While overall the SEA is comprehensive with respect to the natural heritage it has unfortunately been restricted to looking at designated sites within a 15km radius which is a rule of thumb often used for Plans but is not suitable for rivers where a whole catchment may need to be included.
The SEA objectives B1-B3 are comprehensive. However the indicator for B1 has been restricted to the article 17 reports of this Department which does not include birds. In addition objective B3 has only included compliance with the Wildlife Acts 1976-2010 with regard to the protection of species in schedule 5. This means that birds and plants have been omitted. All wild birds are protected under the Wildlife Acts and protected plants are listed in SI 274 of 1987.
The SEA refers to a habitat survey which indicates the habitats to be impacted are “River Nore” and “grassy banks”. The photographs in the Masterplan appear to indicate that some of the river is bounded by wall but that some still has riverbank vegetation. Such vegetated areas are important refuges for biodiversity and may be used by otters. Prior to any final design for the linear park an ecological survey/ ecological impact assessment (EcIA), will be necessary to ensure no negative impacts on the ecological corridor or species such as otter and kingfisher, listed on the annexes of the Habitats and Birds Directives respectively.
Prior to finalising project details the Local Authority may find it useful to consult the IFI publication entitled “Planning for watercourses in the urban environment” which can be downloaded from their web site at http://www.fisheriesireland.ie/fisheries-management-1/86-planning-for-watercourses-in- the-urban-environment-1 .
With regard to bat species, which are protected under the Wildlife Acts and listed on annex IV of the Habitats directive, any Plan for the area must take account of bat roosts and foraging sites and appropriate lighting should be used so as not to negatively impact on bat species where necessary. The SEA does not appear to have sourced any baseline data on bats.