Environmental Management Services Ltd.

1. The Heritage Service of the Department of Arts and Culture and the Gaeltacht will be involved to varying degrees in the provision of the network of facilities in the three towns referred to, and their involvement will be:

   Corofin: Provision of a facility in the village of Corofin which will include an information centre for the National Park, graphic and audio-visual displays, a nature study room for school groups, and a headquarters for the National Park.

   Kilfenora: Possible use of Kilfenora Cathedral for interpreting and displaying the monastic and architectural heritage of Kilfenora; and co-ordination with the existing Burren Centre operated by Comhar Cumainn na Boirne.

   Ballyvaughan: Co-operation with three privately owned visitor facilities so that they will accommodate interpreted material at their sites, co-ordinated with similar material at Corofin and Kilfenora.

2. The OPW state that management of the proposed centres at Corofin and Gortlecka will be closely linked, and that numbers of visitors arriving at both centres will be monitored to ensure that numbers remain within design levels. The OPW propose that there will be co-operation and information exchange between these centres, including annual review meetings, but that day-to-day management will remain a matter for each group or individual responsible for running the particular centre.

3. The OPW state in their response that, if planning permission is granted for the facility at Gortlecka, further planning applications will be submitted for facilities at the other locations within six months. The proposed facilities at Gortlecka, Corofin and Ballyvaughan, and the display of monastic and architectural heritage at Kilfenora, will be funded entirely by the Department of Arts Culture and the Gaeltacht. Strengthening of the existing permanent display "Man and the Burren" will also be substantially funded by the Department. The time scale for works to be undertaken by voluntary groups or private individuals will be dependant on, inter alia, planning permission being obtained.

   On the other hand the OPW state that, if planning permission for the Gortlecka facility is not achieved, then a reassessment of the nature, scale and involvement of the Heritage Service at the other locations will be necessary.

4. The response states that the Heritage Service will directly manage the Gortlecka facility, will fund the construction of the Corofin facility, and will occupy part of it as National Park Offices. Day-to-day management of these facilities will be contracted to a local group advised by a committee on which the Heritage Service and other local bodies would be represented. At Ballyvaughan, the Heritage Service would be only peripherally involved.

Our observations on the above responses by the OPW are as follows:

1. The queries and the replies fail to address one of the principal concerns raised in section 3 of our objection on behalf of the Burren Action Group, namely, that the construction of any new facility for visitors to the Burren must be considered premature until the Burren National Park Management Plan (which is still only in draft stage) has been adopted, and until a more detailed action plan for implementation of the Management Plan's recommendations has been produced and accepted. Furthermore, if the proposed facility at Gortlecka is constructed in advance of the recommended up-grading of the existing centres at Kilfenora, Corofin and Ballyvaughan, there is a strong possibility and a very real likelihood that it would become an irreversible focal point for visitors to the National Park. Given the sensitive location of Gortlecka within the National Park, and not on its periphery, this consequence would be highly damaging to the conservation objectives of the Burren National Park.

2. The reference in the query by Clare County Council to "a network of facilities at Gortlecka, Corofin, Kilfenora and Ballyvaughan" being an element of the draft Burren National Park Management Plan and the draft Strategy for North Clare, overlooks a fundamental difference between the location at Gortlecka end the locations of the other three facilities. The site at Gortlecka, as noted above, lies within the core area of the National Park; and it is also situated in an area of unspoiled and undeveloped landscape and fragile ecosystems vulnerable to the effects of the proposed visitor facility. The other three locations where visitor facilities already exist are on the periphery of the National Park, and are situated in well-establishment settlements, at some distance from the vulnerable core area of the National Park. A distinction should therefore be made between the facilities at Corofin, Kilfenora and Ballyvaughan, and that proposed for Gortlecka which is fundamentally flawed from a conservation point of view.

3. In relation to the this particular query, and in evaluating the response by the OPW, Clare County Council will be aware of the decision by An Bord Pleanala on 10 February 1995 to refuse permission for a proposed visitor centre at Luggala in County Wicklow. That decision cited "the impact of the centre on the fragile ecology of the area arising from the intensification of use which would lead to an unacceptable degradation of the physical environment", and "intrusion into this open upland area resulting in a significant deterioration in the character of the area and an irreversible alteration of the landscape". The attention of Clare County Council is also drawn to the visitor management strategy in the recently published Wicklow Mountains National Park Study (Department of Arts, Culture and the Gaeltacht; February 1997) which states, inter alia, that:

   • visitor facilities in general should be located outside the National Park target area in order to reduce vehicle traffic on the mountain roads and reduce pressure on the natural resources of the Park;

   • visitor centres for the National Park should be developed, where possible, in partnership with local communities, in a number of separate locations, on existing main traffic routes; and

   • their location should provide good opportunities for co-operation with local and regional enterprises (paragraphs 4.33.4 and 4.43.3; pages 146 to 148).

   While the scenery and ecosystems of the Burren and the Wicklow Mountains National Parks are clearly different, there is sufficient similarity in their conservation requirements and management objectives to make the above decision and statements very relevant to the question of the proposed visitor facility at Gortlecka. Furthermore, the essential points of the visitor management strategy for the Wicklow Mountains National Park reinforce our conviction that the mention of the Gortlecka site in the Burren Draft Management Plan, and the current planning application for a visitor entry point shelter on the site, derive principally from the existence of the partially constructed Visitors' Centre (raised in section 3 of our objection dated 6 December 1996 on behalf of the Burren Action Group).

4. In response to the query by Clare County Council about the nature and scale of the developments proposed at other locations, the replies by the OPW gave some indication of the nature, but not of the scale. In particular, the OPW appear to have no basis for predicting or controlling the numbers of visitors to the facilities at Kilfenora, Corofin and Ballyvaughan. Since each of these facilities is or will be located in an existing settlement, their ability to absorb and cater for a larger number of visitors than predicted will be significantly better than at an isolated site such as Gortlecka; nevertheless an estimate of numbers should have been provided by the OPW. In the absence of such an estimate, even the most basic aspects of facility design such as car parking spaces, toilets and catering facilities cannot be planned effectively.

5. The reply by the OPW indicating that the Heritage Service proposes to obtain transfer of Kilfenora Cathedral from the Church of Ireland, and to use the Cathedral as an interpretative centre, suggests that this potential facility is still only a probability, and has not yet reached any detailed planning stage. The permission of the Representative Church Body would be required, and no alternative plan appears to be in place if this permission is not received.

6. Independently of our fundamental objection to the Gortlecka site, it would appear that the degree of integration proposed by the OPW is adequate, especially in relation to information exchange and the provision of signs directing visitors from one facility to another. The proposal to monitor visitor numbers arriving at Gortlecka does not address the question of how such monitoring will keep the number of visitors within the facility design level and the carrying capacity of the site and its surroundings. The OPW has offered no proposals for controlling visitor numbers should they exceed the capacity of any particular centre or the network of facilities as a whole.

7. The County Council's query on the time-scale for the provision of visitor facilities has not been adequately answered by the OPW. In particular, it is iniquitous to state that proposals for other facilities will depend on planning application being granted at Gortlecka, and that if permission is not granted, the Heritage Service will re-assess its involvement at the other locations around the Burren National Park. The response appears to be intended to put pressure on the planning authority to grant permission for the facility at Gortlecka, after which substantial funds would be allocated by the Heritage Service for the network of facilities as a whole. If planning permission is not obtained, then the implication appears to be that funding by the Heritage Service and its involvement in the management of visitor facilities in County Clare would be substantially reduced. The County Council will be aware of the adverse response by some elected members to what has been described as an interference with the local authority's ability to determine the application on its own merits (see, for example, the Irish Times dated 17 March 1997).

3. Prediction and Management of Visitor Numbers

In the request for additional information, Clare County Council acknowledged specifically that the management of visitor numbers will require the implementation of tourism development proposals as set out in the draft strategy for North Clare and that the prediction of visitor numbers is a difficult task. The OPW were therefore asked:

1. To indicate how they would implement the tourism development proposals as outlined in the draft National Park Management plan and strategy for North Clare; and,

2. To indicate how they would manage visitor numbers at the Gortlecka site in the event of the discouragement measures proposed not being effective.

In their response, the OPW stated that the role of the Heritage Service will be:

1. To provide or assist in the provision of interpretation and information on the natural heritage of the Burren at Corofin, Kilfenora and Ballyvaughan, and to publish a new strategy document on the national monuments and archaeological sites of the Burren. This strategy document will recommend a cohesive approach to access and presentation of national monuments and archaeological sites, and public comments will be invited.

2. If the proposed methods for discouraging visitors are not effective (a situation which the OPW consider very unlikely, but which the Burren Action Group considers to be a very probable occurrence), it is stated that the Heritage Service will provide advance signs at Kilnaboy Cross indicating to visitors that the Gortlecka facility is full and closed to the public. An electronic link will also be provided to the Corofin centre as part of a visitor management system which will provide information on the total number of vehicles in the Gortlecka car park at any one time. The changeable sign at Kilnaboy can then be used to redirect visitors to the Corofin or Kilfenora centres.

Our observations on these responses by the OPW are:

1. The OPW reply completely fails to address the concern shown by the County Council regarding the difficulty of predicting visitor numbers. In our objection to the proposed visitor entry point, we noted (section 8) that the planning authority should request a report from the applicant describing the precise basis on which the estimate of 35,000 visitors per annum was made. This is an extremely conservative estimate, particularly in view of the fact that none of the other National Parks in Ireland which have visitor facilities received less than 70,000 visitors in 1995. There also appears to be a significant lack of consistency among the various estimates of visitor numbers given by the OPW in their current response to queries and in previous submissions, including the two environmental impact reports.

2. Since the National Park Management Plan and the Strategy for North Clare are still both draft documents, then it cannot be possible at this stage for the OPW or the Heritage Service to describe their roles in the implementation of the strategy with sufficient detail.

3. The proposals for managing visitor numbers appear to be confined to redirecting visitors from one facility to another. No methods are described for preventing visitors from parking cars along the road-sides leading to and from the Gortlecka facility, particularly if the car park in that facility is full. It cannot be assumed that visitors seeing a sign indicating this fact would automatically go to the next available centre; instead it is quite likely that they will park on one of the nearby roads and either walk back to the centre or walk in an uncontrolled fashion across some of the unfenced and easily accessible areas of the Burren.

4. Removal of Overflow Car Park

Clare County Council also noted the proposal by the OPW to totally dismantle the work carried out to date on the overflow car park at Gortlecka, and asked the OPW to indicate:

1. Why such dismantling is proposed; and,

2. Their proposals for managing car parking in the event of demand exceeding the capacity of the main car park.

In response to the query about dismantling the overflow car park, the OPW state that the main car park as proposed will be sufficient to cater for the projected number of people visiting the Gortlecka site. The reply restates that since there will be no exhibition, audio-visual theatre or restaurant, the entry point will not be an attraction in its own right; its sole purpose will be to provide assembly and toilet facilities for walkers. In the event of car parking demand exceeding the capacity of the main car park, the Heritage Service will provide a changeable sign at Kilnaboy and further sign will be placed at the entrance to the Gortlecka car park indicating that it is full, and giving directions to other locations where visitors may park.

It is quite inadequate to state that the capacity of the proposed car park will be sufficient to cater for the number of visitors, especially when no basis has been provided as to how that number has been calculated or predicted. The example of what has happened as the Cliffs of Moher following construction of a visitor facility should be a salutary lesson, which appears to have been ignored in the current application.

5. Management of Bus Traffic

Clare County Council expressed the view that it might not be possible to prevent buses from travelling to the site, and in order to enable the Council to consider this matter more fully, the OPW was asked to indicate:

1. How they propose to prevent buses travelling to the proposed facility, and;

2. How they propose to manage bus traffic which may travel to the site, and which could result in unacceptable parking of such vehicles on the public roads.

In their reply, the OPW state that:

1. Bus companies will be informed that the Gortlecka facility will not accommodate full-size touring buses, but that mini buses will be acceptable. Groups of visitors larger than 30 will be actively discouraged in the OPW literature and promotional material, and such groups will be directed in the first instance to the Corofin centre.

2. The OPW state that they do not expect full-size touring buses to arrive at peak periods after bus operators have been informed about the situation. If any such buses do arrive, they will be allowed to turn back and will be redirected to Corofin or Kilfenora. At non-peak times such buses will be allowed to park in the car park.

These proposals by the OPW to control bus traffic appear to be weak and inconsistent for the following reasons:

1. In the first instance, while most responsible tour operators will clearly take note of any advice given in the promotional literature, it may not be possible to prevent buses arriving unexpectedly when car traffic is at a peak.

2. There is no logical basis for the OPW statement that they do not expect full-size touring buses to arrive at peak periods, and in any event that statement takes no account of the problems which would be caused by such buses arriving during off-peak times. Even if these buses are redirected to Corofin or Kilfenora, their presence on the road will still cause significant traffic congestion as most of the approach roads are too narrow to allow a bus and a car to pass each other.

3. If full-size buses are allowed to park in the car park at off-peak periods, this will create an uncertainty in the tour operator's minds, leading to the possibility that some buses will arrive hoping to find space in the car park. Even if the car park is not full, considerable amount of traffic congestion could be caused by buses manoeuvring in and out of it.

In our view, one effective way to enforce such controls would be to erect signs prohibiting full size buses at all times, and for the Minister for Transport Energy and Communications to make an order under Section 94 of the Road Traffic Act 1961. Such an order could prohibit the driving of any particular class of vehicle on any specified public road if it can be proved that the road is unsuitable for use for that class of vehicle. However, the making and enforcing of such an order would require the act of co-operation of Clare County Council.

A further, and more effective, solution would be restoration by the County Council of the original junction between the Kilnaboy-Carron road and the side road leading to the Gortlecka site. Prior to road widening, this junction was too constricted to permit the passage of full-scale buses.

6. Upgrading of Access Roads to Site

Clare County Council noted that in the event of the proposed development going ahead, the Council would require that the access road to Gortlecka should be upgraded to the standard necessary to carry anticipated traffic loads, and to facilitate local domestic and agricultural movements. In the request for additional information, the County Council asked the OPW to indicate whether funds are available to enable these road works to be carried out, and to confirm that such funds would be given to the local authority to carry out such works.

In reply, the OPW recognised the need for improving the access road to Gortlecka at several locations, and stated that a contribution of some £400,000 was made in December 1990 to Clare County Council for these improvements.

There is clear indication of a discrepancy here between the views of Clare County Council and the OPW. The County Council appear to be of the opinion that funds must be provided at some time in the future to enable them to carry out road improvement works which the Council consider necessary. On the other hand, the OPW appear to be of the view that the required contribution of £400,000 was made to the County Council in December 1990.

The situation confirms our view that the question of road upgrading has not been addressed adequately. In our objection to the proposed visitor facility at Gortlecka we noted that "the narrow network of county roads are unsuitable and cannot be upgraded without seriously damaging their environmental quality", and we suggested that the Applicant should be requested to state at this stage which sections (if any) of the access roads (county roads 102 and 103) would need further improvement, and in particular how many passing bays would be needed on the road from Kilnaboy in the event of the proposed entry point being permitted.

In addition, among the characteristic features of the Burren landscape are the stone walls and road-side margins providing attractive habitats and unique communities of wild flora which have developed over many decades. Any significant road widening would clearly destroy these important features of the landscape which contribute to its attractiveness and uniqueness.

7. Impacts on Candidate Natural Heritage Areas and Special Areas of Conservation

In the request for further information, Clare County Council asked the OPW to indicate the areas of the Burren National Park in the vicinity of the proposed development which are likely to be designated as Natural Heritage Areas or as Special Areas of Conservation, and to indicate the relationship between such areas and the proposed walk-ways which will be associated with the Gortlecka visitor facility.

In their reply, the OPW state that the National Parks and Wildlife Service has proposed certain areas as NHAs and will shortly be proposing other areas as SACs. The NPWS will be managing the proposed facility, and they are satisfied that the development including associated nature trails will not have any significant adverse impacts on the areas proposed for designation as NHAs or SACs. The visitor facility, nature trails and all areas of the National Park in the vicinity are within these proposed NHAs, and are also likely to be designated as SACs.

In our view, this response is totally inadequate as it fails to specify which particular areas have been designated (or may soon be designated) as NHAs and/or SACs. It is our understanding that the Gortlecka site is within the boundary of an NHA/SAC designated area; if permission is therefore granted for any development within such an area, particularly development by an agency of the State, it would create an extremely bad precedent and send out the wrong signals regarding the State's commitment to environmental protection and conservation.

Given the widespread knowledge of the fragility of Burren ecosystems and their vulnerability to large numbers of people walking across them, it is insufficient merely to state that the NPWS is satisfied that the proposed visitors centre will have no significant impact on the areas proposed for designation. Furthermore, no detailed information about the proposed nature trails has been provided, nor has their likely impact been assessed.

8. Relationship of the Proposed Development to the Burren National Park Draft Management Plan and Draft Strategy for North Clare

Clare County Council, in the request for additional information, asked the OPW to indicate the status of these documents and the degree to which they were being relied upon to support the application for planning permission.

The OPW in response, have provided a short history of the origin and preparation of the draft management plan for the Burren National Park. The response notes that "as the development at Gortlecka is set within the context of the overall strategy outlined in the draft plan, the Minister has determined that on receipt of planning permission for the entry point he will confirm the strategy outlined in the plan". On the other hand, if planning permission is refused, the Minister will ask the steering committee to propose amendments to the plan before its adoption. The OPW also states that the Draft Management Plan for the Burren National Park, together with the strategic plan for tourism in the Burren, formed the basis for the Minister's policy in relation to the Burren National Park, and these documents provide the philosophical, organisational and strategic context for the present planning application.

It should be noted again that the inclusion of a development at Gortlecka within the overall strategy of the Burren Draft Management Plan, and the current planning application for a visitor entry point shelter on the site, appear to have no logical basis other than the requirement to make some use of the partially constructed Visitors' Centre. In the absence of the construction already carried out, we believe that the Gortlecka site would have received no mention in the Burren Draft Management Plan.

The County Council may also note that the semantic content of the above response is that the OPW are making further threatening noises regarding the consequences of not being granted planning permission for the facility at Gortlecka. The "amendments to the plan", which would be requested before its adoption if planning permission is refused, are not specified. In order to avoid uncertainty and confusion, and to allow the planning authority to make a well-informed and unhindered decision, the OPW should provide a clear indication of what amendments will be made to the existing draft management plan for the Burren National Park in the event of planning permission being granted or being refused for the facility at Gortlecka (both options should be clearly identified). Otherwise we are forced to conclude that the OPW are attempting to use certain provisions of the draft Burren National Park Management Plan as "bait" to achieve their objective of a development at the Gortlecka site.

Jack O'Sullivan

21 March 1997

Comments to burrenag@iol.ie

Table of Contents