Carlow County Council Planning Authority,
Re: Planning Application #1718, Waterways Ireland proposed development on the Barrow Navigation
Dear Sir / Madam,
I write in connection with the above planning application and wish to strongly reinforce my previous objection to the proposed development. None of the concerns of my previous objection have been addressed adequately by the Further Information provided by Waterways Ireland. In addition:
- The Health and Safety difficulties are even more apparent following the Further Information Safety Audit of the route which confirms that the topography of the towpath dictates that even the proposed width of 2.5m, (which according to TII Publication DN-GEO-0347 (Rural Cycle Scheme Design specifications is less than "the minimum width which should be implemented to provide a reasonable quality of service") cannot be achieved in all sections.
- In addition, the TII specification of a 1m grass verge on both sides of the path (measured from path to river/trees on one side and path to trees/back drains on the other) cannot be achieved in all sections.
- Following the Further Information, Waterways still haven't located a single Otter holt or couch. As was noted in the council's FI request "observations submitted to the local authorities on the planning application provided additional records of the species within the study area including sightings, holts and couches" so it would seem WI survey results are simply not reliable. There is, furthermore, no reason to believe that a pre-construction Otter survey will be any more reliable.
- The pre-planning scoping response to this proposal by Mr Michael Murphy, Development Applications Unit of the Department of Arts Heritage, stated that a 10m riparian buffer on both banks of a waterway is considered to comprise part of the otter habitat. WI Further Information makes the statement that "following this assessment, it was concluded that the footprint of the proposed development does not provide significant otter habitat and the proposed development will replace the surface of the existing path but will not result in the loss of any otter habitat." This is inconsistent and unexplained.
- The extrapolated current usage figures (9 day measurement) provided in the Further Information do not take into account the fact that usage is heavily weighted to the weekends and Sunday in particular and that the track has the very real potential to achieve High Volume (>1500 visitors in a single day) even in the do-nothing scenario. For a High Volume path a desirable minimum path width of 5m is specified by TII.
- The current usage figures provided in the FI (9 day measurement) are low when compared with the 2015-2016 usage figures recorded by WI, namely 87649 users in St Mullins for this period. This again calls into serious question the classification of future use as "Low Volume."
- The Flood Risk plan provided in the Further Information omits significant details concerning previous flooding events. There is ample evidence that erosion results from flooding along the route. The unbound surface proposed is not suitable for the Barrow towpath.