Re. Submission on the Draft Cork City Tree Strategy.

A Chara,

I welcome the publishing of the Draft Cork City Tree Strategy (hereafter the Draft Strategy) and the opportunity to make a submission/observation on the Proposed Draft Plan.

Your report identifies the importance of trees and hedgerows to both humans, providing a sense of wellbeing, landscape, carbon sequestration and water storage, and for biodiversity providing wildlife corridors and places for shelter and food. I live in Tower and over the last few years I have witnessed removal of several tree stands and hedgerows. The Draft City Tree Plant mentions that Tower had an overall canopy cover of 19% in 2021 and that there are significant concentrations of trees along the banks of the Shournagh River. The village is also home to historic woodlands visible in 1830’s Ordnance Survey maps, including lands adjacent to the former site of the historic St. Ann’s Hydro. Historic woodland groupings are also located on lands near the national school and the existing treeline along the former Muskerry tram line. The Cork City Development Plan lists Tower as one of four Urban Towns. Figure 2.9 Canopy Losses and Gains by Area, 2018-2021, in the Draft Strategy, shows a net loss of tree canopy in the urban areas. I suspect that this is due to development in the area, but we have not witnessed any additional planting in these Urban Towns.

The Tree Strategy states that it will be prepared with a short-term horizon--through 2028—to align with the 2022-2028 City Development Plan. May I suggest that this timeframe is too short, and I would like to see Cork City Council preparing a tree/hedgerow Masterplan for the City that is aligned to the land zonings in the Development Plan. The Masterplan can cover an extended time period, say 50 years, and this I believe will clearly set out Cork City Council objectives to meeting our National Biodiversity Action Plan. A Masterplan would also align itself to other European and National Plans and Programmes such as the EU Green Deal, the National Carbon Action Plan, the Water Framework Directive and the 2023 Wildlife Act. A Tree Strategy Masterplan may also be subject to a Strategic Environmental Assessment. I believe that compliance with a Tree Masterplan would provide Developers with guidance on how to incorporate trees/hedgerows/biodiversity into their developments.

The Cork City Development Plan 2022-2028 has several objectives for tree retention and land development, including:

• A presumption against development for some woodlands and significant groups of trees with the zoning objective ‘Landscape Preservation Zone (ZO 17)’.

• An objective to support the retention of existing trees and the planting of new trees as part of new developments (Objective 6.5d) and,

• An objective to discourage development proposals necessitating the removal of extensive amounts of trees or hedgerows (Objective 6.9). The Development Plan further establishes that mature trees and hedgerows shall be identified at the initial stages of the planning process and used to guide site layout and design (Para. 11.212) and that all development proposals are expected to avoid adverse impacts on mature trees (Para 11.224).

Nowhere in the City Development Plan or the Tree Strategy has Biodiversity Net Gain (BNG) been mentioned. The UK has introduced BNG with regards to developments and I feel that this should form part of the Tree Strategy and should be conditioned in grants of planning for residential, commercial and industrial developments. The National Parks and Wildlife’s Report on Biodiversity in Ireland has demonstrated that we are losing habitats and species at a high rate. The Wildlife (Amendment) Act 2023 (the 2023 Act), commenced on 17 November 2023. It requires certain public bodies, including government departments, agencies and local authorities to consider biodiversity in their plans, policies, decisions and actions. I accept that this Tree Strategy is a first step to assisting trees and biodiversity in the City and Urban Towns. Recently a National Biodiversity Action Plan was published by the Minister. Cork City Council in performing their functions, must consider the published National Biodiversity Action Plan and Strategy. This document does not appear to have been referenced in the Draft Tree Strategy and I feel that the final issue of the Tree Strategy should reference the requirements and duties of the Council with regards to the Tree Strategy and our National Biodiversity Plan. Cork City Council as the competent authority for development in the City and Urban Towns has a duty of care to protect trees/hedgerows and ecology and by default compliance with the 2023 Wildlife (Amendment) Act.

Section 4.7 of the Draft Strategy sets out the Tree Risk Management strategy for the council. How will this be managed? Does the council have a template for tree assessments and the various options for maintenance or removal of trees? There would be benefit in displaying this assessment procedure in the final Tree Strategy as it would provide transparency to locals, interested stakeholders as to why certain trees were removed. Section 4.8 of the Draft Strategy lists as an internal objective ‘Public trees will only be removed as a last resort option after all alternative solutions have been explored; removal will only be considered when a tree is a safety hazard, is diseased, is poorly established, is causing structural damage that cannot be resolved through reasonable alternative solutions, or whose loss in unavoidable to facilitate significant development and whose value is assessed as having lower overall value than the works themselves’. Again, for completeness and transparency, would it be possible for interested stakeholders to have view of the reports/recommendations in advance of removal of any trees.

Finally, who is going to carry out this work? I understand that resources are stretched in all Local Authorities and I feel that the practicalities of doing this work and ensuring compliance with the Tree Strategy and the various National legislation will be a difficult task. I would suggest that for the public to have faith in the Tree Strategy, details on personnel numbers and roles should be included in the final report.

Public Consultation on the Draft Tree Strategy - Submissions

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