www.urcplanning.com.au [email protected] URC Planning +61 0479 061 172 Urban | Regional | Coastal Planning Consultancy
The Planning Authority Clare County Council New Road, Ennis, Co. Clare
08/06/2016
Re: Planning permit application for coastal erosion management works at and adjacent Carrowmore Dunes, White Strand, Doughmore Bay and Trump International Golf Links and Hotel.
File No. 16371
Dear Sir/Madam,
I refer to the above planning permit application which has been recently submitted to Clare County Council for determination. URC Planning have been requested by the West Coast Surf Club, Lahinch, Co. Clare to prepare a professional planning assessment in respect of the proposal.
The assessment has been undertaken following a review of the information submitted with the planning permit application, the contents of the County Development Plan 2011 - 2017, West Clare Local Area Plan 2012 - 2018, Draft County Development Plan 2017 – 2023, relevant coastal management policy, relevant case studies and academic research and the proper planning and sustainable development of the area.
It is important for to note under Section 34(3)(b) of the Planning & Development Act 2000 (as amended) the Planning Authority shall, when considering an application for permission under this section, have regard to any written submissions or observations concerning the proposed development made to it in accordance with the permission regulations by persons or bodies other than the applicant.
URC Planning Po Box 5039 3121 Richmond Victoria Australia www.urcplanning.com.au [email protected] +61 0479 061 172 White Strand, Doughmore
1.0 Proposal
The proposal involves extensive development and works within the coastal zone and adjacent private land including:
Construction of a sea wall up to 6m OD in height, for a length of 2.8km and depth of 15 – 20m at the seaward side (beach) of the dune system; Up to 145,000m3 of armour stone; Installation of sheet piling within the dune system for 350m; Ancillary construction works including car park and access way.
An Environmental Impact Statement (EIS) and Natura Impact Statement (NIS) have been prepared and submitted as part of the planning permit application.
2.0 Site location
The subject site is located at White Strand, Doughmore Bay, Doonbeg, Co. Clare. More specifically, the specific location of proposed sea wall and associated works is the seaward side of Doonbeg Golf Course on the coastal zone.
The coastal dunes at White Strand are eolian landforms that form in coastal areas through the accreditation of sediment supplied from rivers, coastal erosion and the sea floor. They are part of a sand sharing system, in a constant equilibrium with beaches and sand bars, and are in a constant dynamic through changing tides, waves, currents, sea level and weather1, 2.
The coastal section of the development area covers approximately 50,000 m2 of beach and sand dune area. The site is located in a visible location from public view along the beach and coastal zone, in addition to the marine area.
1 Martinez, M. L. & Norbert, P. P., 2004. Ecology and Conservation. Coastal Dunes, Volume 171, p. 3.
2 Hanley, M. E. et al., 2014. Shifting sands? Coastal protection by sand banks, beaches and dunes. Coastal Engineering, Volume 87, pp. 136-146.
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3.0 Planning & Environmental Legislation, Policy & Guidance
The site is subject to multiple planning and environmental designations and legislative instruments, which are informed by County, National and European Legislation and Policy.
It is important to note under Section 34(2)(a) of the Planning & Development Act 2000 (as amended) when making its decision in relation to an application under this section, the planning authority shall be restricted to considering the proper planning and sustainable development of the area, regard being had to—
(i) the provisions of the development plan,
(ii) the provisions of any special amenity area order relating to the area,
(iii) any European site or other area prescribed for the purposes of section 10 (2)(c),
(iv) where relevant, the policy of the Government, the Minister or any other Minister of the Government,
(v) the matters referred to in subsection (4), and
(vi) any other relevant provision or requirement of this Act, and any regulations made thereunder.
In addition to County and local plans, applicable Government policy should be given due regard when the Planning Authority is informing and making its decision in accordance with the proper planning and sustainable development of the area.
3.1 European Designations With respect to environmental protections, the site and proposed development is regulated by the designation as a Special Area of Conservation (SAC; 002250 - Carrowmore Dunes) and as a proposed Natural Heritage Area (pNAC; 001007 – Whitestrand/Carrowmore Marsh).
The site is designated a Natura 2000 site and is afforded National and European protection (EU Habitats Directive 92/43/EEC and Birds Directive 2009/147/EC).
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The accurate assessment of the proposal in respect of the specific legislation pertaining to the site is essential.
The development has been described by the applicant as a necessary undertaking to ensure the golf course is protected from erosion, with the supporting information opportunely identifying that the dune system will also be protected with no adverse impacts on Natura 2000 sites in the wider hinterland.
It is important to note that the use and development of the golf course is identified as a high threat and a damaging operation to SAC’s and NHA’s by the Heritage Council3. The Heritage Council are a statutory body established under the Heritage Act, 19954.
The need to protect dunes is explored further in a following chapter of this report. However, in the context of the applicable European designations it is important to identify that coastal sand dunes are natural systems which should be allowed to function naturally. Based on comparable case studies and academic research it is considered that the development will have a significant adverse impact; the dunes will be negatively affected by the proposed development and are currently being affected by the existing golf course through coastal squeeze5, 6, 7. This position is supported in further detail at Sections 4 and 5 of this report.
In a site where significant European environmental protections are designated, the undertaking of the proposed development would place the importance of protecting the golf club infrastructure above the importance of protecting a Special Area of Conservation and National Habitat Area.
We say that the proposed development, due to its nature and scale in a highly sensitive location, will have significant negative impacts on the environment, on the SAC and pNHA. The information submitted with the planning permit application does not provide a balanced interpretation of the potential negative impacts the proposal may have on the site and surrounding area.
3 The Heritage Council, 1998. Irish Coastal Habitats: A Study of Impacts on Designated Conservation Areas. [Online] Available at: http://www.heritagecouncil.ie/fileadmin/user_upload/Publications/Wildlife/Microsoft_Word_-_Irish_Coastal_Habitats.pdf [Accessed 02 06 2016]. 4 The Heritage Council, 1995. Heritage Act 1995. [Online] Available at: http://www.heritagecouncil.ie/fileadmin/user_upload/Publications/Corporate/Heritage_Act_1995.pdf [Accessed 02 06 2016]. 5 Pontee, N., 2013. Defining coastal squeeze: A discussion. Ocean & Coastal Management, Volume 84, pp. 204-207. 6 Cooper, J. A. & McKenna, J., 2008. Working with natural processes: the challenge for coastal protection strategies. The Geographical Journal, 174(4), pp. 315-331. 7 Hanley, M. E. et al., 2014. Shifting sands? Coastal protection by sand banks, beaches and dunes. Coastal Engineering, Volume 87, pp. 136-146.
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The potential consequences of the development, which may occur in the short, medium and long-term, are of such a significance that protection of the environment should be prioritised by the responsible authority and the planning application be refused.
The proposal and the receiving environment are of such complex nature that mitigation measures and conditions will not suffice to sufficiently protect the environment. Where the full consequences of the proposal are unknown the decision making process should not rely on the supporting, unbalanced information submitted by the applicant.
3.3 Clare County Development Plan 2011 - 2017 The Clare County Development Plan 2011 – 2017 (CDP) is the most relevant planning policy document informing the decision making for the subject permit application. The CDP is a vast document which considers the wider areas of economic, social, cultural and environmental matters.
For the purposes of this report the most relevant elements of the CDP are incorporated; Chapter 9 ‘Environment’, Chapter 15 ‘Marine and Coastal Zone Management’, Chapter 16 ‘Landscape’ and Chapter 17 ‘Natural Heritage’.
3.3.1 Chapter 9 ‘Environment’ Under Section 9.2 of the CDP, with regard to the protection of water resources, it is an objective (9.2) of the Development Plan:
To permit development where it can be clearly demonstrated that the proposal would not have an unacceptable impact on the water environment, including surface water, groundwater quality and quantity, designated source protection areas, river corridors and associated wetlands, estuarine waters, coastal and transitional waters. (Emphasis added)
It has not been clearly demonstrated that the proposal will comply with Objective 9.2 of the CDP. We consider that the proposal will have an unacceptable impact on the coastal zone environment of the site and surrounding area. This position is supported in further detail at Sections 4 and 5 of this report.
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3.3.2 Chapter 15 ‘Marine and Coastal Zone Management’ Under Section 15.3.6 of the CDP, with regard to the protection of beaches and sand dunes, it is an objective (15.5) of the Development Plan:
A. To protect, enhance and conserve all beaches in the County and to retain Blue Flag status on beaches currently awarded this status whilst seeking to increase the present number;
B. To prohibit maritime development on sites either on or adjacent to designated Blue Flag beaches and on any other popular beach area, where such developments would significantly interfere with the recreational use of the area or would cause damage or degradation of the beaches or sand dunes system. (Emphasis added)
White strand Beach is identified as being a Blue Flag Beach8 and it is an objective of the CDP to protect and conserve this beach and dune system.
We consider that the proposal will have a detrimental impact on the White strand Beach and dune system, will cause damage and degradation and would contravene Objective 15.5 of the Clare CDP. This position is supported in further detail at Sections 4 and 5 of this report.
Furthermore, when constructed the proposal would restrict public walking access along the beach, especially at high tide. Pedestrians would be required to walk on top of the rock armour to achieve passage along the beach. This is clearly identified at Drawing DKR5335/D003 provided as part of the planning permit application, Figure 1 below.
The drawing clearly illustrates that the highest astronomical tide (HWT), identified with a blue line on the drawing, will reach far into the rock armour, covering the beach in front. This will prevent safe access for pedestrians along the beach. As the photograph illustrates, this access will also be restricted outside of the high tide occurrences.
8 Clare County Council, 2016. Blue Flag Beaches. [Online] Available at: http://www.clarecoco.ie/recreation-culture/leisure-and-swimming/beaches/blue-flag-beaches/ [Accessed 05 06 2016]
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Figure 1: Drawing DKR5335/D003 extract from EIS submitted with application.
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In respect of Integrated Coastal Zone Management (ICZM), at Section 15.3.9 of the CDP Clare County Council have recognised its importance in managing the coast in a coordinated manner. The pressures on the coastal area are duly recognised:
Human impacts, resulting from coastal development, tourism, recreation, coastal industry, fishing, aquaculture etc., coupled with global climate change, place continuous pressure on coastal environments
Under Section 15.3.9 of the CDP, with regard to ICZM, it is an objective (15.8) of the Development Plan:
To work in collaboration with local communities and relevant stakeholders in the preparation and implementation of an Integrated Coastal Zone Management Plan for the coastal and estuarine areas of the County.
We consider that the independent and re-active proposal to construct a sea wall represents an uncoordinated approach and is premature pending the completion of an ICZM Plan for the wider coastal area.
Under Section 15.3.12 of the CDP, with regard to Flooding and Coastal Erosion, it is an objective (15.11) of the Development Plan:
To permit developments only where they may not result in an increase in coastal erosion or increase the risk of inundation, either at the subject site or at another location in the vicinity. (Emphasis added)
We consider that the proposal will result in an increase in coastal erosion and possibly inundation at other locations in the vicinity of the site and would contravene Objective 15.11 of the Clare CDP.
This position is supported in further detail at Sections 4 and 5 of this report.
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We bring your attention to a statement included at Page 3 of the covering letter submitted by the applicant as part of the planning permit application. In respect to Section 15.3.12 of the CDP, that letter states:
Importantly, Doonbeg is identified as one area where coastal erosion is a risk issue. The applicant in this instance is seeking consent to put in place a proposal that will benefit the community by way of the coastal protection works.
It appears the applicants are relying on the identification of ‘Potential Risk’ areas where four (4) sites are identified, with the following being relevant:
Rhynagonnaught, Doonbeg – possible undermining of the road due to flooding issues.
It appears the above reference relates to a section of roadway along the coast, located approximately 1.7km southwest of the subject site and separated from the site by Creagh River as identified in the image below.
Doonbeg Golf Course – Application Site
Rhynagonnaught, Doonbeg
Figure 2: Google Earth Image identifying Rhynagonnaught, Doonbeg
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As substantiated in further detail at Sections 4 and 5 of this report, the proposal may increase coastal erosion and inundation at adjacent land and possibly at the sensitive location of Rhynagonnaught, Doonbeg where the public roadway is at risk of coastal erosion.
The flood maps included within the Clare CDP 2011 – 2017, in particular the ‘Infrastructure, Environment and Flood Risk Zones Map H6’, identifies existing flood areas in this region.
The map identifies that flood risk in the area of, and surrounding, the planning permit application is limited to a minor section of the dune system fronting the beach and along existing watercourses more inland. The map clearly shows that the flooding does not occur across the extent of the golf course. The map suggests that the issue of flooding experienced by the houses and agricultural land to the east of the golf course does not permeate ‘through’ dune system at the golf club, but rather is a result of coastal inundation and storm and tidal surge along the watercourses to the north, south and east of the golf club. This demonstrates that the proposed sea wall will not increase flood protection to those landowners but in turn may exacerbate flooding along the existing watercourses as wave energy is redirected either side of the proposed sea wall.
Figure 3: Infrastructure, Environment and Flood Risk Zones Map H6 - Clare CDP 2011-2017
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Doonbeg Golf Course – Application Site
Figure 4: Enlarged - Infrastructure, Environment and Flood Risk Zones Map H6 - Clare CDP 2011-2017.
3.3.3 Chapter 16 ‘Landscape’ The Clare CDP includes 26 Landscape Character Types, grouped into Upland Types, Lowland Types and Coastal Types.
The site is situated within the ‘Coastal Plain and Dunes’ Landscape Character Type and ‘Mutton Island and White Strand’ Seascape Character area with views from sea to land, from land to sea and along the coastline.
With regard to ‘Living Landscapes’, the site is designated as being within a ‘Heritage Landscape’, which are described under Section 16.4.2 of the CDP as areas where natural and cultural heritage are given priority and where development is not precluded but happens more slowly and carefully.
Section 16.4.5 of the CDP identifies that the Heritage Landscape area is an area where sensitive environmental resources are located.
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The CDP explores their function in more detail as follows:
Heritage Landscapes are envisioned as the most valued parts of the County – that are important to the people of County Clare as well as the wider community – both nationally and internationally. The principal role of these Landscapes is to sustain natural and cultural heritage. (Emphasis added)
It is important to note the principal role of these landscapes is to sustain natural and cultural heritage. The introduction of a human-made structure to sustain a golf course at the cost of the natural landscape is at odds with the designation of this area.
The Heritage Landscape areas are further categorised into 4 categories. The site is identified as ‘The Coast’ which has been defined by having regard to the Heritage Council’s LCA Seascape Areas 1-8.
A review of the Heritage Council Landscape Character Assessment of Co. Clare identifies that the site is categorised in ‘Area 6: Mutton Island and White Strand’9.
A key characteristic of the area is identified as being:
White Strand is a Blue Flag Beach and also classified as a visually vulnerable and visually sensitive area.
With regard to Principles for Seascape Management the Heritage Council state:
Dune system at Carrowmore should be strictly protected.
9 The Heritage Council, 2012. Landscape Character Assessment of Co. Clare. [Online] Available at: http://www.heritagecouncil.ie/fileadmin/user_upload/Publications/Landscape/Landscape_Clare/area_6.pdf [Accessed 05 06 2016]
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Under Section 16.4.5 of the CDP, with regard to Heritage Landscapes, it is an objective (16.5) of the Development Plan:
To require that all proposed developments in Heritage Landscapes, demonstrate that every effort has been made to reduce visual impact. This must be demonstrated for all aspects of the proposal- from site selection through to details of siting & design. All other relevant provisions of the Development Plan must be complied with.
All proposed developments in these areas will be required to demonstrate;-
i That sites have been selected to avoid visually prominent locations
ii That site layouts avail of existing topography and vegetation to minimise visibility from scenic routes, walking trails, public amenities and roads.
iii That design for buildings and structures minimise height and visual contrast through careful choice of forms, finishes and colour and that any site works seek to reduce the visual impact of the development. (Emphasis added)
We consider that the proposal is within a visually prominent location, will have a significant visual impact and would severely detract from this highly sensitive area.
The contention of the permit applicant that the dunes will reform on top of and in front of the rock armour are erroneous and demonstrate their lack of knowledge of the coastal zone and its processes. The photomontages included in the EIS, which depict sand covering the rock armour and grass growing within the rock, are false assumptions and cannot be relied upon to inform a robust visual assessment of the proposal.
It is also considered that the use of these inaccurate photomontages is misleading for the community consultation process as they inaccurately convey the impact of the proposal, including the substantive visual impacts.
The current situation where the dunes are currently being eroded further landward than the location of the rock armour demonstrates that this area of beach will continue to erode rather than deposit sediment. This will be exacerbated with sea level rise. The proposal will represent a visually dominant and ‘hard’ presence in this natural setting.
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3.3.4 Chapter 17 ‘Natural Heritage’ Under Section 17.3.1 of the CDP, it is an objective (17.2) of the Development Plan:
To ensure the sustainable management and conservation of areas of natural and geological heritage within the County.
It has not been clearly demonstrated that the proposal will comply with Objective 17.2 of the CDP as the proposal is likely to result in negative impacts on the beach and dune system. This position is supported in further detail at Sections 4 and 5 of this report.
Under Section 17.3.3 of the CDP, with regard to Natura 2000 sites, it is an objective (17.3) of the Development Plan:
To afford the highest level of protection to all designated Natura 2000 sites in accordance with the relevant Directives and legislation on such matters. (Emphasis added)
The proposal does not comply with Objective 17.3 of the CDP as the development is likely to result in negative impacts on the dune system which is a SAC and should be afforded the highest level of protection. This position is supported in further detail at Sections 4 and 5 of this report.
Under Section 17.3.6 of the CDP, with regard to Natural Heritage Areas, it is an objective (17.5) of the Development Plan:
A. To actively promote the conservation and protection of areas designated as an NHA (including proposed sites) and to only consider proposals for development within or affecting an NHA where, having assessed the impact, it can be clearly demonstrated that the proposed development will not have a significant adverse effect on the NHA or pNHA.
B Where a development proposal is shown to have a significant adverse effect, it will only be considered where it can be demonstrated that the development is of regional or national significance and serves the common good, in the areas of transport, energy (including energy transmission and storage), communications and necessary flood protection works and tourism. (Emphasis added)
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The subject site is designated a pNHA and afforded the above protection under the CDP. The proposed development does not comply with Objective 17.3 of the CDP as the proposal will have a significant adverse effect on the dune system. As clarified by An Bord Pleanála, the proposal is not considered to be of a regional or national significance and therefore must not be afforded any special consideration. This position is supported in further detail at Sections 4 and 5 of this report.
3.4 West Clare Local Area Plan 2012 – 2018
The West Clare Local Area Plan provides no further guidance on the assessment of the proposal than that already included in the CDP.
The plan covers a wide area of the West Clare area, with no further specific objectives or policies in respect of coastal protection, coastal erosion, environmental assessment or protected areas.
3.5 Draft Clare County Development Plan 2017 - 2023
The Draft Clare CDP 2017 – 2013 is in its final stages of completion and adoption. The plan incorporates many new policies which are of significant relevance to coastal zone management.
With respect to coastal erosion and flooding, Objective 12.2 of the Draft CDP states:
To engage with the OPW to develop appropriate strategies for the management of identified coastal flood and erosion hazards and associated risks;
To permit developments only where the Council is satisfied that it will not result in an increase in coastal erosion or increase the risk of inundation, either at the subject site or at another location in the vicinity;
To have regard to any future adopted Integrated Coastal Zone Management Plan for the coastal and estuarine areas of the county, undertaken in accordance with the Habitats and SEA Directive.
With respect to coastal squeeze, Objective 12.13 of the Draft CDP states:
To ensure that coastal squeeze is taken into consideration in formulating and assessing coastal development proposals.
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The following section (12.3.14) of the Draft CDP is of particular relevance:
Figure 5: Section 12.3.14 Draft Clare County Development Plan 2017 – 2023
With respect to protection of beaches and sand dunes, Objective 12.14 of the Draft CDP states:
a) To prohibit maritime development on sites either on or adjacent to any popular beach area, where such developments would significantly interfere with the recreational use of the area or would cause damage or degradation of the beaches or sand dune system;
b) To engage with all relevant stakeholders to proactively monitor and manage the dune systems in the county during the lifetime of this plan, in full compliance with the EU Habitats Directive;
c) To protect the structure and function of sand dunes of the county, (which include Annex I habitats and Annex II species), and prohibit any development that would damage the integrity (ecological and visual) of these areas or prevent full compliance with the requirements of the Habitats and Birds Directives. (Emphasis added)
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Section 12.3.15 of the Draft CDP confirms the importance and sensitivity of sand dunes:
Sand dunes, whilst also forming a rich and varied habitat, in particular form an effective natural coastal defence. Interference with the dunes can have a serious impact on the coastal area. Sand dunes can be vulnerable to damage e.g. from weather events or from human activities.
It is important, not only to the economy of coastal areas, but also in the interest of protecting natural amenities, that the beaches and sand dunes of the county are protected and proactively managed.
The Draft Clare County Development Plan 2017 – 2023 provides vital, modern policy relating to coastal protection and the coastal environment. The proposal would have a significant impact on the natural coastal system for an indefinite period and it is vital that the responsible authority look long term with respect to any proposals for a sea wall; the first step is the Draft CDP which will govern the area for the next six years.
3.6 Relevant Government Plans, Reports and Policies
There are a number of Government and Government associated plans, reports and policies which provide valuable background information and guidance on coastal management. In particular, these documents identify a modern approach to coastal protection which is informed through a greater understanding of how coasts work.
The contents of these documents should be given weight and consideration in the assessment of the proposal to ensure the decision is in accordance with the proper planning and sustainable development of the area. The substantial extent of existing Government funded and supported research and guidance should not go under-utilised.
3.6.1 Coastal Zone Management. A Draft Policy for Ireland 1997 The Draft Coastal Zone Management Policy for Ireland is a report that was jointly commissioned by the Department of the Environment and Local Government, the Department of the Marine and Natural
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Resources and the Department of Arts, Heritage, Gaeltacht and the Islands to provide a coherent framework for the co-ordinated and sustainable management of coastal areas10.
In respect of protective designations associated with coastal areas, such as SAC’s, the draft policy states at Section 5.49:
There are significant interactions between nature conservation and coastal protection. In the past, many engineering works designed for coastal protection have had detrimental effects on sites of nature conservation value, for example, by disrupting the natural sediment exchange between beaches and dunes. (Emphasis added)
The draft Government policy includes a section dedicated to coastal protection. Chapter 9 of the draft policy identifies an important fact relating to the coastal zone:
The coastal area is very dynamic and a shoreline may advance or retreat in an unpredictable manner. Overall, however, long-term erosion, and hence recession, is a natural and widespread process around the coastline of Ireland. (Emphasis added)
Section 9.14 – 9.17 of the draft policy identifies that there are three options in relation to coastal erosion: 1. protect with ‘hard’ works; 2. mitigate specific impacts through ‘soft’ works; or 3. accept natural shoreline changes and accommodate the problems they cause.
It explains that 'hard' solutions include sea walls and sheet piling. The draft policy provides a very clear and important statement in respect to ‘hard’ solutions:
These ‘hard’ solutions often give rise to significant impacts on the coastline adjacent to the frontage being protected, and sometimes further afield. For example, a cliff or dune protection scheme can deprive the coast of fresh supplies of beach sediment, while groynes will interrupt the natural pattern of transport of such sediment along the coast, 'starving' other parts of the shoreline, and leading to erosion. Such effects can lead to a requirement for further coastal protection works. (Emphasis added)
10 Department of the Environment and Local Government, the Department of the Marine and Natural Resources and the Department of Arts, Heritage, Gaeltacht and the Islands, 2014. Our Coast - The European Portal for ICZM. [Online] Available at: http://ec.europa.eu/ourcoast/download.cfm?fileID=1449 [Accessed 05 06 2016]
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The EIS submitted as part of the planning permit application includes the following statement in respect to the proposal:
Whilst the effect upon the fixed dune habitat is expected to be significant positive, the effect upon all other habitats, mammals and birds is expected to be neutral or slightly positive.
The determination of the EIS that the proposal will result in a positive impact on the dune system and habitats is therefore contrary to existing professional advice in respect to such structures.
Section 9.2 the draft Irish Government policy states:
Modern thinking about coast protection schemes has increasingly turned towards 'soft' engineering. Traditional rigid, impermeable and 'brittle' structures, for example mass concrete or masonry walls, are now less favoured than techniques which encourage the dissipation of wave and tidal energy.
The above guidance and the additional information included in the Draft Coastal Zone Management Policy for Ireland is of vital importance and must be referred to in the assessment of the planning permit application.
3.6.2 The Heritage Council: Review of Integrated Coastal Zone Management & Principals of Best Practice The Heritage Council Review of Integrated Coastal Zone Management & Principals of Best Practice has been formed from a two month study with the purpose to examine approaches to Integrated Coastal Zone Management (ICZM) with a view to identifying best practice11.
The report examines case studies of ICZM in various countries and provides increased understanding of the process of ICZM to facilitate future policy development in Ireland.
11 Cummins, V., O'Mahony, C. & Connolly, N., 2002. Review of Integrated Coastal Zone Management & Principals Of Best Practice, Cork: Coastal and Marine Resources Centre.
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Of particular consideration is reference to the eight principles which the European Union have devised as a basis for ICZM12. Principle 4 is of particular relevance to this case:
Work with natural processes
Working with natural processes is particularly relevant in the case of coastal engineering. In order to mitigate against negative impacts of hard engineering, alternative solutions which work with natural processes should be sought, including the use of soft engineering and/or ‘setback and retreat’ options where possible.
Principle 4 acknowledges that hard engineering, such as the wall proposed, have negative impacts on the environment and it advocates for other solutions which work with natural process to be employed.
3.6.3 Assessment of Human Activity in the Coastal Zone 2001 Assessment of Human Activity in the Coastal Zone 2001 is an Irish Government funded project that was prepared for the Marine Institute13.
With respect to issues surrounding erosion and coastal defences the report states
Impacts on natural processes: There is concern regarding the impacts of hard man made protection works on natural processes. The focus is now on programmes that reinforce natural defences, with the aim of creating more environmentally acceptable protection.
The report includes discussion in respect of golf courses in coastal areas. It acknowledges that some golf courses make little alteration to the natural environment, while others involve substantial structural developments. In respect of preventing erosion, the report states:
Golf course developers may also erect rock armour defences against erosion; these local protection measures usually contribute to increased erosion on the adjacent coastline. (Emphasis added)
12 European Union, 2007. Consolidated versions of the Treaty on European Union and the Treaty on the Functioning of the European Union 2012/C 326/01. [Online] Available at: http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A12012E%2FTXT [Accessed 04 06 2016]. 13 Connolly, N. et al., 2001. Assessment of Human Activity in the Coastal Zone. [Online] Available at: http://oar.marine.ie/bitstream/10793/562/1/INTERREG%209%20Assessment%20of%20Human%20Activity%20in%20the%20Coastal%20Zone.pdf [Accessed 06 06 2016].
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3.6.4 Environmentally Friendly Coastal Protection - Code of Practice 1996 The Environmentally Friendly Coastal Protection (ECOPRO) is a ‘Code of Practice’ book published following a joint partnership between Department of the Marine, Ireland and Department of the Environment for Northern Ireland14.
The ECOPRO Code of Practice is an Irish Government publication which aims to promote the use of soft engineering coastal protection techniques. It includes information on suitable coastal protection and management solutions with particular emphasis on environmental impact. The code has a clear set of guidelines on coastal erosion management, compiled for local authority planners and engineers, community groups and individual property owners15.
ECOPRO advocates the use of soft engineering options wherever possible. In respect of such coastal protection techniques it states:
These attempt to work with natural processes rather than oppose them. An environmentally friendly scheme must often consider a certain amount of erosion as being beneficial, providing sediment interchange along the coast.
The ECOPRO code of practice is a valuable Government publication which should be utilised in the assessment of whether or not the proposed sea wall complies with the proper planning and sustainable development of the area.
14 Department of the Marine, Ireland and Department of the Environment for Northern Ireland, 1996. Environmentally friendly coastal protection code of practice. 1st ed. Dublin: Dublin Stationery Office. 15 Dollard, B., 1998. Environmentally friendly coastal protection The ECOPRO project. Survey Ireland, pp. 21-28. Available at: www.vliz.be/imisdocs/publications/40766.pdf [Accessed 06 06 2016].
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4.0 The Coastal Zone
The coastal zone at White Strand is a sandy environment and a system in continual and sometimes sudden flux. Coastal sandy environments represent dynamic and linked systems in which tides, waves, currents, storm surges, sea level and weather control the continuous reworking and exchange of sediment between offshore, beach face and supra-tidal dune systems16, 17, 18.
Coastal erosion at the subject site has been depicted as being a problem18, however erosion is part of a natural process in the cycle of the coastal environment.
Interrupting the natural process of sediment transfer will result in physical impacts either within the site or adjacent. As identified by Cooper & McKenna (2008) while armour will protect the dune front, wave reflection and scouring induced by the hard impermeable surface may seriously damage the recreational beach by removing sand.
As identified by Hanley, et al. (2014) sand dunes are integral to the defence of a land area which must withstand periodic storms where damage and erosion occurs. The cycle of the coastal area is extended over a vast temporal scale. Where dunes are eroded they rely on a dynamic interaction of dunemorphology, sediment supply, accumulation, and stabilisation to reform over time. The recent erosion of the dunes at White Strand is part of a natural process of sediment transfer.
This coastal area requires an uninterrupted path and system to allow for erosion and deposition to occur and sediment to be exchanged between the offshore, beach and dune area. An interruption in to natural process between sand bars, beaches and dunes will impact on their continual formation, movement, structure and survival16, 17, 18.
16 Cooper, J. A. & McKenna, J., 2008. Working with natural processes: the challenge for coastal protection strategies. The Geographical Journal, 174(4), pp. 315-331. 17 Hanley, M. E. et al., 2014. Shifting sands? Coastal protection by sand banks, beaches and dunes. Coastal Engineering, Volume 87, pp. 136-146. 18 Devoy, R. J., 2008. Coastal Vulnerability and the Implications of Sea-Level Rise for Ireland. Journal of Coastal Research, 24(2), p. 325–341.
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5.0 Coastal Protection of White Strand, Doughmore
Coastal protection can be defined as a mitigation measure to protect settlement, infrastructure and areas of significant recreation and culture from flooding and coastal erosion19, 20.
Coastal areas, whether they be densely populated cities or remote rural areas, can be exposed to significant consequences from storm events, increased coastal erosion, sea level rise, flooding, gradual inundation of low-lying lands and salinisation of groundwater21, 22. These issues, which are evident at the subject site and nearby area, are not a new phenomenon.
Traditionally coastal protection has been approached through the use of ‘hard’ engineering methods. These methoids include the construction of breakwaters, groynes, seawalls, dykes and gabions. This ‘hard’ engineered approach has often resulted in negative or uncalculated impacts on the local environment and is even known to impact surrounding ecosystems on larger scales21. These hard engineered solutions are becoming increasingly unpopular due to their adverse impact on beach amenity, environmental impact and visual impact23, 21.
The partial erosion of White Strand beach and dune system is not in question - it is expected of such an integrated coastal system. The issue the planning application is attempting to ‘solve’ is the protection of the private infrastructure located within the zone of dynamic variability. This is a ‘problem waiting to happen’ for both the environmental system and the golf course area adjacent (Cooper & McKenna, 2008) for two reasons:
1. The presence of the golf course compromises the ability of this coastal system to adjust to changing conditions; 2. The increase in erosion along the dune system is a threat to the constructed golf course area which is built within part of that system.
19 Borsje, B. W. et al., 2011. How ecological engineering can serve in coastal protection. Ecological Engineering, Volume 37, p. 113–122. 20 Cooper, J. A. & McKenna, J., 2008. Working with natural processes: the challenge for coastal protection strategies. The Geographical Journal, 174(4), pp. 315-331. 21 Spalding, M. D., Ruffo, S., Lacambra, C., Meliane, I., Zeitlin Hale, L., Shepard, C. C., & Beck, M. W. (2014). The role of ecosystems in coastal protection: Adapting to climate change and coastal hazards. Ocean & Coastal Management, 90: 50-57. 22 Hanson, S., Nicholls, R., Ranger, N., Hallegatte, S., Corfee-Morlot, J., Herweijer, C., & Chateau, J. (2011). A global ranking of port cities with high exposure to climate extremes. Climate Change, 104: 89–111. 23 El-Sharnouby, B., & Soliman, A. (2011). Behaviour of shore protection structures at Alexandria, Egypt, during the storm of December 2010. The International Maritime Transport and Logistics Conference "A Vision for Future Integration". Alexandria.
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The dilemma is clear: without any action (‘do nothing scenario’) it is probable that part of the golf course will have to adapt or retreat a certain extent, allowing the natural coastal process to continue. With the action proposed (‘hard engineering’), which includes construction of a 2.8km sea armour wall, the natural process will be interrupted, resulting in impacts to the dune system, the beach and sand bars, in addition to the environment and ecosystem within and adjacent to the site.
The proposed development may temporarily prevent the golf course from being eroded in the near term, however that near term benefit to a private enterprise would be at the cost of the local and adjacent environment, representing a disbenefit to the general public who use the coastal zone area for recreation needs.
The resulting impacts, of which there is a very high probability will arise from the proposed development, include:
Reduction or elimination of sediment supply;
Prevention of energy attenuation;
Reflection or redirection of excess energy;
Reduction and alteration of habitat;
Acceleration of beach scouring and erosion;
Reduction of visual amenity;
Contribution to ‘coastal squeeze’.24, 25, 26
These impacts in turn will have significant consequences for the coastal environment in and around the subject site. They will negatively impact important coastal ecosystem services such as recreational area, landscape/seascape quality, storm attenuation… amongst other things (Cooper, et al., 2016).
24 Cooper, J. A. G., O’Connor, M. C. & McIvor, S., 2016. Coastal defences versus coastal ecosystems: A regional appraisal. Marine Policy, p. In Press. 25 Cooper, J. A. & McKenna, J., 2008. Working with natural processes: the challenge for coastal protection strategies. The Geographical Journal, 174(4), pp. 315-331. 26 Hanley, M. E. et al., 2014. Shifting sands? Coastal protection by sand banks, beaches and dunes. Coastal Engineering, Volume 87, pp. 136-146.
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The design of the proposed sea wall at White Strand, which will reach a height of 6m OD, will contribute to the numerous negative environmental and ecological impacts identified above. The proposal is of such a scale that the natural processes will be severely interrupted.
The societal perception that coastal erosion causes economic loss and societal issues often ignores the important facts that (i) coastal erosion provides many societal benefits through its contribution to coastal ecosystem services (in particular sustaining beaches) and (ii) efforts to combat coastal erosion are damaging to coastal ecosystems and the services they provide (Cooper, et al., 2016).
The combined protection (‘hard engineering) of the golf course at Doonbeg and protection of the beach and dune ecosystem will not be achieved by the proposed development. The hard engineering proposal will only achieve partial short term results for the golf course but will generate considerably more significant longterm problems within and adjacent to the site.
5.1 Hard Engineering Coastal Protection Case Study: Rossnowlagh, Ireland.
The 2km beach (Belalt Strand) at Rossnowlagh lies in Donegal Bay, south of Donegal Town. The beach is composed of fine sand backed by a narrow gravel ridge, with vegetated sand dunes present on the landward side of the beach.
Rossnowlagh is a major holiday resort for the area. Land use consists primarily of caravan sites, holiday homes, a hotel and car park, with cattle grazing the dunes periodically27.
As a means to protect the existing landuse within the dune system, rock armour has been built covering over 50% of the area between the beach and the dune system. The rock armour protects the areas of the dune which it is in front of, however it has been concluded that, due to the armour, erosion has probably accelerated on the remaining sections of natural dune that are unprotected28.
27 Eurosion [European Union], 2004. EUROSION Case Study Rossnowlagh Donegal. [Online] Available at: http://copranet.projects.eucc- d.de/files/000126_EUROSION_Rossnowlagh.pdf [Accessed 08 06 2016]. 28 Cooper, J. A. & McKenna, J., 2008. Working with natural processes: the challenge for coastal protection strategies. The Geographical Journal, 174(4), pp. 315-331.
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Figure 6: Rock Armour Sea Wall, Rossnowlagh. Copyright Eurosion
Negative impacts on the beach environment, resulting from the rock armour, have been identified to include wave reflection and subsequent scouring of the recreational beach by removing sand29,30. External sand supply is identified as being quite limited, as storm-wave sand release from the dunes to augment the beach and improve its wave-damping capabilities is effectively prevented by the armour wall and it is likely that erosion will intensify30.
As identified by Cooper & McKenna (2008) the proliferation of coastal defences at Rossnowlagh has been largely driven by private owners rushing to realise the value of coastal sites, aided by an uninformed and pro-development planning ethos.
29 Eurosion [European Union], 2004. EUROSION Case Study Rossnowlagh Donegal. [Online] Available at: http://copranet.projects.eucc- d.de/files/000126_EUROSION_Rossnowlagh.pdf [Accessed 08 06 2016]. 30 Cooper, J. A. & McKenna, J., 2008. Working with natural processes: the challenge for coastal protection strategies. The Geographical Journal, 174(4), pp. 315-331.
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The Eurosion (European Union, 2004) case study of coastal management at Rossnowlagh concluded:
Armour prevents the beach and dune to function as a dynamic system by presenting a barrier. Thus the beach can no longer adjust to storm waves by eroding dune sand. Incoming wave energy is now reflected rather than being harmlessly dissipated. Wave reflection from the armour often causes scour, leading to beach narrowing, steepening and lowering. In summary, armour may ‘save’ the dunes at the expense of the beach.
Figure 7: Rock Armour Sea Wall, Rossnowlagh. Copyright Eurosion
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6.0 Conclusion
The proposed development has been assessed in accordance with the relevant legislation, policies, guideline documents and scientific research. The subject site is extremely sensitive to human induced change and is of European significance due to its environmental characteristics, and is consequently afforded legislative protection to reflect this status.
The proposal is significant in terms of size, visual impact, environmental impact, temporal scale and consequence to the site and surrounding area.
This assessment has concluded that the proposal should not be supported as it does not accord with the Clare County Development Plan, relevant policies and guidance and the proper planning and sustainable development of the area. The proposal contradicts modern coastal zone management which is now supported by factual scientific information and extensive field research of past cases.
It has been determined by An Bord Pleanála that the proposal is not of regional importance and therefore will serve private interests only. The prevention of erosion of the golf course is not of strategic significance and alternatives should be explored which will not negatively impact this public natural and protected environment.
On the basis of balanced judgement, where economic factors should not influence planning outcomes at the expense of the environment, the proposed development should be refused planning permission.
Yours sincerely,
______
Neil Cooney
Managing Director, URC Planning
Urban | Regional | Coastal - Planning Consultancy
BSc Spatial Planning (Dublin Institute of Technology) | Pg. Dip Marine Spatial Planning (University of Ulster) | M.I.P.I.
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