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43. Brian MacDomhnaillSubmission to Monaghan County Council re County Development Plan 2025-2031 & Climate Action Plan Brian Mac Domhnaill, Introduction: I worked for 20 years as Research & Evaluation Officer with the community-owned drinking water sector’s representative organisation, the NFGWS and was PRO for Monaghan GWS Federation. As part of my work I served as deputy chair of the inter-agency National Source Protection Pilot Project from 2003-2010 and co-authored its report as well as associated educational resources for primary schools, I helped design and co-managed pilot projects with the EPA on the effective management of septic tank systems (to mitigate against pollution) and worked with the groundwater team of the Geological Survey of Ireland and with the Centre for Freshwater and Environment Studies in Dundalk Institute of Technology as part of a strategy to improve the protection of lakes, springs and borewells supplying Ireland’s group water scheme sector. I also sat for a number of years on the EPA-led ‘Pesticide Working Group’, which aims to address herbicide contamination of the aquatic environment. Through my working career, I became acutely aware of the factors damaging our environment and I came to understand the inter-connectedness of life, terrestrial and aquatic. Like most people who care deeply for our environment, I experience intense frustration and anger at the destructive practices I see all around me and am all too aware that this can lead to despair. I am currently a member of the Monaghan branch of the Irish Wildlife Trust and he Friends of the Dromore River. Inspiring confidence: In terms of its focus on environmental issues in general and the biodiversity and climate crises in particular, the forthcoming plans need to inspire public confidence that its proposed strategies and measures will be implemented. regardless of the environmental consequences of particular actions and activities. There is a perception that those with wealth and power are able to avoid the consequences of their breaches of regulations. As a recent example of your Executive’s failure to deal honestly with environmental issues, we had the ‘debate’ about the EPA’s findings in relation to the damage caused by ammonium from our ever- expanding poultry sector in the north and west of the county. Instead of robustly defending the integrity of the EPA and its determination from unwarranted attacks by elected representatives, senior Council officials opted to stay silent. The failure to date to ensure the appointment of a Wildlife Protection Officer has been of particular concern, as it has resulted in open season on hedgerows across the county, with vast stetches being removed altogether. Meanwhile the loss of our precious wetlands continues unabated. The biodiversity and climate crises cannot continue to be hostage to narrow sectional interests. Monaghan County Council’s Development Plan 2025-31 and the Climate Action Plan should be prepared with reference to the findings of the Citizen’s Assembly on biodiversity and the urgent need to mitigate the impacts of Climate Change but, more importantly, both the Executive and elected council members must declare their commitment to seeing its promise delivered and stand up to those who will oppose and try to frustrate strategies and measures that are aimed at averting the catastrophic collapse of our wildlife species and the projected consequences of Climate Change. A strengthened Environmental Section: While my dealings with Monaghan County Council Environment Section have been positive, I believe that more resources are needed to help it deal effectively with the significant environmental challenges facing our county. A strengthened Environment Section under the plans might: 1. provide a portal through which citizens may liaise with all Sections of Monaghan County Council on environmental issues as well as with the various agencies that have regulatory responsibility for particular environmental issues (e.g. DAFM regulation of herbicide sale and use). 2. provide a process, with timelines, for dealing with matters raised, keeping the citizen informed of developments and of the final outcome/action taken. 3. ensure that environmental measures within the County Development Plan are actually being implemented. For example, previous plans have stated that hedgerow must be replaced where it is removed during roadworks. This provision is seldom enforced. 4. develop and oversee the implementation of an environmental protection checklist in advance of any infrastructural works being undertaken by Monaghan County Council or on its behalf. [See, as an example, the NFGWS guidance document at https://nfgws.ie/wp- content/uploads/2019/02/NFGWS-Advice-Note-on-Mitigating-Environmental-Impact-of- GWS-Capital-Works-July-2020.pdf. Climate Action: Trees as mitigation The plans should set an ambitious target for native tree propagation and planting, addressing the following issues: Site identification for planting both on publicly-owned lands and (though offering free trees) on private lands. Coillte-owned properties should also be considered for extensive broadleaf planting and the Council should lead discussions to further this objective. Infill of hedgerow/planting new hedgerow (with appropriate species) should be a priority, especially given the ravages of ash dieback. Clear guidance should be provided that includes planting the hedge on a raised ditch (which will provide habitat for mining bees and for many wildflower species that thrive in hedge banks), using 70% whitethorn and at least 6 species in total. In the absence of clear guidelines, people will continue to plant inappropriate non-native hedgerow (e.g. beech, laurel and lelandia) and with no raised ditch . Community partners that might be mobilised for seed collection/germination/propagation of target species and planting of whips (Tidy Towns, Schools, Environmental organisations etc.) Training for volunteers and council staff that will be involved in delivering this element of the plan. [John McKeon of the Monaghan branch of the Irish Wildlife Trust (formerly of Teagasc) provides an excellent practical course] Equipment that might be required. While seed germination/propagation doesn’t require any special equipment, there may be a need for planting pots, heavy duty gloves (for haw collection), grappling poles (for hard-to-reach berries/seed). These might be funded through the Community Environment Scheme. Insurance to cover those involved in tree planting, if necessary. Targets need to be set so that an annual review can measure delivery of this element of the plan. Climate Action: Wetlands The plans should address the ongoing loss and degradation of wetlands in the county as a result of infilling and drainage, recognising that the current requirement for planning permission where more than 0.2 hectares of wetland is to be lost does not offer sufficient protection to these valuable sites. Short of an outright ban on infilling/drainage, there needs to be: 1. a requirement for an environmental assessment by a competent professional where any works are planned in wetlands including rivers, lakes, marshes, fens and bogs. 2. Identification/mapping of wetlands across the county that have been degraded through historic dumping of municipal/household waste and a schedule of works to restore these. 3. the construction of new wetlands/large ponds on publicly-owned lands and on private lands, with the consent of the proprietors. 4. planning permissions for all building developments on sites over a half-acre to include construction of a permanent shallow pond. Even very small ponds will make a difference. 5. an outright ban on construction of buildings on floodplains. This should include the projected extent of those floodplains in the context of heavier and more prolonged rainfall due to climate change. 6. to reduce the risk of flash flooding, all newly-paved areas should be bounded by vegetated strips/sumps or be drained into nearby vegetated areas to allow infiltration. Where possible, vegetated strips/sumps should be retrofitted in or close to existing paved surfaces and especially car parks. Climate Action: Water conservation The plans should incentivise the installation of water conservation/rainwater and greywater harvesting on all newbuilds. A reduced developmental charge could be the reward for those who install approved systems in their homes, while businesses might be incentivised through a rates reduction over a period of years. The plans should also consider supports towards retrofitting water saving systems in existing premises, bearing in mind that toilets alone account for up to one-third of all water use in domestic premises. Collaboration with Irish Water and with the county’s GWS sector would help deliver on this strategy. Besides reducing water demand/abstractions, it would deliver potentially huge energy savings (as a result of less water pumping and treatment) and will also reduce the volume of chemical sludge for disposal. Furthermore, it would reduce the volume of wastewater being released into the environment. Climate Action: Energy generation in water distribution networks The potential for generating energy through installation of in-line turbines in watermains has already been proven in a pilot project in Blackstairs GWS in County Wexford (see https://nfgws.ie/blackstiars- gws-reducing-its-carbon-footprint/). This cost-effective technology would be appropriate in Monaghan where electricity generating turbines could replace pressure reducing valves on many distribution networks. Again, this should be considered in conjunction with the GWS sector and Irish Water as well as with community organisations that may be able to avail of the energy generated. Climate Action: Energy generation from solar systems and back-up generators As with water conservation, incentives should be considered to promote the installation of solar energy systems in all new builds and in existing premises. In the case of business, an allowance on rates bills over a defined period of years would encourage take-up. In light of the projected impact on electricity supply due to more intensive storms as a result of Climate Change, installation of appropriate back-up generators should be encouraged for all businesses/facilities that rely on consistent service (e.g nursing homes and other health facilities). Biodiversity Enhancement: Maintenance of hedgerow At present Monaghan County Council sends a reminder on September 1st for landowners to commence cutting hedges. This needs to stop. Other than where there is an issue of public safety because of obscured sight lines, good practice is for hedgerow to be faced every 2-3 years. The current practice of cutting hedges low and tight is ecologically disastrous. At the very least, landowners should be encouraged by Monaghan County Council to hold off on hedge-cutting until haws and other berries have been eaten by wild birds. It is important to remember that many species overwinter in hedgerow. Biodiversity Enhancement: Herbicide/pesticide The County Council plan should lead by example in encouraging citizens to move away from the use of toxic chemical products to control unwanted vegetation. In addition: 1. a bye-law should be introduced prohibiting private citizens from applying herbicides on public property, including roadside verges near their properties and on bridges. 2. this bye-law should apply to Community Employment schemes/Tidy Towns also. 3. Council staff should only use herbicide for the control of invasive species where no other effective control is available. 4. an awareness campaign should be launched to convince the public of the environmental and human health issues that arise from the use of herbicide, replicating the campaign devised by Stranooden GWS as part of its Source Protection Pilot Project (See file:///C:/Users/User1/Downloads/PHASE-II-FINAL-REPORT.pdf) Biodiversity Enhancement: Mowing public spaces The plans should make a clear commitment to following the advice contained in the All-Ireland Pollinator Plan vis-à-vis reducing grass cutting in public spaces and leaving areas uncut. In tandem, there needs to be a Council-led campaign aimed at convincing members of the public that manicured green areas are bad for nature. A strategy is required aimed at changing mindsets in relation to how public spaces should be managed. While there are always going to be people who are fixated with ‘tidiness’, the plans should be unapologetic in championing a new and enlightened way of thinking about this issue. Again, this campaign should be run in partnership with community environmental organisations, Tidy Towns, schools etc. Biodiversity Enhancement: Collaboration with CE schemes/Tidy Towns The plans should encourage (and positively support) a change in the focus of Community Employment schemes and Tidy towns groups from the control of vegetation to biodiversity enhancement (through establishing and managing community composting and mulching facilities, collection, propagation and distribution of local wildflower seeds, management of native tree nurseries generated from locally collected seed etc.). The council could facilitate these initiatives through providing the use of appropriate publicly-owned sites. To their credit, several Tidy Towns groups are already committed to this more enlightened approach. Biodiversity Enhancement: Drainage sumps Pollution of the aquatic environment as a result of run-off from roads and other hard surfaces may be mitigated through the construction of sumps/ditches into which drains discharge. While it would be unreasonable to retrofit such sumps after every drain, the plans could at least commit to the installation of sumps on all future works on hard surfaces, including roads and car parks. Biodiversity Enhancement: Endangered wild bird species Wild birds, such as the endangered Swift, could be supported through a change in planning regulations to ensure that all new buildings include built-in nest boxes. County Mayo has seen a rise in the population of Swifts due to County Council promotion of in-built boxes on public buildings. Conclusion There are already many resources and guidance documents pointing to the steps needed to resolve environmental issues and the Monaghan GWS sector has, with the support of Monaghan County Council, been to the forefront of trialling practical strategies in this regard. In addition to the Stranooden GWS Pilot Project, which details efforts to reduce nutrient and herbicide impacts on the Dromore River system, the GWS sector has developed in partnership with the EPA a community-based approach to managing septic tank systems. More recently, Tydavnet GWS has opened a state-of-the- art environment education centre at Knocknagrave. Monaghan County Council would do well to build on these and other initiatives to become a leading local authority in relation to biodiversity enhancement and climate action. The Council plans should commit to a strategy aimed at restoring Ballybay Wetlands Centre to the purpose for which it was built and funded. Finally, the plans need to have a clear focus on co-ordinated action between Sections of the County council and between the County Council and a range of partners. The benefits of co-ordinated action, where various Statutory and voluntary organisations bring their particular skills to the table was demonstrated in the approach to the Stranooden project and, more recently, in co-ordinated efforts to address pollution pressures in the Mountain Water sub-catchment of the Blackwater (with LAWPRO acting as co-ordinator). These inter-agency fora ensure that all stakeholders are kept informed of what others are doing and they incentivise action. With the best will in the world, no local authority will be able to tackle the crises of our time without close collaboration across the entire Council team and with a range of external Statutory and voluntary organisations. Again, the co-ordination for all of this could rest in an enhanced and adequately resourced Environment Section.