Observation to An Bord Pleanala

OBSERVER:

(Your own name and, very important, your addresss. This must be the same name and address that the council sends the planning observation registered letters to)

TO:

The Secretary,

An Bord Pleanala,

64 Marlborough Street,

Dublin 1

SUBJECT MATTER OF THE OBSERVATION:

Waterways Ireland Proposed Barrow Blueway. The proposal comprises the development of a multi-use shared leisure route (Blueway), approximately 115km long on the existing navigation towpath, which is a National Waymarked Way. It includes tailored surface finishes, information, directional and safety signage and associated works.

LOCATION OF DEVELOPMENT:

The route commences in Lowtown in Co. Kildare, passes Co. Laois and finishes in St. Mullins Co. Carlow. Approximately 52km of the route is in Co. Carlow.

In Co. Carlow the route runs through the townlands of: Newacre, Newgarden, Bestfield or Dunganstown, Strawhall, Carlow, Graigue, Clogrenan, Killeeshal, Ballinabrannagh, Ballygowan, Part of Tomard Upper (ED Rathornan), Tomard Upper (ED Rathornan), Part of Tomard Lower (ED Clogrenan), Rathornan, Rathvinden, Ballyknockan (Idrone West By), Leighlinbridge, Rathellin, Dunleckney, Moneybeg, Kilree, Sliguff, Kilgraney (Idrone East By), Clonmoney (Idrone East By), Ballyellin and Tomdarragh, Ballyteigelea (Idrone East By), Borris, Ballynagrane, Cournellan, Ballykeenan (St. Mullin's Lower By), Harristown, Tinnahinch, Knockeen, Carriglead, Bahana, St. Mullins.

PLANNING AUTHORITY:

Carlow County Council

PLANNING AUTHORITY REGISTER REFERENCE NUMBER:

Planning Application Reference #1718

Dear Sir/Madam,

I wish to make an observation on the appeal by Waterways Ireland against the refusal of permission for their Barrow Blueway planning application and to write in support of the appeal by Save the Barrow Line challenging the narrowness of grounds for refusal.

With regards to the Waterways Ireland appeal, I wish to refute their claims regarding the nature of flooding events in County Carlow

[It would be useful to add in your own personal observation regarding the effects of flooding on the towpath especially where Waterways have already installed a hard surface (e.g. Storm Frank damage at the Devils eyebrow, general ponding of water on the hard surfaces). Waterways do not claim that flooding does not occur but they do claim that it is low velocity flooding and that it does not result in any erosion on the towpath]

I wish to object to Waterways Ireland introduction of an alternative tar and chip surface type when this surface type has not been part of any public consultation and is unsuitable for the area. The proposed new tar and chip surface is quite alien to the wild landscape of the SAC and is a further step in the urbanisation of our rural landscape, the very landscape, according to Bord Failte, that tourists come to see. Since it is much less permeable than a natural grass surface it is not clear what implications that would have for the delicate ecological make up of the SAC in terms of run-off during periods of flooding.

Additionally, with regard to Carlow County Council’s grounds for refusal, it would seem to me that there were many other grounds for refusing such an intrusive development in an EU designated Special Area of Conservation. The Barrow/Nore SAC is a wildlife and ecological corridor which supports a diversity of species along its linear habitats. It creates a connection between Natura and non Natura areas. An Taisce, in its submission on the original application, noted that the development would remove linear riparian habitat which would have a negative impact on the ecological corridor and its connectivity role.

It is not clear how or at what time of year the environmental assessments were carried out so it is difficult to rely on them. If local people were able to give the planning authority evidence of observing otter holts or breeding sites, why weren’t Waterways Ireland surveys able to find them? No dedicated kingfisher survey was carried out which is surprising to say the least.

Why do we need this project? Waterways Ireland’s own 2015-16 visitor numbers for the existing grassy towpath are close to twice the numbers being currently achieved at the Waterford Greenway and are up to four times higher than the numbers being achieved at other Blueway sites Waterways point to.

There are fears for the safety of this proposed track which runs beside a deep river. As it is cyclists, walkers and other canal users share the towpath and the grassy surface dictates a pace which accommodates all users. The proposed development will enable speed and create conflict between walkers and cyclists. This point is confirmed by the response by Mr Gerry Dornan, engineer with Kildare County Council, to the River Barrow Cycling Trail Feasibility and Technical Specification Report. Specifically Mr Dornan states that a 2.5m shared use trail will create conflict with pedestrians as a result of inadequate space for cycling. Indeed, as Waterways Ireland have already conceded, there are narrow parts of the towpath where even a 2.5m width is not achievable.

Why didn’t Carlow County Council take all these important issues into account when it made its decision to refuse permission? I think these issues should have been included in the grounds for refusal.

Yours sincerely

(Your signature)