The declaration by government of a climate and biodiversity emergency was a reaction to the global decline in biological diversity. The National Biodiversity Action Plan 2017-2021 (NBAP) attempts to redress degradation of biodiversity nationally by requiring public authorities to mainstream biodiversity into decision making and to ensure conservation and restoration of biodiversity. A primary commitment in the NBAP is to move to a level of no net loss of biodiversity through implementation of actions including for mitigation measures. In order to protect the quality of the city’s open spaces and natural resources and to provide for their sustainable management and enhancement, they have been linked together into a green network.
While we agree with the above, we must ensure that habitat loss should be avoided at all costs as many of the habitats although some are classed as scrub are highly valuable to our city’s wildlife species and are historic in their nature as long-term habitats which are important for the continuation of a variety of species. Quite often we lose our blackthorns , our hazel woodlands as they are classed as scrub and not held in the high regard, they need to be held in.
These are established or potential amenity corridors facilitating non-motorised travel along linear routes (including rights of way), often with wildlife corridor importance along coastal areas, through woodlands and parks, river or canal corridors. Recreation and alternative circulation routes for pedestrians and cyclists
Greenways
Greenways should not impact on the existing users such as vulnerable users , families who go at a slow pace of life and where areas are set aside for biodiversity ,they must be recognised as slow zones if integrated into existing areas of mixed users. Greenways should not cause a negative impact on any biodiverse sites such as Merlin Woods
Policy 5.1 Green Network and Biodiversity
Support sustainable use and management of areas of ecological importance, parks and recreation amenity areas and facilities through an integrated green network policy approach in line with the Galway Recreation and Amenity Needs Study and where superseded by the Green Space Strategy, where it can be demonstrated that there will be no adverse impacts on the integrity of European sites.
Already sites are impacted so we must have some form of management plans that protects areas from trampling and allows for regeneration and rewilding of areas which were previously wild but now affected by overuse by people, these areas may need to be temporarily fenced off to allow recovery before it becomes uninhabitable for wildlife.
16 Promote the multi-use of indoor and outdoor (both private and public) recreation and leisure facilities and amenities to accommodate a diverse range of recreational needs.
5.3 Protected Spaces
The city has a diverse range of habitats and species of national and European importance which are protected by legislation. A key aspect of the plan is to ensure compliance with environmental legislation. Complementing this approach, the green network will seek to conserve and restore biodiversity, improve connectivity between habitats and reduce the effects of fragmentation which can lead to permanent loss of species.
And again: Already sites are impacted so we must have some form of management plans that protects areas from trampling and allows for regeneration and rewilding of areas which were previously wild but now affected by overuse by people, these areas may need to be temporarily fenced off to allow recovery before it becomes uninhabitable for wildlife
5.3.1 European Designated Sites
The city supports a number of European designated sites and protected habitats, including Galway Bay Complex and Lough Corrib Special Areas of Conservation (SACs), designated under the EU Habitats Directive and the Inner Galway Bay and Lough Corrib Special Protection Area (SPAs), designated under the EU ‘Birds’ Directive. These areas host the natural habitat types listed in Annex I and habitats of the protected species listed in Annex II. They are part of the Natura 2000 network of ecologically important sites across the EU and they seek to conserve a range of sensitive habitats and species.
Proposed plans and projects should consider DEHLG Guidance for Planning Authorities on Appropriate Assessment of Plans and Projects in Ireland (2009), and potential impacts identified in the Natura Impact Report (NIR) of the City Development Plan relating to habitat loss and fragmentation, water quality, disturbance and in combination effects. The EU Habitats Directive promotes a hierarchy of avoidance/protection, mitigation and compensatory measures and is based on a precautionary approach. The Directive provides an auditing tool to help deliver sustainable development. It provides a case-by-case mechanism for recording the implications of development on a European site and its conservation objectives and facilitates the decision-making process.
It is critical that there is continued protection and sensitive management of these sites, so that the sites’ intrinsic high ecological and biodiversity value is safeguarded and, in some cases, restored. The policies and objectives of the City Development Plan have been drafted taking cognisance of Article 6 of the Habitats Directive. All plans including lower tier plans and projects identified as having potential to impact on European Sites are required to adhere to the requirements of the Habitats Directive, to ensure no adverse impact on the integrity of European Sites.
Merlin Park Woods has areas of European Importance Annex 1 habitats which would fall in the protection of the Habitats Directive , it is important we recognise those sites that fall into this protection so we do not repeat previous mistakes where planning was approved and communities had to fight to get the planning rejected , It is important we work together in an early and collaborative way to ensure a healthy , biodiverse friendly progressive city. These areas should be named as such , there is very little awareness in the plan of the high status of some of the habitats within the woods despite it not yet being considered for designation .
Policy 5.2 Protected Spaces: Sites of European, National and Local Ecological Importance
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Protect European sites that form part of the Natura 2000 network (including Special Protection Areas and Special Areas of Conservation) in accordance with the requirements in the EU Habitats Directive (92/43/EEC), EU Birds Directive (2009/147/EC) and associated national legislation.
Policy 5.5 Community Spaces: Greenways, Boreens and Public Rights of Way
Create, enhance and maintain accessible and safe public rights of way, where appropriate for pedestrian convenience, including public lighting where appropriate. Excluding local and important biodiversity sites where species inhabiting it rely on the continuation of dark zones
Promote and facilitate safe and convenient walking and cycling routes through land use policy and the implementation of measures set out in the Galway Transport Strategy. Again, slow zones through woodlands should be implemented and acknowledged
Table 5.6 Network of Local Biodiversity Areas
Merlin Park Woods
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Mature broad-leaf trees, mixed broad-leaf / conifer woodlands. A full description of the woodland and its habitats should be included here European Habitats Annex 1 Priority Habitat Orchid rich meadows , Limestone Areas ,semi natural Grassland
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Doughiska
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Area of exposed limestone rock with calcareous grassland and scrub located along the eastern boundary of the city. The grassland contains orchid species and protects Small white orchid.
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Section 5.10 Specific Objectives should include
Short Term
Investigate and plan for restoration of Merlin River and
Long term
Ensure water flows through Merlin Woods to ensure no further loss of wildlife species which depend on it for their survival
Medium/Long Term
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Explore the potential for developing lands adjacent to Terryland Castle, Merlin Castle and Menlough Castle for public realm and landscaping to enhance the context of the Castles while protecting the existing habitats and in keeping with heritage of the area.
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Objective 5.10.14
Retain car parking of approximately 30 car parking spaces for amenity purposes east of Merlin Park Woods at Doughiska if they do not impede on the entrance to Merlin Park Woods and community garden area
Objective 5.10.38
Progress the acquisition of lands for recreation and amenity purposes, and other lands which will enhance the extent of the green network, in particular key linkages and lands for active and passive recreation. Lands purchased by city council of existing Merlin Woodlands which was previously owned by private owners should be safeguarded for this purpose, it is already utilised by people in the community as a walk-through woodland to the quarry , it is also an important area for our wildlife and would help to negate loss of land on Dublin R due to bus corridor
Objective 5.10.39
Acquire and develop predominately for public use, lands zoned for recreation and amenity use in conjunction with new housing at Castlegar, Doughiska, Terryland Valley, Ballymoneen, Knocknacarra, Roscam and Ardaun. Important to create connecting wildlife corridors for Merlin Woods , any green spaces should be of adequate size within developments and again old scrubland should be retained