Uimhir Thagarta Uathúil: 
GLWC-C2-228
Stádas: 
Submitted
Údar: 
Galway Environmental Network

Chapter 5: Natural Heritage, Recreation and Amenity

GEN submits that in preparing the GCDP 2023-2029 Galway City Council must acknowledge
and accept in the GCDP 2023-2029 that:

  • Biodiversity Loss presents an existential threat at least equivalent to and probably greater than Climate Breakdown.
  • “Biodiversity is declining at an unprecedented rate, and the pressures driving this decline are intensifying. None of the Aichi Biodiversity Targets will be fully met, in turn threatening the achievement of the Sustainable Development Goals and undermining efforts to address climate change.” [The Global Biodiversity Outlook, 5th Edition].
  • It must Declare a Climate and Biodiversity Emergency.
  • Take the required Immediate and effective action.
  • Transformative change is required to address the threat. [IPBES (2019)].
  • It must learn from and adopt best practice from elsewhere in Ireland and abroad – Fingal County Council and Ennis for instance.
  • A vision of what we want Galway City to look like in the year 2100 is required.
  • Adequate resources must be made available.
  • Clear and measurable targets and timelines must be established

Galway City Council must commit in the GCDP 2023-2029 to:

  • Taking urgent and effective transformative action to address the existential threat of biodiversity loss. This needs to commence right now - it cannot await the adoption of the GCDP 2023-2029.
  • Preparing statutory Local Area Plans for the Headford Road area, Murrough, the city centre, including the Inner Harbour and Ceannt Station lands, the regeneration area to the east side of Eyre Square, the Harbour Lands and Nun’s Island. Make appropriate provision in these LAPs to protect and restore biodiversity including connectivity to surrounding areas of biodiversity. Fingal County Council has been an exemplar in including biodiversity in LAPs.“The preparation of Local Area Plans provides a key opportunity for the protection,management, enhancement and provision of green infrastructure which is fully integratedwith new development.” [From Barnhill Local Area Plan, February 2019] https://www.fingal.ie/sites/default/files/2019-09/barnhill_lap_-_text_0.pdf
  • Providing the necessary resources to support the Biodiversity Officer in recovering, restoring and renewing Biodiversity within the city.
  • Including the following objectives from the current National Biodiversity Plan, inadequate as it may be, at a minimum:
    • Review and update the Biodiversity and Heritage Action Plans. [Objective 1.1.5].
    • Include policies and objectives for the protection and restoration of biodiversity.
      [Objective 1.1.6]
    • Develop a Green Infrastructure at local level and promote the use of nature-based
      solutions for the delivery of a coherent and integrated network. [Objective 1.1.7].
    • Carry out hedgerow surveys [ Objective 2.1.12].
    • Develop and implement a communications campaign in support of public and
      sectoral understanding of the value of biodiversity and full implementation of this
      NBAP. [Objective 3.1.7].
    • Protect, enhance and monitor the ecological status of water during the second cycle
      of the Water Framework Directive (2015-2021) including reducing risks to water
      quality and utilising ecological expertise in decision-making, and in analysis of
      cumulative effects. [Objective 4.2.1].
    • Implement recommendations of EPA STRIVE Report Series No. 99 (Management
      Strategies for the Protection of High Status Waterbodies) including, amongst other
      measures: prioritisation for protection measures; planning/licensing control;
      assessment of cumulative impacts; and integrated monitoring and protection. [
      Objective 4.2.3].
    • Continue and enhance measures for eradication, where feasible, control and
      containment of invasive species. [Objective 4.4.3].
    • Encourage horticultural nurseries to produce native species, varieties and landraces
      from appropriate native sources for public and private sector plantings. Endeavour
      to plant native species in order to reduce importation of non-native species, varieties
      and landraces. [ Objective 4.4.4].
    • Implement measures to achieve good ecological and environmental status of marine
      and coastal habitats as required by the Habitats, Directive, Water Framework
      Directive and Marine Strategy Framework Directive (MSFD) and in line with the
      OSPAR Convention (Convention for the protection of the marine environment in the
      North- East Atlantic). [Objective 5.1.2].
    • Promote the incorporation of ecological engineering features in new and existing
      structures such as coastal defences. [Objective 5.1.4].
    • Implement the conservation measures necessary to achieve the published
      conservation objectives for Natura 2000 sites. Develop and implement additional
      measures as necessary to achieve favourable conservation status both nationally
      and at site level. [Objective 6.1.7]
    • Increase connectivity of the protected areas network using appropriate buffer zones,
      corridors, stepping stones and/or flyways. [Objective 6.2.1]
  • Including in the GCDP 2023-2029 any revised/new objectives included in the next National
    Biodiversity Plan once it is published.
  • Producing a new Galway City Biodiversity Action Plan to succeed the existing plan.
  • Assessing every single policy and objective in the Draft Development Plan to ensure that it
    will achieve a ‘Biodiversity Net Gain’, not just ‘No Net Loss.
  • Assigning the highest level of protection to Merlin Park Woods and the meadows as an
    important green biodiversity area with Annex 1 habitats.
  • Recognising as valuable habitats that must be recovered, restored and enhanced:
    • areas of scrub and undergrowth – don’t rip out and replace with new ‘landscaping’,
    • small green areas in industrial estates and housing estates,
    • the banks of waterways,
    • waterways,
    • grass margins along roads and wetlands.
  • Carrying out an inventory of habitats in the city. 
  • Recognising the negative implications for biodiversity of all-weather pitches.
    ● Implementing a range of actions from the All-Ireland Pollinator Plan. 
  • Leaving some green spaces unmown, as was done in a part of Nolan Park in Renmore during 2020, while still mowing along desire lines to promote walking. 
  • Supporting community groups to integrate the All-Ireland Pollinator Plan into local green
    spaces. 
  • Collaborating with Tidy Towns groups towards protecting, restoring and renewing
    biodiversity. 
  • Considering establishing voluntary Wildlife Rangers. 
  • Collaborating with the extensive knowledge base within NUI Galway, GMIT, local NGOs,
    community and voluntary groups. 
  • Increasing awareness of the value of local green and blue spaces. 
  • Proactively supporting the National Park City Galway initiative. 
  • Ensuring access for all to green and blue spaces while protecting wildlife and biodiversity.
  •  Ensuring that permissions for development have appropriate conditions attached to recover, restore and enhance biodiversity and ecosystems. 
  • Ensuring conditions attached to existing and future planning permissions are enforced to recover, restore and enhance biodiversity and ecosystems. 
  • Focusing all new development on existing infill, brownfield and regeneration sites in the city. 
  • Excluding any development on existing greenfield sites.
  • Please see the supporting documentation attached to this submission which provides the
    incontrovertible evidence backing up the above submission.