Submission to ABP re TIGL Doonbeg

29th May 2019
Submission Summary

An Taisce acknowledge that while the distinction drawn by the applicants between accreting and eroding dune systems is valid, the erosion of the Carrowmore dune system is nonetheless part of the natural dynamism of dune systems, albeit exacerbated in this case by the presence of the golf course. Furthermore, Scottish Natural Heritage (SNH) and HR Wallingford (who carried out the beach monitoring studies for the applicant) authored a “Guide to managing coastal erosion in beach and dune systems” (2000)1 which calls into question the use of hard coastal protection works in dune systems generally: “Most approaches to erosion management are damaging to the environment to a greater or lesser extent. This is particularly so for projects entailing civil engineering operations such as revetment and seawall construction or major beach renourishment schemes.”

And: “Solid revetments and seawalls are not normally considered appropriate for dune protection2…they normally disrupt the natural dynamism of dunes and replace it with an artificial shoreline.” Further, in relation to eroding dune systems in particular: “Construction of continuous defences along an eroding dune face will dramatically change the coastal landscape and will disrupt the natural interchange of sand between beach and dune. This should be avoided if at all possible as the impacts are effectively irreversible ” [An Taisce emphasis added].

Due to the disruptive and daaging impacts of hard engineering works on dune systems, SNH maintain that adaptive management policies should, in all cases, be attempted before resorting to revetments and seawalls. Specifically, they state that, “management approaches to the threat of asset loss should start with the consideration of adapting the backshore to allow natural erosion to continue.”

While TIGL is undisputedly of economic importance to the local and wider West Clare community, it must be noted that the erosional forces threaten just the three seaward-most holes, which are built precisely on the sensitive dune system. An Taisce submit that the potential for an adaptive management plan to be put in place, whereby the at risk holes are realigned and located on land which is less erosion-prone, should be seriously considered as a viable alternative to the construction of coastal defense works.

While the applicant states in Section 2.2.1 that An Taisce have solely referenced generic desktop studies and do not have site specific data, we would observe that while our submission does indeed draw on the recognised expertise provided by Scottish National Heritage, our response also relies heavily on submissions made to Clare County Council on this specific development by their own Environmental Assessment Officer (EAO), and the ecological consultancy JBA Consulting, who were engaged by Clare County Council to examine the RFI data provided to the council. We also reference the NPWS documentation which is specific to this site, and submissions by them in relation to this specific development. Both the EAO and JBA Consulting outlined that the data necessary to give a definitive conclusion on the coastal processes would need to be based on longer term data, and as such An Taisce cannot definitively prove potential impact by the development, no more than the applicant can disprove it, based on the data available.

Irrespective of the type of sediment dynamics of the system, the fundamental premise of An Taisce’s appeal is that insufficient data has been provided to remove all reasonable doubt that the proposal would not have adverse impacts on the Carrowmore Dunes Special Area of Conservation (SAC), and we would argue that this remains the case. The interpretation of reasonable doubt has been clearly elucidated by the courts, and the stringent guidelines appertaining to such a conclusion. Further, where An Taisce highlight lacunae in the data, which would lead to uncertainty, our judgement is based on the data provided in the planning documentation, including the opinion of other bodies such as the NPWS, JBA Consulting and the Environmental Assessment Officer (EAO) from Clare County Council, and is informed by recent well argued legal judgements.

Submission below