11th March 2022 Our Ref: SCP210101.3
Re. Draft Galway City Development Plan 2023-2029 and SEA Environmental Report
Dear Ms Philbin,
We acknowledge your notice, dated 27th January 2022, in relation to the Draft Galway City Development Plan 2023-2029 (the ‘Plan’) and SEA Environmental Report.
The EPA is one of the statutory environmental authorities under the SEA Regulations. In our role as an SEA environmental authority, we focus on promoting the full and transparent integration of the findings of the Environmental Assessment into the Plan and advocating that the key environmental challenges for Ireland are addressed as relevant and appropriate to the plan. Our functions as an SEA environmental authority do not include approving or enforcing SEAs or plans.
As a priority, we focus our efforts on reviewing and commenting on key sector plans. For land use plans at county and local level, we provide a ‘self-service approach’ via the attached guidance document ‘SEA of Local Authority Land Use Plans – EPA Recommendations and Resources’.
This document is updated regularly and sets out our key recommendations for integrating environmental considerations into Local Authority Land Use Plans. We suggest that you take this guidance document into account and incorporate the relevant recommendations, in finalising and implementing the Plan.
We also refer you to our previous submission, dated 12th February 2021, which we attach for your convenience and which should also be taken into account at this point.
Galway City Council should also ensure that the Plan aligns with key relevant higher-level plans and programmes and is consistent with the relevant objectives and policy commitments of the National Planning Framework and the Northern & Western Regional Spatial and Economic Strategy.
Comments on the Environmental Report
Non-Technical Summary
We note the Non-Technical Summary as included with the SEA Environmental Report. There is merit to considering the inclusion of some key mapping from the ER (for example: Plan Area Map, European Sites Map, Environmental Sensitivity Map), to further enhance the content of the NTS.
Mitigation Measures
Where you have identified the potential for likely significant effects, you should provide appropriate mitigation measures to avoid or minimise these. You should ensure that the Plan includes clear commitments to implement the mitigation measures.
Monitoring
The Monitoring Programme should be flexible to take account of specific environmental issues and unforeseen adverse impacts should they arise. It should consider and deal with the possibility of cumulative effects. Monitoring of both positive and negative effects should be considered. The monitoring programme should set out the various data sources, monitoring frequencies and responsibilities.
If the monitoring identifies adverse impacts during the implementation of the Plan, Galway City Council should ensure that suitable and effective remedial action is taken.
Guidance on SEA-related monitoring is available on the EPA website at https://www.epa.ie/publications/research/environmental-technologies/research-306-guidance.php
State of the Environment Report – Ireland’s Environment 2020
In finalising the Plan and integrating the findings of the SEA into the Plan, the recommendations, key issues and challenges described in our State of the Environment Report Ireland’s Environment – An Integrated Assessment 2020 (EPA, 2020) should be considered, as relevant and appropriate. This should also be taken into account, in preparing the Plan and SEA.
Future Amendments to the Plan
You should screen any future amendments to the Plan for likely significant effects, using the same method of assessment applied in the “environmental assessment” of the Plan.
SEA Statement – “Information on the Decision”
Once the Plan is adopted, you should prepare an SEA Statement that summarises:
- How environmental considerations have been integrated into the Plan;
- How the Environmental Report, submissions, observations and consultations have been taken into account during the preparation of the Plan;
- The reasons for choosing the Plan adopted in the light of other reasonable alternatives dealt with; and,
- The measures decided upon to monitor the significant environmental effects of implementation of the Plan.
You should send a copy of the SEA Statement with the above information to any environmental authority consulted during the SEA process.
Guidance on preparing SEA Statements is available on the EPA website at the following link: https://www.epa.ie/publications/research/environmental-technologies/research-306-guidance.php
Environmental Authorities
Under the SEA Regulations, you should consult with:
- Environmental Protection Agency;
- Minister for Housing, Local Government and Heritage;
- Minister for Environment, Climate and Communications; and
- Minister for Agriculture, Food and the Marine.
- any adjoining planning authority whose area is contiguous to the area of a planning authority which prepared a draft plan, proposed variation or local area plan.
Yours Sincerely,
________________________
David Galvin
SEA Section
Office of Evidence and Assessment