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: [email protected]
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.