Chief Executive’s Report on Draft Plan Consultation
Volume 2 – Summary of Submissions Received
Cork City Submission No.:
Person:
Organisation:
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Inland Fisheries Ireland
Summary of Submission and Observation:
• Submission from the Inland Fisheries Ireland (IFI) sets out their intentions to ensure that fisheries of the State, including all inland fisheries, sea angling and mollusc fisheries, are protected including the physical habitat, the facilities, access, quantity and quality of the water, plant life and animal life on which the fish depend. Their submission erlates to various aspects of the Development Plan such as Water Quality and Municipal Sewage Treatment Infrastructure • In their view that the Development in considering the protection of the quality of the aquatic environment must address not only water quality but also include the protection of the physical environment, hydrological processes and biodiversity. • Maintenance of habitat is a particularly important objective of fisheries authorities. It entails a greater knowledge of the environmental responses of aquatic life to pollution/environmental degradation and tends towards more stringent habitat and water quality objectives. • Protection of fisheries is a requirement of The EU Water Framework Directive (2000/60/EC) requiring the protection of the ecological status of river catchments. • The Development Plan must recognise that protection of the aquatic environment/habitat not only requires the protection of water quality but also necessitates the protection and maintenance of physical habitat and hydrological processes/regimes. • • River management policies are integral to the best practice and proper management of rivers and for the protection of habits & water quality. • Protection of water quality & environment/habitat loss are linked. • Clear consideration should be given to all elements which impact water courses and habitats. Sufficient treatment capacity must be available both within the receiving sewerage systems locally and downstream of waste water treatment plants over the full duration of the plan in order that the ecological integrity of the ultimate receiving waters are protected. • highlight the importance of building a comprehensive and robust assessment of both local infrastructural needs and Local Authority capacity to meet those needs into the plan. • Development in areas with inadequate or overloaded WWTP is not a sustainable practice, taking account of the adverse effects of increased wastewater discharges on the general well being and quality of rivers.
Water Quality and Municipal Sewage Treatment Infrastructure •
Water Quality and Integrated Constructed Wetlands (ICWs):
• IFI welcomes the installation of systems intended to treat wastewaters and improve the quality of discharges to the environment, to be designed by engineers and scientists. • Integrated Constructed Wetlands (ICWs) must be viewed as an adjunct to good agricultural practice and not as a low cost way of getting rid of farm waste. Due to the extensive size and water demands of ICWs it may be necessary to consider the implications of surface water abstractions to sustain the wetlands during periods of dry weather.
Aquatic Habitat Protection (including protection of Riparian Habitat) :
• The current planning regulations do not sufficiently address issues of watercourse protection and management. The impacts of some developments on the aquatic environment may only become apparent in the long term. • Developments such as road and bypass development, urbanisation, flood relief, afforestation, river drainage have caused and are causing major disturbances to the physical habitat. • The Council under the terms of the EU Water Framework Directive (WFD) (2000/60/EC) is legally obliged to protect the ecological status of river catchments and channels. • It is a poor reflection on the development objectives which exist both at National and Local Planning level for the protection of the natural environment, when a stream or river which has existed forever in a locality with its own habitat, wildlife etc; is allowed to be covered over and in effect lost forever. • To insure that impacts from development/change in land use practices (including flood plain development) do not interfere with the aquatic environment it is essential that those areas adjacent to waterways (riparian buffer zones) are managed in a manner which will lessen impacts to these habitats. A riparian/buffer zone is a
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