Doonbeg - The further information supplied has not adequately addressed the ecological issues
An Taisce have today made a submission [Note 1] to Clare County Council in respect of the 'Further Information' supplied by Trump International Golf Links (TIGL Ireland Enterprises Ltd) in repect of their planning application for coastal erosion management works (Planning Reference 16/1012)
The further information supplied by TIGL Ireland Enterprises Ltd has not adequately addressed the ecological issues with the application. This is largely because they are erroneously conflating the erosion of the dune frontage as a result of the golf course stopping the dunes' movement with the natural erosion associated with normal dune dynamics. That in turn has led them to claim that the do-nothing scenario (leaving the dunes along with no hard protections) will be "profoundly detrimental" to the dune habitats. So the premise of all of their arguments that the proposed walls will help the dunes is incorrect.
Therefore, An Taisce’s initial concerns about the impact of the proposal on the habitats and species protected by the Carrowmore Dunes SAC still stand.
Ian Lumley, Advocacy Officer of An Taisce stated "The solution being put forward by Trump International Golf Links Ltd is bad for the people who love White Strand the Beach, Surf and Dunes and the protected habitats and species that depend upon its sustainable management. The further information has not changed the negative impacts. The conservation of sand dunes internationally has proven that they are more cost effective at protecting the coast than hard sea defenses and that they supply valued biodiversity and ecosystem services to local communities. The scientific consensus is that sea walls are not compatible with sand dune conservation. The golf course design simply has to change."
There are strong parallels between the Doonbeg case and the impact on sand dunes at the Trump International Golf Links Menie golf course in Aberdeenshire, Scotland. The golf course overlaps the Foveran Links Site of Special Scientific Interest, which was designated as such because it was one of the prime examples of mobile sand dune systems in the UK. Before the golf course was constructed the dunes naturally shifted northward by as much as 11 metres per year over an area of 15 hectares. However, when TIGL stabilised the dunes to protect the golf course, their natural movement was severely impeded. Dr Jim Hansom, a geomorphologist at Glasgow University, said in an interview with the BBC (published 8 November 2017) that this loss of natural dynamism will likely result in the dunes losing their designation as an SSSI. Similarly, Scottish Natural Heritage, which is now assessing the status of the Foveran Links SSSI, stated that the golf course had caused habitat loss and damage to the dune system. [Note 2]
An Taisce submit that the further information provided by the applicant has not adequately addressed the concerns expressed by the PA because the response:
- has erroneously interpreted the relationship between the development and the normal dune dynamics and therefore not adequately scientifically justified the reasoning behind the protection works and
- has failed to provide the necessary details, assessments, and surveys to satisfactorily conclude that the proposal would result in no adverse impacts to the receiving environment.
It still cannot be concluded that the development would not have significant adverse impacts on the SAC and the beach site as a whole, thereby breaching Ireland’s legal obligations under the Environmental Impact Assessment Directive and the Habitats Directive.
Therefore, on the basis of the further information provided, An Taisce must again object to the proposed coastal protection works.
It is expected that Clare County Council will make their decision by 21st December 2017 and it would then be popssible for parties to appeal their decision to An Bord Pleanala (The Planning Board).
An Taisce have also written to the Minister for Arts, Heritage and the Gaeltacht requesting enforcement inspection of the original planning application for the golf course in 1998. [Note 1 - Appendix]
For further information, contact:
Ian Lumley, An Taisce Advocacy Officer: +353 1 454 1786
Charles Stanley-Smith, Communications, An Taisce. Tel: +353 87 241 1995
An Taisce The National Trust for Ireland
 An Taisce's third (and current submission) http://www.antaisce.org/sites/antaisce.org/files/20171130-02-161012rfi.pdf
 BBC report on the detrimental effects of the TIGL golf course in Aberdeenshire, Scotland http://www.bbc.com/news/uk-scotland-41845278
 An Taisce's second submission on this application https://drive.google.com/file/d/0BxEVOTzgFnKEN3ZUQ2V6cUhqZEE/view?usp=sharing
 An Taisce’s first submission on this application https://drive.google.com/file/d/0BxEVOTzgFnKEX1dWemhjdmJFQjg/view?usp=sharing
 National Parks and Wildlife Service (NPWS) (2014b) Carrowmore Dunes SAC Conservation Objectives Supporting Document: Marine Habitats, [online] available: http://www.npws.ie/sites/default/files/publications/pdf/002250%20Carrowmore%20Dunes%20SAC%20Marine%20Supporting%20Doc%20V1.pdf
 An Taisce press release 3rd February 2017 "An Taisce makes second submission to the Trump’s Doonbeg Wall" http://www.antaisce.org/articles/an-taisce-makes-second-submission-to-the-trump%E2%80%99s-doonbeg-wall
 An Taisce welcomes the news that plans for construction of a 2.8km coastal wall at Doonbeg, Co. Clare have been abandoned. An Taisce press release, when the original proposal for a 2.8 km wall was withdrawn http://www.antaisce.org/articles/proposed-construction-of-28km-wall-abandoned-at-doonbeg-golf-course
 An Taisce’s submission to Clare County Council: https://drive.google.com/file/d/0BxEVOTzgFnKEX1dWemhjdmJFQjg/view?usp=sharing
 National Parks and Wildlife Service (2014) Carrowmore Dunes SAC (site code 2250) Conservation objectives supporting document - Coastal Habitats https://www.npws.ie/sites/default/files/publications/pdf/002250%20Carrowmore%20Dunes%20SAC%20Coastal%20Supporting%20Doc%20V1.pdf
 - Scottish Natural Heritage (SNH) (2000) Beach Dunes: A Guide to Managing Coastal Erosion in Beach/Dune Systems, [online]. Available at: http://www.snh.gov.uk/publications-data-and-research/publications/searchthe-catalogue/publication-detail/?id=112 [accessed: 02/06/2016A]
 An Taisce’s submission calls on Donald Trump to make Doonbeg Golf Course Great. Press release on An Taisce's submission to the original Wall at Doonbeg. http://www.antaisce.org/articles/an-taisce%E2%80%99s-submission-calls-on-donald-trump-to-make-doonbeg-golf-course-great
About An Taisce
An Taisce is a charity that works to preserve and protect Ireland's natural and built heritage. We are an independent charitable voice for the environment and for heritage issues. We are not a government body, semi-state or agency. Founded in 1948, we are one of Ireland’s oldest and largest environmental organisations.