Environmental coalition raises alarm over Skellig Michael management plan

January 10th 2019 – immediate release
Environmental groups and the public are being left in the dark over the Government’s plans to manage Skellig Michael, Ireland’s largest environmental coalition has said.
The comments from the Environmental Pillar come in the wake of the launch of a public consultation in late December on the next management plan of this important UNESCO site.
The site attracted global fame following its inclusion in the new Star Wars trilogy despite concerns from environmental groups over the potential for damage during filming. [1]
The Government must now submit a new management plan to UNESCO in 2019, with the public consultation supposed to help guide and inform the content and direction of the new Plan.
However, in a letter sent this week to the Minister for Heritage Josepha Madigan TD, the Pillar warned that the consultation is “fundamentally flawed” as the only document available for review is the old plan which expired in 2018.
As there is no draft of the next plan available, the Pillar outlined in the letter that “in essence we are in the dark about the government’s proposals” for the heritage site.
There is also no mention in the consultation notice about the screening for Strategic Environmental Assessment and Natura Impact Statement which is required by law for any plans or programmes such as the Skellig Michael Management Plan. [2]
The notification text also says that the responses received from the public and concerned groups will help to guide and inform the content of the new Plan before it is submitted to UNESCO.
The Pillar is interpreting from this text that there will be no further consultation on the actual draft plan something that it describes as “absolutely unacceptable”.
In its letter, the Pillar said that best practice should see the draft plan subjected to a 6-8 weeks public consultation, followed by workshops with key concerned groups, and then the publication of the draft final plan along with the required environmental assessment.
The Pillar also outlined concerned to the Minister with the short four-week window for submissions which includes the Christmas and New Year’s period when most people are on leave.
According to the Pillar, all of the above issues effectively see the consultation process run in contravention of the Government’s requirements under the Aarhus Convention, European Directives and the State’s own consultation guidelines. [3][4][5]
In this light, the Pillar is seeking an extension to the deadline, currently set for 18 January, by at least another 14 days and for answers to our questions posed in relation to the consultation and the actual draft plan.
Earlier this week, the Pillar flagged concerned with a similar decision to launch a public consultation on new draft regulations for upland burning over the Christmas period. [6]
The Department of Culture, Heritage and the Gaeltacht has since extended the date for submissions to 31 January 2019, and the Pillar would like to see similar action for this consultation.
Environmental Pillar spokesperson, Charles Stanley Smith said:
“The success of ‘Star Wars’, is largely positive in terms of local tourism but in terms of visitor numbers is putting undue strain on Skellig Michael as a leading Irish UNESCO site and on the island’s birds habitats.  The Environmental Pillar would condemn any increase in landings and rather look for improvements of ‘Skellig’ related tourism projects on the mainland.
“Despite the clear importance of further debate on this issue, the Government decided that it was best to sneak in a public consultation at the end of December when most people are on leave for the Christmas and New Year’s break.”
“The deadline – currently set for 18 January – effectively gives the public and concerned conservationists a two week window to get their valid views across on this important subject matter.”
“In addition, the consultation is not included on the Government’s consultation portal escaping the automated email system to alert concerned groups. As a result, most of the Pillar’s member organisations have only just found about it through Twitter.
“This is not adequate, nor is it acceptable from a legal standpoint and it is quite clear that the Government’s decision runs in contravention of the requirements of international and European law and also the State’s own consultation guidelines.”
[1]An Taisce. Letter to the Minister for Arts Heritage and Gaeltacht from August 2015.https://goo.gl/B3z6uu
[2] Screening for SEA and screening for Appropriate Assessment must be undertaken and consultation with the Environmental Protection Agency and other organisations is a requirement of SEA in Ireland. These documents must then also be submitted for public consultation. The website here has more information http://www.epa.ie/monitoringassessment/assessment/sea/
[3] “Depending on the significance of the proposal, a consultation process would ordinarily be expected to vary from 2 to 12 weeks… A longer period is appropriate where those with limited resources, such as individuals and small businesses, are being consulted. In addition, longer consultation periods may be necessary when the consultation process falls around holiday periods.” Consultation Principles & Guidance: https://goo.gl/xQy3k9
[4] Directive 2003/35/EC: “The public concerned shall be entitled to express comments and opinions to the competent authority before a decision is taken… Reasonable time-frames for the different phases shall be provided, allowing sufficient time for informing the public and for the public concerned to prepare and participate effectively in environmental decision-making…”https://goo.gl/7CeQHB
[5] In a Spanish case from 2009, the Aarhus Convention Compliance Committee found that “a period of 20 days for the public to prepare and participate effectively cannot be considered reasonable, in particular, if such period includes days of general celebration in the country”. https://goo.gl/gQtFYW
[6] Environmental Pillar. Extension of public consultation on controversial upland burning welcomed by environmental coalition: https://goo.gl/LzZfCv