COUNTY DONEGAL DEVELOPMENT PLAN

SUBMISSION FROM SAVE INISHOWEN – INDEPENDENT ACTION GROUP

1) Introduction: Inishowen at a Crossroads

Inishowen is a unique place at a cross roads in it’s history. It’s uniqueness includes its
location as a peninsula, in the northern most part of Ireland and yet close enough to the border with Northern Ireland to be influenced by the recent changes there. The landscape of Inishowen is probably the most striking and valuable feature. Bord Failte report that studies of why tourists visit Ireland show their top reason is the landscape. In Inishowen we have a rare diversity of scenery: countryside, hills, beaches, and cliffs, all in relatively close proximity to each other. The predominant characteristic of our landscape is it’s rural nature, the quiet, relaxed atmosphere and the traditional ways of life. Inishowen has long standing established communities, tourist spots and historical/archaeological sites. The development of Inishowen as a ‘green box’ is to be encouraged.
People who live in Inishowen have a quality of life that is the envy of many city dwellers: few traffic jams, quiet leisure activities, knowing your neighbour, community continuity, feeling safe, clean air, relatively little noise or light pollution.
In the face of the decline in farming and fishing and the loss of textile jobs especially Fruit of the Loom, there is a need for the Council and other bodies working for the ‘common good’, for ‘ar son an phobal’ to make sustainable communities their top priority, and the criteria by which all other decisions should be measured.
The development of Inishowen as a ‘green box’ is to be encouraged. As Dr Peter Doran has said recently:

“ Sustainable tourism is about preserving the unique attractions of our peninsula as a tourist destination, namely the level and depth of contact with local people in a relaxed and clean environment characterised by an unhurried pace of life and beautiful landscapes” InishTimes (August 25th 2005)

However Inishowen is at a crossroads. The people of Inishowen have a choice. The choice is between prioritising the laying of foundations for sustainable ways of life or allowing the current rate and nature of housing development to destroy the core ingredients of what makes Inishowen the place it is and the place where people want to live and tourists want to visit.
We have all seen the decline in employment opportunities (Fruit of Loom). Developers are asset stripping our resources and taking the profit away with them. New developments putting pressure on water supplies, which are already short in some areas, electricity supplies, the quality of the roads. Unfortunately certain areas are already overdeveloped, with little benefit to permanent communities. Other counties in Ireland have stricter planning rules and have restricted holiday home developments. We are risking rural depopulation with increased prices for land, sites and houses. The landscape has been transformed into urban ribbon type development with clusters of housing scattered throughout the countryside be spoiling the views and prospects at each turn of the road.
Planning regulations and enforcement are weak. There is an absence of enforcement of existing planning regulations. Many cases exist of people getting round the regulations of the old plan with no follow up and no enforcement. The new draft plan does nothing to change this situation.
We are living through a period of decline in our indigenous ways of making a living: fishing, farming and industry. And at the same time we are watching the increase in holiday home developments that threaten the core ingredients of Inishowens’ uniqueness.

Local Area Development Plan
We believe that the best option is for Inishowen to develop its own Local Area Development Plan. The process for developing this should be open, inclusive and transparent, involving people on the ground. The process would allow us to assess what we have got and what can best be done to maintain living, sustainable, vibrant communities in Inishowen.
A LADP would allow Inishowen to consider the impact of the National Spatial Strategy’s projected ‘corridor’ development between Letterkenny and Derry. Such a large-scale development of industry, business and urban housing will have huge implications for Inishowen. This puts Inishowen in a unique position, facing the choice of staying a ‘green space’ or becoming a dormitory, with all its disadvantages.

2) General Comments on Draft Development Plan

In reading the draft plan, in both full form and in its summary form several points are clear.
1) It is a weak plan. For example, the language is vague when it should be clear and precise. It is a legal document and must stand up to legal scrutiny. It should therefore be written in language that is clear and precise.
2) There are contradictions between sections. There is a need for more joined up planning to be reflected in the plan.
3) The plan does away with categories one, two and three that offered some protection to areas where, though there was some building, the green fields around it could be protected by Category Three status. In the new plan it is only used to protect obvious areas of hills and mountaintops.
4) Category Three is replaced with EHSA’a. These do not give the same protection.
5) The plan appears to be building-development driven
6) Real enforcement of planning permission conditions is non-existent. Three officers to cover the whole of Donegal is inadequate.
7) The plan appears not to be based on principles of good practice in planning. Research into the projected need for permanent housing, social housing, and holiday homes should have been carried out. This research would then form the basis for deciding how much housing is needed and once that amount had been build then there would be a moratorium on further building. Dilution of national and European guidelines can only lead to further chaos and asset striping
7) The review places few restrictions or rigorous regulation required to meet the specific needs of Inishowen

3) Proposals on Section Two of the Summary Document

We believe the key prioritises for the plan should be:
1) To maintain living, permanent, sustainable, vibrant communities
2) To permanently protect and conserve the countryside, coastal, beach, hill character of Inishowen
3) To protect the quiet, non-commercialised, rural nature of the area and the communities living here
4) To prioritise the development of locally owned business and tourist initiatives that are based on protecting the countryside and the rural character of the area. These initiatives should be long term, of high value and sustainable.

Strengthening Decision Making
It is obvious reading the 2000 Plan next to the 2005 Draft Plan that the development lobby has succeeded in loosening the criteria for where you can build. The 2000 Plan has given us the situation we have at the moment – overbuilding and lack of enforcement of regulations. We suggest a new way of managing the agendas of certain lobby groups.
In national and local government there is an accepted practice called Proofing. It is used on decisions, policies and practices to ensure that there are not unseen detrimental effects on certain groups. The most well known uses are in Gender Proofing and Poverty Proofing.
We recommend that the County Plan should establish criteria against which all decisions, policies and practices are measured. These criteria should be developed in consultation with all the key stakeholders, including local communities.
We propose that the criteria, for the best future for Donegal, should be based on the following:
- To maintain a living, permanent, sustainable, vibrant community
- To permanently protect and conserve the countryside, coastal, beach, hill character of Inishowen
- To protect the quiet, non-commercialised, rural nature of the area and the communities living here

Section 2.2 Employment Generation and Enterprise Development
Eco-tourism is one way of attracting a high return on tourist activity. To support the development of this innovative and unique tourism, initiatives should be set up to assist local farmers and residents.
Proposal: That an Organic Centre, along the lines of the Leitrim Centre should be set up in Inishowen.
Proposal: Farmers who are interested should be supported, through training and finance to offer part of their land as allotments for town residents to use for the production of organic food. A feasibility study should be set up to explore the viability – there are existing schemes in Northern Ireland
Proposal: Farmers markets should be established in all key urban areas, for the sale of products produced by local residents. As well as fruit and vegetables, cakes and breads, these could include local arts and crafts which would also benefit from support and protection.
Proposal: To support the growth of eco-tourism and the above diversification initiatives, funding and training should be provided. In some cases premises and sites will need to be identified and provided. Finally the Council and other appropriate bodies will need to review and update their policies to support these local initiatives.

A Local Area Development Plan for Inishowen will allow for the integrated, joined up planning that will best support these new developments.

Section 2.3 Housing Urban
There is a dearth of up to date play areas for children and of green spaces for adults and children’s leisure activities.
Proposal: All housing developments should be required to build a play area for children along the lines of established good practice and leave an undeveloped green area for children and adult leisure activities.

Escape clauses, like the 10,000-euro bond, undermine the professional judgement of planning officers, the regulations, the values and strategic aims of the Development Plan. They call into question the trustworthiness of both officers and politicians. Loopholes in regulations shatter faith in the system, however imperfect, and confirm a ‘them and us’ mentality in the public’s mind. Individualism is upped a notch and the common good is diminished.

The 10,000-euro bond allows developers to make the case for one more house in any area. In many areas, both urban and rural, there is already a high percentage of rented property, thus exceeding the 20% quota mentioned in the plan. In many areas houses have been built for family members. For different, valid reasons these houses are being rented out on a short term or holiday basis. This creates an imbalance in communities often leading to there being as many non-permanent houses as permanent ones. This eats into a sense of community, a sense of safety and demoralises people already living in the community.
Proposal: Planners should assess what is happening on the ground in any area, in terms of the balance between permanent homes and non-permanent homes before considering new planning applications.
A Local Area Development Plan for Inishowen would allow for this level of assessment.

Section 47 is only a genuine brake on development, and so a protection for communities, if it is a permanent restriction on further building. Seven years, as has been proposed by the Minister, is not strong enough.
Proposal: Section 47’s should be permanent.

There is a very low commitment to the enforcement of planning regulations.
Proposal: the Council must secure extra finance to employ an adequate number of monitoring/enforcement officers. These officers must have the authority to enforce regulations.

The plan is full of vague language that provides loopholes for excessive holiday home development.
Proposal: Keep and strengthen the existing three categories

There are two issues related to landscaping in new houses and developments. One is that in the building of the house(s) there should be a high priority put to the protection of trees, flora, fauna, habitats and existing walls and structures. Many houses destroy the land around the house as they build.
Proposal: Every effort should be made in the planning application criteria to protect the existing environment. Any damage to it would have penalties attached.

Many houses should be required to landscape the land, plants, walls etc around them in such a way that they do not stick out like sore thumbs. For example, walls at the front of houses should not be too big or high or adorned with statues and in rural area should be Regulations requiring the planting of trees, shrubs etc should be enforceable.
Proposal: Existing regulations regarding the siting, materials used, landscaping of new houses should be strengthened and enforced. Protection of the existing environment around the building of a house should be enforced.

Holiday Home Development
Holiday homes are pushing prices up, using up green spaces, creating rural depopulation and ghost estates. Some developments are ruining existing tourist sites. For example, in Greencastle there is a Norman Fort and a Napoleonic Fort side by side. This is a unique site and could have been the opportunity for a tourist initiative highlighting the history of the two forts, their histories and their differences due to the development of warfare and building. However, in the 700th anniversary year of the building of the castle a holiday development has been given the go–ahead to build on the small field that separated the two forts. This development is at the high end of the market with apartments selling for 600,000 euro each. There will be minimum revenue to local businesses. And the possibility of the site being of advantage to the community is lost forever.
This is a frightening example of planning criteria being weighted towards the developer and away from the community. It shows exactly how development is eating away at the core ingredients of tourism and scenic areas. It is as if a farmer stood by and did nothing to stop his cattle getting foot and mouth disease. He would have lost his herd and so his livelihood. In scenarios such as Foot and Mouth, national action is taken to prevent such destructive actions from their negative impact on the common good.

Proposals: (all of which should be subject to existing regulations) Prioritise the rebuilding of existing cottages/structures.

There are problems with allowing up to five holiday homes. This is too many for many townlands. Once one is built most areas would not sustain further building without damage to the community and environment.

There is a need for clarification of “one major holiday home development”. What does this actually mean? What would be permissible? Who would get permission? Would it be a first past the post lottery? How would it be assessed in relation to existing developments?
Proposal: That the offer of “one major holiday home development” is withdrawn from the plan.

Section 2.4 Environmental Services and Protection Water
There is a well-documented and reported serious lack of water in several areas. For example, in the Gleneely Group Number Two and Carrowmenagh Group Water Schemes (Inishowen) local residents are frequently without water entirely or experience very low pressure. Due to bad planning and unchecked holiday home development, a very basic service, and a fundamental human right is being denied to those who live, work and contribute to the area and pay national taxes.
This situation is untenable. The new plan must provide/enable and protect the supply of water to local residents and businesses by not over building.
Proposal: As a matter of urgency an analysis of existing ground water supplies must be carried out. Planning permission should only be given when based on an analysis of adequate water supply. Permission must take into account the existing demand for water in that area, plus it’s actual availability, before being granted.

Waste
The plan has a serious lack of commitment to waste reduction. Recommendations from previous consultations do not appear in the plan.
Proposal: Recommendations from previous consultations should be included in the plan.
Proposal: Kerbside collection of recyclables should be instigated and more civic amenity sites should be provided.

There is inadequate sewerage facilities and plans in urban areas. Further housing developments will only bring these issues to crisis point.
Proposal: No new housing development should be given planning permission until an acceptable sewerage system is developed, located in appropriate areas and installed.

Litter
Maintaining a clean environment is essential. At the moment litter is a problem. This needs to be dealt with. Cavan, the winner of this year’s tidy town competition said that enforcement of existing laws is the only way to beat this problem.
Proposal: The workforce responsible for litter collection should be expanded to an adequate number for the size of Donegal.

Section 2.6 Built and Natural Environment Woodlands
Part of the character of rural Donegal is the woodlands. Many of these woods are ancient and irreplaceable. They have no form of protection.
Proposal: Traditional woodlands need formal enforceable protection and regulations. Existing traditional woodlands should be identified and entered into a database. For example, Ravenscliff, Porthaw Glen, Burt Woods and Kilderry Woods.

Green Field Areas
The places where children can safely go to engage in play and free activities are vital to their overall well-being and development, are becoming sparser as every green space seems to be ear marked and sanctioned for development. Facilitating play and recreation are essential to the healthy and sustainable development of any community.
Proposal: Designated Green Field Areas to be left free from development close to urban centres.
Proposal: A review of all existing play facilities in urban areas should be carried out. New play area should be developed where necessary.
Especially High Scenic Amenity
This terminology replaces the previous Category Three status. It is too narrow and needs to be used more to protect existing countryside. For example, in Inishowen, near Greencastle, it has been applied to the hilltops between Shrove and Glenagiveny. This is offered by the planners as evidence of protecting the countryside. However, no one could build on land that is so isolated, has no services and is not visible to the human eye. It is obviously land that should be protected. EHSA’s should be used in more areas to protect land nearer to potential development. Otherwise it is a weak and ineffectual barrier to the destruction of the countryside.
Proposal: EHSA’s must be made more watertight.
Proposal: EHSA’s should be applied and extended to more areas where development has already and might, in the future, take place.
Proposal: All classifications aimed at protecting the countryside and coastal areas must be clarified, strengthened and rigorously enforced with meaningful sanctions.

Views and Prospects
Again, the terminology is too vague. What is in the view and what is not in the view. The vagueness allows for manipulation and doesn’t provide permanent and lasting protection.
Proposal: That Views and Prospects should be replaced by a clearer and more rigorous term accompanied by clear, enforceable regulations.

Protection of Local Community Heritage
At the moment government bodies decided what is a heritage site and which areas have meaning in a locality. This does not necessarily reflect the experience of local communities built up over generations. There is a need to develop criteria, regulations and enforcement at a local level.
Proposal: In order to provide clear, enforceable protection for areas of special significance to local and wider communities and tourists – i.e. local habitats, woodlands, shore walks, archaeological/historical sites – a new category of protection needs to be established. Local communities will need training in the use of this new category and supported to gain its status as protection for local heritage.

Section 2.7 Tourism
There is a pressing need to develop sustainable, diverse tourism. This means planning for mixed tourist development and leisure: ‘horses for courses’. Keep the quiet, as yet, unspoilt beaches and countryside as they are. (Make jet skis, theme parks, etc illegal in these areas by passing by laws). If there is to be development in quiet areas make it walks or cycle rides, in line with the residents and tourists who enjoy these. Develop existing tourist ‘hot spots’: Buncrana, Moville with more traditional developments, in line with supporting locally owned tourist initiatives.
At the launch of the Green Guide Andrew Ward (IRDL) said:
“ This document reflects a ground swell of opinion from people who are
interested in the development of sustainable tourism…..the amount of
money spent by eco-tourists is so high that we have to position ourselves for
that market” He also said: “Development must not come at the expense of
Inishowen’s unspoilt beauty” InishTimes (August 25th 2005)

Proposal: There should be teams of Council/FAS scheme/CE scheme workers whose job it is to clean up existing walkways, beaches and piers throughout Inishowen Proposal: Protection is needed for the right of way for walking
Proposal: Development of a new initiative to develop and publicise an Inishowen Walking 100 and Cycling 100.
Proposal: Funding and Support for Festivals, for example the new Summer Gathering.
In the plan there is a proposal to increase the number of Blue Flag beaches. Culdaff has this status and it includes portable toilets. On a recent visit the toilets were unusable. Inishowen’s beaches come in all sizes and shapes. This is part of the attraction. Some beaches are relatively isolated and their attraction is the fact that they are untouched by any form of development, so keeping their rural, countryside feel. Not all beaches are suitable for ‘upgrading’ to Blue Flag status. So applying the Blue Flag criteria is inappropriate. Therefore a second set of criteria for ‘rural, unspoilt’ beaches should be developed, with appropriate enforcement.
Proposal: Beaches should be protected from inappropriate developments, e.g. increased car parking, portable toilets, new play areas.
Proposal: A second set of criteria should be produced and enforced for ‘rural, unspoilt’ beaches. Isolated, rural beaches should be identified and maintained as such.

This plan is submitted by SAVE INISHOWEN, an independent action group, comprised of residents from Ballycharry, Buncrana, Culdaff, Moville, Greencastle areas.
Contact: David Simpson 074 93 81224.
Address: C/o Mossy Glen, Lecamy, Carndonagh.
Email: saveinishowen@eircom.net