Biodiversity, Climate and Sustainability

Uimhir Thagarta Uathúil: 
WW-C2-274
Stádas: 
Submitted
Údar: 
West Wicklow Environmental Network
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Údar: 
West Wicklow Environmental Network

Litir Chumhdaigh

West Wicklow Environmental Network was established in August 2019 to provide a platform for individuals and groups throughout West Wicklow with a shared interest in protecting the environment, natural heritage, sustainable development and climate action to come together, communicate, share knowledge and experience, contribute towards policy change at local level and at government level, promote green events and create environmental awareness within West Wicklow. The network now has over 100 members and we have hosted 10 (check) public events (a mixture of physical and online events).

From West Wicklow Environmental Network's perspective there is a great deal to welcome in the draft County Development Plan 2022-2027, particularly the three cross-cutting themes that guide the plan – healthy placemaking, climate change and economic opportunity. However, we are concerned that the Tourism strategy is flawed in not sufficiently acknowledging the fragility of our natural amenities. In addition, we believe the plan should show a greater sense of urgency in relation to sustainable development and transport, land use management and nature-based responses to the climate emergency.

Tuairimí

Chapter 11 Tourism and Recreation

Section 11.1.1 notes that the National Planning Framework recognises that our coastal areas are also a key driver for Ireland’s tourism sector and advocates that such a remarkable but fragile resource needs to be managed carefully to sustain its character and attributes in physical, environmental quality and biodiversity terms. In the context of Wicklow’s County Development Plan the same consideration should be applied to the Wicklow Mountains.

West Wicklow Environmental Network is concerned that this chapter of the draft plan is built on flawed reasoning. It is simply not the case We have already proposed re-wording of SCO9 to place greater emphasis on the protection of natural, built and cultural heritage. West Wicklow Environmental Network is concerned that the Tourism objectives in the draft plan do not take account of the inherent fragility of our natural amenities. For example, where is evidence to support the statement in section 11.2 that Wicklow ‘has the capacity to become a year-round international outdoor activity destination’, or that Wicklow ‘has enormous untapped potential arising from its natural and built assets’ (11.1.4).

The Committee of West Wicklow Environmental Network met with the consultants working on the Glendalough and Wicklow Mountains Masterplan in March and made clear our view that Glendalough and the wider Wicklow Mountains National Park needs investment before it can sustain increased numbers. Presumably the Masterplan that is being developed will indicate what resources will be required to make outdoor recreation in Wicklow sustainable. The strategy needs to be greater than simply spreading people beyond Glendalough, as many other areas in the western part of the Wicklow Mountains are already displaying erosion from heavy footfall, evidence that current activity levels are beyond the natural carrying capacity of the land. The likely increase in extreme weather events due to climate change will exacerbate pressure on Wicklow’s trails and informal recreational routes in the uplands and other natural settings. There is need for strategic investment to manage the impact of current activity levels and to upgrade selected trails and hillwalking routes so that they have the capacity to carry increased numbers sustainably.

West Wicklow Environmental Network proposes the following changes to the wording of objectives in Chapter 11:

Tourism & Recreation Infrastructure

CPO 11.24 - To promote and facilitate improvements to tourism and recreation infrastructure within the County. The Planning Authority will favourably consider proposals for developments that place a particular emphasis on improving traffic flow, sign posting, car parking facilities and touring caravan facilities, service/rest facilities etc, subject to the proper planning and sustainable development of the area, and the objectives of this plan.

CPO 11.28 - To support tourist/visitor park and ride facilities at appropriate locations that will facilitate access to upland amenity areas as identified in the Glendalough and Wicklow Mountains National Park Masterplan or by the Wicklow Outdoor Recreation Committee.

Tourism & Recreation Themes and Products objectives:

Under CPO 11.37 please change ‘hill walking trails in West Wicklow’ to ‘Walking trails in West Wicklow’, as West Wicklow is very poorly served in terms of marked walking routes when compared with East Wicklow, and because hillwalking as an activity is based on informal routes, rather than defined trails.

In addition, please add the following:

The development of a series of community walking trails, in conjunction with local community groups and with the agreement of landowners.

Chapter 12 Sustainable Transportation

Ch12 Sustainable transportation

Section 12.1 mentions that the provision of walking and cycling routes within towns and between towns forms an essential part of a connected transport system. It is not clear how routes will be selected to be part of this connected transport system. West Wicklow Environmental Network encourages Wicklow County Council to work with community groups in deciding on routes.

Section 12.2 - West Wicklow Environmental Network welcomes the possible extension of the Luas to Blessington and seeks provision for feeder buses into Blessington to make it easier for people access public transport from Blessington into the city.  There is also a need for park and ride facilities in Blessington, which should be provided irrespective of the Luas project.

CPO 12.7 To facilitate the development of services and utilities for electric vehicles and alternative fuel vehicle types, including the roll-out of additional electric charging points in collaboration with relevant agencies at appropriate locations. West Wicklow Environmental Network seeks more specific commitments in relation to the roll-out of EV charging points, this is important in giving people the confidence to transition to electric vehicles.

CPO 12.8 – The number of EV points for non-residential should increase from one to two with ducting infrastructure for all spaces. This is on the basis that 30% car sales so far in 2021 have been hybrid or EV, and because the sale of new fossil fuel cars sales may be banned from 2030.

Chapter 13 Water Services

West Wicklow Environmental Network Management welcomes the focus on water quality and the conservation of water resources, however we would like to see a greater focus on nature-based solutions to address climate change and protect water quality.

West Wicklow Environmental Network seeks the addition of the following objective under Water Quality:

To provide practical support to communities concerned about invasive species along waterways. (West Wicklow Environmental Network has been highlighting concern about invasives in the Slaney at Baltinglass for over 18 months and the situation remains unaddressed. We have engaged with the LAWPRO Programme but it seems to require leadership at local level, if leadership came from the Council we believe that volunteers could be found in the local community to assist with the removal of invasive species).

 

In addition, we request the following change to CPO 13.6 - To encourage and promote the use of catchment-sensitive farming practices, including the avoidance of hill burning, in order to meet Water Framework Directive targets and comply with the River Basin Management Plan. (When land is burned, vegetation is lost, resulting in soil entering streams and rivers, thereby increasing water treatment costs).

Chapter 9 Economic Development

West Wicklow Environmental Network notes that Census 2016 revealed that almost 40% of the County’s working population (23,451) are travelling outside the County for work. There is likely to be continued home working as a legacy of Covid 19.

We propose amendments to wording of the following objectives in this chapter

The climate and biodiversity crises present new employment opportunities in the management of Wicklow’s natural resources, for the farming sector, in habitat management and within the forestry sector.

Peatlands are very significant carbon stores, however drained or damaged peatlands emit carbon. Peatland restoration is one of the key nature-based solutions to addressing our climate and biodiversity crises. Due to Wicklow’s extensive upland blanket bog, much of it in poor condition due to historic land use practices, there is scope for Wicklow to become a centre of excellence in peatland restoration. It is notable that Luggala Estate and Wicklow Mountains National Park are both currently commencing peatland restoration projects. To emphasise the importance of peatland restoration in the county, West Wicklow Environmental Network seeks an addition to CPO 9.21 as shown below:

Green Industry CPO 9.21 To encourage and facilitate the development of ‘green’ industries, including industries relating to renewable energy and energy-efficient technologies, waste recycling, and conservation, particularly nature-based solutions to climate change.

Wicklow has the largest proportion of forest cover by county, with almost 22% of Wicklow’s land area under tree cover, and most of this land in conifer plantation. As plantations in upland areas mature, there should be a shift from automatically replanting, to restoring areas of deep peat once felling has taken place. These forests require immediate action in the form of alternative management approaches if their peatland ecosystems are to be placed on a more sustainable footing. As site conditions vary, there should be a scientific, land use approach to identify the most sustainable option for the future management of each forest.

In keeping with Wicklow’s position as a ‘centre of excellence’ in forestry research and management (CPO 9.45) West Wicklow Environmental Network seeks the addition of a new objective in the forestry section of Chapter 9:

Ensure that forest management is based on a scientific, land use approach to identify the most sustainable option for the future management of each forest.

Finally, it is notable that there is no reference to circular economy enterprise opportunities in this chapter, this is something which should be allowed for, preferably with the addition of a new objective.

Chapter 7 Community Development

West Wicklow Environmental Network seeks the addition of ‘Community Trail’ under settlement levels 3 to 8 in in Table 7.1 Community Facilities Hierarchy Model.

Quality recreation opportunities close to home add to people’s health and well-being and reduce the need to travel by car for recreation activity. Gaining access to private land is the greatest constraint on the development of community trails. Where a community brings forward a proposal for a community walk, with the agreement of landowners, they should be supported to deliver the project.

This is in keeping with the objectives of the draft plan including Leisure & Recreation CPO 7.31 - Support the objectives of public health policy including Healthy Ireland and the National Physical Activity Plan.

Chapter 4 Settlement Strategy

West Wicklow Environmental Network questions the settlement targets in Table 3.6 which show a higher growth in open countryside than villages and small towns. This seems inconsistent with the commitment within the draft plan to sustainable growth, including CPO 4.11 below; there should be a greater focus on growth within villages and smaller settlements, rather than on facilitating additional one-off rural housing.

CPO 4.11 Strengthen the established structure of villages and smaller settlements both to support local economies and to accommodate additional population in a way that supports the viability of local infrastructure, businesses and services, such as schools and water services.

Chapter 2 Development Plan Strategy

West Wicklow Environment Network is largely welcoming of the Strategic County Outcomes, however we seek re-wording of the following objectives:

SCO3 Strong Rural Communities & Sustainable Rural Development, the addition of home working to read:

Strengthen rural communities and support the sustainable development of rural areas. Encourage home working, innovation and rural diversification in order to sustain vibrant rural communities. Leverage the potential of rural settlements to accommodate sustainable growth and a range of services including social and economic enterprise.

SCO7 Climate Resilience & the Transition to a Low Carbon Economy, the addition of nature-based solutions to read:

Support the transition to low carbon clean energy by facilitating renewable energy use and generation at appropriate locations and supporting the development of off-shore renewable energy enabling infrastructure especially at ports and harbours. Facilitate the sustainable management of waste including the circular economy. Restrict development in areas that are at risk of flooding and protect the natural landscape and biodiversity. Support nature-based solutions in response to the climate emergency, including the restoration of peatlands.

SCO9 Tourism, there is need to prioritise the protection of our tourism assets; please amend to the wording below:

Make the most of Wicklow’s location within Ireland’s Ancient East and facilitate a year-round tourism industry. Ensure that tourism development respects and protects the natural, built and cultural heritage assets it depends upon.

Chapter 15 Waste and Environmental Emissions

West Wicklow Environmental Network welcomes the inclusion of Light Pollution Objectives in the draft plan, from the perspectives of energy saving, biodiversity protection and human health. In pursuing these objectives, the Council should have regard to the Dark Sky Ireland guidelines.

In relation to CPO 15.5 (below) West Wicklow Environmental Network highlights its concern that Wicklow County Council’s recycling centres no longer take soft plastic. We understand this is due to contamination. In light of the need to improve waste recovery this situation should be revisited. Dun Laoghaire Rathdown Council takes clean, soft plastic packaging at Ballyogan, surely Wicklow County Council can do likewise?

CPO 15.5 - To have regard to the Council’s duty under the 1996 Waste Management Act (as amended), to provide and operate, or arrange for the provision and operation of, such facilities as may be necessary to promote reuse or for the recovery and disposal of household waste arising within its functional area.

Chapter 17 Natural Heritage and Biodiversity

The introduction to Chapter 17 states that ‘Protecting and enhancing biodiversity and landscapes is vital for the health, well-being and quality of life of communities today and will also be vitally important in the future in adapting to climate change.’ West Wicklow Environmental Network supports the sentiments in this statement, but we seek the amendment below as climate adaptation can no longer be a matter for future action.

Protecting and enhancing biodiversity and landscapes is vital for the health, well-being and quality of life of communities today and it has a vital role to play in our response to the climate emergency.

Under Water Systems please add the following objective:

To encourage nature-based solutions in response to the climate emergency, including the restoration of peatlands.

Faisnéis

Uimhir Thagarta Uathúil: 
WW-C2-274
Stádas: 
Submitted
Líon na ndoiciméad faoi cheangal: 
0
Teorainneacha Gafa ar an léarscáil: 
Níl