Coillte and Lough Key Forest Park. Heritage rape,and fraudulent "Ecotourism".
There were no attempts made by Coillte Teo. to consult with the local communities or NGOs regarding the sale or development of their land at Lough Key, Roscommon, to the Newfound Consortium.
The 865 acres of mixed woodlands and open parkland, as well as a 6 mile diameter lake and a number of islands, were all formerly part of the Rockingham Estate and include 23 protected structures recorded in the Roscommon County Development Plan.
All the planned developments will be within the bounds of Lough Key Forest Park. If the planned developments go ahead, 140 hectares of the 350 hectares comprising the park, or 40% of the park, will be developed. In total, there is one hotel, one 18-hole golf course and 304 holiday homes planned for the site.
The planning saga typifies the planning cases that arise again and again with heritage sites that are patently unsuitable for development – useless – if any -interventions by the Department of the Environment, key missing pagers from the EIS, material contraventions of Development Plans without any assessment..
So too has gone Lough Rynn and Lough Muckno. As we wrote in reviewing this and other Coillte sales in February of this year, (2005)‘Coillte’s Chief Executive has said that more than 40 separate negotiations for sale of their lands are ongoing at any one time. How many of these developments are fundamentally incompatible with the natural heritage, historical value and landscape quality of their locations?’ How many demonstrate any real consultation?
Coillte Millennium Forest snub to FOI Commissioner .(freedom of Information)
A Eagarthóir, a chara,
In the past few issues of FNN, I drew attention to the manner in which the Forestry Division and Coillte Teoranta tried to keep secret the sweetheart deal done to placate AIB at the time of the Millennium Forests Project. They succeeded for five years but in the end the FOI Commissioner won the day.
Amongst the more disquieting aspects of Coillte's tactics was its decision to ignore correspondence from the Commissioner. I quote from the Commissioner's decision to release the records, a decision that Coillte did not challenge in the High Court:
"As Coillte did not reply, I [FOI Commissioner] find that I am not in a position to consult with the AIB as even giving a description of the information relating to the AIB ["AIB refused to stay with the project unless the Millennium Committee matched their money"] would involve the disclosure to AIB of information relating to Coillte which is argued as being exempt."
Not only did Coillte snub the FOI Commissioner but allowed information into the public domain which reflects badly on its partner AIB.
To be continued.
Le gach dea ghuí
Éamonn Ó Flannagain
4. PARLIAMENTARY REPLIES
Coillte EU € 8m clawback – who pays? (the taxpayer -as usual)
444. Mr. Sargent asked the Minister for Agriculture and Food if, in view of recouping from Coillte Teoranta circa €8 million of forestry premium grants awarded to it but subsequently excluded from Community financing under the guarantee section of the European agricultural guidance and guarantee fund, and confirmed by a European Court, she has made a decision regarding seeking the return of these funds from Coillte Teoranta. [31508/05] Minister for Agriculture and Food (Mary Coughlan): A final decision in this matter has not been made as yet but the issue is being examined in consultation with the Department of Finance.
5. . EVENTS
12th November 2005 at 12 noon.
Meeting of the Woodland League: WLL going to Brussels
Independent South MEP Kathy Synnott has asked Brendan Kelly and Andrew St. Ledger of the Woodland League to travel to Brussels to meet with the EU commission. It is the intention of Andrew and Brendan to bring as many cases as possible of communities negatively affected by coniferisation and plantation style tree crops. With this in mind, the WLL are making the call to communities that read this to contact us to have their stories heard. The time is running short, as Brendan and Andrew will be travelling on Sunday
the 20th of November (just over 2 weeks). However, it is likely that the WLL will be asked to return to Brussels early in 2006, so if it is not possible to make a submission before the 20th of November, be sure to make it by the end of the year. The WLL are hosting a meeting on Saturday the 12th of November to discuss their trip to Brussels. See site for details. The venue is to be decided, though it will be in the East Galway/Clare region. We aim to make it as central to a large town as possible, to facilitate transport..
several issues that they intend to raise in Brussels, including:
* Sustainable Forest Management/FSC in Ireland, the lack thereof, and the use of the State in using FSC to verify SFM commitments
* Lack of proper consultation in developments, both in forestry and on a wider basis
* Lack of proper independent Environmental Impact Assessments in developments
* The inadequacy of the Forest Service in enforcing national and international laws on forestry and the environment
* Specific case studies - including for, example, Rossport, Lough Key, Derrybrien
* Etc. etc.
The meeting is open to all who wish to attend. Apologies for the short notice for the meeting.
The Woodland League
OPEN LETTER TO THE ROSSPORT FIVE 5th October 2005. The Woodland League would like to salute and acknowledge the integrity, bravery and commitment of the Rossport Five, at a time when so many Irish people are compromised or have sold out on their communities, where corruption is considered normal, where wealth is given precedence over health and human beings are reduced to simple economic values as consumers, where economists
(who are meagre money quacks operating in an imperfect science that ignores social and environmental impacts in its blind calculations) are elevated to high status’ in the spiritual vacuum that is Ireland and the Irish economy. The sacrifice and subsequent release of the Rossport Five draws a line in the sand which challenges the rot in Irish life and inspires the multitude of other communities under siege by big business, aided and abetted by the elected representatives, the supposed servants of the people. Thank you on behalf of the many communities and groups we represent and assist. Always remember the old Druidic triad of Éicse, Fior agus Dúlra (Wisdom, Truth and Nature) – the three candles that illuminate any darkness. The Woodland League Andrew St. Ledger, PRO, +353-(0)87-9933157
6. ARTICLE OF THE WEEK Nov 2005
6.1 Planning objections from outside the county have cast a dark shadow over Boyle
The news this week that appeals have been lodged against the proposed eco-tourism development beside Lough Key Forest Park in Boyle has been met with shock and disappointment locally.
The plans to transform the area into a massive tourism attraction have been widely welcomed by public representatives and communities in the entire North Roscommon region.
Everyone has the right to object and make observations on proposed developments, large and small, with a view to doing so for the greater good. However, it is also essential to take on board the needs of the area and this is where the local argument in support of the project is strong.
Following years of neglect, Lough Key Forest Park is finally getting the upgrade that it needs with works beginning this week on the plans by Coillte and Roscommon County Council for the park itself.
Despite this move many would agree that Boyle has been left behind by the Celtic Tiger and has found it difficult to attract new industries and businesses to the town for various reasons.
New hope had dawned with the prospect of the multimillion resort plans for the area beside Lough Key. Throughout the summer the first signs of growth and development in the town emerged, with new local businesses opening up.
Now, however, objections from outside the county have cast a dark shadow over Boyle, leaving people within the community once again deflated and disappointed that they have no say in what happens in their area.
It is clear that something is needed to drive the future growth and development in Boyle and its surrounding areas. Whether we will be given the opportunity to sample the offerings of ecotourism, however, remains to be seen.
© Roscommon Herald
Wednesday, September 14, 2005
6.2 Lough Key Forest Park - Planning for Newfoundland Consortium project
Roscommon Co Council has passed a 'material contravention' (if you know what that means exactly, let me know) to allow the Newfoundland Consortium's third and final proposal to proceed to the planning stage. On the day, 22 members voted in favour of the proposal and 1 voted against. Cllr. John Cummins said the development would be of huge economic benefit to the region. Cllr. Rachel Doherty said the project had the potential to transform the area and described it as a "unique tourism project in the west"
Current Boyle.com website
6.3 Lough Key Forest Park Appeal
Description of Lough Key Forest Park
Lough Key is located just east of Boyle, County Roscommon. It comprises of approximately 350 hectares (865 acres) of mixed woodlands and some open parkland, as well as a lake that is 6 miles in diameter and a number of islands. This was formerly part of the Rockingham Estate, home of the Stafford King Harmon family.
There are several archaeological points of interest, principally the ruins of a McDermott castle and two medieval priorities, one on Trinity Island and the other on Church Island, but also including several ring-forts, the Fairy Bridge, and more.
You can see the entire park from the Moylurg Tower, built on the site of Rockingham Mansion, which was demolished in the 1960's following a fire. Brian Og MacDermotts estate was handed over to the King family in 1617 which was
formerly owned by the Cistercian Abbey in Boyle. The original grantee was Sir John King who built a great house only to have it pulled down by his grandson a hundred years later. He cleared the cabins, stables and forges and erected a new house promptly called Rockingham. In 1875 Rockingham was passed onto Col. E R King-Harmon who was the Parliamentary Under-Secretary for Ireland and died in 1888. His daughter married Thomas Stafford who became medical Commission for the local government board whose surviving son Sir Cecil was the last private owner of the house. In late autumn 1957 the house was gutted by fire. The house stood where the Moylorg tower now stands.
Lough Key Forest Park is often considered to be one of the most scenic areas of the west of Ireland, and is run by Coillte Teoranta. Apart from the tourism, Coillte also use the park for some commercial forestry, as is evident by clear-felling on the site. Coillte gained the park, along with some 1,000,000 more acres around the country, in the 1988 Forestry Act.
The woodlands are of mixed species. The natives that primarily make up the woodlands are Oak, Ash, Alder, Willow, Downy Birch and Scots Pine. The exotics include Beech, Douglas Fir, Norway Spruce, Sycamore and Western Red Cedar. The commercial plantations consist primarily of Sitka Spruce, Norway Spruce, Grand Fir, Scots Pine and small amounts of Lodgepole Pine.
Also, there are occasional samples of Hawthorn, Wych Elm, Hazel, Elder, Holly and Rowan (all native).
The heritage value of Rockingham Demesne becomes clear from the fact that there are 23 protected structures recorded in the Roscommon County Development Plan.
Descriptions of the Developments
On the 4th of August, 2005, Roscommon County Council granted permission to Newfound Consortium for an "Eco-Tourism" Development comprising two separate developments at Lough Key forest park.
The first (reference 04/2030) consists of 78 two-storey holiday homes, a tennis court, a children’s play area and car parking facilities consisting of 104 spaces, including new access roads, access to public roads, site signage, site lighting and all associated site and service development.
The second (reference 04/2031) consists of a 100 bedroom 3 storey hotel (incorporating Leisure, Spa and Conference facilities) including car parking facilities consisting of 150 spaces, 27 two-story holiday cottages, a tennis court and a children’s play area, including new access roads, access to public roads, site signage, site lighting and all associated site and service development.
There is a third development (04/2032) of a golf course to complement the hotel and holiday cottages which has yet to obtain full planning permission. The golf course is an 18 hole, 72 par golf course, and is accompanied by 199 further holiday homes, with all the associated necessary services including new access roads, access to public roads, site signage, site lighting and all associated site and service development.
In total, there is one hotel, one 18-hole golf course and 304 holiday homes planned for the site.
All the planned developments will be within the bounds of Lough Key Forest Park. If the planned developments go ahead, 140 hectares (347 acres) of the 350 hectare (865 acre) comprising the park will be developed, or 40% of the park will be developed. The hotel and all of the holiday homes, as well as two fairways of the golf course will all be developed within forestry in the park. The holiday homes are planned in groups, with some forestry to remain between the groups. About half of the entire development will be within forestry.
All the developments are located within a Strategic Development Area and a Landscape Conservation Area, within the setting of Rockingham Demesne, in the Rockingham Electoral District known as Errironagh Wood at Lough Key, Forest Park, Boyle, Co Roscommon at Rockingham Demesne Td, Lough Key.
These developments are essentially several housing estates, a hotel and golf course missing the facilities and infrastructure (such as electricity, plumbing, shops, public transport) to accommodate such developments. This creates a precedent for the building of unsupported housing estates in poorly serviced areas, placing obligations on the Local Authority to provide these services in other outlining areas for future similar estates. It is unsustainable to have the occupants commuting to the nearest towns for supplies as well as to the hotel in order to be a part of this "Eco Tourism Resort".
The two granted developments, together with the third application, at Lough Key Forest Park, submitted simultaneously, have been publicly promoted by the applicant as one project. The three proposed developments have also sometimes been treated as one project in the planning process and in the way in which the documents are filed. The three applications were accompanied by one and the same Environmental Impact Statement. The three proposed developments interact and have cumulative impacts.
These three applications, both individually and cumulatively, represent systematic project-splitting. This is one of the issues on which the European Commission is taking the Irish Government to the European Court of Justice. This follows the failure of the Government to take action, with regard to the contents of a Reasoned Opinion from Margot Wallstrom, EU Environment Commissioner, in July 2001. Section 2.4 of this Reasoned Opinion specifically referred to the issue of project-splitting, citing the case of Ballymun. The same issues and arguments apply here. This application constitutes a clear case of project splitting and would have required an integrated application accompanied by an EIS clearly displaying the cumulative environmental impacts.
The viability of the hotel as an all year round business is largely dependent on the existence of the golf course and associated facilities. None of the three parts
of the overall development is viable or sustainable on its own. Despite this, the two are separate proposals, and as things stand the appeals period for the planning permission on the hotel with its neighbouring 27 houses (04/2031) and on the housing estate in 04/2030, will be over long before any decision is made on the golf course and housing estate in 04/2032. The three should have their appeals taken as one.
The description of the development as "Eco-Tourism Project" in the planning application is wrong. The IUCN (now called the World Conservation Union) in 1996 stated that eco-tourism "is environmentally responsible travel and visitation to relatively undisturbed natural areas, in order to enjoy and appreciate nature (and any accompanying cultural features - both past and present) that promotes conservation, has low negative visitor impact, and provides for beneficially active socio-economic involvement of local populations."
Rather than try to define ecotourism, UNEP (United Nations Environment Programme) has produced a list of the basic elements that need to be present in a tourism product for it to be classified as "ecotourism":
In the years since the ecotourism concept was first defined, a general consensus has formed on the basic elements of ecotourism: It…
• Contributes to conservation of biodiversity. • Sustains the well being of local people. • Includes an interpretation / learning experience. • Involves responsible action on the part of tourists and the tourism industry. • Is delivered primarily to small groups by small-scale businesses. • Requires the lowest possible consumption of nonrenewable resources. • Stresses local participation, ownership and business opportunities, particularly for rural people.1
The proposed development does not come near the above definition and seriously lacks the elements required by UNEP for ecotourism. The development is not even a sustainable tourism development, nor a sustainable development.
The description of the development as "eco-tourism" development is clearly a promotional measure. It is redundant for the planning process, as there is no such category as "ecotourism project" contained in the Planning Act and Regulations. Planning permission can thus not be given for an "eco-tourism project".
County Development Plan and Lough Key Plan 2002
In the response to the submission to Roscommon Co. Co. by CLEAN, the applicant (Newfound Consortium) argued that the development is manifestly not in contravention of the County Development Plan and the Lough Key Plan 2002 included in it. This is not correct.
The current Roscommon County Development Plan states, that "the Council will ensure that tourism proposals are developed in an environmentally sensitive manner in line with principles of sustainable development", and that "tourism
developments in areas of environmental sensitivity meet the criteria set out in the development control section in this plan".
It further states "It is an objective of this Plan to encourage the diversification of the rural economy and for further development of tourism. Proposals for such development must be properly located and must not interfere with or detract from areas of special amenity value or nature conservation. Proposals for holiday homes should be located in existing settlements, where they can avail of existing services, or designed as clusters in other appropriate locations, where they can be integrated into the environment." (Roscommon County Development Plan 2002: page 47).
The proposed development is not properly located and interferes with and detracts from an area of special amenity value. It is not located in or adjacent to an existing settlement, where it can avail of existing services. Given the scale of the holiday homes proposals they can hardly be described as "clusters" integrated into the environment.
Whereas option 3, Privatisation of Forest Park, in the Lough Key Plan 2002 says "The park may be of interest to private, developers as a location for a 5 star hotel and/or golf course", this is clearly the least favoured option of the four contained. Option 4, Stakeholders Forum, will be realised in form of an 8 million government backed regeneration of the Park, which will see the development of café facilities, an interpretive centre, assembly and exhibition area, craft shop, an adventure house, pay-to-play area and a maze garden in the park itself. Works are expected to begin shortly on this project. Option 3 contains no holiday homes development.
The Lough Key Plan says of the area in which most of 04/2031 and all of 04/2030 are located: "This zone mostly consists of lands within the Forest Park. It is recommended that these lands be designated a Landscape Conservation Area…The further development of these lands for recreational and leisure purposes, including a hotel, preferably involving the restoration of existing structures in accordance with DoE conservation guidelines, but where necessary including the construction of new buildings, is encouraged. Great care must be taken to preserve the park like character of the zone and views from the lake. Recommendations for the development of Forest Park are outlined in Par. 3.5." There is no mention of holiday homes or even estate development.
Rather the Lough Key Plan says on page 14: "This strategy is based on the concentration of residential and other development into development nodes, intended to reinforce and enhance existing communities and relieve pressure for development in more environmentally sensitive areas. The concentration of development within these nodes allows for the possibility of critical mass to be developed. Shops, pubs, post offices, restaurants and other facilities are only likely to be viable if there is a minimum number of customers within convenient walking distance."
Furthermore none of the recommendations and potentials described in the Forest Park Plan are included in the proposed developments 04/2030, 04/2031, 04/2032, but the project would utilise facilities provided by others.
The area in which the proposed development 04/2032, which is still under consideration by the planning authority, is described by the Lough Key Plan 2002 as following (referred to as Zone 2A in the Lough Key Plan: "These lands are primarily open farmland with the capacity to absorb a degree of development. However because of the open nature of these pasturelands and their visibility from the lake, large amounts of development would be highly visible. In order to provide for and protect the continued use of these lands as agricultural holdings and sustain local communities’ owner-occupier residential development for bona fide farmers and their immediate families should be permitted. Speculative development should be restricted. New development should be carefully designed to minimise negative impacts. New development should conform to the design guidelines (Appendix B). Where possible, access on to the public road should be shared with an existing ‘parent’ residence and the proposed new development should be contiguous with the existing building complex. Zone 2 has been classified into sub-zones A & B.
Zone 2A In order to limit the overall number of houses and reduce pressure for speculative development planning applicants should submit evidence of ownership of a farm of not less than 10 hectares (24.7 acres) within 500m of the proposed site (not necessarily all within the zone)."
A holiday home estate of 199 houses and a golf course cannot be compatible with this, even if the developer has acquired the existing farmland.
How can habitat fragmentation, destruction and reduction on the scale provided for in this project be considered compatible with this? How does all this support the argument in the EIS that the County Development Plan promotes and encourages a project such as this for Lough Key?
Sustainability of the Developments
There is no evidence presented in the project to suggest that this is in any way sustainable. The rapid increase in housing in the Carrick-on-Shannon/Boyle area has resulted in a plethora of empty accommodation for lease or rent. Recently proposed and permitted developments at Cootehall, Knockvicar, Doon, Kilronan, Ardcarne and Coorigeenroe, as well as many other smaller clusters or individual houses in the Lough Key Area have already done much to blight the area and reduce the long-term tourism viability.
Inadequate motivation has been provided for the substantial scale of the development proposed in this location in relation to the extent of demand for such facilities, competition from other nearby existing and proposed facilities, the specific market at which the development is aimed, the financial viability of the development proposal, the absence of existing settlements and/or facilities in the immediate vicinity and the carrying capacity of the lake. Despite this the Planning Authority has made no public attempt to seek answers to these important questions.
The long term financial viability of this project is supported neither by the application nor by the accompanying EIS. The planning authority has not made any public attempts to assess this viability. Financial viability is an essential part of the sustainability of this project. There are hotels in this region that have been closed for years (The Forest Park Hotel, Boyle), or struggling to survive (The Ramada Lough Allen Spa Hotel, Drumshanbo). This issue to has been largely ignored in the rush to avail of the tax designation status that drives this proposal. Insufficient information has been provided regarding the long-term viability of the proposed development in the event of inadequate tourism demand and uptake.
The only information hinting in this direction is from the media, where the developer after the granting of permission expressed concerns himself on the viability of the project without extension of tax incentives.
The Sustainable Rural Housing Guidelines 2005 say on page 23: "In other areas, as the NSS and these guidelines have made clear, appropriately sited holiday home development can be a positive and revitalising force and, subject to normal planning considerations in relation to siting and design, such proposals should be accommodated as they arise." The development does not comply with this.
These guidelines further say on page 22: "In considering new dwelling provision in resort type development such as described above, planning authorities, in supporting high quality development predominantly intended for tourism purposes, should seek to ensure that this is of a scale compatible with the character of the surrounding area." This development is not of a scale compatible with the character of the surrounding area.
If the case could be made that a high quality hotel is required as an accommodation base in the northwest of the country, then it should according to the Lough Key Plan 2002, p.25, be located "as close as possible to the town centre" of Boyle.
Other sustainability issues include…
• Whilst benefits to the local community are claimed, no detailed report is provided to show how these will be achieved. • Social and economic potential problems like enclave tourism and leakage were not addressed by the applicant nor by the planning authority.
The questionable sustainability and viability of this combined project, and the potential for developments of this kind to promote creeping development becomes obvious when you read the justification for a similar hotel and holiday homes development at Kilronan Castle (Ref 05/2211). The following was contained in the further information submission for same, which was granted permission on 11/8/05 by Roscommon County Council: "This planning application affords the perfect opportunity to supplement the existing integrated Tourism Project at Lough Rynn with further accommodation and also leisure and tourism infrastructure facilities. Together both estates create critical mass and human critical mass which is vital for the survival of both facilities."
There is no public transport that serves Lough Key Forest Park. This was not addressed by the applicant and no detailed proposals were provided that would
give evidence of a future public transport scheme. Instead the applicant estimates that an additional 600 vehicles per day will be created by the project (please see 4 day traffic survey by Atkins). A development of the proposed scale is not justified in an area that is not served by public transport.
A letter from the National Roads Authority, dated 1/07/05,on development 04/2030 states that the development "is at variance with national policy in relation to control of frontage development on national roads as outlined in Circular 1/95for the following reason: As for the Authority’s comments ref NRA05/24205, we request that a Road Safety Audit as per NRA Circular 3/2004 be submitted to cover this proposed development entering on to the N4 National Primary route. The necessity for the provision of right turn facilities should be examined by the Audit."
Sale of the Land for Development
The sale of this land has been clouded in controversy. Coillte are required to seek tenders for land sales, and not to do private deals. Tenders were only sought in the case of the hotel site after the planning application was made. There is no information on the planning file regarding these matters.
Maps in the planning seem to indicate that the whole or large parts of the Forest Park are in the ownership of the applicant. This would include the site where the above mentioned €8 million project is to be developed. Other documents on file say that the application sites themselves are partly owned by several farmers and Coillte. This needs clarification.
There is evidence of the mishandling of the sale of the land by Coillte in an advert placed in the Roscommon Herald on the 16th of February, 2005, despite having worked for many months with the Newfound Developers. This stated: "Coillte has received a commercial proposal in relation to development of c 69 ha of its landholding at Lough Key. This proposal comprises a tourism related project on a mix of third party and Coillte owned lands. Coillte’s lands are located in 6 separate blocks. Three of these are along the eastern boundary of Lough Key Forest Park and three are in the environs of the park but with no land boundary to the park. Alternative commercial proposals, compatible with the location, are now invited. Such proposals should include a description of the project envisaged, the land area involved and the commercial terms proposed."
It is not clear who owned the land at the time of the sale. There are several suggestions that parts of the land were owned by different farmers, although the site-map listed the applicant as the sole owner. The date of the sale to the Newfound Consortium is also unknown.
There were no attempts made by Coillte to consult with the local communities or NGOs regarding the sale or development of the land to the Newfound Consortium.
Environmental Impact Statement
The EIS for the developments were not produced to assess the impacts of the individual developments alone, but covers the three proposed developments submitted fewer than three separate planning applications as one project. No
clear distinctions between developments are made in the EIS. There is a similar lack of clarity in many documents on the planning files.
The EIS does not address the issue of alternative sites that would better fit in with good planning and the national spatial strategy. This whole project could for example have been located in the lands between Boyle town and Loch Key, east of the N4, within the development node of Boyle. This would have achieved the aspirations of the County Development Plan, i.e., the development would have been contiguous to a large town with plenty of services and amenities that tourists could avail of.
The visual impact of the hotel is assessed without taking into account that the screening vegetation is deciduous, and that for a large part of the year the hotel will be very visible from the lake, as will the houses when viewed from the Park.
The "Historic Landscape Survey" in the EIS states that "the proposed introduction of a large building, together with services, is not recommended on this site. The heritage value of this proposed development site is high, as it is too near the sensitive area near the Temple, the Landing Place, Forest Park Woodland Walks, the Ha-Ha and the tree-lined shore of Lough Key". A letter from Department of the Environment, Heritage and Local Government (DoEHLG) on development 04/2031, received on 5/08/05 (DAU-2005-RO-RO-04/2031), was also highlighting this and recommended that "the planning authority does not make a final decision for this proposed development until the issues regarding the impacts of the proposed development on the setting and visual amenity of the National Monument (including views from Mac Dermot’s Castle), the protected structures and on the historic demesne landscape hace been satisfactorily resolved". There are no signs that this was attempted by the planning authority.
In the same letter the DoEHLG points out that it had not received information requested in an earlier letter from 17/02/05, where it also had recommended "that an ecological assessment should be carried out, with special emphasis on the potential impact of the proposed development on the protected areas within Lough Key and the protected species". This need is underlined in the EIS in which the Red Data Book listed ‘Birds Nest Orchid’ was identified. Whilst this is not a protected species, it is very rare and localised in Ireland, as it grows over limestone in symbiosis with a certain fungus and is regarded as an indicator of ancient woodland sites. Coillte on their website mention the presence of the otter, which is protected, and the rich biodiversity, especially of resident and visiting birds.
A (similar) letter, dated 5/8/05 from the DoEHLG is on development 04/2030, where attention was drawn to 13.7.4 of the Architectural Heritage Protection Guidelines issued by the Department: "Proposals which attempt to ‘conceal’ housing or other developments within existing woodlands should be carefully scrutinised. Woodlands were an important feature of historic demesne designed landscapes and vistas. They may contain paths, rides and drives. In addition to their aesthetic functions, woodlands played an important role in preserving game and wildlife. Many woodlands which are elements of a designed landscape may
have been formed from older woodlands. The construction of new development within existing woodlands can damage their character and integrity and have an adverse impact on the character of a wider designed landscape and the setting of protected structures."
This shows that the planning authority in its decision to grant has not thoroughly addressed issues it should have addressed in respect to the development, on its own initiative, to be able to come to an informed and qualified decision.
Highly relevant parts of the Historic Landscape Survey in the EIS are missing. There is a notable break on page 10 between the first and second paragraph, and a look at the contents page reveals that the report should consist of 29 pages, but consists of only 13 in the EIS. The fact that the break occurs in the middle of a page is, to say the least, very puzzling. These anomalies raise serious questions as to the validity of this report as presented by the applicant.
From what is left in the report we can see that serious concerns were expressed on pages 10-12 of the submitted report:
• Parts of the proposed development will intrude into the historical parkland. • Proposed fairways in Knocknagapple Wood are totally unacceptable, as they would result in major mature tree disturbance and break the contour of the wood. • Parts of developments can interact with the historic landscape. • The proposed introduction of a large building , i.e the hotel site, together with services, is not recommended on this site, as the heritage value of this site is high, as it is near the sensitive area near the Temple, the Landing Place, Forest Park woodland walks, the Ha-Ha and the tree lined shore of Lough Key. The proximity to the present features in a public rural landscape would be insensitive. • On historic landscape grounds it is not possible to recommend the Club House on the current position on a visually imposed site. It would be an intrusion into the fine Sutherland landscape.
Possible mitigation measures were proposed for some of these impacts, under the impression that the applicant is intending to reinstate or upgrade neglected infrastructure and open up traditional vistas as well as restore some demesne buildings. (Please see 35 below.)
The conservation plan for heritage features deals with issues not within the developers’ remit, and offers no real plan for their protection and conservation. Promises were made for funding of conservation work, but this was not included in the conditions by the planning authority. To quote the response to point 12 of CLEAN’s submission by the developer: "The correspondents have identified one of the principle on-going concerns facing the historical and conservational integrity of the park. The proponents as part of the planning submission and as referenced throughout the EIS, intend as part of the project package, to create a fund which will be supplemented annually by visitors to their holiday package. It is proposed that this fund will be directed at rehabilitating various conservational features and elements throughout the park some of which are in a neglected state and are in danger of being lost completely. As this is only a proposal, it is virtually impossible at this stage of the process to identify who should sit on the
board of this fund and/or be responsible and accountable for distributing funds generated. Likewise, the current stewardship of the Forest Park and these various features rests with State facilities, all of whom either collectively or individually may have their own ideas and priorities for fast tracking a restoration package/fund for the park. Therefore, it is somewhat premature for the proponents to be suggesting definitive park regeneration plans" No adequate in-season surveys of flora, fauna and habitats were undertaken and provided by the developer. In responses to submissions made dealing with this it becomes clear that the applicant’s examination of flora, fauna and habitats is largely a desk top study that relies largely on a few and inconclusive earlier data. It is not acceptable that the applicant leaves proper surveys to an unspecified time in the future, as is expressed under point 8. Fauna in the response to CLEAN’s submission: "The implementation of mitigation and follow up surveys in the proper season (with accompanying mitigation if necessary) will ensure that the conservation status of the fauna remains unaffected in the long term."
It is further quite astounding that the applicant also states therein: "It is the responsibility of the various State facilities to ensure that all measures are taken to carry out all identified mitigation and required survey works."
In the section on flora and fauna in the EIS it is admitted that different seasons can influence both bird and bat assessments in terms of activity and presence of various species. Yet the ground survey for fauna was carried out on 22nd and 25th of October 2004 with a follow up visit on 9th December 2004. Similarly an attempt was made to conduct a flora study on the 10th and 12th of November 2004 and 18th and 20th of November 2004.
There is no attempt anywhere to address the potential serious impacts of this development on the lake itself. Clearly, there is going to be increased usage of the lake for a range of leisure activities. The planning authority is allowing a massive increase in potential use of the lake without any attempt at introducing an integrated management plan for protecting the lake and sharing its resources between the many demands that will be made on them. The implications for the lake from oil and other hydrocarbon run off is not examined either. The ecology of the lake, apart from the work of Frances Lucey on Zebra Mussels, is largely unstudied. Consequently the judgements which have not been, but are required to be made, regarding the lake, are at best only guess work.
Further to this the second Bat Survey has not been made a condition, despite the fact that this area is under consideration as an National Heritage Area for bats, and despite the results of the minimal survey done as part of the EIA, in which many species of bats were identified.
Further problems with the EIS include
• The consequences of light pollution and its potential negative effects on Fauna, especially birds and bats, were not investigated. • There are inadequate conditions requiring the developer to carry out the suggestions for specimen tree protection in the EIS. Lough Key Forest Park is known country-wide for its collection of specimen trees. It is therefore extremely important that this part of our natural heritage be protected. • No technical detail for the geothermal heating were submitted nor was an ecological study of the part of the lake in which the geothermal heating cables are to be laid carried out nor was such required in the further information request or by condition. Such a study is essential as very little is known of the ecology of the lake bottom, and without it the potential impacts of this heat exchanger can only be guessed at. Nor is there any attempt to assess the effect that Zebra Mussels might have on the viability of such a system. It is possible that this may become a no fishing zone of the lake in order to protect the integrity of the cables.
The proposed development at Lough Key Forest Park is unsustainable in environmental, economic and social terms, and, should it be realised, will have an undesirable destructive effect on the recreational, historic, landscape and natural character of Lough Key Forest Park and the former Rockingham Demesne. Further, should tourism uptake be insufficient, the outcome of this proposed development would be a series of unsuitable and unsustainable residential developments, and ultimately an accumulation of unnecessary modern ruins that would permanently blight the character of the park. The development would further set an undesirable precedent for further and similar development, on site, nearby, and in the wider area. Therefore and for all the above reasons the proposed development would be contrary to the principals of proper planning and sustainable development.
From The Woodland League Website
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COILLTE AGAIN: THE RAPE OF CONG; IN ASSOCIATION WITH FIANNA FAIL.
The destruction of glorious woodlands, the legends attached to the area, and the impact of the natural surroundings: were some of the reasons a planning application for a major hotel in Cong have been refused. Plans for a 66 bedroom hotel with leisure complex at Nymphsfield, Cong were appealed by An Taisce to An Bord Pleanala. The board found it would have an impact on the geology, hydrogeology and ecology of the area.
Tim Regan, c/o David O’Malley and Associates of McHale Retail Park, Castlebar, County Mayo had been granted permission subject to 39 conditions for the construction of a two-storey hotel complex, consisting of 30 en-suite bedrooms, 29 two-bedroom suites, six one-bedroom suites, six presidential suites, hotel reception, foyer with associated administrative offices, function room, bar and stores, orangery, restaurant, kitchen and stores, residents bar, amenity area and library, conference rooms, associated toilet areas and stores, heritage display area and shop.
The application included an adjoining leisure pool complex with changing areas, coffee/snack bar, health spa, children’s indoor activity centre and créche, gymnasium and aerobic room and associated storage and offices. The construction of 25 accommodation units in clusters, with access from the proposed new access road including all sewers and services at Nymphsfield, Cong.
The site is a large, wooded area northeast of Cong Village. It lies close to the primary school and several dwellings. To the north of the site is Lynn Medical Centre and directly opposite the site are the grounds of Ashford Castle. The western boundary is formed by the Cospeinnacalliagh River which flows south into the Cong River. The river is the boundary between Counties Mayo and Galway. There is one national monument and several geological features within the site. The national monument, Kelly’s Cave, is in the eastern section of the site and a well defined walk, edged with large, limestone slabs leads to the cave, which is at the northern end of a small clearing, also edged with limestone slabs.
An Taisce appealed the decision on the grounds that part of the original Ashford Castle estate transferred to the Irish Government to maintain its woodland amenity therefore there is no legal entitlement to dispose of the site. An Taisce submitted the application site is entirely unsuitable for the proposed development and should be rejected on these grounds.
Siobhan McMurray who owns a residence in the vicinity objected because of loss of privacy, traffic impact and other issues.
Frank J. May, owner / occupier of an adjoining dwelling said the forestry is part of Cong’s inheritance from the Guinness family and Coillte have no right to sell it.
Fiona and Roy Simpson, owners / occupiers of a nearby dwelling, said the development will destroy glorious woodland and associated flora and fauna and archaeological features.
Inspector Jenny Kelly recommended refusal of the application because it is in close proximity to features of national geological and ecological importance and would have an irreversible impact on the geology, hydrogeology and ecology of the area.
"The proposed development would, therefore, be prejudicial to public health and give rise to an unacceptable risk of water pollution."
Not many friends of the environment left in Celtic Tigerland..
FNN 172: Parliamentary Questions – Appeal for support
The response to FNN’s appeal for support from subscribers has been, with a single exception, silence.
This is really discouraging for those of us who have worked hard to keep FNN alive and kicking. We paste below the Sunday Times coverage of FNN 171, which also received a half page in Monday’s Irish Independent (with photographs from our site) and a debate between Tony Lowes and Gerry Egan of Coillte on Monday’s RTE Morning Ireland news.
Our next issue will include replies to the written Parliamentary Questions below which have been tabled to greet our Ministers on their return.
Please support us. This is meaningful work and at the moment there us no one else to do it.
Caroline, Ian, and Tony
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or by post to Friends of the Irish Environment, Allihies, Co. Cork.
Of lies, incompetence ,& non native coniferous trees.
Minister for Environment
If the Minister will provide a list of the 125 rivers known to host the fresh water pearl mussel Margaritifera margaritifera with their location by county and their length; the 45 catchments involved with their location by county and their extent in hectares; and the amount of afforestation by hectares in each of these catchments.
Minister for Agriculture
To ask the Minister if she can assure the Deputy that she revealed the full Terms of Reference of the Forestry and Margaritifera Group’s Technical Working Group for the proposed Forestry Guidelines in her reply to this Deputy’s parliamentary question [21512/06] and that no agreement was reached with Coillte Teo to ensure that the Terms of Reference included the requirement for the Guidelines to be ‘cost efficient’.
To ask the Minister if the definition of peat soils incorporated in Schedule 1 of the ‘Nitrates’ Regulations 2006 [European Communities (Good Agriculture Practice for the Protection of Waters) Regulations, 2006 (S.I. No. of 2006)] as
‘soils with an organic matter content exceeding 20%’ will also be applied to soils used for forestry.
To ask the Minister if she is satisfied that the foliar analysis upon which her Forest Service’s approval of fertilisation of forestry is based is sufficient to determine phosphorous deficiency in the soil.
To ask the Minister for the maximum amount of phosphates fertilisers permitted to be applied per hectare for afforestation projects over their rotation.
If the Minister can assure the Deputy that sufficient information is required to be provided in the application for all Felling Licences to ensure her Forest Service is able to assess the impact on the environment and if she will provide the information required for each application.
To ask the Minister if her Forest Service has the ability to regulate forest road construction if it is not being approved for grant aid to ensure the protection of the environment?
To ask the Minister if her Forest Service has the ability to regulate hand fertilization if it is outside the grant aid period to ensure the protection of the environment?
If the Minister could specify the enforcement provisions she has to control unapproved plantations of trees and the powers she has to require that the development be reversed and the owner be prosecuted.
If the Minister will give the date on which Coillte Teo. reimbursed the Government for the grant aid intended for farmers claimed by Coillte Teo. which was clawed back by the European Commission.
If the Minister will institute a review of the 1996 Strategic Plan for the Development of the Forestry Sector in Ireland which reflects the current planting rates and accepts the reality of the current planting figures being unable to allow the Government to reach the targets required for ‘critical mass’ as specified in that Plan and in the terms of reference of Peter Bacon’s Review of that Plan.
Mussel power leaves the trees standing
A TINY creature is about to cost the Irish forestry industry millions in lost revenue. The pearl mussel, which lives 120 years and is extremely sensitive to pollution, is set to change forever the way trees are grown and felled in parts of Ireland.
The difficulties for Coillte, the state forestry agency, began after phosphorous and nitrate silt leaked into the Owenriff river in Galway in May 2004, and
caused an algae bloom that asphyxiated most of the mussels living downstream.
The bivalve is a protected species under European law, and Ireland has the largest remaining population.
Mary Coughlan, the minister for agriculture, imposed a moratorium on forestry activities in all pearl mussel areas last May, some 18 months after officials in the National Parks and Wildlife Service (NPWS) recognised the problem. Coillte can now neither continue fertilising the trees in these areas nor cut them down in an economically viable way. Gerry Egan, Coillte’s company secretary, said yesterday less than a quarter of the company’s forests, were affected. But internal documents and environmentalists suggest otherwise.
Aine O’Connor, an environmental officer at the NPWS, began an internal debate on the issue in an e-mail to her colleagues in October 2004, five months after the bloom emerged.
"I am very concerned that populations in other river catchments are at risk," she wrote.
"Current evidence suggests that clear felling of conifer plantations in blanket bog and heath catchments lead to massive losses . . . I believe that all forestry activities in mussel catchments should be suspended."
One of her colleagues, Noel Kirby, replied: "Having looked at the Owenriff situation it is my impression that we are sitting on fertiliser time bombs that are coming to the fore after 50-plus years of fertiliser usage for forestry."
A spokesman for the Department of Agriculture said last week that clear felling had been prohibited in 25 river catchment areas and there was now a ban on new planting as well. Studies are being carried out to decide what kind of forestry might be more suitable in these areas.
The mussel is known to live in 25 rivers nationwide, including the Shannon, Suir, Barrow, Nore, Slaney, Bandon, both Blackwaters and Lough Corrib. The Department of Agriculture confirmed that if the mussel is discovered elsewhere, the ban will be extended to those rivers too. In the past the species has lived in most Irish waterways.
In another internal e-mail released to Friends of the Irish Environment under a European access to information law Pat Warner, a Forest Service inspector, warned the problem could be bigger than expected.
"Please be aware," he wrote, "that unless [pearl mussels] are a lot more rare than I think, you are contemplating closing down a significant amount of the state’s afforestation programme, both private and public, if you ban fertilisers in whole catchments. You can’t grow commercial timber in uplands without fertiliser."
Coillte’s forestry model, which involves regular clear felling of swathes of forest, is now known to acidify soil and dump huge amounts of phosphorous and nitrates into the ground and rivers.
Jim Ryan, an official at the NPWS, told his colleagues he was "stunned" at the amount of fertiliser used by Coillte and the Forest Service and referred to one study in the Cloosh forest in Galway where phosphorous levels in the water from fertilisation and clear felling were 40 times the accepted limit.
Coillte, established in 1989 with the principal remit of making a profit, has almost exclusively grown non-native coniferous trees in poor-quality peat uplands, the same areas susceptible to the chemical leaching that pollutes rivers and kills the pearl mussel.
Last year the European Environment Agency found that 83% of all forestry planted between 1990 and 2000, most of which is still waiting to be harvested and sold, was on peat. While Coillte and the government say the study is wrong, another analysis by University College Cork (UCC) found that at least 50% of forested land is planted on peat bogs.
© Sunday Times sept 2006