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Landscape 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 approach.

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 achieved.

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 landscape issues.

Article 5 General Measures

Each party undertakes to

  1. 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 identity.
  2. Establish and implement landscape policies aimed at landscape protection, management and planning through the adoption of the specific measures set out in article 6.
  3. 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.
  4. 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 engage in

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:

  1. Training for specialists in landscape appraisals and operations;
  2. Multidisciplinary training programmes in landscape policy, protection, management and planning, for professionals in the private and public sectors and for associations concerned;
  3. 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:


  1. to identify its own landscapes throughout its territory;
  2. to analyse their characteristics and the forces and pressures transforming them;
  3. 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 8.

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.

E.      Implementation

To put landscape policies into effect, each Party undertakes to introduce instruments aimed at protecting, managing and/or planning the landscape.

Opening Statement

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 good.

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 demands.

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:

  1. 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.
  2. 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.

  3. 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 environment.
  4. 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.

  5. 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.

  7. 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)
  8. 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.

  9. 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).
  10. This approach is also emphasised in item 3.2.3 on location and design.

    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.

  11. 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.
  12. 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.

  13. 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.
  14. 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.

  15. 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 .
  16. 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 feasible.

    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.

  17. We welcome the emphasis on addressing the issue of holiday home development in a positive and sustainable manner (page 20).
  18. 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 necessary.

  19. 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 areas.
  20. 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.

  21. 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 dispersed housing.

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 sites.


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 landscape.

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 subset.

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 requiring attention.

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