TIGL rebuttal provides more data on Doonbeg, but not sufficient proof
The controversial Trump International Golf Links (TIGL) proposal for coastal walls at Doonbeg, County Clare is back in the limelight, with An Taisce and others commenting on the rebuttals made by TIGL as part of an ongoing planning appeal to An Bord Pleanála.
TIGL have applied to install two coastal defence structures, totalling approximately 1km in length, in an effort to prevent further erosion of their links golf course. Clare County Council approved this development, despite two separate internal scientific reports, one commissioned from an ecological consultancy and the other from their own Environmental Assessment Officer, which both highlighted how the limited data were not sufficient to rule out impacts on the dune system.
TIGL have previously carried out similar works on a golf course in Aberdeenshire, Scotland, with detrimental impacts on that dynamic dune system. 
The beach in question incorporates the protected Carrowmore Dunes Special Area of Conservation (SAC), which the NPWS consider the best dune system in County Clare, and is of considerable European conservation importance. 
Several parties, including An Taisce, appealed this planning decision by Clare County Council to An Bord Pleanála on the grounds that the defence structures could permanently alter and degrade the dynamic dune system. An Taisce argued that there was insufficient evidence to demonstrate that the dune system, which is legally protected under the European Habitats Directive, would not be impacted.  This echoed the concerns voiced by JBA ecological consultants, Clare County Council’s own Environmental Assessment Officer and the NPWS.
The primary grounds of the appeal were that insufficient long-term data was available to model the potential impacts of the defence structures on the coastal erosion processes. The structures could irrevocably alter the dune habitats, with unforeseen impacts such as increased erosion on the neighbouring unprotected dunes.
While TIGL included some further sediment modelling in their response, the additional data were the result of three surveys covering a period of just 10 months, not the long-term data which was deemed necessary.
Their response also appears to imply that An Taisce, and others, didn’t understand the specifics of the dune system, despite the appeals being largely based on reports from Clare County Council’s own Environmental Officer, and an ecological consultant they hired to assess this specific development, in addition to documentation from the NPWS on the SAC itself.
Although the response by TIGL is a catalogue of rebuttals of the various appeal points, An Taisce maintain that they have still failed to address the fundamental issue, which is that the data they are relying on is insufficient to prove the development won’t negatively impact on the protected dunes. This is a legal requirement under Article 6(3) of the Habitats Directive . The only way to address this is to gather several more years’ worth of data.
An Taisce believe that An Bord Pleanála should overturn the decision by Clare County Council, who appear to have granted permission for this development against their own internal scientific advice, and in contravention of the requirements of Article 6 (3) of the Habitats Directive. The dune system is of European conservation importance, and in this age of a declared biodiversity emergency it is vital that any development in this ecologically sensitive area is carefully considered, despite the high profile nature and economic benefits of the proposed development.
Dr. Elaine McGoff, Natural Environment Officer with An Taisce, said:
‘TIGL have still failed to provide the necessary data, despite hundreds of pages of rebuttals. They can argue the toss and endlessly pick holes in the various appeals, but the fact remains that without sufficient data the science simply isn’t sound’
Phoebe Duvall in An Taisce’s Planning Office, added:
‘Given that the ecological consultants hired by Clare County Council, the Council’s own Environmental Assessment Officer, and the NPWS all expressed concerns regarding the environmental impact of this proposal, and the lack of necessary data, we question how the decision to grant permission was made in the first place. This is a protected site, the reasons for approval of any development in this area must be transparent and defensible.’
Ian Lumley, Advocacy Officer with An Taisce said:
‘The conservation of sand dunes internationally has proven that they are more cost effective at protecting the coast than hard sea defences 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’
An Taisce’s submission to ABP http://www.antaisce.org/sites/antaisce.org/files/20190528-abp-300535-17.pdf
For further information, contact:
Dr, Elaine McGoff, Natural Environment Officer, An Taisce: +353 1 707 7063
Charles Stanley-Smith, Communications, An Taisce. Tel: +353 87 241 1995
An Taisce The National Trust for Ireland
- 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. BBC report on the detrimental effects of the TIGL golf course in Aberdeenshire, Scotland http://www.bbc.com/news/uk-scotland-41845278
- NPWS (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
- Paragraphs 6(3) and 6(4)of the Habitats Directive lay down the procedure to be followed when planning new developments that might affect a Natura 2000 site. Thus:
Any plan or project likely to have a significant effect on a Natura 2000, either individually or in combination with other plans or projects, shall undergo an Appropriate Assessment to determine its implications for the site. The competent authorities can only agree to the plan or project after having ascertained that it will not adversely affect the integrity of the site concerned (Article 6.3)
An Taisce - Protecting Ireland’s heritage, safeguarding its future
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.