Concerning the appeal of 58 holiday homes, clubhouse and bar, restaurant, health centre & tennis court, at Ventry, Dingle, County Kerry
Your planning reference No PL 08.103176
Observation to An Bord Pleanala
Friends of the Irish Environment has grave concerns about the proposed development at Ventry and strongly opposes a grant of permission by the Board.
The proposed development is seriously flawed on a number of grounds, all of which must be taken into account by the Board.
Our principal reasons for opposition are as follow:
1. The Environmental Impact Statement accompanying the application is fundamentally inadequate, and fails to address with any completeness a number of issues of crucial significance to the Board's evaluation of the project. The Board cannot properly carry out an assessment of the development's likely effects based on the EIS provided.
2. The scale of the development is profoundly out of character with the surrounding area and, especially in line with government and EU guidelines on sustainable tourism development, cannot be considered proper planning and development.
3. The injection of a development of this scale into a culturally rich Irish-speaking area would represent a serious planning mistake. The issues of cultural heritage at stake go far beyond the relatively superficial questions on this score to which the EIS confined itself. Questions of cultural authenticity, landscape idiom, land prices and control by local people of their tourism resources have not been addressed.
4. It is not at all clear that the site is of only slight importance under the habitats directive. Friends of the Irish Environment notes with alarm that there have been very few Special Areas of Conservation designations proposed for the Dingle Peninsula. The EIS notes in conclusory fashion that the site was not significant enough to be included on the draft list of Special Areas of Conservations, yet we feel that there has been no scientific offered as justification for this conclusion.
We will briefly address each of these points in turn.
1. The EIA question.
Although an EIS has been provided for this proposed development, it is inadequate to its task. Because the EIS does not fully identify all potential effects, it is not a document upon which the Board can base a complete environmental impact assessment. An EIS is not meant to provide a summary of why, in the developer's view, there will be no adverse effects, but to fully and systematically identify the relevant adverse effects (as set out in the environmental impact assessment directive 85/337/EEC) and to discuss possible mitigation.
Ventry is an area of extreme sensitivity-linguistically, culturally and in terms of the landscape/culture continuum. This dynamic of cultural and material factors is something the EIS hardly acknowledges. The resistance of objectors (and it is worthy of the Board's note that the vast majority of local people are squarely against this development) is not based on the fact that "outsiders" will come to Ventry, as the EIS seems to suggest. Rather, the intrusion onto this historic landscape of a full 58 holiday homes and attendant buildings alters the very language of the visual landscape, and suburbanises the atmosphere of one of Ireland's rare and rich treasures.
It is safe to say that in a small community like Ventry, the sudden injection of 58 residential buildings plus attendant buildings and car-parking etc, will be a radical and dramatic alteration. The alteration will be in the idiom of the locality. The proposed development will be a dominant physical presence. It cannot be said to be "vernacular", since it is so large relative to all organic development that has taken place in the locality to date. Vernacular multiplied many times is surely by definition no longer vernacular in any recognisable sense.
The descriptive terminology used in the EIS is revealing: "The developed house types are similar to other types found successful in other equivalent holiday developments‚Ä¶." (1.5.1) The uniqueness of the place-its linguistic heritage, its FIEld patterns, its unspoiled character-makes it almost unthinkable that a generic pattern of "successful" holiday cottages could be contemplated for it.
Alternatives and possible mitigation
The EIS discusses (1.6) site planning options and alternatives. In EIA terms, discussion of alternatives must indicate mitigating alternatives, with a view to lessening adverse environmental impacts. Instead, this EIS focuses on the issue of how this scheme is not as damaging as an earlier scheme for which there was permission granted. In terms of the EIS at hand, surely comparison with an earlier, yet more intrusive scheme, is not relevant, and does not satisfy the criterion of discussion of possible mitigation of adverse environmental effects.
Land use issues; exclusion of the site from protective designations
Land use issues are crucial to the Board's analysis of the appropriateness of this site. We will discuss the significance (below) of the fact that the Dingle Peninsula seems to have very few Special Areas of Conservations proposed for it. This means that the peninsula lacks the full protection of European bio-diversity law. While the Kerry Development Plan indicates that the area all around the site is designated as Amenity and/or Conservation Area, as the EIS says (2.1), the subject site is "specifically excluded." The EIS does not attempt to account for this peculiar fact. We assume that the Board will satisfy itself on this score in the course of its deliberations. We note with surprise that the proposed NHA for the area also "specifically excludes" the subject site (EIS 2.2). We call on the Board to account for the fact that this one particular site, so like its surroundings, continues to receive a "specifically excluded" status.
We believe that the proposed development is seriously at variance with the county development plan objectives on tourism, which require the strengthening of the "existing settlement pattern of tourist centres," as referred to in the EIS. This development would place an inordinately large suburban style village in the midst of agricultural land, which has been developing according to small scale interventions for generations. Friends of the Irish Environment calls on the Board to affirm the county tourism policy which seeks to strengthen existing centres and locally owned tourism amenities.
The section of the EIS on archaeology (2.3) is inadequate. We note that the EIA directive requires that archaeological heritage be treated as part of the environment for purposes of assessing the possible adverse effects of a development. (See Annex III of Directive 85/337.) The EIS seems to consider only the crudest form of damage (that is, physical wrecking) to be relevant. The fact that holiday cottages will be built in large number right up next to ring forts does not seem to be treated as damage. Surely the context and setting of national monuments is as important as actual physical interference. This more sophisticated concept of damage was not included in the identification of impacts. Apart from the "damage during construction phase", the authors of the EIS apparently did not consider that the utter change in the context of these important monuments would be of significance. We ask the Board to take this question into account.
Effects on tourism resources
The EIS discusses the effect of the development on the local "tourism product" (EIS 2.4). As with many of the recent holiday home developments in Ireland, there is an underlying assumption that if you build them, they will come. There is every possibility that the suburbanisation of the rural landscape, especially in a place as famous for its dramatic scenery as Dingle, will have a chilling effect on tourism, especially from the Continent. The Board must require that statements in an EIS such as "The proposed development, by virtue of its character housing accompanied by recreational facilities), will ensure that the complex is used all year round" be accompanied by comparative statistics from similar developments in Ireland. One does not hear the people of Enniscrone or Kilkee saying that the holiday homes built there have been occupied all year round.
Visibility; views; the "vernacular" question
The proposed development is not a development that would have or could have derived organically from the needs or economy of the locality. It will be, as many other holiday home developments in Ireland, essentially tax driven. The impacts on the landscape and character of the area are cultural and aesthetic, and have to do with factors of local colour and mood which will most certainly be altered in dramatic fashion by 58 holiday homes, even if designed in imitation vernacular style.
The EIS argues that the proposed development will only be visible from one of the relevant listed views. We would argue from first principles that an intervention of this scale into an agricultural landscape cannot help but represent a major intrusion-visually, aesthetically and emotionally. Terming the holiday homes a "clachan" cannot conceal the fact that the development will be an extremely unnatural intrusion.
The natural siting for tourism developments is in existing towns and villages. Local people should be offered grants or seed money to restore their own extra buildings for purposes of self-catering. We fear that ireland may now be pursuing a policy that Spain mistakenly pursued in the 1970s, and is now spending money to undo by demolition. That is, the policy of privatising all the spectacular views and building up intensively around these, such that the aesthetic wholeness of our unique localities is incrementally destroyed. The EIS makes much of the fact that the clustering of the houses is not as insensitive or intrusive as it might be. When one is dealing with 58 houses in setting of this kind, with other buildings and car parking, any placement of buildings would be intrusive and damaging to the local aesthetic/cultural uniqueness of the place.
The EIS states at 3.2.5 that "The dwellings will sit into the landscape in this area, and will effectively integrate with the existing landscape and settlement pattern." It is impossible for a holiday complex of so many units to "integrate" into an existing pattern, since pattern is unintelligible without a corresponding consideration of scale.
Flora and fauna analysis
Section 4 on Flora and Fauna is particularly sad, in our view. The studies upon which it is based were conducted during winter conditions. Anecdotal evidence abounds of the presence of migratory birds, otters and various important marine plants. The unscientific statement that "bird numbers are small" is particularly unsatisfying. It is well known that adequate analysis of the presence of plant species cannot be carried out in December in Ireland. We ask the Board to take this important fact into account and require further independent research into the plant life of the site during a more representative period of the year.
Surely the juxtaposition of FIElds and dunes constitutes a rare and wonderful sight. There is ample reason to preserve this site on the basis that it is short-sighted and improper in planning terms to place a holiday village so near the sea when the proximity of agricultural activity overlooking the sea is one of the principal charm points of the area.
We draw the Board's attention to the very puzzling statement in section 4.7 of the EIS: "The site is adjacent to a proposed NHA-Ventry Dunes and Marshes #1384-which covers the strand east of the fence line and the dunes and marshes to the north and south of the land (see map). The NHA has not been surveyed completely but it does not seem to have habitats of high enough quality to be proposed as a Special Area of Conservation." We are troubled by the idea that the proposed NHA has not been fully surveyed, and that on the basis of this incomplete scientific evidence, the EIS asserts that "No priority habitat or species listed by the habitats directive occur on the site and there are no plants protected by the Flora Protection order 1987." Then, "The chough and common/artctic tern are included in Annex I of the Bird Directive 79/409/EEC as requiring special conservation measures." It is difficult to tell from this presentation whether or not the birds in question are receiving the requisite protection under the wilds birds directive. It is the responsibility of the Board to satisfied itself hat the terms of the wild birds directive are being met.
Section 5 of the EIS dealing with traffic fails to point out that traffic from tourism developments is mitigated only when the developments are located within existing settlements-existing towns and villages. Ireland's beauty spots are notoriously car-jammed during the summer months and this will surely result in an adverse effect on tourism generally in the near future. The entire thrust of the development-outside existing towns, car-based and out of scale-is contrary to the spirit of sustainable development, and policies of the Irish government and the European Union with regard to sustainable development.
Water and sewage
We find Section 6 of the EIS on water to be utterly confusing. It is unclear whether adequate water supply and sewage is in fact available. It would appear that the water situation is still unresolved, and the developers are hoping for the best in that respect. There is no indication of what will happen if it turns out that there proves to be no source of acceptable drinking water to serve the site. Surely the Board should be fully satisfied that there is an adequate and safe water supply for such a large development. The section on sewage is less than revealing as to the actual system being put in place. The precise nature of treatment and disposal being proposed is less than clear. We note that improper sewage disposal could be extremely damaging to the nearby marine ecology.
Culture; socio-economic impacts
Section 7 on Socio-Economic Impacts is not adequate to a site of this extreme sensitivity. Merely to say that rural Ireland is losing population and needs jobs is not proper analysis. There are larger questions as to national industrial policy, agricultural trends etc, which go beyond the scope of this application. However, since the EIS purports to assert that holiday home developments improve the population outlook, we beg to differ. In scenic areas where there have been large scale holiday home developments, it is well known that there is a serious spiralling effect on local land prices. It is acknowledged by everyone, and most adamantly by Friends of the Irish Environment, that there must be both planning and economic policy to encourage local people to remain in Gaeltacht areas, which are both fragile and vitally important cultural communities. Turning agricultural land into holiday home developments is a proven method of raising land prices beyond the reach of locals, destroying any possibility of maintaining cultural cohesion.
The pull into larger cities and towns can only be reversed by carefully targeted planning and economic policies which provide start up money and incentives for local people to develop small scale business appropriate to the proper development of their area. Local people in areas like Dingle must retain control over their own local tourism industry. Once that slips from their hands, they have essentially lost the ability to remain in their own place.
We remind that Board that it is official policy that the Irish language must be preserved in its natural cultural setting. Large-scale holiday home developments, especially those driven by tax imperatives, cannot be seen as a means of achieving this, and will undoubtedly have the very opposite effect.
We question in the most serious terms whether the figure of 37 jobs is a convincing one. Again, since it is asserted in the EIS we wonder why the authors did not include a comparative study based on other places in Ireland where there has been significant holiday home development. We trust that the Board will only consider post-construction phase job predictions. We call on the Board to ask of the developer how many of the jobs will be part time and how many full time (based on factual comparisons with similar developments), and what their pay scale is likely to be. We note that it is said that some hotels in the West of Ireland now employ students from abroad in the summer, rather than local people. While this is not objectionable in itself, a handful of poorly paid jobs is hardly a reason to ask the community to give up one of its scenic treasures to facilitate a private development. "Cleaning staff" of eight persons strikes us as a particularly fanciful figure. The Board is invited to require more factually-based predictions of job creation.
We ask the Board to engage in a more complex analysis and assessment than would be possible on the basis of Section 7.3 of the EIS on "Cultural Impacts." The EIS would suggest that objectors are unhappy at the thought of an influx of outsiders. That is obviously not even remotely the case. The problem rather lies in the loss of the authentic character of the locality, which fosters and provides a natural setting for a cultural life which is an aspect of Ireland which requires protection from official bodies such as the Board itself. Tourism development must respect the dominant historical mood of the place in which it takes place. Otherwise, one witnesses a downward spiral of cultural cohesion and a rapid loss of identity. We reiterate that it is a misnomer to term "vernacular" a development of this utterly incongruous scale.
We find Section 8 of the EIS on "Interaction of Impacts" to be purely pro forma (even though, as per the directive, it ought to have been taken seriously) and without content.
2. Tourism policy objectives
In 1997, the government published an important document entitled Sustainable Development: A Strategy for Ireland. Friends of the Irish Environment believes that the Board must take into account the objectives expressed in that document.
We note that on page 123 of the publication, there is specific reference to the Dingle Peninsula. "It is recognised that a small number of sensitive landscapes is already experiencing significant pressure from tourism. These include the Burren, Connemara, the Ring of Kerry, the Dingle Peninsula and the Wicklow Mountains." While the document itself as well as all interested parties recognise the desirability of sensitive and careful development even in areas under pressure, this proposed development is clearly not of the type that would be allowed for in any coherent management plan for the area in question.
Page 117 of the same document states that "Maintaining the Irish environment and physical cultural heritage, which are recognised as being of high quality, will provide the foundation on which to build sustainable tourism and take advantage of ‚Ä¶.international trends." Similarly, page 118 says that "A key issue for tourism is the protection of our natural and cultural landscape. Local development plans must ensure the protection of this landscape, as well as the preservation of views and of human heritage‚Ä¶.National tourism policy recognises that Ireland should not aim at becoming a mass tourism destination. Local authorities, in preparing development plans, will make provision for sustainable tourism and, in considering applications for tourism development, must recognise capacity limitations and not permit over-development."
Environmental regulations governing the use of European funds for tourism purposes, the imperatives of the EIA directive, and the European eco-labelling scheme for tourism, give a clear indication of European policy in this area.
We urge the Board to recognise that, being of a scale that is entirely out of harmony with locally-generated, organic and incremental development, this development must be refused as being contrary to national and EU environmental and sustainable tourism policies.
3. The issue of local culture and the use of minority languages
We have explained above our views on the inadequacy of the EIS's analysis of the possible effects of this type of development on the extremely sensitive cultural value of the area. This inadequacy on the part of the EIS does not release the Board from the obligation to fully assess the likely effects on the cultural heritage of Ventry and the Dingle area. We draw the Board's attention to the inclusion of effects on the cultural heritage in the EIA directive.
Irish government policy has always attempted to foster types of developments in Irish speaking areas that would be conducive to the preservation of the language and culture so vital to national identity. The injection of large scale holiday villages into this fragile balance is extremely dangerous and can have unpredictable consequences. We have drawn the Board's attention to the problem of land prices in areas where there is pressure from holiday home developments. The Board should assess by analogy the effects on land prices of holiday home developments in other scenic/coastal parts of Ireland, and then fully assess the likely effects on the Irish-speaking population of Ventry.
Industrial, residential and commercial development in Irish-speaking regions must be seen as part of a dynamic. The EIS provided with this application merely points to a static number of jobs and states that these jobs will encourage people to stay in the area. We point to the dangers of allowing this sort of development, in that it will likely have the complex effect of raising the costs of purchasing local property for locals, increasing the inclination to sell out and move away by other landowners, and also, crucially, changing the tourism mix, in a manner that starkly reduces local control over local tourism.
We draw the Board's attention to the fact that Denmark sought and received an opt-out from Community law with respect to the possibility of non-residents owning holiday homes in Danish coastal areas; not out of a wish to exclude outsiders, but rather in recognition of the fact that these property-related phenomena act in a dynamic fashion, and could have the ultimate effect of driving local people from their traditional communities.
We urge the Board in the strongest possible terms to assess this dynamic and to enforce a land use principle that allows local communities to remain in control of their own tourism potential. To allow this development would be contrary to national policy on the Irish language and thus clearly contrary to proper planning and development.
4. Friends of the Irish Environment is concerned that there are few proposed Special Areas of Conservations for the Dingle Peninsula.
It is in this light that we must react to statements made by the relevant authorities and repeated by the developer that the site in question was not of a standard to warrant inclusion on Ireland's draft list of Special Areas of Conservations. We feel that there should have been more effort made to fully assess the possible presence of important plant and marine life in and near the site. We are concerned about the effect of waste generated at the site on the marine ecology of the im- Mediate area. We are unconvinced by the EIS that there has been a full assessment of plant and animal life on and near the site. The EIS itself acknowledges that there has been no complete survey done of the proposed NHA for the area, and that the site in question is "specifically excluded" from the NHA and other designations. No scientific account is offered as to why this specific exclusion has been made.
We ask the Board to asses statements made to the effect that there are implications under the habitats directive for allowing this site to go ahead, in the light of the troubling fact that (a) there has been few Special Areas of Conservations proposed for the Dingle area; and (b) that there has been no scientific explanation offered for the often-repeated fact that this site has received specific exclusion from national and local protective designations.
For these reasons, and others raised by the many objectors to this proposed development, we ask the Board to refuse permission, particularly in view of the fact that the EIS is inadequate and fails to fulfil the requirements of the EIA directive (85/337). The EIS provided is too incomplete to act as the basis upon which an assessment of likely environmental effects may be made. Also, the development is out of scale and harmony with local cultural and physical heritage. It is similarly out of harmony with the landscape and natural amenity value of the area, and clearly contrary to national and European policy on sustainable development.