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Celt Submission re Development plan of Portumna Forest Park

CELT Submission :

It has come to our attention that Coillte and Failte Ireland have created a joint proposal for a

major infrastructure development at the important wildlife area of Portumna Forest Park, in

the Portumna Forest Park presented as a 5-10 year Sustainable strategy and Masterplan.

The proposal was put before the public on 24th October and the deadline for consultation

submissions is now set at 22nd November - an unreasonably short time period for fair and

broad public consultation.  We call for a new deadline extended to at least the end of

January 2024 to allow people to properly assess the value of the Park in terms of

biodiversity and eco-tourism.  In his Foreword to the Draft 4 th National Biodiversity Plan,

Minister Malcolm Noonan says “The new way of doing things must involve active listening

and hearing all points of view.”  It is our opinion that fair, open and extensive public

consultation must take place and to limit it to less than one month for a project of this

proposed scale is clearly inadequate.

CELT wish to state that we object in the strongest terms to the vision outlined, as we believe

that the proposal would be inappropriate, detrimental to the biodiversity and ecological

integrity of the forest park and much too large to be accommodated by the site. 

Some of the developments proposed include.

-        accommodation in the centre of the forest park to include from 40 to 80 log cabins

-        a visitor centre/ cafe/ retail complex

-        a shuttle bus running throughout the park and connecting to the town

-        a suspended walkway over the waters edge

-        pontoons for water activities

-        wild camping in the nature sensitive 'Turlough' area

-        extensive adventure areas to include zip-lining and others activities

Of greatest concern is that there appears to be little evidence of care or thought given to the

ecological integrity and wellbeing of the Forest Park, the multitude of wildlife, flora and fauna

that live there, nor for the thriving natural ecosystems which makes this park the unique and

beautiful nature setting that it is, and which offers the local community and visitors alike a

unique nature space for ecological education, recreation and health and wellbeing. 

Without an adequate and independent environmental impact assessment, and at a time of

national and international biodiversity and climate crisis and what has been highlighted as

the serious threat of ecological collapse and sixth mass extinction it would appear this

proposal is not taking seriously the threat to all life forms at this time.

Given the existing plan proposed, extensive impacts on Natura 2000 sites would inevitably

be expected as a result of the project, including negative impacts during the construction and

operation phases of developments. Impacts associated with Habitat loss, Habitat damage,

Species Loss, disturbance and pollution would all be expected as a result of the

developments outlined. Extensive areas outside of those designated would also be expected

to be damaged and disturbed as a knock-on effect. Some of these areas are also considered

to be of high value and support a wide variety of habitats and species.

The Plan will have a negative impact on the Natura 2000 areas within and adjacent to

the Forest Park, according to Ecologist Jen Fischer, who has highlighted that the

proposed master plan for Portumna Forest Park is situated within and immediately adjacent

to the two Natura 2000 sites namely Lough Derg North East Shore SAC (Site Code

002241) and Lough Derg (Shannon) SPA (site code 004058), indicating that any works

that occur within or immediately adjacent to the Natura sites should be subject to a full article

6, Appropriate Assessment.

The following habitats have been listed as qualifying interests for the Lough Derg North East

Shore SAC.  

·        [5130] Juniper Scrub

·        [7210] Cladium Fens*

·        [7230] Alkaline Fens

·        [8240] Limestone Pavement*

·        [91E0] Alluvial Forests*

·        [91J0] Yew Woodlands

With regard to the tourism potential, the proposed development by Coillte / Failte Ireland at

Portumna Forest Park, we believe is a missed opportunity. This proposed development

would be detrimental to the Park, quite possibly as has been seen in the failed development

with similar plans at Killykeen Forest Park, Co.Cavan.  Such lakeshore park sites are of high

ecological value and it is our contention that they are inappropriate for extensive

infrastructure developments and should be developed as eco-tourism awareness-raising and

educational facilities in similar manner to Connemara National Park.  

Numbers of eco-conscious visitors are increasing all the time. They want a close-to-nature,

educational, caring-for-nature experience. This could include many activities such as bird

watching, wildlife studies, taking part in biodiversity monitoring, traditional crafts, nature-

inspired art work, guided walks with ecologists / specialists and hands-on volunteer work

with nature conservation projects, none of which needs the scale of development proposed

to occur. 

Environmental NGOs could be involved to help create such experiences.  As visitor numbers

increase with such developments, we believe sites outside the park could be developed for

accommodation, and the local community fully engaged in the development of these.

With reference to the excellent community led development and supports offered to the

Mountbellew community, as shown in their new development and tourism plan, The Peoples

Transition, we believe that Failte Ireland and Coillte should extend their research, and

engage in regenerative tourism appropriate methods and approaches, in transitioning our

communities and tourism developments, to meet the needs as laid out in the Climate Action

Low Carbon Development, amendment Act, 2012 and reassess its focus, to support actions

that will meet the emissions reduction targets, set out in this ambitious plan, and which are

currently identified as way off track due to the ongoing ‘business as usual’ approach to

tourism and development, such as is outlined in this plan.   

For example if a new walking / cycling path connecting the park directly to the town would

be necessary, we believe this should be undertaken with the least impact and disturbance

on the existing ecosystems.  The proposed shuttle bus service through the Park could

surely use the existing road to the existing car park without creating a new route that would

inevitably cause huge disturbance to wildlife.  

New footpaths and boardwalks ought to be limited to minimise encroachment on

lakeshore habitats.  The rich wildlife biodiversity of Lough Derg (as already featured on the

existing information board by eminent ecologist and author Gordon D’Arcy) which can be

experienced at Portumna Forest Park is one of Ireland's major natural assets and it would

clearly be advantageous to make the Forest Park a showpiece for sensitive eco-

tourism.  In recent years, the area has also become important as habitat for the Sea Eagles

which nest on islands in the lake.  They add considerably to the eco-tourism attraction and

any development should take into account how they could be affected.

Ireland's commitment to achieve adherence to the UN Sustainable Development Goals by

2030 means that we need to carefully assess any developments that would affect our

progress. The Climate Action Low Carbon Development Act, the National Biodiversity

Plan and the recommendations of the Citizens' Assembly on Biodiversity Loss all call

development to be biodiversity positive, with the Citizens Assembly identifying the need to

urgently recognise the rights of nature itself to exist, flourish and regenerate, calling for the

need for greater care in any new developments affecting biodiversity. 

Healthy biodiversity is essential for a healthy planet and provides healthy air, water and soil.

Loss of  biodiversity threatens the health of people, animals, plants and soil. Healthy

ecosystems are rich in  symbiotic relationships and loss of any element creates a threat to

other elements. Ultimately  human life is dependent upon healthy ecosystems and their

interactions which create a healthy  planet. The air that we breath, the water we drink and

use in our homes and business, all of the  food on our plates are products of biodiversity. We

are also drawn to nature for recreation and amenity and for inspiration.

With regard to climate, restoring and conserving nature, including natural ecosystems,

would take a lot of carbon out of the atmosphere and store it for a long time, sometimes

indefinitely. 

We have a clear moral obligation to protect the other living things that we share this

planet with and  we also have a rational imperative to halt biodiversity loss as it threatens

our economic well-being,  and global security. The continued loss of biodiversity is a

threat to the UN Sustainable  Development Goals, including poverty alleviation and food,

water and energy security. The World  Economic Forum (WEF) produces the annual

Global Risks report. For a number of  years, the health of the planet has dominated

concerns for the global economy, with environmental  risks identified as the five most

critical long-term threats to the world as well as the most potentially damaging to people

and planet. The five leading critical threats to the world are identified as:  Climate action

failure, Extreme weather, Biodiversity loss, Natural resource crisis and Human 

environmental damage.  

Environmental impact assessments and also now carbon emission impacts are clearly

essential if costly mistakes are to be avoided.  It is surely better to have a carefully produced

plan that takes impacts and risks into account and is widely endorsed by the public and it is

essentially in Ireland's interest to care for and make best use of our unique natural

environment.

We support the challenge to this plan raised by the local Port Omna Beo Biodiversity group

and other community groups on the grounds that:

1) A full and independent environmental impact assessment should be done.

2) The shear size of the proposed development is far too great in relation to the size of the

park.

3) The proposed development would severely impact sensitive wildlife areas including the

lakeshore breeding grounds of birds and the turlough.

4) The proposed development would significantly and permanently alter the whole raison

être of the forest park from being a place to connect with and learn about nature and the

special wildlife biodiversity habitats there, to being a tourism leisure and recreation centre

with limited small and disturbed natural areas.

In light of the Biodiversity Loss & Climate crisis and the need to protect and conserve nature

in line with Ireland’s national and international commitments, we call upon you to review the

proposal and to work with the local community in transitioning to a more ecological and

sustainable vision for the park, in line with the needs of all of the life-forms living there and in

the near vicinity.

The Citizens' Assembly on Biodiversity Loss voted overwhelmingly to recommend that there

should be a referendum to amend the Constitution with a view to protecting biodiversity, and

concluded that the State has comprehensively failed to adequately fund, implement and

enforce existing national legislation, national policies, EU biodiversity-related laws and

directives related to biodiversity. It said this must change and it is inevitable that change will

happen.

According to a RTE Report in November 2022 on the Citizens Assembly recommendations,

it stated that the 99 members of the assembly voted for the ambition of the State to be

significantly increased to reflect the scale of Ireland's biodiversity crisis and that adequate

funding and resources must be made available to address this crisis, and that Coillte could

refocus their attention and resources to support this and reflect the urgency of addressing

Ireland’s Biodiversity crisis on land under their stewardship.

83% of the members of the assembly voted in favour of a constitutional referendum to install

the protection of biodiversity and nature into the Irish Constitution. The vast majority of the

assembly members voted very specifically that the proposal to amend the Constitution to

protect biodiversity should include substantive and procedural environmental rights for both

people and for nature. For people, such an amendment, if passed in a referendum, would for

example, confer a constitutional right to a clean, healthy, safe environment; a right to a

stable and healthy climate; rights of future generations to these or other environmental

rights.

The recommendations of the Citizens Assembly on Biodiversity report also included

recommendations that are particularly relevant to Portumna Forest Park , such as listed

below..

 State owned woodlands should be recognised and managed as a strategic long-term

national asset for the benefit of the common good. (the ‘5-10year Sustainable

Strategy and Master Plan’ is not in line with the enlightened thinking of The Citizens

Assembly)

 The assembly believes that Ireland’s woodlands and forestry require a change of

management approach for the benefit of its people now and the generations to come.

 There is a conflict of interest between business aims and corporate responsibility,

particularly for state agencies. The state must fundamentally reassess the

constitution, goals and operations of Coillte and the 1988 Forestry Act reassessment

to ensure biodiversity and positive ecosystem services are core objectives for

Coillte...

 Protected sites do not exist in isolation (See Plan)

 The assembly believes that the needs of Ireland’s economy must be balanced with

the need to conserve and restore our national resources and biodiversity. 

 It is time we start valuing our natural heritage as much as our Cultural Heritage...... 

Given the recommendations from the Citizens Assembly listed above, we request that

Coillte, Fáillte Ireland, Galway County Council and other stake holders reconsider their plans

in line with the Citizen Assembly recommendations, and with the people of Portumna’s

considerations and Portumna Beo’s Biodiversity Group’s considerations and concerns, who

have asked that we ‘cherish our forests as part of our living history’ 

We support Portumna Beo’s Biodiversity Group concerns and who have identified that ‘there

is a need for a plan for the Portumna area, but a plan with a wider vision, with longer term

aims and with community involvement.  Given Portumna’s unique location in the Shannon

Basin, with Callows and associated habitats, with Lough Derg and its aquatic life and

shoreline, with the Wetlands and the Forest Park, Portumna has the potential to be declared

a National Nature Park, providing an Ecology Education Hub.’  

We request a full and independent environmental impact assessment and an extension of

public consultation until at least the end of January 2024 to allow people to meet, discuss,

formulate and put forward their own ideas and suggestions for a sustainable upgrade of the

park with due respect for the wildlife and biodiversity and with fresh vision for how our Forest

Park can be enhanced to act as a sanctuary and haven for our native biodiversity to thrive

and flourish and so that our Nature Spaces are enhanced outdoor educational classrooms

due to the the experience they offer, and for Coillte to establish a new vision that might

support the wildlife and biodiversity of the park itself to be enhanced whilst providing a better

educational resource for current and future generations..

R S Wilson

Coordinator

CELT (Centre for Environmental Living & Training)

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