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)