Re: Planning application by the Commissioners of Public Works in Ireland (on behalf of the Minister for Arts, Culture and the Gaeltacht) to Clare County council for planning permission for an entry point, at Crag Road (CR103), Gortlecka and Knockaunroe, to the Burren National Park, comprising covered waiting area, toilets, ranger accommodate, ancillary parking, storage and signage (Ref. no. P96/1330).
Following the enactment of the Heritage Act, 1995, the Heritage Council was appointed on 10 July, 1995. Under section 6(1) of the Act,"the functions of the Council shall be to propose policies and priorities for the identification, protection,preservation and enhancement of the national heritage, including monuments, archeological objects, heritage objects, architectural heritage, flora, fauna, wildlife habitats, landscapes, seascapes, wrecks, geology, heritage gardens, and parks and inland waterways".
The establishment of a National Park in 1990 and the policies currently pursued by the National Parks and Wildlife Service (NPWS) have major implications for the protection, preservation and enhancement of the Burren, as part of the national heritage. It is in this context that the Heritage Council recommend that you give due consideration to the comments presented below.
1.The Burren National Park adheres to the World Conservation Union (IUCN) management Category II. The IUCN is the leading international professional network on the selection, establishment and management of national parks and other protected areas. As currently applied in Ireland, the IUCN management Category II requires that all of the land within the National Park is state owned. In the context of overall sustainable development in areas such as the Burren, where farming practices have created and maintain the semi-natural ecosystem, and where the extensive area forms a discrete geological entity, almost all of which is of conservation value, this approach is inappropriate. The establishment of a state owned parcel of land which comprises approximately 1562ha to conserve the ecological and landscape integrity of an area which comprises approximately 500 sq km (50000ha) is inadequate. Conservation measures must be adopted to deal with the total landscape unit which is the Burren, and to attempt to integrate conservation and best practice in all activities in the region.
Recommendation: The Council advise that a policy of protected landscape in the Burren conforming to IUCN management Category V should be pursued. In the IUCN publication "Parks for Life", such an approach for Ireland is advocated, and its application in the Burren is entirely appropriate.
2. The choice of site for the current application is based on the Brady, Shipman and Martin study, which confines itself to the existing National Park boundery. There is no question but that the area in the vicinity of Mullaghmore, Lough Gealain, Knockaunroe and Trauvaun is of extremely high conservation value, and should be afforded the highest level of protection possible. However, the current boundary of the National Park bears little or no relationship to ecological, geological or landscape boundaries, but is based almost exclusively on land ownership. The delineation of the National Park should be based upon meaningful and defensible ecological, geological or landscape boundaries, and if this principle is followed, there can be little justification for the current National Park boundary. It is the view of the Heritage Council that the present extent of the National Park, and the habitats that it protects, should comprise the core area of any management system, where no visitor facilities or other structures are constructed. This is to ensure that in protected areas the special attributes which lead to and encourage the development of tourist economies are not themselves threatened. The Federation of National and Nature Parks in Europe (FNNPE) have recognised this in their recently published document Loving them to death? Sustainable tourism in Europe's Nature and National Parks in which it states "the tourism sector should promote the idea that, in protected areas, breath taking scenery and glimpses of wildlife are only revealed to those that make the effort.". To protect this sensitive area, the boundary of the National Park should be extended, particularly to the south and southwest as far as Kilnaboy and Corofin. Visitor facilities, on whatever scale is deemed necessary, could then be provided in areas of existing infrastructure, well away from the core area of the National Park. Building on the strengths of the existing community based centres in the vicinity should be actively pursued.
Recommendation: Following detailed public consultation, and meaningful community participation, that the boundary of the National Park be extended, particularly to the south and southwest, so that the National Park extends to the main Corofin to Kilnaboy road, and incorporates the wetlands extending to Lough Atedaun at Corofin. The extension of the National Park could be by way of partnership agreement with land owners.
3. The concept of zoning is an important part in any management strategy for a National Park, and this is recognised in the Draft Park Management Plan (Brady, Shipman and Martin). In the Draft Park Management Plan three zones are identified; The Natural Zone, the Cultural Zone and the Intensive Management Zone, with the Natural Zone covering "the majority of the Park". The two other zones comprise just small areas within the present National Park and cannot be considered zones in the recognised meaning of the word. It is clear that this zoning system is inadequate. A zoning system needs to be considered in relation to the total Burren area if it is to have any practical meaning or application from a management perspective. This would be a prerequisite if a policy of protected landscape conforming to IUCN management Category V was pursued.
Recommendation: that a zoning system is developed for the Burren as a whole, and that there is an adequate buffer zone surrounding particularly sensitive habitats such as the oligotrophic wetlands of Lough Gealain and Knockaunroe. For these hydrologically dependent habitats, a catchment based zoning system should be developed.
4. Much of the area in the immediate vicinity of the Crag Road is a Priority Habitat under EU Directive 92/42/EEC (the Habitats Directive), and consequently is of high conservation value. The oligotrophic wetlands in particular are highly susceptible to damage through nutrient enrichment. The measures being recommended as part of the construction work to limit harmful practices at the construction site, as described in the Gortlecka Environmental Background Document, highlight and recognise the sensitive nature of the area. Whether or not the proposed development at Gortlecka will actually cause damage to the area in the long term is a subject of dispute, but adherence to the precautionary principle of sustainable development would preclude the development progressing as there is a risk that some damage could ensue.
Recommendation: to adopt the precautionary principle of sustainable development within the National Park, and to ensure that no development which even presents a risk of damage is undertaken, particularly in close proximity to the oligotrophic wetlands.
5. While some management objectives are presented in the Burren National Park Study, there is a general absence of specific management strategies. This not only applies to the Burren National Park, but is a major weakness in almost all of the National Parks in Ireland. Without details of specific management strategies it is impossible to assess adequately the impacts of the proposed development on the National Park.
For instance, one of the issues central to sustainable tourism in the context of the Burren National Park is visitor pressure and traffic flows, yet there is little tangible management strategy to deal with the issue. In particular there are few contingency plans to cater for an unacceptable level of traffic to the area, should this arise in future. In this context, the statement in the Gortlecka Environmental Background Document that "should the level of usage at any time conflict with conservation requirements, the NPWS would use available measures to reduce the number of visitors (e.g. information adjustment of opening hours, etc.)", is meaningless. How for example, is the "conflict with conservation requirement" to be monitored or assessed, and what are the precise strategies that will be used to reduce the numbers of visitors?
A comprehensive management plan should incorporate a worst case scenario, and have a contingency plan to cater for such a scenario should the need arise. There is no consideration presented in the context of the current planning application, which is a serious weakness in the proposal, and once again, the precautionary principle should be applied.
Recommendation: ensure that a detailed management plan, including specific management strategies, is prepared for the Burren National Park before any tourist facilities are planned.
6. Much of the justification for proceeding with the construction of a limited nevel of visitor facility at Gortlecka is the statement in the Burren National Park Study that the "site at Gortlecka, where it was proposed to develop the major visitor centre, remains the most suitable location for any such facilities". The Heritage Council does not agree that this is the logical conclusion to be drawn from the study. Indeed, the Burren National Park Study, prepared by Brady, Shipman and Martin, was presented in a draft form, and accepted by the Minister as a discussion document for public consultation over a twelve week period.
While the Heritage Council welcomed the consultative process as outlined at the time, it is disappointing that the finalised version of the Burren National Park Study, incorporating the various submissions made on the draft document, was not published. The merits of the Brady, Shipman and Martin study cannot be assessed adequately until this is done.
Recommendation: complete the consultative process as outlined in the press release of 20th February 1996 by the Department of Arts, Culture and the Gaeltacht, and publish the final version of the Management Plan for Burren. Prior to the publication of this plan, in the light of the earlier recommendations, the merits of this application cannot be competently assessed.
The Heritage Council has a number of specific comments on the planning application which are outlined below.
7. It is noted that some of the information accompanying this planning application is inaccurate.
In the light of these inaccuracies and omissions, it is not possible to assess the full implication of this planning application.
8. The proposal to construct a visitor facility at Gortlecka is based largely on the assumption that "without promotion and signposting it is unlikely to attract additional visitors to the area". This is a sweeping statement not based on any objective assessment criterion. The central issue in predicting whether or not the provision of a visitor facility at Gortlecka is likely to impact negatively on the conservation objectives of the area, is the availability of credible visitor projection figures.
The Gortlecka Environmental Background Document states that "it is not possible to predict with accuracy the number of visitors who would be attracted to the Gortlecka National Park entry point "because "there are few natural attractions similar to Gortlecka with car park facilities only". It should be noted that the "natural attraction" of the Cliffs of Moher originally had no facilities of any kind, yet is currently the principal visitor attraction in the area attracting up to 900,000 visitors annually. This illustrates that there has not been adequate consideration of visitor trojection figures, therefore, it is impossible to determine the likely future impact of the proposed development on the area.
In general, the Heritage council is concerned that, by having a visitor facility in place, irrespective of scale, there is no adequate mechanism to control the number of visitors to the site. The proposal could lead to an uncontrollable increase in visitor numbers, which would require further development at a later stage to manage the extra visitors. Adopting the precautionary principle, this would result in a decision not to proceed with the proposed development, due to possible future difficulties.
It is the opinion of the Heritage Council that the plans for, and the controversy surrounding the construction of a visitor facility at Mullaghmore/Gortlecka, is a symptom of a more fundamental problem associated with the establishment of the Burren National Park and the management of the Burren landscape as a whole. Until some of these fundamental problems are confronted, there cannot be an effective conservation policy in the Burren, nor should a decision be taken in favour of this application.