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Alliance Ireland Submission on Consultation Draft of the Guidelines
for Planning Authorities in Relation to Sustainable Rural Housing
Issued by the Irish Department of Environment, Heritage and Local
Government in March 2004
Landscape Alliance Ireland is partnership of individuals, NGO's,
representatives organisations and public officials committed to
quality in our shared landscape present and future and to the view
that landscape must be considered in its totality; urban, suburban
and rural rather than the present almost universal piecemeal
Our objectives include providing a platform for open, broad based
discussion on all dimensions of landscape quality, stimulating and
encouraging such discussion and debate and thus ensuring that
concerns, problems and solutions relating to landscape management
are brought to the notice those who exercise control over, or are
involved in any way with landscape change.
Landscape Alliance Ireland is committed to the formulation and
implementation of landscape policy at local, regional, national and
international level to facilitate development of a framework
approach within which effective total landscape management can be
In particular Landscape Alliance Ireland is committed to the
implementation of the European Landscape Convention which has been
signed and ratified by Ireland very early in the life of the
convention in an act of considerable vision and commitment to the
quality of the landscape of Ireland and Europe.
In this context we would wish that this progressive convention
would guide the preparation of the final rural housing guidelines
and we draw attention to the following extracts:
Article 2 Scope
Subject to the provisions contained in Article 15 this
convention applies to the entire territory of the parties and covers
natural, rural, urban and periurban areas. It includes land, inland
water and marine areas. It concerns landscapes that might be
considered outstanding as well as everyday or degraded landscapes.
Article 3 Aims
The aims of this convention are to promote landscape protection,
management and planning and to organise European co-operation on
Article 5 General Measures
Each party undertakes to
- Recognise landscapes in law as an essential component of
peoples surroundings, an expression of the diversity of their
shared cultural and natural heritage and a foundation of their
- Establish and implement landscape policies aimed at
landscape protection, management and planning through the
adoption of the specific measures set out in article 6.
- Establish procedures for the participation of the general
public, local and regional authorities and other parties with an
interest in the definition and implementation of the landscape
policies mentioned in paragraph B above.
- Integrate landscape into its regional and town planning
policies and in its cultural, environmental, agricultural,
social and economic policies, as well as in any other policies
with possible direct or indirect impact on landscape.
Under Article 6 - Specific Measures each party is required to
A. Awareness Raising
Each Party undertakes to increase awareness among the civil
society, private organisations, and public authorities of the value
of landscapes, their role and changes to them
B. Training and education.
Each party undertakes to promote:
- Training for specialists in landscape appraisals and
- Multidisciplinary training programmes in landscape policy,
protection, management and planning, for professionals in the
private and public sectors and for associations concerned;
- School and university courses which, in the relevant subject
areas, address the values attaching to landscapes and the issues
raised by their protection, management and planning.
C. Identification and assessment
1. With the active participation of the
interested parties, as stipulated in Article 5.c, and with a view of
imporiving knowledge of its landscapes, each Party undertakes:
- to identify its own landscapes throughout its territory;
- to analyse their characteristics and the forces and
pressures transforming them;
- to take note of changes;
b. to assess the landscape thus identified, taking
into account the particular values assigned to them by
the interested parties and the population concerned.
2. These identification and assessment procedures
shall be guided by the exchange of experience and methodology,
organised between the Parties at European level pusuant to Article
D. Landscape quality objectives
Each party undertakes to define landscape quality objectives
for the landscape identified and assessed, after public consultation
in accordance with Article 5.c.
To put landscape policies into effect, each Party undertakes
to introduce instruments aimed at protecting, managing and/or
planning the landscape.
We very much welcome the opening up of the debate on the whole
issue of housing in the rural landscape. For far too long this
serious issue has not received the political or public attention
that it warranted. This failure contributed further to the problems
associated with this very difficult area of planning.
We must record our concern, however at the implication in the
document that the planning process might in certain ways be
compromised by the wish that planning be granted where new houses
‘generally compatible with the conservation of sensitive areas’.
Responsible planning is a characteristic of an ordered,
advanced society, where it is recognised that individual ‘hard
cases’ must at times be subordinate to the interests of the common
The guidelines seem to place too great an emphasis on
facilitating rural housing rather than seeking to achieve a
sustainable balance between all of the various constraints and
There is a paucity of hard facts available concerning the
patterns in existing rural housing. This lack of information only
encourages conjecture and discussions more heated by ignorance that
knowledge. As government are now willing to attempt to resolve this
issue, they should commission the necessary research to ensure that
the guidelines are properly informed.
The EPA has already raised concerns about our ground water.
These concerns could become far more serious if global warming
changes our rainfall patterns in the near future. Our aquifers are
already at serious risk from the proliferation of private unpoliced
waste disposal systems. Just this week Dr. Mary Kelly of the EPA
expressed concern about the need to close the gap between policy and
practice in relation to protecting our environment –
"arguably our most valuable asset".
The draft guidelines document will prove a valuable
contribution to the debate and discussions that must now take place
at national and local level on all aspects of the issue of meeting
our rural housing needs in a sustainable manner.
The Key Points of our Submission are as follows:
- The scope and range of the draft guidelines document is to be
commended in bringing together in a relatively integrated
fashion all of the policies, strategies and plans that relate to
rural housing and endeavouring to establish a thread of
consistency through the different layers.
We would welcome a similarly integrated approach to the Irish
landscape as this would greatly assist the debate surrounding
rural housing and would be seen as a significant step in the
implementation of the European Landscape Convention.
We would have preferred if the guidelines were published as
part of an integrated approach towards meeting the nations housing
needs in our cities, towns, villages and countryside. The
appropriateness of this approach was most effectively demonstrated
at the 2003 National Landscape Forum.
Treating rural housing needs in isolation is likely to result
in an imbalanced document. These guidelines should therefore be
treated as work in progress pending the preparation of the
national overview guidelines.
- We are concerned however that the necessary balance has not
been achieved within the document between the need to provide
for rural housing and yet conserve our rural landscape in a
manner that is truly sustainable ensuring that it does not
result in an unacceptable level of deterioration in our rural
heritage, natural or man-made, be it landscape, buildings or
It proved a difficult and unsatisfactory document to evaluate
due to the fact that many of the policies, plans and strategies
referred to are already on record as making a clear commitment to
genuinely sustainable development in rural areas and yet there is
an underlying trend through the guidelines document that would
attempt to suggest that the provision of rural housing should take
precedence over all other concerns.
- There is a suggestion within the document which is most
clearly stated in the second page of the Minister’s foreword
that the provision of rural housing in itself would "ensure
a vibrant future for all rural areas". This statement is
likely to create false expectations as housing in itself will
not create a vibrant sustainable community.
- The question of cumulative impacts and the capacity of the
rural landscape to accommodate housing development is
inadequately addressed within the document, as it is only
referred to in the appendices under supplementary information on
heritage (pages 37 and 38) and in relation to holiday home
development under section 3.2.2. (page 21)
Of all the potential developments that can take place in the
rural landscape, housing is the one where the question of
cumulative impacts and capacity should be to the forefront of any
guideline document, particularly when references are made to
development plans and planning guidelines at a local level.
- We very much welcome the emphasis within the document on a
requirement for planning authorities to work with all interests
in order to create a shared view of how the issue of rural
settlement should be addressed in the particular authority
concerned through the development plan as stated in the planning
context (page 9).
This approach is also emphasised in item 3.2.3 on location and
This proactive approach is further emphasised under item 4.7
design where there is a requirement for planning authorities to
ensure that new housing development in rural areas integrate well
with their physical surroundings and we particularly welcome the
series of actions called for and would urge that these be
implemented as a matter of urgency and this can be very
effectively done within the context of the European Landscape
Convention as will be demonstrated in the Council of Europe
Workshop in Cork in June 2003.
We note with interest the suggestion of an award scheme. Whilst
this would be valuable in itself we would suggest that a portfolio
of photographs of successful models should be prepared in each
local authority and exhibited widely and if possible ‘open days’
should be arranged where those intending to seek planning
permission or housing in sensitive areas could be taken to see
successful models on the ground. This concept has been very
successfully used in the farming sector.
The concept of a photographic observatory of landscape such as
is already in existence in France would be a valuable way also of
demonstrating to the local population the cumulative impact of
individual developments over time on the quality of the landscape
noting both positive and negative trends.
These approaches are central to the proactive stance and work
of Landscape Alliance Ireland over the past ten years.
- We would have to record our concern at the tendency within the
draft guidelines to focus excessive attention on the concept of
scenic landscape rather than landscape quality.
It has long been recognised that the weakness in the original
Foras Forbartha landscape studies related to the emphasis on
sublime landscapes. The guideline documents uses outdated
selective terminology such as ‘beauty spots’ (page 8), ‘scenic
landscapes’ (page 11), ‘sensitive scenic areas’ (page 21),
‘important landscape character’ (page 23), ‘important
landscapes’ (page 32) and ‘important landscapes’ as a
heading (page 37), such terms may be misleading, particularly
where under the European Landscape Convention Ireland is committed
to quality in our total landscape..
The European Landscape Convention was born out of a recognition
that an excessive focus on particularly visually attractive
landscapes had contributed throughout Europe to a progressive
deterioration in the quality of the so called ordinary landscapes
and it is vitally important as a ratifying nation to the
convention that we actively support this broader more holistic
understanding of landscape quality and its role in ensuring an
acceptable quality of life for the total population.
We accept that the ingredients of the approach that we are
requesting are contained within the document, but it is vitally
important that the right signal is sent at this time.
- The issue of objectives is very relevant as referred to on
page 14. In line with the European Landscape Convention we would
strongly urge that landscape quality objectives be also
prepared and incorporated in the development plan.
We believe that such objectives would greatly assist in
ensuring the protection of existing landscape quality and more
importantly the potential for enhancing landscape quality, whilst
at the same time facilitating development within the landscape.
- Landscape Alliance Ireland are supportive of the concept of
facilitating persons with strong roots or links in rural areas
with regard to their housing requirements in the area, subject
to best practice rules of good planning, as reiterated again and
again in the guidelines .
We would however have to stress a number of aspects of such a
strategy in relation to transport which must be faced up to.
In the first instance as is generally recognised, it is
difficult if not impossible to provide a public transport system
for a dispersed rural population. Therefore where a significant
proportion of the population lives in dispersed locations
throughout the landscape there is an inevitable intensification of
transport problems as all of the individual transport units
converge on the relevant employment, shopping and education
centres. Thus there is a potential for significant additional
public costs involved in providing an adequate transport
infrastructure extending in a spiders web fashion throughout the
nation to accommodate such traffic.
There is the additional and often ignored issue of the time
absorbed in commuting which is becoming increasingly significant
throughout the country. This ‘lost time’ not alone reduces the
quality family time available to the individuals but also quite
dramatically reduces the contribution the individuals make to
their community as they are not available to participate in
various voluntary and social organisations.
It should also be noted that they are not available to engage
in passive policing of their community and this may well result in
serious law and order issues in the future as the desirable
balance between the different age groups in communities is not
There is an urgent need for a true cost assessment of such
implications attaching to dispersed rural housing.
We accept that it is possible that there may be significant
community savings in other directions which offset potential costs
but we do not have the necessary research data available.
- We welcome the emphasis on addressing the issue of holiday
home development in a positive and sustainable manner (page 20).
We are not assured however that the liberalisation of the
planning process to facilitate rural housing under the guidelines
will not contribute to the reverse of this policy.
We would therefore recommend that it be a requirement of the
planning process that where a home changes from being in permanent
residence to becoming a holiday home that planning permission be
required for change of use. This at least would provide statistics
and would allow the planning authorities to intervene where
- We consider it interesting that the document appears to make
no reference what so ever to the tourism industry with the
exception of the sections discussing holiday homes. It is even
more curious that the tourism sector is not recorded as an
occupation of those working full-time or part-time in rural
Tourism is likely to virtually replace agriculture as the main
source of employment in the rural landscape, certainly in the
West, North and South.
Whilst Landscape Alliance Ireland would always have argued that
an excessive focus on the tourism dimension of landscape was
unhealthy, there is the need to recognise that our landscape is a
significant part of our tourism product.
However we would argue that our first priority should always be
to ensure the highest quality landscape for the people of Ireland
and if we succeed in that we will not alone ensure a healthy
tourism industry but more importantly ensure that the tourism
industry is less susceptible to peaks and valleys.
Tourists can be greatly influenced by the image that we portray
through our promotional literature and in many respects we
persisted in promoting a unreal fairytale image of the Irish
landscape for far too long.
That said, Ireland is fortunate in having a very high quality
diverse landscape throughout the island and housing can be
accommodated within that landscape successfully and a vibrant
population can be sustained which will add to the experience of
tourists in enjoying that landscape, provided our approach is
sufficiently sensitive, sophisticated and informed.
- The role of the cost of building land in driving the demand
for once-off rural housing should be explored in greater detail
in the guidelines.
As it has long been accepted that it would be preferable if
rural housing needs could be met within the framework of existing
towns, villages and hamlets, the guidelines should explore more
fully all possible options for promoting same as an alternative to
Local Authorities should be facilitated in intervening in the
housing site market in a similar fashion to the activities of the
IDA. They could be provided with a roll-over fund (a commercial
loan from the National Pension Fund) to purchase and service land
adjoining existing settlements. They could sell the sites to those
seeking ‘rural’ sites at a modest profit in line with the
returns being earned by the Pension Fund and reinvest in further
There is a very serious multi-faceted issue at the heart of the
issue of rural housing that requires focused attention. There is
no quick-fix simple solution. There is a requirement for an
investment of energy and resources to achieve an equitable,
sustainable and caring solution.
The aspirations for genuine sustainability implied by the
guidelines must be realised, but not just in terms of meeting
rural housing needs, but also in terms of ensuring a living and
lived-in landscape of dynamic heritage, natural and human
diversity and environmental quality, that is of course, if we are
to be more successful in this millennium that we were in the
preceding 30 or so years with regard to interventions in our rural
The evolution of our rural landscape in the coming years will
be greatly influenced by CAP Reform, the price of fuel, the
centralisation of services illustrated by the thinking behind the
Hanly Report on our Health Services and the progressive withdrawal
of outreach services by commercial/state services such as banks
and post offices etc. These forces for change must be factored
into a responsible review of the contents of these guidelines.
The issue of addressing housing needs requires an integrated
national guidelines document of which rural guidelines should be a
We appreciate that we are dealing with a draft of what was a
difficult document to prepare and recognise that the document
would benefit from some consistent editing. There is much to
commend in the document but there are imbalances and omissions
It requires an executive summary where some of the points in
the foreword might be more effectively accommodated in a manner
that would do justice to the overall scope of the guidelines and
its repeated commitment to sustainability and the value and role
of the planning process.
The people of Ireland and our environment/landscape/heritage
are our ultimate renewable resources. They deserve balanced
protection, nurturing and respect.
Submission collated and finalised by Terry O’Regan, Founder/Coordinator
of Landscape Alliance Ireland, Old Abbey Gardens, Waterfall, near Cork
City. t. 021 4871460, f. 021 4872503, e.mail mailto:email@example.com