Agenda item

Pages 44 and 45: 9 (v) Leisure and Environment

The following summary of submission received was CONSIDERED:


“The submission by the Department of Culture, Heritage and the Gaeltacht suggests that ‘environment’ should be given greater prominence in Chapter 9 – Leisure and Environment. Submission notes that Section 9.1.7 deals with natural heritage and states the area is rich in fauna and flora, however no references are given to allow policy to be developed in relation to these natural heritage assets.


Comments that the Habitat Survey referred to in the SEA appears to be over 10 years old and that no protected mammal surveys (bats, otter, badger) appear to have been carried out. Seeks a commitment that habitat and protected mammal surveys of the Plan area will be carried out within the lifetime of the Plan.


Critical of three policies relating to Green Infrastructure which primarily address improving pedestrian and cycle links. While generally welcomed as a positive contribution towards sustainable travel in the Plan area it is important to differentiate between the primary function – the movement of people – and any secondary

benefits arising from the development and upgrading of the pedestrian/cycle network.


Submission notes that while pollinators are mentioned in the context of the proposed Masterplan for Jamestown Park, there appears to be no wider commitment within the LAP to manage lands in accordance with the All-Ireland Pollinator Plan 2015-2020.”


The following Response and Recommendation of the Executive was CONSIDERED:


“The submission does not appear to have recognised or acknowledged the context of the hierarchy of statutory spatial plans and that Local Area Plans are ‘subservient to’ and required to be fully consistent with the overarching ‘parent’ County Development Plan (CDP) – in this case the 2016-2022 DLR CDP.


Section 4.1 of the CDP – Landscape, Natural Heritage and Biodiversity contains 36 no. policy objectives, the majority of which are strategic, and consequently have County-wide application e.g. preservation of Landscape Character Areas, High Amenity Zones, Coastal Zone Management, Protection of Natural Heritage and Environment, Habitats Directive, Biodiversity Plans, Designated Sites, County-wide Ecological Network, Hedgerows etc. Section 4.2 contains a further 15 no. policies relating to open space and recreation. It is noted that the Department of Arts, Heritage and the Gaeltacht’s submission on the Draft CDP (March – May 2015) stated that, ‘The Department welcomes the strong policies in the Plan to protect natural heritage, protected sites and biodiversity’. It is thus considered that the Department’s comments are balanced by the significant number of environmental policies contained in the County Development Plan.


In relation to the request for a commitment to update Habitat Survey of the Plan area it is proposed the Draft Plan be amended to incorporate same.


The references to separating out the primary function and any potential secondary benefits arising from the introduction of both improved and new pedestrian cycle networks throughout the Plan area are acknowledged. While retaining the crossing points of the M50 within the final LAP (see Policy BELAP MOV12 – New Linkages), it is

proposed to remove Policy BELAP ENV 6 – M50 Crossings from the Section ‘Green Infrastructure’. It is proposed the Draft Plan be amended to reflect same.


In relation to pollinators the Council became an All-Ireland Pollinator Plan Partner in mid-March 2019. In becoming a Pollinator Plan Partner DLR agrees to support the ethos of the All-Ireland Pollinator Plan. DLR is currently rolling out – at a County-wide level – a suite of pollinator friendly actions including developing Nature Wildlife areas (of which there are three in the BELAP area), a ‘Slow to Mow’ campaign, improving wildlife corridors, reduction of chemical use for weed control, and requiring pollinator areas in emerging new developments. As the ethos of the All-Ireland Pollinator Plan is being rolled out across the entirety of DLR on a County-wide basis it is considered unnecessary to duplicate this support in finer-grain local plans and projects.



Amend the Draft Plan as follows:


Remove Policy BELAP ENV6 - M50 crossings (and alter subsequent policy numbering as appropriate)


Amend Policy BELAP ENV7 (now 6) – Routes through Parkland – as follows:


To improve, enhance and develop green pedestrian and cycle routes within and adjacent to parkland and amenity areas to create a network of green corridors across the Plan area.


Add new policy to Section 9.3.6 Environmental Protection Policy as follows:


Policy BELAP ENV13 – Habitats Survey: Planning applications for development in areas of environmental sensitivity will be required to provide an updated habitat and protected mammal survey.


The Executive’s Response and Recommendation on pages 44 and 45 was AGREED.