IPI Submission on the National Landscape Strategy Issues Paper
Thursday, December 22, 2011
Mr Paul McMahon
Built Heritage and Architectural Policy Section
Department of Arts, Heritage and the Gaeltacht
Date: 17th November 2011
Re: Strategy Issues Paper
Dear Mr McMahon,
The Irish Planning Institute acknowledges the provisions of the European Landscape Convention and the requirements for the preparation of a landscape strategy. However, there are many challenges that such a strategy will present. It is these challenges that this submission will focus on.
A more comprehensive submission dealing with the micro issues can be submitted by the Institute at a later stage. The Institute consider the following headings to be of most importance: -
1. Need for a national Landscape Strategy
It is imperative that the need for a national landscape strategy is established and presented clearly so that the public in general understand why it is being prepared. Reference to the ratification of Europe’s European Landscape Convention (2000) is inadequate. Failure to present a concise and clear explanation to the general public as to the importance for such a strategy will result in a lack of public participation in the process at large, resulting in a strategy that will ultimately be meaningless.
2. Context of the landscape strategy
The Institute is strongly of the view that the Landscape Strategy should not be prepared in isolation but rather should be part of a suite of strategic plans that are supported by the National Spatial Strategy setting out a clear vision for development in Ireland for the short, medium and long term. The Institute, therefore re-iterate the need to review and update the National Spatial Strategy so as to ensure that it is reflective of the current economic situation we now find ourselves in which has forced us to re-examine previous policies and assess their current relevance. The national spatial strategy needs to set out a robust planning framework in conjunction with the National Development Plan that will inform and provide clear direction at national level for future development. It is these plans that will inform other strategies such as the landscape strategy and provide clear guidance on driving forces that will affect the landscape into the future. In this regard, the landscape strategy should clearly identify the driving forces for change that affect and may affect our landscape. It is these driving forces that will ultimately inform planning policies for the future and shape our landscape going forward.
The issues paper makes reference to ‘public policy’. However, no explanation is given as to what this is and more importantly what the aims of public policies are. The importance of consistency in policy formulation between all government departments is crucial so that the need for a national strategy setting out clear policies that will shape the future in this country may be emphasised.
3. Consultation process
The consultation process for a national landscape strategy like any other policy document should ensure that a proper and meaningful participatory process is pursued. Essentially everyone views the landscape in a different way, which is often dependent on where someone lives and how one uses the resources within the landscape. The landscape strategy will therefore impact on various sectors such as tourism, industry, agriculture, food, et al. Differing landscape views give rise to different considerations thereby requiring the national strategy to be both cognisant and accommodating in this regard.
The Institute strongly suggest that the steering committee should be extended to include representatives from all professional bodies that would be directly or indirectly involved in the preparation and implementation of such strategies. It would, therefore, be of particular importance to include a representative of this Institute on the Steering Committee as planners will be directly responsible for the preparation and implementation of landscape strategies including landscape character assessments.
Furthermore, it is considered that a very robust public participation process needs to be commissioned from the start so as to ensure, above all things, that everyone understands the objectives of the landscape strategy and the processes required to ensure that we achieve these objectives. In addition, the need for a public policy expert on the steering committee should also be examined.
It is important that the landscape strategy is not and should not be viewed as a means of controlling development. Such views particularly at the outset can lead to a resistance in engaging in the overall process. However, it is also necessary that the landscape strategy be realistic about the level to which development at or near sensitive landscapes is already constrained. In addition, it will undoubtedly be the case that any national landscape strategy will result in the identification of sensitive landscapes, where certain kinds of development are probably already restricted and will necessarily be restricted in to the future. The Strategy Issues Paper would, in some sections, seem to suggest that this is not the case, which is misleading to members of the public and potentially damaging to any process of engagement that would take place on that basis. The need for a strong and meaningful public participatory process is required. The issues paper does not provide any clear guidance on how this is to be achieved.
4. Landscape Strategy and considerations
Landscapes have evolved through time and contain eco-systems some of which are very complex. It is the functions of these eco-systems and the components of such that help shape the landscape. Landscape strategies, therefore, should be all encompassing and, more importantly, functional plans that clearly set out what is meant by the term ‘landscape’.
The strategic issues paper defines landscape as “an area, as perceived by local people, whose character is the result of the action and interaction of natural and/or human factors”. However, the European Landscape Convention defines landscape as “an area, as perceived by people, whose character is the result of the action and interaction of natural and/or human factors”. It is considered that the restriction of landscape perception to local people is highly exclusionary and suggests that landscape is a local issue rather than a subject of national importance.
Within Ireland, there are many landscapes of national and international cultural and heritage importance that people, who are not local to the area, have an affinity with (e.g., Tara, the Rock of Cashel, Bru na Boinne and Skellig Michael, the latter two sites being UNESCO World Heritage Sites). The proper planning and sustainable development of the country dictates that these landscapes be protected for future generations. In such instances, wide ranges of people are entitled to contribute to discussion about the area. For example, the opinion of experts in the field of archaeology or landscape can legitimately contribute to defining such areas and, more so, is valuable when considering how best to manage such landscape and accommodate the continuing interaction of natural and human factors. It is noteworthy that many of Ireland’s more prominent landscapes are also major tourist attractions. Given the importance of tourism to the Irish economy, it is vital that the consideration of landscape extends to broader issues about management in addition to local factors. It is suggested that the national landscape strategy adopt the definition of landscape as set out in the European Landscape Convention in order to ensure that the debate about landscape can be as inclusive as possible and to facilitate expert opinion to contribute to landscape management. Moreover, where the protection of landscapes of national and international cultural and heritage value is at issue, it is of paramount importance that these landscapes be identified, and the particulars of what is necessary for their protection of their integrity (e.g., extent of the area, features, etc.) be established, in national, rather than local, statutory policy.
It is further suggested that, in elaborating on the definition of landscape set out in the European Landscape Convention, the national landscape strategy should seek to dispel the perception that landscape refers to the rural environment and to emphasis that landscape includes the built environment. With regard to landscapes of value that include the built environment or a transition from urban to rural, it is necessary to ensure that any development or change takes place in the context of quality measures such as good urban design, high quality architectural treatment and strong building control measures. In addition, care should be taken to prevent a one-size-fits-all approach to the implementation of quality measures for development in all landscapes as local and regional distinctiveness of landscapes (whether built or rural) is often a key factor in the value of a landscape for local people, but also as a tourist destination.
The national landscape strategy should also address the role of other processes and legislative provisions such as Strategic Environmental Assessment, Environmental Assessment, Appropriate Assessment and Water Framework Directives. These processes all impact on the future shaping of the landscape. Reference is made to a national landscape atlas containing access to national and international mapping systems. It is considered that the role of GIS needs to be examined and incorporated into the strategy. Furthermore, there is no reference to the INSPIRE directive which establishes an infrastructure for spatial information in European Communities. The Directive seeks to ensure that spatial data infrastructures are compatible and usable in a community and trans-boundary context. The Department of Environment have commenced work on this data infrastructure. Information collected and collated as part of the landscape strategy should comply with this new data infrastructure.
The trans-boundary context is important when considering landscapes and there appears to be little consideration given to this in the issues paper. Consideration of public policies in a different jurisdiction can directly impact on how landscapes evolve. Co-operation and coordination of policies will be required if the national landscape strategy is to properly implemented.
As previously stated, the way in which people view the landscape is a significant consideration as it is the variance in such views that gives rise to conflicts in land-use management. The issues paper makes reference to ‘developing effective methods of partnership and engagement in the development of the strategy’ to overcome conflicting perceptions of the landscape. However, no further detail is given as to what is meant by ‘partnership and engagement’ and, more importantly, how this is to be achieved. The trans-boundary context is an important considered in this regard.
As set out in the issues paper, it is intended that the preparation of the landscape strategy will increase public awareness about landscapes. The preparation of the strategy should be a participatory process and, therefore, will require significant funding to ensure that the public at large are educated and engage in the overall process. Consideration needs to be given to the funding required in this regard. The actions as set out in the issues paper consequently will also require a commitment of significant funding if they are to be followed through.
Additionally, the collection of data in relation to the landscape is also a timely and costly exercise. The role of existing state and semi-state bodies in the collection of such data in the context of current staffing resources should be carefully considered. For example, there have been significant reductions in staffing numbers in planning departments in the majority of local authorities. The preparation of a national comprehensive landscape strategy in addition to national plans such as the revision of a national spatial strategy requires significant resources to ensure the timely delivery of a robust strategy based on the most up-to-date data. The cost of upgrading IT systems to facilitate the data and to comply with the INSPIRE Directive should also be carefully considered.
The Institute, whilst supporting the view that the landscape should be managed in a way that is in the interests of proper planning and sustainable development, are also of the view that such a strategy should not be seen or construed as a mechanism for stifling change or development on the landscape. The Irish landscape contains many historical and significantly important areas such as the Bru na Boinne area and Rock of Cashel. The importance of landscapes can be linked to their recreational, economic and social values to name but a few. The role of a national landscape strategy should be to educate on how we can manage our landscape to allow for existing and emerging land-uses without unduly negating the existing positive values of those landscapes. Public policy clearly has a defining role to play in this regard and, therefore, the need for coherent strategic policies that marry across all government departments are crucial. The steering group should be extended to take account of all professional disciplines that are affected by the preparation of this process. The importance of public participation is vital from the outset to minimise resistance to the strategy and to ensure that the public are educated as to the need for such a strategy and the objectives of such.
The Irish Planning Institute are willing to put forward a representative to fully engage with the Department on the preparation of this strategy. Further, if the Department considers it beneficial, the Institute are willing to meet and elaborate on any issues raised in this submission.
Irish Planning Institute