Submission to Skelligs Management Plan
An Taisce welcomes the opportunity to make the following comments on the December 2018 Skellig Michael World Heritage Site Management Plan 2019-2029.
PRELIMINARY LEGAL ISSUE Screening is required for Strategic Environmental Assessment (SEA) and Appropriate Assessment under the Habitats Directive as a preliminary matter. No information has been provided in the consultation call as to how this is to be carried out.
INADEQUACY OF CONSULTATION PROCESS PROVIDED The process of seeking pre-Draft Plan consultation on the formulation for a further decade of the Management Plan for one of the State’s two World Heritage Sites is welcome. However the manner in which the process has been initiated does not reflect the serious engagement with public, stakeholder and NGOs, that meaningful consultation requires.
The undertaking of any pre Draft consultation on a new plan should provide information on the outcome of the previous plan. The 2008 WHS Management Plan contained 67 Actions. An essential preliminary action in any consultation is a plan review to provide oversight of the achievement of the previous plan actions and identification of areas in which actions have not been met. In this case it would be expected that the consultation call would provide a performance review of the 2008 WHS plan in relation climate, physical conservation of the monument and associate features, ecology, visitor impact, safety and capacity, and promotion and marketing.
In the case of a number of the actions, particularly those related to monitoring climate and bird population and visitor impact, the data provided will be an important consideration in the future management of the site and any interventions needed.