On 4th March 2013 An Bord Pleanála decided to grant planning permission for the new pier development at Doolin, Co. Clare. This marks about 2 and half years since I became involved in the case to save the waves at Doolin Point and Crab Island.
For a background on this topic please click here.
I’ve just finished analysing the decision of the board and the detailed assessment undertaken by the Planning Inspector. To say the least I am puzzled, outraged and disappointed with what has turned out to be, in the most part, a game of process with a final political decision at the end.
Planning can be a difficult discipline to understand at the best of time and it is especially technical and detailed in this case. Being a Town Planner I must first applaud the Boards Inspector who prepared a comprehensive report on the case with every aspect of the proposal given due consideration. I cannot give the same appreciation to the Board members who have failed the planning process in this instance.
To give you some context of the information associated with this case; the Board’s decision is 9 pages long with the Inspectors report a lengthy 84 pages in total. To break down my assessment and critic of the case I’ll first look at the Board’s decision and then the Inspectors report. I hope to prepare another article soon on the way forward from here for the affected parties.
In a nutshell the decision of An Bord Pleanála’s considered that with the attached conditions “the proposed development would improve the public safety of facilities at Doolin, would enhance the potential for development of tourism and employment in the area, would provide an opportunity to enhance/upgrade the landside facilities and amenities at Doolin, would not result in significant adverse effects on the environment and would be in accordance with the proper planning and sustainable development of the area.“
Not only am I deeply concerned of the potential impact the development could have on the surfing waves in the area, I am also worried of the impact the development will have on the environment, in particular the dolphins and other sea creature along with the view and feel of the area.
Copyright: Paudie Scanlon
Regarding the potential impacts on quality of surfing waves the Board “agreed with the Inspector that the waves in question were of significance and in themselves play a role in the emerging sport, leisure and tourism activity of surfing. The Board acknowledged that the hydrodynamic modelling submitted with the application does not cover all potential scenarios but considered that Clare County Council’s approach to assessing impacts was reasonable.
On the basis of the information provided, the Board did not consider it likely that the impacts on the surfers’ waves would be significant and considered that any impacts would not be of such a nature and extent to warrant a refusal of the proposed development.”
Firstly, I have to question how the Council’s approach to assessing impacts was ‘reasonable‘. As I will outline later in more detail, the Inspector concluded that the information provided to assess the impacts on waves was not suitable. So, how can a body come to a conclusion on the impact of something if the information they are basing their decision on is inaccurate? This is the first of many points that are puzzling. You must remember that the Inspector is an impartial, highly respected professional who has a qualification in the area of Spatial Planning and years of experience in the field.
The Board’s decision includes a condition relating to the impact of the development on the surfing waves. Condition 6 states:
“The specific design of the pier revetment, and the materials used, shall be such that the reflection co-efficient shall be no greater than 0.4 as set out in the environmental impact statement.
Reason: In the interest of clarity and preserving the quality of the adjacent surf waves.”
While this condition may seem to be a good outcome and a win for the protection of the waves it is far from so. The condition holds very little weight as the Council do not even know how this will be achieved or even if it can be achieved. In addition the enforceability of this condition is slim. Should the development be built and the revetment not achieve the required outcome do we really think that the pier will be removed? that the revetment will be redesigned and reconstructed? The short answer is no. This is dealt with in more detail in the Inspectors report and continued in this article below.
The Board members consist of very educated people with varying backgrounds that relate either directly or indirectly to planning. My concern of some decisions of An Bord Pleanála in recent years is that the economic climate of Ireland has had an overshadowing influence on decisions.
Photos Copyright: Paudie Scanlon.
The Inspector’s Report is extremely lengthy and this is purely due to the scale of the development and the complexities involved in the impacts it may have. For the full report click on this file.
I have noted above that this decision has serious consequences for the environment as well as the surfing waves, however, I will focus for the most part on the sections that relate to surfing. In addition I intend to only refer to the opinions and comments of the Inspector and not that of the information submitted by each party.
In respect to the significance of surfing to northwest Clare the Inspector stated:
“While different in its profile to ‘traditional’ tourism streams, long term economic potential for the area should not be overlooked. As asserted by the WCSC/ISA, it has a year-round aspect, and is perhaps less seasonal than the ‘traditional’ streams served by the ferry operators.”
“These waves, and Crab Island in particular, clearly occupy a special spot within this network.”
To be fair, like the Inspector, the Board members agreed that the waves in the area are significant and that surfing itself is an important sport and activity.
I believe that a very important aspect of this case is the potential surfing has in Ireland as an activity, sport and tourism attraction. The Inspector acknowledges this, but it seems to be lost on the Board members.
“It is my understanding that travel patterns and destinations chosen by people when relatively young are recognised as having a life-long impact, and that many regional tourism industries worldwide seek to capitalise on this principle, attracting people at the young/low spend phase with the expectation that this will result in repeat visits at the older/high spend phase. It is my opinion, on the basis of the information presented, that surfing has a long-term sustainable role plan in the tourism spectrum for north and west Clare, as recognised by Fáilte Ireland.”
I am perplexed that the Environmental Impact Statement (EIS) was considered to be acceptable. It has many flaws and this is highlighted in the recommendation of the Inspector to request further information.
With regard to the EIS the Inspector states:
“It is my opinion that the quality and significance of these surfing waves, and in particular Crab Island, is not reflected in the EIS. It does not go much further than referring to the fact that these breaks are only surfed by experienced surfers.”
The Inspector continues in different variances to acknowledge the significance of the waves, the difference between the waves at Crab Island and say Lahinch beach and the negativity the development would ensue should Crab Island be destroyed. The following analogy put forward by the Inspector is fitting:
“There is a contention presented by the applicant that the waves at Doolin are for the few, and for the ‘elite’ of the sport. In absolute terms, and considering surfing in the region as a whole, this does indeed seem to be the case. However, this does not tell the full story. Analogies could perhaps be drawn between Crab Island and high profile venues for other sports, such as a stadium or arena. While there may be other venues in the region for that sport, the profile and platform that a world-class ‘stage’ offers the sport in that area is always recognised.
While it may only be the sport’s top practitioners that get to compete at such a venue, there is a strong relationship in sport between the aspirational standards practiced at the top level and the extent of participation at grass roots. reasonably be said that those surfing at Crab Island are the ‘poster boys’ of the sport, there is a strong proportionate link between the profile that they generate for the sport and locality, and the high participation levels seen at the more ‘entry level’ beaches in the vicinity, such as Lahinch.”
I think that every County Counil in Ireland that holds surfing breaks within its municapility should take note of the following comment of the Inspector:
“In my opinion, the current and future significance of surfing to North and West Clare, culturally, socially, and economically, warrants support and protection from the relevant authorities, and that the waves at Doolin have a particular role to play in this regard. If the waves at Doolin are to be diminished in quality in order to facilitate an improved replacement pier, the benefits and disbenefits to the respective sectors should receive appropriate weighting.“
There are many supporting and to a lesser extent unsuportative points made by the Inspector in respect of protecting the waves throughout the report. It provides some interesting reading and I appreciate the length the Inspector went to get to grips with surfing and all that is involved with it.
One important point I must make before moving to the business end of the Inspector’s report relates to Condition 6 of the Board’s decision, quoted earlier, which relates to the design of the development. The Inspector states:
“If conditions and materials were specified in the conditions, and on the basis of the uncertainty surrounding this issue, there would be no guarantee that the pier would perform with a reflective index of 0.4 or less. My preference would be for conditions to specify the specific design of the proposal, where that design had been shown to achieve the desired performance. However, this has not been shown. The next best option is for conditions to specify a performance of 0.4, although I would have some concerns as to whether such a condition would be enforceable in practical terms.”
It appears that the token of including a condition to address surfers concerns may only be that and may not come to fruition when construction begins.
Photos Copyright: Paudie Scanlon.
Without writing a thesis I will move to the conclusions of the Inspector which are summarised as follows:
1. “The onus is on the County Council in the first instance to satisfy the board that there would be no undue adverse environmental impacts from the proposed development. Questions have been raised by the WCSC/ISA and others regarding the County Council’s modelling process. In light of such questions, the effect on the surf waves is not fully known, and the consequent impact on surfing remains unquantified.
2. The lack of legible and accessible information on the bathymetry in the area is an impediment to assessment of the issues involved. The modelling tools used are appropriate, although the scenarios modelled include significant gaps, particularly the modelling of just one swell height and one swell direction. There is information to suggest that varying these parameters, particularly swell direction, might produce affects at the surf breaks that would be less benign than those shown in the modelling presented. These unanswered questions should be addressed by way of further information. In my opinion, the applicant should be asked to submit a full set of plots covering all combinations of the following scenarios – Offshore swell height: 0.5m, 1m, 2m Swell direction :2200, 2450, 2700 Tide levels: MLWN, MTL Periods: 12s, 16s 10.6.4
3. The combinations of the above would result in 36 scenarios, as opposed to 22 in the EIS. Multiple scenarios for swell height and swell direction would be introduced, whereas a reduced and representative set of scenarios for tide level and period would be required. The selection above represents something of a compromise between the scenarios modelled by the applicant and the scenarios requested by the WCSC/ISA (see section 12.11.4 below). I recommend that the same set of output parameters be required for each scenario, but without the plots of wave driven currents, which have been shown to not be problematic. As such, the required output parameters would be: Hs before, Hs after, Hs difference plots, SE before, SE after, SE difference plots. A total requirement for 216 plots would result from the above.
4. I also have concerns regarding the level of focus on Hs plots as the determinant of significant impacts on surf waves. In my opinion SE difference plots are more likely to provide a realistic understanding of the impact on surf waves.
5. I have concerns as to whether the revetment and materials proposed could deliver the reflection coefficient of 0.4. If approval is to be granted, a condition of that approval should require the achievement of this figure by way of detailed design.
6. I consider the subject proposal to be a necessary piece of regional infrastructure that would deliver significant benefits to the local tourism industry. However, by the same token, while it would assist in the safe and convenient transport of tourists, it also has the potential to impact negatively on the tourism ‘product’ on 3 separate fronts, as follows. • Potential negative impact on the quality of surfing waves at Doolin • Negative impact on the limestone pavement at Doolin • Potential negative impact on the bird colony at the Cliffs of Moher.
7. As such, I would urge caution, given the potential of the proposed development to impact negatively on the very industry it is intended to support. In my opinion, there is every likelihood that these matters could be successfully addressed by way of further information and/or condition.”
The above is a lengthy and somewhat detailed article however, to write anything less would not clearly illustrate the travesty of a decision that has occurred. Following the above conclusions the Inspector recommended that Further Information be requested before making a decision. This recommendation was ignored by the Board members. To view the said Further Information that the Inspector deemed to be paramount, please click on this file.
It is clear from the linked document that the concerns are not limited to surfing but extend to the environment of the area and its protected sites which have European Designations.
In my opinion the Board made a pre-mature and uninformed decision which will have drastic consequences for the environment and surfing. As stated by the surfers and indeed the Inspector a pier can be built at this location however the correct design needs to be proposed to ensure the impacts to the environment and waves are reduced to a minimum. It is not at all clear that the Board have granted a development that meets such a design.