Consultation on Louth County Green Infrastructure Strategy An Taisce welcomes the preparation of a Green Infrastructure Strategy. It is noted that this consultation is running concurrent to the review of the County Development Plan (CDP). It is considered the CDP, notwithstanding the above strategy, should adopt a Green Infrastructure approach and include a section entitled Green Infrastructure modelled on the content of the Fingal County Development Plan 2010 – 2016 (Chapter 3). In any case, An Taisce would like to make the following comments which we request the Planning Authority (PA) take into consideration in the finalisation and adoption of the strategy, including the accompanying Strategic Environmental Assessment (SEA) and Article 6 Habitats Directive Assessment (HDA). Green Infrastructure The CDP should adopt a Green Infrastructure Strategy and include a section entitled Green Infrastructure modelled on the content of the Fingal County Development Plan 2010 – 2016 (Chapter 3). Achieving Smarter Travel The Green Infrastructure Strategy must include permeability and way-finding studies to identify a safe network of existing/future walking and cycling routes which must be used as a chief criteria in selecting all land zoned for new development connecting with key services and amenities such as schools, shops, parks etc Water The Green Infrastructure Strategy must include a suite of integrated policy measures to ensure that the PA’s legal obligations under the Water Framework Directive and the operable River Basin Management Plan are achieved. Surface Water The use of Sustainable Urban Drainage Systems (SUDS) and rainwater harvesting must be made mandatory for all new development proposals. The Green Infrastructure Strategy should seek to implement a Green Roofs policy through the development management process. It should be a mandatory requirement for all new developments to include an element of green roof technologies. Integrated Constructed Wetlands The PA should explore the use of Integrated Constructed Wetlands (ICW) as a low –cost and environmentally sustainable alternative to heavy engineered and energy intensive waste water treatment facilities. Natural Capital & Ecosystem Services In order to prevent potential legal action the Green Infrastructure Strategy must rigidly adhere to its substantial legal obligations under EU law. Achieving adherence to the PA’s legal obligations under the Habitats Directive and other environmental legislation cannot be achieved without the preparation in tandem with the Green Infrastructure Strategy of a full Strategic Environmental Assessment and Habitats Directive Assessment. The policy recommendations of the National Biodiversity Plan 2010 – 2015 should be fully incorporated into the Green Infrastructure Strategy and a Local Biodiversity Action Plan prepared. Allotments & Community Gardens The Green Infrastructure Strategy must designate suitable locations for allotments/community gardens and include a requirement that a designated area for allotment space be required in each new residential/mixed-use developments. Implementation & Monitoring Targets & Monitoring The Green Infrastructure Strategy must include a detailed implementation and monitoring schedule which outlines the manner in which the Green Infrastructure Strategy envisages the future development of the area. A designated implementation officer must be appointed to oversee the implementation of the Green Infrastructure Strategy and ensure joined up thinking between development management, forward planning, environment, service, infrastructure provision etc. Conclusion The key priority of the Green Infrastructure Strategy must be transition to a low-carbon society and economy and to mitigate the significant risks associated with rising energy costs and climate change adaptation. Business as usual is no longer an option, we can no longer afford to continue the pursuit of the failed short-sighted policy approaches of the past and that our collective future must be different. The international and national economic recession has provided a narrow window of opportunity to take action to concentrate investment and focus policy on the transition to a post-oil low-carbon locally resilient society. This is the major challenge of our time and will require urgent understanding of the nature of the challenges; no shortage of decisive political leadership, a radical change of direction together with robust and, in some instances, policy implementation which will be politically unpopular in the short-term. The statutory planning system, through the regulation of physical development and land use, has the most critical role to play in facilitating this transition. The success or otherwise of the forthcoming Green Infrastructure Strategy can only be judged against verifiable and implementable criteria which are subject to ongoing monitoring. We look forward to making further submissions to the Green Infrastructure Strategy in due course. Download the submission here.