Planning for biodiversity: The National Peatlands Park

Chapter 12 Biodiversity and Green Infrastructure

Butterfly Conservation Ireland (BCI) offers the following comments concerning and suggested amendments to Chapter 12 of the Kildare County Development Plan 2023-2029. Key comments and suggested amendments are indicated in bold.

12.5.3 County Kildare Biodiversity Action Plan 2009-2014

At 12.5.3 remove the sentence: The County Kildare Biodiversity Plan will be reviewed during the lifetime of this plan. Replace with: A new County Kildare Biodiversity Action Plan will be published by 2024.

Reason: a central Kildare resource containing biodiversity aims, objectives and initiatives is essential. This document will illustrate the large reach, responsibility and accountability of the Council and partner organisations for biodiversity and the protection of nature. This new enhanced objective to reach 27% of land for nature (see Chapter 13) should provide the cornerstone of the Plan with milestones for the achievement of this target. A published document will help inform the public, ensure implementation, and form a tool to track progress

At BI A3 remove the sentence: Review the County Kildare Biodiversity Plan within the lifetime of this Plan.

Replace with: Publish a new County Kildare Biodiversity Action Plan by 2024

12.6.1 Natura 2000 network

BCI welcomes the policy and objectives stated under 12.6.1 to protect Natura 2000 sites and their environs and the Council’s support for any management plans for European sites.

12.8 County Biodiversity Sites

At 12.8 the Plan states “Many sites of biodiversity value within the County do not meet the criteria that would enable them to be designated at an international or national level”.

Replace with: “Sites of biodiversity value that meet the criteria for designation at an international level which remain undesignated and sites of biodiversity value that do not meet the criteria that would enable them to be designated at an international or national level exist in the County”.

Reason: The statement  at 12.8 is not wholly accurate. Some sites that meet the criteria, such as Lullymore West, Lullybeg Nature Reserve, Harristown Common, and Kingsbog Common meet the criteria for designation but have been left without formal designation.

For example, Harristown Common meets at least three qualifying characteristics for a Special Area of Conservation.

The fen habitat characteristics on the eastern section of  Harristown Common appears to correspond to alkaline fen (Natura 2000 code 7230) protected under Annex I of the E.U. Habitats’ Directive. Molinia meadows on calcareous, peaty or clayey-silt-laden soils (Molinion caeruleae) (Natura Code 6410) is also present. A further qualifying feature for a Special Area of Conservation, the Marsh Fritillary (Natura 2000 Code 1065) also exists on the site. The presence of the very rare, protected mollusc, Vertigo geyeri (Natura Code 1013), a qualifying feature for a Special Area of Conservation, looks likely especially on the fen on the eastern section. It is possible that a petrifying spring, (a Schoenus nigricans Spring), is also present, on the eastern section. This feature is a priority habitat in Annex I of the European Union Habitats Directive.

12.8.1 County Biodiversity Sites

The policy and objectives stated here are broadly welcome. However, BCI is concerned regarding the action at BI A10 to “Work with Teagasc and landowners throughout the county in order to identify suitable ‘Hare’s Corner’ projects which would create pocket sized habitats in order to enhance biodiversity.”

While broadly welcome, such habitat creation initiatives must apply appropriate design (avoiding unsustainable enhancements) and link the habitats with compatible habitats in the wider landscape to avoid the risk of creating ecological traps. This occurs when an animal selects a habitat that appears suitable but which lacks the resources necessary for survival and reproduction found in more suitable areas because the unsuitable habitat appears more attractive[1].

12.9.1 Hedgerows contains the sentence: These species are listed in Chapter 16, Development Management Standards.

This should read: These species are listed in Chapter 15, Development Management Standards.

Reason: Typographical error in 12.9.1.

At 12.9.1 it is stated: “This coupled with the fact that two-thirds of hedges adjoin intensively managed farmland, means that there are implications for the overall biodiversity potential of the resource.”

BCI recommends that the Plan should encourage the retention and appropriate management of extended width margins, and that hedge-cutting should be carried out to allow more individual hedgerow trees to grow to maturity.

Reason: Merckx et al. (2012)[2] found hedgerow trees and extended width margins locally increased the number of larger moth species (but not abundance). The study found that where hedgerows containing hedgerow trees with extended field margins are present, species richness and abundance were not affected by intensive farming, measured by the amount of arable land in the landscape.

The study recommended increasing the density of hedgerow trees to lessen the effects of agricultural intensification. The study underlined the value of hedgerow trees, claiming “a disproportionate effect on ecosystem functioning given the small area occupied by any individual tree.” As moths are a key component of the eco-system with many associated species, the effects arising from hedgerows and trees described for moths apply to many other animal groups.

12.9.2

BI O15 and BI O16 refers to the use of “native plants of local provenance.” The Council may need to harvest seed locally for this purpose or obtain seed certified as being of local provenance from as close as possible to the locality. The nearest source known to BCI is in County Wicklow (https://nonesohardy.ie/native-woodland-scheme/).

BCI recommends that the Council operates a nursery to grow native plants of local provenance to ensure the objective is achieved.

12.10.1 Riparian Zones

BCI welcomes the policy and objectives stated here, and especially BIO30:

“Avoid developing walking/cycling trails through sensitive ecological habitats. A multi-disciplinary team including an ecologist and flood risk expert shall review all riverine sites to determine the appropriate zonation (ref Table 12.4) and permissible uses”.

12.11 Wetlands and Ramsar Sites

BCI notes that most of the wetland sites we advocate for inclusion in a new National Peatlands Park are listed in Table 12.5 as sites of ecological importance. These are: Allenwood South West Bog – Lodge, Ballybrack Bog, Ballydermot, Ballydermot (Derrybrennan), Ballysooghan Bog, Bog of Allen Killinthomas – Ballydermot, Crabtree River – Ballydermot, Cushaling East Wet Heath – Ballydermot, Cushaling River Valley, Drumsru Bog – Lodge, Lodge Bog cNHA – Lodge, Lodge Bog cNHA – Lodge, Lodge Bog South cNHA-Lodge, Lullybeg Butterfly Reserve, Lullybeg Cutaway - Ballydermot (Lullymore), Lullymore East Cutaway – Lodge, Lullymore Wetlands-Ballydermot (Lullymore), North of Heritage Park, West of Lugherra River and Ummeras Bog.

BCI welcome the policy stated at BI P8: “Ensure that Kildare’s wetlands and watercourses are retained for their biodiversity and flood protection values and maintain good ecological status of wetlands and watercourses in support of the provisions of the Water Framework Directive and Ramsar Convention”.

BCI welcomes the objectives BI O31- BI O34 and assert that these objectives can best be met by the Council’s support for the creation of a new National Peatlands Park in northwest Kildare.

12.14.5 Kildare County Council’s Green Infrastructure Strategy

12.14.6.5

Here the Plan states:

Within the Bord Na Mona landownership complex there will be a need to develop a separate masterplan that will identify its own Core Areas, Stepping Stones and Connections/Corridors. This masterplan should, at a minimum, include the following ‘core areas’ – one should centre around Lullymore Heritage Park, Lullybeg Wetlands, Butterfly Reserve, Lodge Bog – with an extensive buffer zone; a second core area would focus on Ballynafagh Bog, Ballynafagh Lake and Hodgestown Bog; a third area would focus on Killinthomas Wood (Coillte owned), Ballydermot Bog East; a fourth would focus on Ummeras. Each of these would be connected either through the Grand Canal Greenway or the Barrow Blueway/Slate River and/or new and broad Peatway Corridors (the Connectors) and elsewhere there will be other ‘stepping stones’ in the form of key wetlands, intact raised bogs, woodlands, etc. A number of proposed long distance peatways that could connect the Royal Canal with the Grand Canal/Barrow Blueway are listed below in Section 12.14.8.8. It is expected that 50% of the Peatland Area will remain free from any development.

Comments: BCI agrees that the Bord na Móna masterplan should include the areas listed at 12.14.6.5 but emphatically “at a minimum.” Furthermore, the peatland sites listed at 12.14.6.5 (except Ballynafagh Bog, Ballynafagh Lake and Hodgestown Bog) and Ummeras Bog exist as part of the larger area proposed as a new National Peatlands Park, supported by the Council (Chapter 4 4.24, RE O126, RE O127). In that context, BCI welcomes the action stated at BI A22 to: “Work with Bord Na Mona to prepare a Green Infrastructure Masterplan that will inform the delineation of core areas, stepping stones and corridors (long distance peatways) as identified in Sections 12.14.6, 12.14.7and 12.14.8, that may inform the designation of an interconnected Bog of Allen Nature Reserve, Special Amenity Area Order and/or National Peatlands Park.”

BCI also requires clarity concerning the statement, “It is expected that 50% of the Peatland Area will remain free from any development.” The loss of any peatland or any semi-natural habitat is of serious concern to BCI.

Reason: This does not align with objectives stated elsewhere in the Plan, such as at 12.8.1: “It is the policy of the County to (BI P5) Identify and conserve locally important biodiversity sites in the county which contribute to the overall ecological network of County Kildare.”

Reason: It does not align with the policy stated at BI P8: “It is the policy of the Council to ensure that Kildare’s wetlands and watercourses are retained for their biodiversity and flood protection values and maintain good ecological status of wetlands and watercourses in support of the provisions of the Water Framework Directive and Ramsar Convention”. The objectives flowing from this policy would also be unmet if half of our peatlands were subject to development.

Reason: According to the Natural History Museum in London, out of all EU countries (including the UK) only Malta is worse in terms of biodiversity loss than Ireland[3].

Submission prepared by Jesmond Harding, Butterfly House, Butterfly Conservation Ireland, Pagestown, Mulhussey, Maynooth, Co. Kildare W23 N8C2.

[1] Robertson, Bruce A. and Hutto, Richard L., "A Framework for Understanding Ecological Traps and an

Evaluation of Existing Evidence" (2006). Biological Sciences Faculty Publications. 284.

https://scholarworks.umt.edu/biosci_pubs/284

[2] Merckx, T., Marini, L., Feber, R.E., Macdonald, D.W., Kleijn, D. & Sveriges lantbruksuniversitet 2012, "Hedgerow trees and extended-width field margins enhance macro-moth diversity: implications for management", The Journal of applied ecology, vol. 49, no. 6, pp. 1396-1404.

[3] https://www.nhm.ac.uk/discover/news/2020/september/uk-has-led-the-world-in-destroying-the-natural-environment.html#:~:text=While%20countries%20such%20as%20Canada,UK%20only%20has%2050.3%25%20remaining.

[1] Robertson, Bruce A. and Hutto, Richard L., "A Framework for Understanding Ecological Traps and an

Evaluation of Existing Evidence" (2006). Biological Sciences Faculty Publications. 284.

https://scholarworks.umt.edu/biosci_pubs/284

[2] Merckx, T., Marini, L., Feber, R.E., Macdonald, D.W., Kleijn, D. & Sveriges lantbruksuniversitet 2012, "Hedgerow trees and extended-width field margins enhance macro-moth diversity: implications for management", The Journal of applied ecology, vol. 49, no. 6, pp. 1396-1404.