17.4 Natural Heritage & Biodiversity Objectives
Only a small fraction of the targets under our National Biodiversity Action Plan have been completed, including critical action points such as developing management plans for our national park network.
Currently Ireland has the fifth lowest land under protection of all OECD countries and even then the review warned that, at present, Ireland offers little more than “paper protection” for these designated protected areas that are “supposed to be the national jewels in the crown of our land”. Instead, the forum’s review said, “they are inadequately managed and in poor condition, with few exceptions”.
Similarly Wicklow’s Biodiversity Action Plan is barely functioning as a plan for current action despite the council’s declaration of a Climate and Biodiversity Emergency.
Currently Wicklow has 15 SACs and 4 SPAs. It also has the Wicklow Mountains National Park and some Nature Reserves. But it does not have any NHAs yet. All biodiversity is in collapse, not just specific habitats or critically endangered key species. In fact in the last 3 decades the greatest decreases have been in what are viewed as 'common' species.
In relation to the areas that are already designated there are a number of issues:
- they are not properly managed, regulated, funded or protected
- their integrity is constantly being eroded by a variety of activity and actions which go unchallenged or resolved. When our most highly classified and designated sites cannot be properly protected it holds out little hope for addressing the WCC declared Biodiversity Emergency
- just focusing on keys sites creates islandisation and does not allow for movement of species and strengthening of gene pools
- focusing on key sites does not to address general biodiversity loss particularly of so-called 'common' species
- The National Park, our forests and designated areas are mainly seen by WCC as areas for human tourism, recreation etc and have become oversubscribed to various human recreational activities with little or no regulation. This has undermined and damaged the habitats and biodiversity within. To address this we need to have areas zoned for different recreational activities with strict rules that are enforced. And to have areas where no recreational activities are allowed.
Aside from the existing designated areas there is an urgent need for protection of general biodiversity where the largest declines have been happening. A lot of this has been driven in many ways by a dis-connect between the County Strategic Environmental Assessment and individual Environmental Impact Assessments. In general an individual EIA considers a small area and is based on a very short term, sometimes a one off or one season field visit. On this basis it may not reveal any designated protected species or habitats, nor does it take account of the number of individuals or biomass of 'common' species. When each of these developments go-ahead the impact on biodiversity and the natural environment is not measured or documented in a central location. The combined impact of developments has proved to be significant over the last 3 decades. There needs to be a measure of the cumulative impact of development on all aspects of the natural world.
This lack of protection can be easily addressed by actions such as:
- better rules, design, landscaping guidelines for developments i.e. inclusion of swift bricks, artificial House Martin nests, spaces for Bats to roost in all new buildings.
- living roofs and walls in new buildings
- more extensive and better natural landscaping around developments - native trees, shrubs, wildflowers, cover for animals, hedgerows, hedgehog highways between houses etc
- planning for hedgerows, trees, natural cover between all developments, urban areas linking out to the wider countryside
- the building of wildlife under and over passes at roads (a wildlife over pass at Glen of the Downs for example is urgently required to improve the value of the area to wildlife)
- the new County Development Plan to have a clear and measurable objective to create a network of wildlife corridors connecting all our protected sites, forests, wider countryside and urban areas together.
Wildlife corridors can be a mixture of hedgerows, treelines, riparian ways, wildflower verges, over and underpasses. This is vital to prevent islandisation of habitats and species. It will allow freedom of movement for wildlife, shelter and food. Of course this will lead to better, healthier genetic stock. It also creates a much more aesthetically pleasing and healthy environment for the human population
CPO 17.5 Projects giving rise to adverse effects on the integrity of European sites (cumulatively, directly or indirectly) arising from their size or scale, land take, proximity, resource requirements, emissions (disposal to land, water or air), transportation requirements, duration of construction, operation, decommissioning or from any other effects shall not be permitted on the basis of this plan11 .
The wording "adverse effects" leaves a lot of grey area open to interpretation. Given that we as a county and a nation have failed miserably to protect our biodiversity and natural environment, the minimum we should be doing is giving full unconditional protection our EU designated sites.
CPO 17.8 Ensure ecological impact assessment is carried out for any proposed development likely to have a significant impact on proposed Natural Heritage Areas (pNHAs), Natural Heritage Areas (NHAs), Statutory Nature Reserves, Refuges for Fauna, Annex I habitats, or rare and threatened species including those species protected by law and their habitats. Ensure appropriate avoidance and mitigation measures are incorporated into development proposals as part of any ecological impact assessment.
Again, all proposed developments for a pNHA or NHA (none of which exist yet in Co. Wicklow), should be subject to an EIA, not just those that are considered "likely to have a significant impact". That is too vague. Who dtermines what if the impact will be significant? That is the whole point of doing an EIA.
CPO 17.9 The Council recognises the natural heritage and amenity value of the Wicklow Mountains National Park and shall consult at all times with National Park management regarding any developments likely to impact upon the conservation value of the park, or on issues regarding visitor areas
In relation to WMNP (and other areas of the county) the levels of visitors and the activities they are partaking in is leading to further disturbance of wildlife, and eroding of habitats. There is no sustainability at the moment. If there was there would be a genuine recognition that there is a maximum limit to the number of visitors to these places and that activities have to be zoned and rules regulated and enforced (i.e. dedicated walking trails, dedicated bike trails, all dogs onlead). Off trail activities should be banned or only done with express advance permission and only for purposes of biodiversity recordeing etc. WCC need to stop just viewing our natural environment as a product to promote for economic gain or for human social benefits.
CPO 17.12 To protect non-designated sites from inappropriate development, ensuring that ecological impact assessment is carried out for any proposed development likely to have a significant impact on locally important natural habitats, species or wildlife corridors. Ensure appropriate avoidance and mitigation measures are incorporated into development proposals as part of any ecological impact assessment.
Biodiversity has collapsed to such an extent that all widlife and habitats are now important. It has been the cumulative losses through developments where it was deemed there were no impact to 'important' habitats or species that has contributed significantly to the collapse in our biodiversity, particularly populations of 'common' species.
Woodlands, Trees and Hedgerows
It is a shame that the pending Wicklow Tree Strategy was not adopted and referenced in this CDP. I would like to see this CDP amended to have a policy that the default position is that all trees 10 years old or older are fully protected and can only be considered for felling by application for a felling licence and only granted when there is no alternative but to fell. Mature trees offer huge biodiversity benefits and carbon storage services. Replacing a felled mature tree with a sapling is of realistic benefit in the timeframes we are now looking at to turn things around with regards to Biodiversity Loss and Climate Change.
As well as a policy to keep mature trees in the ground there should be a policy to create new areas of woodland consisting of native species. Ket targets and timelines for this new woodland creation should included in the CDP.
I would also recommend a policy objective within the CDP of phasing out non-native forestry within the county. It adds very little of biodiversity value, far less carbon storage than native trees and in many cases they have led to dmage to habitats through chemicals associated with this forestry and acidification of water courses.
CPO 17.18 To promote the preservation of trees, groups of trees or woodlands in particular native tree species, and those trees associated with demesne planting, in the interest of amenity or the environmental, as set out in Schedule 17.05 A and B, and Maps 17.05 and 17.05A - H of this plan.
Change this to read the preservation of all trees 10 years or over.
CPO 17.19 To consider the making of Tree Preservation Orders (TPOs) to protect trees and woodlands of high value, where it appears that they are in danger of being felled.
Replace the TPO process with a blanket protection of all mature trees. This is a far more appropriate approach given the emergencies we are faced with.
CPO 17.20 Development that requires the felling of mature trees of environmental and/or amenity value, even though they may not have a TPO in place, will be discouraged.
The language here is too weak and vague - "discouraged"
All trees have environmental value (even dead trees). Once again the starting point should be that all mature trees (10 years or older) are protected. If a tree is dead and a dnager then yes it may be felled are application for a felling licence has been approved. But in such a case the dead would should be left in situ, where it still has biodiversity and ecosystem value.
CPO 17.21 To discourage the felling of mature trees to facilitate development and encourage tree surgery rather than felling where possible.
Again the starting point should be that all mature trees are protected. Using the word "discourage" is weak and vague. It lacks any real committment particular given that WCC has declared a Climate and Biodiversity Emergency
CPO 17.22 To encourage the preservation and enhancement of native and semi-natural woodlands, groups of trees and individual trees, as part of the development management process, and require the planting of native broad leaved species, and species of local provenance in all new developments.
Again the wording is vague and meaningless - "encourage"
All mature trees and groups of trees should be preserved.
The requirement for planting of native broad leaved species in all new developments ahould be carefully monitored by WCC to ensure that this is done to maximise the biodiversity value of such planting. I would alos recommend that this be extended to make the planting of pocket forests a requirement in new developments.
CPO 17.23 To encourage the retention, wherever possible, of hedgerows and other distinctive boundary treatment in the County. Where removal of a hedgerow, stone wall or other distinctive boundary treatment is unavoidable, provision of the same type of boundary will be required of similar length and set back within the site in advance of the commencement of construction works on the site (unless otherwise agreed by the Planning Authority)
CPO 17.37 To resist development that would significantly or unnecessarily alter the natural landscape and topography, including land infilling / reclamation projects or projects involving significant landscape remodelling, unless it can be demonstrated that the development would enhance the landscape and / or not give rise to adverse impacts
Change wording from "To resist" to "To prevent". Resist is vague and meaningless.
Map No. 17.09B - Areas of Outstanding Natural Beauty (AONB) Landscape Categories
I propose that in relation to The Bray Mountains Group (3 - AONB) the SAOO covering Bray Head be extended to include all this mountains group, and further that the Bray Mountains Group become a Regional Park for the county. During the SRUNA project which eventually led to SAOO status being awarded to Bray Head, it was proposed at that stage that The Bray Mountains Group be formed into a Regional Park.