Draft Carlow County Development Plan 2022-2028

To whom it may concern,

As Social Enterprise Republic of Ireland (SERI – www.socialenterprise.ie),the representative body for Social Enterprises in Ireland, we strongly believe that the following items should be included as key commitments in the future Carlow County Development Plan:

1. A commitment to facilitate, enable and support the development of a vibrant Social Enterprise sector, as a valuable and important component of the overall Economic Development vision.

Social Enterprise is responsible for a significant level of service delivery, employment and facilities across education, housing, healthcare, childcare, tourism, sport and recreation, culture, heritage and the arts, energy, recycling and environmental initiatives. It is an essential pillar in the regeneration of many communities with many people dependent on social enterprises for essential supports. The Local Authority should ensure that relevant staff have knowledge of the challenges faced by social enterprises and that social enterprises have access to enterprise support structures and supports.

1. A commitment to work with Social Enterprises to access and develop appropriate fit for purpose land and buildings as spaces to enable development and growth of new services and products.

Social Enterprises require access to facilities to grow and develop their business services and products. Lacking access to essential capital to facilitate self-funded development, Social Enterprises require Local Authorities to have a greater awareness of their needs and incorporate Social Enterprises into local regeneration and other plans. Proactive approaches to provide infrastructural and service supports to facilitate Social Enterprises will create synergies, networking and the potential for collaboration.

1. A commitment to include Social Clauses in Public Procurement.

Social Enterprises require more accessible forms of Public Procurement in order to participate and benefit from state funded contracts. Local Authorities can facilitate this in how they structure their public procurement exercises when delivering on the County Development Plan investments. Social Clauses can be introduced making Public Procurement tenders more accessible for Social Enterprises.

1. A commitment to identity and disseminate best practice local examples of social enterprises and increase public understanding of their contribution to society and the economy.

SERI will continue to communicate the social enterprise agenda in a co-ordinated way, however, it is important that the Local Authority also underpin that messaging to ensure coherence and to improve public understanding of social enterprise as a whole, and its contribution to society and the economy. This messaging can also provide ideas and inspiration for communities in meeting identified community services and product needs.

Social Enterprise Republic of Ireland (SERI is available and open to meeting with Carlow Local Authority and advising how they might better support local Social Enterprises based on identified needs.

If you would like any further information, please do not hesitate to contact me on 087-9842505 or at tammy@socialenterprise.ie

CEO, SERI: Social Enterprise Republic of Ireland

SERI County Development Plan Submission Notes

1. Background to Social Enterprise Republic of Ireland

SERI, established in 2020, is a company limited by guarantee, born from the passion and knowledge within the Social Enterprise sector and responding to a universally recognised need for a united voice. Formed by some of Irelands leading social enterprise practitioners and supporters, SERI seeks to champion for the sector and members, representing and promoting its collective voice, both nationally and internationally.

SERI is a new beginning for Social Enterprise in Ireland and will grow the sector to benefit all people and communities by working shoulder to shoulder with local and national government to deliver a better eco system for social enterprises in which to operate.

SERI focuses on 4 main areas;

1. Representation–listening to members, championing, advocating, and representing.
2. Awareness–generating more understanding, demonstrating value, telling stories.
3. Support–signposting supports, identifying gaps, sharing best practice, networking.
4. Relationships–with Government, international orgs, N.I., other SE support organisations.

2. The Social Enterprise Sector in Ireland

The spectrum of social enterprise activity in Ireland is wide, and social enterprises take a variety of different forms, including, amongst others:

• Work Integration Social Enterprises (WISEs), which support disadvantaged people to prepare for, and participate in, the labour market.
• Enterprise Development social enterprises which support the creation of other enterprises (e.g. through the provision of office space and facilities).
• ‘Deficient Demand’ social enterprises which seek to meet a demand for goods and services within a community where there is insufficient demand for the operation of a regular market due to inherent economic and social disadvantage or low density of population.
• Environmental social enterprises which focus on environmental sustainability.
• Social enterprises contracted with the public sector to deliver public services in disadvantaged areas and communities.
• Some cooperatives which do not distribute profits to shareholders and are established to achieve a clear social impact also utilise the social enterprise model.

The activities of some social enterprises can cut across more than one of these areas.

3. Recent Development for Social Enterprise In Ireland

• 2013 Government produced a report on social enterprise.
• 2014 Minister for State Sean Sherlock TD given the social enterprise portfolio to develop.
• 2016 Minister for State Ann Phelan TD succeeded Minister Sherlock TD.
• 2016 Minister Michael Ring TD established the Department of Rural & Community Development with responsibility for Social Enterprise.
• 2017 Government assigned policy responsibility for social enterprise to the newly established Department of Rural and Community Development.
• 2018 In Dublin in July, Minister Michael Ring TD launched the National Social Enterprise Policy for Ireland 2019-2022.
• 2020 Minister Humphries TD leads the implementation of the social Enterprise Policy.

4. National Social Enterprise Policy

The national Policy defines Social Enterprise as “an enterprise whose objective is to achieve a social, societal or environmental impact rather than maximising profit for its owners or shareholders. It pursues its objectives by trading on an ongoing basis through the provision of goods and/or services and by reinvesting surpluses into achieving social objectives. It is governed in a fully accountable and transparent manner and independent of the public sector. If dissolved it should transfer its assets to another organisation with a similar mission”.

The Policy is focused on three objectives to support Social Enterprise growth:

1. Building Awareness of Social Enterprise
2. Growing and Strengthening Social Enterprise
3. Achieving Better Policy Alignment

The Policy sets out a series of 26 commitments on the part of Government across these three Objectives for the development of social enterprise over the period 2019-2022. These commitments will be delivered in partnership with social enterprise stakeholders. The objective of the Policy is to support social enterprise to grow in scale and impact.

5. Social Enterprise and Local Authorities

Local Authorities play a key role in leading the social, economic and cultural development of local areas.  Local Authorities are involved in the delivery of a range of supports to social enterprises through initiatives such as the Social Inclusion and Community Activation Programme (SICAP), and the Community Enhancement Programme. Local Authorities Ireland has also worked with Social Innovation Fund Ireland (SIFI) and IPB Insurance on the €1.6 million Social Enterprise Development Fund which is being delivered by SIFI over the period 2018-2020.

Submission from the HSA

Submission relates to entire CDP and Environmental Report. 

Dear Sir/ Madam,
 
Please find attached a copy of the submissions and observations of the Eastern and Midland Regional Assembly regarding the Draft Carlow County Development Plan 2022-2028, for your information. 

This submission was approved by the elected members of the Eastern and Midland Regional Assembly at the meeting of September 10th, 2021.

Kind Regards, 

Clare Bannon
 

We refer to attached submission 

Draft Carlow County Development Plan 2022 - 2028 

Lands at Tinryland

The new Carlow County Development Plan presents an opportunity to promote the county as a place that prides itself on its climate action and renewable energy credentials. Closely linked with this is the perception of the local authority area as an excellent place to potentially do business and create employment.

Chapter 7 of the Draft County Development Plan 2022-2028 marks a departure to a more progressive approach to solar farm applications, than within the current adopted plan. The Draft Plan has innovative and forward-looking policies that will provide an incentive for the solar industry to become established in the county, and therefore help facilitate and attract inward investment. The primary objective for deploying renewable energy in Ireland is to advance economic development, improve energy security, access to energy, and mitigate against climate change. These key areas are all covered within the Draft Development Plan, but further synergy is needed between them in policy terms.

Lightsource bp welcomes the overall tone and approach the Council have adopted towards renewable energy within Chapter 7 of the Draft Development Plan. The Council’s commitment to reduced CO2 emissions, is both laudable and timely within the current climate emergency. Lightsource bp is encouraged by the strategic ‘Aim’ of Chapter 7, and how climate mitigation is to be embedded into council policies and objectives:

‘Aim:  To combat climate change and its impacts in the County by promoting and supporting policies and objectives which contribute towards a transition to a low-carbon and climate resilient future, and which focus on reducing greenhouse gas emissions and energy demands through appropriate and effective climate mitigation and adaptation measures’.

The above ‘Aim’ within Chapter 7 is welcome, particularly as it focuses on moving the county ‘towards a transition to a low-carbon and climate resilient future.’ However, this aim should be worded more decisively with dates and targets in line with wider national policies within the Climate Action Plan 2019. Only through the setting of defined and focused targets on carbon and other GHG emissions, can such an ‘Aim’ be measured and benchmarked for success. Lightsource bp contend that the stated ‘Aim’ should relate and refer to the current national policy on renewable electricity generation, namely the Climate Action Plan 2019. This would typically mean amending the ‘Aim’ to reflect the national target to generate 70% of electricity demand within the County, to be sourced from renewables by 2030.  Lightsource bp is of the view that solar generation can contribute significantly, in a timely manner to such agreed targets. We are of the view that the target should be amended to state:

‘Aim:  To combat climate change and its impacts in the County by promoting and supporting policies and objectives which contribute towards a transition to a low-carbon and climate resilient future, and which focus on reducing greenhouse gas emissions and energy demands in line with targets within the Climate Action Plan, through appropriate and effective climate mitigation and adaptation measures’

Section 7.5.4 of Chapter 7 refers to the above Climate Action Plan (2019). However, the entire Chapter fails to mention even once, the central pillar within the Climate Action Plan of 70% renewable electricity generation by 2030. This is rather disappointing and indeed glaringly absent from this important Chapter within the Draft Development Plan. In addition, none of the polices within Chapter 7 promote or refer to this central target of the Climate Action Plan. Entitling the section ‘Climate Action and Energy’ seems rather odd when one of the central pillars of the Climate Action Plan is not referred to or translated into policy.

Lightsource bp welcome the removal of the current Energy Policy 9 from the Draft Plan. The latter 10MW cap on solar farm applications was unsustainable, creating a regional inequality in the drive towards achieving national targets on renewable energy.  Lightsource bp is of the view that each solar farm project should be considered and assessed on a site-by-site basis. The proposed Draft Plan provides policy to support the long-established principles of proper planning and sustainable development in combination with site-specific environmental considerations. If adopted, the Draft County Development Plan will enable Carlow to share equitably the national responsibility for renewable energy commitments needed over the coming years. As an eastern county within a region where electricity demand is much higher than other parts of Ireland, where the grid network is substantially better served and with land perfectly suited to solar development, Carlow is best placed to accommodate utility scale solar developments and meet renewable energy commitments.

Lightsource bp welcome the following policies and objectives within the Draft County Plan;

•             CA. P2: Support the transition of the County to a competitive, low carbon, climate-resilient and environmentally sustainable economy by 2050, by way of reducing greenhouse gases, increasing renewable energy, and improving energy efficiency.

•             RE. P1: Encourage and facilitate the production of energy from renewable sources, such as from wind, solar, bioenergy, hydroelectricity, and geothermal, subject to compliance with proper planning and environmental considerations.

•             RE. 01: Seek to achieve a minimum of 130MW of renewable electricity in the County by 2030, by enabling renewable energy developments, and through micro-generation including rooftop solar, wind, hydro-electric and bioenergy combined heat and power (CHP).

• IF. P1:  Support the development, reinforcement, renewal, and expansion of key supporting infrastructure to facilitate renewable energy developments, subject to compliance with proper planning and environmental considerations.

•             SE. P2: Favourably consider the development of solar farms on agricultural lands which allow for farm diversification and multipurpose land use.

•             SE. 01: Increase the penetration of solar energy developments at appropriate locations subject to compliance with proper planning and environmental considerations.

Lightsource bp would however urge caution in the adoption of Policy SE. P1: which reads as follows:

‘Favourably consider the redevelopment of brown field sites for large solar PV projects subject to proper planning and environmental considerations’.

Preference or undue weight afforded to the use of brownfield land fails to take cognisance of the current land requirements for modern utility scale solar farms. Achieving competitiveness and reaching the targets set for renewable electricity generation as per the Climate Action Plan 2019 (70% by 2030) will require larger sites and economies of scale. Brownfield supply in Ireland is largely in central urban areas or in edge of town locations. The scale of brownfield required for a solar farm is unlikely to be found within an Irish brownfield context.

A solar farm project will be unlikely to compete commercially on urban brownfield land against the financial strength of a residential developer. The use of the word ‘brownfield’ in Policy BE. P1 is therefore too generic and open to interpretation by third parties and objectors. If the Council’s definition of ‘brownfield’ really means rural brownfield such as cut away bog and landfill, then this should be stated. Lightsource bp would however highlight that such rural brownfield sites are not always suitable due to issues pertaining to biodiversity, ground stability and gas release.

In addition, Lightsource bp is of the view that Section 7.10.3.2 could be developed to consider the most pressing challenges to solar development and planning considerations across the county. This section should outline that solar farms are relatively quick to deploy, in comparison with other energy generation technologies, and we believe well sited solar farms can help meet urgent renewable energy targets, without impacting negatively on local communities or the environment. In particular, the Draft County Development Plan should consider the innovative approach known as co-location, where solar, battery storage and wind farms symbiotically co-exist. This is a highly sustainable use of existing infrastructure, with the solar farm and a nearby wind farm sharing infrastructure. We would suggest that a policy objective should be included as below:

‘Favourable consideration will be given to the re-use, shared use (co-location), refurbishment, repair and repowering of existing renewable energy technology developments in order to prolong the life span of developments such as wind farms and solar farms providing that these do not result in unacceptable impacts on the environment or residential / visual amenity.’

Lightsource bp is also of the view that the County Development Plan should provide clarity to prohibit the unnecessary use of restrictive conditions that prevent an increase in MW export capacity without submitting a new planning application. Such conditions prevent repowering within the original planning approval, are unreasonable and run contrary to the ability of generators to repower simply because a suggested MW figure may have been quoted on drawings or within the text of a supporting statements. Such restrictive conditions on MW capacity are contrary to a condition lead flexible approach to repowering. The final export capacity of a solar farm is not a land use issue and should not be controlled or capped within a condition of planning consent. Naturally, if MW export capacity is linked to development contributions, the additional contributions should be sought by the Local Authority.

Finally, Lightsource bp would suggest that policy provision within the new Development Plan should extend to providing support for flexible and enforceable conditions in any planning consent for a solar farm, to allow minor non-material changes to the panel and infrastructure layout. This level of detail can be agreed prior to commencement of development. The rationale behind this is that many utility scale solar farms have been afforded a 10-year permission by the Local Authority, and technology can evolve in relation to panel types and infrastructure in the years leading up to the commencement of development. A flexible and open condition requesting the submission and agreement of the final design, elevations, colour and location of panels and electrical infrastructure prior to the commencement of development could address this issue. The nature of the proposed amendments and the materiality of the changes is of course central to this approach.

The policies within the new Carlow County Development Plan therefore should be clear, targeted, and focused, demonstrating how renewable forms of energy are to be encouraged and in what areas of the local economy they can particularly assist. The use of renewable energy like solar, can stimulate jobs and reduce reliance on fossil fuels. As stated above, Quality Indicators used to locate many foreign direct investment companies include access to reliable energy that has come from low carbon sources.

Utility scale solar developments provide the best opportunity to achieve both local ‘green’ targets set within the County Development Plan and help assist with national targets on electricity generation. In addition, they facilitate reductions in carbon emissions and contribute positively to the local environment through biodiversity enhancement.

The draft County Development Plan has considered business, employment, and enterprise creation within Chapter 4. Lightsource bp are of the view that economic development must be sustainable and achieved within the context of carbon reductions. This is lacking within the tone and wording of Chapter 4. The Enterprise and Employment Strategy refers to the following policy:

• ES. P1: Work in partnership with Enterprise Ireland, IDA Ireland, adjoining local authorities, the Regional Assembly and all other relevant agencies to proactively pursue sustainable enterprise and economic development in line with the vision of Carlow County Council together with policies and objectives set out in national, regional and local strategies.

Through the new Development Plan, Carlow has an opportunity to take ambitious steps to attract inward investment, both indigenous and foreign direct investment (FDI). It is the view of Lightsource bp that utility scale solar is a key incentive in this process. Increasingly FDI companies wish to locate near to a secure supply of renewable electricity. This can be seen in Ireland with Facebook in Meath, Eli Lilly in Kinsale, Amazon in Cork, and Microsoft in Dublin. Peter Freed, Data Centre Renewable Energy Manager in Facebook encapsulates this ‘green goal’ very well in the statement below:

“Our goal is simple: power our data centres with clean and renewable energy and, where possible, help green the grid by adding new renewable resources.”

The infrastructure facilities that are normally promoted in any town referred to within a County Development Plan are likely that the town boasts a number of fully serviced sites, it has excellent transport links, and the availability of high-speed broadband in the area. What very often is not considered is the potential end user’s requirements for clean, secure, and renewable energy. Quality Indicators used to steer the location for FDI investment include access to reliable energy that has come from low carbon sources.

Amongst the type of FDI companies that may consider Carlow as a location are likely to be Pharmaceutical providers, Data Centres and other FDIs with internal corporate policies that require substantial (if not 100%) of their energy to be sourced from renewable sources, to reduce their and carbon footprint. In N. Ireland, Lightsource bp has developed solar farms which serve a local manufacturer called Brett Martin (produces plastic sheet manufacturing) and Belfast International Airport. These are excellent examples of solar energy supporting local enterprise, creating and protecting jobs, and meeting renewable energy targets. The Council should be aspiring to become a supporting platform for local business development and companies that embrace renewables. Policies that are both positive towards renewable technology such as utility scale solar, and actively forge the link between employment, investment and renewable energy are required in Chapter 4.

The policies within the new Carlow County Development Plan therefore should be clear, targeted, and focused, demonstrating how renewable forms of energy are to be encouraged and in what areas of the local economy they can particularly assist. The use of renewable energy like solar, can stimulate jobs and reduce reliance on fossil fuels. As stated above, Quality Indicators used to locate many foreign direct investment companies include access to reliable energy that has come from low carbon sources.

Utility scale solar developments provide the best opportunity to achieve both local ‘green’ targets set within the County Development Plan and help assist with national targets on electricity generation. In addition, they facilitate reductions in carbon emissions and contribute positively to the local environment through biodiversity enhancement.

Re: Draft Carlow County Development Plan 2022 - 2028
Submission on behalf of Euro Care International re land at Ballylennon, Pollerton Little, Co. Carlow

Carlow County Council should not facilitate engagement with relevant stakeholders including Waterways Ireland to promote the development of a “Blueway” on the river Barrow as the proposal has already been refused by both Carlow County Council Planning Office and An Bord Pleanala. ABP: PL01.301245

To support such a development the County Development Plan 2022-28 would be ignoring “Section 12(11) of The Act states that in making the[Development] Plan members shall be restricted to considering the proper planning and sustainable development of the area to which the Development Plan relates, the statutory obligations of any Local Authority in the area...”

The Barrow track is walked and cycled by all age  groups for most months of the year.  The fact that the Barrow Track floods most years appears to have been ignored by people who are advocates for the hard path. I can give examples of where the hard path had been damaged by flooding and I can give examples of where the grass on the trackway has been resistant to flood damage. I contend that the hard path is not thought through by advocates of the development.

Most people in Carlow are unaware as to how unique the Barrow track is in term of the biodiversity of flora and fauna. Over the years I have posted many unique photographs of insects including butterflies and damselflies and wildflowers onto Facebook groups. As often in the case many who grow up along the Barrow do not realise how special and unique it is. There is a reason why the development of the hard path has been rejected by An Board Pleanala and Carlow County Council Planning Office

Ronan

Dear Forward Planners

Please see attached re submission on Enhanced Conservation Measures for Common Swift populations.

Thank you for your time and attention in this matter.

Dear Forward Planners

In recent decades, multiple factors have combined to leave Ireland as a laggard in key areas of environmental protection.

In order to redress some of this policy defeciency, it is requested that Carlow County:

(a) creates and adopts a Tree Policy for the county, to cover both rural and especially urban areas.

(b) considers the appointment of a suitably trained Biodiversity Officer to help Carlow County fulfil its obligations with regard to Biodiversity

I welcome the idea of having this plan for the coming years.  I welcome the zoning as Amenity the field at McArdle's Cross, at present being used as a Soccer pitch by St Joseph's AFC.  this is a very positive proposal as open space and amenity areas are vital in the vicinity of the village.

In relation to housing, I feel strongly that a balance must be struck between Local Authority housing and Private Development.  For that reason, I propose that what is marked as Village Expansion Area (in pink) in front of the Parochial House be changed to a mixture of New Residential and Social Housing.  In the overall proposed plan for the village I note that the New Residential area is very small.  My proposal could be enhanced by the inclusinon of sheltered accommodation for the elderly as part of the mix.

I would include with that area the small Open Space (green) on the left of the avenue going up to the Parochial House and also the area betweent he Cemetery and the soccer pitch, zoned Community / Education in the Proposed Plan.  A small area below the school should be retained for Education to provide some extra ground for the school.

I trust these suggestions are helpful and that they will be given serious consideration at your meeting.

Additional information with map

Draft Carlow County Development Plan 2022 - 2028 Submission by Sean  Mahon on behalf of Jim Farrell

Draft Carlow County Development Plan 2022 - 2028 Submission by Sean Mahon on behalf of Denis & Laura Mullins, Doyles Shop, Royal Oak, Bagenalstown

Draft County Development Plan 2022-2028 Submission by Thompson Project Management Ltd.

Draft Carlow County Development Plan 2022-2028

Chapter 2: Core Strategy and Settlement Strategy

Chapter 15: Larger Serviced Villages

15.4.3       Rathtoe

Ref: Land use rezoning Submission at Rathoe or Rathtoe, Tullow, Co. Carlow.

Dear Sir/Madam

On behalf of our client Seamus O’Toole, please see attached submission which seeks the rezoning of lands at Rathoe or Rathtoe, Tullow, Co. Carlow.

This submission proposes the Rezoning of subject lands.

Please see Submission attached in relation to same.

Regards

Declan T. Kehoe MCIAT C.Build E MCABE

Director

Kehoe Architectural Design

pp Seamus O’Toole

RE: DRAFT Carlow County Development Plan 2022-2028
Submission on behalf of Donald Coady  - Lands at Scorteen, Borris Co. Carlow.

Dear Sir, Madam / Miss. 
Please take note of the following submission on behalf of our client Donald Coady
To the DRAFT Carlow County Development Plan 2022-2028. – Chapter 15 –Borris Plan.

Introduction.
The Planning Authority has commenced the preparation of the Carlow County Development Plan (CDP)   to cover  the  period  2022  to  2028 incorporating  Borris, which is classed as a Town and Village Rural Node. The purpose of the CDP is to set  out  an  overall  strategy  for  the  proper  planning  and  sustainable  development of the County.

Summary.
This is a submission to the draft Carlow County Development Plan 2022-2028 (the Draft Plan) seeking an amendment to the proposed development boundary of the draft Plan for Borris.
The lands within my client’s ownership are contained within the village of Borris and forms part of a parcel of land, which was granted planning for the construction of 9 Houses in 2007 under application PL06/1063.
Development works did not proceed at that time and the planning was not availed of.

Proposal
In the interests of proper planning and development the village of Borris, we are proposing to alter the original application development design in order to provide a more integrated and low-density development. 
This low-density development will offer a viable and controlled alternative to those seeking to construct one off dwellings within the rural setting.
The site is readily serviced and forms a natural expansion of the village and consolidation of the existing settlement pattern.
 

We feel that the development plan needs to reconsider the planned De-zoning of any sites that have a considerable amount works carried out that would  help to reduce the overall build cost.
The price of building has risen by as much as 25% in the last 9 months alone and this needs to be addressed now,  as the draft development plan can not have taking the curent influtation of the cost of materials / Labour to build in to consideration, as the recent timing of these price increases.
All this will reflect on the visibility on wheater it is cost effective to build housing units going forward.

On Ard bhaile it’s self this is a large 10 acre 80% fully serviced site which includes  ESB ,Eir,Water,Storm, Foul, P/L, Roads & foot paths with drop kerbs in place for each individual Unit. The Draft Development plan for Carlow 2022-2028 proposes that nearly 50% of this land be used for open space and amenities. 

The Original Plans granted ref 04/686 was a very well laid out site with all stand alone detached house's on genorous plots with access to large open space's.
This was the main reason behind Woodlawn developments purchasing this development.
This would of been a perfect development for decent size affordable houses and for the buyer who would like to trade up (now making there existing house available e.g first time buyers)

To make the changes outlined in the draft development plan to a project of this size should be re-evaluated.
A time when rents are out of control in Co Carlow, due to lack of supply and the high price that are allready( which is well above the Draft development plans section 4.2.7 rent predicted prices for the next seven years sateting that in 2028 rent will only be  €1068 P/M for a 3bed ????) I have been speaking with local rental agents and the current price for a 3 Bed house is €1250.00 per month in 2021. 
Affordable house are not available 90% of all house's  been built in County Carlow are all earmarked for social housing. This needs to be addressed in the New Development Plan for 2022-2028

This carlow development plan proposal to reduce numbers of units at Ard bhaile for reason's we do not understand would mean.

• The price paid for the land was unsustainable.
• A complete new site layout is required
• Extensive civil works will be needed
• The  removal of existing services 
• The Removal and relocation of existing drop Kerbs & foot paths
• Reinstating of roads.

After completing the Millrace green in Carlow Town 22 Units for Social Housing we were Planning to move to Rathvilly and commecnnce development which could have come to the market in the first half 2022.

Now that we have incurred delays in planning with the Draft development Plan, and due to the extent of works possibly required, And as a result the end price will be completly out of reach for your average buyer. It would be more cost efective and viable to go to another green field Site we own. Should the proposal in this development plan be passed we will have no option but to wait a number of years before it will be cost effective to develop this site. (Possibly the next Development Plan in 2029)

We strongly recommend this is Reconsidered.

Re: Submission to Public Consultation for the Carlow Development Plan, Proposed Removal of Structures from the Record of Protected Structures.

Dear Sir/Madam,

I am writing to you in relation to a pair of derelict 19th century structures that stand on the east side of Shamrock Square, at the junction of Barrack Street, Tullow Street, Staplestown Road, Pollerton Road and Green Lane, in Carlow Town.  These structures were included in the Record of Protected Structures due to their well-preserved Victorian shopfronts,  (RPS Nos. CT 93 and CT 94).  As discussed in the attached Heritage Assessment Report,the structures were probably built around 1830-1840, with the shopfronts added during the second half of the 19th century.   

Both of the subject structures were heavily damaged in a fire in 2008, and have since become extremely ruinous and structurally unstable.  To illustrate the current conditions of the structures, I attach the MESH Architects Heritage Assessment Report, and a structural assessment report prepared by Martin Peters, structural/civil engineer. 

The properties are under new ownership, and preplanning discussions have taken place with officials in Carlow County Council, in relation to possible redevelopment of the site.  As a result of those discussions, it was suggested that a request to remove the derelict structures from the RPS would be appropriate.  

Our client has therefore requested that MESH Architects lodge a submission to the Carlow Development Plan process, to request that both structure be removed from the Record of Protected Structures.

Please contact us if you have any questions.

Kind regards,

Thomas C. McGimsey, MRIAI,

MESH Architects

Please ignore

Please see the attached letter together with an OS Map to identify the area of land to be considered for medium density residential use.

I have posted a brief  yet succinct message in the cover letter .NO to a blue-way cycle path !!

 I am emailling you to say that Carlow County Council should not facilitate engagement with relevant stakeholders including Waterways Ireland to promote the development of a “Blueway” on the river Barrow as the proposal has already been refused by both Carlow County Council Planning Office and An Bord Pleanala. ABP: PL01.301245

To support such a development the County Development Plan 2022-28 would be ignoring “Section 12(11) of The Act states that in making the[Development] Plan members shall be restricted to considering the proper planning and sustainable development of the area to which the Development Plan relates, the statutory obligations of any Local Authority in the local area.

Draft Carlow County Development Plan 2022 - 2028 Submission by Paul & Thelma Nolan

Please see the attached PDF to find our comments on the entire Draft Plan.

Best, Denis Devane

I am very concerned that Carlow county council are seemingly ignoring an bord pleanala and their own planning department. These experts are not happy with the plan . I am incredulous that it is being attempted to circumnavigate rules to get it through at all costs.  The people come to the tow path especially between graignamanagh and st Mullins, because BECAUSE it is natural riverbank unspoilt and a native habitat to varied water and land based wildlife and aquatic life . The tree lined path would be destroyed if any works are carried out on the tow path as the roots would be damaged and destroyed . Do you not care about the lack of tree cover in ireland .do you not care about the last wild natural places. It is a place of unique and special attraction and could generate much revenue if ha dled sensitively. 

Carlow County Council should not facilitate engagement with relevant stakeholders including Waterways Ireland to promote the development of a “Blueway” on the river Barrow as the proposal has already been refused by both Carlow County Council Planning Office and An Bord Pleanala. ABP: PL01.301245

To support such a development the County Development Plan 2022-28 would be ignoring “Section 12(11) of The Act states that in making the[Development] Plan members shall be restricted to considering the proper planning and sustainable development of the area to which the Development Plan relates, the statutory obligations of any Local Authority in the area...”

In my file headed Submission on Carlow County Draft Development Plan by Save the Barrow Line Group I give my comments in detail

See paragraph 2 of Submission on Carlow County Draft Development Plan from Save the Barrow Line Group

See paragraph 3 of file attached entitled Submission on Carlow County Draft Development Plan from Save the Barrow Line Group

see paragraph 1 of attached file Submission om Carlow County Draft Development Plan by Save the Barrow Line group

See paragraph 2 of attached file entitled edited Submission on Carlow County Draft Development Plan by Save the Barrow Line group

See paragraph 3 of attached file statement entitled Submission to Carlow County Council Draft Development Plan by Save the Barrow Line group

Please see letter attached.

Keep Ireland Open Submission

I would like to express my deep appreciation for the recent installation of wonderfully detailed and attractive storyboards that have appeared at local heritage sites right across the county. They are a fantastic resource for locals and visitors to gain an understanding of the site being visited and to give us all an insight into our local history. I hope there will be more work in the promotion of our many heritage sites and it is a welcome and timely development that a Heritage Officer has also now been appointed.

Proposals to develop a Greenway along the path of the defunct railway line from Bagenalstown, trhough Borris and Glynn are most welcome. This is the best option to link up with the Waterford Greenway and will be a fantastic addition to the tourism infrastructure of the county. This should be pursued as early as possible and consideration also given to the old line to Tullow.

I am a weekly user of the Barrow towpath and I have cycled it from Carlow to St Mullins on hundreds of occasions. When the proposal to construct a cycle path as part of the Barrow Blueway was proposed I was totally against such a development based on my own experiences of using the Towpath and my appreciation for the delicate natural reserve it is.

My understanding is that the proposal received record numbers of objections - showing the depth of feeling about the importance of protecting the delicate natural environment along this narrow wilderness corridor. The Towpath has many other incompatable uses wth mass cycle tourism - it is a national long distance walking trail and a grass surface at that. It would be sacrilage to remove a grass path for a hard surface. There are also many swimming spots that are very popular and of course fishing is also a very important activity.  

I am still of that view and if the Greenway along the old railway line is advanced we will have the best of both worlds - a cycle track through the stunning scenery of south Carlow AND our walking trail along the River Barrow.

I am concerned with recent media reports that Carlow County Council is open to revisiting the decision of An Bord Pleanála not to permit the cycle path along the River. The decision of An Bord Pleanála, PLO1.301245 was very clear. This was not a suitable development. It is incumbent of Carlow County Council that they not facilitate enagement with relevant stakeholders, such as Waterways Ireland (WWI) to promote the development of a bike path on the River Bank.

To support such a development the County Development Plan 2022-28 would be ignoring “Section 12(11) of The Act states that in making the[Development] Plan members shall be restricted to considering the proper planning and sustainable development of the area to which the Development Plan relates, the statutory obligations of any Local Authority in the area...”

By all means develop the boating and fishing aspects of the River; there is much work needed to improve the navigation channel on the river. The overall maintenance of the River itself and the Towpath are not satisfactory and require the attention of all stakeholders working together. The greatest improvement that can be made to improve access, to improve visitor numbers and to support local tourism is to inverst in boating on the river. We can see how the River Shannon and the River Erne have become such an essential part of the tourism offering in the surrounding counties. I am mystified as to why similar efforts to develop the boating opportunties of our River have been ignored by WWI who seem intent of the development of a cycle path above all else.

My final contribution is to draw attention to the superb network of local roads that cross cross the county. I use these every day of the week and they are mainly traffic free. I would like Carlow County Council to undertake a study of building our own network of cycle friendly routes that could be promoted for shared use. I have seen excellent signage along the Royal Canal Cycle path showing 'shared use' between cars , cyclists. and walkers. Carlow could have a cycling infrastructure that would give tourism a real boost if developed and give us an edge on other locations. I should also add that the quality of the surface on our lcoa roads is generally excellent and much better than in many other counties.

Mr Michael Quinn has instructed Turley Town Planning Consultants o make a submission in respect of the Draft Carlow County Development Plan 2022-2028 in relation to lands at Dublin Road, Carlow.

The subject lands (approximately 4.5 hectare / 11 acres in size are strategically located close to key employment centres including MSD, approximately 4 kilometres from Carlow Town Centre and located on one of the main arterial routes of the Town – R448, Dublin Road providing rapid access to the Town and also the M9 via Junction 4.

Purpose of this Submission

The purpose of this submission is, namely, to seek the:

1. Rezoning of the lands at Dublin Road from their existing ‘Community-Educational-Institutional’, to ‘Objective H - Enterprise and Employment’ Zoning; and

The subject lands present an opportunity to support the growth and expansion of existing and new employment generating uses on the Dublin Road. The Carlow County Development Plan (and associated further statutory plans) must ensure that sufficient lands are zoned to support economic development in Carlow Town and that zoned lands are located appropriately in order to complement and support existing enterprise and to allow employment generating hubs/clusters to be established.

Housing:
As stated in the draft Co. Carlow Development Plan 2022- 2028, 12% of housing units in Leighlinbridge are recorded as vacant, higher than the National average( 9.1% )and County average  (8%). Why then would more land in the area be rezoned for housing?

Location:
Milford Road is a  narrow road with severe blind bends and poor sight lines. There has been vehicular accidents in recent times on this road . A very large volume  of traffic uses this road for access to the Nursing Home and Arboretum Garden Centre , in addition to pedestrian and vehicular traffic.
 The current Development Plan specifies “ the provision of additional new housing on appropriately zoned lands and the completion of Ballyknockan Manor & Friarslough to the west of the town”, with the necessary services in place, which meet the current allocation for housing and completes the developments.
Genesis, has made a submission to change land at Milford Road from agricultural to residential. This proposed change by Genesis goes against the current Draft of Co. Carlow  Development Plan 2022-2022.

Yours Faithfully,

Grainne Moran

Dear Sir/Madam,

In the midst of a Biodiversity and Climate emergency the suggestions made below in the attached document in indented bold italics will show how natural heritage and biodiversity can be conserved and enhanced going forward along with sustainable development in both urban and rural areas .

Green Infrastructure/ Regeneration Strategy

The Carlow County Development Plan review will ‘’deal with biodiversity and environmental protection’’……, it refers to the United Nations sustainable development goals including goal 15 which aims to ‘’ Protect, restore and promote sustainable use of terrestrial ecosystems, sustainably manage forests, combat desertification, and halt and reverse land degradation and halt biodiversity loss’’, it acknowledges the role of heritage in promoting biodiversity.

Project Carlow 2040 acknowledges the benefits of biodiversity, particularly in an urban setting. It includes enhancing biodiversity resources under its sustainability principles for development going forward.

''Urban policy-makers have increasingly been exploring the links between urban planning and public health, specifically in relation to the potential for urban environments to have positive impacts on health outcomes and healthy lifestyles, such as through.....access to ‘nature’/biodiversity''.

''These health services are understood to range from direct positive effects on mental and physical health from increased biodiversity, to improved well-being resulting from increased exposure to nature'' 

''Supports biodiversity initiatives in the Town Centre.''

''Encouraging biodiversity within the public realm.''  

''Integrating unique amenity and biodiversity spaces into the urban fabric''.  

''Protect and enhance Carlow Town’s unique biodiversity''

‘’Maintaining, enhancing and protecting healthy air and water and enhancing biodiversity resources’’

• These benefits of biodiversity also need to be acknowledged in the Carlow County Development Plan 2022-2028 such that developments/initiatives contributing to such biodiversity and human health and well-being are adequately funded, resourced and acknowledged and that biodiversity is protected and conserved.
• Swifts form an integral part of this urban biodiversity and must be conserved with a view to including provisions for in built boxes in developments going forward as part of the plan. 
• In built Swift boxes should be included in any new developments at the IT Carlow Campus.

Project Ireland 2040 also acknowledges the benefit of green infrastructure ….

(’’ 3. Takes space back into the public realm

In the first instance, Carlow County Council plan to deliver more public space, with the aim to encourage more people to spend more time outdoors. Carlow County Council also plans to make public space more responsive to the needs of those who use it. This Strategy seeks to provide plentiful, accessible and exciting public spaces in Carlow Town that are filled with people all day and all year round, providing a fundamental element of urban life. Extended and new riverside pedestrian routes, open spaces, and activities all connected by greatly improved pedestrian/cyclist networks will support this concept alongside a focus on green infrastructure, where Carlow will seek to find economic opportunities in the greening process. Overall, improving the quality and enhancing the accessibility to public open spaces will result in multiple benefits including health and wellbeing as well as sustainable transport, biodiversity and recreation.’’)

The current draft county development plan acknowledges the biodiversity benefits of Green Infrastructure; namely ‘’ • Improved habitats for wildlife • Provision of ecological corridors • Landscape permeability • Reducing habitat fragmentation • Providing a buffer against climate change for habitats and species’’

• We must ensure that any further ‘’Green Infrastructure’’ development within Carlow does not contradict any of these biodiversity benefits.
• We must acknowledge and protect existing green spaces currently providing for and fulfilling the role of Green Infrastructure.
• Existing urban areas within Carlow town which need to be protected from unsuitable developments and acknowledged as currently providing green infrastructure which supports biodiversity and human well-being in open green spaces in an urban environment include those listed below; Green spaces around the old Youth Centre and Castle Rangers FC, Green Space behind/ south of New Oak Boys AFC, Green space east of Eire Og football grounds, Link road south of River Burren and surrounding woods and scrub areas which was never opened, Green Space River Burren Linear walk between railway bridge and new link road that was never opened, River Barrow Tow path full length of county.
• The green space area east of Eire Og, the link road south of the river Burren and surrounding woods and scrub areas which was never opened, the green space between the railway bridge and the new link road that was never opened forming part of the River Burren Linear walk, and  the Burren linear walk itself,  should all be designated as a high amenity urban area managed for biodiversity and human well-being through the provision of an outdoor space (as is) within a densely populated part of Carlow town.  
• The view of the Barrow Valley, Lugnaquilla and the Wicklow mountains, Mt. Leinster and the Blackstairs Mountains, Brandon Hill and Slievenamon, from the elevated ridge to the west side of the county extending from Killeshin and Rossmore in Laois and Clogrenan in Carlow at the north all the way south to Milebush Cross Roads and Coorleagh should be preserved and afforded protection from development which would hinder the view, especially that at 52.711463, -7.051644, where all of the above can be seen from one point.

Population and Housing

• Include planning provisions for the requirement of environmentally sustainable nest boxes for bats and swifts to encourage urban biodiversity in largescale new developments within the county such as any extensions to the IT Carlow Campus and Technological University, Carlow College St. Patrick’s, any other third level institutions, secondary schools, primary schools, housing estates urban regeneration areas etc with a particular focus on urban areas throughout the county.   

Infrastructure (Water/Wastewater and Environmental Services)

• Include the use of Integrated Constructed Wetlands in the process of wastewater treatment in the upgrade of all existing and the creation of new wastewater treatment plants throughout the county, to include public access for recreation and amenity where possible.  

Tourism

The Carlow Tourism strategy and Action Plan 2020-2025 recommends a marketing proposition for County Carlow as: ‘A home of Irish heritage and culture - where visitors can discover the stories of Carlow people in spectacular houses and gardens, set amidst scenic mountains and picturesque rivers which provide the backdrop for a diverse range of outdoor activities and other historic and nature-based offerings. Experience Ireland’s Ancient East on Dublin’s Doorstep’.

While the marketing proposition acknowledges the natural elements provided by the county in terms of ‘’scenic mountains and picturesque rivers’’, the plan only actually refers to nature once and never actually acknowledges the tourism benefits provided for by biodiversity.

• The County Development plan 2022-2028 needs to acknowledge the contribution of and provide facilities for nature based tourism opportunities in Co. Carlow which are made possible by the very biodiversity which sustains them, including those involved in outdoors pursuits primarily based on enjoying the natural environment of Carlow including hillwalkers, birdwatchers, runners, cyclists etc…

Biodiversity

• Improve the conservation status of all natural heritage designated sites including Special Areas of Conservation and proposed Natural Heritage Areas.
• Designate a Biodiversity officer for county Carlow to help implement the Carlow Town Biodiversity Strategy and Action Plan, The All-Ireland Pollinator Plan and any other biodiversity projects etc and so help improve the status of biodiversity within the county.

Swifts

Background

The Swift is a Red-listed bird of conservation concern in Ireland (Gilbert, Stanbury & Lewis, 2021). Swifts come to Ireland’s towns to breed, arriving in May and departing in August each year. They are faithful to their nest sites returning to the same one for the duration of their life. These are known as traditional nest sites. The swift exists in our towns without causing any public nuisance. There are never any droppings left under the nests (all droppings are removed by adult birds), making them an ideal town inhabitant, especially as they provide a good service by consuming thousands of flying insects. There is no risk of spread of zoonotic disease or spread of disease to domestic livestock/companion animals.

The Countryside Bird Survey has recorded a steady decline in swifts over many years with the swift showing the third steepest decline among all species monitored (Lewis et al, 2020), having declined by over 57% in eighteen years (Lewis et al, 2019). The main cause of this decline is loss of breeding sites (Whelan, Hayes & Caffrey, 2019). They nest in buildings in towns (with all known Carlow nest sites in man-made structures (Webb, 2021). Their traditional nests can usually be found at the top of walls or in cavities in brick work. They gain access to the tops of walls by climbing behind the fascia board. When repairs or renovation work are carried out to roofs and guttering the birds can no longer gain access to their traditional nesting site. Since swifts live in colonies, repair or renovation work can often affect more than one pair of birds. Swifts now rely on the buildings in our towns for their nest sites. In order to secure the future of swifts, we need to ensure that their traditional nest sites are secured where possible, and to provide new nest sites so that the population can recover.

In order to protect and increase swift numbers nest boxes can be installed at suitable locations, generally in public buildings, like schools and universities. These buildings are in public ownership, so the nest boxes are generally safe from disturbance. In private residences nest boxes are sometimes removed if ownership of the residence changes.

Artificial nest boxes can be used very successfully for swifts if they are placed in the correct location. Nest boxes should be at least 4 metres above ground level and placed such that they do not receive full sun in summer. They would generally be placed facing North or East. There must be a clear flyway in front i.e. no trees or other obstacles. The special entrance to the boxes allow swifts to enter, but exclude other species such as starlings.

In-built artificial nesting cavities are swift boxes specifically designed to be built into the fabric of a new building and provide the most sustainable and long term conservation benefits option for swifts as the cavity provides a nest site for the swifts for the duration of the life of the building.  Building in swift boxes may help towards achieving and obtaining the LEED and/or BREEAM building standard for sustainable new construction projects in Ireland.

In addition to the nest boxes installation, a swift attraction call system must also be installed. Speed of occupancy of a nest box can be considerably accelerated by playing swift attraction calls. The attraction calls make the swift think that other swifts are nesting in this location and so indicate that this is an attractive place to breed. Any swift looking for a nest site will explore this area for a vacant place. The sound system should be placed as near as possible to the nest boxes e.g. on a window sill or attached to the box. Swift attraction calls only need to be used until the swifts take up occupancy. Swift attraction calls are operated on a timer - so it doesn’t play continuously and can be set to operate outside of work hours.

Carlow Town Biodiversity Strategy and Action Plan 2021-2025. 

2.3 Flagship Project 3- Save our Swifts

One of the Flagship Projects (3) identified as part of the plan is 'Save our Swifts'.  4 actions have been listed under the Save our Swifts project. All these actions as proposed should be implemented. Additional actions which are not included but which should be enacted going forward under the Biodiversity Strategy and Action Plan and as part of the Carlow County Development Plan 2022-2028 include:

• Commission Birdwatch Ireland and the Heritage Council of Ireland to complete a swift survey of County Carlow as a whole including the Greater Carlow Graiguecullen Urban area, all towns and villages, and rural and urban heritage sites to identify all known nesting sites within the county and protect them from inappropriate development which would result in the loss of a nesting site.
• Provide a workshop for architects, planners, heritage officer, etc. to raise awareness of the need to take Swifts into consideration in projects to refurbish old buildings and in new constructions.
• Physically build in Swift boxes to new buildings within the town and county which will provide permanent security for Swift nests into the future. 
• Include planning provisions for the requirement of environmentally sustainable in-built nest boxes for bats and swifts to encourage urban biodiversity in largescale new developments within the county such as any extensions to the IT Carlow Campus and Technological University, Carlow College St. Patrick’s, any other third level institutions, secondary schools and primary schools with a particular focus on urban areas.

• Legal protection of existing swift colonies in public and council owned buildings.

• Buildings which are of natural and cultural heritage importance for the preservation of swift nest sites which should be afforded protection include The Carlow Youth Centre (Glendale Avenue, Carlow Town), Carlow College St. Patrick’s, St. Dympna’s Hospital, Old Perry’s Cash and Carry (Kennedy Street, Carlow Town), Leinster Crescent (Dublin Road, Carlow Town), Cullen’s Mill (Leighlinbridge), The Old Mill (Church Street, Leighlinbridge), The Black Castle (Leighlinbridge), Old National School (Ballon), Altamont Gardens Stone Farm Outhouses, Saint Columba’s National School (Tullow), Scoil Phádraig Naofa (Tullow), St. Brigid’s Church (Clonegal).

This is now more important than ever in the midst of a Climate and Biodiversity Emergency, as Swifts are now Red-listed birds of conservation concern having declined by over 57% in eighteen years (Lewis et al, 2019), with all known Carlow nest sites in man-made structures (Webb, 2021). 

• Support the establishment of the Greater Carlow Graiguecullen Urban area as a ‘Swift City’ to be the first of its kind in the Republic of Ireland following the lead of the Belfast Swift city initiative, the first of its kind in the world, which will help promote the conservation work being undertaken for this species and other biodiversity within Carlow and provide for the increase in numbers of swifts further promoting nature based tourism opportunities within Carlow.

Peatlands

• Provide for the protection of non-statutory listed but nonetheless natural heritage sites of biodiversity, conservation and cultural heritage importance, including but not limited to the Drummin Bog and Boolyvanannan/Red Bog at Tomard upper. 

Tomard wood is a conifer plantation owned by Coillte in the northwest of Carlow. This woods borders the Red Bog or Boolyvannanan Bog. Historically turf was cut on this bog which has since ceased and conifers have been planted right up to the high bog. The bog immediately borders Coillte lands and may even lie within the lands owned by Coillte. A private conifer plantation borders the other side of the bog where Bilboa windfarm is currently planned. 

There are Marsh Fritillary ((Habitats Directive (92/43/EEC), Annex II, Convention on the Conservation of European Wildlife and Natural Habitats (Bern Convention) Appendix II) butterflies present around the bog with breeding confirmed within close proximity to the high bog on previously cutover and planted Coillte lands. Historically, locals remember Red Grouse (Birds of Conservation Concern (BOCCI- Red List, EU Birds Directive - Protected Species Annex II, Section I,  Annex III, Section I) present in the area while Golden Plover (BOCCI - Red List, EU Birds Directive - Protected Species Annex I), Common Snipe, Woodcock, Swifts, Kestrel (all BOCCI - Red List) are regularly seen in the area. There are recent historical records of Hen Harrier (BOCCI - Amber List, EU Birds Directive - Protected Species Annex I) in the area too.

Coillte natures mission includes:

Restoring important biodiversity areas by investing in major habitat improvements 

Rehabilitating ecosystem services by bringing sensitive or degraded lands into better health  

Peatland environments are rare in Carlow especially in the west of the county. There is an opportunity for Carlow County Council under the new development plan and Coillte being a large landowner in the area to bring about positive change in this area restoring lost biodiversity and sequestering carbon emissions through bog rehabilitation. 

• I would like to see an active effort by the council and Coillte in this area to help restore native biodiversity to this bog and help rehabilitate the site. Communication and cooperation between the county council and Coillte with adjoining landowners and the planned Bilboa windfarm project, but perhaps most importantly the local community, could help bring about positive change for the benefit of the environment and the preservation of both our cultural and natural heritage in the midst of a climate and biodiversity emergency. 

Examples of management could include keeping conifers back from the bog and efforts made to restore the water holding capacity of the peatland environment. Encroaching spruce should be removed. Habitat management for Devil's -bit Scabious the foodplant of the Marsh Fritillary. 

All-Ireland Pollinator Plan

• Enact the all-Ireland Pollinator plan on public lands to include but not limited to public parks, public roads (roundabouts, road verges), public buildings and grounds (Duckett’s Grove etc where possible.

Invasive Species

• Survey and implement a plan to remove all invasive alien species (including Himalayan Balsam, Japanese Knotweed, Winter Heliotrope etc…) from our native waterways which are currently contributing to the decline of native biodiversity here and the very structural integrity of our waterways.

Flood Protection

• Ensure the protection of the river Barrow floodplains which currently provide annual flood attenuation relief for Carlow Town, Leighlinbridge, Bagenalstown, Goresbridge, Borris and Graiguenamanagh while also providing seasonal habitat for nationally important wintering numbers of wetland birds such as Golden Plover (Red-listed and Annex I) and Lapwing (Red-listed), allowing the river to maintain its current flooding patterns. This will require careful consideration of any development within the footprint of the river and Special Area of Conservation.
• Assess the feasibility of providing financial relief (acknowledgement) to landowners whose lands are periodically flooded providing this flood attenuation relief (for the residents of the Barrow valley) and biodiversity resource without the need for any infrastructural flood relief developments.
• The use of natural flood mitigation strategies over hard infrastructure with a view to providing habitats for wildlife while protecting human livelihoods and centres of urban conurbations.

Barrow Track

• No further development of the Barrow Blueway idea. Maintain the Barrow towpath as is and has functioned for the past 100 plus years as a natural vegetation riverbank walkway.
• The track itself provides habitat for many floral species as well as feeding opportunities for protected avian waterbird species such as Snipe (Red-listed), Green Sandpiper, Grey Heron, Little Egret, Moorhen, Little Grebe as well as otters which cannot feed on a manmade gravel, grit, tarmac or similar surface. 

References

Webb, P., 2021. A survey of Swift (Apus apus) nesting sites in county Carlow 2018/19/20. [pdf] Available at: < https://www.swiftconservation.ie/wp-content/uploads/2021/03/Co.-Carlow-Swift-Report-2018_2019_2020-1.pdf >

Lewis, L. J., Coombes, D., Burke, B., O’Halloran, J., Walsh, A., Tierney, T. D. & Cummins, S. (2019) Countryside Bird Survey: Status and trends of common and widespread breeding birds 1998-2016. Irish Wildlife Manuals, No. 115. National Parks and Wildlife Service, Department of Culture, Heritage and the Gaeltacht, Ireland.

Gilbert G., Stanbury, A. and Lewis, L., 2021. “Birds of Conservation Concern in Ireland 2020 –2026”. Irish Birds 9: 523—544

Lewis, L. J., Coombes, R, H., Burke, B., Tierney, T. D., Cummins, S., Walsh, A. J., Ryan, N. & O’Halloran, J., 2020. Countryside Bird Survey Report 1998-2019. BirdWatch Ireland. Wicklow.

Whelan, R., Hayes, W. & Caffrey, B., 2019. Saving Swifts. Publication funded by The Department of Culture, Heritage and the Gaeltacht through the National Parks and Wildlife Service’s National Biodiversity Action Plan Fund.

Scott Cawley, 2021. Carlow Town Biodiversity Strategy & Action Plan 2021-2025.  Carlow County Council, Carlow Town Development Forum, Department of Housing, Local Government and Heritage.

Future Analytics, 2020. County Carlow Tourism Strategy and Action Plan 2020-2025. Carlow Tourism, Carlow County Council.

Dear Sir/Madam,

In the midst of a Biodiversity and Climate emergency the suggestions made below in indented bold italics will show how natural heritage and biodiversity can be conserved and enhanced going forward along with sustainable development in both urban and rural areas .

Green Infrastructure/ Regeneration Strategy

The Carlow County Development Plan review will ‘’deal with biodiversity and environmental protection’’……, it refers to the United Nations sustainable development goals including goal 15 which aims to ‘’ Protect, restore and promote sustainable use of terrestrial ecosystems, sustainably manage forests, combat desertification, and halt and reverse land degradation and halt biodiversity loss’’, it acknowledges the role of heritage in promoting biodiversity.

Project Carlow 2040 acknowledges the benefits of biodiversity, particularly in an urban setting. It includes enhancing biodiversity resources under its sustainability principles for development going forward.

''Urban policy-makers have increasingly been exploring the links between urban planning and public health, specifically in relation to the potential for urban environments to have positive impacts on health outcomes and healthy lifestyles, such as through.....access to ‘nature’/biodiversity''.

''These health services are understood to range from direct positive effects on mental and physical health from increased biodiversity, to improved well-being resulting from increased exposure to nature'' 

''Supports biodiversity initiatives in the Town Centre.''

''Encouraging biodiversity within the public realm.''  

''Integrating unique amenity and biodiversity spaces into the urban fabric''.  

''Protect and enhance Carlow Town’s unique biodiversity''

‘’Maintaining, enhancing and protecting healthy air and water and enhancing biodiversity resources’’

• These benefits of biodiversity also need to be acknowledged in the Carlow County Development Plan 2022-2028 such that developments/initiatives contributing to such biodiversity and human health and well-being are adequately funded, resourced and acknowledged and that biodiversity is protected and conserved.
• Swifts form an integral part of this urban biodiversity and must be conserved with a view to including provisions for in built boxes in developments going forward as part of the plan. 
• In built Swift boxes should be included in any new developments at the IT Carlow Campus.

Project Ireland 2040 also acknowledges the benefit of green infrastructure ….

(’’ 3. Takes space back into the public realm

In the first instance, Carlow County Council plan to deliver more public space, with the aim to encourage more people to spend more time outdoors. Carlow County Council also plans to make public space more responsive to the needs of those who use it. This Strategy seeks to provide plentiful, accessible and exciting public spaces in Carlow Town that are filled with people all day and all year round, providing a fundamental element of urban life. Extended and new riverside pedestrian routes, open spaces, and activities all connected by greatly improved pedestrian/cyclist networks will support this concept alongside a focus on green infrastructure, where Carlow will seek to find economic opportunities in the greening process. Overall, improving the quality and enhancing the accessibility to public open spaces will result in multiple benefits including health and wellbeing as well as sustainable transport, biodiversity and recreation.’’)

The current draft county development plan acknowledges the biodiversity benefits of Green Infrastructure; namely ‘’ • Improved habitats for wildlife • Provision of ecological corridors • Landscape permeability • Reducing habitat fragmentation • Providing a buffer against climate change for habitats and species’’

• We must ensure that any further ‘’Green Infrastructure’’ development within Carlow does not contradict any of these biodiversity benefits.
• We must acknowledge and protect existing green spaces currently providing for and fulfilling the role of Green Infrastructure.
• Existing urban areas within Carlow town which need to be protected from unsuitable developments and acknowledged as currently providing green infrastructure which supports biodiversity and human well-being in open green spaces in an urban environment include those listed below; Green spaces around the old Youth Centre and Castle Rangers FC, Green Space behind/ south of New Oak Boys AFC, Green space east of Eire Og football grounds, Link road south of River Burren and surrounding woods and scrub areas which was never opened, Green Space River Burren Linear walk between railway bridge and new link road that was never opened, River Barrow Tow path full length of county.
• The green space area east of Eire Og, the link road south of the river Burren and surrounding woods and scrub areas which was never opened, the green space between the railway bridge and the new link road that was never opened forming part of the River Burren Linear walk, and  the Burren linear walk itself,  should all be designated as a high amenity urban area managed for biodiversity and human well-being through the provision of an outdoor space (as is) within a densely populated part of Carlow town.  
• The view of the Barrow Valley, Lugnaquilla and the Wicklow mountains, Mt. Leinster and the Blackstairs Mountains, Brandon Hill and Slievenamon, from the elevated ridge to the west side of the county extending from Killeshin and Rossmore in Laois and Clogrenan in Carlow at the north all the way south to Milebush Cross Roads and Coorleagh should be preserved and afforded protection from development which would hinder the view, especially that at 52.711463, -7.051644, where all of the above can be seen from one point.

Population and Housing

• Include planning provisions for the requirement of environmentally sustainable nest boxes for bats and swifts to encourage urban biodiversity in largescale new developments within the county such as any extensions to the IT Carlow Campus and Technological University, Carlow College St. Patrick’s, any other third level institutions, secondary schools, primary schools, housing estates urban regeneration areas etc with a particular focus on urban areas throughout the county.   

Infrastructure (Water/Wastewater and Environmental Services)

• Include the use of Integrated Constructed Wetlands in the process of wastewater treatment in the upgrade of all existing and the creation of new wastewater treatment plants throughout the county, to include public access for recreation and amenity where possible.  

Tourism

The Carlow Tourism strategy and Action Plan 2020-2025 recommends a marketing proposition for County Carlow as: ‘A home of Irish heritage and culture - where visitors can discover the stories of Carlow people in spectacular houses and gardens, set amidst scenic mountains and picturesque rivers which provide the backdrop for a diverse range of outdoor activities and other historic and nature-based offerings. Experience Ireland’s Ancient East on Dublin’s Doorstep’.

While the marketing proposition acknowledges the natural elements provided by the county in terms of ‘’scenic mountains and picturesque rivers’’, the plan only actually refers to nature once and never actually acknowledges the tourism benefits provided for by biodiversity.

• The County Development plan 2022-2028 needs to acknowledge the contribution of and provide facilities for nature based tourism opportunities in Co. Carlow which are made possible by the very biodiversity which sustains them, including those involved in outdoors pursuits primarily based on enjoying the natural environment of Carlow including hillwalkers, birdwatchers, runners, cyclists etc…

Biodiversity

• Improve the conservation status of all natural heritage designated sites including Special Areas of Conservation and proposed Natural Heritage Areas.
• Designate a Biodiversity officer for county Carlow to help implement the Carlow Town Biodiversity Strategy and Action Plan, The All-Ireland Pollinator Plan and any other biodiversity projects etc and so help improve the status of biodiversity within the county.

Swifts

Background

The Swift is a Red-listed bird of conservation concern in Ireland (Gilbert, Stanbury & Lewis, 2021). Swifts come to Ireland’s towns to breed, arriving in May and departing in August each year. They are faithful to their nest sites returning to the same one for the duration of their life. These are known as traditional nest sites. The swift exists in our towns without causing any public nuisance. There are never any droppings left under the nests (all droppings are removed by adult birds), making them an ideal town inhabitant, especially as they provide a good service by consuming thousands of flying insects. There is no risk of spread of zoonotic disease or spread of disease to domestic livestock/companion animals.

The Countryside Bird Survey has recorded a steady decline in swifts over many years with the swift showing the third steepest decline among all species monitored (Lewis et al, 2020), having declined by over 57% in eighteen years (Lewis et al, 2019). The main cause of this decline is loss of breeding sites (Whelan, Hayes & Caffrey, 2019). They nest in buildings in towns (with all known Carlow nest sites in man-made structures (Webb, 2021). Their traditional nests can usually be found at the top of walls or in cavities in brick work. They gain access to the tops of walls by climbing behind the fascia board. When repairs or renovation work are carried out to roofs and guttering the birds can no longer gain access to their traditional nesting site. Since swifts live in colonies, repair or renovation work can often affect more than one pair of birds. Swifts now rely on the buildings in our towns for their nest sites. In order to secure the future of swifts, we need to ensure that their traditional nest sites are secured where possible, and to provide new nest sites so that the population can recover.

In order to protect and increase swift numbers nest boxes can be installed at suitable locations, generally in public buildings, like schools and universities. These buildings are in public ownership, so the nest boxes are generally safe from disturbance. In private residences nest boxes are sometimes removed if ownership of the residence changes.

Artificial nest boxes can be used very successfully for swifts if they are placed in the correct location. Nest boxes should be at least 4 metres above ground level and placed such that they do not receive full sun in summer. They would generally be placed facing North or East. There must be a clear flyway in front i.e. no trees or other obstacles. The special entrance to the boxes allow swifts to enter, but exclude other species such as starlings.

In-built artificial nesting cavities are swift boxes specifically designed to be built into the fabric of a new building and provide the most sustainable and long term conservation benefits option for swifts as the cavity provides a nest site for the swifts for the duration of the life of the building.  Building in swift boxes may help towards achieving and obtaining the LEED and/or BREEAM building standard for sustainable new construction projects in Ireland.

In addition to the nest boxes installation, a swift attraction call system must also be installed. Speed of occupancy of a nest box can be considerably accelerated by playing swift attraction calls. The attraction calls make the swift think that other swifts are nesting in this location and so indicate that this is an attractive place to breed. Any swift looking for a nest site will explore this area for a vacant place. The sound system should be placed as near as possible to the nest boxes e.g. on a window sill or attached to the box. Swift attraction calls only need to be used until the swifts take up occupancy. Swift attraction calls are operated on a timer - so it doesn’t play continuously and can be set to operate outside of work hours.

Carlow Town Biodiversity Strategy and Action Plan 2021-2025. 

2.3 Flagship Project 3- Save our Swifts

One of the Flagship Projects (3) identified as part of the plan is 'Save our Swifts'.  4 actions have been listed under the Save our Swifts project. All these actions as proposed should be implemented. Additional actions which are not included but which should be enacted going forward under the Biodiversity Strategy and Action Plan and as part of the Carlow County Development Plan 2022-2028 include:

• Commission Birdwatch Ireland and the Heritage Council of Ireland to complete a swift survey of County Carlow as a whole including the Greater Carlow Graiguecullen Urban area, all towns and villages, and rural and urban heritage sites to identify all known nesting sites within the county and protect them from inappropriate development which would result in the loss of a nesting site.
• Provide a workshop for architects, planners, heritage officer, etc. to raise awareness of the need to take Swifts into consideration in projects to refurbish old buildings and in new constructions.
• Physically build in Swift boxes to new buildings within the town and county which will provide permanent security for Swift nests into the future. 
• Include planning provisions for the requirement of environmentally sustainable in-built nest boxes for bats and swifts to encourage urban biodiversity in largescale new developments within the county such as any extensions to the IT Carlow Campus and Technological University, Carlow College St. Patrick’s, any other third level institutions, secondary schools and primary schools with a particular focus on urban areas.

• Legal protection of existing swift colonies in public and council owned buildings.

• Buildings which are of natural and cultural heritage importance for the preservation of swift nest sites which should be afforded protection include The Carlow Youth Centre (Glendale Avenue, Carlow Town), Carlow College St. Patrick’s, St. Dympna’s Hospital, Old Perry’s Cash and Carry (Kennedy Street, Carlow Town), Leinster Crescent (Dublin Road, Carlow Town), Cullen’s Mill (Leighlinbridge), The Old Mill (Church Street, Leighlinbridge), The Black Castle (Leighlinbridge), Old National School (Ballon), Altamont Gardens Stone Farm Outhouses, Saint Columba’s National School (Tullow), Scoil Phádraig Naofa (Tullow), St. Brigid’s Church (Clonegal).

This is now more important than ever in the midst of a Climate and Biodiversity Emergency, as Swifts are now Red-listed birds of conservation concern having declined by over 57% in eighteen years (Lewis et al, 2019), with all known Carlow nest sites in man-made structures (Webb, 2021). 

• Support the establishment of the Greater Carlow Graiguecullen Urban area as a ‘Swift City’ to be the first of its kind in the Republic of Ireland following the lead of the Belfast Swift city initiative, the first of its kind in the world, which will help promote the conservation work being undertaken for this species and other biodiversity within Carlow and provide for the increase in numbers of swifts further promoting nature based tourism opportunities within Carlow.

Peatlands

• Provide for the protection of non-statutory listed but nonetheless natural heritage sites of biodiversity, conservation and cultural heritage importance, including but not limited to the Drummin Bog and Boolyvanannan/Red Bog at Tomard upper. 

Tomard wood is a conifer plantation owned by Coillte in the northwest of Carlow. This woods borders the Red Bog or Boolyvannanan Bog. Historically turf was cut on this bog which has since ceased and conifers have been planted right up to the high bog. The bog immediately borders Coillte lands and may even lie within the lands owned by Coillte. A private conifer plantation borders the other side of the bog where Bilboa windfarm is currently planned. 

There are Marsh Fritillary ((Habitats Directive (92/43/EEC), Annex II, Convention on the Conservation of European Wildlife and Natural Habitats (Bern Convention) Appendix II) butterflies present around the bog with breeding confirmed within close proximity to the high bog on previously cutover and planted Coillte lands. Historically, locals remember Red Grouse (Birds of Conservation Concern (BOCCI- Red List, EU Birds Directive - Protected Species Annex II, Section I,  Annex III, Section I) present in the area while Golden Plover (BOCCI - Red List, EU Birds Directive - Protected Species Annex I), Common Snipe, Woodcock, Swifts, Kestrel (all BOCCI - Red List) are regularly seen in the area. There are recent historical records of Hen Harrier (BOCCI - Amber List, EU Birds Directive - Protected Species Annex I) in the area too.

Coillte natures mission includes:

Restoring important biodiversity areas by investing in major habitat improvements 

Rehabilitating ecosystem services by bringing sensitive or degraded lands into better health  

Peatland environments are rare in Carlow especially in the west of the county. There is an opportunity for Carlow County Council under the new development plan and Coillte being a large landowner in the area to bring about positive change in this area restoring lost biodiversity and sequestering carbon emissions through bog rehabilitation. 

• I would like to see an active effort by the council and Coillte in this area to help restore native biodiversity to this bog and help rehabilitate the site. Communication and cooperation between the county council and Coillte with adjoining landowners and the planned Bilboa windfarm project, but perhaps most importantly the local community, could help bring about positive change for the benefit of the environment and the preservation of both our cultural and natural heritage in the midst of a climate and biodiversity emergency. 

Examples of management could include keeping conifers back from the bog and efforts made to restore the water holding capacity of the peatland environment. Encroaching spruce should be removed. Habitat management for Devil's -bit Scabious the foodplant of the Marsh Fritillary. 

All-Ireland Pollinator Plan

• Enact the all-Ireland Pollinator plan on public lands to include but not limited to public parks, public roads (roundabouts, road verges), public buildings and grounds (Duckett’s Grove etc where possible.

Invasive Species

• Survey and implement a plan to remove all invasive alien species (including Himalayan Balsam, Japanese Knotweed, Winter Heliotrope etc…) from our native waterways which are currently contributing to the decline of native biodiversity here and the very structural integrity of our waterways.

Flood Protection

• Ensure the protection of the river Barrow floodplains which currently provide annual flood attenuation relief for Carlow Town, Leighlinbridge, Bagenalstown, Goresbridge, Borris and Graiguenamanagh while also providing seasonal habitat for nationally important wintering numbers of wetland birds such as Golden Plover (Red-listed and Annex I) and Lapwing (Red-listed), allowing the river to maintain its current flooding patterns. This will require careful consideration of any development within the footprint of the river and Special Area of Conservation.
• Assess the feasibility of providing financial relief (acknowledgement) to landowners whose lands are periodically flooded providing this flood attenuation relief (for the residents of the Barrow valley) and biodiversity resource without the need for any infrastructural flood relief developments.
• The use of natural flood mitigation strategies over hard infrastructure with a view to providing habitats for wildlife while protecting human livelihoods and centres of urban conurbations.

Barrow Track

• No further development of the Barrow Blueway idea. Maintain the Barrow towpath as is and has functioned for the past 100 plus years as a natural vegetation riverbank walkway.
• The track itself provides habitat for many floral species as well as feeding opportunities for protected avian waterbird species such as Snipe (Red-listed), Green Sandpiper, Grey Heron, Little Egret, Moorhen, Little Grebe as well as otters which cannot feed on a manmade gravel, grit, tarmac or similar surface. 

References

Webb, P., 2021. A survey of Swift (Apus apus) nesting sites in county Carlow 2018/19/20. [pdf] Available at: < https://www.swiftconservation.ie/wp-content/uploads/2021/03/Co.-Carlow-Swift-Report-2018_2019_2020-1.pdf >

Lewis, L. J., Coombes, D., Burke, B., O’Halloran, J., Walsh, A., Tierney, T. D. & Cummins, S. (2019) Countryside Bird Survey: Status and trends of common and widespread breeding birds 1998-2016. Irish Wildlife Manuals, No. 115. National Parks and Wildlife Service, Department of Culture, Heritage and the Gaeltacht, Ireland.

Gilbert G., Stanbury, A. and Lewis, L., 2021. “Birds of Conservation Concern in Ireland 2020 –2026”. Irish Birds 9: 523—544

Lewis, L. J., Coombes, R, H., Burke, B., Tierney, T. D., Cummins, S., Walsh, A. J., Ryan, N. & O’Halloran, J., 2020. Countryside Bird Survey Report 1998-2019. BirdWatch Ireland. Wicklow.

Whelan, R., Hayes, W. & Caffrey, B., 2019. Saving Swifts. Publication funded by The Department of Culture, Heritage and the Gaeltacht through the National Parks and Wildlife Service’s National Biodiversity Action Plan Fund.

Scott Cawley, 2021. Carlow Town Biodiversity Strategy & Action Plan 2021-2025.  Carlow County Council, Carlow Town Development Forum, Department of Housing, Local Government and Heritage.

Future Analytics, 2020. County Carlow Tourism Strategy and Action Plan 2020-2025. Carlow Tourism, Carlow County Council.

Dear Sir/Madam,

In the midst of a Biodiversity and Climate emergency the suggestions made below in indented bold italics will show how natural heritage and biodiversity can be conserved and enhanced going forward along with sustainable development in both urban and rural areas .

Green Infrastructure/ Regeneration Strategy

The Carlow County Development Plan review will ‘’deal with biodiversity and environmental protection’’……, it refers to the United Nations sustainable development goals including goal 15 which aims to ‘’ Protect, restore and promote sustainable use of terrestrial ecosystems, sustainably manage forests, combat desertification, and halt and reverse land degradation and halt biodiversity loss’’, it acknowledges the role of heritage in promoting biodiversity.

Project Carlow 2040 acknowledges the benefits of biodiversity, particularly in an urban setting. It includes enhancing biodiversity resources under its sustainability principles for development going forward.

''Urban policy-makers have increasingly been exploring the links between urban planning and public health, specifically in relation to the potential for urban environments to have positive impacts on health outcomes and healthy lifestyles, such as through.....access to ‘nature’/biodiversity''.

''These health services are understood to range from direct positive effects on mental and physical health from increased biodiversity, to improved well-being resulting from increased exposure to nature'' 

''Supports biodiversity initiatives in the Town Centre.''

''Encouraging biodiversity within the public realm.''  

''Integrating unique amenity and biodiversity spaces into the urban fabric''.  

''Protect and enhance Carlow Town’s unique biodiversity''

‘’Maintaining, enhancing and protecting healthy air and water and enhancing biodiversity resources’’

• These benefits of biodiversity also need to be acknowledged in the Carlow County Development Plan 2022-2028 such that developments/initiatives contributing to such biodiversity and human health and well-being are adequately funded, resourced and acknowledged and that biodiversity is protected and conserved.
• Swifts form an integral part of this urban biodiversity and must be conserved with a view to including provisions for in built boxes in developments going forward as part of the plan. 
• In built Swift boxes should be included in any new developments at the IT Carlow Campus.

Project Ireland 2040 also acknowledges the benefit of green infrastructure ….

(’’ 3. Takes space back into the public realm

In the first instance, Carlow County Council plan to deliver more public space, with the aim to encourage more people to spend more time outdoors. Carlow County Council also plans to make public space more responsive to the needs of those who use it. This Strategy seeks to provide plentiful, accessible and exciting public spaces in Carlow Town that are filled with people all day and all year round, providing a fundamental element of urban life. Extended and new riverside pedestrian routes, open spaces, and activities all connected by greatly improved pedestrian/cyclist networks will support this concept alongside a focus on green infrastructure, where Carlow will seek to find economic opportunities in the greening process. Overall, improving the quality and enhancing the accessibility to public open spaces will result in multiple benefits including health and wellbeing as well as sustainable transport, biodiversity and recreation.’’)

The current draft county development plan acknowledges the biodiversity benefits of Green Infrastructure; namely ‘’ • Improved habitats for wildlife • Provision of ecological corridors • Landscape permeability • Reducing habitat fragmentation • Providing a buffer against climate change for habitats and species’’

• We must ensure that any further ‘’Green Infrastructure’’ development within Carlow does not contradict any of these biodiversity benefits.
• We must acknowledge and protect existing green spaces currently providing for and fulfilling the role of Green Infrastructure.
• Existing urban areas within Carlow town which need to be protected from unsuitable developments and acknowledged as currently providing green infrastructure which supports biodiversity and human well-being in open green spaces in an urban environment include those listed below; Green spaces around the old Youth Centre and Castle Rangers FC, Green Space behind/ south of New Oak Boys AFC, Green space east of Eire Og football grounds, Link road south of River Burren and surrounding woods and scrub areas which was never opened, Green Space River Burren Linear walk between railway bridge and new link road that was never opened, River Barrow Tow path full length of county.
• The green space area east of Eire Og, the link road south of the river Burren and surrounding woods and scrub areas which was never opened, the green space between the railway bridge and the new link road that was never opened forming part of the River Burren Linear walk, and  the Burren linear walk itself,  should all be designated as a high amenity urban area managed for biodiversity and human well-being through the provision of an outdoor space (as is) within a densely populated part of Carlow town.  
• The view of the Barrow Valley, Lugnaquilla and the Wicklow mountains, Mt. Leinster and the Blackstairs Mountains, Brandon Hill and Slievenamon, from the elevated ridge to the west side of the county extending from Killeshin and Rossmore in Laois and Clogrenan in Carlow at the north all the way south to Milebush Cross Roads and Coorleagh should be preserved and afforded protection from development which would hinder the view, especially that at 52.711463, -7.051644, where all of the above can be seen from one point.

Population and Housing

• Include planning provisions for the requirement of environmentally sustainable nest boxes for bats and swifts to encourage urban biodiversity in largescale new developments within the county such as any extensions to the IT Carlow Campus and Technological University, Carlow College St. Patrick’s, any other third level institutions, secondary schools, primary schools, housing estates urban regeneration areas etc with a particular focus on urban areas throughout the county.   

Infrastructure (Water/Wastewater and Environmental Services)

• Include the use of Integrated Constructed Wetlands in the process of wastewater treatment in the upgrade of all existing and the creation of new wastewater treatment plants throughout the county, to include public access for recreation and amenity where possible.  

Tourism

The Carlow Tourism strategy and Action Plan 2020-2025 recommends a marketing proposition for County Carlow as: ‘A home of Irish heritage and culture - where visitors can discover the stories of Carlow people in spectacular houses and gardens, set amidst scenic mountains and picturesque rivers which provide the backdrop for a diverse range of outdoor activities and other historic and nature-based offerings. Experience Ireland’s Ancient East on Dublin’s Doorstep’.

While the marketing proposition acknowledges the natural elements provided by the county in terms of ‘’scenic mountains and picturesque rivers’’, the plan only actually refers to nature once and never actually acknowledges the tourism benefits provided for by biodiversity.

• The County Development plan 2022-2028 needs to acknowledge the contribution of and provide facilities for nature based tourism opportunities in Co. Carlow which are made possible by the very biodiversity which sustains them, including those involved in outdoors pursuits primarily based on enjoying the natural environment of Carlow including hillwalkers, birdwatchers, runners, cyclists etc…

Biodiversity

• Improve the conservation status of all natural heritage designated sites including Special Areas of Conservation and proposed Natural Heritage Areas.
• Designate a Biodiversity officer for county Carlow to help implement the Carlow Town Biodiversity Strategy and Action Plan, The All-Ireland Pollinator Plan and any other biodiversity projects etc and so help improve the status of biodiversity within the county.

Swifts

Background

The Swift is a Red-listed bird of conservation concern in Ireland (Gilbert, Stanbury & Lewis, 2021). Swifts come to Ireland’s towns to breed, arriving in May and departing in August each year. They are faithful to their nest sites returning to the same one for the duration of their life. These are known as traditional nest sites. The swift exists in our towns without causing any public nuisance. There are never any droppings left under the nests (all droppings are removed by adult birds), making them an ideal town inhabitant, especially as they provide a good service by consuming thousands of flying insects. There is no risk of spread of zoonotic disease or spread of disease to domestic livestock/companion animals.

The Countryside Bird Survey has recorded a steady decline in swifts over many years with the swift showing the third steepest decline among all species monitored (Lewis et al, 2020), having declined by over 57% in eighteen years (Lewis et al, 2019). The main cause of this decline is loss of breeding sites (Whelan, Hayes & Caffrey, 2019). They nest in buildings in towns (with all known Carlow nest sites in man-made structures (Webb, 2021). Their traditional nests can usually be found at the top of walls or in cavities in brick work. They gain access to the tops of walls by climbing behind the fascia board. When repairs or renovation work are carried out to roofs and guttering the birds can no longer gain access to their traditional nesting site. Since swifts live in colonies, repair or renovation work can often affect more than one pair of birds. Swifts now rely on the buildings in our towns for their nest sites. In order to secure the future of swifts, we need to ensure that their traditional nest sites are secured where possible, and to provide new nest sites so that the population can recover.

In order to protect and increase swift numbers nest boxes can be installed at suitable locations, generally in public buildings, like schools and universities. These buildings are in public ownership, so the nest boxes are generally safe from disturbance. In private residences nest boxes are sometimes removed if ownership of the residence changes.

Artificial nest boxes can be used very successfully for swifts if they are placed in the correct location. Nest boxes should be at least 4 metres above ground level and placed such that they do not receive full sun in summer. They would generally be placed facing North or East. There must be a clear flyway in front i.e. no trees or other obstacles. The special entrance to the boxes allow swifts to enter, but exclude other species such as starlings.

In-built artificial nesting cavities are swift boxes specifically designed to be built into the fabric of a new building and provide the most sustainable and long term conservation benefits option for swifts as the cavity provides a nest site for the swifts for the duration of the life of the building.  Building in swift boxes may help towards achieving and obtaining the LEED and/or BREEAM building standard for sustainable new construction projects in Ireland.

In addition to the nest boxes installation, a swift attraction call system must also be installed. Speed of occupancy of a nest box can be considerably accelerated by playing swift attraction calls. The attraction calls make the swift think that other swifts are nesting in this location and so indicate that this is an attractive place to breed. Any swift looking for a nest site will explore this area for a vacant place. The sound system should be placed as near as possible to the nest boxes e.g. on a window sill or attached to the box. Swift attraction calls only need to be used until the swifts take up occupancy. Swift attraction calls are operated on a timer - so it doesn’t play continuously and can be set to operate outside of work hours.

Carlow Town Biodiversity Strategy and Action Plan 2021-2025. 

2.3 Flagship Project 3- Save our Swifts

One of the Flagship Projects (3) identified as part of the plan is 'Save our Swifts'.  4 actions have been listed under the Save our Swifts project. All these actions as proposed should be implemented. Additional actions which are not included but which should be enacted going forward under the Biodiversity Strategy and Action Plan and as part of the Carlow County Development Plan 2022-2028 include:

• Commission Birdwatch Ireland and the Heritage Council of Ireland to complete a swift survey of County Carlow as a whole including the Greater Carlow Graiguecullen Urban area, all towns and villages, and rural and urban heritage sites to identify all known nesting sites within the county and protect them from inappropriate development which would result in the loss of a nesting site.
• Provide a workshop for architects, planners, heritage officer, etc. to raise awareness of the need to take Swifts into consideration in projects to refurbish old buildings and in new constructions.
• Physically build in Swift boxes to new buildings within the town and county which will provide permanent security for Swift nests into the future. 
• Include planning provisions for the requirement of environmentally sustainable in-built nest boxes for bats and swifts to encourage urban biodiversity in largescale new developments within the county such as any extensions to the IT Carlow Campus and Technological University, Carlow College St. Patrick’s, any other third level institutions, secondary schools and primary schools with a particular focus on urban areas.

• Legal protection of existing swift colonies in public and council owned buildings.

• Buildings which are of natural and cultural heritage importance for the preservation of swift nest sites which should be afforded protection include The Carlow Youth Centre (Glendale Avenue, Carlow Town), Carlow College St. Patrick’s, St. Dympna’s Hospital, Old Perry’s Cash and Carry (Kennedy Street, Carlow Town), Leinster Crescent (Dublin Road, Carlow Town), Cullen’s Mill (Leighlinbridge), The Old Mill (Church Street, Leighlinbridge), The Black Castle (Leighlinbridge), Old National School (Ballon), Altamont Gardens Stone Farm Outhouses, Saint Columba’s National School (Tullow), Scoil Phádraig Naofa (Tullow), St. Brigid’s Church (Clonegal).

This is now more important than ever in the midst of a Climate and Biodiversity Emergency, as Swifts are now Red-listed birds of conservation concern having declined by over 57% in eighteen years (Lewis et al, 2019), with all known Carlow nest sites in man-made structures (Webb, 2021). 

• Support the establishment of the Greater Carlow Graiguecullen Urban area as a ‘Swift City’ to be the first of its kind in the Republic of Ireland following the lead of the Belfast Swift city initiative, the first of its kind in the world, which will help promote the conservation work being undertaken for this species and other biodiversity within Carlow and provide for the increase in numbers of swifts further promoting nature based tourism opportunities within Carlow.

Peatlands

• Provide for the protection of non-statutory listed but nonetheless natural heritage sites of biodiversity, conservation and cultural heritage importance, including but not limited to the Drummin Bog and Boolyvanannan/Red Bog at Tomard upper. 

Tomard wood is a conifer plantation owned by Coillte in the northwest of Carlow. This woods borders the Red Bog or Boolyvannanan Bog. Historically turf was cut on this bog which has since ceased and conifers have been planted right up to the high bog. The bog immediately borders Coillte lands and may even lie within the lands owned by Coillte. A private conifer plantation borders the other side of the bog where Bilboa windfarm is currently planned. 

There are Marsh Fritillary ((Habitats Directive (92/43/EEC), Annex II, Convention on the Conservation of European Wildlife and Natural Habitats (Bern Convention) Appendix II) butterflies present around the bog with breeding confirmed within close proximity to the high bog on previously cutover and planted Coillte lands. Historically, locals remember Red Grouse (Birds of Conservation Concern (BOCCI- Red List, EU Birds Directive - Protected Species Annex II, Section I,  Annex III, Section I) present in the area while Golden Plover (BOCCI - Red List, EU Birds Directive - Protected Species Annex I), Common Snipe, Woodcock, Swifts, Kestrel (all BOCCI - Red List) are regularly seen in the area. There are recent historical records of Hen Harrier (BOCCI - Amber List, EU Birds Directive - Protected Species Annex I) in the area too.

Coillte natures mission includes:

Restoring important biodiversity areas by investing in major habitat improvements 

Rehabilitating ecosystem services by bringing sensitive or degraded lands into better health  

Peatland environments are rare in Carlow especially in the west of the county. There is an opportunity for Carlow County Council under the new development plan and Coillte being a large landowner in the area to bring about positive change in this area restoring lost biodiversity and sequestering carbon emissions through bog rehabilitation. 

• I would like to see an active effort by the council and Coillte in this area to help restore native biodiversity to this bog and help rehabilitate the site. Communication and cooperation between the county council and Coillte with adjoining landowners and the planned Bilboa windfarm project, but perhaps most importantly the local community, could help bring about positive change for the benefit of the environment and the preservation of both our cultural and natural heritage in the midst of a climate and biodiversity emergency. 

Examples of management could include keeping conifers back from the bog and efforts made to restore the water holding capacity of the peatland environment. Encroaching spruce should be removed. Habitat management for Devil's -bit Scabious the foodplant of the Marsh Fritillary. 

All-Ireland Pollinator Plan

• Enact the all-Ireland Pollinator plan on public lands to include but not limited to public parks, public roads (roundabouts, road verges), public buildings and grounds (Duckett’s Grove etc where possible.

Invasive Species

• Survey and implement a plan to remove all invasive alien species (including Himalayan Balsam, Japanese Knotweed, Winter Heliotrope etc…) from our native waterways which are currently contributing to the decline of native biodiversity here and the very structural integrity of our waterways.

Flood Protection

• Ensure the protection of the river Barrow floodplains which currently provide annual flood attenuation relief for Carlow Town, Leighlinbridge, Bagenalstown, Goresbridge, Borris and Graiguenamanagh while also providing seasonal habitat for nationally important wintering numbers of wetland birds such as Golden Plover (Red-listed and Annex I) and Lapwing (Red-listed), allowing the river to maintain its current flooding patterns. This will require careful consideration of any development within the footprint of the river and Special Area of Conservation.
• Assess the feasibility of providing financial relief (acknowledgement) to landowners whose lands are periodically flooded providing this flood attenuation relief (for the residents of the Barrow valley) and biodiversity resource without the need for any infrastructural flood relief developments.
• The use of natural flood mitigation strategies over hard infrastructure with a view to providing habitats for wildlife while protecting human livelihoods and centres of urban conurbations.

Barrow Track

• No further development of the Barrow Blueway idea. Maintain the Barrow towpath as is and has functioned for the past 100 plus years as a natural vegetation riverbank walkway.
• The track itself provides habitat for many floral species as well as feeding opportunities for protected avian waterbird species such as Snipe (Red-listed), Green Sandpiper, Grey Heron, Little Egret, Moorhen, Little Grebe as well as otters which cannot feed on a manmade gravel, grit, tarmac or similar surface. 

References

Webb, P., 2021. A survey of Swift (Apus apus) nesting sites in county Carlow 2018/19/20. [pdf] Available at: < https://www.swiftconservation.ie/wp-content/uploads/2021/03/Co.-Carlow-Swift-Report-2018_2019_2020-1.pdf >

Lewis, L. J., Coombes, D., Burke, B., O’Halloran, J., Walsh, A., Tierney, T. D. & Cummins, S. (2019) Countryside Bird Survey: Status and trends of common and widespread breeding birds 1998-2016. Irish Wildlife Manuals, No. 115. National Parks and Wildlife Service, Department of Culture, Heritage and the Gaeltacht, Ireland.

Gilbert G., Stanbury, A. and Lewis, L., 2021. “Birds of Conservation Concern in Ireland 2020 –2026”. Irish Birds 9: 523—544

Lewis, L. J., Coombes, R, H., Burke, B., Tierney, T. D., Cummins, S., Walsh, A. J., Ryan, N. & O’Halloran, J., 2020. Countryside Bird Survey Report 1998-2019. BirdWatch Ireland. Wicklow.

Whelan, R., Hayes, W. & Caffrey, B., 2019. Saving Swifts. Publication funded by The Department of Culture, Heritage and the Gaeltacht through the National Parks and Wildlife Service’s National Biodiversity Action Plan Fund.

Scott Cawley, 2021. Carlow Town Biodiversity Strategy & Action Plan 2021-2025.  Carlow County Council, Carlow Town Development Forum, Department of Housing, Local Government and Heritage.

Future Analytics, 2020. County Carlow Tourism Strategy and Action Plan 2020-2025. Carlow Tourism, Carlow County Council.

Carlow Regional Game Council objected to The Barrow Blueway Proposal back in 2017 and subsequently the proposal was refused planning permission by Carlow County Council and An Bord Pleanala. The Barrow Track is a well-established amenity for leisure activities like, dog walking, angling, bird watching, leisure walking, along with water activities such as boating, canoeing, swimming etc. The proposal to develop the track to make it suitable for cyclist and cyclist related activities will surely only lead to one outcome and that will be confrontation, resentment, anger, and guaranteed mayhem. In 1991 Brady Shipman & Martin conducted a survey on behalf of Carlow Rural Tourism, Carlow County Council and Waterways Ireland, into the development of the trackline between Carlow Town and Bagenalstown. It suggested a number of possibilities as outlined in their final report. Under the heading of "Cycling" it clearly made reference to the very high possibility of a conflict between cycling and angling and urged caution. All of the above amenities are carried out at a leisurely pace and without interruption. The introduction of a group of cyclist whizzing down the trackline at speed will not only create a nuisance to other recreational users but will also certainly cause a major "Health and Safety" issue going forward. We are not against cyclists and there has been some lovely tracks developed around the county for their use without going somewhere that was never intended for such activity. As a Game Hunting and Conservation Association we carry out vermin control along the bounds of the trackline and this benefits all types of nesting wildlife on the Barrow, the control of mink, magpies and grey rows are paramount to the survival of game and song birds along the trackline. The amount of flora and fauna present on the trackline is immense. We do care for this very important piece of habitat and urge that it remain in its natural state.

Dear Sir / Madam,

Please find attached Clogrennane Lime Ltd.’s submission in relation to the Draft Carlow County Development Plan 2022 – 2028.  

SLR Consulting Ireland acts as planning and environmental advisors to Clogrennane Lime Ltd., Clogrennane, Co. Carlow. This submission relating to the Draft Carlow County Development Plan 2022 – 2028 has been prepared on their behalf. 

An acknowledgement of receipt would be very much appreciated. 

Should you have any further queries, please do not hesitate to revert back to me. 

Regards,

We believe that this proposal is entirely consistent with Section 3.16.1.2 based on siting and design criteria for rural housing in the countryside .The application is for in -fill within the established guidelines .

We hope and believe that this change from Demesne to residential status will preserve the environmental integrity of the area and is consistent with the strategy outlined .

Second attachment

The purpose of this submission is to highlight the importance of the Blueway to Carlow.

Swifts

Background

The Swift is a Red-listed bird of conservation concern in Ireland (Gilbert, Stanbury & Lewis, 2021). Swifts come to Ireland’s towns to breed, arriving in May and departing in August each year. They are faithful to their nest sites returning to the same one for the duration of their life. These are known as traditional nest sites. The swift exists in our towns without causing any public nuisance. There are never any droppings left under the nests (all droppings are removed by adult birds), making them an ideal town inhabitant, especially as they provide a good service by consuming thousands of flying insects. There is no risk of spread of zoonotic disease or spread of disease to domestic livestock/companion animals.

The Countryside Bird Survey has recorded a steady decline in swifts over many years with the swift showing the third steepest decline among all species monitored (Lewis et al, 2020), having declined by over 57% in eighteen years (Lewis et al, 2019). The main cause of this decline is loss of breeding sites (Whelan, Hayes & Caffrey, 2019). They nest in buildings in towns (with all known Carlow nest sites in man-made structures (Webb, 2021). Their traditional nests can usually be found at the top of walls or in cavities in brick work. They gain access to the tops of walls by climbing behind the fascia board. When repairs or renovation work are carried out to roofs and guttering the birds can no longer gain access to their traditional nesting site. Since swifts live in colonies, repair or renovation work can often affect more than one pair of birds. Swifts now rely on the buildings in our towns for their nest sites. In order to secure the future of swifts, we need to ensure that their traditional nest sites are secured where possible, and to provide new nest sites so that the population can recover.

In order to protect and increase swift numbers nest boxes can be installed at suitable locations, generally in public buildings, like schools and universities. These buildings are in public ownership, so the nest boxes are generally safe from disturbance. In private residences nest boxes are sometimes removed if ownership of the residence changes.

Artificial nest boxes can be used very successfully for swifts if they are placed in the correct location. Nest boxes should be at least 4 metres above ground level and placed such that they do not receive full sun in summer. They would generally be placed facing North or East. There must be a clear flyway in front i.e. no trees or other obstacles. The special entrance to the boxes allow swifts to enter, but exclude other species such as starlings.

In-built artificial nesting cavities are swift boxes specifically designed to be built into the fabric of a new building and provide the most sustainable and long term conservation benefits option for swifts as the cavity provides a nest site for the swifts for the duration of the life of the building.  Building in swift boxes may help towards achieving and obtaining the LEED and/or BREEAM building standard for sustainable new construction projects in Ireland.

In addition to the nest boxes installation, a swift attraction call system must also be installed. Speed of occupancy of a nest box can be considerably accelerated by playing swift attraction calls. The attraction calls make the swift think that other swifts are nesting in this location and so indicate that this is an attractive place to breed. Any swift looking for a nest site will explore this area for a vacant place. The sound system should be placed as near as possible to the nest boxes e.g. on a window sill or attached to the box. Swift attraction calls only need to be used until the swifts take up occupancy. Swift attraction calls are operated on a timer - so it doesn’t play continuously and can be set to operate outside of work hours.

Carlow Town Biodiversity Strategy and Action Plan 2021-2025. 

2.3 Flagship Project 3- Save our Swifts

One of the Flagship Projects (3) identified as part of the plan is 'Save our Swifts'.  4 actions have been listed under the Save our Swifts project. All these actions as proposed should be implemented. Additional actions which are not included but which should be enacted going forward under the Biodiversity Strategy and Action Plan and as part of the Carlow County Development Plan 2022-2028 include:

• Commission Birdwatch Ireland and the Heritage Council of Ireland to complete a swift survey of County Carlow as a whole including the Greater Carlow Graiguecullen Urban area, all towns and villages, and rural and urban heritage sites to identify all known nesting sites within the county and protect them from inappropriate development which would result in the loss of a nesting site.
• Provide a workshop for architects, planners, heritage officer, etc. to raise awareness of the need to take Swifts into consideration in projects to refurbish old buildings and in new constructions.
• Physically build in Swift boxes to new buildings within the town and county which will provide permanent security for Swift nests into the future. 
• Include planning provisions for the requirement of environmentally sustainable in-built nest boxes for bats and swifts to encourage urban biodiversity in largescale new developments within the county such as any extensions to the IT Carlow Campus and Technological University, Carlow College St. Patrick’s, any other third level institutions, secondary schools and primary schools with a particular focus on urban areas.

• Legal protection of existing swift colonies in public and council owned buildings.

• Buildings which are of natural and cultural heritage importance for the preservation of swift nest sites which should be afforded protection include The Carlow Youth Centre (Glendale Avenue, Carlow Town), Carlow College St. Patrick’s, St. Dympna’s Hospital, Old Perry’s Cash and Carry (Kennedy Street, Carlow Town), Leinster Crescent (Dublin Road, Carlow Town), Cullen’s Mill (Leighlinbridge), The Old Mill (Church Street, Leighlinbridge), The Black Castle (Leighlinbridge), Old National School (Ballon), Altamont Gardens Stone Farm Outhouses, Saint Columba’s National School (Tullow), Scoil Phádraig Naofa (Tullow), St. Brigid’s Church (Clonegal).

This is now more important than ever in the midst of a Climate and Biodiversity Emergency, as Swifts are now Red-listed birds of conservation concern having declined by over 57% in eighteen years (Lewis et al, 2019), with all known Carlow nest sites in man-made structures (Webb, 2021). 

• Support the establishment of the Greater Carlow Graiguecullen Urban area as a ‘Swift City’ to be the first of its kind in the Republic of Ireland following the lead of the Belfast Swift city initiative, the first of its kind in the world, which will help promote the conservation work being undertaken for this species and other biodiversity within Carlow and provide for the increase in numbers of swifts further promoting nature based tourism opportunities within Carlow.

Biodiversity

• Designate a Biodiversity officer for county Carlow to help implement the Carlow Town Biodiversity Strategy and Action Plan, The All-Ireland Pollinator Plan and any other biodiversity projects etc and so help improve the status of biodiversity within the county.

References

Webb, P., 2021. A survey of Swift (Apus apus) nesting sites in county Carlow 2018/19/20. [pdf] Available at: < https://www.swiftconservation.ie/wp-content/uploads/2021/03/Co.-Carlow-Swift-Report-2018_2019_2020-1.pdf >

Lewis, L. J., Coombes, D., Burke, B., O’Halloran, J., Walsh, A., Tierney, T. D. & Cummins, S. (2019) Countryside Bird Survey: Status and trends of common and widespread breeding birds 1998-2016. Irish Wildlife Manuals, No. 115. National Parks and Wildlife Service, Department of Culture, Heritage and the Gaeltacht, Ireland.

Gilbert G., Stanbury, A. and Lewis, L., 2021. “Birds of Conservation Concern in Ireland 2020 –2026”. Irish Birds 9: 523—544