Sustainable Skerries welcomes the vision but has deep concerns at lack of staffing and funding for the draft Fingal Biodiversity Plan

With a Climate and Biodiversity Emergency declared in the Dáil in 2019, we need to do better than implementing only a fraction of actions deemed necessary by the draft Fingal Biodiversity Action Plan. This is the main observation made by Sustainable Skerries in their submission. Have you made yours? You have until tomorrow night, as it closes on 5 July 2022, 23:59 h.

Here is ours:

Sustainable Skerries commends Fingal County Council on the vision of, and the many targeted initiatives in, this plan. However, we are deeply concerned that of the 100 actions required to halt the loss of biodiversity in Fingal by 2030, only 30 are prioritised for implementation, due to the financial and staff constraints. Several actions seem to need relatively little extra funding, so it seems that human resources are the bottleneck. Extra staff for the biodiversity team should thus be a priority. Many additional actions might make it to the “prioritised for implementation” list if there were two, or maybe even just one, extra staff in the Fingal County Council Biodiversity Team.

It is understandable that the council faces difficult decisions with regard to funding initiatives in the county, but for something as important as this more efforts must be made to obtain the necessary budget. We would like to see Fingal County Council work with the government to get further, ring fenced, funding to meet our obligations to cope with the biodiversity emergency. For instance, Minister Malcolm Noonan recently launched the “Strategic Action Plan for the Renewal of the National Parks and Wildlife Service”. With the increased resourcing and staffing this plan provides for, there is an opportunity for Fingal County Council to work with the NPWS to implement more than the 30 prioritised actions.   

The current draft of the Biodiversity Action Plan seems to solely focus on actions that can be achieved with direct Council funding,  and does not identify how Fingal Coco might seek to bridge the gap by promoting existing centrally-funded schemes, targeting EU funding,  or maximising biodiversity benefits from privately funded initiatives. 

 It is noted that Action 72 (Explore funding models for carbon offsetting to fund wetland and

woodland development) could be a key and rapidly developing opportunity in this context,  which is why we feel it should be a priority action.  

There are obvious possible synergies with efforts being made outside Fingal in central and local government particularly with respect to the preparation of the numerous guidance documents, procedures and training requirements identified. 

Actions 33-38, especially those which involve producing guidance documents for biodiversity-friendly building and infrastructure projects, are relevant to all local authorities nationally, not just Fingal County Council. One example is Action 38:” Pilot a biodiversity inclusive design for a social housing estate with green roofs, green walls, wetland & pond SUDS, green carparking, nest boxes in facades, wildflower meadows and wildlife friendly shrubs and trees in open space.” 

A priority action to be added to the plan should be to identify partners (including other local authorities and national organisations) and together find new funding streams, thus maximising the potential for efficient use of public money by coordinating with other public bodies to deliver those actions not just in Fingal but nationwide. We note that they are not prioritised in the current draft and suggest that with additional staffing, and by cooperating with other bodies, they could still be achieved.

While we welcome the actions that are being prioritised, some of the actions which appear to have been de-scoped do not require significant funding to make progress in, rather a political will and staff resources for coordination.

Rewilding: There is no overarching objective relating to rewilding of small and marginal areas of public lands – areas that could be essential stepping stones in Fingals ecological network,, a potentially cost free exercise (apart from staffing implications for coordination) that could be begun simply by taking less actions and spending less money

Fingal County Council’s own webinar introducing the plan highlighted the importance of protecting the network which connects Nature Development areas with Special Areas of Conservation. Sustainable Skerries agrees that corridors linking these areas must be protected.  Providing corridors through which wildlife can move about is a priority. One simple, achievable action would be the revision of mowing regimes. Leave some areas completely unmown for the summer, leaving them to become natural wildflower meadows, while reducing mowing frequency on areas that still need to be cut, allowing pollinators a window of opportunity to harvest flowering plants. By extending the mowing interval by even a week, preferably longer, money is saved, staff can be redeployed to other activities, CO2 emissions reduced, fossil fuel usage reduced and nature benefits. A truly win/win situation. Allowing native wildflowers to flourish, which provide essential food for pollinators, will in turn maintain a biodiverse environment for other wildlife.

Coupled with this, there is an opportunity for the plans in Action 6, currently envisaged only for golf clubs, to be extended to other sports clubs as well. Plenty of local clubs (cricket, rugby, GAA, soccer etc) have significant green areas not used for playing on, as well as green areas around the playing fields.

The continued use of herbicide by the council in graveyards is a cause for concern. While this must undoubtedly be handled sensitively there are more appropriate ways to maintain these areas. Fingal County Council must ban the use of herbicides in all contexts across the whole county and work with grieving relatives to address their concerns in the context of the biodiversity emergency we are facing.

Action 40 (Support and promote All Ireland Pollinator Plan Actions for Councils and monitor resulting changes) has as an objective that Fingal County Council increase to only 20% the land in the council’s control to be given over to biodiversity improvement. This is too low, and there is a huge opportunity here for an inexpensive win for Fingal. This seems to cost little or no money, and if managed properly actually saves money for use in other areas of the plan.

Sustainable Skerries is disappointed that Action 18 (Incorporate measures for

biodiversity conservation in the management plans for a Regional Parks in Finga)l has not been prioritised. Such management plans give Fingal County Council an opportunity to set an example in best practice for biodiversity management. If Fingal County Council does not even draw up biodiversity management plans for its own regional parks, how can it expect other organisations to take biodiversity seriously? If funding is an issue please see our point on engaging with the government and NPWS above.

Actions 37 & 38, which cover social and council housing and associated parks and infrastructure, must be prioritised. Again, there are aspects of these actions that are low cost if some imagination is applied. If staffing resources were made available and some ways were found to involve residents directly the plans would be far more successful.

In the cases of privately owned property, altering planning restrictions to make it easier for people to make changes to their own properties in order to build for biodiversity would be welcomed. Furthermore Fingal County Council must be making sure that all of the items mentioned in these actions form part of any new building schemes in the county, as part of the planning process. Where planning of a new estate is with An Bord Pleanála, Fingal County Council must make submissions highlighting these needs.

Actions related to agriculture including overall targeted awareness raising in Fingal are underrepresented in the draft plan. Fingal County Council must do more to engage with farmers, many of whom are well aware of the biodiversity emergency we are witnessing. Fingal County Council itself could support farmers making changes by adopting an “Organic First” policy when purchasing food (for catering etc.). This should be an additional (and implemented) action.

Agroforestry, combining forestry and agriculture, is very promising for biodiversity and climate change mitigation and adaptation. Action 48 (Acquire sites for woodland planting at St Catherine’s park and Ardgillan Demesne and prepare masterplans for the design of these woodlands) should be extended to include a “model farm” scheme.It could be combined with Action 61 (Develop a 400ha demonstration Agri-Environment EIP Scheme with local farmers in Fingal targeting farmland birds and habitats and water quality improvement measures).  A demonstration of regenerative agroforestry would enable farmers to see for themselves how regenerative agriculture can sequester carbon. The biodiversity crisis, after all, cannot be separated from climate change.

We were pleased to see the inclusion of a proposed education centre in Turvey Nature Park and nature education programme for primary and secondary schools. In order for the objectives of this plan to be met and sustained we believe education will play an essential role, otherwise these actions will be misunderstood or poorly prioritised across communities in Fingal in the future. In order to create, design and deliver such nature-based learning for schools, significant resources should be allocated to ensuring that this becomes embedded in curricula across schools in Fingal as soon as possible. Such education programmes should ideally go hand-in-hand with school’s management of their grounds to increase biodiversity and attract wildlife which in turn will create an ideal “classroom” / field site for such education programmes. The creation of education officer roles who liaise with schools directly in coordinating and delivering such programmes is vital to the longevity of this plan. The creation of an education centre in Turvey Nature Park would further embed such learning and act as an ideal site for school field trips / school tours to allow children and adults alike to immerse themselves in wild native Irish landscape and learn hands-on about what they can do in their communities.

Many of the Target KPI’s identified relate to preparation of guidance documents or production of reports.  Given the life-cycle of the Plan, the KPI’s should be extended to include the demonstrable implementation of the guidance measures or report recommendations.   Acknowledging some measures may require additional funding, it is suggested the KPI could commit Fingal to the swift implementation of no/low-cost measures/recommendations,  or the identification of funding routes for more costly or longer-term measures.

In summary, while we have some suggestions for changes, overall, we welcome this plan – and are shocked that only so few of its suggested actions are currently due to be implemented during its lifetime, due to staffing and financial constraints. With a Climate and Biodiversity Emergency declared in the Dáil in 2019, we need to do better than implementing only a fraction of actions deemed necessary.

From the draft Fingal Biodiversity Action Plan, title: Fingal Ecological Network by Jeroen Helmer, Ark Natuurontwikkeling. Wouldn’t it be great if Fingal was looking like that…?