Loading...
HomeMy WebLinkAbout2560489 - Submission - An TaisceAn Taisce The National Trust for Ireland 5 Foster Place Dublin 2, Ireland D02 VOP9 20260119-18-60489 Monaghan County Council, Planning Department, The Glen, Kilygowan, n, Co. Monaghan. Sent by email to: planning@monaghancoco.ie 19th January 2026 Ref: 25/60489 App: Connolly Partnership For: planning permission is sought by Connolly Partnership for the construction a housing development on a site of 1.87 Hectares, consisting of a total of 45 dwellinghouses comprising of 5 No. single storey semi-detached houses; 40 No. two storey detached, semi-detached & terraced houses and, new site entrance onto existing public road R183, with associated amendment to the existing road frontage of the adjoining carparking at Connolly's Public House (Eircode A75CF58), connection to existing public sewer system, The development will provide for a total of 95 No. car parking spaces, bin stores; Landscaping, boundary treatments; public lighting; pedestrian & bicycle path through the site linking adjoining Cois Locha Estate subject to agreement, and all associated site infrastructure and engineering works necessary to facilitate the development Site: Doohamlat, Castleblayney,, County Monaghan, A75CF58 A Chara, We thank you for referring the above application to An Taisce for comment. 1. Water Framework Directive We note that the subject site adjoins the river waterbody labelled as 'Major Lough Stream_010' to the west, which has been designated as poor water quality status during the EPA's latest reporting period (2019-2024) and is considered to be at risk of not achieving good status by 2027. The objectives of the Water Framework Directive (WFD) (2000/60/EC) are to protect all high status waters, prevent further deterioration of all waters and to restore degraded surface and ground waters An Taisce is a membership -based charity I Join us at www.antalsce.org/membership An Taisce - The National Trust for Ireland I Protecting Ireland's heritage, safeguarding its future Registered Office: Tailors' Hall, Back Lane, Dublin, O08 X2A3, Ireland I www.antaisce.org 1 +353 1 707 7076 1 info(aantaisce.ora Company Limited by Guarantee no. 12469 1 Charity CHY4741 I Charity Regulator no. 20006358 1 EU Transparency Register no. 275657497595-21 Directors: Terri Morrissey (Chair), Neil Whoriskey (Vice Chair), John Conroy (Treasurer), Laura Segura Gutierrez (Secretary), Finbarr Murray, Helen Shaw, Tony Holohan to good status by 2027. Specifically, where there is bad or moderate water quality there is the legal imperative to bring that water body up to good status by 2027. Therefore, the proposal should be assessed against Article 4 of the WFD to determine whether the project may cause a deterioration of the status of a surface or ground water body or if it may jeopardise the attainment of good surface or ground water status or of good ecological potential and good surface or ground water chemical status. Close consideration should be given to the potential for construction phase run-off to enter the receiving aquatic ecosystem, as well as operational phase foul and surface water run-off. 2. Riparian Buffer Zone We submit that a sufficient riparian buffer zone should be established and/or maintained between the proposed development and the aforementioned stream to preserve the ecological integrity of this water body. Inland Fisheries Ireland (IFI) offers useful guidance for buffer zones across various development types which should be adhered tot. The importance of a sufficient buffer zone is exemplified by its importance for flood regulation, erosion mitigation and protection against sediment run-off. A biodiversity management plan for the subject proposal should include riparian zone enhancement, with planting of native tree species of Irish provenance, and continuous buffer zone management of such planted species as well as retention and active management of any existing riparian vegetation. 3. Artificial Lighting It is submitted that proposed external lighting specifications should be assessed with regard to the following important lighting design considerations, as specified by Dark Sky Ireland2: • Colour temperature (less than 2,700 Kelvins), • Light distribution (luminaire's beam less than 80 degrees), • Illuminance (less than 5 lux for pedestrian and decorative surfaces), • Luminance (100 cd/m2 or less), • Colour rendering index (CRI) (exterior lighting should not exceed CRI Ra90), • Energy efficiency (40 lumens per watt or greater). A dimming regime in the evening time should also be considered. Embedding these lighting design specifications within the subject proposal would contribute to reducing light pollution effects on nocturnal wildlife, including essential pollinators, human health and the night sky. Artificial light is recognised as a major threat to biodiversity due to disturbance to biological functions such as melatonin production and circadian rhythms, including bats. It should be ensured that the proposal contains dedicated bat surveys to determine the presence/absence of roosting or foraging bat species. Mature broadleaved trees, and other roosting refuges could be adversely impacted by 1 https://www.fisheriesireland.ie/sites/default/files/migrated/docman/IFIUrbanWatercoursesPlanningGuide.pdf 2 https://www.darksky.ie wp-content/uploads/2024/05/DSI-Environmentally-Friendly-Lighting-Guide-4.pdf Page 2 of 6 direct light pollution. It is recommended that the lighting plan for the project be assessed with regard to guidance from EUROBATS 8 Guidelines for Consideration of Bats in Lighting Projects.'3 4. Climate Action By reducing land take and infrastructure sprawl, compact settlement can significantly cut embodied carbon due to the significant carbon footprint of external areas such as roads, footpaths and green spaces in residential development. Such emissions due to landscaping and infrastructure are highest for low density semi-detached housing (+32%) compared to duplex units (+19%) and apartment buildings (+12%)6. A full lifecycle assessment of emissions embodied in construction materials and low -carbon material sourcing is an important consideration when assessing residential development proposals, in order to adhere to the residential sectoral emissions ceiling and the Climate Action and Low Carbon Development Act 2021 (as amended). We would highlight the Traffic Light Tool, developed by the RE-CUGI project which allows for an assessment of a development proposal against low -carbon and compact urban growth requirements.' The criteria for this assessment tool (site location, layout, car parking, walls, roofs, density) has been derived from the Viable Homes Handbook.8 This highlights how "In the case of a typical green field development, infrastructure adds approximately 30% additional embodied carbon per dwelling." Attenuation tanks are also carbon intensive to construct, furthermore, they require large areas of excavation and requirements for root protection have a negative impact on planting trees and biodiversity potential. The planning authority should consider integration of attenuation at roof level and swales at ground level into the development as a low -carbon alternative to replace the need for attenuation tanks. We would also highlight the importance of commitment by the developer to low -carbon measures and technologies, including heat pumps and solar panels. This will further the proposal's contribution to delivery of the national climate objective for a climate resilient, biodiversity rich and climate neutral economy by 2050, as specified in s.5(3)(1) of the Climate Action and Low Carbon Development (Amendment) Act 2021. As noted by the Climate Change Advisory Council in their recent Cross- sectoral Review (2025)4: "Research indicates that co -adoption of low -carbon technologies, such as pairing solar PV with electric vehicles (EVs) or heat pumps, yields greater cost savings and emissions reductions and will be essential to achieve climate objectives." This requires close consideration by the Council when assessing development of the type proposed in the context of a climate emergency and EPA projections that Ireland is well off course meeting its EU and national obligations for emissions reductions by 2030. Requiring the consideration of these building life cycle and climate action elements as part of the development consent process sets a good precedent within residential development planning for securing commitment to these urgent measures and technologies which are now established to be commercially and technically feasible. 3 EUROBATS 8 Guidelines for consideration of bats in lighting projects https://www.researchgate.net/publication/328306660 Guidelines for consideration of bats in lighting prof ects 4 Climate Change Advisory Council. 2025. Annual Review 2025L Cross-sectoral Review. https://www.climatecouncil.ie/councilpublications/annualreviewandreport/CCAC-AR2025-Cross-sectoral- final. df Page 3 of 6 This is particularly urgent given the targets within the National Retrofit Plan and the Climate Action Plan 2024 of 170,000 new dwellings using heat pumps by 2025 and 280,000 by 2030, as well as 120,000 dwellings retrofitted to BER B2 or a cost optimal equivalent by 2025 and 500,000 dwellings by 2030. Furthermore, reports by the Climate Change Advisory Council and Irish Solar Energy Association states that in order to achieve the renewable energy target of 80% by 2030, 2.5GW of grid -connected renewable capacity needs to be integrated into new residential developments of all scales via domestic rooftop installations.' It should be noted that a solar mandate for all new residential buildings by 31 December 2029 is a requirement under Article 10 of the Energy Performance of Buildings Directive (EU/2024/1275). Therefore, the subject proposal has an important role to play in achieving these targets and obligations. As outlined in a report by the Irish Green Building Council, construction and operation of the Irish built environment accounts for approximately 23MtCO2e of annual emissions in a standard year which accounts for 37% of national emissions due to building operations and embodied carbon.' A commitment by the developer to implementation of the aforementioned measures could help to reduce the greenhouse gas intensity which may arise from the subject proposal. 5. Car Dependency Despite the now widely recognised need to reduce car dependence as part of our efforts to address the climate and biodiversity crises, there is an ongoing systemic failure to ensure that new housing developments are actually linked to safe cycling and walking routes to schools, local services, employment centres, recreation areas, and enhanced public transport in the satellite commuter housing areas. This renders these areas unsafe for walking and cycling to schools, local services and amenities. Residential schemes often include strong walking and cycling permeability within the boundary of the site itself, but they are frequently located on the fringes of cities and towns at a significant remove from existing transport links or services (grocery stores, health facilities, etc.). They are also often sited in areas with very limited existing public transport routes and capacity or pedestrian and cycling infrastructure. Therefore, although a new residential development may provide high quality foot and cycle permeability around the dwellings, these often terminate immediately outside the site boundary, thereby discouraging residents from using active travel modes outside of the development itself and thereby increasing car dependence. It should be ensured that the subject proposal's design adheres to the need to promote a modal shift towards increased pedestrian, public transport and cycle friendly development, in adherence to the National Sustainable Mobility Policy and the Compact Settlement Guidelines. Access to public transport links and cycling/pedestrian infrastructure outside the subject site boundary is a crucial consideration. With regard to permeability, the Council should have regard to the NTA's guidance$, which emphasises how permeability contributes to the attractiveness of a neighbourhood. Furthermore, close consideration should be given to the Design Manual for Urban Roads and Streets (DMURS) to 5 Climate Action Plan 2024. Page 196. https://www.gov.ie/en/publication/79659-climate-action-plan-2024/ 6 https://www.climatecouncil.ie/councilpublications/councilworkinapaperseries/WORKIN-2.PDF ' O'Hegarty et al. 2022. Whole Life Carbon in Construction and in the Built Environment in Ireland. https://www.igbc.ie/resources/whole-life-carbon-in-construction-and-in-the-built-environment-in-ireland-v4 8 https://www.nationaltransport.ie/wp- content/uploads/2011/12/Permeability Best Practice Guide NTA 20151.pdf Page 4 of 6 ensure that the project is in compliance, particularly as regards permeability where Design Principle 1 and subsequent elaboration states the following: "To support the creation of integrated street networks which promote higher levels of permeability and legibility for all users, and in particular more sustainable forms of transport. (p. 29) When designing new street networks, designers should implement solutions that support the development of sustainable communities. In general, such networks should: • Be based on layouts where all streets lead to other streets, limiting the use of cul-de-sacs that provide no through access. • Maximise the number of walkabl%ycleable routes between destinations. (p. 41)" 6. Social and Community Infrastructure It is recommended that a Social and Community Infrastructure Assessment should be carried out to determine the sufficiency of existing community infrastructure to meet the additional demand generated by the subject proposal, as well as shaping plans for future community infrastructure if deficiencies are identified. Proper provision of community and social infrastructure in tandem with housing is essential for building sustainable and properly planned communities. The Council should also draw upon the concept of the '15 minute city' to ensure compact settlement within walking and cycling range of local services, amenities and access to public transport. As noted in the Compact Settlement guidelines (2024, Section 1.3.2, p. 4): "This should be the overarching objective when planning for sustainable residential development and compact settlements. Planning authorities at settlement level should plan for an integrated network of well -designed neighbourhoods that can meet day-to-day needs (such as food, healthcare, education, sports and professional services) within a short 10 to 15 minute (approx.) walk of all homes. In the case of larger settlements, the residents of less central neighbourhoods should have opportunities to travel by public transport and other sustainable modes (e.g. green ways) to access higher order services, employment and amenities at more central and accessible locations. This will reduce the need for travel and the need for travel by private car, supporting the transition to a lower carbon society and the creation of settlements that are more socially inclusive. "[An Taisce emphasis]. 7. Nature -based Solutions We would query the extent to which the subject proposal consists of impermeable hard surfaces which has implications for excess surface water management by adding pressures to existing urban drainage systems and increasing the likelihood of pollutant spread via surface water runoff. With rainfall intensity projected to increase according to climate change modelling and assessments, there is an urgent necessity to integrate permeable urban greening infrastructure into urban design which has been recognised by the EPA and the national government. Page 5 of 6 For example, continued use of impermeable surfacing has adverse implications in terms of its contribution to the soil sealing effect which refers to the covering of soil with hard impermeable material to facilitate infrastructural development. This eliminates penetration of the soil by air and water which is detrimental to soil health and is considered to be irreversible damage due to artificial surfaces being maintained for a long period of time9. One study demonstrates how the use of permeable surfacing allows for higher infiltration and evaporation of water compared to impermeable surfacing, as well as providing cooler surface temperatures and reducing the urban heat island effect.10 The European Environment Agency has recognised that "Permeable pavements (e.g. concrete pavers with voids) and porous pavements (which are permeable over their entire surface) are increasingly used in spatial planning, as such materials help to mitigate the impact of paving on water and carbon cycles': Furthermore, a recent strategy entitled 'Nature Based Management of Urban Rainwater and Urban Surface Water Discharges'14 outlines the benefits of moving away from impermeable grey engineering urban design: "Reducing the percentage of impermeable surfacing and increasing the area of urban landscaping result in multiple benefits in addition to the reduction in rainfall induced flood risk and runoff pollution. These benefits include reduced "heat island" effect and urban noise, a more pleasant urban environment that supports active and sustainable transport modes and increased biodiversity. " We would also highlight the recommendations from the Compact Settlement Guidelines (2024) which: "The following key principles should be applied in the preparation of local plans and in the preparation and consideration of individual planning applications, (c) Promote urban greening and Nature -based Solutions (including Sustainable Drainage Systems and slow -the -flow initiatives) for the management of urban surface waters in all new developments and retrofitting in existing areas to ensure that the benefits of ecosystem services are realised. Planning authorities should adopt a nature -based approach to urban drainage that uses soft -engineering techniques and native vegetation (including the protection of the riparian zone) to minimise the impact on natural river processes. '21 Please acknowledge our submission and advise us of any decision made. Is mise le meas, Sean O'Callaghan Planning and Environmental Policy Officer An Taisce — The National Trust for Ireland 9 https://www.eea.europa.eu/publications/soil-monitoring-in-europe to Fini et al. 2017. Nature -based solutions to mitigate soil sealing in urban areas: Results from a 4 -year study comparing permeable, porous and impermeable pavements https://www.sciencedirect.com/science/article/abs/pii/S0013935117305297 11 Page 45. https://www.gov.ie/en/publication/aaea6-sustainable-residential-development-and-comDact- settlements-guidelines-for-planning-authorities/ Page 6 of 6