Development plan · Mayo County Council
Mayo County Development Plan 2022–2028
The council's development plan written statement: its strategy, policies, objectives and development standards.
Mayo County Council · 2022–2028 · 165 pages
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- VOLUME 1 Written Statement M AYO C O U N T Y D E V E LO P M E N T PLAN 2022 - 2028
- Contents CHAPTER 1 INTRODUCTION CHAPTER 2 CORE AND SETTLEMENT STRATEGY CHAPTER 3 HOUSING CHAPTER 4 ECONOMIC DEVELOPMENT CHAPTER 5 TOURISM AND RECREATION CHAPTER 6 MOVEMENT AND TRANSPORT CHAPTER 7 INFRASTRUCTURE CHAPTER 8 SUSTAINABLE COMMUNITIES CHAPTER 9 BUILT ENVIRONMENT CHAPTER 10 NATURAL ENVIRONMENT CHAPTER 11 CLIMATE ACTION AND RENEWABLE ENERGY CHAPTER 12 SETTLEMENT PLANS Ballinrobe (Tier II) Ballyhaunis (Tier II) Béal an Mhuirthead (Tier II) Claremorris (Tier II) Swinford (Tier II) Balla (Tier III) Charlestown (Tier III) Crossmolina (Tier III) Foxford (Tier III) Killala (Tier III) Kiltimagh (Tier III) Knock (Tier III) Louisburgh (Tier III) Newport (Tier III) Settlement Plans for Tier IV Rural Settlements and Tier V Rural Villages i 1 19 43 61 81 105 127 147 161 175 197 217 228 236 242 247 254 261 264 267 271 274 278 282 286 289 293
- ii iii Figures, Tables & Maps Figures Figure 1.1 National Strategic Outcomes of NPF Figure 1.2 Five Growth Objectives of RSES Figure 1.3 Context of Plan Nationally, Regionally and Locally Figure 1.4 United Nations Sustainable Development Goals Figure 1.5 Irish Hierarchy of Plans and EU and National Legislation and Policy Figure 2.1 Forecast Household Size Cohort in County Mayo Figure 2.2 Synergy between Rural and Urban through Settlement Hierarchy Figure 3.1 HNDA Assessment Areas Figure 3.2 Housing Tenure Targets for Households in County Mayo During Plan Period Figure 5.1 Key Elements of Wild Mayo – Destination Mayo Tourism Strategy Figure 5.2 Quality Tourist Destination Factors Figure 7.1 Circular Economy Process Figure 7.2 Source Pathway Receptor Model Figure 10.1 Landscape Sensitivity Matrix Figure 11.1 Climate Action: Nature Based Solutions Figure 12.1 Thriving Towns and Villages Matrix Tables Table 1.1 Implementation of Section 28 Ministerial Guidelines Table 1.2 Implementation and Monitoring Table Table 2.1 Transitional Population Projections for County Mayo Table 2.2 Population Targets for County Mayo Table 2.3 Targeted Population Ration to 2027 Table 2.4 Core Strategy Table Table 2.5 Retail Hierarchy Table 2.5 Settlement Hierarchy Table 3.1 Overview of Social and Affordable Housing Needs Requirements Table 3.2 Overview of Social Housing Requests by Municipal District Table 3.3 Progress on Rebuilding Ireland Social Housing Targets 2019 Table 3.4 Housing Tenure Targets for Households in County Mayo During Plan Period Table 5.1 Priority Infrastructure Table 5.2 Key Tourism Pillars Table 6.1 Daytime/Night-time Populations in Tier I and Tier II Settlements Table 6.2 Modes of Travel in Tier I Towns Table 6.3 Modes of travel in Tier II Towns and Nationally Table 6.4 List of walking and Cycling projects in County mayo Table 6.5 Proposed Road Projects in County Mayo Table 6.6 National and Regional Road Classifications in County Mayo Table 6.7 Marine Related Projects in County Mayo Table 7.1 Water Services Priority Projects Table 10.1 Development Impact – Landscape Sensitivity Matrix Table 11.1 Climate Action Mitigation/Adaptation Table Table 12.1 Settlement Hierarchy Table 12.2 Land Use Zoning Objectives for Tier II Towns Table 12.3 Land Use Zoning Matrix for Tier II Towns Maps Map 1.1 Mayo County Council Municipal Districts Map 2.1 Strategic Road Network in Mayo Map 2.2 Strategic Economic Drivers for County Mayo Map 2.3 Settlement Hierarchy Map Map 3.1 Rural Area Under String Urban Influence & Scenic Routes and Views Map 5.1 Existing Trails in County Mayo Map 5.2 Spiritual Trail and Timber Trail in County Mayo Map 6.1 Proposed County Greenway Plan – Linear long distance and Town Greenway Network Map 7.1 Broadband Connection Points in County Mayo Map 10.1 Landscape Protection Policy Areas Map 10.2 Scenic Routes and Scenic Routes with Designated Views Map 10.3 Blue Dot High Status Water Catchments in County Mayo iiiiiii iii
- iv Map 12.1 Opportunity Site A Ballinrobe Map 12.2 Opportunity Site B Ballinrobe Map 12.3 Opportunity Site C Ballinrobe Map 12.4 Opportunity Site D Ballinrobe Map 12.5 Opportunity Site E Ballinrobe Map 12.6 Opportunity Site F Ballinrobe Map 12.7 Opportunity Site A Ballyhaunis Map 12.8 Opportunity Site B Ballyhaunis Map 12.9 Opportunity Site C Ballyhaunis Map 12.10 Opportunity Site D Ballyhaunis Map 12.11 Opportunity Site A Béal an Mhuirthead Map 12.12 Opportunity Site B Béal an Mhuirthead Map 12.13 Opportunity Site C Béal an Mhuirthead Map 12.14 Opportunity Site A Claremorris Map 12.15 Opportunity Site B Claremorris Map 12.16 Opportunity Site C Claremorris Map 12.17 Opportunity Site D Claremorris Map 12.18 Opportunity Site E Claremorris Map 12.19 Opportunity Site F Claremorris Map 12.20 Opportunity Site A Swinford Map 12.21 Opportunity Site B Swinford Map 12.22 Opportunity Site C Claremorris Map 12.23 Opportunity Site D Swinford Map 12.24 Opportunity Site E Swinford Map 12.25 Opportunity Site F Swinford Map 12.26 Opportunity Site G Swinford Glossary of Terms Active Travel Travelling with a purpose using your own energy (walking & cycling). Appropriate Assessment (AA) Is a focused and detailed impact assessment of the implications of the plan or project, alone and in combination with other plans and projects, on the integrity of a Natura 2000 site in view of its conservation objectives. Architectural Conservation Area (ACA) A place, area, group of structures or townscape, taking account of building lines and heights, which is of special architectural, historical, archaeological, artistic, cultural, scientific, social or technical interest, or contributes to the appreciation of protected structures and whose character it is an objective of a development plan to preserve. Backland development Development which takes place to the rear of existing structures fronting a street or roadway. Biodiversity The variability among living organisms on the earth, including the variability within and between species and within and between ecosystems. Brownfield Site A site which has been subjected to building, engineering or other operations, including but not limited to residential, commercial, industrial buildings/land no longer in use and has become abandoned/obsolete/ vacant. Climate Change Changes in the earth’s weather, including changes in temperature, wind patterns and rainfall, especially the increase in the temperature of the earth’s atmosphere that is caused by the increase of particular gases, especially carbon dioxide. Carbon sequestration Process of transferring carbon from the atmosphere to the terrestrial biosphere (soil or vegetation). Community Facilities Facilities that are open to and provided for the benefit of the public. Compact Growth Development occurring within the existing footprint’ of built-up areas cities, towns and villages. Comparison Goods Goods that are required on an infrequent basis by individuals and households such as clothing and footwear, furniture and furnishings and household equipment (excluding non-durable household goods), medical and pharmaceutical products, therapeutic appliances and equipment, educational and recreational equipment and accessories, books, newspapers and magazines, goods for personal care and goods not elsewhere classified. Convenience Goods Goods that are required on a daily basis by individuals and households such as food, beverages (non-alcoholic and alcoholic), tobacco and nondurable household goods. Critical Mass Refers to building up higher levels of population, services and functions in particular area. viviv v
- Cumulative effects Are changes to the environment that are caused by an action in combination with other past, present and future human actions. Development Contributions Charges or levies placed on developers relating to the cost of services and utilities which are provided by Mayo County Council. Ecological Corridors Nature corridors such as hedgerows, riverbanks etc. used by species to get from one conservation site/habitat to another. Ecosystem Is a group of plants, animals and bacteria that work together to remain healthy. Environmental Impact Assessment Report (EIAR) Pursuant to EU Directive 85/ 337/ EEC (as amended in 1997), EIA is a legislative procedure used for identifying the environmental effects of development projects to be applied to the assessment of the environmental effects of certain public and private projects which are likely to have significant effects on the environment. Green Infrastructure An inter-connected network of green open spaces that provide a range of ecosystem services - from clean air and water to wildlife habitat. Hedgerow A natural or semi-natural row of bushes, shrubs and/or trees forming a boundary. Household One or more persons occupying a dwelling which has a kitchen and bathroom facilities. Housing Stock Houses that already exist. Infill Development Development taking place on a vacant or undeveloped site between other developments. National Planning Framework A planning framework for Ireland that aims to achieve balanced regional development and promote areas of critical mass through a network of cities and towns identified as Metropolitan Areas, Regional Growth Centres or Key Towns. Natura 2000 network The assemblage of sites which are identified as Special Areas of Conservation under the Habitats Directive or classified as Special Protection Areas under the Birds Directive 79/409/EEC, or a Site of Community Importance. Natural Heritage Area (NHA) Designation for wildlife conservation in the country. Protected Structure Any structure or specified part of a structure, which is included in the Record of Protected Structures. A structure is defined by the Act as ‘any building, structure, excavation, or other thing constructed or made on, in or under any land, or any part of a structure’. In relation to a protected structure or proposed protected structure, the meaning of the term ‘structure’ is expanded to include: a) the interior of the structure; b) the land lying within the curtilage of the structure; c) any other structures lying within that curtilage and their interiors, and d) all fixtures and features which form part of the interior or exterior of the above structures. Recorded Monument An archaeological monument protected under the National Monument (Amendments Act) 1994-2004. Regional Spatial and Economic Strategy (RSES) A planning framework for a Region for long term strategic development of that Region consistent with the National Planning Framework. (Mayo falls within the Northern and Western Region). Residential Densities The number of residential units per area unit (e.g. hectare). Rural Generated Housing Housing needed in rural areas within the established rural community by people working in rural areas or nearby urban areas. Sequential approach Where development takes place outwards from the centre of an urban area with lands closest to the town centre being developed first. Seveso II Major Accident Directive which is aimed at the prevention of major accidents which involve dangerous substances and the limitation of their consequence for humans and the environment. Smart County The concept of Smart County is an extension and the next phase in the development of a Smart Region model, which recognises that, in order for the County to achieve a potential smart future requires consideration of the opportunities, benefits and challenges that smart technologies and data can offer beyond the traditional applications in rural and urban context. Smarter travel A sustainable transportation model which promotes sustainable modes of transport such as public transport, walking and cycling, along with other actions such as e-working over dependency on car travel. Sustainable Mobility Sustainable Mobility can be described as linking people and places in a sustainable way by supporting: • comfortable and affordable journeys to and from work, home, school, college, shops and leisure; • travelling by cleaner and greener transport and; • a shift away from the private car to greater use of active travel (walking and cycling) and public transport (e.g. bus, rail). viivivi vii
- Sustainable Development Development that meets the needs of the present without compromising the ability of future generations to develop their own needs. Special Areas of Conservation Prime wildlife conservation areas/sites considered of importance at both Irish and European level; the legal basis for their designation is the Habitats Directive. Special Protection Area Sites/areas primarily classified for the conservation of bird species; the legal basis for their designation is the EU Birds Directive. Town Centre Town, village or district centres that provides a broad range of facilities and services and serve as a focus for the community and for public transport, excluding retail parks, local centres and small parades of shops of purely local significance. Tree Preservation Order An order made by Mayo County Council for the preservation of any tree, trees, groups of trees or woodlands. The order may prohibit the cutting down, topping, lopping or wilful destruction of trees except with the consent of the Council which may be granted subject to conditions. Urban Generated Rural Housing Housing demand that is driven by people living and working in urban areas, who wish to live in the countryside and includes second homes. 1INTRODUCTION viii 1INTRODUCTION viii 1
- 1 Municipal Districts Ballina Castlebar Claremorris-Swinford Westport-Belmullet Chapter 1 Introduction 1.1 Introduction The Mayo County Development Plan 2022-2028 sets out the roadmap for the overall proper planning and sustainable development of County Mayo over the plan period. While the Plan is in place for a six-year period, it is framed having regard to the long-term development objectives of the county up until 2040, to align with national and regional spatial plans. The Plan governs the whole functional area of Mayo County Council, including the former Town Council functional areas of Castlebar, Ballina and Westport. The Council operates through four Municipal Districts (MD) in the county, which include Ballina MD; Castlebar MD; Claremorris-Swinford MD and Westport-Belmullet MD (see Map 1.1). The Plan, when adopted, will replace the Mayo County Development Plan 2014-2020. This plan provides for, and manages, the physical, economic, and social development of the County, in the interests of the overall common good, and in compliance with environmental legislation. It includes a set of development objectives and standards, which set out where land is to be developed, and for what purposes (e.g. housing, retail, education, schools, employment, open space, amenity, conservation etc). It informs decisions on where public services such as roads and water infrastructure are to be provided and affects the type of buildings that can be constructed and h facets of daily economic and social life, in terms of where people can live, what services and facilities are available and where job opportunities are to be sited. 1.2 Profile of County Mayo County Mayo is located on the west coast of Ireland in the province of Connacht. The county stretches from Lough Corrib and Killary Harbour in the south to the barony of Erris and Killala Bay in the north, and from the Atlantic Ocean on the west coast to the counties of Sligo and Roscommon on the east. Mayo is the third-largest county in area in the state and the second largest county in Connacht, in terms of size and population. Mayo has a population of 130,507, Castlebar being the largest town has a population of just over 12,000, followed by Ballina (10,171), Westport (6,198), Claremorris (3,687) and Ballinrobe (2,786). Over 71% of people in Mayo live in rural areas. There is a distinct geological difference between the west and the east of the county. The west consists of large areas of extensive Atlantic blanket bog, whereas the east is largely a limestone landscape. • Mayo has the longest coastline in Ireland, at 1,168 km or approximately 21% of the total coastline of the State. • The highest point in Mayo (and Connacht) is Mweelrea, at 814 m (2,671 ft). • The River Moy in the northeast of the county is renowned for it • Ireland’s largest island, Achill Island, lies off Mayo’s west coast. • Mayo has Ireland’s highest cliffs at Croaghaun, Achill Island, while the Benwee Head cliffs in Kilcommon Erris drop almost perpendicularly 900 feet (270 m) into the Atlantic Ocean. • The northwest areas of County Mayo have some of the best renewable energy resources in Europe, if not the world, in terms of wind resources, ocean wave, tidal and hydroelectric resources. CHAPTER 1 INTRODUCTION 12 3
- 2 3 CHAPTER 1 INTRODUCTION The county possesses a strong community identity and a rich and diverse cultural heritage. Mayo’s Gaeltacht region, comprising of three distinct areas (Erris, Achill Island and Tourmakeady), is the third largest in Ireland with 10,886 inhabitants, representing 11.5% of the total Gaeltacht population in the state. Significant progress continues to be made in the improvement of physical, social and community infrastructure in the towns and villages throughout the county, as it is recognised that social infrastructure and community development supports economic growth, provides employment opportunities and improves the well-being and quality of life for the people of Mayo. The county contains an extensive national road network and rail network, which connects the towns of Ballina, Castlebar, Westport, Claremorris, Ballyhaunis and Foxford. The county also contains Ireland West Airport Knock. The airport provides an international gateway to the west region, and its Strategic Development Zone (SDZ) has the potential to become a major enterprise and employment hub within the Atlantic Economic Corridor. 1.3 Strategic Context The Plan builds on the review of the 2014-2020 County Development Plan and is required to set out a strategy for the growth and development of County Mayo, consistent with national and regional spatial plans. The Plan must also have regard or be consistent with national development guidelines, local strategies and programmes, and must comply with both planning and environmental legislation. Since the adoption of the Mayo County Development Plan 2014-2020, significant changes have occurred in the policy and regulatory environment for land use planning in Ireland. A new national and regional hierarchy of plans are now in place. Project Ireland 2040, which includes the National Planning Framework (NPF) and National Development Plan (NDP), sets out the Government’s policy on spatial planning over the period to 2040. The NPF influences all spatial plans from national to local level. The Regional Spatial and Economic Strategy (RSES) sets out the mechanism for delivering the NPF at a regional level. The County Development Plan will provide an overall strategy for development for the county, whilst local area plans provide more detailed planning guidance for urban areas with over 5,000 population. 1.3.1 The National Planning Framework The NPF is a high-level strategy that provides the sustainable framework to guide where development and investment occurs in Ireland up until 2040. The NPF is centred around ten national policy objectives called National Strategic Outcomes (NSOs) (see Figure 1.1 below). Regional and local plans must align with these NSOs, which are underpinned by 75 national policy objectives (NPOs). The preparation of the County Development Plan has been informed by these NSOs and related NPOs. The NSOs emphasise that regional and international connectivity will contribute to the development of a strong economy. The top priority of the NPF is sustainable growth of compact cities, towns and villages. Figure 1.1: National Strategic Objectives of the NPF Source: Project 2040. 1.3.2 Regional Spatial and Economic Strategy (RSES) The RSES is a strategic plan to support implementation of Project Ireland 2040 (NPF and NDP) and the economic policies and objectives of the Government, by providing a long-term strategic planning and economic framework for the development of the region. The adopted RSES (2020-2032) for the Northern and Western Region identifies regional assets, opportunities and pressures and provides appropriate policy responses in the form of Regional Policy Objectives (RPOs). Development plans for counties within the Northern and Western Regional Assembly (NWRA) area must align with this RSES. At a strategic level, the RSES provides a framework for investment to better manage spatial planning and economic development to sustainably grow the Region to 2032 and beyond. It aims to transform the region with a new, focused approach to the delivery of housing, enterprise, infrastructure, healthcare, education and childcare, while also developing more employment clusters in high-value sectors such as tech, advanced engineering, food and medtech. 4 5
- CHAPTER 1 INTRODUCTION 4 5 The NWRA RSES provides for a growth framework to transform the region based on 5 Growth Ambitions: • Vibrant Ambition - Economy and Employment • Natural Ambition - Environment • Connected Ambition - Connectivity • Inclusive Ambition - Quality of Life • Enabling Ambition - Infrastructure Figure 1.2: Five Growth Ambitions of the RSES Source: NWRA RSES 2020-2032 Figure 1.3: Showing Context of Plan, Nationally, Regionally and Locally 1.4 UN Sustainable Development Goals There is significant alignment between the NPF, the RSES and the UN Sustainable Development Goals (SDGs). These Goals also act as a foundation for the Mayo County Development Plan, 2022-2028. There are 17 Sustainable Development Goals (SDGs) set by the UN General Assembly in 2015 as a blueprint to achieve better and more sustainable development for all. The NPF states: “sustainability is at the heart of long-term planning and the NPF seeks to ensure that decisions we take today meet our own needs without compromising the ability of future generations to meet their needs”. RPO 5.5 of the RSES expands on the concept the sustainable use of natural assets by seeking to: Ensure efficient and sustainable use of all our natural resources, including inland waterways, peatlands, and forests in a manner which ensures a healthy society a clean environment and there is no net contribution to biodiversity loss arising from development supported in this strategy. Conserve and protect designated areas and natural heritage areas. Conserve and protect European sites and their integrity. Development Plan objectives can have a direct impact on achieving the SDGs, such as Sustainable Communities and Climate Action and have an indirect impact on the achievement of many other SDGs. The strategic aims and development objectives in the Plan are therefore proofed against the SDGs. Figure 1.4: United Nations Sustainable Development Goals Figure 1.2 above illustrates these growth ambitions with associated guiding principles, aligned with the NPF’s strategic objectives, such as compact growth, sustainable growth, supportive infrastructure, place-making and a low carbon future. The RSES identities the large urban areas as key economic drivers for the region, and at county level. In Mayo, the RSES identifies strategic roles for Castlebar and Ballina, as designated Key Towns, and Westport, as a town with strategic development potential of a regional scale intrinsically linked to Castlebar. 1.3.3 Mayo County Development Plan 2022-2028 In order to achieve the outcomes of the NPF and RSES, the Mayo County Development Plan 2022 – 2028 is considered the first of three development plans to 2040. Figure 1.3 below shows how the Plan fits in the nationally, regionally and locally context. The intention of this plan is to build on the development foundations already established in Mayo and to ‘plant seeds’ throughout to stimulate growth. With the implementation of a comprehensive monitoring regime, the second of the three development plans will provide adjustments and policy interventions that are necessary to re-align with both the NPF and RSES but will also see necessary adjustments to align with the National Marine Planning Framework. The third development plan will build on previous two plans and may require further adjustments and policy intervention to ensure alignments with the NPF and RSES. 6 7
- CHAPTER 1 INTRODUCTION 6 7 1.5 Climate Action Climate change impacts are currently experienced worldwide. Coastal areas in western parts of Europe, such as Ireland, can expect more heavy rain, higher risk of flooding from rivers and higher risk of storms in winter. County Mayo is particularly vulnerable to river, coastal/tidal flooding, drought, colder winters as well as surface water flooding arising from heavy rain. Tackling climate change is a top priority for the EU and the European Commission has presented a package of measures designed to make Europe the world’s first climate-neutral continent by 2050. The European Green Deal includes key policies aimed at ambitiously cutting emissions, preserving Europe’s natural environment and investing in cutting-edge research and innovation. It sets out an achievable roadmap that will ensure the EU’s economy becomes sustainable by turning climate and environmental challenges into opportunities across all policy areas that will result in economic growth and jobs. Furthermore, the national Climate Action Plan (2021) sets out a course of action to address the impacts of climate change on Ireland’s environment, society, economic and natural resources. The Climate Action Plan identifies the scale of the challenge and examines impacts on a range of key sectors including Electricity, Transport, Built Environment, Industry and Agriculture and charts a course towards ambitious emission reduction targets. Mayo County Council has adopted and is implementing a Climate Adaptation Strategy for the county and will also deliver a Climate Action Plan. Climate change is an integral theme of the Development Plan. 1.6 Planning Guidelines The Minister for Housing, Local Government and Heritage, issues statutory guidelines from time to time, to planning authorities, who must have regard to them in carrying out their functions, including in the preparation of the County Development Plan. They cover a wide range of issues including architectural heritage, childcare facilities, landscape, residential density and design, environmental assessment and development management. Where planning guidance documents contain Specific Planning Policy Requirements (SPPR), such as in the Interim Guidelines on Statutory Plans, Renewable Energy and Climate Change (2017), Apartment Guidelines (2018) and Building Height Guidelines (2018), local authorities are required to be consistent with these documents. 1.7 Preparation of the Development Plan and the Legislative Context The preparation of the Development Plan has been influenced by a number of strategic international, national, regional and local policy documents, guidelines, strategies and legislation. Figure 1.5 below illustrates the Irish hierarchy of plans and demonstrates how EU and national legislation and policy, as well as local input, will feed into the preparation of the County Development Plan. Figure 1.5: Irish Hierarchy of Plans and EU and National Legislation and Policy The Plan must also have regard to the Development Plans of adjoining Local Authorities, which include Galway, Sligo and Roscommon. Development plans must comply with the requirements of the Planning and Development Act 2000 (as amended), in particular, Sections 9, 10, 11 and 12. Development plans must be consistent, as far as is practicable, with national plans, policies or strategies that the Minister for Housing, Local Government and Heritage determines relate to proper planning and sustainable development. Section 10(2) of the Planning and Development Acts 2000 (as amended) requires development plans to include mandatory development objectives relating to zoning of lands, provision of infrastructure, conservation and protection of the environment, management of features and preservation of the landscape, etc. The County Development Plan accords with planning legislative requirements. 1.8 Environmental Reports The County Development Plan has also been informed by the preparation of three Environmental Assessments, in tandem with the plan making process. In accordance with European and National legislation, the Council has carried out a Strategic Environmental Assessment (SEA) and an Appropriate Assessment (AA) under the SEA Directive and Habitats Directive. These assessments are undertaken in order to ensure that the potential impacts of the objectives contained in the Plan on the environment can be evaluated. This process informs the content of the plan and ensures that development responds appropriately to the sensitivities and requirements of the wider natural environment. A Strategic Flood Risk Assessment (SFRA) has also been undertaken for the plan area. This provides a broad assessment of flood risk within the county and will inform strategic land use planning decisions in this and other local plans. It is considered that the development objectives in the Plan are consistent, in as far as practicable, with the conservation and protection of the environment. 8 9
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