EPA Submission:

This submission provides a brief outline of the role and function of the EPA as an environmental authority and its approach to land use plans.  The EPAs guidance document ‘Strategic Environmental Assessment of Local Authority Land Use Plans – EPA Recommendations and Resources’ has been included with the submission.  Advice is also contained in the submission in respect of the fact that further modifications to the Draft Plan should be subject to the same method of assessment as originally applied in the ‘environmental assessment of the Draft Plan,’ as well as the requirement for the Planning Authority to prepare an SEA Statement once the Plan is adopted.

Chief Executive Recommendation No 8:

 Include the following recommendations of the SEA Environmental Report:

(8a)        To include the following before the final paragraph of Section 1.7 (Implementation and Monitoring) in Volume I of the Plan:

The Council shall, in conjunction with the Regional Assembly and other sources as relevant, implement the monitoring programme as set out in the SEA Environmental Report and Statement. This will include the preparation of stand-alone SEA Monitoring Reports:

To accompany the report required of the manager under section 15(2) of the Act, including information in relation to progress on, and the results of, monitoring the significant environmental effects of implementation of the development plan;

On the significant environmental effects of implementing the Plan, in advance of the beginning of the review of the next Plan.

(8b) Include the following before the final paragraph of Section 7.4 Road Transportation and Movement in Volume I of the Plan:

Where projects for new infrastructure, including green infrastructure, are not already provided for by existing plans / programmes or are not already permitted, then the feasibility of progressing these projects should be examined, taking into account planning need, environmental sensitivities as identified in the SEA Environmental Report and the objectives of the plan relating to sustainable mobility. A Corridor and Route Selection Process should be undertaken where appropriate, for relevant new road infrastructure in two stages: Stage 1 – Route Corridor Identification, Evaluation and Selection and Stage 2 – Route Identification, Evaluation and Selection.

(8c) Amend policy objective NH 10.5 (Volume I, Chapter 10) as set out below:

NH 10.5               

Ensure that no plans, programmes, etc. or projects are permitted that give rise to significant cumulative, direct, indirect or secondary impacts on the integrity of European Sites 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, (either individually or in combination with other plans, programmes, etc. or projects).

(8d) Amend policy objective NH 10.6 (Volume I, Chapter 10) as set out below:

NH 10.6

Ensure that any plan or project that could have a significant adverse impact (either alone or in combination with other plans and projects) upon the conservation objectives of any Natura 2000 Site or would result in the deterioration of any habitat or any species reliant on that habitat will not be permitted unless in exceptional circumstances.

(8e) To include the following at the end of the final paragraph of Section 10.7 (10.7 Woodlands, Trees and Hedgerows), Chapter 10, Volume I of the Plan:

The Habitats Directive provides a level of protection to Annex IV species, such as Bats and Otter. Proposed developments, including all proposals where woodland, tree or hedgerow removal is proposed, should be consistent with this.

(8f) Amend policy objective NH 10.13 (Volume I, Chapter 10) as set out below:

NH 10.13:

“Protect and enhance the valuable peatland resource in County Roscommon whilst protecting the heritage and environmental value of these peatland areas. The aims of the National Peatlands Strategy and the implementation of the National Raised Bog Special Areas of Conservation Management Plan 2017-2022 and the Enhanced Decommissioning Rehabilitation and Restoration Scheme will be supported.

(8g) Include the following at the end of the final paragraph of Section 10.8 (Peatlands) in Chapter 10, Volume I of the Plan:

Developments sited on peatlands have the potential to increase overall carbon losses, potentially undermining expected carbon savings (in the case of renewable energy developments) and damaging rare habitats of European importance. It is recommended that when developing project proposals for developments on peatlands, assessments are undertaken that consider peatland stability, carbon emissions balance and hydrology and ecology.

(8h) Include the following at the end of the final paragraph of Section 10.10 (Inland Waterways):

The Council shall be available to engage with the NPWS with the objective of facilitating the monitoring and surveying of wetland sites in Roscommon.†

And Include the following associated footnote:

† Consideration should be given to Inland Fisheries Ireland’s guidance document “Planning for watercourses in the urban environment” (2020).

(8i) Include the following policy objective after policy objective NH10.16 of Section 10.10 (Inland Waterways) in Chapter 10, Volume I of the Plan:

NH10.TBC

Support the sustainable development of the fisheries and aquaculture industry in co-operation with the Department of Agriculture, Food and the Marine and the Inland Fisheries Ireland.

(8j) Amend the following paragraph of Section 10.15 (Green Infrastructure Strategy) in Chapter 10, Volume I of the Plan:

The Green Infrastructure Strategy will include provisions for improved accessibility across the County through improved and connected walking and cycling routes whilst also ensuring adequate protection to the existing environment and ecology of the landscape. Proposed infrastructure should contribute towards the protection or enhancement of existing green infrastructure and have regard to the “Connecting with nature for health and wellbeing” EPA Research Report 2020. The Strategy will seek to ensure that areas and networks of green infrastructure are identified, protected, enhanced, managed and created to provide a wide range of environmental, social and economic benefits to communities.

(8k) Include the following at the end of the final paragraph of Section 12.3 (Chapter 12, Volume I), under the sub-heading ‘Pre-planning’:

Proposals for development should demonstrate compliance with the various written provisions of the Plan, as relevant, including those relating to environmental protection and management. Environmental considerations, such as those related to elevated levels of flood risk or ecological designations may limit the types of uses that may be possible at certain sites. Prospective applicants are encouraged to engage with the Planning Authority at the earliest opportunity to seek guidance as to the appropriateness of emerging proposals.

(8l) Include the following at the end of the final paragraph of Section 12.18 (Tourism and Recreation Facilities) of Chapter 12, Volume I of the Plan:

Proposed developments should seek to manage any increase in visitor numbers and/or any change in visitor behaviour in order to avoid significant environmental effects, including loss of habitat and disturbance. Proposals should also ensure that new projects and activities are a suitable distance from ecological sensitivities. Visitor/habitat management plans may be required. Considerations should include potential impacts on existing infrastructure (including drinking water, wastewater, waste and transport) resulting from tourism proposals.

(8m) Include the following at the end of the paragraph titled ‘Sustainable Design’ of Section 12.5 (Overarching Planning Principles) of Chapter 12, Volume I of the Plan:

Lighting fixtures should be designed so as to avoid creating glare and should have minimum environmental impact.

(8n) Include the following after the bullet points in the paragraph titled ‘Assessments Required’ of Section 12.5 (Overarching Planning Principles) in Chapter 12 of Volume I:

Proposals for development will be assessed in terms of potential impact on existing adjacent developments, existing land uses and/or the surrounding landscape. Where proposed developments would be likely to have a significant adverse effect on the amenities of the area through pollution by noise, fumes, odours, dust, grit or vibration, or cause pollution of air, water and/or soil, mitigation measures should be included in order to eliminate adverse environmental impacts or reduce them to an acceptable operating level. Proposals shall also ensure that investigations are carried out in relation to the nature and extent of any soil and groundwater contamination and the risks associated with site development work, where brownfield development is proposed.

The EPA’s publication Code of Practice: Environmental Risk Assessment for Unregulated Waste Disposal Sites (2007) shall be taken into account as relevant.

Chief Executive Recommendation No 9:

Update Section 9 of the SEA Environmental Report to reflect the final integration of recommendations into the Plan and reflect finalised policy objective numbers and sub-section locations of all recommendations.

On the PROPOSAL of Cllr. Keogh

SECONDED by Cllr. Fallon

It was AGREED to accept the Chief Executives recommendation No. 8 and recommendation No 9