Landscape Alliance Ireland submission on the draft National Landscape Strategy
In view of the recent change of minister, our submission must of necessity begin with the hope that
the new minister Heather Humphreys will pursue the implementation of the National Landscape
Strategy with at least the same level of interest and commitment as Minister Jimmy Deenihan.
LAI has actively supported and informed the development of the National Landscape Strategy since
2007 and advocated the need for such a strategy since 1995 – we will continue to pursue the
dynamic and proactive implementation of such a policy into the future and in relation to the
strategy document as published the following are the LAI recommendations
‘Landscape Character Assessment’
The document contains a strong commitment to proceeding with a National Landscape Character
Assessment suggesting that the initial investment of scarce resources and strategy energy will be
directed towards this exercise.
LAI are of the view that before proceeding with same that a feasibility study be undertaken to decide
how best to deliver on Article 6 C 1, 1a, 1b, and 2 of the European Landscape Convention as
contrary to a common misconception the said article does not endorse LCA as the only means of
delivering on Article 6 rather it states that members should “be guided by the exchanges of
experience and methodology”.
We recognise that pragmatically we may have to accept that a certain ‘status quo’ has been
established with an LCA exercise of variable and often suspect quality has been completed in most
local authorities.
The feasibility study recommended above may conclude that in practical terms it may be best to
engage in an exercise at national and local level that incrementally converges in a satisfactory
outcome in the shortest time frame possible.
We respectfully suggest that at a national level the LCA exercise if proceeded with should be
confined to a GIS exercise to identify the landscape character types of Ireland – ideally this exercise
should cover the whole of the island of Ireland resulting in an LCA map that will act as a resource for
local authorities.
Concurrently national landscape objectives must be proposed and agreed through a consultation
process building on the steering committee already established.
As part of this exercise the current so-called Draft 2000 LCA Guidelines should be immediately and
formally withdrawn as despite a common misconception that these are not Guidelines – they
became ‘de facto’ guidelines at local authority level due to the utter irresponsible performance of
the Department of Environment in not revising same in response to submissions received in 2001 they are worse than worthless - they are toxic to the aims of the European Landscape Convention.
A new appropriate guideline document for local authorities reflecting these objectives must
therefore be prepared as a matter of urgency and issued following consultation.
The local authorities must revisit their LCA output and rework them in line with the national
guidelines and objectives.
We suggest that the concept of landscape character areas ‘per se’ should be critically evaluated and
possibly abandoned.
We also consider the separation of Landscape Character Assessment and Historic Landscape
Characterisation is dysfunctional, wasteful and confusing.
In the light of the above we therefore suggest that section 3.2 of the draft National Landscape
Strategy be re-titled ‘Landscape Identification, Analysis and Assessment’ and that the thrust of the
following text commits to an evaluation of the current position on ‘Landscape Identification, Analysis
and Assessment’ in Ireland and elsewhere to decide how best to proceed having account of
resources and needs.
Timeframe
It is vital that the timeframe decided and the actions contained therein delivers results on the
ground within 3 years – this is feasible if the focus is on awareness-raising and the development and
articulation of Landscape Quality Objectives.
If this timeframe is not achieved then we can forget the National Landscape Strategy, just as we
failed to deliver a National Spatial Strategy as events and politicians will have passed us by.
Delivery
To deliver on this strategy a small dedicated unit lead by a committed ‘Landscape Supremo’ will have
to be established. This supremo must have a clear multidisciplinary grasp of landscape and be driven
to deliver on what is shamefully a long-overdue strategy.
The resources required will deliver handsome and real dividends within a short timeframe in an
improved planning process, a reduction in wasteful conflict and most importantly an increase in the
medium and long-term sustainable value of our shared landscape.
Friday 1st August 2014
Terry O’Regan, Founder & Co-ordinator,
Landscape Alliance Ireland,
Cork