As with the SEA, the NIR has 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. This means that the Lower River Suir cSAC has been excluded.
Cumulative impacts are examined in table 2-3. However, this does not include the linear parks already in existence which could have a cumulative impact with the new one proposed.
Apart from a risk to water quality which, depending on the hydrological conditions, could have an impact some distance downstream, there is also a risk to the qualifying interests of kingfishers and otters. While the NIR has concluded no significant adverse effect on the integrity of the Natura 2000 network, this has been done on the basis of mitigatory policies. This Department would have expected some data to be presented of the use of the site by otters and kingfishers in the NIR which would lead to recommendations with regard to ecological constraints that may be present and could impact on the design of the linear park. Alternatively, an assumption that these species are present could have been made and a discussion included of the type of mitigation necessary to ensure no adverse impacts on these species, including their food source and the aquatic and terrestrial habitats they use.
It will be essential therefore, as stated above for SEA, that prior to any final design for the linear park an ecological survey/EcIA will be necessary to ensure no negative impacts on the qualifying interests for the Natura 2000 sites. It will also be essential that the ecologist working on the appropriate assessment (AA) screening/AA for the project is consulted at the start of the project so that any necessary mitigation or design changes can be incorporated early in the project.