IPCC Comments on draft County Development PLan 2022

Section 1.4.2 should highlight that by developing a National Peatlands Park the Government's National Planning Framework will be supported and the National Strategic Outcomes will be recognised. A National Peatland Park would be a focal point for intergrating all NSOs within the County of Kildare.

Peatlands once accounted for 14.3% of the landscape of County Kildare but the majority of Irish peatlands have been converted to other uses such as industrial peatland, agricultural land, afforested and cutover peatland. These are emitting greenhouse gases and contributing to climate change. The climate crisis means that land managers and individuals need to work together from all sectors to not only restore the carbon sequestration function in peatlands but to protect the carbon stocks in peatland and prevent further degradation. Without restoration of the hydrological and ecological functioning of peatlands climate change itself will accelerate further loss of peatland sites. As the emmisions from damaged peatlands and the carbon savings from peatland restoration are eligible for national carbon accounting under the UN Framework Convention on Climate change there is an oportunity for Ireland to inlcude peatland restoration and rewetting in the national climate action plans. County Kildare should also seriously look at the oportunity that has arisen from the end of industrial peat extraction which is leaving a large land bank available for consevation at a landscape scale which has to this time been un-available and a serious hinderence to proper conservation. The development of a National Peatlands Park would bolster and improve County Kildare's efforts in combatting climate change and strengthen all it's efforts in reversing biodiversity loss.

Many of the guiding principles will be supported by the development of a National Peatland Park and this should be highlighted within this section. (changes in bold)

(i) To develop a county that is resilient to climate change, plans for and adapts to climate change and flood risk, facilitates a low carbon future, supports energy efficiency and conservation and enables the decarbonisation of our lifestyles and economy. This principle is supported by the creation of a National Peatlands Park.

(vii) To recognise the role of the rural countryside in supporting the rural economy and its role as a key resource for education, agriculture, equine, bloodstock, forestry, energy production, tourism, recreation, mineral extraction and rural based enterprises, such as the creation of a National Peatlands Park.

(viii) To support, facilitate and promote the sustainable development of renewable energy sources in the county without hindering conservation at a landcape scale. (All developments, including renewable, need to be sensitive to the environment and biodiversity and should not hinder conservation at a landscape scale which Ireland is currently lacking).

(ix) To protect local assets by preserving the quality of the landscape, open space, recreational resources, natural, architectural, archaeological and
cultural heritage and the material assets of the county. This will be supported by the creation of a National Peatlands Park.

CSO 1.2 Ensure that the future growth and spatial development of County Kildare provides for a county that is resilient to climate change, enables the decarbonisation of the county’s economy and reduces the county’s carbon footprint in support of national targets for climate mitigation and adaption objectives as well as targets for greenhouse gas emissions reductions. The creation of a National Peatlands Park will further enable the county to climate change proof the landscape while providing for biodiversity and greenhouse gas emmision reductions.

CSO 1.7 Promote and facilitate the development of sustainable and socially integrated communities through land use planning, by providing for land uses capable of accommodating employment, environmental education, community, leisure, recreational and cultural facilities having regard to the quality of the environment, landscape character and the archaeological and architectural heritage. The intergration of the county's peatlands into a National Peatlands Park will also promote their ecosystem benefits, protect and store carbon and provide for biodiversity while highlighting sustainable living.

CSO 1.8 Support the implementation of Kildare’s Climate Change Adaptation Plan in conjunction with all relevant stakeholders including the creation of a National Peatlands Park to support all climate change adaptions, biodiversity recovery, Sustainable Development Goals and the National Planning Framework.

4.24 Peatland Tourism

The end of industrial extraction of peat within the County has heralded a new oportunity to reverse the biodiversity loss and greenhouse gas emmisions emmanating from the large expanses of brownfield sites. The benefit from the rehabilitation and restoration of these areas in terms of conservation and ecosystem services can not be understated. Coupled with the development of the blueways and greenways, creating a corridor for toursim the peatlands of County Kildare can be the gateway for the midlands bringing international and domestic visitors. If sensitive to the receiving environment there is a chance for a sustainable tourism economy, creating jobs and supporting the indigenous population who also benefit from the local environmental amenity.

The IPCC suport the creation of National Peatlands Park (please change from National Peatlands Heritage Park) which celebrates the close connection of the people and peatlands but heralds a new appreciation of the globally unique peatland habitats.

IN O32

Recognise the important role of natural boglands and other wetland areas in flooding patterns. Development in these areas shall therefore be subject to a Flood Risk Assessment in accordance with the relevant guidelines.

Please explain "natural" boglands, there is very few intact raised bogs left and these should never be developed. This action should be further expanded to include all peatland, as the rehabilitation of which will improve flood retention and water quality. The Council should strive to rehabilatate and restore as much peatland as possible if climate change mitigation and flood relief is really on the agenda. The IPCC suggest the removal of the word "natural".

EC O11

Encourage wind energy developments in suitable locations in an environ- mentally sustainable manner whilst having regard to Government policy and the County Wind Energy Strategy.

Please ammend to...

"Encourage wind energy developments in suitable locations in an environ- mentally sustainable manner whilst having regard to Government policy and the County Wind Energy Strategy while being sensitive to the EU and national target of 30% of land for biodiveristy"

The rush for renewable energy has fragmented rare and unique blanket bog habitat and this should not happen to the conservation potential of the brownfield sites which have come out of industrial production within the County. The renewable energy agenda should be sensitive to biodiversity and conservation.

7.12.7 Peatlands

EC P17

Support the preparation of a comprehensive “after use” framework plan for the industrial peatlands and associated workshops, office buildings, industrial sites and power stations in Kildare, acknowledging the significant contribution that these expansive lands make towards the special landscape of the Bog of Allen including the creation of a National Peatlands Park, being a focal point for the environmental landscape, conservation and amenity.

EC O53

Support the implementation of the recommendations contained in the National Peatlands Strategy 2015 and any subsequent revisions including the creation of a National Peatlands Park and Peatland Centre of Excellence.

County Kildare has huge potential in conservation and biodiversity and the end of industrial extraction puts forward a new agenda in terms of economic sustainability, County Kildare should seize the oportunity to engage with stakeholders and develop a new Peatland Centre of Excellence as set out in the National Peatland Strategy. The County already has many environmental educational facilities which could support this, such as the Bog of Allen Nature Centre and Lullymore Heritage and Discovery Centre but this needs to be first realised in policy and joined up thinking.

8.2.4 Kildare 2025 Economic Development Strategy

Please include.....

This strategy outlines 5 Strategic Objectives for the Plan, which include:

1. Strengthen the resilience of our retail sector to rebuild stronger and greener

2. Facilitate and support the retail offering’s expansion and sustainment in County Kildare.

3. Measures to revitalise town centres.

4. Explore new opportunities in the circular economy for our retail businesses

5. Enable retailers to adopt online business models.

6. Provide branding, identity and linkage oportunities by creating a National Peatlands Park brand incorporating the peatland landscape charactor into the economic and retail sector.

Please ammend.....

Peatlands form a distinctive aspect of Kildare’s Landscape. They represent some of the counties last areas of wilderness. The former Bog of Allen is the largest raised peat bog in Ireland. At over 950 square kilometres, it spreads across nine counties, including Kildare, and is the source of the River Boyne. Contained within this bogland in Kildare are a number of protected sites, the former boglands of Bord Na Móna and a number of visitor attraction centres around the bogland heritage such as Lullymore. There are also many sites that are not protected that will be recognised within the plan, such as the sites listed within the Bog of Allen Heritage Survey and the Kildare Wetland Survey. With the end of industrial peat extraction the CDP will move forward with the creation of a National Peatlands Park linking them with environmental corridors. This will bolster tourism oportunities while being sensitive to the needs of biodiversity and conservation. This will offer visitors a unique experience and provide a gatway to the peatlands of the midlands. The National Peatland Strategy 2014 which set targets for the re-use of cutaway bogs in terms of environmental protection, forestry, energy production and recognises the importance of this peatland landscape and promotes the concept of a National Peatland Park to explore the rich natural, archaeological, and cultural heritage of this unique landscape.

This section should be removed as "economimcal purposes" is too vague. How does this tie in with the 30% of land for biodiversity and conservation as highlighted elsewhere in the plan?

RD O28

Work with all relevant stakeholders including Bord na Móna to support the sustainable re-use of circa 30-50% of cutaway boglands for economical purposes.

BIO3

The Council should consider that the protection of all wetlands identified within the Kildare Wetland Survey should be a priority. In particular boglands within the county have been reduced to just 12% of conservation worthy sites from the original extent of peatland and theses should be a priority for protection and carbon storage.

12.14.6.8

Ummeras Bog

This area is proposed for a Peatlands National Park which will form part of the wider National Peatlands Park, which is supported by the Council.