For Dublin Bay Proposals see www.dublincity.ie to appreciate the profound changes envisaged for the City and Dublin Bay in the coming years. The City Council have retained a group of consultants to draft a plan for the city to respond to climate change and rising sea levels. In Tolka Branch we have given the proposals some thought and consideration and have submitted the following views as part of the overall Birdwatch sumbission. The closing date for views is 30 November, 2007
Submission of Birdwatch Ireland incorporating the Tolka Branch views;
23rd November 2007
FAO. Mr Tom Vaughan
Dublin City Council
Re. Dublin Bay – An Integrated Economic, Cultural and Social Vision for Sustainable
Development (September 2007)
Thank you for the opportunity to comment on the study detailed above, a first stage in the
development of the future strategic role of Dublin Bay.
We welcome the study as an attempt at a coherent approach to longer term planning for the
future management and protection of Dublin Bay and its components. However, we have a
number of concerns and comments which we make in our submission, and we would welcome
the opportunity to be involved in the future phases of planning for the area.
Our comments focus on ensuring a sustainable approach is taken in developing the future of
Dublin Bay, in particular that:
o birds and the natural environment are properly taken into account.
o best practice including an ecosystem approach to managing our changing climate is
developed.
o robust functioning ecological networks for people and for wildlife are provided and
protected.
Some general comments follow, and some more specific comments are provided in the
Appendices of this letter, including a detailed submission from our Dublin Tolka Branch.
To ensure a sustainable approach to the development of Dublin Bay, we believe a number of
issues need to be addressed in the Vision document, and incorporated into the process of
developing a strategy for the bay.
Raising the status of the natural environment in the planning and decision making
processes, is very important in the context of this study and Dublin Bay in particular.
Throughout the document, an economic social and cultural vision for Dublin referred to in the
Dublin City Development Plan, is identified. It is important that this is not confused with the
definition of sustainability, where the environment is a pillar in its own right rather than merged
with culture. With this in mind, it is important to raise the profile of the natural environment in
Dublin city and to ensure that biodiversity is a significant component the vision, and in the
definition of sustainability in its true sense. We welcome reference to Integrated Coastal Zone
Management, and we believe this approach should actively be pursued. While a national
framework may not exist, a European context and examples do, and as such, this approach,
which incorporates natural systems and wider stakeholder engagement, should be pursued.
An assessment of the need for port developments, expansions and relocations in a
Republic of Ireland, All-Ireland and European context is needed. We note that this document
puts the port in the context of the National Development Plan. However, it is important that the
need for ports, their capacity, and hence the future purpose and extent of port activities of Dublin
and other ports should be assessed in an all-Ireland and European context. We note that there
are also proposals to develop Belfast port. It is important that coastal sites of national and
international importance for wildlife are not compromised by port developments that are not
assessed in a strategic manner.
Birds and the natural environment need to be properly taken into account. As mentioned in
the document, the Dublin Bay area is of particular importance for its wild birds and the habitats
they rely on. Obligations relating to the protection of wild birds go beyond the boundaries of
designated sites (as detailed in Appendix 3). It is important that wild birds are taken into account
throughout the phased planning of component parts of the bay – both spatially and temporally.
Given the scope of the vision it is important that a robust Strategic Environmental Assessment
takes place detailing the ecological implications. This approach needs to ensure all ecological
needs and potential impacts are addressed coherently at all stages.
Best practice, including an ecosystem approach to managing our changing climate, needs
to be developed. The indirect impacts of climate change on people, including food production,
water quality, and supply (including flooding) and health are mediated by natural systems. It is
important that there is a full understanding of and integration of the natural environment’s roles in
providing ecosystem services as part of this vision. In fact, a recent EU Green Paper on
adaptation to Climate Change notes that ecosystem services must lie at the centre of any
adaptation policy recognising that the impacts of climate-change on human wellbeing are
essentially mediated by natural systems. Innovative and imaginative ways are needed, and the
range of Options provided should be expanded to incorporate these. In particular, we believe that;
o infilling on mudflat areas with rising sea levels, and increased flooding risk is not
appropriate.
o the impacts of climate change are likely to be more than rising sea levels – other
predicted changes for a range of climate change scenarios are not taken into account
(details refer to Appendix 1).
Rather than addressing natural environment issues in terms of reassessing ‘the balance’ referred
to in Page 29, we believe an ecosystem approach needs to be developed, where ecosystems are
at the core of solutions to environmental problems. An opportunity for best practice and leading in
a European context for innovative ways of adapting to and mitigating for climate change impacts
exists. As well as incorporating this principle into the Vision, a wider range of Options need to be
presented, and a full ecological and ecosystems services approach needs to be adopted to
ensure natural systems are retained, created, and enhanced to provide long-term climateproofing
functions.
Robust functioning ecological networks for people and for wildlife should be provided and
protected.
Designated sites (page 32). In order to meet obligations relating to listed species and designated
sites (under the EU Birds Directive) there is a need to ensure the protection of designated sites
(as detailed in Appendix 3). By providing coherent and linked networks of sites, through habitat
enhancement and creation through appropriate management, connectivity for species
movements, and habitat dynamics can be accommodated. Where possible, designated site areas
should be extended and connected to allow habitat expansion and mitigation for habitat loss. The
designated sites of Dublin Bay should be assessed in the context of the entire inner and outer
Bay, and in the context of the necklace of wetlands along the east coast of Ireland, as well as
further inland. Opportunities for habitat creation and retention should be explored in this context
for the range of important species and habitats the Bay supports as a staging post, flyway,
wintering, feeding and breeding location. The ecological needs of supporting species, and the
change in species composition due to climate change scenarios should be fully assessed.
Recreation. The quality of amenity and biodiversity are linked, and are not necessarily exclusive
(as inferred on page 33). Appropriate management and strategic planning are required to ensure
sustainable management of both. The Vision needs to address the existing and growing demand
for amenity space in a quantitative manner in order to allow the management of amenity and the
natural environment in a sustainable manner. While there is mention of the availability of
greenspace, the S2S, and use of Sandymount and Bull Island, the Vision should also highlight
the need for a full assessment and strategic approach to management of amenity and protection
of natural heritage interests bearing in mind increasing population, and changing types of amenity
use. This is an important aspect in determining the evolving use of the Bay and the provision of
greenspace and amenity in Dublin in the next 50 years.
We note that birdwatching is not listed as an amenity use (Page11) of the Bay. We have four
active Dublin branches, a growing membership, and an increasing national and international
interest in birdwatching activities, particularly in Dublin Bay. Additionally, the use of the Bay as an
education and scientific resource is not referred to by this document.
Yours sincerely
Siobhán Egan
Senior Conservation Officer - Policy
Appendix 1: Specific comments
1. An ecosystem approach needs to be incorporated as a core principle. Amongst other
things;
o Pg16 under the section called ‘Planning to manage change’ should include ‘ecosystem
approaches’.
o Habitat creation on the Poolbeg peninsula should be designed to create habitats, mitigate
for potential looses due to climate change, and function in absorbing river flood waters,
as well as managing water entering the bay, dealing with rising waters.
o The range of Options presented does not include the option to not infill, or the range of
measure to mitigate for or adapt to climate change. Similarly, (page 2, para 3) alternative
futures should consider such Options not covered.
o The study does not identify the need for sediment deposition and erosion analysis of
ongoing dynamics both in the bay and along the east coast. The possible impacts of the
various Options proposed may have in this context needs to be considered.
o The development of greenspace in the Poolbeg peninsula does not consider flood
mitigation from waterflow from bodies flowing through the city and into the bay. Habitat
creation through wetlands for water attenuation as well as wildlife and amenity purposes
should be a component of the design.
o The proposal to infill components on the mudflat areas as part some of the options
considered should be removed. We note that a European Court of Justice ruling
regarding this issue is imminent. The range of options should include possibilities without
infill of mudflat or extension of the peninsula into the Bay.
o Modeling of wind blown sand onto peninsula and the impacts of a changing climate on
this phenomena needs to be assessed and incorporated into the strategic planning of the
Bay, along with large scale wetland creation as mitigation for possible habitat loss and as
a water attenuation and buffering effect for adapting to raising sea levels and increased
flooding from waterbodies feeding into the bay.
o Soft landscaping as mitigation for habitat loss and for providing coastal defenses rather
than hard engineering as part of an adaptation strategy for the Bay.
o Pg16 ‘Planning to manage change’ should include ‘ecosystem approaches’ to deal with
raising sea levels, adapting and mitigating for climate change, particularly given dynamic
nature of the bay, management of water
o Pg 15 climate change mitigation measures - the opportunity to build in mitigation and
adaptation measures on a large scale should be addressed here
2. The goals at the core of the sustainable strategic approach (as detailed on page 28) need
to be changed as;
o Sustainable design needs to incorporate large scale habitat creation that will allow for
adaptation and mitigation for a changing climate.
o The aim of ‘minimal impact’ should be changed to ‘avoid adverse impacts and seek to
enhance’. Similarly, page 40, #7, should go further than meeting a bear minimum for
natural resources – especially where national or nature reserve is purposed. In fact, best
practice should be pursued.
3. The national reserve (referred to on page 2), should included mechanisms for engaging other
stakeholders in decision making processes around its governance (page14) that involve active
participation in determining any plan of action. The document is not clear in identifying either a
nature reserve, marine reserve or a national reserve – which may all have different objectives.
Stakeholders should be involved in governance processes such as a Dublin Bay Trust (page
15) and mechanisms controlling the Bay.
4. Ecological health (page 2) should refer to not just water quality (page11&14) and blue flag
status, but should incorporate management plans for designated sites, with long term
conservation objectives for the interests of the designated sites. The ecological objectives for
estuaries (referred to on page 33) should also be tied in with conservation objectives of
designated sites through the development of management plans in order to develop of best
practice. Reference (on page 34) to ‘natural or near-natural’ states should change so that the aim
should be ‘fully functioning ecology of the bay including habitat and species requirements’.
5. Informed decision making (referred to on page 2) is key in the process of developing the
future strategic role of Dublin Bay, particularly for gaps in knowledge for ecology, amenity use
etc.
6. Page 6 should refer to the interests of ecological NGOs as stakeholders.
7. Page 10&11 – As well as those who live within a 20 minute walk of the coast, drive to the
coast, use public transport including the Dart. It is important to assess amenity use and growth.
As with projected cargo growth (page17) changes should be modeled for population changes and
increased amenity needs.
8. Page 12 – The EU Habitats and Birds Directives afford protection to designated sites as well
as listed species and habitats that afforded protection outside designated sites – terns,
sanddunes, otters, bats etc. which are supported by Dublin Bay, adjacent greenspaces, and the
port.
9. Page 16 – On what basis is 50% determined? The proportion of ‘greenspace’ relative to
increased ‘resident’ and ‘visiting’ population should be determined. Greenspace should be
designed in an ecological context – linked network of greenspace and relative to existing
greenspace, for all Options being considered and phases of development.
10. Page 26 - Under ‘Environmental Issues- Costs and benefits’. The ‘medium’ determined
here are not on par. The analysis should be based on more options (as previously detailed) and
consider which benefit, protect, enhance and avoid adverse impacts on natural environment
components. Consideration as to which as most sustainable (including mitigation and adaptation
measures) in the face of a range of climate change scenarios should be included.
11. Page 32 – The Ramsar designation is for wetlands and the protected species they support,
and wider obligations for protected species under this agreement and EU Directives should be
provided here, along with reference to the Dublin City Biodiversity Action Plan (on page 12)
where globally, nationally, and locally significant natural heritage is concerned.
12. Page 34 – While access and leisure are of the highest priority, there is a need to ensure this
is sustainable, that natural environment is taken into consideration, and to ensure that amenity
quality is not compromised as a result of degraded natural environment.
13. The Vision document does not cover landscape, seascape or skylines (either cultural or
natural) as part of the character of Dublin Bay.
Appendix 2: Submission from the Tolka Branch of BirdWatch Ireland
Comments on Dublin City Council’s Report on Dublin Bay - an Integrated Economic,
Cultural and Social Vision for Sustainable Development
Who are we?
Tolka Branch promotes bird watching and the enjoyment of our natural heritage in Dublin and
around Ireland and represents over 300 members of BirdWatch Ireland in the central and north
Dublin area. We also attract many visitors from outside Ireland though our website
(www.dublinbirding.ie) and other promotional activities. Tolka Branch of BirdWatch Ireland
welcomes the opportunity to comment on Dublin City Council’s study on Dublin Bay published in
September 2007.
Climate Change – an opportunity?
We appreciate the background issue and concern of rising sea levels anticipated over the coming
years, and the need to protect the lands, properties, communities and businesses affected by a
change in sea level. Ireland is not alone in facing this challenge. Solutions and the
experience of other nations should combine to inform discussions on this subject.
We also see this level of accelerated change in sea levels as an opportunity for medium term
planning and change, rather than as a cause for a reactionary and possibly over-defensive
response. Popular concerns and values increasingly emphasise the need to preserve and
conserve the endowments of current geographical and biological ecosystems. This is
underpinned by national legislation and international conventions, which set the legal parameters
for natural heritage protection. There are a number of conventions and legal instruments in
place, which set the boundaries to what public authorities may do with Dublin Bay. The
future of Dublin Bay will necessarily have to be considered in this legal context.
Alongside these legal considerations Tolka Branch of BirdWatch Ireland considers that there are
opportunities to be taken in the context of the responses to the inevitable change in the sea
levels. Sea defences have tended to homogenise coastal habitats and linearise coastlines. It is
our view that sea defences should not imply the demise of habitats but rather be seen as
an opportunity to increase habitat diversity with minimal ecological impact. Opportunities
to mitigate for and adapt to a changing climate are afforded by many habitats in Dublin
Bay. These habitats should be enhanced, and habitat creation should be pursued, as part
of the solution to environmental problems and mitigating for the possible loss of
important habitats, and providing public benefit. The ecological objectives for Dublin bay
have not been set out or defined to our knowledge, and it is with a view to developing such
objectives that we offer these preliminary views.
Four Ecological Concerns
We consider that there are four main concerns of ecological importance, which must be
addressed in Dublin Bay.
Firstly, saline lagoons are one of the most threatened coastal habitats. Tidal mudflats are
critically important for migrating shorebirds for use as staging posts and refugia from colder
climates. The unique spectacle of migrating birds on the North Bull Island is not only of
international scientific importance, but also provides Dubliners and birdwatchers from around
Ireland with a unique encounter with nature. In this context we are concerned at proposals to
convert the tidal zones around the North Bull Island and the Tolka basin into freshwater (or less
saline than at present) lagoons. This would fundamentally alter the underpinning saline
ecosystem and would cause an ecological shock to the flora and fauna of the area, which support
avian diversity.
Secondly, tidal replenishment of beaches, such as Dollymount Strand, acts as an important
source of food for seashore birds such as gulls, waders and terns. The removal of beach area,
apart from the amenity value, would diminish avian diversity in the area. Absence of a tidal wash
will remove food from the food web including larvae and algal propagules, which are brought into
shore sometimes from a great distance. Blocking tidal movements, in the absence of mitigating
measures, will eliminate this source of food both from the lagoon areas and the beaches.
Thirdly, Dublin Bay already provides important nesting and roosting space for birds. Terns nest
on disused port platforms in Dublin Port, and Sandymount Strand hosts up to 18,000 sea and
shorebirds, at peak roosting times. Any proposals for Dublin Bay should seek to preserve these
areas, or provide alternate suitable locations.
Fourthly, the sustainable development of Dublin Bay should include habitat creation to offset
habitat losses where possible, support the movements of important species, and create more
valuable spaces for people and for wildlife. For example, new inter-tidal marine habitats such
as rocky shores could stimulate a regeneration of lost habitat species. The management of water
systems provides an opportunity to create new habitats as well as introducing mitigating measure
to preserve existing habitats.
Final comments
The proposals outlined in the study for Dublin Bay are profound and far-reaching. Their ecological
impact must be set out in advance of the next stage of consultation so that interested groups, on
a fully informed basis, can formulate comments. Environmental Impact Assessments should
be carried out on each and every aspect of the range of proposals in advance of the next
phase of consultation.
Conclusions
Tolka Branch of BirdWatch Ireland considers that there is an opportunity for Dublin City Council to
take a far seeing approach, which can embrace innovative environmental possibilities, in the
management of Dublin Bay. This new approach can sit easily with both the economic and social
needs of the City. Environmental management, building on and protecting the natural
environment, has become an integral part of sustainable development, and has an economic
significance in itself in terms of gains to overall welfare for citizens, amenity value, tourism,
international reputation and science and research potential. We have set out our four primary and
preliminary ecological concerns, from the perspective of sustaining avian abundance and
diversity, which should form part of the overall sustainable objectives for Dublin Bay. We would
welcome any further opportunity to comment on proposals in the next phase of consultation.
Tolka Branch of BirdWatch Ireland,
Dublin, November 2007
dublinbirding@gmail.com
Appendix 3: Brief summary of national and international obligations to protect wild bird
interests.
Wild birds and their habitats are protected through national and European legislation, and
international agreements and conventions. Accordingly, Ireland is required to:
o Maintain favourable conservation status of all naturally occurring wild bird species (EU Birds
Directive).
o Protect listed bird species and their habitat requirements for breeding and feeding, in the
wider countryside and through the designate of sites as Special Protection Areas (SPAs).
This adds to the network of designated sites called Natura 2000, which Ireland has an
obligation to protect and monitor (EU Birds Directive and EU Habitats Directive).
o Make special provision for all regularly occurring migratory bird species on land and sea
regarding their breeding, moulting, wintering and staging posts along migration routes (EU
Birds Directive, Bonn Convention).
o Make special provision for wetlands and wetland birds (EU Birds Directive, Ramsar
Convention, African-Eurasian Waterbird Agreement, Wetlands International)
o Halt the decline of biodiversity on local, national and global scales (Rio Convention on
Biological Diversity, Berne Convention).
Under the EU Habitats and Birds Directives listed habitats and species are afforded special
protection through the designation of sites and other means. Where designated sites, or the
features for which they are designated, may be threatened by development, the competent
authority must undertake an appropriate assessment under Article 6.3 of the Habitats Directive:
Any plan or project not directly connected with or necessary to the
management of the site but likely to have a significant effect thereon, either
individually or in combination with other plans or projects, shall be subject
to appropriate assessment of its implications for the site in view of the site's
conservation objectives. …the competent national authorities shall agree to
the plan or project only after having ascertained that it will not adversely
affect the integrity of the site concerned...
In addition, Article 4.1 of the Bird Directives states:
The species mentioned in Annex I shall be the subject of special conservation
measures concerning their habitat in order to ensure their survival and
reproduction in their area of distribution
While Article 4.2 states:
Member states shall take similar measures for regularly occurring
migratory species not listed in Annex I, bearing in mind their need for
protection in the geographical sea and land area where this directive
applies, as regards their breeding, moulting and wintering areas and
staging posts along their migration routes.