Manager's Report on Public Consultation

Manager’s Report on

Public Consultation Pre Draft Submissions

LLOONNGGFFOORRDD COUNTY DEVELOPMENT PLAN 2009-2015 REVIEW

Prepared by the Planning Section Longford Local Authorities

June 2013 2 CONTENTS

1. INTRODUCTION AND BACKGROUND 4

1.1 PROCESS TO DATE ...... 5 1.2 INDICATIVE TIMESCALE ...... 6 1.3 PRELIMINARY PUBLIC CONSULTATION ...... 7 2. SUBMISSIONS 8

2.1 LIST OF PERSONS OR BODIES WHO MADE SUBMISSIONS OR OBSERVATIONS...... 9 2.1.1 ACKNOWLEDGEMENTS ...... 12 2.2 SUMMARY OF ISSUES RAISED AND MANAGER’S RESPONSE...... 13 2.2.1 MIDLAND REGIONAL AUTHORITY (MRA) ...... 13 2.2.2 WIND ENERGY ...... 16 2.2.3 INFRASTRUCTURE ...... 20 2.2.4 ENVIRONMENT & HERITAGE ...... 23 2.2.5 PROTECTION OF STRUCTURES ...... 30 2.2.6 LAND USE ZONINGS...... 31 2.2.7 PRESERVATION OF PUBLIC RIGHTS OF WAY & ACCESS PROVISION ...... 33 2.2.8 DEVELOPMENT AND RENEWAL ...... 35 2.2.9 PROPER PLANNING & SUSTAINABLE DEVELOPMENT ...... 38 2.2.10 MAJOR ACCIDENTS DIRECTIVE ...... 42 2.2.11 PROVISION OF COMMUNITY FACILITIES...... 43 3. STRATEGIC ENVIRONMENTAL ASSESSMENT (SEA) 45 4. APPROPRIATE ASSESSMENT 50 5. ROLE OF THE MEMBER 51 6. SUMMARY OF RECOMMENDATIONS AND CONCLUSION 52 7. PERSONS/BODIES CONSULTED BY THE PLANNING AUTHORITY 66 Appendix 1: Draft Strategic Environmental Assessment Scoping Report...... Appendix 2: Copies of Submissions......

3 1. Introduction and Background

This report relates to submissions received as part of the initial public consultation period on the Review of the Longford County Development Plan (CDP), 2009-2015, as required by Section 11 (4) (a) of the Planning and Development Act, 2000 (as amended).

In line with the statutory requirements of the Planning and Development Act, 2000 (as amended), coupled with the changing economic climate both nationally and locally over recent years, and the implications of this on the development of the County, it was necessary to carry out public consultation prior to the preparation of a Draft Plan. This report deals with issues that have emerged as a result of the pre-draft phase of public consultation and responds to the issues raised in the submissions and observations made during the public consultation process. The report also makes recommendations in respect of the preparation of the Draft Plan as deemed appropriate.

Strategic Environmental Assessment Strategic Environmental Assessment (SEA) is the process that applies to Plans and Programmes, introduced in 2004, which assesses the environmental impacts that are likely to arise as a result of the implementation of the plan. The SEA and CDP process run in tandem with each other, sharing public consultation phases. Submissions, therefore, were also invited on environmental issues relating to the physical development of the County. Further information on SEA can be viewed in Appendix 1.

Appendix 1 is a copy of the Draft Scoping Report which seeks to identify the main environmental issues and the level of detail to be included in the full environmental report which will be made available with the Draft County Development Plan.

4 Appropriate Assessment An Appropriate Assessment (AA) is also being undertaken alongside the Development Plan Review which assesses the implications of the Plan alone and in combination with other strategic actions and projects, on the integrity of Natura 2000 sites in view of its conservation objectives.

Strategic Flood Risk Assessment A strategic flood risk assessment (SFRA) of the plan has been initiated in order to integrate flood considerations into the Plan ensuring that it is consistent with the Flood Risk Management Guidelines for Planning Authorities.

The preparation of the Plan, SEA, AA and SFRA take place concurrently and the findings of the AA and SFRA will inform both the Draft Plan and the SEA. These processes will ensure full integration and consideration of environmental issues throughout each stage of the CDP process.

1.1 Process to Date

A planning authority is obliged to make a development plan every 6 years. Longford County Council therefore started the preparation of a new County Development Plan on March 8th 2013.

The County Development Plan, prepared under the Planning and Development Act, 2000 (as amended) is a six year plan providing a framework for the sustainable physical development of the County, while considering the conservation and protection of the built and natural environment. It also aims to carefully consider the needs of all groups and individuals within the County and promote equal opportunities. The Development Plan sets out an overall strategy for the proper planning and sustainable development of Longford County in terms of social, cultural, economic and physical development and consists of a written statement supported by mapping and other appendices indicating the development objectives for the County. The Plan must also be consistent with the

5 National Spatial Strategy 2002-2020 and the Midlands Regional Planning Guidelines 2010-2022. Planning applications are assessed against the policies and objectives set out in the Plan.

In accordance with the requirements of the Act, extensive notification of the review process was given. Notice was published in the Longford Leader and forwarded to the relevant bodies in accordance with Section 11 (1) & (2) of the Planning and Development Act 2000 (as amended) on the 8th of March, 2013.

1.2 Indicative Timescale

Below is an indicative timeframe for the County Development Plan review process, from initial pre-draft public consultation which has already taken place to adoption of the Plan.

o March 2013 - Formal Notice and invitation of submissions o March-April 2013 - Public Meetings held in Longford Town, Granard, Ballymahon, Drumlish, Edgeworthstown and Lanesborough. o May 2013 - First Phase of Consultation ends o June 2013 - Manager’s report on first phase of consultation submitted to Council o (up to)September 2013 - Directions from elected members o December 2013 - Draft CDP and Environmental Report o January 2014 - Second Phase of Public Consultation commences o July 2014 - Second Manager’s Report o Up to April 2015- New CDP with Environmental Report

6 1.3 Preliminary Public Consultation

A total number of 114 submissions were received during the pre-draft public consultation period, the majority of which relate to wind energy development.

In addition, the Council sought to obtain the views and ideas of all interested parties concerning the development of the County and so public meetings were held, regarding all aspects of the County Development Plan, in each of the County Libraries during the consultation phase. Details of these meetings were advertised in the local press and are included for reference at Section 7 of this document.

In accordance with the Planning and Development Act, 2000 (as amended), and the Planning and Development Regulations, 2001 - 2012, the relevant prescribed authorities were notified and invited to make submissions/observations. In addition to this, the Council also sought to obtain the views of relevant stakeholders. Public information leaflets were also circulated to all Community Groups in the County informing them of the process, notifying them about public meetings and inviting submissions.

Details of those consulted as part of the public consultation process is set out at Section 7 and Appendix 2 includes a copy of all submissions/observations received by the Planning Authority in response to the public consultation process.

7 2. Submissions

Under Section 12 of the Planning and Development Acts 2000-2011, as amended, a number of valid written submissions were received. This report, as a requirement of the planning legislation:

x lists the persons or bodies who made the submission or observation x summarises the issues raised by those parties x summarises the issues raised and recommendations made by the Midland Regional Planning Authority and x gives the opinion of the Manager to the issues raised taking account of the proper planning and sustainable development in the area, the statutory obligations of the Local Authority and the Midland Regional Planning Guidelines and objectives of the Government x outlines the recommendations of the Manager in relation to the manner in which those issues and recommendations should be addressed in the Draft Development Plan

8 2.1 List of persons or bodies who made submissions or observations

The following table lists the persons and bodies who submitted submissions/observations to the CDP review as part of the pre-draft public consultation process.

Reference Date Name

PD 1 13.03.2013 Health & Safety Authority PD 2 22.03.2013 Inland Fisheries Board PD 3 05.04.2013 Bord Na Mona PD 4 17.04.2013 Leitrim County Council PD 5 25.04.2013 National Roads Authority PD 6 26.04.2013 Seamus Hourican PD 7 19.04.2013 Midland Regional Authority PD 8 29.04.2013 Keep Ireland Open PD 9 30.04.2013 Matthew Grzywacz PD 10 01.05.2013 Sharon and Nick Nally PD 11 03.05.2013 Larry & Catherine Gallagher PD 12 03.05.2013 Newtowncashel Tidy Towns Committee PD 13 03.05.2013 Rachel Hunt PD 14 03.05.2013 Darragh Kelly PD 15 03.05.2013 Caroline Kelly PD 16 03.05.2013 Therese Callaghan PD 17 03.05.2013 Patrick Kelly PD 18 03.05.2013 Amy Kelly PD 19 03.05.2013 Edel Kelly PD 20 03.05.2013 Jan Lovett PD 21 03.05.2013 Charlie Keogh PD 22 03.05.2013 James Kelly PD 23 03.05.2013 Noel O’Neill PD 24 03.05.2013 Kate & Padraig Keegan PD 25 03.05.2013 Michael Doherty PD 26 03.05.2013 Gemma Nolan PD 27 03.05.2013 Mary Kelly PD 28 03.05.2013 Patrick Jones PD 29 03.05.2013 Legan Community Childcare Ltd PD 30 03.05.2013 Gabriel Kelly PD 31 03.05.2013 Eileen Burke

9 PD 32 03.05.2013 Robert Hamlin PD 33 03.05.2013 Kathleen Kelly PD 34 03.05.2013 James Nally PD 35 03.05.2013 Mary Skelly PD 36 03.05.2013 S. Keegan PD 37 03.05.2013 Margaret Boyce PD 38 03.05.2013 Maureen McDermott PD 39 03.05.2013 L. Beggs PD 40 03.05.2013 Bernard Nally PD 41 03.05.2013 Anthony Greene PD 42 03.05.2013 Ursula McGoey PD 43 03.05.2013 Jacqueline Beggs PD 44 03.05.2013 Aron Cox PD 45 03.05.2013 Leona McHugh PD 46 03.05.2013 Martas Barkarokas PD 47 03.05.2013 Linda Burke PD 48 03.05.2013 John Joseph Kenny PD 49 03.05.2013 Peter Hunt PD 50 03.05.2013 Bernie Kelly PD 51 03.05.2013 Gerry Gilchrist PD 52 03.05.2013 Amy Hamilton PD 53 03.05.2013 Geraldine Gilchrist PD 54 03.05.2013 Mary Moran PD 55 03.05.2013 Raymond Kelly PD 56 03.05.2013 Peter Flood PD 57 03.05.2013 Legan Gun Club PD 58 03.05.2013 Kevin Gannon PD 59 03.05.2013 Katie Flood PD 60 03.05.2013 Christopher Burke PD 61 03.05.2013 Eileen Burke PD 62 03.05.2013 Pete Mannion PD 63 03.05.2013 Jason Kelly PD 64 03.05.2013 Damien Gannon PD 65 03.05.2013 Michelle Mitchell PD 66 03.05.2013 CM Kelly PD 67 03.05.2013 Anne Jones PD 68 03.05.2013 Mike Nolan PD 69 03.05.2013 John J. Reilly PD 70 03.05.2013 Catherine McGuire PD 71 03.05.2013 Sean Duke PD 72 03.05.2013 Colman Lovett PD 73 03.05.2013 Shena Kearney PD 74 03.05.2013 Peggy Ham PD 75 03.05.2013 Paul Leavy PD 76 03.05.2013 Kathleen Leavy

10 PD 77 03.05.2013 Rose Campbell PD 78 03.05.2013 Ciara Price PD 79 03.05.2013 Irene McGlynn PD 80 03.05.2013 James McGuire PD 81 03.05.2013 Colm Matthews PD 82 03.05.2013 Caroline Doherty PD 83 03.05.2013 Rebecca Donohoe PD 84 03.05.2013 Joe Keogh PD 85 03.05.2013 Teresa Delea PD 86 03.05.2013 Miriam & Bill Murphy PD 87 03.05.2013 Jane Musgrave PD 88 03.05.2013 Nuala, Nicole & Darragh Flynn PD 89 03.05.2013 Leigh Kelly PD 90 03.05.2013 Louise Kelly PD 91 03.05.2013 Carmel & Paul Nulty PD 92 03.05.2013 Peter Rooney PD 93 03.05.2013 Michael & Eilish O’Halloran PD 94 03.05.2013 Mary Flood PD 95 03.05.2013 John O’Brien PD 96 03.05.2013 Graham Kelly PD 97 03.05.2013 Residents of Cornadowagh, Newtowncashel C/o Sandra Dowd PD 98 01.05.21013 EPA PD 99 02.05.2013 Longford Environmental Alliance PD 100 03.05.2013 Drumlish Tidy Towns Committee PD 101 03.05.2013 Irish Wind Energy Association PD 102 03.05.2013 County Longford Community & Voluntary Forum PD 103 03.05.2013 Longford I.F.A. PD 104 03.05.2013 Yvonne Ni Mhurchu PD 105 03.05.2013 Longford Community Resources Ltd PD 106 03.05.2013 Longford Women’s Link PD 107 03.05.2013 Lakeland Windfarm Information Group PD 108 03.05.2013 William Moran PD 109 03.05.2013 Newtownforbes Tidy Towns Association PD 110 03.05.2013 Element Power Ireland Ltd PD 111 03.05.2013 Avril Moran PD 112 03.05.2013 Abbeylara Tidy Towns Committee PD 113 03.05.2013 Martin & Cathy Moran Valerie & Kathleen Moran PD 114 03.05.2013 Fehily Timoney & Company

11 2.1.1 Acknowledgements

The following acknowledgements were also received as part of the public consultation process.

Name Date

Department of Agriculture, Fisheries and Food 05/04/13

An Bord Pleanála 21/03/13

An Garda Síochána 14/03/13

Minister for Agriculture, Food and the Marine 05/03/13

Department of Communications, Energy and 13/05/13 Natural Resources

12 2.2 Summary of issues raised and Manager’s Response

2.2.1 Midland Regional Authority (MRA)

Summary of Issues Raised:

The MRA submitted their submission in accordance with Section 27(A) of the Planning and Development Act 2000 (as amended).

The publication of the Planning Consultation Paper by the Council was welcomed and the co-operation of the Forward Planning Section of Longford County Council in the process to date was welcomed.

Attention in the submission is directed to recent planning guidance issued/updated by the Department of Environment, Community and Local Government since the publication of the previous Development Plan, which should be incorporated in the review.

It is suggested that the Plan should address the issues of residential land in the context of population targets contained within the RPGs. Current and future policy should acknowledge the need and make provision for the realignment of growth ratios to ensure that the pattern of spatial development in Longford Town and the remainder of the County is in line with RPG provisions and settlement strategy and in particular the consolidation of services across all tiers of the settlement hierarchy.

The MRA outline the following key strategic areas of relevance to County Longford that require consideration in terms of economic development, transport and infrastructure, environment and amenity and tourism that require alignment with the Midland Regional Planning Guidelines as part of the review.

13 The following issues are recommended for incorporation into the Draft Plan.

Settlement Strategy o Population provision to align with the allocated proportions in Regional Guidelines o Consolidation of services and infrastructure in line with Settlement Hierarchy outlined in the Regional Guidelines

Economic Development o Reuse of brownfield and vacant sites o Support for the expansion of engineering, pharmaceuticals and food industries in conjunction with education providers such as Athlone Institute of Technology o Promotion of the midlandsireland.ie brand in terms of regional identity o Support diversification of the Rural Economy and support diversification of the peat lands in a holistic manner

Transport and Infrastructure o Prioritisation of road investment priorities in conjunction with routes of Strategic Importance (including their protection) o Infrastructure and zoning aligned with Core Strategy o Policy to support integrated public transport o Improved public transport o Support the sustainable provision of telecommunications infrastructure including broadband

Environment, Amenity and Tourism o Promotion of awareness and access to heritage in terms of tourism development and economic development o Exploration of Strategic Open Space section in the plan in line with walking/cycling routes and amenity/recreational facilities o Incorporation of the Shannon Catchment Flood Risk Assessment and

14 Management Study (CFRAMS) o Landscape Character Assessment to consider Regional application

It is suggested that policy should be included to ensure that infrastructure provision is not only in line with projected population requirements, but also to support the economic development and expansion required to attract and retain growth.

Response of the Manager:

The positive recognition of the Planning Consultation Paper and the Council’s consultative approach with the Midland Regional Authority is welcomed.

The Draft Plan will incorporate all of the recommendations as set out in the Midland Regional Authority submission and will include a Core Strategy identifying the quantum, location and phasing of development for the plan period that is consistent with the regionally defined population targets and settlement hierarchy, and, which reflects the availability of existing services, planned investment, sequential development and environmental requirements (i.e. an evidence based approach in determining the suitability of lands for zoning purposes).

Policy will be provided to support the preparation of a Strategic Open Space Plan for the County, addressing cycling/walking routes and incorporating the main amenity, leisure and recreational facilities en route.

Recommendation:

It is recommended to incorporate all of the recommendations as set out by the Midland Regional Authority in the preparation of the Draft Plan.

15 2.2.2 Wind Energy

Summary of Issues Raised:

92 submissions were received in respect of Wind Energy Development which can be summarised as follows:

For: (PD 3, PD 101, PD 110, PD 114 (See Section 2.1 pages 8-11 for reference)

Justification: o Benefits of wind energy and obligations in meeting renewable energy commitments are outlined (20% of overall EU energy consumption coming from renewable sources) o Reference to DoEHLG Wind Energy Development Guidelines (2006) o “Longford has significant potential for the development of renewable energy….more could be done to realize the full potential within the County”. Currently Longford has no installed wind energy o Economic benefits should be highlighted o Cutaway peat bogs identified as opportune sites for wind energy development (grid connection application with EirGrid for a proposed wind farm at Derryaroge bog) o Request to encourage more supportive policy and identify the benefit of larger scale turbines to reduce overall numbers amongst other issues

Against: (PD 9 - PD 10, PD 13 - PD 96, PD 107 - PD 108, PD 111, PD 113 (See Section 2.1 pages 8-11 for reference)

The submissions received in this regard relate to the development of large ‘industrial scale’ (150m +) wind energy projects. The concerns as set out under these submissions are as follows:

16 o Health & Safety Implications o Negative economic impact o Visual amenity impact concerns o Noise and shadow flicker concerns o Environmental impact and effect on wildlife patterns including flight path of wild geese o Safety o Current guidelines in relation to wind turbines are outdated. Emphasis on the need for proper guidelines and research o Concerns about the lack of consultation with the local community o Concerns about destruction of fragile ecosystems and animal habitats o No benefit to community as power is being sent to the UK o Negative effects on general wellbeing o Reduction in the value of the properties in the area o Impact on roads o Reference to a report from the French Academie Nationale De Medecine, Paris which recommended that any construction of wind turbines of over 2.5 MW capacity within 1.5km of homes should be suspended pending further research into ill-effects of noise on human health. Report outlines health complaints including depression, anxiety and headaches o Development should be excluded for the Development Plan pending further research o Strategic Environmental Assessment of on-shore wind energy plans is yet to be undertaken o Need less invasive alternatives in renewable energy o Absence of cost/benefit analysis o Increased setback distances required o Safety in relation to Abbeyshrule airfield o Lack of community benefits o Request that areas of cutaway bogs be the only designated areas for wind farms subject to environmental assessment o Siting Layout and Design – request that wind turbines should not be permitted

17 within 2.5km of any noise sensitive property and that there be no increase in background noise over 5dB be permitted

Response of the Manager:

The Draft Plan will include Wind Energy Policy in light of the available national guidelines, Planning Guidelines for Wind Farm Development 2006 issued by the Department of Environment, Heritage and Local Government. Any subsequent update to national policy in this regard will also be incorporated into the policy formulation criteria.

Policy will be provided to support the preparation of a Renewable Energy Strategy for the County having regard to the Sustainable Energy Authority of Ireland (SEAI) Draft ‘Methodology for Local Authority Renewable Energy Strategies’ or any subsequent update.

Strategic areas of the County will be identified for wind energy development, with the help of the recently updated SEAI Wind Atlas for Ireland, including an assessment of the suitability of Bord na Mona cutaway peatlands, in particular, for larger scale wind energy projects. In addition to the requirements of the Wind Energy Guidelines, any designation and associated policy in this regard will be consistent with, and take account of, nature conservation and environmental legislation and targets, including the conservation and protection of the designated and proposed Natura 2000 sites and Natural Heritage Areas in and adjacent to the County.

Policy will ensure full compliance with the requirements of the EU SEA Directive (2001/42/EC) and the associated SEA Regulations 2004 (SI No. 436 of 2004) and SEA Guidelines 2004 (DoEHLG, 2004) and comply with the requirements of the EU Habitats Directive (92/43/EEC), in particular the need for Appropriate Assessment, in line with the Natural Habitats Regulations (SI No. 94 of 1997), Appropriate Assessment Guidelines 2009 (DoEHLG, 2009) and the Planning and Development Act 2000-2010.

18 Recommendation:

It is recommended that Wind Energy Policy be formulated having regard to Planning Guidelines for Wind Farm Development 2006 issued by the Department of Environment, Heritage and Local Government with the designation of strategic areas mapped based on the SEAI Wind Atlas and taking account of nature conservation and environmental legislation and targets, including the conservation and protection of the designated and proposed Natura 2000 sites and Natural Heritage Areas in and adjacent to the County (Special Areas of Conservation, Special Protection Areas, Natural Heritage Areas or as habitats capable of supporting Annex I species). Regard should also be had to the need to protect designated heritage sites, designated sensitive rural landscapes, visually vulnerable areas, scenic routes and scenic views

Bord na Mona cutaway bogs, in particular, are recommended for assessment in terms of suitability to accommodate larger scale wind energy projects.

Policy in respect of community gain should be formulated in respect of large scale wind energy proposals.

It is recommended that the Draft Plan should support the development of a Renewable Energy Strategy for the County having regard to the (SEAI) Draft ‘Methodology for Local Authority Renewable Energy Strategies’ or any subsequent update.

19 2.2.3 Infrastructure

Letters were issued to infrastructure and service providers in March 2013, requesting details of long-term plans for the provision of infrastructure or services in the County, as provided for by the Planning and Development Acts.

National Roads Authority (NRA)

Emphasises importance of maintaining high quality access on the national road network inter and intra-regionally in the delivery of objectives outlined under the national spatial strategy, including policy relating to competitiveness and balanced regional development. Relevant issues in relation to the maintenance of capacity of national roads in terms of physical development policy include the frequency of access points to the network, the extent of development adjoining and environs of national roads and their interchanges and the traffic volumes generated by development.

The NRA recommends: o Regard be had to the Department of Environment, Community and Local Government Spatial Planning & National Roads Guidelines for Planning Authorities (2012) o Protect carrying capacity, operational efficiency & safety o Review industry, enterprise and employment zonings that could generate traffic o Incorporate capacity enhancements and traffic management measures as part of new large scale developments o Promote new regional & local road and transportation infrastructure o Avoid creation of new access where speed limits of >50kph apply & avoid proliferation of access in >60kph areas o Where less restrictive approach is employed this should be Plan led. Where the Council proposes to identify ‘exceptional circumstances’ an evidence base will need to be established in consultation with the NRA o Protect route options for infrastructure from adverse development and incorporate proposed N4 Rooskey to Mullingar proposal into Draft Plan

20 o Positive work carried out by the Council in integrating land use and transport, notably the preparation of the Strategic Transport Assessment in association with the Longford Northern Environs Local Area Plan o Importance of safeguarding the strategic inter-urban and inter-regional function of national roads o Recommended that a Strategic Transport Assessment should be considered as part of the Draft Plan o Recommends that Traffic and Transport Assessments and Road Safety Audits be requested alongside significant development proposals. o Regard should be had to NRA Policy on the Provision of Tourist and Leisure Signage on National Roads (March 2011) o Noise mitigation should be provided for as part of development proposals where appropriate

Longford Environmental Alliance o Recommends that the Draft Plan should provide for more sustainable methods of travel

Keep Ireland Open o Reference to potential of walking and cycling, including designation/expansion of walking and cycle networks in terms of tourism potential, should be developed having regard to various strategies in this area o Support cycle lanes o Support provision of parking for cyclists o Investigate funding for development of walking and cycling trails e.g. Royal Canal o Promote greenways and linear parks

Response of the Manager:

The Council recognises the importance of the national road network in the County and is committed to protecting their strategic role in catering for inter-urban and inter-regional

21 transport requirements. In this regard, the County Development Plan already recognises the importance of national roads and supports the objective of maintaining and protecting safety and efficiency.

The County Council will continue to consult with the National Roads Authority (NRA) in relation to the provision of services to motorists and the reservation of lands for future NRA projects. Development standards in relation to National Roads should be reviewed in light of changes to national policy and guidelines and documentation to accompany significant development proposals should be prescribed.

The Council will continue to promote (and secure investment for) alternative forms of transport that reduce dependence on the private car, such as public transport initiatives and facilities for cyclists and pedestrians.

Recommendation:

The Draft Plan should recognise the importance of the National Road network in the County and include policy to protect their strategic role in catering for inter-urban and inter-regional transport requirements. In this regard, it is recommended that the Draft Plan supports the objective of maintaining and protecting safety and efficiency and facilitates the provision of the necessary infrastructure required to promote the sustainable development of the County.

A comprehensive review of existing National Roads policy is recommended to be carried out in accordance with the Department of Environment Community and Local Government Spatial Planning & National Roads Guidelines for Planning Authorities (2012) and incorporated into the Draft Plan accordingly, including:

o Align infrastructural policies and programmes with the settlement strategy and land use proposals for the County o Continue to make representations to the NRA for the provision of needed road infrastructure

22 o Promote road safety as a high priority o Aid and facilitate the provision of public transport infrastructure and support and encourage rural transport initiatives o Outline measures, including the reservation of land, to facilitate future infrastructure works o Require, where appropriate, proposals for development to be accompanied by traffic and transport assessments and/or road safety audits and, where relevant, which address the proposal and any potential cumulative impact in association with neighbouring developments on the road network

Policy should also be provided to facilitate alternative modes of transport including the promotion of walking and cycling by encouraging safe footpaths/cycle ways and requiring this, where appropriate, as part of any new development. The Draft Plan should also promote the potential development of long distance walking routes and cycling, particularly those with historical and cultural associations (including green infrastructure) and links to other routes in adjacent Counties.

2.2.4 Environment & Heritage

Conservation and protection of the environment and the conservation and protection of European sites and any other relevant sites.

Inland Fisheries Ireland (IFI)

IFI outline their role in protecting the fisheries of the state and the need to protect all aspects of the aquatic environment.

The IFI considers; o The Draft Plan should address not only water quality but also the protection of

23 the physical environment, hydrological processes and biodiversity o Be consistent with the EU Water Framework Directive (2000/60/EC) and River Basin Management Plans o Where appropriate, development should not be permitted until sewerage upgrading is complete and operational or the developer provides secondary treatment until sewerage upgrading is complete and operational o Integrated Constructed Wetland should be supported in accordance with DoEHLG Integrated Constructed Wetlands, Guidance Document for Farmyard Soiled Water and Domestic Wastewater Applications (Nov 2010) o Riparian buffers should be provided to ensure watercourse protection and management o Policy should be provided to protect against invasive species which harm local native species o River crossing structures standards should be prescribed o Water conservation should be promoted o Sustainable Urban Drainage Systems requirements o Designation of Special Amenity Areas as linear parks along waterways

Bord na Mona o Outline commitment for protection of biodiversity and promotion of best practice techniques to assist in the rehabilitation and management of cut-away bogs in line with the Bord na Mona Biodiversity Action Plan (2010-2015)

Irish Farmers Association (IFA) o Endorse the facilitation of housing for farm families to sustain rural communities o Request that the words “dairy producer” is removed from AGR5 o AGR6 should follow National Department of Environment guidance on the Nitrates Directive. o The Council should set an annual maintenance programme for the river in the County under its management. o Request that ILW3 should be removed from the Plan as it may be contrary to the recommendations of the CFRAMS on the Shannon.

24 o Propose that areas of cut-away bog could be flooded as part of a flood relief plan for the Shannon.

County Longford Community & Voluntary Forum o Need to address Climate Change

Longford Environmental Alliance o Need to address climate change and flooding issues

PD 104 o County Longford has a strong community identity and a diverse cultural heritage o Fundamental policy of the state to preserve the Irish language o Availability of Irish Language Services in the various sectors of the Local Authorities is paramount o Outlined developments that could be considered favourably in County Longford including community centres that support Irish, education facilities and tourism projects. o Bilingual and Irish Language place names and signs should be encouraged.

Keep Ireland Open o Policy should facilitate the preservation of the character of the landscape, including policies related to views and prospects and places and features of natural beauty and interest o Protect rights of way and support accesses to lake shores, river and canal banks, through the acquisition of land for public rights of way and parking and lay-by facilities, where appropriate o Facilitate the creation or expansion of walking/cycling routes o Develop and protect Natural & Recreational Amenities o Protect and improve Inland Lakes and Waterways o Promote, protect and provide access to natural amenities, archaeological heritage and National Monuments and geological sites o Landscape Character Assessment

25 o Manage Forestry while protecting the environment o Manage Agriculture while protecting the environment o Preserve and enhance natural amenities and recreation amenities as an integral part of the development of the County, both in terms of providing an attractive and accessible resource for the County’s population and in terms of attracting inward investment from tourism and increasing the marketability of Longford as a location for industry, business and commercial activity

Environment Heritage and Amenities o Review Landscape Character Assessment and protect areas of high amenity o Review of Heritage Plan

Archaeological Heritage o Protection of archaeological heritage and National Monuments including provision of public access

Natural Heritage and Diversity o Promote, protect and provide access to natural amenities

Geological Sites o Protect and provide access to geological sites o Consult with Geological Survey of Ireland for relevant development proposals

Inland Lakes and Waterways o Information should be provided on lakeside and riverside amenity areas and policy provided to protect these areas from inappropriate development. o Explore potential for walking and cycling, horse riding, wildlife, bird watching and other non noise generating activities in these areas o Facilitate public access o Implementation of visual protection zones along the Royal Canal o Provide riparian zones o Policy to facilitate inter-county tourism links

26 o Discourage water skiing and power boats o Support designation of Lough Ree as a National Park

Natural & Recreational Amenities o Support improved signage o Investigate Special Amenity Area designations

Response of the Manager:

The Council recognises and is strongly committed to the protection of the County’s water sources, water quality and also the protection of the physical environment, hydrological processes and biodiversity. In this regard, the existing Plan is committed to the implementation of the EU Water Framework Directive (2000/60/EC) and River Basin Management Plans.

The natural heritage of the County is viewed as a major asset and policies contained in the existing County Development Plan will be reviewed and updated as part of the Draft Plan. This will be carried out in tandem with a landscape character assessment of the County which will identify, in detail, landscape areas of importance in the County.

The importance of the agricultural industry to the economy of the County is recognized as is the need to facilitate the modernisation of the agricultural industry in the County in accordance with statutory responsibilities and national guidance. It is also important that the Draft Plan encourages and promotes appropriate initiatives which will secure the development and viability of existing rural communities.

The potential of climate change, to alter the development environment and how the planning system can avoid or prevent negative impacts in this context, will be an important consideration in the development policy contained within this plan.

The existing Development Plan has an extensive range of policies and objectives that aim to facilitate the preservation of the character of the landscape, including policies

27 related to views and prospects and places and features of natural beauty and interest. This policy will be reviewed as part of the Draft Plan and in light of a Landscape Character Assessment that is to be incorporated into the Draft Plan.

The importance of Lough Ree, the second largest lake in the Shannon system with the highest navigation use of Ireland’s waterways connecting to the Erne system and on to Northern Ireland, is recognised. With several natural heritage designations, Lough Ree, with its diverse habitats and early Christian archaeological heritage located along its shoreline and the islands within, provides significant potential in terms of tourism development enhanced by its proximity to the linked gateway town of Athlone.

The promotion of Irish Language should be encouraged throughout the Plan.

Recommendation:

The Draft Plan should outline its commitment and review policy in respect to the implementation of the EU Water Framework Directive (2000/60/EC) and River Basin Management Plans including the protection of water quality and it’s associated physical environment, hydrological processes and biodiversity and should include policy which is appropriate in this regard.

The Draft Plan should recognise the importance of the protection of the archaeological and natural heritage of the area and should review and strengthen these policies accordingly. Policy should ensure that the natural assets of the County are protected and enhanced while allowing for appropriate access and recreational activity.

It is recommended that the policy in respect of natural & recreational amenities, inland lakes & waterways and protection of geological sites should be reviewed and, where appropriate, updated and incorporated into the Draft Plan accordingly. Policy in this regard should encourage and promote the investigation and use of the potential of our natural & recreational amenities including the Canal towpaths for the provision of designated walking and cycle routes and wildlife corridors for recreational, amenity

28 and educational purposes. This should be carried out in the context of an important resource for the population of the County and with a view towards the promotion of sustainable tourism projects in County Longford.

Policies should also be reviewed in light of the Landscape Character Assessment which is to be carried out as part of the Development Plan review process.

Policy supporting alternative uses of cut-over boglands, including the provision of alternative energy and promotion of biodiversity should be included in the Draft Plan.

It is recommended that existing agricultural policy is reviewed and updated as part of the Draft Plan. A balanced approach to rural housing, in line with the Sustainable Rural Housing Guidelines and the promotion of appropriate initiatives which will secure the development and viability of existing rural communities, should be provided.

All criteria in respect of effluent spreading on land should follow National Department of Environment guidance on the Nitrates Directive and policy should support the maintenance of rivers in the County.

Policy should support co-operation in conjunction with the Office of Public Works in the establishment of catchment based Flood Planning Groups involving all key actors including planning authorities and groups representing agriculture, forestry, water management, land management (e.g. Bord na Mona and the National Parks and Wildlife Service.

ILW3 should be reviewed and updated if necessary to ensure consistency with the recommendations of the CFRAMS on the Shannon. The policy should, however, protect against large scale commercial water extraction.

Policy should be provided to promote and explore the feasibility of Lough Ree being designated as a National Park.

29 A full Strategic Flood Risk Assessment is being carried out as part of the Development Plan review, the recommendations of which should be incorporated in the Draft Plan.

Climate Change should be considered and should inform policy provision in the Draft Plan.

The promotion of Irish Language should be encouraged throughout the Plan.

2.2.5 Protection of Structures

Longford Environmental Alliance outline the need to identify buildings of outstanding value and include them for protection as part of the Draft Plan.

Response of the Manager:

The architectural heritage of the County represents a finite resource and irreplaceable asset to the County and contributes to the quality of our built environment. It is important that these structures are protected as they are illustrative of a period within the historical landscape and development of the county. These structures are also key repositories of traditional building skills and design techniques.

Accordingly, the provision of policy for their protection is paramount. In this regard, policy should be provided to ensure the protection of Protected Structures in addition to any structure listed on the Draft National Inventory of Architectural Heritage for County Longford.

30 Recommendation:

The Draft Plan should review current policies to ensure the protection of the architectural heritage of the County.

Policy should also be provided to support the updating of the Record of Protected Structures.

Policy should be included to ensure the protection of Protected Structures in addition to any structure listed on the Draft National Inventory of Architectural Heritage for County Longford.

2.2.6 Land Use Zonings

PD 6, P 11, PD 97 (See Section 2.1 pages 8-11 for reference)

Summary of Issues Raised:

o Request for inclusion of lands within the Aughnacliffe Development Envelope o Request for omission of lands in Newtowncashel Development Envelope due to flooding, proximity to Lough Ree and lack of essential infrastructure

Response of the Manager:

Consideration of specific zoning requests for the zoning of any particular piece of land is not considered at this stage in accordance with s.11(4)(b)(ii) of the Planning and

31 Development Act 2000 (as amended).

A Strategic Flood Risk Assessment will be carried out as part of the Development Plan review process which will inform the zoning provisions of the Draft Plan.

Recommendation:

It is not recommended that any zonings be considered at this stage in the plan making process, however it is recommended that all zonings be reviewed in light of the findings of the Strategic Flood Risk Assessment currently underway.

It is an objective that adequate lands are zoned so that the development needs of the economy and society of the County, over the plan period and for a reasonable period beyond can be met, while ensuring that priorities for development are clear and that there is a progressive approach to development.

All zoning provisions should be evidence based, in accordance with the requirements of the Core Strategy, in line with population targets set out in the Midland Regional Planning Guidelines and reflect each settlements role in the Settlement Hierarchy.

The following considerations should inform zonings;

o Position of the Settlement in the Regional Settlement Hierarchy and the population allocations set out under the Regional Planning Guidelines o Availability of services and infrastructure-planned and existing e.g. Smarter Travel and Water Services Investment Programme (WSIP) o Potential for economic and social development of the settlement o Sequential Test o The need to consolidate settlements, keeping them physically compact o Flood Risk Assessment o Ground and surface water vulnerability o Environmental impact, including S.E.A and H.D.A. requirements

32 o Planning history o Market availability/choice

2.2.7 Preservation of Public Rights of Way & Access Provision

Summary of Issues Raised:

Keep Ireland Open outline recommendation for the inclusion of policy to;

o Support countryside recreational activities and highlight the importance of public rights of way in this regard o Protect public rights of way and create additional rights of way o Facilitate the preservation of the character of the landscape, including policies related to views and prospects and places and features of natural beauty and interest o Protect rights of way and support accesses to lake shores, river and canal banks through the acquisition of land for public rights of way and parking and lay-by facilities where appropriate o Facilitate the creation or expansion of walking/cycling routes o Develop and protect Natural & Recreational Amenities including improved access o Promote, protect and provide access to natural amenities, archaeological heritage and National Monuments and geological sites o Preserve and enhance natural amenities and recreation amenities as an integral part of the development of the County, both in terms of providing an attractive and accessible resource for the County’s population and in terms of attracting inward investment from tourism and increasing the marketability of Longford as a location for industry, business and commercial activity

Response of the Manager:

High quality countryside, amenity areas and recreation facilities are of extreme

33 importance to the Council in delivering an adequate level of quality of life and achieving community cohesiveness. The Draft Development Plan will outline the requirements of the planning authority for public open space and recreation space provision in connection with development proposals, including the provision of access to same (walking and cycling routes). Land use proposals will also be required to define the requirements of the planning authority for the reservation of recreation and open space, and access to areas of amenity potential.

Public rights of way constitute an important amenity and economic asset. They enable enjoyment of the County’s high quality landscape and are important for tourism development and recreation and the enjoyment of the County’s cultural heritage.

The existing Development Plan has an extensive range of policies and objectives that aim to facilitate the preservation of the character of the landscape, including policies related to views and prospects and places and features of natural beauty and interest. This policy will be reviewed as part of the Draft Plan and in light of a Landscape Character Assessment that is to be incorporated into the Draft Plan. As part of the review, the preservation of public rights of way, which give access to areas of natural beauty or recreational utility, should be incorporated and policy included to support their mapping.

Recommendation:

The Draft Plan should identify areas within the County that are of significance and deserving of protection and review policies and update any necessary changes in light of the Landscape Character Assessment which is to be carried out as part of the Draft Plan process.

Policy should ensure that amenities within the County are appropriately preserved in accordance with the relevant guidelines and that, where possible, access is encouraged, promoted, provided and maintained. In this regard, policy should also be included to facilitate the improvement and development of walkways and cycleways throughout

34 the County.

Policy should be provided to encourage the preservation of the existing public rights of way within the County and to identify public rights of way which give access to places of natural beauty or recreational activity and to support their inclusion in the County Development Plan on a map.

Policy should promote the development of tourism in the County through facilitating access to the amenities of the County while ensuring that the facilitation of tourism does not impact negatively on the environmental quality of the County’s amenities.

2.2.8 Development and Renewal

A number of submissions were received from various Tidy Town and Village Groups PD 12, PD 100, PD 109, PD 112 (Newtowncashel, Drumlish, Newtownforbes, Abbeylara)

Summary of Issues Raised:

Newtowncashel

Newtowncashel Tidy Towns Committee outline the following issues to be dealt with as part of their submission:

o Need to address dereliction and vacant housing o Assessments of housing need o Flooding o Public transport provision o Environment and amenity protection

35 Drumlish

Drumlish Tidy Towns Committee submitted a document titled, ‘Drumlish Village and Area Enhancement Plan’. This comprehensive document sets out a vision for Drumlish to “provide a framework for the enhancement of the Village Core, Heritage buildings and the natural amenities of the Drumlish area, for use and enjoyment by all, in an environmentally friendly and sustainable way”

The submission requests consideration of the following themes as set out in the submitted aforementioned plan.

o Drumlish Village Core (preservation and improvement of the village character) o Heritage (renovation of buildings) o Amenity Walks, Tracks and Trails (promote tourism-signage) o Footpaths

Newtownforbes

Newtownforbes Tidy Towns Committee outline the following issues to be dealt with as part of their submission:

o The need for renewal works o The need for additional parking bays o The need for completely highlighting and upgrading the existing traffic calming measure on the Main Street. o Need for additional calming measures on the N4 beside Scoil Mhuire Primary School o Lack of a children’s playground o The provision of footpaths and cycle paths o Flooding around the village o By-pass for the village o Request that early Medieval Church and Graveyard and former “Bishops House” adjacent to Caislean Breac be placed on the Record of Protected Structures

36 Abbeylara

Abbeylara Tidy Towns Committee outline the following issues to be dealt with as part of their submission:

o Danger at Abbeylara crossroads o Water problem at Bernard Smyths on the Granard Rd, after heavy rain the water flows out the gate and straight into the Abbeylara Village

Response of the Manager:

The Council recognises the need for regeneration to occur in its towns and villages throughout the County. Policy contained within the Draft Development Plan, including the application of zoning, will aim to optimise regeneration.

Recommendation:

It is recommended that policy be included to maintain the vitality and character of established town, village centres and rural areas and ensure that quality underpins all forms of development through developing and maintaining a sense of place and local distinctiveness.

Policy should also ensure:

37 provision of cycleways, footpaths and walking trails o Application of good urban design principles in settlement centres o Policies of the revised Retail Strategy are considered and update any other related policies where required o Facilitation of renewal and development within settlements to promote social inclusion by creating good public realm and having a mix of services where they are most accessible o Protection of architectural heritage o Ensuring environmental protection and enhancement o Encouraging linkages with relevant development bodies i.e. the IDA and County Enterprise Board in promoting the development and renewal of areas

2.2.9 Proper Planning & Sustainable Development

Longford Women’s Link, Longford Community Resources, Longford Environmental Alliance, Keep Ireland Open

Summary of Issues Raised:

Housing o Need to ensure a mixture of house types (homeless, travellers, older people etc) o Ensure availability for varying income levels o Plan the provision of social housing o Prioritise the housing needs o Enforcement of the Derelict Sites Act o Need for sustainable patterns of growth (communities) in line with balanced economic investment and environmental protection. o Need to promote music & culture o Also included as part of the submission is Longford Women’s Manifesto which

38 promotes greater social inclusion and equal participation o Need to address and support local retail requirements

Agriculture o Grazing land should be provided as a recreational source o Fencing in amenity areas should be excluded unless it is essential to the viability of the farm and conforms to best practice and does not impinge on visual amenity

Forestry o Additional information should be provided in respect of forestry o Forestry should not obstruct existing rights of way/access and existing rights of way should be identified before planting commences o Engage with Coillte in developing an off-road cycling strategy o Best practice in forestry planting and felling (Forestry Service) should be required in the context of landscape protection o Discourage new forestry development (except broadleaf) in NHAs, SPAs SACs etc and other sensitive areas

Tourism o Tourism and recreation should be combined o Promote agri-tourism in conjunction with the protection of the visual amenity of the countryside

Aggregates & Mining o Such development should only be permitted where the environment and landscape are protected o Require development to be phased and each phase to be rehabilitated before the next is commenced o Protection of rights of way o Introduction of requirement for landscape and visual assessments to determine the extent of the area of visual influence in order to protect visual amenities o Implementation of environmental legislation.

39 o Concrete and tarmac developments to be located within exiting sites o Implement enforcement and licensing requirements

Response of the Manager:

The Draft Development Plan will allow for linkage to be made with the current County Development Board (CDB) Strategy and it is envisioned that the CDB Strategy will contribute to the socio-economic context for the Development Plan. The land use policies of the development plan will inform and reflect the socio-economic and cultural considerations of the strategy and the Development Plan will take account of those matters which are particularly relevant to land use.

The Draft Development Plan in balancing sustainable development with the social, community and cultural requirements of the County, must recognise the dispersed nature of rural settlement in County Longford. In an attempt to create equal opportunities for employment, housing, services and facilities, the settlement strategy for the County will define suitable rural towns and villages where such facilities will be encouraged, thereby reducing the need to travel. This strategic approach recognises the need to bring rural communities through a period of social, economic and cultural change that may not appear sustainable by urban standards but offers a more secure future where the network of rural settlements is built upon to sustain a range of viable services and community facilities. To this end it is envisioned that the Draft Plan will encourage and support the facilitation of social, community and cultural requirements (and access to such facilities) while still emphasising sustainability. The use of natural resources will also be reviewed as part of the Draft Plan.

The Council also recognises the need for high quality developments in order to create a sense of place which adds to the quality of life experienced thus enhancing social inclusion. This shall also be reflected as part of the Housing Strategy that is to be incorporated into the Draft Plan. Development standards will be reviewed to reflect necessary design changes.

40 The importance of agriculture, forestry, tourism and aggregate and mining to the economy of the county is recognised as is the need to balance environmental awareness and environmentally friendly practices in these areas.

Recommendation:

Policy should be provided to ensure that the Settlement Strategy defines suitable rural towns and villages to create equal opportunities for employment, housing, services and facilities, thus reducing the need to travel as well as meeting housing need in rural areas and balance this with the preservation of the character of rural areas and the protection of it from urban sprawl. The Draft Development Plan should reflect the need to create high quality developments thus improving the quality of life for the residents of the County and enhancing the overall attractiveness of the County as a place to live and work.

In this regard, sustainable development and social inclusion should be core considerations.

Policy should also promote the provision of affordable and social housing and ensure that linkage is made with the County Development Board Strategy and that socio- economic and cultural considerations, which are relevant to land use, are reflected.

Retail policy should be formulated for incorporation into the Draft Plan arising from the finding of the Retail Strategy currently underway.

The Draft Plan should recognise Longford’s rich cultural history, as reflected in the number of annual festivals celebrating music, literature, natural history and other aspects of County life.

The Draft Plan should develop policies to support agriculture including agricultural diversification (including agri-tourism) ensuring maintenance of the integrity of viable

41 farming areas.

Existing policy in respect of agriculture, forestry, tourism and aggregate and mining should also be reviewed and updated as part of the preparation of the Draft Plan. Environmental considerations (including the SEA & AA) should strongly influence any revised policy and encourage and promote environmental awareness and environmentally friendly practices.

2.2.10 Major Accidents Directive

Relating to the control, having regard to the provisions of the Major Accidents Directive and associated regulations for

1. siting of new establishments 2. modification of existing establishments, and 3. development in the vicinity of such establishments for the purposes of reducing the risk, or limiting the consequences, of a major accident.

Summary of Issues Raised:

A submission was received form the Health and Safety Authority (HSA) regarding the Major Accident Directive. It was acknowledged that although there are no notified sites in Longford, the Council should provide an indication of planning policy in relation to major accident hazard sites, distances in relation to such sites should be indicated on maps etc and policy should be included on the siting of new major hazard establishments.

Response of the Manager:

This directive applies to establishments where dangerous substances are produced, used, handled or stored. The Draft Development Plan should ensure that policies, including

42 land use, reflect the Directive and guidelines issued from the HSA.

Recommendation:

It is recommended that the Draft Plan complies with the provisions of the Major Accidents Directive

2.2.11 Provision of Community Facilities

Summary of Issues Raised:

Longford Community Resources Limited (LCRL) outline the need for more public and community facilities to accommodate community workers, youth services, employment schemes etc. In this regard, the Army Barracks has been identified as an opportunity site.

Response of the Manager: The Draft Development Plan will ensure that policies are positively geared towards the facilitation of community services. The Council also intends to take an integrated approach to ensure that policies of other relevant bodies are represented.

The Army Barracks, located within the Longford Town Council administrative area, is outside the remit of the County Development Plan, however, the identification of opportunity sites for the expansion of community facilities will be considered as part of the review process.

43 Recommendation:

It is recommended that policies and zoning provision be included in the Draft Plan to positively facilitate the expansion of community services and promote the retention and development of existing services, particularly where these services promote social inclusion and aid marginalised or vulnerable groups.

The Draft Plan should co-ordinate with RAPID to ensure the provision of public parks and recreational facilities and have regard to the County Development Board Strategy in developing objectives for community facilities and amenities.

44 3. Strategic Environmental Assessment (SEA)

As part of the SEA screening process, environmental authorities were notified that a submission or observation in relation to whether or not implementation of the Proposed Variation would be likely to have significant effects on the environment may be made to the Authorities. One submission in response to the notice was made by the Environmental Protection Agency (EPA).

Submission: Environmental Protection Agency (EPA)

Summary of Issues Raised:

A submission was received from the Environmental Protection Agency (EPA) in relation to the SEA Scoping on the Review of the Longford County Development Plan 2009- 2015. The submission consists of an SEA Scoping Pack, Integration of Environmental Considerations Checklist and a number of specific comments to be taken into account in the preparation of the Plan and SEA, as per the Planning and Development (Strategic Environmental Assessment) Regulations 2004 (S.I. No. 436 of 2004).

The following issues are outlined in the submission:

o Scoping Process Guidelines o Specific Comments to be considered x Protection of surface and groundwater in accordance with the requirements of the Water Framework Directive and the Shannon and Northwest River Basin Management Plans and their respective Programmes of Measures, as relevant and appropriate x Provision of adequate and appropriate critical service infrastructure (drinking water, wastewater, waste etc.) x Protection of nationally and internationally designated conservation sites and promoting the need for conservation/maintenance of ecological linkages and corridors

45 x Incorporation of green infrastructure into the Plan x Full implementation of the Flood Risk Management Guidelines (DEHLG 2009) as relevant and appropriate x Consideration should be given, as appropriate, to rezoning/dezoning undeveloped lands at significant risk of flooding (Zone A and Zone B) and ensuring that development/land use zoning is appropriate to the risk of flooding identified. x Protection of areas of significant landscape character o Updated SEA Regulations/Circulars o European Communities (Birds and Natural Habitats) Regulations 2011 o Environmental Authorities o A generic guidance document was submitted with the following specific environmental information highlighted: o Water x It is noted that surface water quality within the Plan area, under EPA Q- rating classification is predominantly good quality; however the Black River was recorded as being of moderate status (Q3/4) in 2011 x Lough Ree is classified as being oligotrophic/mesotrophic, while Lough Gowna is noted as being moderately eutrophic. Under the Water Framework Directive Classification, Lough Ree, Gowna, Forbes and Kinale are all classified as being moderate status. x Incorporation of the specific relevant objectives and measures as set out in the Shannon and North West River Basin Management Plans (RBMPs) x Full range of protection areas within the River Basin Districts should be taken into account. These include the Camlin River (nutrient sensitive water) and Lough Ree on the Shannon (nutrient sensitive lake) o Drinking Water/Water Supply x It is noted that one water supply in Longford is currently listed on the EPA’s most recent Remedial Action List (RAL) (Q4 2012); Newtowncashel due to “inadequate treatment for cryptosporidium”

46 o Wastewater Treatment x It is noted that there are three wastewater treatment plants currently which have failed to comply with the overall requirements of the Urban Waste Water Treatment Regulations (2001), namely Clondra, Drumlish and Newtownforbes treatment plants.

o Specific Sites to be considered in the Plan x Designated sites, located within 15km of the Plan Area, should be taken into account in the Plan. These include the following Lough Forbes Complex (NHA/SAC), Mount Jessop Bog (NHA), Derrymore Bog (NHA), Lough Bannow (NHA), Lough Ree (NHA/SAC/SPA), Lough Gowna(NHA), Brown Bog (SAC), Ardagullion Bog (SAC), Ballykenny Fisherstown Bog (SPA), Lough Kinale & Derragh Lough (NHA/SPA) and Glen Lough (SPA). Glen Lough is also listed as a Ramsar. o The EPA, as part of their submission, also included an SEA Pack containing SEA Process Guidance, SEA Scoping Checklist, SEA Process Checklist and Wetlands Conservation and Protection

The EPA have indicated that further comment will be indicated upon receipt of the Draft Environmental Report and Plan and associated documents during the next statutory consultation phase of the SEA Process.

Response of the Manager:

The EPA’s submission will be taken into account in both the preparation of the Plan and the undertaking of the SEA.

In order to contribute towards achieving SEA Best Practice for the SEA, ‘SEA Strengths/Best Practice Examples’ and ‘Limits of SEA Effectiveness’ as identified in the Environmental Protection Agency’s Review of Effectiveness of SEA in Ireland 2012 - Key Findings and Recommendations Report (2012) were examined. The output of this

47 examination is a list of actions for the SEA which is detailed on Table 2.1 in the SEA Scoping Report which is attached to this report.

Specific Comments to be Considered The specific comments will be addressed through land use zoning which will be informed by the SEA, AA and SFRA as well as through the other - policy and objective - provisions contained within the Plan. To this effect, the SEA Scoping Report includes a List of Suggested Provisions to be integrated into the Draft Plan. A suggestion with regard to Green Infrastructure has been added to this list on foot of the EPA submission.

Upgrade works have been initiated in respect of the wastewater treatment plants cited in the EPA submission.

Updated SEA Regulations / Circular The cited legislation will be complied with and the cited circular considered throughout the undertaking of the SEA.

European Communities (Birds and Natural Habitats) Regulations 2011 The cited legislation will be complied with and the cited circular considered throughout the undertaking of the SEA and AA.

Guidance Documents Regard will be had to the guidance document submitted.

Environmental Authorities Notice will be given to the contacts as identified by the EPA submission during the SEA Scoping process.

Copies of relevant documentation throughout the Plan/SEA process will be made available and notified on as appropriate.

48 Recommendation:

A full Strategic Environmental Assessment, Appropriate Assessment and Strategic Flood Risk Assessment are being carried out in tandem with the Plan-making process, evaluating the likely environmental effects of implementing the Plan.

It is recommended that the SEA, AA and SFRA be carried out in accordance with the relevant legislation and guidance.

A Draft SEA Scoping Report has been circulated to all relevant environmental bodies for comment and it is recommended that all comments received be reviewed and incorporated into the Scoping Report (which will inform the Draft Plan) where appropriate.

49 4. Appropriate Assessment

An Appropriate Assessment (AA) is being undertaken in tandem with the preparation of the Draft Plan. The Assessment evaluates the implications of the Plan alone and in combination with other strategic actions and projects, on the integrity of Natura 2000 sites in view of their conservation objectives.

The Appropriate Assessment process will inform the policy formation in the Draft Plan.

50 5. Role of the Member

In accordance with Section 11 (4) (d) of the Planning and Development Act 2000 – 2012, following the consideration of the Manager’s Report, the members of the planning authority may issue directions to the Manager regarding the preparation of the Draft Development Plan, and any such directions shall be strategic in nature, consistent with the draft core strategy, and shall take account of the statutory obligations of any local authority in the area and any relevant policies or objectives for the time being of the Government or of any Minister of the Government, and the Manager shall comply with any such directions.

Directions must be issued not later than 10 weeks (prior to Friday September 6th 2013) after the submission of the Manager’s Report. In issuing directions, the members are restricted to considering the proper planning and sustainable development of the area to which the Development Plan relates.

Not later than 12 weeks following the receipt of any directions, a Draft Development Plan will be prepared and submitted to the members of the planning authority for their consideration.

51 6. Summary of Recommendations and Conclusion

The following table sets out a summary of the Manager’s recommendations arising from the submissions received as part of the pre-draft public consultation process.

Midland Regional Authority

It is recommended to incorporate all of the recommendations as set out by the Midland Regional Authority in the preparation of the Draft Plan.

Policy will be provided to support the preparation of a strategic open space plan for the County, addressing cycling/walking routes and incorporating the main amenity, leisure and recreational facilities en route.

Wind Energy

52 Bord na Mona cutaway bogs, in particular are recommended for assessment in terms of suitability to accommodate larger scale wind energy projects.

Policy in respect of community gain should be formulated in respect of large scale wind energy proposals.

It is recommended that the Draft Plan should support the development of a Renewable Energy Strategy for the County having regard to the Draft Sustainable Energy Authority of Ireland (SEAI) ‘A Methodology for Local Authority Renewable Energy Strategies’ or any subsequent update.

Infrastructure

The Draft Plan should recognise the importance of the National Road network in the County and include policy to protect their strategic role in catering for inter- urban and inter-regional transport requirements. In this regard, it is recommended that the Draft Plan supports the objective of maintaining and protecting safety and efficiency and facilitates the provision of the necessary infrastructure required to promote the sustainable development of the County.

A comprehensive review of existing National Roads policy is recommended to be carried out in accordance with the Department of Environment, Community and Local Government Spatial Planning & National Roads Guidelines for Planning Authorities (2012) and incorporated into the Draft Plan accordingly, including:

o Align infrastructural policies and programmes with the settlement strategy and land use proposals for the County o Continue to make representations to the NRA for the provision of

53 needed road infrastructure o Promote road safety as a high priority o Aid and facilitate the provision of public transport infrastructure and support and encourage rural transport initiatives o Outline measures, including the reservation of land, to facilitate future infrastructure works o Require, where appropriate, proposals for development to be accompanied by traffic and transport assessments and/or road safety audits and, where relevant, which address the proposal and any potential cumulative impact in association with neighbouring developments on the road network

Environment & Heritage

The Draft Plan should recognise the importance of the protection of the archaeological and natural heritage of the area and should review and strengthen

54 these policies accordingly. Policy should ensure that the natural assets of the County are protected and enhanced while allowing for appropriate access and recreational activity.

Policies should also be reviewed in light of the Landscape Character Assessment which is to be carried out as part of the Development Plan review process.

Policy supporting alternative uses of cut-over boglands, including the provision of alternative energy and promotion of biodiversity should be included in the Draft Plan.

55 Policy should support co-operation, in conjunction with the Office of Public Works, in the establishment of catchment based Flood Planning Groups involving all key actors including planning authorities and groups representing agriculture, forestry, water management, land management (e.g. Bord na Mona and the National Parks and Wildlife Service.

ILW3 should be reviewed and updated if necessary to ensure consistency with the recommendations of the CFRAMS on the Shannon. The policy should however protect against large scale commercial water extraction.

Policy should be provided to promote and explore the feasibility of Lough Ree being designated as a National Park.

A full Strategic Flood Risk Assessment is being carried out as part of the Development Plan review, the recommendations of which should be incorporated in the Draft Plan.

Climate Change should be considered and should inform policy provision in the Draft Plan.

The promotion of Irish Language should be encouraged throughout the Plan.

Protection of Structures

The Draft Plan should review current policies to ensure the protection of the architectural heritage of the County.

Policy should also be provided to support the updating of the Record of Protected Structures.

56 Policy should be included to ensure the protection of Protected Structures in addition to any structure listed on the Draft National Inventory of Architectural Heritage for County Longford.

Land Use Zonings

It is not recommended that any zonings be considered at this stage in the Plan- making process, however it is recommended that all zonings be reviewed in light of the findings of the Strategic Flood Risk Assessment currently underway.

The following considerations should inform zonings

57 o Ground and surface water vulnerability o Environmental impact, including S.E.A and H.D.A. requirements o Planning history o Market availability/choice

Preservation of Public Rights of Way & Access Provision

58 Development & Renewal

Policy should also ensure:

o The preservation and enhancement of quality of life in all areas through the protection and promotion of the awareness of, and access to, heritage for rural and urban/village dwellers and promote location based activity and amenity development o Support is provided to create vibrant and thriving urban and rural communities, firmly rooted in the concepts of sustainability and maintaining a high quality of life o Appropriate lands are zoned for development and developments facilitate the provision of cycleways, footpaths and walking trails o Application of good urban design principles in settlement centres o Policies of the revised Retail Strategy are considered and update any other related policies where required o Facilitation of renewal and development within settlements to promote social inclusion by creating good public realm and having a mix of services where they are most accessible o Protection of architectural heritage o Ensuring environmental protection and enhancement o Encouraging linkages with relevant development bodies i.e. the IDA and County Enterprise Board in promoting the development and renewal of areas

59 Proper Planning & Sustainable Development

Policy should be provided to ensure that the settlement strategy defines suitable rural towns and villages to create equal opportunities for employment, housing, services and facilities, thus reducing the need to travel as well as meeting housing need in rural areas and balance this with the preservation of the character of rural areas and the protection of it from urban sprawl. The Draft Development Plan should reflect the need to create high quality developments thus improving the quality of life for the residents of the County and enhancing the overall attractiveness of the County as a place to live and work.

In this regard, sustainable development and social inclusion should be core considerations.

Policy should also promote the provision of affordable and social housing and ensure that linkage is made with the County Development Board Strategy and that socio-economic and cultural considerations which are relevant to land use are reflected.

Retail policy should be formulated for incorporation into the Draft Plan arising from the finding of the Retail Strategy currently underway.

The Draft Plan should recognise Longford’s rich cultural history, as reflected in the number of annual festivals celebrating music, literature, natural history and other aspects of County life.

The Draft Plan should develop policies to support agriculture including agricultural diversification (including agri-tourism), ensuring maintenance of the integrity of viable farming areas.

Existing policy in respect of agriculture, forestry, tourism and aggregate and

60 mining should also be reviewed and updated as part of the preparation of the Draft Plan. Environmental considerations (including the SEA & AA) should strongly influence any revised policy and encourage and promote environmental awareness and environmentally friendly practices.

Major Accidents Directive

It is recommended that policies, including land use, reflect the Major Accidents Directive and associated regulations and guidelines issued from the HSA.

Provision of Community Facilities

Environmental Protection Agency

A full Strategic Environmental Assessment, Appropriate Assessment and Strategic Flood Risk Assessment are being carried out in tandem with the Plan- making process, evaluating the likely environmental effects of implementing the

61 Plan.

It is recommended that the SEA, AA and SFRA be carried out in accordance with the relevant legislation and guidance.

The above recommendations should be included in the preparation of the Draft Plan alongside any directions of the Members (which must be strategic in nature and take account of the statutory obligations of the local authority and any relevant policies or objectives of the Government or of any Minister of the Government).

The Manager will comply with any such directions received and prepare the Draft Plan in accordance with the following mandatory objectives of a development Plan.

Mandatory Objectives o The zoning of land for the use solely or primarily of particular areas for particular purposes (whether residential, commercial, industrial, agricultural, recreational, as open space or otherwise, or a mixture of those uses), where and to such extent as the proper planning and sustainable development of the area, in the opinion of the planning authority, requires the uses to be indicated;

62 o The provision or facilitation of the provision of infrastructure including (i) transport, energy and communication facilities, (ii) water supplies and waste water services (regard having been had to the water services strategic plan for the area made in accordance with the Water Services Act 2007), (iii) waste recovery and disposal facilities (regard having been had to the Waste Management Plan for the area made in accordance with the Waste Management Act 1996), and (iv) any ancillary facilities or services; o The conservation and protection of the environment including, in particular, the archaeological and natural heritage and the conservation and protection of European sites and any other sites which may be prescribed; o The encouragement, pursuant to Article 10 of the Habitats Directive, of the management of features of the landscape, such as traditional field boundaries, important for the ecological coherence of the Natura 2000 network and essential for the migration, dispersal and genetic exchange of wild species; o The promotion of compliance with environmental standards and objectives established— (i) for bodies of surface water, by the European Communities (Surface Waters) Regulations 2009; (ii) for groundwater, by the European Communities (Groundwater) Regulations 2010; which standards and objectives are included in river basin management plans (within the meaning of Regulation 13 of the European Communities (Water Policy) Regulations 2003);

63 o The integration of the planning and sustainable development of the area with the social, community and cultural requirements of the area and its population; o The preservation of the character of the landscape where, and to the extent that, in the opinion of the planning authority, the proper planning and sustainable development of the area requires it, including the preservation of views and prospects and the amenities of places and features of natural beauty or interest; o The protection of structures, or parts of structures, which are of special architectural, historical, archaeological, artistic, cultural, scientific, social or technical interest; o The preservation of the character of architectural conservation areas; o The development and renewal of areas in need of regeneration; o The provision of accommodation for travellers, and the use of particular areas for that purpose; o The preservation, improvement and extension of amenities and recreational amenities; o The control, having regard to the provisions of the Major Accidents Directive and any regulations, under any enactment, giving effect to that Directive, of— (i) siting of new establishments, (ii) modification of existing establishments, and (iii) development in the vicinity of such establishments, for the purposes of reducing the risk, or limiting the consequences, of a major accident;

64 o The provision, or facilitation of the provision, of services for the community including, in particular, schools, crèches and other education and childcare facilities; o The promotion of sustainable settlement and transportation strategies in urban and rural areas including the promotion of measures to— (i) reduce energy demand in response to the likelihood of increases in energy and other costs due to long-term decline in non-renewable resources, (ii) reduce anthropogenic greenhouse gas emissions, and (iii) address the necessity of adaptation to climate change in particular, having regard to location, layout and design of new development; o The preservation of public rights of way which give access to seashore, mountain, lakeshore, riverbank or other place of natural beauty or recreational utility, which public rights of way shall be identified both by marking them on at least one of the maps forming part of the development plan and by indicating their location on a list appended to the development plan, and o The landscape, in accordance with relevant policies or objectives for the time being of the Government or any Minister of the Government relating to providing a framework for identification, assessment, protection, management and planning of landscapes and developed having regard to the European Landscape Convention done at Florence on 20 October 2000.

65 7. Persons/Bodies Consulted by the Planning Authority

Prescribed Bodies Department of Environment, Community and Local Government An Bord Pleanála The Minister for Agriculture, Fisheries and Food The Minister for Arts, Heritage and the Gaeltacht The Minister for Communications, Energy and Natural Resources The Minister for Defence The Minister for Education and Skills The Minister for Transport, Tourism and Sport An Chomhairle Ealaíon The Office of Public Works Dublin Airport Authority ESB (Electric Ireland) Forfás Fáilte Ireland The Health Service Executive The Heritage Council The Health and Safety Authority Inland Fisheries Ireland Shannon Regional Fisheries Board Northern Regional Fisheries Board The National Roads Authority An Taisce The National Trust for Ireland Westmeath County Council Roscommon County Council Cavan County Council Leitrim County Council Longford County Council Granard Town Council

66 Longford County Enterprise Board Longford Enterprise Centre Midland Regional Authority BMW Regional Assembly Border Regional Authority West Regional Authority Mid-East Regional Authority Mid-West Regional Authority South-East Regional Authority EirGrid Environmental Protection Agency

Infrastructure Providers National Treasury Management Agency Bord Gáis Energy Bord na Móna Plc. Coillte An Garda Síochána Headquarters Superintendent Denis Shields Airtricity Waterways Ireland Iarnród Eireann

67 Environmental Bodies Environmental Protection Agency Department of Communications, Energy and Natural Resources Department of Agriculture, Fisheries and Food Department of the Environment, Community and Local Government Department of Arts, Heritage and the Gaeltacht Leitrim County Council Roscommon County Council Westmeath County Council Cavan County Council

Community Groups Abbeyshrule Community Development Association Ardagh Community Centre Ballyboro Football Club Ballymahon AFC Ballymahon Badminton Club Ballymahon Community Group Ballymahon Sports Centre Ballymahon Tidy Towns Ballymahon Twinning Association Bog Lane Theatre Company Carrickedmond Community Hall Convent House Day Care Derryhaun Development Association Inny Anglers Development Assoc. Kenagh & District Development Association Kenagh Community Centre Association Kenagh Community Co-Op

68 Lanesboro Badminton Club Lanesboro Boxing Club Lanesboro Parish Hall Committee Lanesboro Tourism Co-op Society Ltd. Legan & Carrickboy Development Assoc. Lough Ree Area Development Co-Op Lough Ree Athletics Club Lough Ree Sub Aqua Club Newtowncashel Tidy Towns Second Longford Ballymahon Scouts Select Vestry of St Georges Church Kenagh Shannonside Heritage Sli na Mona Residents Association St. Sinneach's Hall Committee Tang Muintir Community Council Ltd. Traditional Horse Fair of Lanesboro Annagh Watersport & Leisure Ltd. Ballinamuck Community Association Ballinamuck Community Enterprise Society Ltd. Colmcille Basketball Colmcille Community Centre Colmcille Ploughing & Heritage Festival Cullyfad Community Groups Dromard Community Club Dromard Community Text Alert Dromard GAA Club Dromard Rural Development Association Dromard Rural Development Group Drumlish Tidy Towns Committee Drumlish/Ballinamuck Gun Club Ennybegs Community Centre Ennybegs Village Enhancement Committee

69 Killoe Development Group Killoe Yew Tree Drama Group Latin School Community Centre Committee Leebeen Park Development Co.Ltd. North Longford Anglers Abbeylara GAA Club Abbeylara Parish Development Abbeylara Rural Dev. Group Abbeylara Tidy Towns Edgeworthstown District Development Association Ltd. Granard Agricultural Show Granard Area Action Group Ltd. Granard Pitch & Putt Club 5th Generation (Ireland) Granard Tidy Towns Mostrim GAA Mullinalaghta Development Group Rath Mhuire Resource Centre Sean Connolly's GFC Cameroonians Association in Longford Co. Longford Agricultural Show Society Co. Longford Bee Keepers Association Co. Longford Historical Society Co. Longford Tourism Committee Co. Longford Association for People with Intellectual Disabilities Co. Longford Citizens Information Service Co. Longford Scuba Divers Co. Longford Ploughing Association County Longford Action Group Disabled People of Longford Eya Omo Yoruba in Ireland Farrell Clan

70 GAA Longford Hurling Board HOPE ICA Irish Wheelchair Association Longford ACORN Longford Childcare Network Longford Community Games Longford Environmental Alliance Longford Genealogy Longford Heritage Company Longford Mental Health Association Longford Purchasing Group Longford Society for the Prevention of Cruelty of Animals Longford Womens' Link Longford Women's Manifesto Group National Council for the Blind National Learning Network National Parents Council Primary (Longford Branch) Parents for Parents Sheridan Clan Backstage Theatre Ballymacormack Community Development Group Camlin & District Anglers Clondra Community Association Clonguish Ladies GAA Club EDI Centre Newtownforbes Development Co-Op Ltd Co. Longford Golf Club Harmony House Community Centre Ltd Longford ‘Falcons’ Basketball Club Longford Boy Scouts Longford Chamber of Commerce and Industry

71 Longford Ladies GAA Longford Marathon Longford Pipe Band Longford Rugby Club Longford Swimming Club Longford Tidy Towns Group Longford Vintage Club Mac Eoin Park Residents Association Royal Canal Amenity Group St. Marthas' Conference, Society of St. Vincent de Paul Temperance Hall Committee

Public Meetings Longford Branch Library (Longford Town) (March 11th 2013) Granard Branch Library (March 14th 2013) Ballymahon Branch Library (March 15th 2013) Drumlish Branch Library (March 20th 2013) Edgeworthstown Branch Library (April 2nd 2013) Lanesborough Branch Library (April 2nd 2013)

72 Appendix 1: Draft Strategic Environmental Assessment Scoping Report

Appendix 1: Draft Strategic Environmental Assessment Scoping Report

Department of Environment, Community & Local Government Submission

73 Appendix 2: Copies of Submissions

Appendix 2 Copies of Submissions Received

Received