EU Habitats Directive 92/ 43/EEC Article 12 states that:
1. Member States shall take the requisite measures to establish a system of strict protection for the animal species in Annex IV (a) ‘in their natural range prohibiting,
(b) deliberate disturbance of these species, particularly during the period of breeding, rearing, hibernation, and migration,
(d) deterioration or destruction of breeding sites or resting places.’
I have been keeping a close eye on how the situation relating to the lands adjacent to Pairc na Coille retirement home has been evolving. The developer has commissioned an environmental impact assessment which at first glance appeared to be a whitewash. Upon further examination, I have discovered so many flaws especially with regards to the scope and methodology used to determine and ascertain whether or not this development has the potential to adversely impact Bat populations in the area, specifically the Lesser Horseshoe Bat, an Annex IV species, which is protected by E.U law as stated above.
I would like to bring special attention to the following: “Two static detectors, one at the north-east of the site (Grid Ref: R 327RO 76609) and one at the center perimeter of the site (Grid Ref: R 32854 76605), as shown in Figure 5.2, were deployed for a total of 19 days. These detectors allowed a specified look into species composition, commuting and foraging activities within the site.” What was the reasoning behind placing the two detectors here for the complete duration of the survey? To gain a more comprehensive picture of bat activity, it is essential to survey more than two specific locations in such a large area. The two locations that were surveyed are arguably two areas that bats would avoid due to the prevalence of anthropogenic noise and lighting namely street lights and traffic. Of the 1997 bat passes recorded over the 19 days, approximately 60 were the Lesser Horse Shoe Bat. This is a significant finding especially when you consider the placement of the static detectors at the north end and center of the site. The southern end of the site would likely see more Lesser Horseshoe activity due to its closer proximity in terms of the flight path to two other sites of significant importance for this particular Bat.
The Newhall and Edenvale complex which is a proposed Natural Heritage Area and part of a wider Special area of conservation is located 1.8km south of the site in question. This PNHA has special significance as a roosting site for the Lesser Horse Shoe Bat. Cahircalla Woods, another pNHA, is situated only 1.1km south of the site and has been mapped by NPWS as a feeding ground for the bat.
The range of the lesser horseshoe bat in Ireland is, for the most part, limited to six western counties – Clare, Cork, Galway, Kerry, Limerick, and Mayo. The Irish population of this species is estimated at 14,000 individuals and is considered of International Importance because it has declined dramatically and become extinct in many other parts of Europe.
The site next to Park na Coille is within the core foraging range of this bat and in the E.I.A it states that “from a precautionary perspective, a pathway for indirect effect was identified as a result of disturbance. The site is considered to be in the likely zone of impact and further assessment is required.”
The use of the word “indirect” baffles the mind. To deny animals access to a part of their core foraging range by intentionally destroying an essential area that they use is a direct action that impacts on their chances of survival. These bats are creatures of habit and spend lifetimes mapping out pathways and networks. The proposed destruction of the wooded area at Pairc na Coille would break an important link and potentially have a detrimental impact on the bat population.
The council must re-examine the scope provided to the developer for this assessment and ensure correct protocols are followed and sufficient surveying of the site is completed. The developer must re-visit and commission a new, comprehensive study into the potential impact of re-developing this site and destroying what is an essential natural habitat for a rare protected animal.
As stated in the E.I.A, by MKO “The site is considered to be in the likely zone of impact and further assessment is required.”