The proposed Moving of the town developent line into the SAC/SPA/pNHA area within Ballyragget will be nothing but detremtial to the biodiversity of our town. 

There has been numerous studies done in the past that have showed how integral the area is to the area and is inhabitands. also the fact that this area is adgacent to the floodplain is also inviting contamination from runoff from potential construction and from any proposed residents of any developments.

Any potential spill of herbacides being used by residents in their gardens or especially on pathways would be detremential for the SPA/SAC and would end up wiping out a large amount of the water based environment espcially the highly coveded salmon run that is a critical partener in the regeneration of the totaly unique spiecies of fresh water perl muscle that the only place in the world it is found is in our area of the nore and any damage to the salmon an trout stocks would surley be detremtial the the survival of the Nore Freshwater Perl Muscle




The River corridor
• Designated as Natura 2000 sites protection under EU law, River Barrow and River Nore SAC 002162 and River Nore SPA 004233
• River Nore / Abbeyleix Wood Complex pNHA 002076 status has limited protection. Recommend that proper legal protection is provided by designating the site as an NHA.
• While the Draft County development plan has identified the pNHA site in the county as the same status as an NHA the SEA has not identified the limited legal protection of the pNHAs in its assessment

See below from NPWS website
In addition, there are 630 proposed NHAs (pNHAs), which were published on a non-statutory basis in 1995, but have not since been statutorily proposed or designated. These sites are of significance for wildlife and habitats. Some of the pNHAs are tiny, such as a roosting place for rare bats. Others are large - a woodland or a lake, for example. The pNHAs cover approximately 65,000ha and designation will proceed on a phased basis over the coming years.
Prior to statutory designation, pNHAs are subject to limited protection, in the form of:

• Agri-environmental farm planning schemes such as Rural Environment Protection Scheme (REPS 3 and 4) and Agri Environmental Options Scheme (AEOS) continue to support the objective of maintaining and enhancing the conservation status of pNHAs. The farm plans operate for a period of 5 years. REPS 4 plans will continue to operate until 2014.
• Forest Service requirement for NPWS approval before they will pay afforestation grants on pNHA lands,
• Recognition of the ecological value of pNHAs by Planning and Licencing Authorities.
Under the Wildlife Amendment Act (2000), NHAs are legally protected from damage from the date they are formally proposed for designation.



Kilkenny Local Area Plan Habitat Assessment 2010 - Ballyragget
• Identifies the area along the river of International importance.
• Identifies hedgerows of local importance (higher value)
• Identifies hedgerows of local importance (lower value) and other habitats.


Freshwater Pearl Mussel and the Nore Freshwater Pearl Mussel
• Environmental Assessments has identified unfavourable to bad status in 2008, decline in 2013, decline in 2018.
• Commitment needed to improve the quality of water within the catchment. What efforts are proposed to reach the high water status of programmes such as the Blue Dot catchment programme?
• Provide protection for the river corridor of the River Nore and the tributaries that discharge to the river.


Green Infrastructure
• Designated sites (SAC, SPA, NHA) should have links to locally biodiverse areas
• Wildlife corridors, hedgerows, tree lines, woodland habitats etc
• Stepping stone areas where there is a gap in connectivity between wildlife corridors smaller ecological areas can be used to reduce the distance between wildlife corridors.

Some of the known wildlefe seen by our residents associaton
Breeding pairs of otters, their dens are within our SAC and pNHA, also to note when it floods they come up into the area that has been proposed to be rezoned in the new CDP
Nesting pairs of Grey Heron - they are constantly feeding on frogs in the SAC and propised development are have nested in an ajecent area to the development area.
Little Igrets are seen annually using the space for feeding.

King fishers somtimes come to the inner ditch in times of flooding in order to feed and escape the flood waters.

The adjacent field is a thourroughfare for birds of prey that can be seen on a daily basis, the are perching on treetops and hunting mice, rats, frogs and rabbits etc, converting this area into a developed area would have a large impact on their feeding habits.

Under both of our bridges there is an abundance of eels crayfish and if this area was to be contaminated it would be detremential for them.

The popsed expanded development area is also a thourrough fare for other wildlife like foxe's, badgers, pinemartins among others 
Bats - there is currently an abundance of bats in the area and the can be seen all over the SAC/SPA/pNHA and the sourrounding fields with atleas one known colony in a very close vicinity to the proposed expanded development area.

“Sustainable use of infill and brownfield sites over the use of greenfield sites”.
There is an abundance of other area's within the small town of ballyragget that could be developed on that would not have any risk of an environmental impact as building directly adjacent to the SAC/SPA/pNHA




Main opinion: 

The County Council should take the serious risk to SAC/SPA/pNHA in ballyragget and give it the respect it deserves, ratify it as a NHA and give it its deserved legal protection, seriously consider totally removing the development boundary from any adjacent lands and carry out the necessary surveys and engage with residents on how to work with them to improve the area to the benefit of both the environment and the people of the town.

Main requests: 

While the Draft County development plan has identified the pNHA site in the county as the same status as an NHA the SEA has not identified the limited legal protection of the pNHAs in its assessment

Main reasons: 

for the betterment of our environment and all its inhabitants and hopefully help in the regeneration of all its wild life including the Nore Fresh water pearl muscle.