Dr. Fred Logue:

I will first deal with the conventions. I agree 100% they should be recognised in the Bill, not just formally but in substance. There should be documentation to explain how they have been embedded in the Bill. Along the lines of the point made by the Chair in respect of the Aarhus Convention, the Department is proposing the Bill should include some kind of explanation about how it has been done, in letter and in spirit. As the Senator is aware, the 2000 Act has very good provisions on built and architectural heritage.

There is an opportunity to strengthen that.

In terms of the prescribed bodies, with the ratification of the Aarhus Convention by the EU and Ireland in 2012, the ENGOs and environmental organisations now have a special role to play in the planning system. Unfortunately, that is not really recognised in the draft Bill. Those who drafted it are actually trying to reduce the scope of their actions through both the appeal restrictions and judicial review. Even at a local level near where I live, a member of the public contacted me about a significant decision with very serious environmental consequences that the local authority had not notified to An Taisce or the National Parks and Wildlife Service. There would be a benefit to doing this, even if it was only a very small development. An Taisce may not even have come up on their radar. There is a benefit to looking at circumstances-----