter and Associated Loughs. However, the connection is a long hydrological pathway allowing significant time for settlement and dilution and as such there is no potential for change in water quality of this receiving habitat. Refer to Figure 2-3 below for the location of Drumgole Lough pNHA ((Site Code 001601) Dromore Lakes pNHA (Site Code 000001 the Kilroosky Lough Cluster SAC (Site Code 001786), Lough Oughter and Associated Loughs SAC (Site Code: 000007) and the hydrological connectivity in the context of the site. Further assessment is provided in the EIAR Biodiversity chapter. Figure 2-3. Designated Sites and Hydrological Connections 2.1.4 Bathing Waters and Recreational Waterbodies The local environment also includes areas of natural resources that relate to populations and human health that may be impacted by the Proposed Development, this includes economic resources, recreational and bathing waters, and drinking water resources. A review of Environmental Sensitivity Mapping online maps that includes the Register of Protected Areas (RPA) under the Water Framework Directive (WFD) has shown that there are no Recreational Waters, Bathing Waterbodies, within the proposed development or located within a 20km radius of the proposed development. RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 15 2.1.5 Water Supplies A review of the Environmental Protection Agency's (EPA) online mapping, which includes the Register of Protected Areas (RPA) established under the Water Framework Directive (WFD) does not show any Surface Water Drinking RPAs in the vicinity of the site. There is one known reported abstraction from surface water in the vicinity of the proposed development (Monaghan County Council, 2025). The area is supplied by Drumgole group water scheme which abstract water from Annaghmakerig Lough located c.1.9km north of the proposed development. However, no hydrological connection is identified between the site and the lough. RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 16 3 HYDROGEOLOGY 3.1.1 Groundwater Bodies The GSI (2026) National Bedrock Aquifer Map classifies that the proposed development site including the Renewable Biogas site and as being located within one groundwater body (GWB) i.e. Cavan groundwater body (GWB) (European Code: IE_NW_G_061) as presented in Figure 3-1. The key characteristics of the ‘Cavan’ groundwater body (GWB) have been identified by the GSI as follows: The Cavan Groundwater Body (GWB) is underlain predominantly by low transmissivity bedrock, with the northern section where the proposed site is located comprised mainly of Ordovician metasedimentary rocks. These rocks have experienced significant structural deformation, resulting in numerous faults aligned southwest to northeast and additional intersecting perpendicular faults. The area is mainly covered by glacial till (~71%), with smaller extents of peat (~9%) and rock outcrop or shallow subsoil (~10%). Groundwater recharge primarily occurs via rainfall infiltration through thin or permeable subsoils and exposed rock outcrops. However, recharge is often limited in areas where thick, low-permeability subsoils such as till and peat dominate, leading to reduced aquifer infiltration. Groundwater flow paths in the Cavan GWB are typically short ranging between 30 and 300 metres—with groundwater discharging quickly to nearby streams, springs, and lakes. These short flow paths reflect the limited storage and permeability of the aquifer. Groundwater flow direction is mainly governed by surface topography, with a general trend towards the north and east. Figure 3-1. WFD Groundwater Bodies 3.1.2 Groundwater Quality The Water Framework Directive (WFD) 2000/60/EC was adopted in 2000 as a single piece of legislation covering rivers, lakes, groundwater, transitional (estuarine) and coastal waters. In RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 17 addition to protecting said waters, its objectives include the attainment of ‘Good Status’ in water bodies that are of lesser status at present and retaining ‘Good Status’ or better where such status exists at present. ‘Good Status’ was to be achieved in all waters by 2015, as well as maintaining ‘high status’ where the status already exists. The EPA co-ordinates the activities of the River Basin Districts, local authorities and state agencies in implementing the directive, and operates a groundwater quality monitoring programme undertaking surveys and studies across the Republic of Ireland. Presently, the groundwater body in the region of the site (Cavan GWB - European Code: IE_NW_G_061) for which the site is located entirely within, has a WFD status of “Good” (WFD Period: 2016-2021) and a WFD risk score (3rd Cycle) of “Not at Risk” of not achieving good status. The objective is to protect the “Good status” and “not at risk” score by recognising that the quality of the groundwater could be at risk in the future due to point and diffuse sources of pollution. 3.1.3 Source Protection Areas There are no recorded Public Supply Source Protection Area or Group Scheme Preliminary Source Protection Areas in the vicinity of the site. The nearest Public Supply Source Protection Area is Clones Scotshouse PWS (IE_GSI_SPA_90) located c. 10km west of the site. The nearest groundwater Group Scheme Preliminary Source Protection Area is Templeport (IE_GSI_ZOC_161) located c. 35.3km west of the site. Groundwater flow paths in the Cavan GWB are typically short— ranging between 30 and 300 metres—with groundwater discharging quickly to nearby streams, springs, and lakes. Based on the flow proximity of the proposed development site to the PWS, the flow paths within the aquifer and the fact none of the river transverses these source protection areas. There is no hydrogeological connection between the site and the PWS. 3.1.4 Aquifer Classification & Vulnerability The GSI has devised a system for classifying the bedrock aquifers in Ireland. The aquifer classification for bedrock depends on a number of parameters including, the area extent of the aquifer (km2), well yield (m3/d), specific capacity (m3/d/m) and groundwater throughput (mm3/d). There are three main classifications: regionally important, locally important and poor aquifers. Where an aquifer has been classified as regionally important, it is further subdivided according to the main groundwater flow regime within it. This sub-division includes regionally important fissured aquifers (Rf) and regionally important karstified aquifers (Rk). Locally important aquifers are sub- divided into those that are generally moderately productive (Lm) and those that are generally moderately productive only in local zones (Ll). Similarly, poor aquifers are classed as either generally unproductive except for local zones (Pl) or generally unproductive (Pu). According to GSI (2025), the bedrock aquifer underlying the site is classified as a Poor Aquifer (PI), i.e. Bedrock which is Generally Unproductive except for Local Zones as presented in Figure 3-2. The potential for vertical or horizontal migration within this type of aquifer is poor as fractures will be disconnected. As such the aquifer is not a significant pathway for off-site migration. RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 18 Figure 3-2. Aquifer Classification Aquifer vulnerability is a term used to represent the intrinsic geological and hydrological characteristics that determine the ease with which groundwater may be contaminated generally by human activities. According to GSI regional mapping, the groundwater vulnerability rating is classified as ‘Low’ for the proposed development. Aquifer vulnerability classifications are primarily based on the permeability and thickness of subsoils. According to GSI regional mapping, the groundwater vulnerability rating is classified as ‘Low’ for the site, refer to Figure 3-3. RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 19 Figure 3-3. Groundwater Vulnerability Rating RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 20 4 WATER BODY IDENTIFICATION & STATUS This section presents the water bodies identified for assessment, reasoning and water body status. The overall Project site lies entirely within Erne WFD Catchment (Catchment ID: 36) and River Sub Basin Dromore_sc_20. The Erne catchment is divided into 28 Sub-Catchments with 129 river waterbodies, 132 lake waterbodies, five transitional waterbodies, 39 groundwater bodies and no coastal waterbodies. The Project site is located within the Dromore_sc_20 WFD sub-catchment (Dromore 60 WFD River Sub Basin; EPA, 2025). This WFD Screening has identified 3 no. WFD surface waterbodies and 1 no. groundwater bodies which need to be considered. The Coolkill Lough Stream, Rockcorry Stream, the Drumgole lough, the Dromore River and the underlying Cavan groundwater body (GWB). As stated in section 2.1.1, The Coolkill Lough and Rockcorry Streams are located within the WFD surface waterbody ‘DROMORE_070’ (WFD Code: IE_NW_36D020700). The Dromore River is located within the ‘DROMORE_080’ WFD surface waterbody. Drumgole lough (WFD Code: IE_NW_36_415) is assessed as its own waterbody via modelling. There is an existing ‘indirect’ hydrological connection/pathway through the site drainage which discharges to the Coolkill Lough Stream which eventually outfalls to the Dromore River. There is also an existing ‘indirect’ hydrogeological connection/pathway through lateral migration via groundwater within the underlying subsoils/top of weathered bedrock and/or Poor Aquifer (PI) to the surrounding hydrological environment i.e. the Coolkill Lough and Rockcorry Stream. The site has an indirect connection to the Natura 2000 site Lough Oughter and Associated Loughs SAC (Site Code: 000007) located 14km west via Dromore river. The surface and groundwater bodies are listed in Table 4-1 below. For each waterbody, the most recent WFD status (Period: 2019-2024), risk score and location in relation to the site are provided (EPA, 2025). Table 4-1 WFD Waterbodies Located Within the Study Area Type WFD Classification WFD Name/ID WFD Status (2016-2021) WFD Risk Score Location Surface Water River Waterbody DROMORE_070 (European Code: IE: IE_NW_36D020700) ‘Poor’ ‘At Risk’ Downstream of Site River Waterbody DROMORE_080 (European Code: IE_NW_36D020900) ‘High’ ‘Not at Risk’ Downstream of Site Lake Water Body Drumgole (European Code: IE_NW_36_415) ‘Poor’ ‘Review’ Downstream of Site Groundwater Groundwater Body Cavan GWB (European Code: IE_NW_G_061) ‘Good’ ‘Not at Risk’ Underlying site Sections 4.1, 4.2 and 4.3 below summarise the surface water quality of the DROMORE_070, DROMORE_080 and Drumgole Lough WFD surface waterbodies, respectively. Sections 4.4 summarise the groundwater quality of the underlying Poor Aquifer –(PI) i.e. Cavan groundwater body (GWB). RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 21 4.1 The DROMORE_070 WFD River Waterbody The Dromore_070 (European Code: IE_NW_36D020700) for which the Coolkill Lough and Rockcorry Streams are located within has a most recent WFD surface water status (WFD Period: 2019-2024) of ‘Poor’ and its current WFD risk score (3rd risk cycle) is ‘At Risk’ of not achieving good status by 2027. The most recent Sub-Catchment Assessment carried out by the EPA in January 2019 on the Dromore_SC_020 Sub-Catchment states the main pressure identified on the Dromore_070 WFD surface waterbody from agriculture and urban wastewater, likely attributing to the poor ecological and biological status or potential. Monitoring of the concentrations of Ammonia Total (as N) by the EPA has shown an upward trend, and Ortho-Phosphate (as P) have shown a downward trend. The most recent catchment report (HA 36 Erne Catchment Report) carried out by the EPA in May 2025 on the Erne Catchment states that significant pressures on the Dromore_070 WFD surface waterbody includes agriculture and urban wastewater. Figure 4-1. Surface Water Quality for Dromore_070 WFD Surface Waterbody 4.2 The DROMORE_080 WFD River Waterbody The Dromore_080 (European Code: IE_NW_36D020900) for which the Dromore River is located within has a most recent WFD surface water status (WFD Period: 2019-2024) of ‘High’ and its current WFD risk score (3rd risk cycle) is ‘Not at risk’ of not achieving good status by 2027. The most recent catchment report (HA 36 Erne Catchment Report) carried out by the EPA in May 2025 on the Erne Catchment does not state any significant pressures on the Dromore_080 WFD surface waterbody. RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 22 Figure 4-2. Surface Water Quality for Dromore_080 WFD Surface Waterbody 4.3 The Drumgole WFD Lake Waterbody The Drumgole (European Code: IE_NW_36_415) has a most recent WFD surface water status (WFD Period: 2019-2024) of ‘Poor’ and its current WFD risk score (3rd risk cycle) is under Review. The most recent Sub-Catchment Assessment carried out by the EPA in January 2019 on the Dromore_SC_020 Sub-Catchment states the main pressure identified on the Drumgole WFD surface waterbody from agriculture. Figure 4-3. Surface Water Quality for Drumgole WFD Surface Waterbody 4.4 The Cavan Groundwater Body (GWB) As stated in Section 3.1.1 above, the Cavan groundwater body (GWB) (European Code: IE_NW_G_061) underlays the entire site. The site is located within a ‘Poor Aquifer- (PI), this is an aquifer which is incapable of supplying regionally important supplies (e.g., large public water supplies). Based on the most recent data published by the EPA, the Cavan GWB has a WFD status of ‘Good’ (WFD Period: 2019-2024) and a WFD risk score (3rd Cycle) of ‘Not at Risk’ of not achieving good status, meaning it has achieved its objectives end the overall status is considered good. This” Good’” status is related to the overall groundwater status i.e. quantitative groundwater status and chemical groundwater status. The most recent catchment report (HA 36 Erne Catchment Report) carried out by the EPA in May 2025 on the Erne Catchment does not state any pressures on the Cavan groundwater body (GWB) (European Code: IE_NW_G_061). RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 23 Figure 4-4.Groundwater Quality for Cavan Groundwater Body RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 24 5 DESCRIPTION OF THE PROJECT The purpose of this section is to provide an overview of the key relevant details of the construction and operational phases of the Project. The information presented in this section is informed by the project design, but it is not a complete description of the Project. Please refer to chapter 2 for a complete description of the Proposed Development. The Proposed Project comprises two elements. The Proposed Development for which planning permission is sought is the Renewable Biogas Plant at Maghernakelly, Drum, Co. Monaghan, occupying approximately 6.2 ha. The second element is the approximately 3.5 km Linear Gas Grid Connection between the Renewable Biogas Plant and the existing national gas network at Dromore West. The Linear Gas Grid Connection will be delivered separately by Gas Networks Ireland under the applicable statutory consenting process but forms part of the overall Proposed Project for the purposes of EIA and this WFD assessment. Figure 5-1. Proposed Development Layout (McAdam, 2025) The works can be summarised in the following two sections: • Construction Phase • Operational Phase RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 25 5.1 Construction Phase During construction of the development, the potential of impact on water body status is associated with the following sources: ➢ Accidental release of suspended solids (muddy water with increased turbidity (measure of the degree to which the water loses its transparency due to the presence of suspended particulates) – arising from excavation and ground disturbance; ➢ Accidental release of alkaline water from cement/concrete (increase turbidity and pH) works; ➢ Accidental release of hydrocarbons and other construction chemicals (ecotoxic) – accidental spillages from construction plant or onsite storage; and ➢ Accidental release of wastewater (nutrient and microbial rich) – arising from accidental discharge from on-site toilets and washrooms. Construction phase sewerage will be contained in a tank and taken by tanker off site for disposal to McBreen Environmental facility (WFP-CN-21-0003-01), Lismagratty, Cootehill Road, or similar licensed facility nearby. ➢ Removal of any encountered contaminated soil during gas grid connection installation. These are temporary short-lived events which could impact on status without mitigation measures being in place. The most likely impact would be to surface water body status as the groundwater bodies are naturally protected by overlying clays at this site. There is no long term dewatering or water abstractions required during construction so no likely impact on groundwater quantitative status. 5.2 Operational Phase During operation of the development, the potential impact on water body status is associated with the following activities ➢ Accidental release of suspended solids (muddy water with increased turbidity (measure of the degree to which the water loses its transparency due to the presence of suspended particulates) – arising storm water runoff; ➢ Accidental release of hydrocarbons and other chemicals (ecotoxic) – accidental spillages from operational plant or onsite storage; and ➢ Groundwater Abstraction of a maximum of 45m3/day during dry periods. The operation of the Biogas plant will be undertaken in compliance with an EPA IED Licence which will include conditions to protect receiving waters e.g monitoring of any bulk chemical storage, management of any accidental emissions to ground and monitoring programmes. The proposed surface water management strategy is to collect and utilise the majority of the water within the AD process. All captured water will be treated via SDS Aquaswirl Vortex Pollutant Separation System Chambers and SDS AquaFilter Surface Water Filtration Units which will be installed on the inlet pipework to the attenuation tanks, to reduce the overall amount of total suspended solids, heavy metals, and hydrocarbons within the surface water run-off. Any excess water which will be discharged off site will have undergone this treatment. Attenuation will be provided on site for flows up to and including the 100-year plus 30% climate change allowance and discharge surface water to the downstream network is managed with a restricted flowrate. As a worst-case scenario, should onsite water re-use be halted, the proposed development will discharge water at a rate equivalent to the greenfield run-off currently experienced with attenuation being provided. The maximum design discharge flow from the site will be 83.5l/s which is the calculated greenfield runoff rate for the site for a 1-in-100-year event. It is noted that the proposed development site does include large permeable areas that are typically associated with landscaping (i.e. earthworks berm). In general, any run-off from these areas shall follow the RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 26 existing drainage regime, directed to and utilising existing drainage ditches that shall remain along the boundary of the site, with flow directed to the existing discharge point on the north-east site boundary. Foul water flows generated from the proposed development will be directed to a private foul water treatment plant via a network of pipes and manholes. The plant will treat the foul water and discharge the treated water to a Foul Water Pumping Station. Occasional removal of solids from the treatment plant off-site to McBreen Environmental facility or similar licensed facility. The Foul Water Pumping Station will pump the treated effluent to be used on site as part of the AD process. As such, there will be no trade effluent (waste waters) or domestic type wastewater discharging from the proposed development. As the AD plant will utilise poultry and animal manures – this will lead likely lead to a reduction in the impact of agricultural runoff to receiving water in Co. Monaghan. Currently as noted the water body status of the surface water body is Poor and agriculture is noted as a significant Pressure. RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 27 6 ASSESSMENT OF SOURCE-PATHWAY-RECEPTOR (SPR) MODEL A conceptual site model is developed based on a good understanding of the hydrological and hydrogeological environment, plausible sources of impact and knowledge of receptor requirements. This in turn allows possible Source Pathway Receptor (S-P-R) linkages to be identified. If no S-P-R linkages are identified, then there is no risk to identified receptors. 6.1 Assessment of Potential Sources of Impact This section presents the information related to the current waterbody status identified in the development area. The Proposed Development site lies within the Dromore WFD sub-catchment (Dromore_SC_020 WFD River Sub Basin EPA, 2025). The Groundwater Body (GWB) underlying the site is the Cavan Groundwater Body (EU Ground Waterbody Code: IE_NW_G_061). This WFD Screening has identified three (3) no. WFD surface waterbodies and one (1) no. WFD groundwater bodies of relevance due to the close proximity and connection of these waterbodies during the construction and operation of the Proposed Development. Table 1 and 2 in appendix A provides the impacts and includes the robust mitigation and design measures which will be incorporated into the Proposed Development throughout the construction and operational phases. RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 7-28 7 NO DETERIORATION ASSESSMENT 7.1 HYDROLOGICAL ENVIRONMENT As discussed in section 6 of this report, the Proposed Development has an indirect hydrological connection to the Coolkill Lough Stream (Dromore_070 river waterbody) located approximately 350 metres east of the Proposed Development Site or 395m from the point of discharge. There is a risk of surface water entering the Coolkill Lough Stream through the proposed drainage network which ultimately discharges to the Rockcorry Stream, the Dromore River and then to the Lough Oughter and Associated Loughs 14km west of the site. There are mitigation and design measures which will be implemented during the construction phase to protect the hydrological and hydrogeological environment. There is a potential of accidental discharges during the construction phase, however these are temporary short-lived events that will not impact on the water status of waterbodies long-term and as such will not impact on trends in water quality and overall status assessment. Construction of the Renewable Biogas Plant will be undertaken in accordance with the CEMP and Soil and Surface Water Management Plan, including measures for sediment control, management of excavation water, refuelling, concrete works and accidental spills. The Linear Gas Grid Connection will be delivered separately by Gas Networks Ireland. The pollution- prevention, excavation-water, sediment-control and watercourse-crossing measures identified in this assessment in respect of those works are therefore presented as recommendations for implementation by GNI through its applicable construction and environmental management procedures. There are no changes to the overall hydrological and hydrogeological regime as a result of the Proposed Development. There are no proposed diversions of any drainage ditches or waterbodies as part of the Proposed Development. The implementation of the design and mitigation measures outlined in this document, CEMP and the surface water management plan will ensure, there is no perceptible impact on the water quality of the Coolkill Lough stream, Rockcorry Stream Drumgole Lough and the Dromore River i.e. no change to the WFD status or elements in terms of the hydrological environment. Taking account of these measures, construction activities are not predicted to cause deterioration in the status of any WFD quality element or deterioration in the overall status of the identified surface waterbodies. 7.2 HYDROGEOLOGICAL ENVIRONMENT As discussed in section 6 of this report, all areas associated with enabling works and operational phase have an indirect connection with the ‘Cavan’ groundwater body (GWB) (European Code: IE_NW_G_061) and is described as a ‘Poor Aquifer – (PI)’. No long-term dewatering will be required during groundworks. Local sustainable groundwater abstraction will be undertaken during drought periods. As such, no changes in water quality or levels are expected unless there are local alterations to the groundwater regime at the site. There is no potential for changes in water quality or levels unless the groundwater regime at the site undergoes local changes. There are no planned discharges to groundwater during the operational phase. However, there is a proposed groundwater abstraction onsite which will be designed sustainably so there is no potential for over abstraction. The project design includes hard standing areas across the site. However, these areas will have a minimal impact on infiltration capacities due to the extent and size of the Cavan GWB in relation to the proposed site. RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 7-29 There is limited potential of accidental discharges during the construction phase. However, should these occur they are temporary short-lived events that will not impact on the water status of the underlying bedrock aquifer long-term and as such will not impact on trends in water quality and overall status assessment. The project-specific mitigation measures will be implemented to ensure the protection of the hydrogeological environment during construction which will ensure that there will be no negative impact on the quantitative or qualitative of the underlying Poor Aquifer (Cavan GWB). In terms of the operational phase, the risk to the aquifer is considered to be low since there are no proposed discharges to ground and all bulk oil for backup generator and operational site vehicles will be stored in fully bunded areas with 110% capacity. All other chemicals are stored within the AD building. All generators will be double bunded meaning the fuel tanks will sit inside another fuel tank in the event of a spill, emergency spill procedures and spill mats will be in place in the event of an accidental spill or leak. The proposed hard standing area across the Renewable Biogas site will also provide protection as no permeable surfaces are proposed within the process areas. All foul water produced during the operation phase will be treated on site as stated above. The solids from the foul water will be separated and disposed off site at McBreen Environmental facility (or similar) and all the liquid will be introduced back into the AD process. There are no proposed wastewater discharges during the operation phase. There is a proposed groundwater abstraction well on site to a maximum of 45m3/day during dry periods. However, given the demand and the catchment size of Cavan GWB and proposed dual pumping to storage system, there is no risk associated with over abstraction which can impact the WFD quantitative status of the GWB. The implementation of the mitigation measures outlined in this document, CEMP and the surface water management plan will ensure, there is no perceptible impact on the water quality of the Cavan GWB i.e. no change to the WFD status or elements in terms of the hydrogeological environment. On that basis, the abstraction is not predicted to cause a measurable adverse change in groundwater levels at groundwater-body scale or deterioration in the quantitative status of the Cavan GWB. 7.3 ASSESSMENT IN TERMS OF FUTURE GOOD STATUS The Dromore_070 (European Code: IE_NW_36D020700) for which the Coolkill lough Stream and Rockcorry streams are located within has a most recent WFD surface water status (WFD Period: 2019-2024) of ‘Poor’ and its current WFD risk score (3rd risk cycle) is under ‘At Risk’ of not achieving good status by 2027. The most recent Sub-Catchment Assessment carried out by the EPA in January 2019 on the Dromore_SC_020 Sub-Catchment states the main pressure identified on the Dromore_070 WFD surface waterbody is from agriculture, likely attributing to the poor ecological and biological status or potential. Monitoring of the concentrations of Ammonia Total (as N) by the EPA has shown an upward trend, and Ortho -Phosphate (as P) have shown a downward trend. The Dromore_080 (European Code: IE_NW_36D020900) for which the Dromore river is located within has a most recent WFD surface water status (WFD Period: 2019-2024) of ‘High’ and its current WFD risk score (3rd risk cycle) is ‘Not at risk’ of not achieving good status by 2027. The most recent Sub-Catchment Assessment carried out by the EPA in December 2018 on the Dromore_SC_020 Sub-Catchment states is passed all Ecological Status or potential. The Cavan groundwater body (GWB) (European Code: IE_NW_G_061) underlays the entire portion of the and is described as a ‘Poor Aquifer – (PI)’. This is a generally unproductive except for Local Zones. Based on the most recent data published by the EPA, the Cavan GWB has a WFD status of ‘Good’ (WFD Period: 2019-2024) and a WFD risk score (3rd Cycle) of ‘Not at Risk’ of not achieving good status. The objective is to protect the “Good status” and “not at risk” score by recognising that the quality of the groundwater could be at risk in the future due to point and diffuse sources of pollution. This ‘Good’” status is related to the overall groundwater status i.e. quantitative groundwater status and chemical groundwater status. RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 7-30 At present there are no local targeted measures within the catchments to maintain or achieve improvements to the status of the water bodies. However, the following are some pressures associated with waterbody catchments: • Management of pollution from agricultural activities. • Management of pollution from urban environments. No dewatering or discharge to ground is required during operation. There is a proposed groundwater abstraction well on site to a maximum of 45m3/day during dry periods. However, given the demand and the catchment size of Cavan GWB. There is no risk associated with over abstraction which can impact the WFD quantitative status of the GWB. As such there will be no change to the existing status as a result of the proposed event. Based on the above information it is not considered that any aspects of the proposed event will prevent the WFD objectives from being achieved or to meet the requirements and/or objectives in the third RBMP 2022-2027 (River Basin Management Plan) and Water Action Plan 2024 - A River Basin Management Plan for Ireland. RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 8-31 8 CONCLUSIONS Appendix A contains the background information and the WFD classification elements for surface water and groundwater body status. The colour coded system referred to in Appendix A – Table 1 and Table 2 are used to give a visual impression of the surface water and groundwater assessment, respectively Appendix B presents the methodology for the surface water and groundwater assessments. The WFD assessment indicates that, based on the current understanding of the Project, there is no potential for adverse or minor temporary/ long-term or localised effects on the Coolkill lough stream, Rockcorry stream, Drumgole Lough and Dromore River. Therefore, it has been assessed that the proposed development will not cause any deterioration or change in water body status or prevent attainment, or potential to achieve, future good status or to meet the requirements and/or objectives in the third RBMP 2022-2027 (River Basin Management Plan) and Water Action Plan 2024 - A River Basin Management Plan for Ireland. The WFD assessment indicates that there is no potential for adverse or minor temporary or localised effects on the Cavan groundwater body (GWB). Therefore, it has been assessed that it is unlikely that the proposed site will cause any deterioration or change on its water body status or prevent attainment, or potential to achieve the WFD objectives or to meet the requirements and/or objectives in the third RBMP 2022-2027 (River Basin Management Plan) and Water Action Plan 2024 - A River Basin Management Plan for Ireland. Accordingly, no WFD deterioration or impediment to the achievement of WFD objectives is predicted as a result of the Proposed Project. No further assessment of WFD is recommended given that no significant deterioration or change in water body status is expected based on the current understanding of the Project during construction and operation. RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 8-32 APPENDIX A. RECEIVED: 28/08/2026 Surface WaterScheme ElementsPhase (Construction/ Operation)Construction ConstructionOperationOperationIdentified Quantitative ImpactsIncreased run-off and sediment loadingPollution due to accidential discharges or spillages during the construction phaseIncrease in HardstandingAccidental Leaks and DischargesMacrophytes and phytobenthos - combinedNo measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No anticipated impacts to the hydrological environment with no deterioration to the WFD StatusMacroinvertebratesNo measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No anticipated impacts to the hydrological environment with no deterioration to the WFD StatusFishNo measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No anticipated impacts to the hydrological environment with no deterioration to the WFD StatusTotal AmmoniaNo measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No anticipated impacts to the hydrological environment with no deterioration to the WFD StatusTotal NitrogenNo measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No anticipated impacts to the hydrological environment with no deterioration to the WFD StatusOrtho-PhosphateNo measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No anticipated impacts to the hydrological environment with no deterioration to the WFD StatusQuantity and dynamics of river flowNo measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No anticipated impacts to the hydrological environment with no deterioration to the WFD StatusConnection to GroundwaterNo measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No anticipated impacts to the hydrological environment with no deterioration to the WFD StatusRiver continuityNo measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No anticipated impacts to the hydrological environment with no deterioration to the WFD StatusRiver depth and width variation bedNo measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No anticipated impacts to the hydrological environment with no deterioration to the WFD StatusStructure and substrate of river bedNo measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No anticipated impacts to the hydrological environment with no deterioration to the WFD StatusStructure of riparian zoneNo measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No anticipated impacts to the hydrological environment with no deterioration to the WFD StatusPhysio-Chemical StatusRisk screening of potential to cause deterioration of current WFD statusHydromorphological ElementsPredicted change to status elements (green = none, amber = possibly, red = likely)Predicted change to status elements (green = none, amber = possibly, red = likely)Predicted change to status elements (green = none, amber = possibly, red = likely)Proposed Development Overall Impact with mitgation measuresWFD StatusMitigation MeasuresConstruction: The project-specific CEMP includes robust mitigation measures to protect the hydrological environment. The CEMP sets out requirements and standards which must be met during the construction stage and includes relevant mitigation measures outlined in the EIA Report and any subsequent conditions provided in planning for water protection. These include management of soils, re-fuelling machinery and chemical handling and control of water during the construction phase.Operation: The proposed development is designed to ensure the protection of the hydrological environment. In order to limit the surface water discharge from the site, greenfield rates are applied and to ensure improvement in the overall surface water quality before ultimate discharge the principles of Sustainable Drainage Systems, (SuDS) are implemented throughout the site. Majority of the surface water will be reused on site. Any discharge which will occur from site is through a water treatment system. Site will acquire an EPA IED Licence and monitoring of all containment measures will be undertaken as part of an EPA licence. The licence includes conditions to protect water quality discharge to ensure no impact on water body status.DROMORE_070 (European Code: IE: IE_NW_36D020700)DROMORE_080 (European Code: IE_NW_36D020900)Drumgole (European Code: IE_NW_36_415)RECEIVED: 28/08/2026 GroundwaterScheme ElementsPhase (Construction/ Operation)Construction Construction Operation Operation Identified Quantitative ImpactsIncreased run-off and sediment loadingPollution due to accidential discharges or spillages during the construction phaseIncrease in HardstandingAccidental Leaks and DischargesSaline or other intrusions.To identify groundwater bodies where the intrusion of poor quality water as a result of groundwater abstraction is leading to sustained upward trends in pollutant concentrations or significant impact on one or more groundwater abstractions.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No anticipated impacts to the hydrologeological environment with no deterioration to the WFD StatusSurface water.To assess the impact of groundwater abstractions on the ecological status of surface water bodies.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No anticipated impacts to the hydrologeological environment with no deterioration to the WFD StatusGroundwater Dependent TerrestrialEcosystems (GWDTE's)To assess the impact of groundwater abstractions on the condition of GWDTE'S.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No anticipated impacts to the hydrologeological environment with no deterioration to the WFD StatusWater balanceTo identify groundwater bodies where abstractions exceed the available resource.Not Applicable (No dewatering anticipated)Not Applicable (No dewatering anticipated)No measurable change anticipated.No measurable change anticipated.No anticipated impacts to the hydrologeological environment with no deterioration to the WFD StatusSaline or other intrusions.To identify groundwater bodies where the intrusion of poor quality water as a result of groundwater abstraction is leading to sustained upward trends in pollutant concentrations or significant impact on one or more groundwater abstractions.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No anticipated impacts to the hydrologeological environment with no deterioration to the WFD StatusSurface water.To assess the impact of groundwater abstractions on the ecological status of surface water bodies.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No anticipated impacts to the hydrologeological environment with no deterioration to the WFD StatusGroundwater Dependent TerrestrialEcosystems (GWDTE's)To assess the impact of nutrient concentrations in groundwater (primarily phosphates) on GWDTE's.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No anticipated impacts to the hydrologeological environment with no deterioration to the WFD StatusDrinking Water Protected Areas (DrWPAs)To identify groundwater bodies failing to meet the DrWPA objectives defined in Article 7 of the WFD or at risk of failing in the future.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No anticipated impacts to the hydrologeological environment with no deterioration to the WFD StatusGeneral quality assessmentTo identify groundwater bodies where widespread deterioration in quality has or will compromise the strategic use of groundwater.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No measurable change anticipated.No anticipated impacts to the hydrologeological environment with no deterioration to the WFD StatusChemical ElementsPredicted change to status elements (green = none, amber = possibly, red = likely)Risk screening of potential to cause deterioration of current WFD statusProposed Development Overall ImpactQuantitative ElementsPredicted change to status elements (green = none, amber = possibly, red = likely)Mitigation MeasuresConstruction: The project-specific CEMP includes robust mitigation measures to protect the underlying hydrogeological environment. The CEMP will be a live document during the works. It sets out requirements and standards which must be met during the construction stage anand includes the relevant mitigation measures outlined in the EIA Report and any subsequent planning conditions. Mitigation measures for protection of water quality include a soil management, re-fuelling machinery and chemical handling and control of water during the construction phase. No signficant dewatering is required and as such there is no negative impact on quantitative status.Operation: The proposed development is designed to ensure the protection of the underlyinghydrogeological environment based on bulk fuel storage in bunded areas and no proposed discharges to groundwater. Majority of surface water is captured on site and reused for AD process. All discharges will be to the drainage ditches. However, all surface water captured on are treated prior to reuse and discharge off site. So any surface and groundwater interaction will not result in the detoriation of the WFD status of Cavan GWB. The proposed groundwater abstraction to maminum of 45m3/day will not cause any detoriation to the WFD quantitative status of the GWB based on the abstraction demand and the size of the GWB due to over abstraction.Cavan GWB (European Code: IE_NW_G_061)RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 8-33 RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 8-34 APPENDIX B. APPENDIX B WATER FRAMEWORK DIRECTIVE ASSESSMENT MATRIX 1.1 Background to Surface Water Body Status & Groundwater Body Status Under the WFD, surface water body status is classified on the basis of chemical and ecological status or potential. Ecological status is assigned to surface water bodies that are natural and considered by the EPA not to have been significantly modified for anthropogenic purposes (i.e., culverting). Ecological potential is assigned to artificial and man-made water bodies (such as canals), or natural water bodies that have undergone significant modification. The term ‘ecological potential’ is used as it may be impossible to achieve good ecological status because of modification for a specific use, such as navigation or flood protection. The ecological potential represents the degree to which the quality of the water body approaches the maximum it could achieve. The worst-case classification is assigned as the overall surface water body status, in a ‘one-out all-out’ system (i.e., by taking the worst case of all the combined risk outcomes). This system is summarised below in Figure 1. Figure 1. WFD classification elements for surface water body status (Environmental Agency, 2015) 1.1.2 Chemical Status Chemical status is defined by compliance with environmental standards for chemicals that are priority substances and/or priority hazardous substances, in accordance with the Environmental Quality Standards Directive (2008/105/EC). This is assigned on a scale of good or fail. Surface water bodies are RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 8-35 only monitored for priority substances where there are known discharges of these pollutants; otherwise, surface water bodies are reported as being at good chemical status. 1.1.3 Ecological Status Ecological status or potential is defined by the overall health or condition of the watercourse. This is assigned on a scale of High, Good, Moderate, Poor or Bad, and on the basis of four classification elements or ‘tests’, as follows: • Biological: This test is designed to assess the status indicated by a biological quality element such as the abundance of fish, invertebrates or algae and by the presence of invasive species. The biological quality elements can influence an overall water body status from Bad through to High. • Physico-chemical: This test is designed to assess compliance with environmental standards for supporting physicochemical conditions, such as dissolved oxygen, phosphorus and ammonia. The physicochemical elements can only influence an overall water body status from Moderate through to High. • Specific pollutants: This test is designed to assess compliance with environmental standards for concentrations of specific pollutants, such as zinc, cypermethrin or arsenic. As with the physico- chemical test, the specific pollutant assessment can only influence an overall water body status from Moderate through to High. • Hydromorphology: For natural waterbodies, this test is undertaken when the biological and physicochemical tests indicate that a water body may be of High status. It specifically assesses elements such as water flow, sediment composition and movement, continuity, and structure of the habitat against reference or ‘largely undisturbed’ conditions. If the hydromorphological elements do not support High status, then the status of the water body is limited to Good overall status. For artificial or highly modified waterbodies, hydromorphological elements are assessed initially to determine which of the biological and physico-chemical elements should be used in the classification of ecological potential. In all cases, assessment of baseline hydromorphological conditions are an important factor in determining possible reasons for classifying biological and physicochemical elements of a water body as less than Good, and hence in determining what mitigation measures may be required to address these failing water bodies. 1.2 Background to Groundwater Body Status Under the WFD, groundwater body status is classified on the basis of quantitative and chemical status. Status is assessed primarily using data collected from the EPA monitoring network; therefore, the scale of assessment means that groundwater status is mainly influenced by larger scale effects such as significant abstraction or widespread/ diffuse pollution. The worst-case classification is assigned as the overall groundwater body status, in a ‘one-out all-out’ system. This system is summarised in Figure 2 below. 1.2.1 Quantitative Status Quantitative status is defined by the quantity of groundwater available as baseflow to watercourses and water-dependent ecosystems, and as ‘resource’ available for use as drinking water and other consumptive purposes. This is assigned on a scale of Good or Poor, and on the basis of four classification elements or ‘tests’ as follows: • Saline or other intrusions: This test is designed to identify groundwater bodies where the intrusion of poor quality water, such as saline water or water of different chemical composition, as a result of groundwater abstraction is leading to sustained upward trends in pollutant concentrations or significant impact on one or more groundwater abstractions. • Surface water: This test is designed to identify groundwater bodies where groundwater abstraction is leading to a significant diminution of the ecological status of associated surface water bodies. RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 8-36 • Groundwater Dependent Terrestrial Ecosystems (GWDTEs): This test is designed to identify groundwater bodies where groundwater abstraction is leading to “significant damage” to associated GWDTEs (with respect to water quantity). • Water balance: This test is designed to identify groundwater bodies where groundwater abstraction exceeds the “available groundwater resource”, defined as the rate of overall recharge to the groundwater body itself, as well as the rate of flow required to meet the ecological needs of associated surface water bodies and GWDTEs. 1.2.2 Chemical Status Chemical status is defined by the concentrations of a range of key pollutants, by the quality of groundwater feeding into watercourses and water-dependent ecosystems and by the quality of groundwater available for drinking water purposes. This is assigned on a scale of Good or Poor, and on the basis of five classification elements or ‘tests’ as follows: • Saline or other intrusions: This test is designed to identify groundwater bodies where the intrusion of poor-quality water, such as saline water or water of different chemical composition, as a result of groundwater abstraction is leading to sustained upward trends in pollutant concentrations or significant impact on one or more groundwater abstractions. • Surface water: This test is designed to identify groundwater bodies where groundwater abstraction is leading to a significant diminution of the chemical status of associated surface water bodies. • GWDTEs: This test is designed to identify groundwater bodies where groundwater abstraction is leading to “significant damage” to associated GWDTE’s (with respect to water quality). • Drinking Water Protected Areas (DrWPAs): This test is designed to identify groundwater bodies failing to meet the DrWPA objectives defined in Article 7 of the WFD or at risk of failing in the future. • General quality assessment: This test is designed to identify groundwater bodies where widespread deterioration in quality has or will compromise the strategic use of groundwater. Figure 2. WFD classification elements for groundwater body status (Environmental Agency, 2015) RECEIVED: 28/08/2026 Monaghan Renewable Biogas Plant / 257501.0350 AWN Consulting Ltd 8-37 RECEIVED: 28/08/2026 AUGUST 2026 VOLUME III APPENDICES TO ENVIRONMENTAL IMPACT ASSESSMENT REPORT APPENDIX 10.4 GROUNDWATER ABSTRACTION FEASIBILITY ASSESSMENT Stream BioEnergy Ireland Limited RECEIVED: 28/08/2026 RE Groundwater Abstraction Feasibility Assessment Anaerobic Digestor at Maghernakelly, Co. Monaghan CLIENT Stream Bio Energy DOCUMENT REFERENCE 247501.0350 DATE 21 November 2025 AWN Consulting Ltd, The Tecpro Building, IDA Business & Technology Park, Clonshaugh, Dublin 17, D17 XD90 REPORT RECEIVED: 28/08/2026 DOCUMENT CONTROL SHEET Document Control Sheet Our Reference 247501.0350 Original Issue Date 21 November 2025 Client: Stream Bio Energy Client Address: Revision Revision Date Description Details Written by Approved by Signature Name Rashaqat Ali Siddiqui Teri Hayes Title Environmental Consultants Director Date 21 November 2025 Disclaimer This report considers the specific instructions and requirements of our client. It is not intended for third-party use or reliance, and no responsibility is accepted for any third party. The provisions in this report apply solely to this project and should not be assumed applicable to other developments without review and modification. RECEIVED: 28/08/2026 Stream Bio Energy / 247501.0350 AWN Consulting Ltd TABLE OF CONTENTS 1. INTRODUCTION 1 1.1 Background ..............................................................................................................1 1.1.1 Proposed Development .......................................................................................... 1 1.2 Objective of the Report ............................................................................................2 1.2.1 Sources of Information .......................................................................................... 2 2. HYDROLOGICAL SETTING 4 2.1 Geological Setting ....................................................................................................5 2.2 Hydrogeological Setting ...........................................................................................5 2.2.1 Aquifer Classification & Groundwater Body Characteristics ......................................... 5 2.2.2 Aquifer Vulnerability .............................................................................................. 6 2.2.3 Known Yields Water Supply Data ............................................................................ 8 2.2.4 Water Quality ..................................................................................................... 12 3. CONCLUSIONS 13 3.1 Summary of Hydrogeological Setting ..................................................................... 13 LIST OF FIGURES Figure 1-1. Site Location Map 1 Figure 2-1. Aquifer Classification 6 Figure 2-2. Regional Recharge Map 8 Figure 2-3. Well Productivities in the Ordovician aquifers (CGSP, 2008) 9 Figure 2-4. Groundwater wells within Red Island Formation 10 LIST OF TABLES Table 1-1. Vulnerability Mapping Guidelines (Source: DoELG, EPA, GSI, 1999) 7 Table 2-2. GSI Well Card Index 10 RECEIVED: 28/08/2026 Stream Bio Energy / 247501.0350 AWN Consulting Ltd 1 1. INTRODUCTION 1.1 Background AWN have been requested by Stream Bioenergy to carry out a Desktop Groundwater Abstraction Feasibility Assessment for a proposed development of a Renewable Biogas Plant at Maghernakelly, Drum, Co. Monaghan. The site of the Proposed Development is located in Maghernakelly, Drum, Co. Monaghan, covering a total area of approximately 6.2 hectares as shown in Figure 1.1. It is c.4km north of Cootehill and 17.5km southwest of Monaghan town. The site is currently a greenfield site. Currently, the lands are undeveloped and entirely unoccupied by any building structures. The site is comprised of two fields which are divided by tree lined hedgerows and drainage ditches, with gated field accesses from the adjacent public roads. It is bounded to the north by L2280 Drumcall Road, to the east by the R189 regional road, and to the west by Maghernakelly Road. To the south, the site adjoins New Park Farma farmyard and an existing residential property. The site is undulating with substantial elevation change from approximately 109mOD in the southern section to around 93mOD at the northern boundary. Overhead power lines traverse the site from east to west. Figure 1-1. Site Location Map 1.1.1 Proposed Development The Proposed Development comprises a renewable biogas plant designed to process up to 99,000 tonnes per annum of organic feedstock, consisting predominantly of poultry manure, with smaller proportions of cattle slurry and agri-food organic wastes. The facility will generate biogas through anaerobic digestion, RECEIVED: 28/08/2026 Stream Bio Energy / 247501.0350 AWN Consulting Ltd 2 upgrade it to biomethane for injection into the national gas grid, and produce digestate outputs for reuse in accordance with regulatory requirements. Water demand for the facility will be met through a combination of sources, including installation of an on-site groundwater well, supplemented by process-generated liquid streams and other backup supply options as required. 1.2 Objective of the Report The scope of work for this study has the following primary objective: Identify from available information, potential groundwater yields on the site. The following key areas were identified as requiring review within the desk study, in order to develop an understanding of likely yields: • Assess the groundwater resources available for development within the defined study area with particular focus on the principal aquifer units and known well yield data. • Review of sustainable yields from available field test data in order to confirm the estimated ‘sustainable yield’. • Assessment of recharge based on meteorological data, aquifer vulnerability, and subsoil properties. • Identification of any constraints to sustainable abstraction. 1.2.1 Sources of Information Reference is made in this report to information from a number of existing data sources and reports including the following: • Geology and hydrogeology, and drainage (including both quaternary deposits and bedrock geology and associated hydrogeological data) within the local area, together with data on the hydrological environment. Sources include Geological Survey of Ireland (GSI) www.gsi.ie mapping databases (geotechnical data sets, karst features and borehole data), • National Parks & Wildlife Service (NPWS): On-line data resources available at http://webgis.npws.ie/npwsviewer/, and • Environmental Protection Agency (EPA) on-line resources http://gis.epa.ie/Envision/. The projected water requirements in terms of yield and quality, and daily usage trends, is discussed as part of a feasibility assessment which also outlines the following: • Summary of geology and hydrogeology; and • Summary of likely well yield and water quality (based on desk study information). With regard to the proposed trial borehole locations for site-specific sustainable yield assessment, these investigations will be subject to detailed site assessment at the post-planning stage. This approach reflects the exceptional cost associated with drilling and testing exploratory groundwater wells, which, for a project of this scale and nature, can only be reasonably undertaken once planning permission has been secured. RECEIVED: 28/08/2026 Stream Bio Energy / 247501.0350 AWN Consulting Ltd 3 The assessment will give due consideration to the findings of this study, the identification of on -site hazards, areas of resource demand, and the practical requirements for safe access by drilling equipment. RECEIVED: 28/08/2026 Stream Bio Energy / 247501.0350 AWN Consulting Ltd 4 2. HYDROLOGICAL SETTING The Proposed Development site is located within the Erne WFD Catchment (Catchment ID: 36) and the Dromore_sc_20 WFD sub-catchment (Dromore 60 WFD River Sub Basin; EPA, 2025). A field drain runs along the perimeter of the site. A site walkover was carried out on 1st October 2024 by AWN Hydrogeologist to establish site conditions. During the walkover it was identified that the site elevation substantially decreases from south to north. Two field drains were noted along the western and eastern boundary flowing in a northernly direction and discharging into an existing drain on the northern boundary of the site parallel to L2280. The drain was observed to have very low volume with areas of dry drain, making it difficult to confirm flow direction. However, based on the local topography and on site observations it was determined that the drainage ditch discharges via a culvert under the R189 into another drainage ditch, which is hydrologically connected to the Coolkill Lough Stream (EPA Code: IE_NW_36D020700), located approximately 350 metres east of the proposed development, which subsequently discharges into Coolkill Lough. The Rockcorry Stream (EPA Code: IE_NW_36D020700) originates from Coolkill Lough and flows in a north westerly direction before passing through Drumgole Lough (EPA Code: IE_NW_36_415). It then continues in a southerly direction before ultimately discharging into the Dromore River (EPA Code: IE_NW_36D020900), approximately 3 km from the proposed development site. According to EPA mapping (see Figure 6-3), no watercourses traverse the proposed development site. In relation to the Proposed Development site, the nearest (active) surface waterbody EPA monitoring station is: ‘Br.W. of Clementstown’ (StationCode: RS36D020700) which is located in the DROMORE_070 waterbody adjacent to Cootehill town c. 3.5km birds eye distance of the proposed development site. The most recent water quality status recorded by the EPA (2022) at this monitoring station (EPA Code: RS36D020700) is classified as Q3 Poor, which denotes moderately polluted waterbody. This Value is based primarily on the relative proportions of pollution sensitive to tolerant macroinvertebrates (the young stages of insects primarily but also snails, worms, shrimps etc.) resident at a river site. The EPA has confirmed that the significant pressures for this waterbody are associated with agriculture, anthropogenic and, urban wastewater. According to EPA (2025), Coolkill Lough stream has a WFD status (2019-2024) of ‘Poor’ and a WFD risk score of ‘At Risk of Not achieving Good Status’ by 2027. DROMORE_070 waterbody (EPA Code: IE_NW_36D020900) is currently classified a by the EPA as having ‘Poor’ WFD water quality status (2016- 2021 period) and is ‘At Risk of Not achieving Good Status’. This ‘Poor’ status assigned to the Coolkill Lough stream and Dromore_70 is due to its poor biological (invertebrate) status or potential. According to the NPWS (2025) on-line database there are no special protected areas within, adjacent to or in the immediate vicinity of the subject development site. The development site is not located within or directly adjacent to any Natura 2000 site. The closest European listed sites are as follows: ► Drumgole Lough pNHA ((Site Code 001601) c. 930m North ► Dromore Lakes pNHA (Site Code 000001) c.2km north; ► Kilroosky Lough Cluster SAC (Site Code 001786) c.12km north west; ► Lough Oughter and Associated Loughs SAC (Site Code: 000007) c.14km west. According to NPWS (2025), there are no NPWS protected areas in the vicinity of the Proposed Development site. The nearest Natura 2000 Site is Kilroosky Lough Cluster SAC (Site code: 001786) located circa 12km north of the proposed development. The development site has no hydrological connection with this SAC. RECEIVED: 28/08/2026 Stream Bio Energy / 247501.0350 AWN Consulting Ltd 5 The site does have an indirect hydrological connection to the Drumgole pNHA (c. 9km Hydrological distance and Lough Oughter and Associated Loughs SAC (c. 38km hydrological distance). However, the connection is a long hydrological pathway allowing significant time for settlement and dilution and as such there is no potential for change in water quality of this receiving habitat. 2.1 Geological Setting According to GSI (2025), quaternary sediments in the site indicates the principal subsoil type in the area comprises of till derived from tills derived from Paleozoic Sandstones and Shales which are of low permeability, there is a small region of Alluvium sediments in the northern section of the proposed site boundary. The GSI classifies the bedrock beneath the site and the surrounding area as dominated by Greywacke, microconglomerate & argillite. The bedrock underlying the site is part of the Red Island Formation and made up of Greywacke, shale, sandstone & conglomerate. The lithological description comprises Green to greenish-grey medium or coarse grained, locally conglomeratic, volcaniclastic greywacke. 2.2 Hydrogeological Setting 2.2.1 Aquifer Classification & Groundwater Body Characteristics The GSI has devised a system for classifying the bedrock aquifers in Ireland. The aquifer classification for bedrock depends on a number of parameters including, the area extent of the aquifer (km2), well yield (m3/d), specific capacity (m3/d/m) and groundwater transmissivity (mm3/d). There are three main classifications: regionally important, locally important and poor aquifers. Where an aquifer has been classified as regionally important, it is further subdivided according to the main groundwater flow regime within it. This sub-division includes regionally important fissured aquifers (Rf) and regionally important karstified aquifers (Rk). Locally important aquifers are sub-divided into those that are generally moderately productive (Lm) and those that are generally moderately productive only in local zones (Ll). Similarly, poor aquifers are classed as either generally unproductive except for local zones (Pl) or generally unproductive (Pu). The GSI (2025) classifies the principal aquifer types in Ireland as: Bedrock Aquifer ► Rkc – Regionally Important Aquifer – Karstified (conduit) ► Rkd – Regionally Important Aquifer – Karstified (diffuse) ► RK – Regionally Important Aquifer – Karstified ► Rf – Regionally Important Aquifer – Fissured bedrock ► Lm – Locally Important Aquifer – Bedrock which is Generally Moderately Productive ► Lk – Locally Important Aquifer – Karstified ► LI – Locally Important Aquifer – Bedrock which is Moderately Productive only in Local Zones ► PI – Poor Aquifer – Bedrock which is Generally Unproductive except for Local Zones ► PU – Poor Aquifer – Bedrock which is Generally Unproductive Gravel Aquifer ► Lg - Locally Important Aquifer - Sand & Gravel ► Rg - Regionally Important Aquifer - Sand & Gravel The site is underlain by Cavan Groundwater Body (GWB) EPA Code: IE_NW_G_061. According to GSI (2025), the bedrock aquifer underlying the Proposed Development site is classified as a Poor Aquifer (PI), i.e. Bedrock which is Generally Unproductive except for Local Zones as presented in Figure 2-1. The GSI RECEIVED: 28/08/2026 Stream Bio Energy / 247501.0350 AWN Consulting Ltd 6 database does not presently indicate the presence of karst features in the vicinity of the site. The nature of the Greywacke and Sandstones in Red Island Formation would also not tend to be karstified. Figure 2-1. Aquifer Classification In general, transmissivity rates (the rate at which water travels through a unit mass of rock) in these rock units are likely to be low (less than 20m2/day) (GSI, 2004). However, higher values may be achieved in faulted zones, especially in the coarser-grained rocks, which may be exemplified by the ‘excellent’ and ‘good’ yields. The available specific dry weather flows are low, ranging from 0.01-0.55 l/s/km2 suggesting that these aquifers do not make a significant baseflow contribution to streamflow. Storativity is also expected to be low. The GWB is predominantly covered by till subsoil (71%), with a smaller proportion of peat (9%) and approximately 10% of the body is mapped as rock outcrop/shallow subsoil. In the absence of inter-granular permeability, groundwater flow is expected to be concentrated in fractured and weathered zones and in the vicinity of fault zones. Available groundwater levels are mainly 0-10 m below ground level (60% <3 mbgl). Flow paths are likely to be short (30-300 m) with groundwater discharging rapidly to nearby lakes, streams and small springs. There are observed deeper water strikes, indicating that there is a component of deep groundwater flow, however shallow groundwater flow is dominant throughout the GWB. Groundwater flow directions are expected to follow topography – overall in a northerly direction. 2.2.2 Aquifer Vulnerability Aquifer vulnerability is a term used to represent the intrinsic geological and hydrological characteristics that determine the ease with which groundwater may be contaminated generally by human activities. Due to the nature of the flow of groundwater through bedrock in Ireland, which is almost completely through fissures, the main feature that protects groundwater from contamination, and therefore the most RECEIVED: 28/08/2026 Stream Bio Energy / 247501.0350 AWN Consulting Ltd 7 important feature in protection of groundwater, is the subsoil (which can consist solely or of mixtures of, peat, sand, gravel, glacial till, clays or silts). The vulnerability assessment is categorised as shown in Table 1 below. Table 2-1. Vulnerability Mapping Guidelines (Source: DoELG, EPA, GSI, 1999) Vulnerability Rating Hydrogeological Condition Subsoil Permeability (type) and Thickness Unsaturated Zone Karst Features High Permeability (sand/ gravel) Moderate Permeability (e.g. sandy subsoil) Low Permeability (e.g. clayey subsoil, clay, peat) (Sand / gravel aquifers only) (<30 m radius) Extreme (E) 0 – 3 m 0 – 3 m 0 – 3 m 0 – 3 m - High (H) >3 m 3 – 10 m 3 – 5 m >3 m n/a Moderate (M) n/a >10 m 5 – 10 m n/a n/a Low (L) n/a n/a >10 m n/a n/a Notes: (1) n/a: Not applicable (2) Precises permeability values cannot be given at present (3) Release point of contaminants is assumed to be 1 – 2 m below ground surface According to GSI regional mapping, the groundwater vulnerability rating is classified as ‘Low’ for the s ite. Based on the description of the subsoils, Low vulnerability indicates an overburden depth of more than 10m underlying the site. The recharge within this GBW occur via rainfall which infiltrates through area of shallow and more permeable soil cover and outcrops. Due to areas of low permeability subsoils, a high proportion of the available recharge will discharge to the streams in the GWB. In addition, the steep drumlin slopes will promote surface runoff. Desktop review of GSI recharge map indicates that the average annual recharge is 43mm/year in the vicinity of the proposed development as presented in Figure 2-2. RECEIVED: 28/08/2026 Stream Bio Energy / 247501.0350 AWN Consulting Ltd 8 Figure 2-2. Regional Recharge Map 2.2.3 Known Yields Water Supply Data 2.2.3.1 Groundwater Source Protection Zones There are no GSI or EPA groundwater source protection zones in the immediate vicinity of the site (GSI, 2025). The nearest Public Supply Source Protection area is Clones Scotshouse PWS (IE_GSI_SPA_90) located c. 10km west of the site. The PWS is located in the Cooldaragh formation which is comprised of Silty Mudstone. Cavan GWB: Lower Palaeozoic Rocks Cavan Groundwater Source Protection (CGSP) Report was consulted. This outlines that the Lower Palaeozoic (Ordovician and Silurian age) rocks in Cavan generally comprise sandstones and shales; Ordovician rocks tend to be shalier and also contain rocks of a volcanic origin. The Ordovician and Silurian age rocks in Co. Cavan are part of a larger area of these types of rocks, which is known as the Longford- Down Inlier (McConnell et al., 2001). In general, the rocks are characterised by low fissure permeability. Shaly layers within these rocks prevent clean fractures from opening up under tectonic pressure. Fractures can become filled with fault gouge, a clay material created by the disintegration of the rock material under tectonic forces. This material seals up fractures, restricting the flow of groundwater. The coarser, thicker sandstone units are likely to have a greater degree of fracturing than the more plastic interbedded shales. Brittle volcanic layers may also have a greater degree of fracturing. Permeabilities in the upper few metres of the surface weathered zone are often high although they decrease rapidly with depth. Results mainly from the drilling of private domestic wells or for small industrial companies have shown that local zones of higher RECEIVED: 28/08/2026 Stream Bio Energy / 247501.0350 AWN Consulting Ltd 9 permeability are present, indicated by the ‘high’ yields encountered. These yields are often associated with fractures and faults. It is not possible, given the present data, to delineate the areas of higher permeability within such formations. The GSI has developed the concept of ‘productivity’ as a semi-quantitative method of utilising limited well test data (Wright, 2000). A ‘borehole productivity index’ is assigned to a well from one of five classes: I (highest), II, III, IV, and V, using a graphical comparison of well discharge (Q) with specific capacity (Sc). Productivity and yield data were compiled and analysed within the county; the Ordovician aquifer occurs in. Seventeen wells had productivity values. There are no records of wells with class I, II or III productivities. According to GSI aquifer classification flowchart, commonly any aquifers which are classified as PI has the transmissivity of less than 50 and the productivity index is mostly IV and V with a rare occurrence of III. Figure 2-3. Well Productivities in the Ordovician aquifers (CGSP, 2008) Woods & Wright (2001) suggest that the groundwater levels in Ordovician rock units are variable but are usually less than 10 m below ground surface, and that the aquifers are generally unconfined. Although fractured, Ordovician and Silurian rocks generally have a low permeability and are mostly regarded as a poor aquifer. Such rocks will often yield enough water to a well to supply 18 to 43 m3/day and occasionally may achieve higher yields in major fracture zones. However, since the yields often depend on the permeability developed in the uppermost few meters of broken and weathered rock, the yields will often decrease markedly in dry spells as the water table falls. To overcome this, management of pumping is taken on site e.g. Dual pump installation with interim pumping during dry spells which will not have potential impact the quantitative status of the groundwater body. Well Search & Yields The GSI Well Card Index is a record of wells drilled in Ireland, water supply and site investigation boreholes. It is noted that this record is not comprehensive as under the European Union (Water Policy) (Abstractions Registration) Regulations 2018 (S.I. No. 261 of 2018), Water Environment (Abstractions and Associated Impoundments) Act 2022 and S.I. No. 419/2024 - Water Environment (Abstractions and Associated Impoundments) Regulations 2024 registration requirements, wells with abstraction volumes of 25m3/day and above are obligated to register with EPA. There are no groundwater wells registered with RECEIVED: 28/08/2026 Stream Bio Energy / 247501.0350 AWN Consulting Ltd 10 EPA in the vicinity of the proposed development. To establish a general yield within the Red Island Formation 71 wells were reviewed and are presented in Figure 2-4 and Table 2-2 show the surrounding wells (and yields) relative to the development. Based on the review of the yields provided in Table 2-2, it is safe to assume that there is a potential for 45m3/day yield with dual wells pumping to storage within this aquifer based on potentially encountering fracture systems during well drilling. Figure 2-4. Groundwater wells within Red Island Formation Table 2-2. GSI Well Card Index GSI Name Source Type Hole depth Bedrock Depth County Source Use Yield class Productivity Yield M3/d 2331SEW170 Borehole 109.7 25 Cavan Agricultural & domestic use Poor 28 2331SEW164 Borehole 42.7 0 Cavan Agricultural & domestic use Poor V 21.8 2331SEW160 Borehole 38.1 0 Cavan Unknown Moderate III 78.5 2331NEW169 Dug well 3.1 0 Monaghan Unknown Poor 21.8 2331NEW170 Dug well 1.8 0 Monaghan Unknown Poor 19.6 2331NEW171 Dug well 3.7 0 Monaghan Unknown Poor 15.3 2331NEW172 Dug well 5.5 0 Monaghan Unknown Poor 30.5 2331NEW173 Dug well 3.7 0 Monaghan Unknown 0 2331NEW174 Dug well 1.8 0 Monaghan Unknown Moderate 43.6 2331NEW175 Dug well 3.1 0 Monaghan Unknown Poor 21.8 RECEIVED: 28/08/2026 Stream Bio Energy / 247501.0350 AWN Consulting Ltd 11 GSI Name Source Type Hole depth Bedrock Depth County Source Use Yield class Productivity Yield M3/d 2331NEW176 Borehole 29.6 0 Monaghan Unknown Poor 38.2 2331NEW177 Borehole 29 0 Monaghan Unknown Excellent 436 2331SEW037 Borehole 21.3 21.3 Monaghan Unknown Moderate III 87.3 2331SEW044 Borehole 5.2 5.2 Monaghan Other 0 2331SEW045 Borehole 11 0 Monaghan Other 0 2331SEW046 Borehole 6.5 6.5 Monaghan Other 0 2331SEW016 Borehole 0 0 Monaghan Unknown Poor 25.9 2331SEW017 Borehole 0 0 Monaghan Unknown Poor 25.9 2331SEW018 Borehole 0 0 Monaghan Unknown Poor 25.9 2331SEW020 Borehole 53 30 Monaghan Unknown Failure 0 2331SEW021 Borehole 37 30 Monaghan Unknown Poor 8.6 2331SEW023 Borehole 30 0 Monaghan Unknown Good 172.8 2331SEW024 Borehole 60 18 Monaghan Unknown Moderate 51.8 2331SEW025 Borehole 56 21 Monaghan Unknown Poor 6.9 2331SEW026 Borehole 47 0 Monaghan Unknown Moderate 64.8 2331SEW051 Borehole 11.5 0 Monaghan Other 0 2331SEW052 Borehole 11.5 0 Monaghan Other 0 2331SEW171 Borehole 137.2 0 Monaghan Domestic use only Poor 16.4 2331NEW212 Borehole 11.5 0 Monaghan Other 0 2331SEW027 Borehole 52 0 Monaghan Unknown Moderate 86.4 2331SEW028 Borehole 45 0 Monaghan Unknown Poor 8.6 2331SEW029 Borehole 46 41 Monaghan Unknown Poor 34.6 2331SEW031 Dug well 1.8 0 Monaghan Unknown Poor 21.8 2331SEW032 Dug well 3.1 0 Monaghan Unknown Moderate 65.5 2331SEW033 Dug well 1.8 0 Monaghan Unknown Poor 30.5 2331SEW035 Dug well 2.4 0 Monaghan Unknown Moderate 54.5 2331SEW036 Dug well 2.4 0 Monaghan Unknown Moderate 43.6 2631SWW099 Borehole 68.6 39.6 Monaghan Domestic use only Poor 32.7 2631SWW103 Borehole 10.5 0 Monaghan Other 0 2631NWW058 Dug well 6.7 1.2 Monaghan Unknown Poor 10.9 2631NWW059 Borehole 30.5 0.7 Monaghan Unknown Poor 10.9 2631NWW061 Borehole 37.8 0 Monaghan Unknown Moderate 43.6 2631NWW062 Borehole 77.7 6.1 Monaghan Unknown Failure 1.1 2631NWW063 Dug well 4.3 0 Monaghan Unknown 0 2631NWW064 Borehole 24.4 0 Monaghan Industrial use Good 218 2631NWW065 Borehole 30.5 9.1 Monaghan Industrial use Good 196 2631NWW066 Dug well 6.1 1.8 Monaghan Unknown Poor 13.1 2631NWW067 Borehole 30.5 0.9 Monaghan Unknown Moderate 87.3 2631NWW068 Borehole 41.4 6.1 Monaghan Unknown Poor 26.2 2631NWW069 Borehole 30.5 3 Monaghan Unknown Good III 273 RECEIVED: 28/08/2026 Stream Bio Energy / 247501.0350 AWN Consulting Ltd 12 GSI Name Source Type Hole depth Bedrock Depth County Source Use Yield class Productivity Yield M3/d 2631NWW070 Dug well 7.3 0 Monaghan Unknown Poor 19.6 2631NWW071 Dug well 4 1.5 Monaghan Unknown Poor 8.2 2631NWW072 Dug well 3.1 1.2 Monaghan Unknown Poor 13.1 2631NWW076 Dug well 3.4 0 Monaghan Unknown Poor 29 2631NWW080 Dug well 3.2 1.8 Monaghan Unknown Poor 27.3 2631NWW025 Borehole 36.6 14.9 Monaghan Unknown Failure 1.6 2631NWW026 Borehole 24.4 0 Monaghan Unknown Poor 30.5 2631SWW001 Unknown 13 0 Monaghan Unknown Failure 0.9 2631SWW004 Unknown 0 0 Monaghan Unknown 0 2631NWW013 Dug well 2.4 0.6 Monaghan Unknown Poor 13.1 2631NWW034 Borehole 28 15 Monaghan Unknown Poor 17.3 2631NWW036 Borehole 75 0 Monaghan Unknown Good 190 2631NWW122 Borehole 10.2 0 Monaghan Other 0 2631SWW010 Borehole 29 0 Monaghan Unknown Poor 32.7 2631SWW015 Dug well 3.1 0 Monaghan Unknown Poor 21.8 2631SWW016 Borehole 27.4 0 Monaghan Unknown Poor 14.2 2631SWW017 Dug well 4.9 0 Monaghan Unknown Moderate 43.6 2631NWW087 Dug well 4.3 0.6 Monaghan Unknown Poor 10.9 2631NWW088 Borehole 32.9 0 Monaghan Unknown Poor 16.4 2331SEW022 Borehole 81 18 Monaghan Unknown Failure 0 2631NWW060 Dug well 3.7 0 Monaghan Unknown 0 2.2.4 Water Quality The groundwater body in the region of the site (Cavan GWB - European Code: IE_NW_G_061) for which the site is located entirely within, has a WFD status of “Good” (WFD Period: 2019 -2024) and a WFD risk score (3rd Cycle) of “Not at Risk” of not achieving good status. The objective is to protect the “Good status” and “not at risk” score by recognising that the quality of the groundwater could be at risk in the future due to point and diffuse sources of pollution. RECEIVED: 28/08/2026 Stream Bio Energy / 247501.0350 AWN Consulting Ltd 13 3. CONCLUSIONS 3.1 Summary of Hydrogeological Setting • Overburden depths are expected to be more than 10m based on groundwater vulnerability and subsoil type. This provides good protection to the underlying aquifer but also reduces recharge to the aquifer. • The site is underlain by Poor Aquifer (PI) which are generally Unproductive except for Local Zones forming part of Cavan GWB, which is classified as of ‘Good status’ under the WFD. • Well yield data for the area indicates variability within the aquifer. According to GSI PI aquifers can produce a yield of up to 100 m3/day. Based on review of Cavan and Monaghan Groundwater Source Protection report, the expected well yield within the Red Island Bedrock formation (which underlies this site area) is between 18 m3/day to 43 m3/day. However, fractures aquifer systems have a potential for producing much higher yields. • Based on the review of the yields provided in Table 2-2, it is safe to assume that there is a potential for 45m3/day yield with dual wells pumping to storage within this aquifer based on potentially encountering fracture systems during well drilling. • The aquifer is characterised by short flow paths which are not well connected. As such the zone of influence during pumping is likely to be local with minimal impact on nearby baseflow in rivers. RECEIVED: 28/08/2026