February 2018 eZine

26th February 2018
This is the first eZine for a while, our apologies for that but we intend to revert to a monthly eZine. In this issue: The National Planning Frame work and the associated National Development Plan are the most important plans made by the Government for of how and where we will live in the future. This is being promoted (somewhat controversially) as Project 2040. The taking of Judicial Reviews is under threat with the Government looking to severely restrict the amount of time in which to take a case. The recent announcement of a call for a transboundary call for submissions on Hinkley C is a win for the requirement for Transboundary Consultations. An Taisce and other groups have appealed Clare County Council’s decision to approve the works at Doonbeg to An Bord Pleanála.

Is Biomass a climate solution – Bord Na Mona’s plan to import US timber

National An Taisce Event
Thursday, March 8, 2018
Tailors' Hall, Back Lane Dublin 8

Public Meeting Thursday 8th March, Tailors’ Hall – 19.00 – 21.30

An Taisce & Biofuelwatch

Aim of event: To highlight the unsustainable use of wood chips and other biofuels for the generation of electricity and heat and the connections between EU biofuel policy and the destruction of forests in the SE USA and other areas. One area of particular concern is Bord Na Mona’s plans to import wood chips from Georgia and elsewhere for powering or co-firing peat burning stations. Recently, it has been suggested that the combination of Biofuel Energy with Carbon Capture and Storage (BECCS) is the way forward and this idea will be discussed.

Speakers:
Jack Spruill – Destruction of American Forests (for fuel in EU) Jack is a farmer and conservationist who runs the Spruill Farm Conservation Project in North Carolina.
Pete Deane – Drax and wood chips. Pete is a campaigner with Biofuelwatch. He is involved in the campaign against the use of wood pellets imported from the US in the Drax power station in the UK.
Ian Lumley – Biofuels in Ireland and BNMs’ plans for the importation of wood pellets. Ian is An Taisce's Advocacy Officer and he will discuss biofuel policy in Ireland with emphasis on the plans of Bord na Mona’s biofuel plans.
Paul Price – BECCS – Bio-energy with carbon capture and storage. Paul (Dublin City University, IE NETS project) will discuss the deployment of bioenergy with CCS (BECCS).
Chair: Dr. Aideen O’Dochartaigh.

Admission is free but please register on Eventbrite so we can track numbers https://www.eventbrite.ie/e/is-biofuel-a-climate-solution-bord-na-monas-plan-to-import-us-timber-tickets-43305906131?ref=estw

Dublin Bay – Nature and History

Local Association Event
Monday, March 5, 2018
Monday March 5th - Cancelled due to ilnness

Cancelled due to illness

An illustrated talk by Richard Nairn

Monday March 5th 8pm St. Patrick’s Hall, Monkstown, Co. Dublin.

Based on a new book, this fascinating talk weaves together the history and ecology of Dublin Bay. Learn about the real story of Molly Malone’s cockles and mussels and the reasons why the Bull Island exists.

Richard Nairn is a writer and ecologist who grew up in Dublin and has lived by the sea all his life. He studied Science at Trinity College Dublin and University College Cork and was the first Director of IWC BirdWatch Ireland. He currently provides ecological advice to Dublin Port Company and the Dublin local authorities. He is an active sailor and has also walked all the shores of Dublin Bay. He has written three books including Ireland’s Coastline (Collins Press 2005).

Flyer here: https://drive.google.com/file/d/1shDzqTGB7gz8h3DOukebUP7mVe9_GYEE/view?usp=sharing

Cancelled due to illness

Cost An Taisce Members: 
€5 incl Tea
Cost Non Members: 
€5 incl Tea

Celebrate Tree Week

Local Association Event
Friday, March 9, 2018
Scoil Lorcain, Eaton Sq, Monkstown 10:30 am

Celebrate National Tree week with a planting of a quince tree and four Autumn Raspberries.

Cost An Taisce Members: 
€0
Cost Non Members: 
€0

The sinking of the Lusitania

Local Association Event
Tuesday, March 20, 2018
The Goat, Goatstown @ 8:00 pm

Illustrated talk by Cormac Louth, frequent lecturer on maritime matters. Member of the Maritime Institute of Ireland and Dun Laoghaire Borouigh Historical Society.

Cost An Taisce Members: 
€4
Cost Non Members: 
€5

The Fitzwilliams of Merrion

Local Association Event
Tuesday, April 17, 2018
The Goat, Goatstown @ 8:00 pm

Illustrated talk by Des Smyth, Chair of Mount Merrion Historical Society

Cost An Taisce Members: 
€4
Cost Non Members: 
€5

How does the National Planning Framework & National Development Plan 2018-2027 measure up?

16th February 2018
Press Release

Ireland is badly missing its EU climate action targets, and will face increasing exposure and cost from storm and flood impact. Decades of bad planning have left a legacy of car based dispersed sprawl, with climate, air pollution, congestion and other adverse social, economic environmental impacts.

The previous attempt at national strategic planning the 2002 National Spatial Strategy designated too many regional growth centres as gateways and hubs, and failed to control one off rural housing dispersal.

How then Does the National Planning Framework (NPF) and National Development Plan 2018 - 2027 (NDP) measure up?

What is to be welcomed?

The published National Planning Framework opens with a reiteration and incorporation of the UN Sustainable Development Goals (SDGs 2015). The National Planning Framework NPF affirms ”a major new policy emphasis on renewing and developing existing settlements

The 10 “Strategic Outcomes” set out in the 2016 draft have been amended to give a new provision for a “Transition to a Low Carbon and Climate Resilient Society" and to the protection of “Amenity and Heritage”, resolving some of the deficiencies in consideration of heritage in the 2016 Draft.

What is to be questioned?

Rural development and housing
The NPF provides extensive and welcome policies on strengthening the status of rural towns and villages, and the importance of villages as rural service bases, With emphasis on “Compact Growth” and a fight against sprawl.

This is undermined by a general “National Policy Objective 19” to accommodate one off housing in rural areas base only on design and siting consideration and vague provision of “having regard to the viability of smaller town and rural settlements”. Only in a “rural area under urban influence" is consideration of “demonstrable social and economic need“ the insertion of “social” occurring since the Draft.

These new provisions seriously undermine rural village and town objectives of the NPF.

This is despite the NPF stating "..... in some locations, almost all recent single housing in the countryside has been developed privately, with social housing provided largely in settlements. In many parts of rural Ireland, where a significant majority of housing output is in the countryside, this has contributed to spatial and social imbalance and the decline in population of smaller settlements. As a result, many key services have closed, in part due to population decline, leaving more marginalised and vulnerable citizens without access to those services."

Implementation and unresolved role and effectiveness of Planning Regulator.

The implementation of the NPF is predicated on the establishment of the Planning Regulator, the legislation for which remains at Bill stage in the Oireachtas. Unless effective regulation achieved and public transport and cycling investment is provide to achieve sustainable settlement and mobility Ireland sprawl will continue and worsen.

Climate Action

The NDP provides a 7.6 billion exchequer allocation with an additional 14.2 billion from the private and semi state sector under Climate.

The plan does not quantify the level of emission reductions which would be achieved by the level of investment proposed, including the housing retrofitting targets 30,000 to 45,000 per annum from 2021. However, we welcome the increase in housing retrofitting but it needs to be closer to 100,000 per annum.

Ireland needs clear timetabled targets for advancing decarbonisation, to achieve the scale and impact needed in energy efficiency, building retro fitting and alternative renewable energy provision. Climate action is undermined by:

  • the uncritical endorsement by the NPF of the industry led Foodwise 2025 strategy which is increasing dairy and beef production emissions.
  • the overwhelming focus of transport investment outside Dublin on Motorway and road building
  • the proposed 320 million funding by the NDP of the additional Dublin Airport runway which does not address the increased impact of aviation emissions, for which there is no current mitigation.

There is a provision of 940 million for flood protection, but no consideration of the level of threat and cost from Ireland’s future exposure to increasing storm and flood impact, including on critical infrastructure.

Sustainable transport

The NPF seeks to promote more compact development with sustainable transport, but no targets are set out for any shifting of the current level of car journeys to public transport and cycling. The 2020 sustainable transport targets in 2009 the Department of Transport Smarter Travel policy are ignored.

There are no public transport investment proposals of any significance outside Dublin, with bus investment measures proposed for Cork and Galway only. Most of the public transport measure projected for Dublin are for after 2027 beyond the life of the NPF. There is no strategy for the maintenance and enhanced use of the national rail network both for passengers and freight. The NDP funding allocation for rail is only for maintenance and safety to maintain in a “steady state”.

The NDP provisions for Enhance Regional Accessibility are unsustainable road investment based including reactivation of the A5 cross border proposal and 3 significant road projects:

  • 850-900 million euro Cork Limerick Motorway which will increase car based sprawl patterns of development and travel. This disregards the concerns set out in the draft NPF (page 123) and omitted in the todays publication that :” Investment in connectivity first without urban consolidation measures will likely worsen the current trends towards sprawl”
  • 550- 600 million Galway Ring Road which will not solve the city’s unsustainable car dependence and congestion.
  • The provision of extra lanes on the M7 from Nass to Newbridge which will increase congestion on the already overcrowded M50

ENDS

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
email: publicaffairs@antaisce.org
An Taisce The National Trust for Ireland
www.antaisce.org

Notes

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.

An Taisce very critical of the Government's plan to shorten the period to take Judicial Reviews

7th February 2018
Press Release

The Government’s plan to shorten the period to initiate a Judicial Review in the case of Critical Infra-Structure from 8 to 4 weeks goes against key requirements of the Aarhus Convention.

Currently there is an 8 week window to make an application to the court for leave to Judicially Review planning decisions. Within that period you need to get hold of the decision and understand what legal issues there are with it, and to request information which you may need to inform your decision to challenge.

The Government also intending to increase the level of justifcation the public need to provide to have standing to entitle them to take such cases - so the burden will fall even more to eNGOs

There is talk about serial objectors - An Taisce have only taken 5 Judicial Reviews in the last 5 years all based on contravention of planning or various EU Directives – An Taisce won 3 of those and the other 2 are still before the courts.

An Taisce only take cases where we can demonstrate that Planning Rules/Guideline or EU Directives have been contravened, because taking a case where you don’t like a result costs time and doesn’t win.

Under Aarhus, An Taisce is entitled to "adequate and effective remedies ... and be fair, equitable, timely and not prohibitively expensive" and will fight to continue to be able to take well reasoned Judicial Reviews, in a reasonable timeframe.

ENDS

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
email: publicaffairs@antaisce.org
An Taisce The National Trust for Ireland
www.antaisce.org

Notes

The United Nations Economic Commission for Europe (UNECE) Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters (commonly referred to as the Aarhus Convention) was adopted on 25 June 1998. Ireland ratified the Convention on 20 June 2012.

The Aarhus Convention lays down a set of basic rules to promote public involvement in environmental matters. The Convention has 3 pillars:

  1. Access to environmental information: This includes information on the state of the environment and/or on human health issues as well as information on policies and measures taken. Read more in our document on Access to environmental information.
  2. Public participation in environmental decision making: Members of the public have a right to participate in a range of decisions where there may be an environmental impact. These include planning matters and other environmental licensing decisions, such as foreshore licences, waste licences and Integrated Pollution Prevention Control licences. Public authorities responsible for decision making on such licences are obliged to publish notices on specific licence applications, which must inform the public on how they may participate. Comments submitted by the public are to be taken into consideration in the decision-making process.
  3. Access to justice in environmental matters: Members of the public and environmental non-governmental organisations have the right to seek a review of decisions that have been made which may affect the environment. The review procedures must provide “adequate and effective remedies ... and be fair, equitable, timely and not prohibitively expensive”.

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.

An Taisce calls for statement from Taoiseach ahead of Wednesday’s “Keep it in the ground” Bill: time to “put up or shut up” on meaningful climate action.

6th February 2018
Press Release

Speaking recently in the European Parliament, Taoiseach Leo Varadkar spelled out his deep unhappiness at his own government’s wholly inadequate response to climate change: “As far as I am concerned, we are a laggard. I am not proud of Ireland’s performance on climate change ... There are lots of things that we intend to do so that we can meet those targets. And it’s something that I am very committed to, and certainly, my generation of politicians is very committed to.”

John Gibbons, An Taisce’s Climate Change spokesperson stated “We welcome that statement and evident new resolve: but ultimately, it is tangible actions that matter, not words. Wednesday this week will see the Taoiseach’s first opportunity to deliver such action, when the Petroleum and Other Minerals Development (Climate Emergency Measures) Bill 2017 comes before the Dáil for second stage debate.” He continued “Informally known as the ‘keep it in the ground’ Bill, this would prohibit further exploration and drilling for new fossil fuel resources anywhere in Irish territorial waters - unless and until the current dangerous concentrations of the greenhouse pollutant carbon dioxide fall back to scientifically determined safe levels.”

In December 2015 in Paris, world leaders agreed to take urgent action to halt climate change. States committed to “holding the increase in the global average temperature to well below 2°C above preindustrial levels and pursuing efforts to limit the temperature increase to 1.5°C above pre-industrial levels’’. Yet despite this commitment, the world currently remains on track for catastrophic global warming with worsening health, environmental and economic impacts, particularly in developing countries. The single biggest contributor to this failure is the continued burning of fossil fuels: coal, oil, natural gas and peat. The fossil fuel industry continues extracting and burning hydrocarbons at unsustainable rates, and even persists in exploring for more. Every single new extraction site that is opened threatens the achievement of the Paris Agreement commitments.

To date, successive Irish governments have defended continued exploration using the straw man argument of enhancing national energy “security”: but seeking new sources for generating devastating pollution is the very opposite of “security”. There is only one genuine and defensible way to secure Ireland’s energy future: and that is with the greatest possible contribution from clean, zero carbon, indigenous renewable resources. That can and should be the sole focus of Ireland’s strategy for “energy security”, not the dangerous distraction of yesterday’s fossil fuels.

The Bill being debated this week represents a modest, but still hugely symbolic, step. It involves zero tangible cost to the Exchequer, and comes with many co-benefits, not least being to protect marine ecologies, and to claw back some of our tattered international reputation.

John Gibbons, stated “The issue for the Dáil this week is only whether to allow the Bill to continue to committee: therefore if there are any technical deficiencies, there will be ample opportunity to correct them there. For tomorrow, the only issue is one of principle: is the Taoiseach genuinely committed to climate leadership, or will he - like his predecessors - refuse at the very first hurdle?”

For the scientific background to this Bill, please see this short video commentary prepared by the eminent international climate scientist Professor Kevin Anderson of the UK’s Tyndal Centre for Climate Change Research: https://www.youtube.com/watch?v=H9vwTKuoicM

ENDS

For further information, contact:
John Gibbons, An Taisce Climate Change Committee: +353 87 233 2689
Charles Stanley-Smith, Communications, An Taisce. Tel: +353 87 241 1995
email: publicaffairs@antaisce.org
An Taisce The National Trust for Ireland
www.antaisce.org

Notes

For the scientific background to this Bill, please see this short video commentary prepared by the eminent international climate scientist Professor Kevin Anderson of the UK’s Tyndal Centre for Climate Change Research: https://www.youtube.com/watch?v=H9vwTKuoicM

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.

An Taisce Welcomes Public Consultation UK Hinkley Point C, Nuclear Power Plant

20th February 2018
Press Release

The Government has today launched public consultations on the UK’s Hinkley Point C, nuclear power station, 5 years after it should have under UN Conventions. The UK Government are building a nuclear power station, Hinkley Point C, on the north coast of Somerset, some 150 miles (~242 km) from Ireland’s East Coast.

Charles Stanley-Smith, An Taisce's Communication Officer stated “These consultations have been hard won through court cases and escalation to the compliance committees of two UNECE conventions on consultation rights and obligations. This is the hard work of An Taisce, The Environmental Pillar and Friends of the Irish Environment and German MEP Ms Sylivia Kotting-Uhl”

He continued "The peoples' rights to these consultations will become increasingly important in our ability to address transboundary impacts of UK projects on our environment, health and economy, into the future. Under UN Conventions, the peoples of neighbouring countries that could be affected by a project need to be consulted. Post Brexit, we may not be able to rely on EU law to safeguard us, but these are UN conventions For instance, the Irish people will now need to be consulted in terms of any other 5 proposed nuclear power station on the UK’s west coast”

Charles Stanley-Smith continued “An Taisce welcomes this Consultation and we would like like to encourage people to participate, in this consultation which is being organised through the Local Authorities across the country. The deadline for your submissions is 17th April 2018”

An Taisce challenged the planning permission and lack of transboundary consultation in the UK Courts [Note 1]. Then along with The Environmental Pillar and Friends of the Irish Environment, they continued their challenge through the compliance mechanisms of the relevant international conventions governing consultation on transboundary impacts. The committees responsible for compliance with the conventions have been robust in upholding the interests of the public.

Following the recommendations of one of these committees, a further round of consultation by the UK on Hinkley Point C happened between July and October last year. In those cases Germany, Denmark and the Netherlands facilitated their public being consulted. Irish eNGOs escalated their concern about the further failure by Ireland to provide for consultation during that period with the Irish public. This resulted in the committee writing to the Irish Government and invited Ireland to uphold the rights of the Irish public to be consulted. This is now finally happening in this extended round of consultation, commencing on Feb 20th, 2018. [Note 2]

We suggest some considerations the public could make in their submission:

  • The discounted economic loss to Ireland of an accident in a plant like Hinkley Point C being ‘conservatively’ estimated by the ESRI in a 2016 report [Note 3] as €161 billion ( scenario 4) ;
  • The serious deficits in the climatic modelling which the UK used in the UK’s assessment of the potential transboundary impacts in the event of an accident; [Note 4]
  • The lack of emergency response planning in Ireland to deal with such an incident to protect the public; The Radiological Protection Institute of Ireland, (RPII) in its 2013 report [Note 5] on the Radiological impacts of the proposed UK plants in Ireland, produced after the UK granted permission assumed the impacts to Irish people can be mitigated against by sheltering indoors, but fail to address basic considerations and practicalities of the feasibility of such mitigation given issues like the contamination of our largely uncovered water supply.
  • The effect on Ireland’s agriculture could be devastating. If an event was to occur in April for example when all the winter fodder is exhausted, new silage can’t be made, and animals would need to be kept inside without food or water. The extent of Insurance coverage in place in the event of an accident is also controversial. The estimates for compensation seem entirely unrealistic in the context of the costs incurred in Fukishima, and even then there is a significant shortfall to be met by a UK Government who will be struggling in the aftermath of a serious Nuclear event.
  • There are additional risks now consequent on Brexit. Currently we can rely on the controls associated with a number of EU Directives, and key EU principles regarding the polluter pays and the precautionary principal which underpin these directives set out in the EU treaties. Amendments are being drafted for the House of Lords debate on the Great Withdrawl Bill may or may not serve to adequately address these principals in the post-Brexit UK legislative codes. The extent of parliamentary oversight to changes in UK legislation post Brexit has already been acknowledged to be a hugely controversial issue, given the extent of powers being granted to amend legislation by regulation in the bill.
  • Also as part of Brexit the UK proposes to withdraw from the EURATOM treaty, which is concerned with a number of matters including Nuclear Waste and safety. The implications of this are entirely unclear.
  • Serious technical issues have become apparent with the design for the reactor pressure vessel proposed for use in Hinkley which have become apparent in Flamanville in France.

ENDS

For further information, contact:
Charles Stanley-Smith, Communications, An Taisce. Tel: +353 87 241 1995
email: publicaffairs@antaisce.org
An Taisce The National Trust for Ireland
www.antaisce.org

Notes

[1] History of Court Cases

  • Development Consent Order for Hinkley Point C was granted on 19th March 2013.
  • An Taisce on learning of the Secretary of State’s decision, mounted a Judicial Review challenge against the decision in the court of England and Wales, taking the matter all the way to the Supreme Court who ultimately ruled against.
  • An Taisce has sought a reference to the EU Court of Justice, (CJEU), to clarify the proper interpretation of Article 7 of the EU Environmental Impact Assessment Directive, (2011/92/EU) regarding the test for transboundary impacts, in light of the two UNECE Conventions which underpinned this article.
  • The UK Supreme Court refused the appeal on paper stating that the CJEU had already ruled on the matter.
  • Subsequently Friends of the Irish Environment, (FIE), supported by An Taisce made a complaint to the implementation committee of one of these conventions The UNECE Convention on Environmental Impact Assessment in a Transboundary Context” (the Espoo Convention),and also by a German Member of Parliament, Ms Sylivia Kotting-Uhl, and other complaints were also made to the Compliance Committee of the UNECE
  • These committees ultimately found the UK to be non-compliant with its consultation obligations in respect of Hinkley Point C.

[2] Details of Consultation Notice in Irish Times 20/02/2018 https://drive.google.com/file/d/1WthkQa7RIEtMNkzFPN9l4dwDEz3aH4yR/view?usp=sharing

[3] ESRI in a 2016 report - https://www.esri.ie/pubs/BKMNEXT313.pdf#page=5

[4] Professor John Sweeney's Assessment

Professor John Sweeney assessed the assessment and reports the UK prepared under Article 37 of the EURATOM treaty and which the UK relied up on in determining its view on the potential for transboundary impacts from HInkley Point C in the event of an accident. Below he has provided a brief summary of his technical report, with a very stark and strong conclusion regarding the confidence on the competence of key elements of the Article 37 submission.

“Summary of Hinkley Concerns

  1. The risk of extreme meteorological events coinciding with an accident occurring at Hinkley are calculated on an unsound basis. The weather database used to estimate e.g. an event which might occur e.g. once in 10,000 years cannot be calculated with any confidence from the short run of data used by the Hinkley proposers. The statistical basis for this is further undermined by the fact that climate changes are currently underway in both the UK and Ireland which render reliance on a short historical climate database unsound.
  2. Similar concerns arise when calculating water levels at this coastal site. Existing tide gauges indicate sea level is rising all along the south coast of England. Current estimates are that sea level will continue to rise into the 22nd Century at least, with ultimate rises of several metres likely. The effect of this requires to be incorporated in any extreme water level calculation and certainly making estimates for the 1:10,000 year event is not statistically valid.
  3. Uncertainty exist as regards future storm surge changes. Combined with sea level rise this poses additional risks which are not handled using the precautionary principle by the Hinkley proposers. Water level considerations are crucial since spent fuel is to be stored for over a century at this coastal site.
  4. The dispersion model used dates from 1981 and several caveats to its use have been made by its original author. These caveats are particularly relevant to the site and situation of Hinkley Point and do not appear to have been considered adequately in the report.
  5. Any dispersion model based on progressive dilution downwind does not adequately consider meteorological conditions conducive to long range transport of a pollution plume in an undispersed state. Chernobyl exemplified this, resulting in serious implications for Irish upland farming. The worst case outcomes for Ireland are therefore not adequately considered in the dispersion modelling used.
  6. Ireland, unlike France and the Channel Islands, was excluded from any accident impact assessment. The Irish coast and the Channel Islands are equidistant from Hinkley and only slightly further than the nearest point on the French Coast. This raises issues of confidence about the extent to which the report can be considered competent. “

[5] RPII 2013 Report - http://www.epa.ie/pubs/reports/radiation/RPII_Proposed_Nuc_Power_Plants_UK_13.pdf

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.

An Taisce appeals Doonbeg Golf course planning permission

26th January 2018
Press Release

An Taisce The National Trust for Ireland have today appealed to An Bord Pleanála the permission granted by Clare County to TIGL Ireland Enterprises Ltd for development which will comprise of coastal erosion management works at, and adjacent to, Carrowmore Dunes, White Strand, Doughmore Bay and Trump International Golf Links and Hotel, Doonbeg, Co. Clare. [Note 1]

Doireann Ni Cheallaigh, An Taisce’s Planning Officer stated “The Natura Impact Statement submitted by the applicant and the Appropriate Assessment carried out by Clare County Council could not satisfy the requirements of Article 6(3) of the Habitats Directive as it has not been appropriately demonstrated that the proposed development would not adversely affect the integrity of the Special Area of Conservation.”

She continued “An Taisce submits that neither the applicant nor the Planning Authority properly took into consideration the available alternatives. For instance, one simple alternative is redesigning the golf course. It would be more sustainable in the long term to redesign the course so that the affected holes are moved away from the coastline so that the natural protection provided by the dunes can be optimised.”

Phoebe Duvall, from An Taisce's Planning Office stated “An Taisce submits that the justification for the proposed protection works is scientifically unfounded and inaccurate. The applicant’s argument is predicated on the erroneous assertion that the coastal erosion that is occuring at Doughmore Bay and causing the loss of the dune frontage is a result of waves, sea level rise, and storms, all of which will be intensified by climate change. This is a misinterpretation of the causes of erosion and loss of dune habitat at the site. Wave action, sea level rise, and storms do not automatically result in disappearance of beaches and dunes.”

As explained by Scottish Natural Heritage [see notes below] and the NPWS [Note 7], cycles of erosion, movement, and stabilisation are both natural and essential to coastal, beach, and dune systems. Indeed in most instances, the ability of a beach to respond to periodic perturbations or long-term changes has been the key to their persistence over several millennia.

An Taisce posits that it is in fact the golf course behind the dunes, which is causing the loss of sand dune habitat. The dunes are fixed and prevented from adapting to rising sea levels and marine erosion by shifting and retreating landward.

An Taisce notes that sea defence and stabilisation works as well as the development and expansion of golf courses are widely accepted as two of the leading drivers of such sand dune loss internationally [Note 5]. The current situation in Doonbeg is a perfect example of this: the inappropriate placement, design, and management of the golf course is preventing natural coastal realignment. Unless the design of the course is altered, coastal squeeze will result in the continued loss of sand dune habitat via unnatural erosion and thus the diminution of their sea defence role and the provision of other ecosystem services.

An Taisce considers that the proposed coastal protection works will significantly exacerbate this situation as they further prevent natural dune shifting.

The NPWS (National Parks and Wildlife Service) also notes the adverse influence of the golf course [Note 7]): “The physical presence of the golf course has impacted negatively on the functioning of the sand dune as an entire system… This is most notable at the centre of the system where the golf course extends right out to the frontline. Given the fact that this system is retreating the golf course should have been located well back from the seaward edge.”

An Taisce is also concerned at the lack of information on compliance with the environmental management conditions attached to the original 1999 permission by An Bord Pleanala for the Doonbeg Golf Resort P.A Reg No. 98/655, ABP: PL03109516.

ENDS

For further information, contact:
Ian Lumley, An Taisce Advocacy Officer, An Taisce: +353 1 454 1786
Charles Stanley-Smith, Communications, An Taisce. Tel: +353 87 241 1995
Doireann Ni Cheallaigh, Planning Officer, An Taisce. Tel: +353 1 454 1786
email: publicaffairs@antaisce.org
An Taisce The National Trust for Ireland
www.antaisce.org

Notes

  1. Link to An Taisce’s appeal https://drive.google.com/file/d/1mIOet9Xw9FuMYzbpIXtoU4AdYn-PbCZh/view?usp=sharing
  2. Guidance on Appropriate Assessment for Planning Authorities - NPWS (National Parks and Wildlife Service) https://www.npws.ie/protected-sites/guidance-appropriate-assessment-planning-authorities
  3. Curr, R. H. F. et al. (2000) Assessing anthropogenic impact on Mediterranean sand dunes from aerial digital photography. Journal of Coastal Conservation, pp. 6(1), 15-22.
  4. Cooper, J. A. G. & McKenna, J. (2008) Working with natural processes: the challenge for coastal protection strategies. The Geographical Journal, pp. 174(4), 315-331.
  5. Doody, J. (1985) Sand Dunes and their Management. Focus on Nature Conservation No. 13. Nature Conservancy Council: Peterborough.
  6. Everard, M., Jones, L. & Watts, B. (2010) Have we neglected the societal importance of sand dunes? An ecosystem services perspective. Aquatic Conservation: Marine and Freshwater Ecosystems, pp. 20(4), 476-487.
  7. NPWS Carrowmore Dunes SAC Conservation Objectives Supporting Documents, 2014: Link: https://www.npws.ie/sites/default/files/publications/pdf/Carrowmore%20Dunes%20SAC%20(002250)%20Conservation%20objectives%20supporting%20document%20-%20Coastal%20habitats%20[Version%201].pdf
  8. UK Article 17 Habitat Reports: Link: http://jncc.defra.gov.uk/page-4064
  9. Heslenfeld, P., Jungerius, P. D. & Klijn, J. A. (2004) European policy for coastal dunes. In Coastal Dunes 1 Ecology and Conservation, Martinez ML, Psuty NP (eds).. Ecological Studies 171, Springer-Verlag: Berlin, p. 335–351.

Importance and Dynamics of Sand Dunes

Sand dune systems are of enormous value to both coastal environments and human populations as a result of their unique dynamism and the species this allows them to support. Scottish Natural Heritage provides a comprehensive description of a typical dune system: “Starting at the beach, a dune system may have up to five distinct zones:

  1. Strandline – the dune system begins on the beach, on the strandline, where seaweed and other debris have provided a growing medium for specialist plants such as orache and sea rocket.
  2. Foredune – some distance above the strandline and before the mobile dune, there may be a band of foredune consisting of sand couch grass.
  3. Mobile dune – larger systems have great rolling ridges of mobile sand. Held in place by marram grass (or lyme grass), the sand shifts almost daily with changes in wind direction. Storm events can remove big sections in winter, but these usually return gradually in summer. Mobility is an essential element of dune systems and shouldn’t be confused with erosion. [An Taisce emphasis added]
  4. Fixed dune – further inland, the dune becomes more and more fixed by the vegetation. On acid dunes, where there’s little seashell in the sand, dune heath can develop. Some acid dune grasslands are called grey dune, and some of these are lichen-rich. The vegetation on more alkaline systems (not all of which are machair) is dune grassland.
  5. Dune slack – in these lower-lying areas between ridges, the vegetation usually requires more moisture. Some dune slacks flood often in winter, while others are permanently flooded.”

Coastal sand dune systems support a broad range of flora and fauna owing to the diversity of the ecological niches found within them [Note 6]. Part of this diversity is due to the complex topography and its concomitant vegetation communities, creating a wide range of habitats from dry dune crests to wet dune slacks. Further internal heterogeneity is generated by location on steep dune slopes, the degree of grazing and disturbance by animals, and successional processes in both dry and wet dune habitats. The diverse niches found within the dynamic mosaic of successional stages within sand dune systems support a wide range of species. Many species dependent on dunes require early successional habitats with sparse vegetation cover and areas of bare sand [Note 6].

Aside from biodiversity, coastal sand dunes are also increasingly recognised for the ecosystem services they provide, which have important socio-economic functions. The porous structure of sandy beaches and dunes absorbs and dissipates wave energy, and stores of sand in the foredunes provide additional material which re-enters the marine transport system and forms a new beach profile after erosion events.

The National Parks and Wildlife Service (NPWS) [Note 7] set out general considerations stating: “Dunes are naturally dynamic systems that require continuous supply and circulation of sand. Sediment supply is especially important in the embryonic dunes and mobile dunes, as well as the strandline communities where accumulation of organic matter in tidal litter is essential for trapping sand and initiating dune formation.”

These natural processes allow sandy coasts to adapt their morphology and maintain their natural coastal defence role with minimal human intervention necessary, provided there is space to allow natural dynamics to operate. This natural and dynamic coastal protection created by sand dunes is more cost effective than hard engineered solutions [Note 6]. Prior to the development of the Golf Course at Doonbeg, the Carrowmore Sand Dunes had been providing a coastal protection service at no cost for hundreds of years.

Current Threats to Dune Systems

Across Europe, it is estimated that 85% of sand dune ecosystems are under threat [Note 9]. Coastal erosion is thought to impact approximately 70% of the Earth’s sandy beach environments. The causes of erosion can be of local (e.g. a decrease in sediment supply) or global importance (e.g. a worldwide change in sea level). However, erosion as a result of dune mobility is a natural process and entirely necessary for the development and maintenance of sand dunes.

Crucially, human activity presents a substantial threat to dune systems. The UK Article 17 reports [Note 8] on habitats and species under the Habitats Directive identifies “sea defence or coast protection works,”such as those in the subject application, as one of the main threats and pressures acting on embryonic shifting dunes, shifting dunes along the shoreline with Ammophila arenaria (“white dunes”), fixed dunes with herbaceous vegetation (“grey dunes”), all of which are found at the Doonbeg site. As described by the NPWS [Note 7]:

“The construction of physical barriers such as sea defences can interrupt longshore drift, leading to beach starvation and increased rates of erosion. Sediment circulation and erosion also has a role to play in the more stabilised dune habitats. Cycles of erosion and stabilisation are part of a naturally functioning dune system, where the creation of new bare areas allows pioneer species and vegetation communities to develop, increasing biodiversity. The construction of physical barriers can interfere with the sediment circulation by cutting the dunes off from the beach resulting in fossilisation or over-stabilisation of dunes.”

An Taisce considers that these facts about dune dynamics are not interpreted accurately in the applicant’s original proposal or in the Request for Further Information (RFI) responses.

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.

Pre-Draft Consultation, Southern Regional Spatial and Economic Strategy

21st February 2018
Submission Summary
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Pre-Draft Consultation, Eastern and Midland Regional Spatial and Economic Strategy

21st February 2018
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Pre-Draft Consultation, Northern and Western Regional Spatial and Economic Strategy

21st February 2018
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National Adaptation Plan highlights the Climate Change Risks to Ireland

19th January 2018
Press Release

The government’s newly published National Adaptation Framework (NAF) makes a good job of setting out the science of climate change and the scale of the challenges facing Ireland in the coming decades, and An Taisce welcomes its publication today by Denis Naughten TD, Minister for Communications, Climate Action and Environment.

In his introductory message, Taoiseach Leo Varadkar refers to the 2017 National Mitigation Plan (NMP) and states that: “no matter how successful these mitigation efforts prove to be, it is very likely that Ireland will still face substantial impacts of climate change due to past emissions”. John Gibbons, An Taisce's Climate Disruption Spokesperson stated "Regrettably, what the NMP [Note 1] in fact represented was a target-free fudge that is little more than a capitulation to special interest pressure groups. However well intended and however well funded, measures to adapt to climate change will certainly be futile unless the dangerous levels of emissions that are fuelling climate change are also tackled earnestly and urgently".

Ireland produces, per capita, the third highest emissions in the European Union [Note 2]. We are set to miss our binding 2020 emissions reductions targets by a very wide margin, exposing the Irish taxpayer to massive financial penalties in the coming decade. This failure to meet our commitments undermines EU solidarity in taking actions commensurate with the extraordinary threats posed by climate change and reduces our own ability to fund both mitigation and adaptation.

The 2018 Climate Change Performance Index [Note 3] recently ranked Ireland as the worst performing country in Europe in terms of taking concrete action to tackle climate change. The report, issued by Germanwatch and the New Climate Institute, ranks Ireland in 49th place - a drop of 28 places from 2016 - out 56 countries reviewed in the Index.

An Taoiseach was right to tell the European Parliament this week that he is “not proud” of Ireland’s role as a “climate laggard”, a position that does significant damage to our international reputation.

John Gibbons, An Taisce's Climate Spokesperson stated "An Taisce calls for an urgent reworking of the NMP so that it can begin to address the woeful performance of our transport and agriculture sectors in particular, and ensure that these sectors directly bear the brunt of the any related financial penalties in the coming years: it is right and proper that the 'polluter must pay'. Fly-tipping of greenhouse gases is every bit as repugnant as that of more visible waste, and no drones are necessary to identify those responsible."

Today’s NAF suggests that Ireland plans to focus on taking local adaptation measures in an attempt to shore ourselves up against the direct impacts of climate change rather than fully living up to our binding Paris Agreement targets on emissions reductions. This would mean that Ireland hopes to free-ride on the mitigation efforts of others.

Ireland will therefore continue to directly fuel the global climate crisis by failing to rein in our extremely high levels of emissions, and, in doing so, will also indirectly undermine already brittle international climate solidarity. “As a policy, this is politically suspect, scientifically bogus and morally bankrupt”, according to John Gibbons.

ENDS

For further information, contact:
John Gibbons, An Taisce Climate Change Committee: +353 87 233 2689
Charles Stanley-Smith, Communications, An Taisce. Tel: +353 87 241 1995
email: publicaffairs@antaisce.org
An Taisce The National Trust for Ireland
www.antaisce.org

Notes

  1. http://www.antaisce.org/articles/national-mitigation-plan-no-ambition-no-targets-no-success
  2. http://www.irishexaminer.com/ireland/irelands-co2-emissions-third-highest-in-eu-431895.html
  3. https://germanwatch.org/en/14639

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.