7. Office of Public Works
1GQ, Cé Sheoirse, Baile Átha Cliath 2, D02 Y098
1GQ, George's Quay, Dublin 2, D02 Y098
T +353 46 942 6000 | info@opw.ie
www.gov.ie/opw
Forward Planning Team,
Monaghan County Council,
Planning Offices,
1 Dublin Street,
Monaghan,
H18 X982
26/06/2023
RE: Issues Paper Monaghan County Draft Development Plan 2025 - 2031
Dear Sir/Madam,
The OPW, as lead agency for flood risk management in Ireland, welcomes the opportunity
to comment on the Issues Paper in the preparation of the Monaghan Draft Development Plan
for the period 2025 – 2031.
This submission is made specifically concerning flood risk management. Further
submissions on the Issues Paper may be made by the OPW concerning the estate portfolio,
heritage and other areas of responsibility.
Flood Risk Management (FRM) – General Guidance
Reference should be made to the Guidelines on the Planning System and Flood Risk
Management (DHPLG/OPW, Nov 2009) issued under Section 28 of the Planning Acts, here
after referred to as the ‘Guidelines’, and associated Circulars and Technical Appendices, to
ensure that the key principles of flood risk management and sustainable planning are
adopted. The sequential approach to managing flood risk within the planning system should
be considered at the earliest stage, and where uncertainty exists the precautionary approach
should be taken or further more detailed assessment carried out before decisions are made,
rather than delegating decisions to the development management stage. The Guidelines set
out a three Stage Flood Risk Assessment process for the Planning Authorities to identify
whether flood risk may exist, and the degree to which it is an issue, and what assessment to
a scale proportionate to the risk should then be carried out. The following is an overview of
this three-stage process;
Stage 1 Flood risk identification – To identify whether there may be any flooding
or surface water management issues related to a plan area or proposed development
site that may warrant further investigation.
Stage 2 Initial flood risk assessment – To confirm sources of flooding that may
affect a plan area or proposed development site, to appraise the adequacy of existing
information and to scope the extent of the risk of flooding which may involve
preparing indicative Flood Zone maps. Where hydraulic models exist, the potential
impact of a development on flooding elsewhere and of the scope of possible
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mitigation measures can be assessed. In addition, the requirements of the detailed
assessment should be scoped.
Stage 3 Detailed flood risk assessment – To assess flood risk issues in sufficient
detail to prepare Flood Zone maps based on a quantitative appraisal of potential flood
risks to a proposed or existing development or to land that is being considered for
zoning, and to identify potential impacts on flood risk elsewhere and of the
effectiveness of any proposed mitigation measures.
In the preparation of the Draft Plan, the OPW recommends that particular attention is paid to
the following sections of the Guidelines;
Chapter 3 – The Planning Principles,
Chapter 3 – The Sequential Approach, and definitions of Appropriate Development,
Chapters 3 and 4 – The Plan-making Justification Test where it is intended to zone
or otherwise designate land where there is a moderate or high probability of flooding,
noting that the application of the Test should be supported by analysis to an
appropriate level of detail.
The OPW advises that clear commitments and strategic objectives regarding flood risk and
the principles of the Guidelines are included in the Draft Plan, and that persons with the
relevant expertise review any flood risk assessments submitted to Monaghan County
Council.
Sequential Approach
The sequential approach uses mapped flood zones alongside considerations of the
vulnerability of different types of development to give priority to development in zones of low
flood probability. Only if there are no reasonable sites available in zones of low flood
probability should consideration be given to development in higher flood probability zones.
To demonstrate that the sequential approach has been applied, flood zone maps should
show the proposed land use zonings overlaid with both Flood Zone A and B. These maps
should be at a reasonable scale and be clearly legible.
Justification Test
Highly vulnerable development is not appropriate in Flood Zone A and B and less vulnerable
development is not appropriate in Flood Zone A. In exceptional circumstances, development
that is generally considered inappropriate because of its vulnerability to flooding may be
justified as appropriate, on the grounds of proper planning and sustainable development
provided that the risks are reduced and/or managed to an acceptable level. The Guidelines
set out that land use zoning, informed by the suitable level of FRA and if necessary a
Justification Test, should be concluded at the Plan-making Stage. Please note that the
Justification Test applies only to the urban centre (i.e., the core area of a city, town or village
which acts as a centre for a broad range of employment, retail, community, residential and
transport functions), and would not be applicable to the periphery of urban areas.
There are three criteria of a Justification Test, all of which must be satisfied, with the third
criteria being the flood risk assessment. This flood risk assessment must demonstrate that
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flood risk can be adequately managed and the use or development of the lands will not cause
unacceptable impacts elsewhere. Monaghan County Council should specify the structural or
non-structural measures as prerequisites to development and provide information on the
residual risks that would remain and how they might be managed. Inappropriate development
that does not satisfy all criteria of the Justification Test should not be considered at the Plan-
making stage.
Specific Flood Risk Management Issues for Consideration
The Flood Risk Management Plans and Flood Maps
The OPW, in conjunction with Monaghan and other County and City Councils, undertook the
National Catchment-based Flood Risk Assessment and Management (CFRAM) Programme,
through which Flood Risk Management Plans (FRMPs) and flood maps were prepared. The
FRMPs were adopted by the Minister for Public Expenditure and Reform under the Floods
Directive as transposed and form part of the Ireland 2040 National Development Plan. The
implementation of these Plans is an objective of the Regional Spatial and Economic
Strategies. It is noted that Monaghan County Council adopted the FRMPs relevant to its
administrative area. The CFRAM Programme included analysis of flood risk in Ballybay,
Carrickmacross, Inishkeen and Monaghan. In this context:
The OPW requests that Monaghan County Council has full regard in the preparation
of its Development Plan 2025 – 2031 to the proposed development of flood relief
schemes in Ballybay, Inishkeen and Monaghan, to ensure that zoning or
development proposals support and do not impede or prevent the progression of
these measures, and that a specific objective in this regard is included in the Draft
Development Plan.
The OPW has a statutory duty to maintain flood relief schemes completed under the
Arterial Drainage Acts, 1945-1995. The local authority will also need to maintain any
flood relief schemes implemented under its powers. The OPW requests that
Monaghan County Council has full regard in the preparation of its Development Plan
2025 – 2031 to the protection, and the need for maintenance, of these schemes.
Monaghan County Council might also consider including a register of key flood risk
infrastructure in the County Development Plan where it would not otherwise be
readily identified or protected from interference or removal.
The flood maps produced under the National CFRAM Programme provide an
important resource for plan making and consideration of development in relation to
the implementation of the Guidelines, and planning authorities should have regard to
these maps in both forward planning and development management. Planning
authorities are reminded that where physical changes have occurred, where there is
evidentially robust additional sources of information, such as site-specific flood risk
assessments or where local, more recent surveys have been undertaken, this
information can and should also be included in the making of spatial planning
decisions.
The flood maps, including those for potential future scenarios taking account of the
possible impacts of climate change, are available to view on the OPW portal,
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www.floodinfo.ie, and may be obtained in GIS format by submitting a Data Request
Form, available from https://www.floodinfo.ie/contact/ to OPW Data Management
Section via email (flood_data@opw.ie).
Map Review Programme
It should be noted that in certain areas physical changes may have occurred since the
preparation of the flood maps under the National CFRAM Programme that would affect the
watercourse and floodplains, and hence the Flood Zones. In some areas, there may have
been limited information recorded on past flood events against which to calibrate the models,
and more recent flood events or other evidence that becomes available may indicate that the
flood extents should be greater or lesser than those currently mapped. In other areas, very
detailed local assessments may have been undertaken, such as for a site-specific flood risk
assessment that could be more detailed, contemporary and/or robust than the flood maps
that were developed through the National CFRAM Programme. The OPW will review, and
where necessary update, the flood maps on an on-going basis.
National Indicative Flood Mapping
The updated indicative flood mapping outlined below were prepared for the purpose of an
initial assessment, at a national level, to assist in the review of areas of potentially significant
flood risk, as required by the EU 'Floods' Directive 2007/60/EC. They provide only an
indication of areas that may be prone to flooding and are therefore not necessarily locally
accurate. As such, while the indicative maps may be used for strategic-level assessments,
they should not be used as the sole basis for defining the Flood Zones, or for making planning
policy.
National Indicative Fluvial Mapping (NIFM)
Indicative fluvial flood maps have been prepared for all watercourses in the country with a
catchment greater than 5km2 through the National Indicative Fluvial Mapping (NIFM) project
that was completed in 2020. These maps provide important flood hazard information for
areas not covered under the National CFRAM Programme, and were developed using much
more robust analysis than that used previously to prepare the PFRA indicative mapping.
However, the maps did not make use of channel survey data, and do not take flood defences
into account. These maps have been prepared for two potential future scenarios taking
account of the potential impact of climate change; the Mid-Range future Scenario (MRFS)
and High-End Future Scenario (HEFS), as well as for current conditions.
The OPW does not provide any predictive fluvial flood maps for catchments with an area of
less than 5km2 that were not included in the National CFRAM Programme. Planning
Authorities may need to carry out their own Flood Risk Assessments to inform the definition
of Flood Zones for these areas.
Further user guidance and details on the preparation of the NIFM outputs and mapping are
available at: https://www.floodinfo.ie/publications/?t=50.
National Coastal Flood Hazard Mapping
The national scale coastal flood hazard maps from the ICPSS project that were published by
OPW under the PFRA in 2012 are now superseded by the outputs of the National Coastal
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Flood Hazard Mapping (NCFHM) 2021 project and these updated coastal flood hazard maps
have recently been published on the www.floodinfo.ie web portal. These coastal flood hazard
maps, for both flood extent and depth, have been produced for a range of annual exceedance
probabilities for the Present Day as well as for multiple Future Scenarios (including: MRFS,
HEFS, H+EFS and H++EFS).
The maps show the worst case scenario as any flood defences potentially protecting the
coastal floodplain are not taken into account, and so are in-line with the definition of the Flood
Zones as set out in the Guidelines. The NCFHM maps are based on more up-to-date
estimates of extreme coastal levels than those used for the CFRAM coastal maps (that were
based on the ICPSS data). As such the NCFHM maps may be considered in preference to
the CFRAM with regards to the definition of the Flood Zones.
Further user guidance and details on the preparation of the NCFHM 2021 project outputs
and mapping are available at: https://www.floodinfo.ie/publications/?t=48.
National Groundwater Flood Mapping
Probabilistic and historic groundwater flood maps have been prepared by Geological Survey
Ireland through the 2016-2019 GWFlood Project. The Groundwater Flood Probability Maps
show the probabilistic flood extent of groundwater flooding in limestone regions and are
focussed primarily (but not entirely) on flooding at seasonally flooded wetlands known as
turloughs. The Historic Groundwater Flood Map shows the observed peak flood extents
caused by groundwater in Ireland and are largely based on the winter 2015 / 2016 flood
event which was the largest flood on record in many areas.
Further user guidance and details on the preparation of the NCFHM are available at:
https://www.gsi.ie/en-ie/programmes-and-projects/groundwater-and-geothermal-
unit/activities/groundwater-flooding/gwflood-project-2016-2019/Pages/default.aspx.
Consideration of Climate Change Impacts
The potential impacts of climate change include increased rainfall intensities, increased
fluvial flood flows and rising sea levels. In line with the Guidelines, while Flood Zones are
defined on the basis of current flood risk, planning authorities need to consider such impacts
in the preparation of plans, such as by avoiding development in areas potentially prone to
flooding in the future, providing space for future flood defences, specifying minimum floor
levels and setting specific development management objectives. It should be noted that the
flood maps prepared under the National CFRAM and the national indicative flood maps (see
above) include maps for two potential future scenarios taking account of different degrees of
climate impact.
Arterial Drainage Schemes and Drainage Districts
The OPW requests that Monaghan County Council has regard in zoning land for
development to ensure that access requirements are preserved for the maintenance of
Arterial Drainage Schemes and Drainage Districts. Applications for development on land
identified as benefiting land may be prone to flooding, and as such site-specific flood risk
assessments may be required in these areas. The location of Arterial Drainage Schemes
and Drainage Districts may be viewed on www.floodinfo.ie.
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Land Protected by Agricultural Embankments
It should be noted that the Flood Zones are defined ignoring the presence of flood defences
(Section 2.25 of the Guidelines). This is particularly important in the context of land that
benefits from some degree of protection from embankments that were constructed to protect
agricultural lands, i.e., as part of an Arterial Drainage Scheme or Drainage District or the so-
called Land Commission Embankments (see www.floodinfo.ie). In such areas, it is strongly
recommended that land should only be zoned for development in accordance with the
definition of appropriate development as set out in the Guidelines.
Impacts on Other Areas
While a particular development may not be prone to flood risk itself, it can increase flooding
up- or down-stream, due to increased runoff from additional drainage or increased paved
areas or due to loss of storage. In line with the Guidelines, proposed new development needs
to avoid increasing such flood risk elsewhere.
Nature-based Solutions and SuDS
The OPW advises that the preparation of development plans should take account of the
opportunities for nature-based solutions to reduce runoff and provide other benefits such as
to water quality, biodiversity, etc. This can include in areas around existing developments,
as well as within existing and proposed development in the form of Sustainable Urban
Drainage Systems (SuDS). Monaghan County Council should refer to The Best Practice
Interim Guidance Document ‘Nature-based Solutions to the Management of Rainwater and
Surface Water Runoff in Urban Areas’ for further guidance.
The Guidelines recommend that the SFRA provide guidance on the likely applicability of
different SuDS techniques for managing surface water run-off at key development sites, and
also identifies where integrated and area based provision of SuDS and green infrastructure
are appropriate in order to avoid reliance on individual site by site solutions.
If further information is required or to request a pre draft consultation meeting, please do not
hesitate to contact the OPW (floodplanning@opw.ie).
Yours sincerely,
____________________________
pp Conor Galvin
Flood Risk Management – Climate Adaptation and Strategic Assessments