In relation to the planning application for the redevelopment of the lands west of Pairc na Coille retirement village in the townland of Drumbiggle, I would like to make the following observations in relation to the Natura Impact Statement produced by MKO on behalf of the applicant, Leadlane Ltd. Inconsistencies appear through-out the document but I would like to point out specifically the complete lack of data in respect of pollinators and their habitat in the ecological impact assessment.
A walkover survey of the site took place on 24th May 2021 led by MKO ecologist Olivia O’ Gorman. This survey “was designed to detect the presence, or likely presence of a range of protected habitats and species” but was limited by access to certain areas of the site. Later on in the year, an arboricultural report was produced by Arbor-Care Ltd on 14th Oct, also as part of the Natura Impact Statement which concluded that “…the arboricultural impact of the proposed development on the site will be high, as the majority of the vegetation on the site will be removed to facilitate the development.” This very definitive conclusion is in stark contrast with some of the observations made by MKO following the walkover survey which seem to lack basic realism.
In the walkover survey report published by MKO, the area is described as having a distinct canopy, under-story, and ground layers. It goes on to detail twenty-seven species of Flora that support pollinators, specifically Butterflies and Bees. However, the report fails to mention the words Butterfly or Bee even once. The Bee and Butterfly friendly Flora recorded on site are as follows:
The lands are described in the report as being “densely vegetated with scrub vegetation consisting of Hawthorn, Willow, Bramble, Nettle” and “dense immature woodland consisting of ash, alder, and sycamore, and clusters of dense hawthorn with a ground storey comprised of areas of boulders covered within moss and plant species.” The immature woodland in question will be destroyed to facilitate this new development, therefore important pollinator habitats consisting of the plant species listed above will be wiped out forever.
The walk-over survey on 24th May 2021 was limited as some of the vegetation was so dense that it was impenetrable. How can MKO ascertain that no E.U Annex II protected Flora or Fauna are present within the site? More time and resources need to be allocated for the completion of this survey as was the case with the dusk and dawn Bat survey. Zero lesser horseshoes Bats were recorded during a dusk and dawn survey carried out by MKO but were recorded by the static detectors in the 19 day bat survey that followed. A one-day walkover survey of the site does not give a full picture.