Kerry Green Party Submission to the Draft Kerry County Development Plan

PROPOSAL: Add an objective: “Promote awareness of the value of restored peatlands in storing carbon and mitigating climate change and promote and support efforts to both prevent further degradation of peatlands and to restore already-degraded peatlands.” 

RATIONALE: Peatlands are the world’s largest natural terrestrial carbon store.  Until recently, they were perceived merely as a source of fuel for home-heating. This perception remains and there is a general lack of awareness of the value of wet peatlands in mitigating climate change. There are 9 Natural Heritage Areas in Kerry designated for petalands. It is critical to improve awareness so that the carbon storage value of Kerry’s peatlands can be fully harnessed in the fight against climate change. It is also critical that Kerry County Council is seen to be leading the way in supporting projects aimed at restoring the carbon storage value of peatlands. 

The plan only contains twenty-one instances of the word ‘peat’ and one instances to the word ‘bog’, and none of these instances relates to the promotion of the importance of undrained peatlands for biodiversity and carbon storage. 

There are arguably multiple places in the plan where the importance of protecting and enhancing peatlands should be included, including this chapter on climate change. This objective would highlight the importance of climate-action importance of peat lands. References to protecting and enhancing peatlands should also be included in other chapters (see below). 

PROPOSAL: Replace KCDP 6-9, “Promote the delivery of social infrastructure and high-quality services, at appropriate locations, through collaboration with the Kerry Public Participation Network (PPN)”, with “Promote the delivery of social infrastructure, high-quality services, and climate and biodiversity action projects through collaboration with the Kerry Public Participation Network (PPN).” 

RATIONALE: As stated in the PPN Handbook, “A Public Participation Network (PPN) is a structure that brings together Community and Voluntary, Environmental and Social Inclusion groups in each local authority area”. The KCDP 6-9 as it stands is not inclusive of the environmental aspect of PPN groups and should be altered to reflect the make-up and purpose of PPNs more accurately. 

PROPOSAL: Add an additional objective in section 6.2.2, Healthy Communities: “Promote the importance of clean air and water, and work to both monitor and reduce the level of air and water pollution in the county”. 

RATIONALE: Clean air and water are key aspects of a healthy environment, and a healthy environment is one of the prerequisites for a healthy community. As a common good, air and water quality needs to be addressed at government level. Local government has a key role in both monitoring air and water quality levels in the county, raising awareness of the current state of air and water pollution, and working to reduce air and water pollution. 

While there is reference in Chapter 11 to improving air quality, there is no reference there to monitoring air quality to ensure transparency and that measures taken are effective. Also, there should be a policy objective around air quality in the ‘Healthy Communities’ section of Chapter 6 in addition to the environment chapter. The fact that it is appropriate to include a policy objective in two chapters demonstrates its importance. 

PROPOSAL: In section 6.3, Community Infrastructure, Services and Facilities, add an additional objective: “Encourage and support the use of vacant, unused or infrequently used buildings by communities, e.g., closed schools, churches, GAA halls, while working transparently with all stakeholders involved.” 

RATIONALE: The Program for Government, Our Shared Future, sets out the Government’s plan to implement a Circular Economy Action Plan. A key aspect of the circular economy is to reuse and repurpose things that have served their original use to avoid waste of resources. In the context of the current housing crisis, and construction supply chain difficulties, it will be important to make optimal use of the county’s current building stock, which should include working with stakeholders to make available unused or infrequently used buildings for communities. 

PROPOSAL: Add an additional objective in section 6.3, Health Services: “Promote Sláintcare’s SH24 service to encourage non-symptomatic Kerry citizens, particularly young people, to avail of the service’s free sexual health tests.” 

RATIONALE: There is currently limited awareness in Kerry of the SH24 service, which provides a free self-administered testing service for sexually transmitted infections. As a predominantly rural county with very limited access to sexual health services, and considering the recently suspected large volume of undiagnosed Syphilis cases in Kerry (HSE concerned about undiagnosed syphilis cases in Kerry and Cork | RadioKerry.ie), this service should be advertised by the local authority to improve access to sexual healthcare in Kerry. This would be an effective way of improving community health without additional use of development resources in the county. 

PROPOSAL: Add an additional objective in section 6.3.4, Education and Lifelong Learning: “Promote and support the development of apprenticeships in the county as alternatives to third level education options and promote awareness of current apprenticeship options.” 

RATIONALE: The government document, Our Rural Future, published in 2021, supports significantly increasing the number of apprenticeships to both promote alternatives to third level education and address the skills gap in certain sectors, including the construction sector, as well as emerging sectors linked to climate change mitigation, such as clean energy and green tech. 

PROPOSAL: Add an additional objective in section 6.3.4, Education and Lifelong Learning: “Small schools should not be closed where they possess reasonable pupil numbers, and when there are clear justifiable savings in travel time and energy for the students. Kerry County council should encourage Kerry schools to participate in any available nationwide programmes aimed optimising resources in rural schools, such as the current Cluster pilot.” 

RATIONALE: Schools in rural areas are often a key binder of communities. When schools close in rural areas, it can lead to an evaporation of the community. In addition, car journeys carrying children to schools comprise a significant proportion of car journeys in Ireland and closing small schools may result in increased journey times for some. Such factors should be considered when determining the future of schools with low pupil numbers. 

PROPOSAL: Add an additional objective in section 6.3.5, Children and young people: “In order to advance the interests of young people living in Kerry, who often do not have a voice in planning and development decisions within the County, and in order to ensure that the development in the county will not result in younger generations having to bear the burden of unsustainable development, Kerry County Council will ensure that young people have a platform to participate in the development of the county, for example through a Kerry Youth Forum facilitated by the council or through enhanced outreach to young people in consultations on significant development projects in the county.” 

RATIONALE: It is not acceptable that the KCDP plan does not contain any measures to take the voices of young people in the county into account in development decision generally. Under section 6.3.5, Children and Young People, there is only one objective, namely, to “work with the relevant agencies and authorities to advance the physical, social, and cultural needs of children and young people”.  The physical, social, and cultural needs of children and young people cannot be fully met by only working with ‘relevant agencies and authorities’ and not working with young people directly. In the time of the climate and biodiversity emergencies, it is critical that young people’s voices are hard, as it is young people and future generations that are most vulnerable to the effects of climate change. Kerry County Council should do its utmost to ensure that young people do not have to shoulder the burdens of decisions made by older generations without regard for the climate and biodiversity emergencies. 

As stated above, in Volume One, the words ‘young’ and ‘youth’ are mentioned only 20 times between them, on 11 pages, mostly in passing. Of the significant references: 

• There is one reference to the provisioning of services to young people and children. 

• There is one reference to working with relevant agencies and authorities to advance the physical, social, and cultural needs of children and young people. 

The above references to young people are not sufficient. The decisions that are made on the back of this development plan will affect younger generations far more than older generations, and young people should be given a more deserving place in the development plan than they have been given so far. 

Most ironically, while the KCDP quotes the fact that Our Rural Future has a policy to ‘Actively involve young people in rural areas in decisions that affect them and their future,’ there is nowhere in the KCDP that refers to this. Nowhere in the KCDP are young people’s voice considered. The KCDP as it stands does not reflect the Our Rural Future document in this respect, though it claims to do so. If the above goal is not added, and if objectives are not added to take young people’s voices into account, then the reference to Our Rural Future should be removed, as the KCDP would not in such a case be in line with Our Rural Future. 

PROPOSAL: Add an objective, “Breaches of legislation to protect Kerry’s environment will be prosecuted by KCC or a report will be sent to the relevant body for prosecution, which will be supported by KCC. Cases of malpractice by contractors must be prosecuted”. 

RATIONALE: Enforcement of environmental law is a vital issue which must not be overlooked. The destruction of Kerry’s natural environment should not be taken lightly, and anyone breaking environmental laws should be held to account to demonstrate that it is not acceptable to bypass environmental law and harm the environment. 

PROPOSAL: Add an objective, “The public is encouraged to submit observations of illegal habitat destruction or malpractice which impedes on the integrity of the county’s biodiversity”. 

RATIONALE: Due to the dispersed populations living in rural areas in Kerry, it can be difficult for the Gardaí to become aware of breaches of environmental law. The Gardaí should be supported to carry out their duties by the wider public as much as possible. One obvious way to do this would be to encourage the public to submit observations of illegal habitat destruction. This would also allow the people of Kerry to become more active in the protection of Kerry’s biodiversity. 

PROPOSAL: Add an objective, “Empower local communities to tackle climate action. Work with Transition Kerry to build on the work done to-date in building a network of sustainable communities.” 

RATIONALE: The Transition Kerry network of individuals and groups has the potential to share knowledge and resources and empower each other. They can tackle many of the UN Sustainable Development Goals at a local level in a way that is relevant for their community. The network should be supported by the local authority for the sustainability services they provide to Kerry and to enhance those same services. 

PROPOSAL:  In section 11.2.3, Wetlands Support, add an objective, “Protect and enhance wetlands as nature-based solutions to flood management, climate change, and the biodiversity crisis.” 

RATIONALE: Wetlands can provide benefits with regard to water shortage, flood management, water treatment, enhancing biodiversity and carbon storage. The ecosystem services provided by wetlands should be valued and capitalized on. Land use and management systems that take no account of the importance of maintaining and protecting wetlands, and thus inevitably lead to the degradation of wetlands, should be discouraged. 

PROPOSAL: In section 11.2.4, Invasive Species, add two objectives:  

• “Raise awareness of the rhododendron crisis and actively support any groups endeavouring to eradicate invasive species in the Killarney National Park (particularly Rhododendron), such as Groundwork.” 

• “Develop an invasive species policy for Kerry, to include a public and contractor awareness campaign, as well as public species recording and guidance on what to do when invasive species are discovered.” 

RATIONALE: There is no reference to rhododendron in the KCDP, which is a surprising omission considering that rhododendron is one of the major challenges facing one of Kerry’s key environment and tourism locations, Killarney National Park. The policy refers to ‘managing’ invasive species, but this is not a strong enough position considering the drastic state of the rhododendron situation in Killarney. The first policy objective proposed would acknowledge the crisis and show that the Kerry local authority is treating it seriously and supporting the efforts of local volunteers that invest significant time and energy into tackling the problem. The second objective proposed would address the fact that the eradication of invasive species requires long term and coordinated strategic policies and planning and cannot be fully addressed by piecemeal measures. 

PROPOSAL: In section11.2.6, add an objective: “Identify biodiversity hotspots in proximity to each other which could benefit from creation of ecological corridors and actively seek to create these corridors.” 

RATIONALE: Development that is undertaken without regard for biodiversity often has a negative impact on biodiversity through the fragmentation of ecosystems. This fragmentation can be addressed by the creation of ecological corridors that allow animals to move between biodiverse areas and maintain their ecosystems. This proposal would be an efficient and affordable way of enhancing the biodiversity in Kerry. 

PROPOSAL: In section 11.2.8, Woodlands and Trees, add the following three objectives:  

• Create native woodlands which are accessible to all by supporting communities and working with stakeholders. 

• All schools in the county must be made within walking distance of a native woodland amenity. To this end, the council will support initiatives aimed at creating these woodlands (suitable sites can be identified through mapping exercises). 

• Survey all council lands, and where suitable for planting, native species are to be planted to create woodland amenities. 

RATIONALE: A paltry percent of land in Ireland is native woodland. Native woodland is culturally and aesthetically important, and is critical for biodiversity. Native woodland also has carbon storage benefits, and is a source of enjoyment for many, allowing for walking in engaging with nature. Native woodlands can also be a source of wonder and education for children. Native woodlands should be made accessible to all to allow everyone the opportunity to benefit from the benefits of native woodlands, and the council should have a role in ensuring this is the case in Kerry. 

PROPOSAL: In section 11.2.8, Woodlands and Trees, add an objective, “Penalise destruction of native woodlands and trees Under Wildlife Act 1976 to 2018 and Forestry Act 2014.” 

RATIONALE: As stated above, native woodland is culturally and aesthetically important, and is critical for biodiversity. Native woodland also has carbon storage benefits. Illegal destruction of native woodlands and trees should not be countenanced and should be penalized with the full rigour of the law. Historical lack of enforcement of the Wildlife Act means that it is necessary to include an explicit objective around this. 

PROPOSAL: In section 11.3, add an objective, “Ensure KCC’s procurement policy for new equipment meets best practice on air and noise pollution. 

RATIONALE: The health and environmental consequences of air and noise pollution are well-documented, and any new equipment should not cause unnecessary air and noise pollution. A policy is required to ensure this is the case going forward.  

Chapter 12: Energy | Kerry County Council (kerrycoco.ie) 

PROPOSAL: In section 12.2, Gas Network, add the following objective: “Not support any gas infrastructure that is in any way tied to fracking, such as Shannon LNG.” 

RATIONALE: It is current government policy that LNG infrastructure should not be progressed until an energy review has taken place. This proposal aligns the KCDP with government policy. If this policy is not included in the plan, it would be difficult to argue that the plan is in line with government policy. 

Note this and the below sections relate to the Killarney Town Development Plan.

PROPOSAL: Add an objective, “Ensure that the biodiversity and the temperate rainforest ecosystem of Killarney National Park, as a UNESCO Biosphere Reserve and as part of both a Special Area of Conservation and a Special Protected Area, are conserved and enhanced.” 

RATIONALE: Killarney Nation Park is one of the last remaining temperate rainforests in Europe, and its significance and value is clear from its designation as a UNESCO Biosphere Reserve, as well as being part of both a Special Area of Conservation and a Special Protected Area. It is also a key attraction for tourists to Killarney. In recent years, rapidly expanding rhododendron infestations and a devastating fire have significantly degraded the value of certain areas of the park, and it is critical that work is done to undo this damage and to prevent such damage occurring in the future. While KA 4 refers to the National Park and conservation objectives, this statement is not nearly strong enough if one considers the importance of the National Park both for Killarney. There should be an explicit objective in Killarney plan to conserve and enhance the biodiversity and temperate rainforest ecosystem of the park, in addition to any objectives in volume one. 

PROPOSAL: Add an objective, “Provide outdoor covered seating facilities in the town centre (for example, in the ‘car park’ area between High Street, New Market Lane, Bohereencael Glebe, and Old Market Lane Square – see the proposal below in the Opportunity Sites section) similar to what has been set up at Prince Street in Cork City, not only for the purpose of outdoor dining but also to provide a place for residents and visitors to sit outside in shelter to socialize, all the while enhancing the atmosphere of the town.” 

RATIONALE: There is a dearth of outdoor seating facilities in the town centre, and such facilities would likely enhance the atmosphere of the town, which is a key aspect of urban regeneration. In particular, this proposal would align with objective five of the Killarney Town Strategic Objectives: “Ensure that the town is attractive, liveable, vibrant, and a well-designed urban place…” While the proposal gives the area near the Glebe as an example, this area could of course be used for other purposes, but in such a case another suitable area should be endeavoured to be found. 

PROPOSAL: Add an objective, “On lands owned by the council, grass should be cut infrequently to increase biodiversity and to show leadership in taking steps, however small, in tackling the biodiversity crisis”. 

RATIONALE: The government declared a biodiversity emergency in 2019, and it would be entirely appropriate for the local authority to show leadership in Killarney by taking steps to enhance biodiversity. While KA29 refers to working with stakeholders regarding grassland management, it is important to include an explicit policy point regarding the council own actions regarding council-owned land. 

PROPOSAL: Add an objective, “Facilitate the revitalization of the Outlet Centre, and additional use of the upstairs space.” 

RATIONALE: The Outlet Centre is currently underutilized, despite it being one of the largest open-space buildings in Killarney open to the public. Options should be explored to enhance its usage. 

PROPOSAL: Add an objective, “Encourage and support food-sellers to reduce food waste by utilizing apps such as ‘Too Good to Go’ or by coordinating between food-sellers and charities, and to reduce packaging waste through offering food refill options (such as in Beech Road’s ‘Going Green’ shop).” 

RATIONALE: Food waste is contributor to climate change, due the greenhouse gases that are unnecessarily emitted when producing the wasted foods. There are now simple yet highly effective technologies available, such as the app ‘Too Good to Go,’ that could be used by Killarney food sellers to reduce waste significantly, all the while offering fresh food to residents at reduced prices. The local authority should show leadership in working with the Chamber of Commerce and business to raise awareness around the problem of food wasted and guide business in how to work together to solve the issue. 

PROPOSAL: Add an objective, “Facilitate and support local food markets and offerings such as the NeighbourFood Killarney Market and the Killarney Fruit and Veg Market in Fairhill car park.” 

RATIONALE: There is a growing demand for locally produced food, not least for the high-quality of such foods. Many people have a desire to support local farmers and businesses rather than very large multinational that thrive on offering convenience to consumers. Local food producers often cannot compete with such large multinationals, and often require support to both market and sell their foods. The local authority should work with the chamber of commerce and food producer to support local food producers and offer them a space to market and sell their goods directly through the public. This would also be a way of supporting local farmers who are in a position to sell their produce direct to market. A thriving town market would also greatly enhance the atmosphere of the town. 

PROPOSAL: Add an objective, “Provision increased numbers of bike racks throughout the town to encourage active travel.” 

RATIONALE: There are insufficient bike racks at present, which likely discourages many residents and visitors from cycling in town to do shopping etc. Increased active travel is key for meeting the second goal of the KCDP, transitioning to a low-carbon society. 

PROPOSAL: Add an objective, “Implement higher parking fees for SUVs due to the additional space they take up and the additional air pollution attributable to them.” 

RATIONALE: Killarney has a compact town centre with narrow streets. SUVs take up significant space, and generally emit more fumes that non-SUVs, so their use in the town centre should be discouraged to ensure Killarney remains a healthy and living town. 

PROPOSAL: Add an objective, “Not to undertake the building of new roads to alleviate traffic due to the risk that new roads will increase instead of decrease private vehicle traffic volume overall due to a more attractive road infrastructure. Improved active travel infrastructure should be provided instead.” 

RATIONALE: It is known that in many cases the creation of new roads does not alleviate traffic but actually increases traffic congestion due to the additional new road infrastructure being more attractive to drive. Additional roads also take up significant space, and this method of attempting to reduce congestion is not sustainable in the long run. 

PROPOSAL: Add an objective, “Cycling infrastructure should be sufficiently protected and designs should accord with the latest cycling infrastructure design standards.” 

RATIONALE: It is not sufficient to simply create more bike lanes etc. when developing cycling infrastructure. There is significant difference in quality between a well-designed and a poorly designed cycling plan, and it is key that cycling is made as safe and attractive as possible to ensure the benefits from active travel accrue to Killarney and its residents. 

PROPOSAL: Add an objective: “Develop protected cycling infrastructure within a least a kilometre of all schools within the Killarney region to encourage active travel school journeys.” 

RATIONALE: MaREI centre research (Microsoft Word - How and Why We Travel – Mobility Demand and Emissions from Passenger Transport - MaREI Template.docx) has shown that companion/escort journeys (such as dropping off children to school) have the highest emissions intensity by journey purpose, and comprise over one tenth of all journeys in Ireland.. Providing safe and accessible opportunities for children to cycling to school should decrease the volume of such journeys, increasing air quality, reducing congestion and dangerous driving at school locations, and encourage a healthier lifestyle for children. 

PROPOSAL: Modify Residential Development Objective TR 12 to specifically reference the need to provide permeability and connectivity in all housing developments. Suggested wording: “Facilitate the development of 2,087 residential units within the town boundary ensuring permeability between developments and connectivity to the urban core by active means” 

RATIONALE: Recent social housing developments have been insufficiently connected to the town centre by any means other than private vehicle. The new development in Lohercannon is an example which we reference where no additional measures to enable active travel were a condition of the development proceeding. 

PROPOSAL: In section 1.4.1 Town Centre and Public Realm Strategy, the following statement would enhance the ability of the town to regain vibrancy. Following paragraph 6 when ends “…surrounding coastal landscape.” insert the following paragraph: “The vibrancy of the town centre can be enhanced further by diverting through motor traffic away from the urban core. The use of the eastern bypass road, new northern relief road and internal link roads will be used to manage through traffic away from the town centre. Such measures would not impact accessibility in the urban core for emergency vehicles, disabled persons or those choosing active modes.” 

RATIONALE: Specific measures to prevent through traffic accessing the town should be employed. Significant investment has been made in bypass and relief roads but the benefit to the town centre is not fully realised. For example, southbound traffic continues to utilise Castle Street & Denny Street instead of diverting to the eastern bypass road. By diverting this traffic, the number of vehicles in the town centre would decrease thereby enhancing the experience for people utilising the space.