Submission / Stage 2 - Draft Galway City Development Plan (2023-2029) - Friends of Merlin Woods

Unique Reference Number: 
GLWC-C2-229
Status: 
Submitted
Author: 
Friends of Merlin Woods
No. of documents attached: 
1
Boundaries Captured on Map: 
No
Author: 
Friends of Merlin Woods

Cover Letter

To Senior Planner,

Planning Department, City Hall, College Road, Galway, H91 X4K8

Submission / Stage 2 - Draft Galway City Development Plan (2023-2029)

Friends of Merlin Woods promotes the positive use of Merlin Woods and its connected meadow lands and works towards attaining the highest possible designation for the environmental protection the area so richly deserves.

As one of the largest and oldest urban woodland within the boundaries of the city and located on the East side of Galway and through our work with Parks Department , Environmental Dept, Heritage Office of Galway City Council alongside local and National Environmental groups, scientists, ecologists, universities, schools and local community , we have brought the woodland out of the darkness where once it was described as a dirty murky woodland to now becoming one of the more recognisable areas for biodiversity in the city , where local people and visitors both nationally and internationally are now visiting on regular basis. Improvements in the woodlands as meant it is vastly more accessible than previously and traditional conservation projects and careful modern management has ensured we can also work to protect the vast number of species and variety of habitats within it. In order to do this, we must be considerate of some of the negative impacts some of the policies and objectives may have and we will highlight some of our concerns that feel need to be addressed in the Draft Galway City Development Plan 2023-2029.

Observations

4.8 Specific Objectives

We have concerns over the wording of this specific objective and believe this should be worded to ensure that where negative impact to important local biodiversity areas or protected sites it should be noted that this would be avoided or consulted with local stakeholders , communities and ensure solutions are discussed through early collaboration dialogue which can ensure no animosity or likelihood of legal challenges

1. Implement traffic management and infrastructural changes to facilitate the provision of the ‘Cross City Link’ as part of the Galway Transport Strategy (GTS) and support any additional land requirements where deemed necessary through design along the associated routes and acknowledge that the objective to deliver the Cross City Link and associated traffic management and infrastructural changes has priority over other objectives including land use zoning objectives along identified routes, where they are in accordance with the proper planning and sustainable development of the area.

1. Implement traffic management and infrastructural changes to facilitate the development of a public bus network in accordance with the Galway Transport Strategy (GTS) and support any additional land requirements where deemed necessary through design along the associated routes and acknowledge that the objective to deliver the public bus network and associated traffic management and infrastructural changes has priority over other objectives including land use zoning objectives along identified routes, where they are in accordance with the proper planning and sustainable development of the area.

26 Facilitate a new access to Merlin Park Hospital from the Dublin Road.

 

The wording of this should be changed to the following

26 Update existing access to Merlin Park Hospital on the Dublin Road

Natural Heritage, Recreation and Amenity

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

  1. 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

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

Doughiska

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.

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

  1. 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.

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

Community and Culture

Policy 7.2 Creative City
10. Support the use of public outdoor spaces for public performance, festivals, events and engagement with the arts and culture activities in accordance with Galway City Public Realm Strategy 2019 and accompanying manuals. Public performance in areas of high biodiversity should be mindful of negative impact to wildlife and an environmental plan should be put forward and should be devised by stakeholders

Policy 7.8 Healthcare Facilities
Support the delivery of an enhanced regional healthcare service, including for a new Emergency Department at University Hospital Galway (UHG) and expanded hospital services at Merlin Park University Hospital (MPUH) that will serve the Metropolitan Area and the wider regional catchment.

We support the enhanced Regional Centre within the existing lands of the hospital, but we must protect all existing woodlands habitats and veteran trees these should not be impacted by development.

Policy 7.9 Institutional Lands

  1. Facilitate and promote the development of institutional land within the city unless it is of recreational and amenity value to local community and wildlife
  1. Retain institutional lands and only allow consideration for change in use where it is demonstrated that certain institutional lands are surplus to requirements, the Council will consider residential use or uses compatible with that of adjoining zones or specifically require that the lands be retained for alternative institutional uses. Where residential development is permitted a reserve of a minimum of 20% of the total site area for communal open space will be required unless it is of high biodiversity value as amenity land .
  1. Promote the retention of public access to institutional lands where this has been traditionally enjoyed or where there is a significant amenity associated with the lands or where land is important as a wildlife area or local biodiversity area.
  1. Promote the retention of public access to these lands where this has been traditionally enjoyed or where there is a significant amenity associated with the lands. Agree that this is vital

7.7 Specific Objectives

Specific Objectives
Promote the conservation/restoration and upgrading of Merlin Castle for use as a biodiversity and heritage hub with community use for Galway East in line with the policies for protection of our high biodiverse green spaces and heritage areas.

 

11.2.1 Institutional and Community CF Land Use Zoning Objectives

The following are specific development objectives for a number of CF zones throughout the city:

  • CF lands at Merlin Park comprising approximately 34 hectares. The Council will consider the development of these lands for institutional, or community facilities use either by the Health Services Executive or another institution and will not permit residential, commercial or industrial development. While ensuring the surrounding woodlands habitats are not impacted negatively

11.2.2 Natural Heritage, Recreation and Amenity RA Land Use Zoning Objectives

32. Investigate the potential of providing, for example kiosks, public toilets
and food trucks, in or in close proximity to public parks and open spaces and along
the coast and waterways

Food trucks should only be allowed at special events ,they may  cause disturbance and noise in a peaceful setting ,they may  impact local business , they will increase litter and without fulltime litter management , it is unfair to expect volunteers to clean up further litter

Green Spaces
Short Term
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 as above … Merlin Park lands acquired on Quarry house should be partially reserved as local biodiversity  land and zoned appropriately as they form part of existing woodland and geological importance with wildlife species of interest residing here such as Orchids , Bird of Preys and historical habitat and any housing should be in area s that do not impact this area.

11.2.8 Residential R and Low Density Residential LDR Land Use Zoning Objectives

Zoning Objective R

To provide for residential development and for associated support development, which will ensure the protection of existing residential amenity and will contribute to sustainable residential neighbourhoods.

Zoning Objective LDR      

To provide for low-density residential development which will ensure the protection of existing residential amenity and environmental sensitivities.

Nb Where possible hedgerows and stone walls shall be retained and supplemented by appropriate landscaping.