The developer has submitted new documents as part of the planning application for the repurposing of the lands adjacent to Pairc na Coille, Ennis co Clare.
Included is an updated Environmental Impact Assessment which attempts to downplay the impact.
This new development could have on the local environment including the Bat population.
The methodology used to ascertain potential impacts.
The scope of the bat survey, and the vague conclusions reached by the applicant fall short of providing any sort of evidence that this development.
Will not have a significant adverse impact on the natural environment at the site beyond.
An E.I.A provided by a developer should include two important parts which seem to have been ignored by MKO:
A new E.I.A is required to address this omission, especially in the case of the Annex IV species which reside and feed on the site.
No reasonable alternatives have been explored by the developer for housing development in Ennis.
Why should a mature wooded area of significant value to the ecology of the area be destroyed?
when other viable sites nearby are far more suitable?
The Bat survey included in the E.I.A is completely unreliable and must be revisited.
The two static detectors were strategically placed at two locations without any explanation or reasonable justification.
Whether intentional or not, these two locations are located at the north end and center of the site.
And one detector is placed close proximity to a road with street lighting.
The other detector is placed well below the trees.
The detector used requires no obstruction in its path to get a maximum detecting range of about 20 meters.
Because of the location here maximum detecting range would be 1 or 2 meters at best
Bats must not be exposed to unnecessary levels of light and sound and will always choose to forage in unlit and quiet areas over noisy and lit-up areas.
A new survey with more static detectors was placed throughout the whole site.
And a comprehensive report on whether or not roosts are present should be carried out and published accordingly.
Bats are protected under the EU Habitats directive and they are of significant importance to agriculture.
As they eat the pests. (several thousand each per night) which attack crops.
The Lesser Horse Shoe Bat which was recorded in this report as being present is on the ‘threatened’ list.
The Irish population of this bat is very important.
Because it is one the largest in Europe and County Clare is one of only 6 counties where this Bat has been recorded.
The site next to Pairc na Coille provides perfect foraging and potential.
Roosting opportunities for the Lesser Horse Shoe due to its proximity to The Edenvale and Newhall complex.
which is part of a wider S.A.C and crucial to the conservation of the species.
The site at Pairc na Coille is thriving with Bats and Clare County Council and a Bord Pleanála must ensure enough scope is given to survey the area in full.
Two detectors at two questionable locations for 19 days doesn’t cut it.
The site in question is situated in part on a slope and its redevelopment will present challenges with regard to drainage.
Trees capture up to 60% of rainfall, reducing surface water runoff entering our drainage systems, reducing flooding potential.
Cities and townlands throughout the world that suffer from seasonal flooding such as Ennis are in urgent need of rethinking their flood management strategies.
Trees in villages, towns, and cities can play an important part in water management.
Including safeguarding water quality and contributing to flooding alleviation.
In recent years, flooding has become an increasing cause for concern in Ennis due to heavier rainfall.
Heavy storms are becoming more common in Ireland and it is predicted that changing weather patterns are likely to continue.
Rainfall in winter has increased and unprecedented flooding has destroyed businesses and homes up and down the country.
The Office Of Public Works (OPW) recently acknowledged that the budget for the new flood control scheme in Co Clare has nearly doubled to close to €20 million.
Due to ‘unexpectedly’ poor ground conditions so would it be wise to lay concrete over the entirety of a mature wooded area close to the town center?
Ennis County Council would be ripping out the natural drainage systems which not only help to alleviate flooding but ensure the watercourses are regulated for toxins.
According to a report by Teagasc, the benefit of trees in towns and cities can see a 75% reduction in sediment mobilization.
And runoff into watercourses and a 75% interception of nutrient run-off into watercourses.
Trees and other green spaces intercept rain, reducing the volume and rate of runoff.
The leaves, branches, and trunks of trees slow the speed at which rain reaches the ground, with some rain evaporating into the atmosphere.
An interception by trees increases the volume of water that infiltrates into the soil, giving drains longer to carry rain away.
Slowing the speed at which rainwater reaches the drains reduces the risk of surface water flooding and pollutants harming water quality.
It is possible, therefore, that allowing for this development to go ahead could,
In turn, lead to increased flooding in areas by overwhelming the already overworked sewage system in Ennis.
The properties surrounding the site at present are free from flooding.
As the site is naturally sloping, its redevelopment could possibly pose risks for some of these properties.
That, coupled with the risk of adding to the present drainage and flooding issues experienced in Ennis.
Should raise alarm bells and the planning application must be opposed.
Scientist now retired.