Re: County Kildare Biodiversity Action Plan 2026-2031
Butterfly Conservation Ireland Limited is a conservation NGO and registered charity formed in 2008 by a group of dedicated naturalists following the alarming decline of most of our butterfly species. This decline has been ongoing since the 1970s and has accelerated since 2008. Butterfly Conservation Ireland is committed to the conservation of butterflies, moths and their habitats.
Butterfly Conservation Ireland operates a nature reserve at Lullybeg, County Kildare in partnership with Bord na Móna. Active conservation techniques are applied on the 30-hectare site to enhance the habitats for several scarce and endangered species.
Butterfly Conservation Ireland advises and provides information to organisations, the general public and individuals concerning butterfly conservation. We make submissions on developments that would impact negatively on important butterfly areas and endangered species. We run a programme of events, free to all. Our website is found at https://butterflyconservation.ie/wp/. Our submission to the Kildare County Biodiversity Action Plan is stated below.
National Peatlands Park
The cessation of peat cutting by Bord na Móna on state-owned land is a great opportunity for the provision of a new national park. The eastern midlands region has no national park, while the western seaboard counties have five national parks with one in County Wicklow. The area of these national parks ranges from 1500 hectares in the case of the Burren National Park to 20,000 hectares in the case of the Wicklow Mountains National Park. The Ballydermot Bog group, comprising Bord na Móna land in the townlands of Lodge, Barnaran, Blackriver, Ballydermot North and South, Codd 1 and Codd2/Sheridans, Lullymore and Lullybeg, Killina, Glashabaun North and South, Derrybrennan and Ticknevin comprises around 7,000 hectares. There are other important boglands in Kildare including Ummeras and the Kilberry bog group which should form part of the Peatlands park. The Ballydermot Bog Group area is a superb wilderness and consists mainly of former raised bog habitat that has been cut for peat. The peat-cutting process has resulted in the development of a range of habitats and land uses. Some of these habitats and land uses have led to the development of species-rich habitats. The main habitats that exist in the area are bogs, acid and calcareous grassland, scrub, mixed and deciduous
woodland, marsh and open water habitats such as flooded cutover bogs and rivers. This diversity has resulted in a stunning landscape in many areas, with a varied landscape contour pleasing to the eye and offering a unique experience for nature lovers, walkers and ramblers, horse riding and many other activities.
In some areas, a number of these habitats exist in close proximity, creating habitat mosaics with high biodiversity value, especially for invertebrates. This mosaic can be seen in areas such as Lullybeg at and around N 68796 25640. Habitats that exist here are mixed and deciduous woodland, scrub, flooded cutaway, ponds, acid and calcareous grassland and fen. Within these broad habitat descriptions are specific habitat types defined by Fossitt (2000). The following grasslands have been identified at Lullybeg: dry calcareous and neutral grassland, dry meadows and grassy verges, dry-humid acid grassland and wet grassland. This habitat diversity applies to other habitats elsewhere in the area.
The Lullymore/Lullybeg/Glashabaun/Blackriver areas are particularly important for butterflies. The importance of Lullymore and Lullybeg for butterflies has been recognised for many years. The report by Nash et al. (2003) describes the area as one of the three prime areas for butterflies in the Republic of Ireland. Ireland has 32 resident butterfly species and three regular migrant species. Twenty-three native resident species and three migrant species (26 in total) have been recorded in the Lullymore/Lullybeg area. Nowhere else in Ireland outside the Burren region contains a similarly large number of butterfly species concentrated in a relatively small area. Accordingly, the area is popular with visitors, who study, take photographs, and enjoy the butterflies and wild flowers that are abundant in several areas.
Two of these butterfly species, the Marsh Fritillary Euphydryas aurinia and Large Heath Coenonympha tullia are threatened in Ireland and Europe. On the red list for Irish butterflies, both are assessed as Vulnerable. The Marsh Fritillary is listed on Annex II on the European Union Habitats’ Directive 1992. Its breeding areas have legal protection. At least two strong, long-term populations of the Marsh Fritillary are known from the area. One is located at Lullymore, for example at N 69296 25844 and the other known population is located at Lullybeg, for example at N 68711 25661. Outside these locations, areas of grassland rich in the Marsh Fritillary breeding plant, Devil’s-bit Scabious Succisa pratensis, (typically a foodplant density of at least 25% extending over 0.5 hectare or greater) may also have Marsh Fritillary populations.
In the areas where the Marsh Fritillary populations exist, Butterfly Conservation Ireland is calling for Kildare County Council to refuse any development plans and to support the maintenance of the current vegetation structure by occasional mechanical disturbance and extensive cattle grazing. The present situation with Butterfly Conservation Ireland which manages the Butterfly Reserve at Lullybeg can be developed further across areas of this landscape.
The Large Heath exists on remnant raised bog at N 65874 25565 and on the adjoining raised bog. It may also exist at N 69926 31748 and N 64469 30361. Butterfly Conservation Ireland advises that all peat cutting cease, that drain blocking and re-wetting be put in place to protect one of the last populations or probably the last population in the area of this species from extinction. This area contains the only known viable population of the Green Hairstreak butterfly Callophrys rubi in the Ballydermot Bog Group area. The scarce moth, Dark Tussock Dicallomera fascelina, rated Near Threatened on the Macro-moth Red List 2016, would also be protected by this measure. Restoration of this raised bog remnant will be a significant indication of Kildare County Council’s environmental credentials.
In addition, the grassland habitats support other endangered butterflies. The Wall Brown Lasiommata megera mainly occurs along the tracks laid down on the site and probably along the sparsely vegetated areas adjoining the industrial railway. Ranked as Endangered on the red list, this species has suffered severe losses in distribution and abundance since the mid-1980s and may be Ireland’s most rapidly declining butterfly. Butterfly Conservation Ireland advocates the maintenance of the current routeway infrastructure and the creation of additional potential habitat using any infrastructure to facilitate visitor
access. The use of loose calcareous aggregate, sloped to face the south and west along these routes may offer additional habitat for the Wall Brown and Dingy Skipper butterfly Erynnis tages, the latter ranked Near Threatened on the red list.
Another butterfly that inhabits open grassland, particularly flower-rich areas where patches of scrub exist is the Dark Green Fritillary Speyeria aglaja. This butterfly is rated Vulnerable on the red list. The population at Lullybeg and Glasabaun may be the only remaining viable populations of this species in County Kildare. Butterfly Conservation Ireland is calling for its grassland habitats to be protected from development and managed by scrub control and extensive summer grazing by cattle.
In addition to the butterfly species named above, there are some declining and threatened moth species. These include the Forester Adscita statices, ranked Endangered on the Macro-moth Red List 2016, Narrow-bordered Bee Hawkmoth Hemaris tityus, Narrow-bordered Five-spot Burnet Zygaena lonicerae, ranked Vulnerable, Small Purple-barred Phytometra viridaria, ranked Near Threatened, Wood Tiger Parasemia plantaginis, ranked Near Threatened, Small Chocolate-tip Clostera pigra, ranked Near Threatened; all of these species occur in the grassland with open scrub used by the rare Marsh Fritillary butterfly.
Species-rich scrub exists in various areas in the area. Some contain unusual species associations. For example, at N 68922 25624, Common Buckthorn Rhamnus cathartica, a lime-loving small tree and Alder Buckthorn, Frangula alnus, which favours damp peat soils, grow together, an unusual circumstance. Grey Willow Salix cinerea, Holly Ilex aquifolium, Downy Birch, Betula pubescens, Mountain Ash Sorbus aucuparia, Creeping Willow Salix repens also occur here. These areas of open scrub are rich is invertebrates, including several dragonfly species. Where species-rich scrub and well-developed bog woodland exists on the cutaway areas, Butterfly Conservation Ireland would like to see these remain undisturbed, with some management to create woodland clearings and open scrub. Such management maintains a diverse vegetation structure, essential for many invertebrates and birds.
There are some flooded areas, such as at N 68901 25450. These areas are important for dragonflies and bird species. Whooper Swan Cygnus cygnus use this area in winter, while Eurasian Lapwing Vanellus vanellus, among other wetland species, use this habitat. It is vital that these areas are not drained.
Several other birds of conservation concern occur in the region. These include red-listed species: Woodcock Scolopax rusticola Kestrel Falco tinnunculus, Meadow Pipit Anthus pratensis, YellowhammerEmberiza citrinella, Golden Plover Pluvialis apricaria, Lapwing, Snipe Gallinago gallinago and amber-listed species: Goshawk Accipiter gentilis, Kingfisher Alcedo atthis, Merlin Falco columbarius, Swallow Hirundo rustica, Sand Martin Riparia riparia, Willow Warbler Phylloscopus trochilus, Linnet Linaria cannabina, Mallard Anas platyrhynchos Mute Swan Cygnus olor and TealAnas crecca .
The area contains sufficient size to maintain the populations of animals and plants present and contains several qualifying features for a Special Area of Conservation under the Habitats’ Directive 1992, including Marsh Fritillary, Otter, active raised bog, degraded raised bogs capable of regeneration, Molinia grassland, orchid-rich grassland, wet heath and dry heath. As well as the biodiversity values, the area offers great scope for recreation and tourism, a great boost to the locality and wider region. The destruction of the Bog of Allen in this region was a biodiversity and heritage disaster. Butterfly Conservation Ireland believes that the time has come to address this crisis, even though a different landscape is now present.
Few areas in Kildare, outside bogs and fens, are rich in biodiversity. The failure to protect these areas from development and the failure to restore bogs where possible and appropriate will result in regional loss of biodiversity. We have reached the point that agricultural land is modified to the extent that species formerly widespread in Kildare occur only on bog habitats.
Management and designation of Special Areas of Conservation
County Kildare has just eight Special Areas of Conservation (SACs), all wetland habitats. All of these require monitoring and management and some areas of the peatlands require restoration work. The council must liaise with the National Parks and Wildlife Service to prepare and implement management plans for these sites. The quality of some parts of these areas is poor. For example, one of the three qualifying features for Ballynafagh Lake’s status as an SAC, the Marsh Fritillary butterfly, no longer occurs on the site because grazing ceased in the early 1990s. The species has been absent from the site for 30 years. The habitat must be reinstated, and grassland rich in the larval food plant Devil’s-bit Scabious Succisa pratensis needs to be restored by the appropriate grazing and reseeding from plants that still occur on the site. The open grassland on part of Pollardstown Fen at N 76373 16018 (among other areas) needs extensive cattle grazing like that currently applied on Dunshane/Harristown/Two-mile House Common, a species-rich wetland and a site of biodiversity importance despite having no designation. We strongly advise that Kildare County Council liaise with the National Parks and Wildlife Service concerning the status of this commonage.
We want Kildare County Council to liaise with the National Parks and Wildlife Service to seek the designation of the Lullymore/Lullybeg/Glashabaun/Blackriver cutaway bog areas as Special Areas of Conservation for the habitats and species stated.
Waterways Ireland’s plans to rock armour sections of waterways in Kildare, Laois and Carlow (and to remove trees) appears to be an attempt to circumvent the refusal of planning consent along parts of the Special Area of Conservation in 2019 when An Bord Pleanála rejected Waterways Ireland’s appeal against the refusal by three local authorities of its application to install hard surfaces along the River Barrow for all of County Carlow and part of County Laois and County Kildare. We expect Kildare County Council’s Biodiversity Action Plan to support the maintenance of our most important wetlands, especially Special Areas of Conservation.
Management of National Heritage Areas
County Kildare has only two National Heritage Areas (NHAs). Both are raised bogs. These bogs must be protected and restored if their value is to be protected.
Designation of National Heritage Areas
Butterfly Conservation Ireland wants a commitment in the Kildare County Biodiversity Action Plan to protect the few areas of high biodiversity that remain. That should start with the council liaising with the National Parks and Wildlife Service to formally designate the proposed National Heritage Areas within the county. The Curragh and the Grand and Royal Canals are on the list of proposed NHAs but it appears that vested interests see their formal designation as an impediment to progress. The biodiversity of the canals has already been diminished by the installation of a bicycle track which commenced in the absence of an adequate biological impact survey. The Curragh continues to be damaged by over-grazing and recreational motoring.
Kingsbog Common, near Kildare town is a species-rich grassland of high ecological value with a population of Marsh Fritillary is not on the proposed NHA list. It requires urgent recognition and protection.
Kildare County Council should liaise with Bord na Móna, the National Parks and Wildlife Service and Umeras Community Development CLG, a local community group in the Monasterevin-Rathangan area (https://www.facebook.com/umeraspeatlands) which hopes to transform the Bord na Móna Umeras Bog into a peatlands nature park modelled on Lough Boora Discovery Park (https://www.loughboora.com/) developed by Bord na Mona, Offaly County Council and their partners. This is an area of high biodiversity value. Part of the bog is being restored under the enhanced rehabilitation scheme administered by Bord na Móna.
One-off houses in rural areas
The proliferation of one-off houses in rural areas is a concern for a range of reasons but we will address the biodiversity issues here. We propose that Kildare County Council make any planning conditional on the retention of existing hedgerow consisting of biodiverse, native plant species. The inappropriate planting of non-native hedging and walls is visually incongruous and results in biodiversity loss. Tree-planting plans for any proposed development should be examined and the list should comprise native species from indigenous sources. The council should also make it a condition of a grant of planning that water courses be maintained and not filled in.
New Housing Developments
Planning consent for housing developments should contain specifications for planting that contain only native trees and shrub species of native provenance that occur naturally in the area. Amenity areas within developments should be allowed to develop naturally without applying seed. If seed is required, it should consist of native herbs and grasses of native provenance suited to the site. The National Pollinator Plan should be applied throughout the county.
Management of hedgerows along public roads
Hedgerows are of great biodiversity value. Their correct management is crucial for biodiversity maintenance. Cutting in an A-shape is recommended. Cutting should be carried out during the appropriate period, between August 31st and March 1st, unless safety requires cutting outside this time. We recommend cutting during February to avoid loss of forage for birds over the winter months. We recommend that one-third of hedgerows are uncut in a given year to allow invertebrates that lay their eggs on hedges to survive. Some hedgerow shrubs should be uncut to allow them to become trees.
A clear strategy is required for managing the herbaceous fringe between the hedge and road for its importance to biodiversity. Where it is not impacting on road user safety its growth and retention should be encouraged. The timing of the cutting of this area should also occur as described for the hedgerow, with uncut patches retained in any given year.
These practices should be promoted throughout the county.
Recruitmentof staff for a Kildare Biodiversity Office
Butterfly Conservation Ireland advocates the employment of ecologists to staff a Biodiversity Office in Kildare. These can review planning issues, prepare management plans for SACs and NHAs, engage with the public, schools, environmental NGOs and others to promote Kildare’s biodiversity and support the Biodiversity Officer. This office should publish material and signage to promote biodiversity. This can be done digitally and in hard copy and physical signage.
We welcome the appointment of a Biodiversity Officer for County Kildare, and we wish her continued success. As indicated above, Butterfly Conservation Ireland urges that the Biodiversity Officer be provided with all the support she requires to ensure that the objectives of the Kildare County Biodiversity Action Plan are met.
Conclusion
This submission is consistent with the Kildare County Development Plan 2023-2029, especially with Chapter 12 Biodiversity and Green Infrastructure and Chapter 9 Our Rural Economy. Particular attention is drawn to the statement on page 427:
While Bord Na Mona has clear intentions of developing extensive areas to meet government renewable targets – in the form of wind and solar farms - nonetheless, the Bog of Allen represents a unique opportunity for nature based solutions on a grand scale to address the national biodiversity crisis and climate change mitigation. 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’ with appropriate buffer zones of scale designed to protect their special interest and setting – one should centre around Lullymore Heritage Park, Lullybeg Wetlands, Butterfly Reserve, Lodge Bog – 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.
This statement is supported by a statement of action:
It is an action of the council to:
Work with Bord Na Mona and other stakeholders 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, 12.14.7 and 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. (Kildare County Development Plan, Biodiversity and Green Infrastructure, p. 425)
The Plan also has the objective (RD 031):
It is an objective of the council to:
Investigate the feasibility of the development of a Peatland National Park in co-operation with Bord Na Mona, NPWS and other relevant stakeholders as per recommendation 9 of the BOGLAND Report from the EPA in 2011 and action A28 of the National Peatland Strategy 2014. (Kildare County Development Plan, Our Rural Economy, p. 12)
This initiative, if realised, would mark a lasting and substantial action to conserve the county’s biodiversity and assist in meeting Ireland’s climate and biodiversity targets and its obligations under the EU Nature Restoration Law is a groundbreaking piece of legislation that mandates EU member states to restore at least 20% of their land and sea areas by 2030.
Yours faithfully
Conservation Officer
Butterfly Conservation Ireland
References
Allen, D., O’Donnell, M., Nelson, B., Tyner, A., Bond, K.G.M., Bryant, T., Crory, A., Mellon, C.,
O’Boyle, J., O’Donnell, E., Rolston, T., Sheppard, R., Strickland, P., Fitzpatrick, U., & Regan, E.
(2016) Ireland Red List No. 9: Macro-moths (Lepidoptera). National Parks and Wildlife Service,
Department of Arts, Heritage and the Gaeltacht, Dublin, Ireland.
Fossitt, J. (2001) A Guide to Habitat in Ireland. Heritage Council, Kilkenny, Republic of Ireland.
Gilbert, G., Stanbury, A., Lewis, L. (2021) Birds of Conservation Concern in Ireland 2020-2026. Irish Birds 9: 523-544
Harding, J. (2008) Discovering Irish Butterflies & their Habitats. J. Harding, Maynooth, County Kildare, Republic of Ireland.
Kildare County Council (2023) Kildare County Development Plan 2023-2029. Kildare County Council, Republic of Ireland.
Nash, D. (2003) Republic of Ireland. Pp. 319-326 in C.A.M. van Swaay & M.S. Warren, eds. Prime Butterfly Areas in Europe: Priority sites for conservation. National Reference Centre for Agriculture, Nature and Fisheries, Ministry of Agriculture, Nature and Fisheries, Ministry of Agriculture, Nature Management and Fisheries, The Netherlands.
Regan, E.C., Nelson, B., Aldwell, B., Bertrand, C., Bond, K., Harding, J., Nash, D., Nixon, D., & Wilson, C.J. (2010) Ireland Red List No. 4 – Butterflies. National Parks and Wildlife Service, Department of the Environment, Heritage and Local Government, Ireland.
Tuairimí
Butterfly House, Pagestown, Maynooth, County Kildare
Email: conservation.butterfly@gmail.com
XXXXXXXXXXXXX
Biodiversity Officer, 26th April 2025
Kildare County Council,
Áras Chill Dara,
Devoy Park, Naas,
Co. Kildare,
W91 X77F
Dear Sir/Madam,
Re: County Kildare Biodiversity Action Plan 2026-2031
Butterfly Conservation Ireland Limited is a conservation NGO and registered charity formed in 2008 by a group of dedicated naturalists following the alarming decline of most of our butterfly species. This decline has been ongoing since the 1970s and has accelerated since 2008. Butterfly Conservation Ireland is committed to the conservation of butterflies, moths and their habitats.
Butterfly Conservation Ireland operates a nature reserve at Lullybeg, County Kildare in partnership with Bord na Móna. Active conservation techniques are applied on the 30-hectare site to enhance the habitats for several scarce and endangered species.
Butterfly Conservation Ireland advises and provides information to organisations, the general public and individuals concerning butterfly conservation. We make submissions on developments that would impact negatively on important butterfly areas and endangered species. We run a programme of events, free to all. Our website is found at https://butterflyconservation.ie/wp/. Our submission to the Kildare County Biodiversity Action Plan is stated below.
National Peatlands Park
The cessation of peat cutting by Bord na Móna on state-owned land is a great opportunity for the provision of a new national park. The eastern midlands region has no national park, while the western seaboard counties have five national parks with one in County Wicklow. The area of these national parks ranges from 1500 hectares in the case of the Burren National Park to 20,000 hectares in the case of the Wicklow Mountains National Park. The Ballydermot Bog group, comprising Bord na Móna land in the townlands of Lodge, Barnaran, Blackriver, Ballydermot North and South, Codd 1 and Codd2/Sheridans, Lullymore and Lullybeg, Killina, Glashabaun North and South, Derrybrennan and Ticknevin comprises around 7,000 hectares. There are other important boglands in Kildare including Ummeras and the Kilberry bog group which should form part of the Peatlands park. The Ballydermot Bog Group area is a superb wilderness and consists mainly of former raised bog habitat that has been cut for peat. The peat-cutting process has resulted in the development of a range of habitats and land uses. Some of these habitats and land uses have led to the development of species-rich habitats. The main habitats that exist in the area are bogs, acid and calcareous grassland, scrub, mixed and deciduous
woodland, marsh and open water habitats such as flooded cutover bogs and rivers. This diversity has resulted in a stunning landscape in many areas, with a varied landscape contour pleasing to the eye and offering a unique experience for nature lovers, walkers and ramblers, horse riding and many other activities.
In some areas, a number of these habitats exist in close proximity, creating habitat mosaics with high biodiversity value, especially for invertebrates. This mosaic can be seen in areas such as Lullybeg at and around N 68796 25640. Habitats that exist here are mixed and deciduous woodland, scrub, flooded cutaway, ponds, acid and calcareous grassland and fen. Within these broad habitat descriptions are specific habitat types defined by Fossitt (2000). The following grasslands have been identified at Lullybeg: dry calcareous and neutral grassland, dry meadows and grassy verges, dry-humid acid grassland and wet grassland. This habitat diversity applies to other habitats elsewhere in the area.
The Lullymore/Lullybeg/Glashabaun/Blackriver areas are particularly important for butterflies. The importance of Lullymore and Lullybeg for butterflies has been recognised for many years. The report by Nash et al. (2003) describes the area as one of the three prime areas for butterflies in the Republic of Ireland. Ireland has 32 resident butterfly species and three regular migrant species. Twenty-three native resident species and three migrant species (26 in total) have been recorded in the Lullymore/Lullybeg area. Nowhere else in Ireland outside the Burren region contains a similarly large number of butterfly species concentrated in a relatively small area. Accordingly, the area is popular with visitors, who study, take photographs, and enjoy the butterflies and wild flowers that are abundant in several areas.
Two of these butterfly species, the Marsh Fritillary Euphydryas aurinia and Large Heath Coenonympha tullia are threatened in Ireland and Europe. On the red list for Irish butterflies, both are assessed as Vulnerable. The Marsh Fritillary is listed on Annex II on the European Union Habitats’ Directive 1992. Its breeding areas have legal protection. At least two strong, long-term populations of the Marsh Fritillary are known from the area. One is located at Lullymore, for example at N 69296 25844 and the other known population is located at Lullybeg, for example at N 68711 25661. Outside these locations, areas of grassland rich in the Marsh Fritillary breeding plant, Devil’s-bit Scabious Succisa pratensis, (typically a foodplant density of at least 25% extending over 0.5 hectare or greater) may also have Marsh Fritillary populations.
In the areas where the Marsh Fritillary populations exist, Butterfly Conservation Ireland is calling for Kildare County Council to refuse any development plans and to support the maintenance of the current vegetation structure by occasional mechanical disturbance and extensive cattle grazing. The present situation with Butterfly Conservation Ireland which manages the Butterfly Reserve at Lullybeg can be developed further across areas of this landscape.
The Large Heath exists on remnant raised bog at N 65874 25565 and on the adjoining raised bog. It may also exist at N 69926 31748 and N 64469 30361. Butterfly Conservation Ireland advises that all peat cutting cease, that drain blocking and re-wetting be put in place to protect one of the last populations or probably the last population in the area of this species from extinction. This area contains the only known viable population of the Green Hairstreak butterfly Callophrys rubi in the Ballydermot Bog Group area. The scarce moth, Dark Tussock Dicallomera fascelina, rated Near Threatened on the Macro-moth Red List 2016, would also be protected by this measure. Restoration of this raised bog remnant will be a significant indication of Kildare County Council’s environmental credentials.
In addition, the grassland habitats support other endangered butterflies. The Wall Brown Lasiommata megera mainly occurs along the tracks laid down on the site and probably along the sparsely vegetated areas adjoining the industrial railway. Ranked as Endangered on the red list, this species has suffered severe losses in distribution and abundance since the mid-1980s and may be Ireland’s most rapidly declining butterfly. Butterfly Conservation Ireland advocates the maintenance of the current routeway infrastructure and the creation of additional potential habitat using any infrastructure to facilitate visitor
access. The use of loose calcareous aggregate, sloped to face the south and west along these routes may offer additional habitat for the Wall Brown and Dingy Skipper butterfly Erynnis tages, the latter ranked Near Threatened on the red list.
Another butterfly that inhabits open grassland, particularly flower-rich areas where patches of scrub exist is the Dark Green Fritillary Speyeria aglaja. This butterfly is rated Vulnerable on the red list. The population at Lullybeg and Glasabaun may be the only remaining viable populations of this species in County Kildare. Butterfly Conservation Ireland is calling for its grassland habitats to be protected from development and managed by scrub control and extensive summer grazing by cattle.
In addition to the butterfly species named above, there are some declining and threatened moth species. These include the Forester Adscita statices, ranked Endangered on the Macro-moth Red List 2016, Narrow-bordered Bee Hawkmoth Hemaris tityus, Narrow-bordered Five-spot Burnet Zygaena lonicerae, ranked Vulnerable, Small Purple-barred Phytometra viridaria, ranked Near Threatened, Wood Tiger Parasemia plantaginis, ranked Near Threatened, Small Chocolate-tip Clostera pigra, ranked Near Threatened; all of these species occur in the grassland with open scrub used by the rare Marsh Fritillary butterfly.
Species-rich scrub exists in various areas in the area. Some contain unusual species associations. For example, at N 68922 25624, Common Buckthorn Rhamnus cathartica, a lime-loving small tree and Alder Buckthorn, Frangula alnus, which favours damp peat soils, grow together, an unusual circumstance. Grey Willow Salix cinerea, Holly Ilex aquifolium, Downy Birch, Betula pubescens, Mountain Ash Sorbus aucuparia, Creeping Willow Salix repens also occur here. These areas of open scrub are rich is invertebrates, including several dragonfly species. Where species-rich scrub and well-developed bog woodland exists on the cutaway areas, Butterfly Conservation Ireland would like to see these remain undisturbed, with some management to create woodland clearings and open scrub. Such management maintains a diverse vegetation structure, essential for many invertebrates and birds.
There are some flooded areas, such as at N 68901 25450. These areas are important for dragonflies and bird species. Whooper Swan Cygnus cygnus use this area in winter, while Eurasian Lapwing Vanellus vanellus, among other wetland species, use this habitat. It is vital that these areas are not drained.
Several other birds of conservation concern occur in the region. These include red-listed species: Woodcock Scolopax rusticola Kestrel Falco tinnunculus, Meadow Pipit Anthus pratensis, Yellowhammer Emberiza citrinella, Golden Plover Pluvialis apricaria, Lapwing, Snipe Gallinago gallinago and amber-listed species: Goshawk Accipiter gentilis, Kingfisher Alcedo atthis, Merlin Falco columbarius, Swallow Hirundo rustica, Sand Martin Riparia riparia, Willow Warbler Phylloscopus trochilus, Linnet Linaria cannabina, Mallard Anas platyrhynchos Mute Swan Cygnus olor and Teal Anas crecca .
The area contains sufficient size to maintain the populations of animals and plants present and contains several qualifying features for a Special Area of Conservation under the Habitats’ Directive 1992, including Marsh Fritillary, Otter, active raised bog, degraded raised bogs capable of regeneration, Molinia grassland, orchid-rich grassland, wet heath and dry heath. As well as the biodiversity values, the area offers great scope for recreation and tourism, a great boost to the locality and wider region. The destruction of the Bog of Allen in this region was a biodiversity and heritage disaster. Butterfly Conservation Ireland believes that the time has come to address this crisis, even though a different landscape is now present.
Few areas in Kildare, outside bogs and fens, are rich in biodiversity. The failure to protect these areas from development and the failure to restore bogs where possible and appropriate will result in regional loss of biodiversity. We have reached the point that agricultural land is modified to the extent that species formerly widespread in Kildare occur only on bog habitats.
Management and designation of Special Areas of Conservation
County Kildare has just eight Special Areas of Conservation (SACs), all wetland habitats. All of these require monitoring and management and some areas of the peatlands require restoration work. The council must liaise with the National Parks and Wildlife Service to prepare and implement management plans for these sites. The quality of some parts of these areas is poor. For example, one of the three qualifying features for Ballynafagh Lake’s status as an SAC, the Marsh Fritillary butterfly, no longer occurs on the site because grazing ceased in the early 1990s. The species has been absent from the site for 30 years. The habitat must be reinstated, and grassland rich in the larval food plant Devil’s-bit Scabious Succisa pratensis needs to be restored by the appropriate grazing and reseeding from plants that still occur on the site. The open grassland on part of Pollardstown Fen at N 76373 16018 (among other areas) needs extensive cattle grazing like that currently applied on Dunshane/Harristown/Two-mile House Common, a species-rich wetland and a site of biodiversity importance despite having no designation. We strongly advise that Kildare County Council liaise with the National Parks and Wildlife Service concerning the status of this commonage.
We want Kildare County Council to liaise with the National Parks and Wildlife Service to seek the designation of the Lullymore/Lullybeg/Glashabaun/Blackriver cutaway bog areas as Special Areas of Conservation for the habitats and species stated.
Waterways Ireland’s plans to rock armour sections of waterways in Kildare, Laois and Carlow (and to remove trees) appears to be an attempt to circumvent the refusal of planning consent along parts of the Special Area of Conservation in 2019 when An Bord Pleanála rejected Waterways Ireland’s appeal against the refusal by three local authorities of its application to install hard surfaces along the River Barrow for all of County Carlow and part of County Laois and County Kildare. We expect Kildare County Council’s Biodiversity Action Plan to support the maintenance of our most important wetlands, especially Special Areas of Conservation.
Management of National Heritage Areas
County Kildare has only two National Heritage Areas (NHAs). Both are raised bogs. These bogs must be protected and restored if their value is to be protected.
Designation of National Heritage Areas
Butterfly Conservation Ireland wants a commitment in the Kildare County Biodiversity Action Plan to protect the few areas of high biodiversity that remain. That should start with the council liaising with the National Parks and Wildlife Service to formally designate the proposed National Heritage Areas within the county. The Curragh and the Grand and Royal Canals are on the list of proposed NHAs but it appears that vested interests see their formal designation as an impediment to progress. The biodiversity of the canals has already been diminished by the installation of a bicycle track which commenced in the absence of an adequate biological impact survey. The Curragh continues to be damaged by over-grazing and recreational motoring.
Kingsbog Common, near Kildare town is a species-rich grassland of high ecological value with a population of Marsh Fritillary is not on the proposed NHA list. It requires urgent recognition and protection.
Kildare County Council should liaise with Bord na Móna, the National Parks and Wildlife Service and Umeras Community Development CLG, a local community group in the Monasterevin-Rathangan area (https://www.facebook.com/umeraspeatlands) which hopes to transform the Bord na Móna Umeras Bog into a peatlands nature park modelled on Lough Boora Discovery Park (https://www.loughboora.com/) developed by Bord na Mona, Offaly County Council and their partners. This is an area of high biodiversity value. Part of the bog is being restored under the enhanced rehabilitation scheme administered by Bord na Móna.
One-off houses in rural areas
The proliferation of one-off houses in rural areas is a concern for a range of reasons but we will address the biodiversity issues here. We propose that Kildare County Council make any planning conditional on the retention of existing hedgerow consisting of biodiverse, native plant species. The inappropriate planting of non-native hedging and walls is visually incongruous and results in biodiversity loss. Tree-planting plans for any proposed development should be examined and the list should comprise native species from indigenous sources. The council should also make it a condition of a grant of planning that water courses be maintained and not filled in.
New Housing Developments
Planning consent for housing developments should contain specifications for planting that contain only native trees and shrub species of native provenance that occur naturally in the area. Amenity areas within developments should be allowed to develop naturally without applying seed. If seed is required, it should consist of native herbs and grasses of native provenance suited to the site. The National Pollinator Plan should be applied throughout the county.
Management of hedgerows along public roads
Hedgerows are of great biodiversity value. Their correct management is crucial for biodiversity maintenance. Cutting in an A-shape is recommended. Cutting should be carried out during the appropriate period, between August 31st and March 1st, unless safety requires cutting outside this time. We recommend cutting during February to avoid loss of forage for birds over the winter months. We recommend that one-third of hedgerows are uncut in a given year to allow invertebrates that lay their eggs on hedges to survive. Some hedgerow shrubs should be uncut to allow them to become trees.
A clear strategy is required for managing the herbaceous fringe between the hedge and road for its importance to biodiversity. Where it is not impacting on road user safety its growth and retention should be encouraged. The timing of the cutting of this area should also occur as described for the hedgerow, with uncut patches retained in any given year.
These practices should be promoted throughout the county.
Recruitment of staff for a Kildare Biodiversity Office
Butterfly Conservation Ireland advocates the employment of ecologists to staff a Biodiversity Office in Kildare. These can review planning issues, prepare management plans for SACs and NHAs, engage with the public, schools, environmental NGOs and others to promote Kildare’s biodiversity and support the Biodiversity Officer. This office should publish material and signage to promote biodiversity. This can be done digitally and in hard copy and physical signage.
We welcome the appointment of a Biodiversity Officer for County Kildare, and we wish her continued success. As indicated above, Butterfly Conservation Ireland urges that the Biodiversity Officer be provided with all the support she requires to ensure that the objectives of the Kildare County Biodiversity Action Plan are met.
Conclusion
This submission is consistent with the Kildare County Development Plan 2023-2029, especially with Chapter 12 Biodiversity and Green Infrastructure and Chapter 9 Our Rural Economy. Particular attention is drawn to the statement on page 427:
While Bord Na Mona has clear intentions of developing extensive areas to meet government renewable targets – in the form of wind and solar farms - nonetheless, the Bog of Allen represents a unique opportunity for nature based solutions on a grand scale to address the national biodiversity crisis and climate change mitigation. 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’ with appropriate buffer zones of scale designed to protect their special interest and setting – one should centre around Lullymore Heritage Park, Lullybeg Wetlands, Butterfly Reserve, Lodge Bog – 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.
This statement is supported by a statement of action:
It is an action of the council to:
Work with Bord Na Mona and other stakeholders 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, 12.14.7 and 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. (Kildare County Development Plan, Biodiversity and Green Infrastructure, p. 425)
The Plan also has the objective (RD 031):
It is an objective of the council to:
Investigate the feasibility of the development of a Peatland National Park in co-operation with Bord Na Mona, NPWS and other relevant stakeholders as per recommendation 9 of the BOGLAND Report from the EPA in 2011 and action A28 of the National Peatland Strategy 2014. (Kildare County Development Plan, Our Rural Economy, p. 12)
This initiative, if realised, would mark a lasting and substantial action to conserve the county’s biodiversity and assist in meeting Ireland’s climate and biodiversity targets and its obligations under the EU Nature Restoration Law is a groundbreaking piece of legislation that mandates EU member states to restore at least 20% of their land and sea areas by 2030.
Yours faithfully
Conservation Officer
Butterfly Conservation Ireland
References
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