Ecological Assessment of the Stream

15th December 2018

Submitted by: Altemar Ltd. Submitted to: Kilcoole Tidy Towns

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Contents

1 Introduction ...... 3 Background ...... 3 Kilcoole Stream Description ...... 4 Pressures on the Kilcoole Stream...... 9 Conservation Sites ...... 9 2. Hydrological Modelling ...... 15 Water quality Data ...... 17 Conclusions ...... 21 Recommendations ...... 21 Apprendix I Mitigation objectives of the Strategic Flood Risk Assessment of the ‘/ and Kilcoole Local Area Plan (LAP) 2013-2019’ ...... 23

2 1 Introduction

Background Keep Kilcoole Tidy, under the umbrella of Kilcoole Community Development Association (KCDA), submitted an application for funding to the Community Water Development Fund in 2018. It was stated in the application that “this will enable future projects to be determined that are required to be carried out on the stream.” This stream is an input stream for the Kilcoole Marshlands which are important wintering sites for wildfowl and wader birds and a birdwatch Ireland Nature reserve. The stream which up to 20 years ago was running outside the village is now in the centre of the village and in close proximity to several industrial estates. The stream was recently diverted for a new housing development but during recent flooding returned to its original path.

The following are the benefits of this project: 1) Identify riparian and aquatic species around stream, and using this information identify current and future threats and develop projects to protect these species as the population of Kilcoole grows. 2) Identify potential flooding possibilities along stream and the impact of development on the flood plains around Kilcoole. Identify projects to build better flood protections in the future. 3) Identify current pollution levels, and if they are low use these as a baseline. If they are high, execute corrective and preventative projects against the pollution. 4) The report will be made available on the website www.kilcoole.ie and announced on the local community Facebook page.

Following discussion between Keep Kilcoole Tidy and Altemar, the focus of the project conclusions was to be on recommendations in a project priority/high, medium and low impact based approach.

Keep Kilcoole Tidy The volunteer organisation Keep Kilcoole Tidy works to maintain and improve the village of Kilcoole, including initiatives to: 1) Improve the general ambience of the village 2) Create and nurture wildlife and natural habitats in the village environs 3) Maintain the tidiness of the village 4) To improve the sustainability and resource management of the village.

Altemar Limited Altemar Ltd. was appointed to carry out the assessment. Altemar is an established environmental consultancy based in Greystones and has been in operation in Ireland since 2001. Altemar provides ecological consultancy services in aquatic and terrestrial environments. Altemar is currently the sole “Environmental Expert” hired by in Inland Fisheries Ireland to evaluate IFI and external projects for environmental assessment. Altemar has designed in-house Appropriate Assessment and Environmental Impact Assessment screening processes for Inland Fisheries Ireland staff. This process includes developing in-house methodologies for environmental assessment, consultant engagement, online submission forms and reporting templates. Altemar has previously carried out ecological elements of the Greystones Delgany Local Area Plan1. Bryan Deegan (MCIEEM) carried out all elements of this assessment. Bryan Deegan is an environmental and aquatic consultant2 with over 20 years’ experience as an Environmental Team Leader working on Irish aquatic and terrestrial development projects. He is particularly experienced in the provision of ecological impact assessment, technical advice, marine and terrestrial ecological surveying, Geographical Information Systems (GIS) and the development of environmental assessment processes for State Organisations.

1 https://www.wicklow.ie/Portals/0/Documents/Planning/Development-Plans-Strategies/Local-Area-Town- Settlement-Plans/Greystones-Delgany/Greystones-Delgany-Kilcoole-Local-Area-Plan-2013-2019/Appendix_C_- _Biodiversity.pdf 2 MSc Environmental Science (TCD), BSc in Applied Marine Biology (Heriot Watt), Diploma in Applied Aquatic Science (GMIT), Certificate in Science (Aquaculture). Member of the Chartered Institute of Ecology and Environmental Management. 3 Kilcoole Stream Description The Kilcoole Stream (Figure 1) is located within Hydrometric Area No. HA 10 (Avoca-Vartry) of the Irish River Network System and is situated within the Eastern River Basin District (ERBD). The Kilcoole Stream under the Water Framework Directive is also identified as IE_EA_10K010580. The Kilcoole Stream rises at an elevation of 120 m OD in the town of site and flows in a south-easterly direction through Kilcoole Village, entering the to the east of Kilcoole. The catchment as seen in Figure 1 is bordered to the north by that of the Three Trout Stream and to the south by the Ballyrohan Stream. It should be noted that these three streams are important from a fisheries perspective: they contain populations of sea trout and their catchments are small, which means they are very sensitive to anthropogenic impacts.

It should be noted that the course of the Kilcoole Stream has been incorrectly plotted on many maps including the EPA Water Framework Directive Mapping (Figure 2). On the WFD, Bing, Google and Discovery maps the course of the stream within the village is to the north of the actual stream location. Based on historic mapping (1832) the course that it follows on the mapping is a millrace which no longer exists. Within the village the actual course of the stream is 220m to the south of former millrace. It is important to recognise this true location of the stream as any future development along the riparian corridor could have a negative impact on the stream and biodiversity associated with the stream. It should also be noted that many of the crossings of the Kilcoole Stream contain piped rather than box culverts. Pipes are not conducive to the movement of fauna as the pipes do not have a mammal ledge and are more prone to blockages and flooding impacts.

The stream is primarily surrounded by agricultural land with riparian woodland in the upper catchment, which reduces to a narrow hedgerow on both sides of the stream, just north of Kilcoole. This treelined cover is maintained through Kilcoole Village, which is an important stepping stone for biodiversity. However, downstream of Kilcoole Village there are two road crossings near Holywell Avenue. In the vicinity of this area the vegetative cover has been removed. It would be important to reinstate the biodiversity corridor in this area and incorporate a riparian buffer as outlined in the IFI guidance.3

As seen in Figure 3 the bedrock of the entire catchment is Greywacke and quartzite. Groundwater vulnerability of the catchment is seen in Figure 4. This is a term used to represent the intrinsic geological and hydrogeological characteristics that determine the ease with which groundwater may be contaminated by human activities. Groundwater vulnerability is usually dependent on the nature (sandy, gravely, clay, etc.,) and depth of soil/subsoil overlying an aquifer (i.e. its shallowness). The travel time, attenuation capacity of the subsoils (i.e. ability to filter contaminants) and the nature of the contaminants are also important elements in determining the vulnerability of groundwater. Groundwater vulnerability is the most important factor in determining control measures on an area where landspreading of organic wastes is proposed. This is because the type, permeability and thickness of the soil and subsoil plays a critical role in preventing groundwater contamination by acting as a protecting filtering layer over the groundwater.

3 https://www.fisheriesireland.ie/documents/86-planning-for-watercourses-in-the-urban-environment-1/file.html 4 Figure 1. Kilcoole Stream and catchment. 5

Figure 2. EPA WFD Plotted course v’s actual course 6

Figure 3. Bedrock type in catchment.

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Figure 4. Groundwater vulnerability. 8 Pressures on the Kilcoole Stream The catchment of the Kilcoole Stream is primarily agricultural with housing developments at Kilpedder, , and Kilcoole villages, and other small housing developments near the watercourse.

Water quality pressures in the catchment include nutrient inputs (eutrophication) from agriculture. In addition, upstream in the catchment the WWTP storm inlet overflow in Kilpedder discharges to the Kilcoole Stream in heavy rainfall events. In the catchment downstream of Kilcoole is another WWTP, fed by sections of Kilcoole, which is discharging to the stream. Industrial/commercial pressures are relatively few within the catchment but could potentially include Kilsaran, DPD Ireland and Tony Doyle Coaches near the N11, Kilcoole industrial Estate, and other small commercial businesses.

The EPA instream invertebrate sampling data notes: “The paucity of pollution sensitive macroinvertebraste species indicated unsatisfactory moderate ecological conditions on the Kilcoole Stream in September 2015. Excessive instream macrophyte growth was indicative of some enrichment.”

This has resulted in the stream being classed as “Moderate” in 2015 under the Water Framework Directive. The WFD establishes a framework for the protection of all waters including rivers, lakes, estuaries, coastal waters and groundwater, and their dependent wildlife/habitats under one piece of environmental legislation. Specifically the WFD aims to protect/enhance all waters (surface, ground and coastal waters) and achieve "Good” status for all waters by December 2015. The Kilcoole Stream is classed as “Moderate” status and is therefore below the water quality requirements under the WFD. Where a water body is assessed as ‘at risk’ as in Figure 6 (red line), there is a risk that it may deteriorate below this level.

Conservation Sites The three main types of conversation designation are: Natural Heritage Area (NHA), Special Area of Conservation (SAC) and Special Protection Area (SPA). Designated Conservation Sites within the Kilcoole Stream catchment are seen in Figures 7 (Special Areas of Conservation), 8 (Special Protection Areas) and 9 (proposed Natural Heritage Areas). No NHA’s are in the catchment.

Special Areas of Conservation (SAC) represent the prime wildlife areas in Ireland that are also considered extremely important from a European perspective. Their selection and designation occurs through the EU Habitats Directive (92.43/EEC). The selected sites have been identified as being of conservation importance in a European context, based on the habitats and species they support, including both plants and animals.

Special Protection Areas (SPAs) are sites that are important to supporting bird-life. The EU Birds Directive (79/409/EEC) is the primary mechanism for this designation.

A Natural Heritage Area (NHA) is the basic designation for wildlife under the Wildlife Amendment Act (2000). Sites are selected by having special scientific significance for one or more species, communities, habitats, landforms or geological features, or for a variety of natural attributes.

Features of interest of the Murrough Wetlands SAC are: Annual vegetation of drift lines, Perennial vegetation of stony banks, Atlantic salt meadows (Glauco-Puccinellietalia maritimae), Mediterranean salt meadows (Juncetalia maritimi), Calcareous fens with Cladium mariscus and species of the Caricion davallianae.and Alkaline fens.

Features of interest of the Murrough SPA are: Red-throated Diver (Gavia stellata), Greylag Goose (Anser anser), Light-bellied Brent Goose (Branta bernicla hrota), Wigeon (Anas penelope), Teal (Anas crecca), Black-headed Gull (Chroicocephalus ridibundus), Herring Gull (Larus argentatus), Little Tern (Sterna albifrons) and Wetland and Waterbirds.

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Figure 5. Water Quality Status of the Kilcoole Stream (High=Blue, Green =Good, Yellow=moderate, Brown = Poor, Red = Bad) 10

Figure 6. Water Quality “At Risk” Score of the Kilcoole Stream (Green = Not at Risk, Red = At Risk) 11

Figure 7. Special Protection Areas

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Figure 8. Special Areas of Conservation 13

Figure 9. proposed Natural Heritage Areas (No Natural Heritage Areas)

14 2. Hydrological Modelling A detailed assessment of the Kilcoole Stream has been carried out and detailed in the Eastern CFRAM Flood Risk Review (IBE0600Rp0001_Flood Risk Review).4 The CFRAM study noted that:

All of the watercourses in both AFAs flow to the low lying area to the rear of Leamore Strand behind the railway embankments before draining to the sea at a point known as The Breaches. The Breaches was found to cause considerable fluvial flooding when the outlet under the railway embankment becomes tidally-locked. As both AFAs drain to the outlet at The Breaches and contribute to flooding, a combined model was required to accurately represent flooding at this location.

On the Kilcoole watercourse, the wall crossing 1007M00301 and the bridge 1007M00292D both cause considerable restrictions to flow which results in out-of-bank flooding during design runs of 10% AEP or greater, as shown in Figure 10. Agricultural land was found to flood, however no roads or properties were found to be affected. The headloss effect of both of these structures can be seen in Figure 4.6.53 in Appendix A.2 of the report.

Figure 10. Model flood extents on the Kilcoole watercourse

On the Kilcoole watercourse, culverts 1007B00090I and 1007B00072I (chainage 3851 and 4035 respectively) cause considerable headloss which results in flooding of properties in Riverside and Beechdale during design runs of 0.1% AEP. Up to approximately 35 properties were found to be affected, as well as the Newtown Road and the R761. The modelled flood extents in this area are shown in Figure 11 and the headloss across culverts in this area can be seen in Figure 4.6.53 in Appendix A.2 of the report. It should be noted that comments received at a Draft flood mapping workshop on 22/05/2014 suggested that culverts in this area are prone to blockage. Sensitivity testing for this model is to be undertaken and reported for the Final version, and it is recommended that this testing incorporates an analysis of culvert blockage in this area.

4 http://eastcfram.irish-surge-forecast.ie/wp-content/uploads/2011/10/Kilcoole-Newcastle.pdf 15

Figure 11. Model flood extents on the Kilcoole watercourse at Riverside and Beechdale

Culvert 1007M00107I at chainage 4752 on the Kilcoole watercourse was found to restrict flow, resulting in flooding from the right bank immediately upstream during design runs of 10% AEP or greater, as shown in Figure 12. This flooding was found to affect agricultural land before re-joining the Kilcoole watercourse in design runs of 10% AEP. During design runs of 1% AEP or greater overland flow was found to travel south, eventually joining overland flow from the Ballyloughlin.

Figure 12. Model flood extents on the lower Kilcoole watercourse 16 Water quality Data Water Quality sampling sites for this assessment are seen in Figure 13 (A-C) and the for the 2016 Geological Survey of Ireland Tellus project are also seen in Figure 13 (yellow dots). Phytochemical data for water samples taken on the 25/10/2018 are seen in table 1 and sediment samples are seen in table 2.

There were three water sampling sites on the Kilcoole Stream: (A) upstream of Kilcoole, (B) in Kilcoole, and (C) downstream of the WWTP. Water quality upstream appeared good with high oxygen levels. However, e-coli of 108/100ml may indicate faecal input into the stream from cattle, septic tanks or the Kilpedder WWTP upstream, and Zinc levels appeared elevated compared to the two downstream sites. Increased E- coli levels were seen at Site B in Kilcoole indicating additional inputs of faecal source/s between site A and B. It is likely that this would be a domestic source e.g. poorly maintained septic tank or misconnections in domestic properties. Ammonia and turbidity levels also saw an increase between site A and B indicating additional agricultural/ anthropogenic influence. On site C elevated Soluble Reactive Phosphorus (SRP), bacteria, copper, turbidity and Ammonia would be expected, as site C is downstream of the WWTP.

In Table 2 the physiochemical data results from the sediment samples taken on the Kilcoole Stream were compared to the average readings of 1883 samples taken in south east of Ireland. A total of 52 major and trace elements were compared. These data results indicate that the Kilcoole Stream, in the majority of cases, was in line with or has lower trace elements than the average levels of the other samples. This would tend to indicate that the levels found in the Kilcoole Stream sediments were not significantly different from the average levels in other catchments.

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Figure 13. Sampling Sites for water sampling (A-C) and for sediment sampling for the 2016 Geological Survey of Ireland Tellus project. 18

Table 1. Physicochemical results from water sampling carried out on 25/10/2018

Dissolved Dissolved Oxygen Total Coliform Stream Site Code Date Total P (mg/L P) SRP (mg/L P) Temperature Conductivity (µS) pH Oxygen % (mg/L O2) (Count/100ml) Kilcoole Stream A 25/10/2018 0.040 0.020 10.5 317 7.54 97.8 10.90 464 Kilcoole Stream B 25/10/2018 0.040 0.020 10.4 333 7.89 98.6 11.64 1,785 Kilcoole Stream C 25/10/2018 0.040 0.030 10.5 349 7.88 91.2 10.06 19,863

E-Coli B.O.D. (mg/L O2) Chlorophyll (µg/L) Ammonia (mpn/100 ml) Nitrite (mg/L N) Nitrate (mg/L N) Alkalinity (mg/L CaCO ) (Count/ 100ml) 3 Kilcoole Stream A 25/10/2018 108 2.00 0.220 0.040 0.010 3.840 192.02 Kilcoole Stream B 25/10/2018 231 2.00 1.560 0.050 0.010 3.890 196.40 Kilcoole Stream C 25/10/2018 482 1.00 0.890 0.180 0.070 4.250 191.54

P Orthophosphate Cromium ug/l Copper ug/l Turbidity NTU Nickel ug/l Lead mg/l Zinc ug/l* (mg/L P) Kilcoole Stream A 25/10/2018 0.85 <0.6 0.08 0.65 0.03 0.04 105.00 Kilcoole Stream B 25/10/2018 0.73 <0.6 0.52 0.57 0.03 0.22 79.00 Kilcoole Stream C 25/10/2018 0.92 0.90 0.93 1.01 0.04 0.27 76.20

19 Table 2. Physicochemical results from sediment sampling carried out in 2016 (GSI)

Sample_ID Easting Northing Na2O_% MgO_% Al2O3_% SiO2_% P2O5_% 596351C 328486 208805 0.7 0.9 6.9 67 0.17 596383C 330642 207592 0.5 1.2 8 55 0.23 Average of 1883 samples 1.02 1.48 14.52 55.93 0.24 S_mgkg Cl_mgkg K2O_% CaO_% TiO2_% 596351C 328486 208805 500 100 1.39 2.74 0.435 596383C 330642 207592 31 100 1.41 6.97 0.46 Average of 1883 samples 411.26 95.84 2.57 1.79 0.76 MnO_% Fe2O3_% Sc_mgkg V_mgkg Cr_mgkg 596351C 328486 208805 0.128 2.13 7.2 40.4 63 596383C 330642 207592 0.124 3.03 1.5 60.5 72.7 Average of 1883 samples 0.39 5.29 11.23 81.04 75.82 Co_mgkg Ni_mgkg Cu_mgkg Zn_mgkg Ga_mgkg 596351C 328486 208805 7.2 15.7 19.4 90 6.1 596383C 330642 207592 10 28 20.2 101.7 7.3 Average of 1883 samples 25.90 32.82 24.72 158.87 16.85 Ge_mgkg As_mgkg Se_mgkg Br_mgkg Rb_mgkg 596351C 328486 208805 0.25 4.1 0.9 21.1 46.5 596383C 330642 207592 0.1 9.2 1.8 33.4 53.8 Average of 1883 samples 1.15 28.84 0.95 22.94 115.70 Sr_mgkg Y_mgkg Zr_mgkg Nb_mgkg Mo_mgkg 596351C 328486 208805 90.6 13.4 370.3 8 0.6 596383C 330642 207592 145.3 18.2 272 7.8 1.4 Average of 1883 samples 93.31 28.63 329.78 13.31 1.05 Nd_mgkg Sm_mgkg Yb_mgkg Hf_mgkg Ta_mgkg 596351C 328486 208805 16.3 1.5 1.2 8.1 0.8 596383C 330642 207592 17.8 2.7 1.5 5.6 0.5 Average of 1883 samples 33.00 5.27 2.69 8.15 0.97 W_mgkg Tl_mgkg Pb_mgkg Bi_mgkg Th_mgkg 596351C 328486 208805 1.1 0.25 24.2 0.2 4.7 596383C 330642 207592 1.1 0.1 30.1 0.6 5.6 Average of 1883 samples 3.29 0.52 65.51 0.68 11.07 U_mgkg Ag_mgkg Cd_mgkg In_mgkg Sn_mgkg 596351C 328486 208805 1.9 0.25 0.5 0.25 3 596383C 330642 207592 2.7 0.25 1 0.4 3.2 Average of 1883 samples 5.62 0.27 1.01 0.25 7.34 Sb_mgkg Te_mgkg I_mgkg Cs_mgkg Ba_mgkg 596351C 328486 208805 0.1 0.25 5.8 3 223 596383C 330642 207592 0.7 0.25 10.8 3 241 Average of 1883 samples 1.08 0.24 8.91 7.81 401.27 La_mgkg Ce_mgkg Au_ugkg Pd_ugkg Pt_ugkg 596351C 328486 208805 15 29 11.49 0.66 0.99 596383C 330642 207592 19 37 6.89 0.83 1.25 Average of 1883 samples 43.11 79.66 20.92 0.81 0.95

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Conclusions The Kilcoole Stream is a locally important stream that based on Inland Fisheries Ireland data contains sea trout. By its very nature being a small catchment, it is very sensitive to anthropogenic influences and inputs. Sediment sampling for contamination taken in 2016 has indicated that the stream is relatively free from contamination. Water quality data at all sites did also indicate this but did also indicate faecal contamination. This could be from agricultural or anthropogenic inputs. The WWTP downstream of Kilcoole is also impacting the water quality of the Kilcoole Stream with increased faecal and non faecal bacterial levels downstream of the WWTP.

Given Kilcoole’s proximity to both and , in addition to the N11, the area is likely to see a significant increase in housing. In addition, given the flat open space surrounding the village, it is likely that these will be in the form of large housing developments. It is critical to note that the Kilcoole stream is one of several watercourses that feeds the Murrough Wetlands SAC and the Murrough SPA. The Kilcoole stream, feeder streams, drainage ditches and riparian strip surrounding the stream should be seen as a biological stepping stone to these Natura 2000 sites, as encapsulated by Article 10 of the Habitats Directive. The recent and future planning applications for large scale housing developments in proximity of the stream would be seen as a threat to the biodiversity associated with the stream, not only in relation to impacting on water quality and instream biodiversity during construction but also on species that use the stream as a biodiversity corridor, including otter (Lutra lutra) and bat species that would be impacted through increased human activity and lighting.

A series of recommendations are proposed to assist Keep Kilcoole Tidy to monitor, protect and enhance the biodiversity value of the stream. These are broken down into high, medium and low priority recommendations:

Recommendations High Priority 1) Discussions to take place with Inland Fisheries Ireland in relation to the protection and enhancement of the Kilcoole Stream as this stream and its trout are at significant risk due to ongoing and future anthropogenic pressures. 2) A monitoring program be established on the stream, at key locations to identify anthropogenic inputs. This should include parameters including those identified in the report. Monitoring of the efficacy of the WWTP should be carried out as increasing pressure will be placed on this facility as the town grows. 3) As outlined in the Strategic Flood Risk Assessment “Developments that are an ‘inappropriate’ use for a flood zone area”, it is recommended that if planning applications are submitted in proximity to the stream that the flood zone areas are developed into wild biodiversity enhancement areas to support the riparian biodiversity corridor and stepping stones to the downstream Natura 2000 sites. 4) A walkover assessment be carried out from the source of the stream to the sea to identify key anthropogenic/agricultural inputs and potential breaches in Water Pollution Acts. Additional sampling may be required to fine tune possible sources, e.g. bacterial sampling. 5) Significant enhancement opportunities are possible throughout the watercourse and it is recommended that a Kilcoole Stream Enhancement and Biodiversity Action Plan is developed in consultation with Inland Fisheries Ireland. The purpose of this would to put a structure in place from the source to the Murrough, designing a continuous biodiversity enhancement corridor “stepping stone” to which developers would adhere to and would form a unified strategy for enhancement along the stream. This could include public paths etc. that would enhance the amenity value of the stream and which would also take into account biodiversity enhancement and education elements.

21 Medium Priority

1) In relation to water quality, if it is the intention of Keep Kilcoole Tidy to improve water quality and biodiversity of the Kilcoole Stream, it is recommended that the group initially adopt a localised and then a catchment wide approach to improving water quality and biodiversity. For example this could include starting with a risk assessment-based approach looking initially at direct discharges/impacts to the stream and impacts within the riparian zone, then gradually moving out to the catchment impacts/policies (e.g. biodiversity corridor enhancement) when the localised and high impacts have been death with. This would need to incorporate recommendations from IFI and may require assistance from WCC to incorporate potential policies into Local Area Plans. 2) Keep Kilcoole Tidy should inform the EPA of the actual course of the stream as this error may lead to planning or development issues and the lack of protection of the riparian zone. 3) Downstream of Kilcoole Village there are two road crossings near Holywell Avenue. Here the vegetative cover has been removed. It would be important to reinstate the biodiversity corridor in this area and incorporate a riparian buffer as outlined in the IFI guidance.

Low Priority

1) Keep Kilcoole Tidy act as guardians to the water quality of the stream and independently monitors the activity of developers/ residents and reports any potential breaches of the Water Pollution Acts to Inland Fisheries Ireland. 2) Misconnections of home appliances, sinks and to a lesser extent toilets to surface water runoff can cause impacts on watercourses in towns and villages. These could have been caused by extensions or exterior buildings being incorrectly plumbed. Homeowners are required to fix these misconnections. If these are identified should be informed.

22 Appendix I Mitigation objectives of the Strategic Flood Risk Assessment of the ‘Greystones/Delgany and Kilcoole Local Area Plan (LAP) 2013-2019’

In order to properly manage flood risk, the following mitigation objectives are included in the Greystones-Delgany and Kilcoole LAP 2013-2019:

TS4: To implement flood management objectives as set out in the Wicklow County Development Plan 2010-2016 and to implement the ‘Guidelines on the Planning System and Flood Risk Management’ (DoEHLG/OPW, 2009). TS5: To restrict the types of development permitted in Flood Zone A and Flood Zone B to the uses that are ‘appropriate’ to each flood zone, as set out in Table 3.2 of the Guidelines for Flood Risk Management (DoEHLG/OPW, 2009). Developments that are an ‘inappropriate’ use for a flood zone area, as set out in Table 3.2 of the Guidelines, will not be permitted, except where a proposal complies with the Justification Test for Development Managements, as set out in Box 5.1 of the Guidelines. Flood Risk Assessments shall be in accordance with the requirements set out in the Guidelines. TS6: Notwithstanding the identification of an area as being at low or no risk of flooding, where the planning authority is of the opinion that flood risk may arise or new information has come to light that may alter the flood designation of the land, an appropriate flood risk assessment may be required to be submitted by an applicant for planning permission. SOC9: Public open space within residential housing estates shall be preserved and enhanced. No development shall be permitted that would compromise the integrity of these spaces. In particular, residential development shall not be permitted on designated public open space within these areas. The following objectives and policies of ‘Section 12.6: Flooding’ of the Wicklow County Development Plan 2010-2016 also apply to the plan area: FL1: To prepare flood zone maps for all zoned lands within the County as part of future Local Area Plans. FL2: Land will not be zoned for development in an area identified as being at high or moderate flood risk (as set out in the Guidelines), unless where it is fully justified (through the Justification Test set out in the Guidelines) that there are wider sustainability grounds for appropriate development and unless the flood risk can be managed to an acceptable level without increasing flood risk elsewhere and where possible, reducing flood risk overall. FL3: Applications for significant new developments or developments in high or moderate flood risk areas shall follow the sequential approach as set out above. FL4: To prohibit development in river flood plains or other areas known to provide natural attenuation for floodwaters except where the development can clearly be justified with the guidelines ‘Justification Test’. FL5: To limit or break up large areas of hard surfacing in new developments and to require all surface car parks to integrate permeability measures such as permeable paving. FL6: Excessive hard surfacing shall not be permitted for new, or extensions to, residential or commercial developments and all applications will be required to show that sustainable drainage techniques have been employed in the design of the development. FL7: To require all new developments to include proposals to deal with rain and surface water collected on site and where deemed necessary, to integrate attenuation and SUDS measures. FL8: Flood assessments will be required with all planning applications proposed in flood risk areas to ensure that the development itself is not at risk of flooding and the development does not increase the flood risk in the relevant catchment (both up and down stream of the application site). Generally a Flood Impact Assessment will be required with all significant developments and a certificate (from a competent person stating that the development will not contribute to flooding within the relevant catchment) will be required with all small developments of areas of 1 hectare or less.

23 FL9: For developments adjacent to all watercourses of a significant conveyance capacity or where it is necessary to maintain the ecological or environmental quality of the watercourse, any structures (including hard landscaping) must be set back from the edge of the watercourse to allow access for channel clearing/ maintenance/ vegetation. A minimum setback of up to 10-15m will be required either side depending on the width of the watercourse.

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