SAVE THE SWILLY - August 29 ,2005

August 29, 2005

SUBMISSION RE: DONEGAL COUNTY DRAFT DEVELOPMENT PLAN 2005

Save The Swilly made submissions to the Donegal County Council in response to the earlier consultation process in September 2004. The thrust of those was that the Donegal County Council should embrace Integrated Coastal Zone Management (ICZM) and implement ICZM strategies for the whole of the county’s coastal area.

We note that the current draft document refers in Section 2.5.9.4 to Policy NRD52: “Identify appropriate strategies for Integrated Coastal Zone Management frameworks and implement these frameworks at selected locations.”

Given the multiple users of Lough Swilly, including commercial fishermen (inshore, shellfish, pelagic and demersal), aquaculture operators, sailors, divers, swimmers, hikers etc., we believe strongly that an ICZM strategy is urgently needed for this area. It is not clear from the Draft Development Plan 2005 which locations in Donegal may be “selected locations” and it is important to clarify this point. Informal discussions have suggested a pilot ICZM project would be launched in Donegal Bay, because it is less contentious than Lough Swilly. We believe this is missing the point of ICZM, which should be to reconcile competing interests, achieving the best outcome for all concerned.

Policy NRD53 states: “Ensure the inclusion of aquaculture as an integral part of such ICZM frameworks.” This suggests that an ICZM framework will be put in place wherever aquaculture developments exist or are contemplated. However, this has not been the case within Lough Swilly, even though our group took the initiative in 2002 to commission an independent Scoping Study for an ICZM [Integrated Coastal Zone Management] strategy for Lough Swilly from the University of Ulster’s Coastal Research Studies Group. This Scoping Study was offered to the Donegal County Council at various stages, with copies provided to all elected members of the Council. We also offered to host a presentation by the lead author of the key findings of the Scoping Study to the Fisheries Committee of the County Council, but did not receive even the courtesy of a reply.

Recent press announcements regarding “a coastal and research facility on Lough Swilly” have made reference to the 2002 Scoping Study, although acknowledgement that it was a Save The Swilly initiative has been omitted. In our view, that is not the spirit in which ICZM should be conducted, and we urge the Council to take the bull by the horns and to initiate a debate that allows all opinions on the subject of aquaculture and its competing interests to be freely aired.

On page 74 of the Development Plan 2005, under Section 2.5.9 The Marine Resource, the Aquaculture section states: “…it is recognised that aquaculture harvesting and associated processing have the potential to provide an economically viable alternative to commercial fishing and aid sustainable rural diversification.” While that may be the case, it is irrational to allow or support a policy that deliberately undermines the fishing sector.

substantial expansion of aquaculture has been allowed within Lough Swilly without any indication of an overall plan; how it might affect other interests; and what the net benefits to the community might be. The Coordinated Local Aquaculture Management Systems (CLAMS) plan is not a version of integrated coastal zone management. It is a mechanism for asserting the interests of the aquaculture industry, which is only one of many stakeholders in the coastal environment. Absence of an overall plan and lack of consideration of other legitimate stakeholders are in direct contradiction to the supposed benefits of the aquaculture policy as cited in the section above, and contrary to EU recommendations:

"Integrated Coastal Zone Management (ICZM) . . . Future aquaculture development should be based on Integrated Zone Strategies and Management Plans which consider aquaculture in relation to all other existing and potential activities and take account of their combined impact on the environment."

• Commission of the European Communities - Communication from the Commission to the Council and the European Parliament: A Strategy for the Sustainable Development of European Aquaculture, September 2002.

A further point on aquaculture and its development within County Donegal goes directly to the Council’s role and responsibility as a statutory consultee in the aquaculture licensing process. Over the past eight years, according to documentation received from the Department of Communications, Marine and Natural Resources, Donegal County Council has not seen fit to make written comment on a single aquaculture licence application, positive or negative. This is, in our view, a serious abrogation of the Council’s duty of care regarding the coastal zone, and we believe the Development Plan 2005 should include a commitment to state clearly the Council’s views on every aquaculture application within the county, and the reasons for these views.

Save The Swilly is not opposed to aquaculture per se, as is commonly claimed. However, we do believe that there are locations appropriate for aquaculture, and other locations which are not appropriate for such developments. We have not objected to all aquaculture developments in Lough Swilly, but what we have stressed is that no aquaculture developments should be allowed without a full assessment of the carrying capacity of the bay for any such activities, and for their cumulative effects. Our main objection is the fact that there is no overall plan – for Lough Swilly, or indeed, nationally.

"Targets have been set for increasing the output from aquaculture over the next 15 years. However, there does not appear to be a vision or strategy for how or where this increase in output will be achieved. Sustainable aquaculture needs to exist in harmony with other resources and activities. There is no clear framework for working with other agencies/interested parties to ensure the industry develops in this way. . . Lack of vision for aquaculture: Although an aquaculture production target for 2015 exists, it appears to have been developed in the absence of a carrying-capacity assessment for the coast, and without a state vision for the industry, in social, economic and environmental terms."

• 'Review of the Aquaculture Licensing Process', prepared by KPMG Consulting/Posford Duvivier Environment, commissioned by Ireland's Department of Marine and Natural Resources, April 2001, pp. 40-41.

"The development of a vision for marine fin-fish and shellfish aquaculture should be based on a thorough understanding of the carrying capacity of the waters where marine aquaculture is already prevalent and in those areas where it is set to expand. It should seek to ensure that its goals do not compromise environmental integrity, or negatively affect other socially, economically and culturally important livelihoods, particularly tourism and fisheries."

• ibid, p.44.

Donegal has a proud record in the area of Integrated Coastal Zone Management (ICZM), having participated in the EU LIFE-sponsored project which produced a Guide to Rural Beach Management. Following that project, Donegal has continued its work on coastal zone management with a carefully-researched strategy on marine leisure and a current cross-border project on beach management, with pilot projects at Rossnowlagh and Benone.

However, we believe far more can be done in developing and extending the Blue Flag Beach programme in County Donegal. For example, in the Guide to Rural Beach Management it is recognised that Ballymastocker Beach at Portsalon could host a second Blue Flag Beach (to add to Warden Beach) if the required infrastructure were put in place. It should be a commitment within the Development Plan 2005 to create a new Blue Flag Beach at Portsalon. The benefits to the local economy are clear, as the growth in tourism in areas with Blue Flag Beaches demonstrates. In fact, according to Policy NRD67, “[The Council will] not favourably consider development proposals which adversely compromise the recreational and environmental amenity of designated and proposed Blue Flag beaches.” We believe this policy should be strengthened and extended, with a commitment to expand the number of Blue Flag beaches in the County, and to allocate funds to this development.

It is known and acknowledged that Ireland's coastal zone is an area of considerable natural wealth, but also one of diversity and, indeed, competition for resources. The Coastal Zone component of Ireland's Spatial Strategy document, published in 2001, notes that "The physical diversity and dynamism of the coast has created an environment that is both highly productive and biologically diverse and which, in turn, is one of the main attractions of the zone for economic activity."

The same document concluded that "The need for Integrated Coastal Zone Management (ICZM) is accepted by the Government as a commitment in its Action Programme for the Millennium and the Department of the Marine and Natural Resources, as lead Department, is charged with preparing (after consulting all relevant Departments) policy and legislative proposals for Government consideration."

While this national strategy has not yet materialised, Donegal County Council has, in effect, embraced the concept of ICZM with its work on beach management and on marine leisure strategy. However, the concept needs to be formally embraced, and a fully-integrated programme for managing the coastline put in place. It is our belief that Lough Swilly is an ideal location for a pilot ICZM project, as it comprises all the attributes of Irish coastal zones. It is a natural deep-water port; it has a range of fishing activities, supporting indigenous inshore and pelagic fishing communities, including oyster, mussel and lobster boats; it has existing and proposed aquaculture licences, including finfish and shellfish operations; there is an extensive and diverse leisure boating sector; there is a growing community of permanent and holiday residents on the shore; it hosts numerous important conservation areas, including Ramsar sites; there exist serious issues relating to waste disposal, especially sewage and industrial effluent, both from onshore industries and marine-based (aquaculture) industries.

Planning decisions in coastal areas need to recognise the implications for water quality, and the Development Plan 2005 must take into account the Water Framework Directive, which will become operative during the life of the Plan. This Directive will require all national and local authorities in Europe to comply with strict water quality criteria applicable to inland waterways and to the coastal zone up to one mile (1.6 kilometres) offshore. It is likely that compliance with the Water Framework Directive will be linked to structural funding from the European Commission, and it should be recognised within Donegal that the new Development Plan must incorporate the requirements of the Water Framework Directive (WFD). By implementing a credible ICZM strategy for the whole Donegal coastline, it is likely that the Council will be meeting many, if not all, of the requirements under WFD.

One aspect of the WFD which will rebound on the Donegal County Council relates to the ongoing explosion in holiday home development along the coastline, and the serious impact on water quality as well as on the quality of life of local communities.

The apparent failure of the County Council to agree to the limitation of holiday home development in the latest iteration of the Draft Development Plan 2005 and to the restoration of a balance between holiday home development and permanent housing -- even though this was strongly voiced by attendees at public consultation meetings such as those in Milford -- has some profound implications:

• “Hollowing-out” of local communities, by depriving first-time buyers of access to affordable housing, undermining the social structure of coastal communities such as Portsalon, Rathmullan and Downings, among many others;
• Use of an apparent “free-for-all” policy on holiday home planning as a justification or rationalisation for other damaging development. For example, in advancing a case for establishing a large salmon-farming operation near Portsalon’s Blue Flag beach, the applicant makes this statement: “The siting of sea cages at the location licensed should not have been judged in isolation, especially in view of other significant shoreline developments, permitted without reference to their visual impact, which now affect the visual amenity of the Portsalon area.” In other words, because past Donegal County Council planning decisions have enabled excessive development of holiday homes at Portsalon, we should therefore be allowed to now introduce equally damaging impacts on the visual amenity in the water!

Models for the development of ICZM strategies do exist elsewhere in the world, notably in Scotland, which last year published a document calling for coastal zone management strategies. These included:

• Creation of a national planning framework which includes a system of coastal and marine spatial planning;
• Encouraging local authorities to prepare coastal policy statements covering the inshore waters within 12 miles of terrestrial boundaries, for inclusion in district-wide plans;
• Creation of a coordination group within government to oversee, lead and champion the development and delivery of Integrated Coastal Zone Management (ICZM) in Scotland;
• Carry out and audit to ensure that the best use is being made of existing mechanisms for collection, analysis and dissemination of data;
• Generate an understanding of the monetary and non-monetary value of the coastal zone;
• Produce a good-quality report on how to get people and communities involved in decision-making related to the coast and inshore waters and review at a national level.

We believe this is a common-sense approach, and that Scotland should be commended for embracing the ICZM approach to coastal policy. In Ireland, we believe County Donegal can and should take the initiative in developing an ICZM strategy and implementing it.

We believe that a systematic and methodical approach to coastal zone management, starting with a detailed objective analysis of the costs and benefits of a particular activity, will serve to maximise the returns from this valuable resource. We submit that a pilot Integrated Coastal Zone Management strategy be included as a core component of the Donegal Development Plan 2006-2010, going beyond the “test” or “pilot” projects now envisaged.

“Coastal management in Ireland is characterized by a sectoral approach to resource exploitation and management. . . . Unless decision makers facilitate the development and implementation of an integrated management strategy for the coastal area, by adopting a broad perspective and a multi-sectoral approach, the policies, which will prevail, will continue to be driven by sectoral interests placing sustainable development of the coast beyond the reach of current and future generations.”

• Review of Integrated Coastal Zone Management & Principles of Best Practice. Prepared for The Heritage Council by the Coastal and Marine Resources Centre, University College Cork. 2004.

In the interests of such a multi-sectoral approach, and in the spirit of full and transparent consultation, Save The Swilly is willing to place this submission in the public record. We submit that all submissions from special- interest groups be similarly accessible to the public. There is a belief that shifts in policy on vital issues such as planning in sensitive areas is influenced by special interests. Transparency of all submissions will serve to dispel such concerns.

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