44. Inland Fisheries Ireland
IIE Baile Átha Cliath, 3044 Céide an Locha, Campas Gnó Larthar Na Cathrach, Baile Átha Cliath 24, D24 Y265
IFI Dublin, 3044 Lake Drive, Citywest Business Campus, Dublin 24, D24 Y265 +353(0)1 8842 600 - dublin@fisheriesireland.ie - www.fisheriesireland.ie
Forward Planning Team,
Monaghan County Council,
Planning Office,
1 Dublin Street,
Monaghan.
Email: devplan@monaghancoco.ie
7th July, 2023
Re: Notice of Intention to Review the existing Monaghan County Development Plan 2019-2025 and to Prepare
a new Monaghan County Development Plan for 2025-2031
Dear Sir/Madam,
We refer to your correspondence regarding the above mentioned notification.
Inland Fisheries Ireland (IFI) is a Statutory Body whose principal function is the protection, management and
conservation of the inland fisheries resource. Protection of the aquatic environment and habitat is a vitally
important element of IFI's work. In the context of the Monaghan County Development Plan the issues of water
quality, fisheries habitat and angling tourism should be given due priority.
“Fisheries” includes all inland fisheries recreational and commercial, sea angling and mollusc fisheries
stipulated under the Fisheries Acts, the physical habitat upon which the fishery relies, the facilities and access,
the quantity and quality of the water and the plant and animal life on which fish depend for shelter and food
and the spawning areas wherein fish deposit their eggs. The protective role of IFI relates to all aspects of the
aquatic environment and all factors that influence the biotic communities within waters, which in any way
relate to the propagation of fish stocks.
The many rivers and lakes in County Monaghan contain valuable fisheries habitats. These habitats support a
wide variety of fish species from salmonids (Atlantic salmon and trout), pike, coarse fish, lamprey species and
European eel among other species. It should be noted that while these river are not designated under the
Habitats Directive they hold species that are listed in Annex II of the directive, i.e. Atlantic salmon and Lamprey
species.
These watercourses not only contribute significantly to the natural heritage value of the county they are also
valuable and popular angling amenities.
Tourism
Freshwater and marine recreational angling directly supports over 11,000 existing Irish jobs, many of which are
located in the most peripheral and rural parts of the Irish countryside and along our coastline (IFI, 2015).
IFI’s National Strategy for Angling Development (NSAD) 2015-2020 is the first comprehensive national
framework for the development of our angling resource. The strategy aims to deliver a wide-ranging set of
investments, innovations and promotions over the five years of the plan. This will ensure that our fish stocks and
angling infrastructure are protected and enhanced for both their economic value and their recreational
benefit to the communities and visitors they serve across Ireland. Effective and sustainable implementation of
the strategy will ensure stability of existing jobs and businesses reliant on angling and the creation of new jobs
as the economic impact of angling grows.
IIE Baile Átha Cliath, 3044 Céide an Locha, Campas Gnó Larthar Na Cathrach, Baile Átha Cliath 24, D24 Y265
IFI Dublin, 3044 Lake Drive, Citywest Business Campus, Dublin 24, D24 Y265 +353(0)1 8842 600 - dublin@fisheriesireland.ie - www.fisheriesireland.ie
Inland Fisheries Ireland supports the protection and development of angling tourism in the Plan through the
adoption of policies with regard to the provision of facilities which encourage angling, promotion of angling
tourism within the county and signposting of rivers, lakes and streams. Signposting of rivers and angling
locations and the provision of information boards giving details of species present and biodiversity should be
supported.
Transport/Infrastructure
Provision of transport and other infrastructure should be planned and constructed in such a way as to protect
and conserve the existing environment. Potential negative impacts of developments of this nature include
impeding the passage of fish and other fauna and poor water quality.
The impact of poorly designed river/stream crossing structures can be serious in terms of habitat loss and
stream fragmentation. Prevention of the free passage of fish, e.g. salmon, trout and lamprey in particular can
result in the loss of spawning habitat and impact on fish populations.
Natural Heritage, Biodiversity and Green Infrastructure
The impacts of development when not policy driven or environmentally managed are numerous, i.e.
destruction of instream habitats, interference with fish spawning and nursery areas, obstruction of fish passage,
removal of angling pools, changes in flow regimes, etc., The destruction of riparian areas along river banks
results in fragmentation of riparian habitat within the river corridor, loss of cover for fish and aquatic animals
and can reduce the value of the amenity.
To insure that impacts from development/land use practices (including flood plain development) do not
interfere with the aquatic environment it is essential that those areas adjacent to waterways (riparian buffer
zones) are managed in a manner, which will lessen impacts on these habitats.
Protection of aquatic zones can require riparian/buffer zones of up to 50m. The width of the riparian/buffer
zone will depend on factors such as land use, land topography (e.g. slope), soil type, channel width/gradient
and critical habitats to be protected.
IFI urges all local authorities to acknowledge and address the need for riparian habitat protection. IFI should
be consulted in relation to any development (greenfield or redevelopment of brownfield sites) that could
impact on aquatic ecosystems and associated riparian habitat. IFI can provide guidance on site specific
measures to enhance, protect, rehabilitate or establish riparian and aquatic habitats.
We refer you our recently updated guidance document IFI Urban Watercourses planning guide, which can be
accessed at https://www.fisheriesireland.ie/extranet/fisheries-management-1/1762-ifi-urban-watercourses-
planning-guide-1.html
Climate Change:
The impacts of climate change include increased temperatures, changes in rainfall patterns, drought and
unpredictable weather, all of which can have a negative impact on fish and the associated aquatic habitat.
Periods of low water levels combined with increasing demands for water can create huge pressures on these
natural resources. The County Development Plan is an opportunity to promote policies and awareness of
water conservation which may ultimately result in a reduction in water use. Water conservation and water use
efficiency are central elements of any strategy to enhance water supply reliability, restore ecosystems, and
respond to climate change and changing demographics. Significant increases in water conservation and
water use efficiency will be required to ensure reliable water supplies in the future.
Best practice should be promoted in respect of water conservation in all developments through methods
such as rain water harvesting.
Another problem which is particular to summer months (when river/stream flows are often low) is wide scale
unregulated water abstraction for crop irrigation. This practice may have significant ecological
implications/impacts if large volumes of water are abstracted over a short period of time from small fish nursery
or spawning streams.
IIE Baile Átha Cliath, 3044 Céide an Locha, Campas Gnó Larthar Na Cathrach, Baile Átha Cliath 24, D24 Y265
IFI Dublin, 3044 Lake Drive, Citywest Business Campus, Dublin 24, D24 Y265 +353(0)1 8842 600 - dublin@fisheriesireland.ie - www.fisheriesireland.ie
Such abstractions during dry weather or drought periods could have severe repercussions for aquatic habitats,
fish stocks and accordingly the ecological status of watercourses in terms of the Water Framework Directive
(WFD).
Rivers and watercourses are natural assets which provide a basis for the development of visual and amenity
features of the areas through which they flow. They can provide a focus for the involvement of the
communities in the protection of water quality and biological/wildlife diversity of aquatic habitats within these
areas.
IFI requests that the Plan provides for the maintenance and preservation of all watercourses and associated
riparian habitats in the county.
Yours faithfully,
Michaela Kirrane and Ailish Keane
Senior Fisheries Environmental Officers
Inland Fisheries Ireland