Specific Comments on the SEA ER

Section 2 – The Draft Masterplan

In Section 2.5 - Relationship with other relevant Plans and Programmes, we acknowledge the plans/programmes referred to in Table 2.1 Relationship with Legislation and Other Plans and Programmes. It may be useful to consider including a reference to the following key plans also:

• Irish Water’s Water Services Strategic Plan (WSSP)

• Southern Regional Waste Management Plan

Section 7 – Evaluation of Alternatives

We acknowledge the alternatives considered for the development of the Plan area and also the detailed assessment carried out in Section 7.4 - Detailed Evaluation of Alternatives. The reason for selecting the preferred alternative is also clearly described. We note the findings of Table 7.5 – Significant positive effects facilitated, potentially significant adverse effects, if unmitigated, and residual non-significant adverse effects. This table clearly summarises the key identified issues to be taken into account, as well as the possible environmental benefits of implementing the preferred alternative.

Section 9 – Mitigation Measures

We note that lower level ‘strategies’ are to be put in place to deal with issues such as conservation and heritage, connectivity aspects, sustainable development, environmental protection etc. We also acknowledge that where specific measures are not provided in the Plan, that the higher level objectives / policies of the City and Environs Development Plan (CDP) will be implemented. It should be ensured however that no conflict arises between any measures proposed in the Plan and the relevant objectives/policies of the CDP.

Section 10 – Monitoring Measures

We acknowledge the proposed monitoring programme, which includes the frequency of environmental monitoring and which highlights the associated ownership of monitoring responsibilities in Table 10.1 Selected Indicators, Targets and Monitoring Sources.

Future Amendments to the Draft Plan

Where amendments to the Plan are proposed, these should be screened for likely significant effects in accordance with the criteria as set out in Schedule 1 of the SEA Regulations and should be subject to the same method of assessment applied in the “environmental assessment” of the Draft Plan.

SEA Statement – “Information on the Decision”

Following adoption of the Plan, an SEA Statement, should summarise the following:

• How environmental considerations have been integrated into the Plan;
• How the Environmental Report, submissions, observations and consultations have been taken into account during the preparation of the Plan;
• The reasons for choosing the Plan adopted in the light of other reasonable alternatives dealt with; and,