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INTRODUCTION
This work examines several aspects of the dispute regarding the cessation of turf cutting on
designated peatlands in Ireland. This conflict centres on the need for the Irish government to
comply with Council Directive 92/43/EEC (Habitats Directive), specifically with the
designation of active raised bogs and active blanket bogs as priority habitats and the desire of
those who had traditionally harvested turf on designated peatlands to continue this practice.
The events and background to the dispute are examined in Chapter 2 in light of information
presented in Chapter 1 regarding the nature of environmental resources, the complex nature of
rural resource systems, changes in approaches to resource management due to the rise in
importance of the concept of sustainability and the cultural significance of Irish peatlands.
These two chapters highlight the problems of implementing conservation strategy which
impacts on a resource system composed of natural and human elements form a top-down
perspective through legislation. In order to marry the competing valuations of environmental
resources in management policy which adheres to the principles of sustainability, an approach
to policy formulation and decision making is required that incorporates the range of
perspectives on resources. Participatory processes involving the range of interested and
affected stakeholders represent one of the most important methods to achieve this and avoid
or mitigate conflicts such as described here. The great utility and necessity of incorporating
participatory processes into environmental decision making structures is explored in Chapter
3, leading to an outline of best practice guidelines for conducting participatory processes. In
Chapter 4 the results of research regarding perceptions of stakeholders towards one of the
participatory processes used to attempt to mitigate this conflict, the Interdepartmental
Working Group on the Cessation of Turf Cutting, are presented and discussed in light of the
guidelines presented in Chapter 3. This chapter also presents a literature review of typologies
of participatory processes and classifies both of the participatory processes used in this
dispute using both primary and secondary data. The final chapter presents the conclusions and
recommendations emerging from this work, mainly relating to the need to incorporate greater
public participation into the Irish environmental decision making context generally and
presenting practical methods through which this can be accomplished.
The main objectives of this research include:
• Outlining of the complex nature of rural resource systems and the need for participatory
processes to manage them in a sustainable fashion

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• Determining the root causes of the conflict between turf cutting interests and conservation
interests in this dispute
• Outlining of general best practice guidelines for conducting participatory processes
• Examining and assessing the two participatory processes used in this dispute in the
context of the guidelines
• Classifying the two participatory processes used in this dispute based on a literature
review of typologies
• Determining practical recommendations which can aid the use of participatory processes
in Irish environmental decision making structures in future based on this case
Research Design And Methodology
This work is qualitative in nature and is based on inductive logic. Research comprised an
examination of stakeholder perceptions of the Interdepartmental Working Group on the
Cessation of Turf Cutting in light of best practice in participatory processes and an
examination of the structure of that process and the Peatlands Council process in the context
of typologies of participatory processes.
In order to meet the needs of this project, a mix of research methods was necessary. Firstly, in
order to outline best practice guidelines and typologies of stakeholder participatory processes,
to outline the characteristics of rural resource systems and to provide background information
on the dispute under examination here extensive literature reviews were required. The
collection of primary information regarding stakeholder perceptions of the Peatlands Council
process was originally envisioned to be conducted through interviews with the facilitators and
stakeholders, but this was ultimately unsuccessful. Interview questions were compiled based
on the elements of best practice which contribute to empowerment and fairness in
participatory processes, based on the literature review conducted in this area. All member
groups of the Peatlands Council were approached regarding interview. The interview
questions were comprehensive and designed to be put to candidates in a semi-structured
interview. The questions are available in Appendix E. Unfortunately, due to the on-going and
sensitive nature of the Peatlands Council process, the facilitator understandably deemed it
unwise for members to participate in this research and communicated this via e-mail (see
Appendix J). The main primary evidence gathered thus consisted of information gleaned from
the facilitators of the Interdepartmental Working Group on the Cessation of Turf Cutting

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regarding the structure and methods of that process and information from the TCCA regarding
their perceptions of involvement with that process. The questions which were put to these
respondents were again based on the literature review of best practice and typologies of
participatory processes. Questions and responses are available in Appendices F-I. Other
candidates approached with regard to interview concerning stakeholder perceptions of the
Interdepartmental Working Group process declined due to its connection with the on-going
Peatlands Council process (see Appendix J).
In light of the difficulties encountered in collecting primary data to analyse stakeholder
perceptions of these two processes in terms of best practice, the information required to meet
the objectives of the project was broadened to include examination of all available content
(newspaper articles, press releases, speeches, interviews with the representatives of the
stakeholder groups involved in the participatory process), the information from which was
coded and categorised using a form of grounded theory called content analysis. The emerging
patterns under different analytical and grounded categories were then compared with best
practice in participatory processes as outlined in the literature review to determine if it was
followed, from which conclusions were drawn. The two participatory processes were
categorised based on typologies encountered in the literature review on that topic and on
information regarding the structure of the processes gleaned from both primary and secondary
information. Reed (2008) uses Grounded Theory Analysis to identify elements of best
practice public participation from the literature while Moore et al. (2001) use a similar
method to identify key elements which engendered commitment in case studies of three
participatory processes. Further explanation and justification of this method is outlined below.
In analysing subjective information, such as the perceptions of the stakeholders towards
aspects of the participatory process, definitive conclusions are difficult to reach. Hypothesis
testing through deductive reasoning is not appropriate due to the extreme improbability that
complete unanimity would be reached in comparison of interview respondents’ answers to
questions. It is likely that most hypotheses could be falsified based on conflicting information
from respondents. Thus, a research design which focuses on the weight of evidence in favour
of particular conclusions is more appropriate. To this end, a technique called content analysis
has been used here, which can be broadly defined as ‘any technique for making inferences by
systematically and objectively identifying special characteristics of messages’ (Berg, 2004, p.
267). The content analysis process is described by Berg (2004, pp. 267-287). Researchers use
content analysis to objectively examine items of social communication and objectively

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analyse the meaning of the message conveyed (Berg, 2004, p. 267). At its heart the process
involves the specification of the characteristics of content elements (paragraphs, themes etc.)
to be examined and the specification and application of rules to identify and record these
characteristics (Berg, 2004, p. 275). Firstly, analytic categories are constructed based on
themes and issues relevant to the literature and the research objectives. Following this, a
comprehensive analysis of the item of communication is undertaken to establish the grounded
categories, or the themes and issues which arise directly from the text. This inductive
approach ensures that the categories produced are grounded in the data. This process can be
referred to as coding. Criteria of selection are then established for each category, where the
occurrence of a particular phrase such as ‘lack of consultation’ in a sentence would mean it
was assigned to a particular category on this theme. The items of communication are then
reread with the criteria of selection in mind and each occurrence of a data chunk which fit the
criteria for a particular category is recorded by location. The list of data chunks under each
category heading can then be compared and contrasted to determine if patterns were evident.
In this work, the patterns which emerged from the coded items of social communication were
then examined in light of the best practice guidelines extrapolated from the literature review
of the elements of participatory processes which are vital to their success.

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CHAPTER 1 RESOURCE MANAGEMENT, RURAL
RESOURCE SYSTEMS AND CONFLICT
Introduction
In order to examine aspects of the environmental dispute being studied by this work, it is first
necessary to examine the nature of environmental resources and the implications of these
characteristics for resource management. Section 1.1 outlines the change in emphasis in
resource management approaches over the last half century, where less tangible components
of the environment have come to assume greater weight in decision making structures, driven
by the rise in importance of the concept of sustainability. Section 1.2 outlines the complex
nature of rural resource systems, highlighting the multitude of components and actors with
differing, and sometimes conflicting, agenda’s which must be considered in their
management. Section 1.3 outlines the cultural significance of Irish peatlands based on the
social and economic gain generated by their traditional use as a source of fuel. The points
made in this chapter will be used in the following one to examine the main elements which
have caused and sustained the dispute under examination in this work.
1.1 Changing Approaches To Environmental Resource Management
Cloke and Park (1985) provide a good account of the nature of environmental resources, the
rural resource system and the implications of these characteristics for management. They note
that resources are culturally defined, abstract objects where anything can be regarded as a
resource if it allows a user to achieve socially-valued goals. Zimmerman (1951 cited in Cloke
and Park, pp.35-37) notes that a resource is defined by the functional relationship between
three elements, namely human wants, human abilities and the appraisal of the environment.
From this perspective the environment is viewed as a reservoir of elements from which
opportunities can be isolated based on technological capacities and the prevailing social and
cultural needs and outlooks with regard to suitability of land for different uses. The growth of
different resource planning approaches over time is charted, where the incorporation of new
approaches to valuing the environment and to assessing which components of the
environment constitute a resource, based on changing societal and cultural values, has led to a
focus on resource management rather than development. It is noted that three different aspects

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of resource planning can play a part in any given planning situation, which can be emphasised
to a greater or lesser extent depending on the aim of the planner. These aspects are the
analysis of resource availability and status, the formulation of approaches to management of
given or potential resources and the development of the resource base, embodied in the roles
of the resource surveyor, manager and developer respectively (Cloke and Park, 1985, p. 37).
An important point to note in the context of this work is that the emphasis between the three
aspects has changed over time, with resource management approaches now to the fore. In the
19th
century, resource development dominated in Great Britain and the United States, where
use of resources was based on maximization of net gain (Cloke and Park, 1985, p. 41). This
approach contrasts with that which has risen since the 1960’s, the resource management
approach, where resource planning and management is characterised by the use of co-
operative policies and increased public involvement, as well as a stronger role for
governments in placing public interest above private gain in resource use (Cloke and Park,
1985, p. 43). A number factors have driven this approach, namely the consideration of less
tangible components of the environment as resources, moves to value these types of resources
and the increased importance of moral elements in the decision making process.
Cloke and Park (1985, p. 41) note that these changes in approach to the management of
resources have been driven by awareness of potential long-term and large-scale damage to the
environment from economic development. In terms of the consideration of less tangible
elements of the environment as resources, it is noted that attention within resource
management switched in the 1960’s from use of resources to provide materials for economic
growth to consideration of resource quality issues which impact on quality of life. Following
Chapman (1969, cited in Cloke and Park, 1985, p. 42), it is noted that societies can afford to
pay more attention to quality of life issues as a threshold of economic development is reached.
The emphasis on environmental quality has two important implications here:
• The overall fabric of the countryside constitutes a resource in its own right
• It is necessary to take all those aspects of the rural environment which can impact on
quality into consideration in resource planning (Cloke and Park, 1985, p. 42)
The consideration of environmental quality in decision making necessitated that valuation
methods for less tangible elements of the environment be developed. Traditionally, resources
were largely developed based on cost/benefit evaluations of using a particular resource, stated

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in economic terms. Methods of valuation for aspects of the environment such as wilderness
and quality were developed to enable them to be considered alongside economic valuations of
resources in decision making. Farber et al. (2006), for example, outline a range of valuation
methods which can be used to determine the trade-offs people are willing to make in terms of
changes in ecosystem services under different land-use strategies. The value of change in a
particular ecosystem service based on development in one manner can be quantified and
assessed relative to development in other avenues or to the baseline position of the ecosystem.
The evaluations of trade-offs can then be used to select the management option which
provides the highest value service flow from the ecosystem. While the valuations of resources
from such perspectives might be considered in the decision making process, the actual weight
given to social and environmental factors compared to economic factors will largely depend
on the political context in which the decision is being made (Cloke and Park, 1985, p. 43).
Cloke and Park (1985, p. 40) note the lowly position of moral and environmental constraints
in the hierarchy of constraints on decision making in resource management at the time of
writing (1985). The fundamental factors, including technical feasibility and strategic
importance of developing a particular resource, are considered first. Following this, pragmatic
factors such as cost, logistics and conflict resolution are examined. Lastly, tertiary factors
such as environmental constraints and moral implications of using a resource in a particular
way are examined. A diagram of this hierarchy of constraints is presented in Figure 1.1.
Figure 1.1: Hierarchy Of Constraints In Resource Management Decision Making. Constraints
Diminish In Importance Following The Green Arrow (Source: Cloke and Park, 1985)

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The change from resource development to resource management orientations has been driven
by the inexorable rise of the concept of sustainability and sustainable development, which
underpins much of the legislation and policy produced regarding the environment both in
Ireland and throughout the developed world. The concepts of sustainability and sustainable
development were popularized following the publication of the report of the Brundtland
Commission, entitled Our Common Future, in 1987. This report redefined the relationship
between development and the environment. The overarching findings of the report were that
economic, social and environmental elements such as food security, loss of biodiversity,
energy and industry were all interconnected and had to be legislated and planned for in a
holistic way. The still useful definition of sustainable development, that it is ‘development
that meets the needs of the present without compromising the ability of future generations to
meet their own needs’ which emerged from the report points to the two key concepts of
sustainable development, namely needs and limitations (Mitchell, 1997, p. 27). Limitations
and growth are interlinked. The report offered guidance on the relationship between economic
growth and development and the limitations imposed on them by social, technological and
environmental considerations. Firstly, it was noted that limitations exist on development due
to the capacity of humans to actually use a resource based on technological and scientific
limitations and the capacity of the environment to absorb the impact of that resource use. In
light of these limitations it is noted that equitable access to constrained resources must be
assured and technology must be used to relieve pressures and avoid approaching the limits of
resources but that every ecosystem could not be maintained in a pristine state as the
continuation of human life involved a certain amount of resource use. A change in the style of
growth was being advocated, making it less energy intensive and more equitable (Mitchell,
1997, pp. 27-28).
While Mitchell (1997, p. 32) notes that the concept of sustainable development can be seen as
an oxymoron, it can be argued that the formulation of policy based on its principles can act as
a pathway through which growth can meet human needs while ensuring that the environment
which forms the basis for growth is not unacceptably degraded. The concept of needs can also
be problematic however, especially in the context of intergenerational versus intragenerational
needs. The definition of sustainable development raises the issue of how a society chooses
how much of a resource should be used and how much should be preserved for future
generations, when the needs of many in less developed areas of the world are not being met in
the present. This has been discussed in both Redclift (1997) and Mitchell (1997). Redclift
(1997, p. 442) also outlines how needs can be defined differently depending on who is

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defining them and the capacity of the society to satisfy them based on technological
advancement. In terms of decision making regarding needs and development, it is argued that
sustainable development is often associated with the drive to empower those spatially closest
to the site and the incorporation of the potential impacts of development into decision making
structures. Mitchell (1997, p. 33) argues that while this is admirable, there is a need to
develop a common purpose or framework within which decisions can be made, as
environmental problems comprise the results of decisions taken at a multitude of spatial
scales.
At any rate, the most important point in terms of this work is that the need to balance growth
with the limitations of the environment has grown since the Brundtland report, through the
impact of the reports of the Earth Summits at Rio de Janeiro (1992) and Johannesburg (2002),
Agenda 21 and the Earth Charter. The principles of sustainability have impacted on such
international legislative instruments as the Habitats Directive, which has precipitated the
conflict under examination here. The following section details the characteristics of rural
resource systems and the implications of these characteristics for management systems which
adhere to principles of sustainability. The potential for conflict in rural resource systems is
also explored.
1.2 Rural Resource Systems and Conflict
Based on the need to balance needs and limitations with regard to environmental resources
under the principles of sustainability, Cloke and Park (1985, p. 45) note that planning systems
for rural resource management must:
• Acknowledge the diverse perceptions and valuations of resources in the countryside
• Take account of the assemblage of resource components within the countryside
• Consider methods to allocate resources equitably and sensibly between competing and
conflicting demands.
This is particularly relevant in the case of rural resource systems, the characteristics of which
are outlined in Cloke and Park (1985, pp. 47-51). These can be summarised as follows:
• The system includes human and environmental elements which need to be incorporated in
the planning system

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• They include both non-utilitarian resources and natural resources
• Planning systems in rural resource systems are influenced by a range of regional, national
and international legislative instruments which can be based on different issues and goals
• Rural resource systems are composed of mosaics of interacting and sometimes conflicting
resource uses, meaning that conflict resolution is extremely important.
The fourth point is particularly relevant here. Cloke and Park (1985) note that individuals can
have a range of goals in using a rural resource in a particular way, ranging from economic
motivations to recreation to the provision of services. The perceptions of an individual as to
what constitutes a resource, in what way and how it should be used or managed will vary
based on socio-economic aspects such as age, education and place of residence. The goals of
resource users in developing a resource in a particular way will also be shaped by political
and scientific factors regarding need or consequences of development in that fashion. Figure
1.2 below presents a visual depiction of some of the most common resource uses and goals,
with the potential for conflict between different groups based on their perception of the most
acceptable form of land use for a particular area. Thus, while one potential resource user
might view a piece of land as an area in which to grow crops and earn a profit, another may
see it as an unspoilt wilderness which provides space for recreation.
Figure 1.2: Potential Resource Uses And Human Elements Which Influence Goals In Rural
Resource Systems (Source: Cloke and Park, 1985, p. 50).

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The range of elements which constitute resource systems and the human elements which must
be incorporated into their management are exemplified in a study by Power et al.(2000) of the
potential of Integrated Coastal Zone Management (ICZM) to provide scientifically based,
locally agreed management planes for seven beach and dune systems in County Donegal. In
an outline of the main problems for management of beach and dune systems in Donegal, it is
noted that traditional uses, such as seaweed gathering, sand extraction and winter livestock
grazing, as well as visitor pressure on the systems for recreational purposes, have led to a
deterioration in conservation status and amenity value of some systems. The economic
development of the dunes for tourism is placed in the context of physical and economic
factors which both hindered the development of Donegal tourism generally and necessitated
its further development. Here the tourism season is short due to the weather and the remote
location of the county and declining employment in traditional industries drove a desire to
capitalise on the Celtic Tiger and the on-going, and at that time recent, political stability in
Northern Ireland by attracting the maximum number of tourists. Set against the desire to
develop the dune systems is the desire to conserve them, as provided for in the designation of
many such systems as candidate SAC’s under the Habitats Directive. A further complicating
factor is the fragmentary nature of management responsibility, even at the level of an
individual dune system. Here the intertidal areas and contiguous inshore waters are managed
by the Department of the Marine and Natural Resources, land above the Mean High Water
Mark (MHWM) in private ownership comes under the control of local planning authorities,
the NPWS administers protected areas such as SAC’s, the Blue Flag scheme is administered
by An Taisce, while the Water Safety Council and the Environmental Protection Agency
advise on water safety in water used for public bathing (Power et al., 2000, pp. 143-144). The
overall picture is a resource system in which numerous actors operate with differing agenda’s
based on their differing goals. While some of the actions taken to meet certain goals may be
complimentary, such as the designation of beaches as ‘Blue Flag’ and drive to increase
tourism numbers, others will almost invariably be in conflict, particularly conservation efforts
and development for economic purposes. This example explicitly demonstrates the complex
nature of resource systems.
Bruckmeier (2005) presents a review of results from conflict research which point to some of
the main characteristics of conflict in resource management. Resource use conflicts in coastal
areas are posited as predominantly resulting from the different interests, needs and values of
resource users. They further depend on varying subjective perceptions and interpretations of

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facts and have cultural, social, economic and ecological dynamics which can be difficult to
reformulate and address through political intervention (Bruckmeier, 2005, p. 66).
To summarise, conflict arises in rural resource systems due to the complex nature of those
systems. Bearing in mind that the system is composed of both natural and human elements,
differing goals of potential resource users, based on a range of socio-economic factors, will
often generate conflict where two particular resource uses are incompatible. The following
section presents an outline of the particular case of Irish peatlands, concentrating on how
resource users value them as a resource and the role socio-economic factors play in
determining how a particular resource will be used at a particular time.
1.3 The Roots of Conflict In Irish Peatlands
The roots of conflict involving peatlands are evident in a number of recent studies. Bullock
and Collier (2011) come to the conclusion that peatlands in Ireland are widely recognised as
cultural landscapes, but that the social and economic gain which is traditionally attached to
peat extraction is an important element in how local communities value the cultural
landscape. This is an important point in relation to the dispute under examination here.
Bullock and Collier (2011, p. 972) note that landscapes, as opposed to habitats, can be viewed
as socio-ecological constructs, which must be preserved both for their natural and cultural
heritage. They are largely valued for their traditional cultural associations by the public rather
than for the habitats or ecosystem services they provide. They argue that approaching
conservation from this point of view, rather than from a purely ecological perspective, would
engender more support from affected local stakeholders towards policies. These conclusions
arise out of a survey conducted by the authors in 2008, which aimed to examine public
preferences for the after uses of cutaway peatlands. The survey consisted of behavioural and
attitudinal questions followed by a contingent valuation question and a set of four discrete
choice experiments. One aim behind the survey was to determine whether local people and
the wider community believed that the use of cutaway peatlands for the creation of a National
Peatlands Park in the Midlands could supply a public benefit. The questionnaires were
accompanied by information sheets describing the condition of peatlands and the deterioration
due to industrial and domestic turf cutting. The sample was a belt across the Midlands where
most of the raised bogs in the country are located (Bullock and Collier, 2011, p. 973).

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The results indicated that 41% of respondents (of 494 total respondents) considered bogs to be
more important as heritage rather than fuel. Results of the choice experiment conducted as
part of the survey revealed public preferences for the composition of a proposed National
Peatland Park. The authors note that while most respondents would value a peatland park,
they would like household, as opposed to industrial, turf cutting to be permitted and would
prefer it to be a long term development. The preference for continued household cutting was
not shown to be unanimous among all groups, however, with negative interaction between
this attribute and higher social class and environmental concern (Bullock and Collier, 2011,
pp. 973-976). This correlates with the description of the diversity of valuations and
perspectives on resources in the rural resource system outlined previously.
A study by Cruickshank and Tomlinson (1995) outlines some of the socio-economic
explanations for the distribution of peat extraction in Northern Ireland which illustrate the
range of elements within the rural resource system that can impact on land-use choices and
preferences, and generate conflict where the tradition of turf-cutting is threatened. Here,
information regarding extent of peat extraction using different methods was overlain in a GIS
program with layers showing factors such as unemployment statistics and socio-economic
regions, particularly the Less Favoured Areas (LFA) regions of Northern Ireland, to examine
spatial coincidences between peat extraction and socioeconomic indicators. To affirm causal
relationships, interviews were conducted with peat producers and representatives of
government departments, with questions targeted to examine reasons for extraction and
perceptions of impact on the environment.
It was shown that a correlation could be drawn between religious affiliation and machine
cutting for fuel, a pattern which the authors associate with a tradition dating back to the
plantation of Ulster, where the Irish were pushed onto poorer lands and resorted to using the
cheap, available fuel. The importance of tradition is exemplified in an area containing poor
agricultural land southwest of Lough Neagh, where small scale peat extraction continues
among local Roman Catholics due to the previous tradition of extraction in the area by the
Irish Peat Development Company (Cruickshank and Tomlinson, 1995, p. 375). Economic
need was also shown to be spatially related to peat extraction, with machine cutting found to
be heavily concentrated in Severely Disadvantaged Area’s (SDA), characterised by small to
very small farming businesses. Resultant low farm incomes and little opportunity for
employment lead to a reliance on turf to reduce household heating bills. Conflict at
Ballynahone Bog directly centred on the valuation of peatlands for economic gain as opposed

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to conservation, as efforts to designate it as an Area of Special Scientific Interest (ASSI) in
1986 were frustrated when a public inquiry ruled for a local horticultural peat company who
wished to expand using the bog. The maintenance and creation of employment was directly
cited as the reason, although the decision was overturned in 1994 and conservation status was
granted (Cruickshank and Tomlinson, 1995, p. 378). The impacts of the prevailing political
ideology on planning for peatland management and rural resource systems were demonstrated
by the policy of government to subsidise turf cutting through grants for purchase of
machinery and promotion of the industry through seminars in Northern Ireland in the 1980’s.
Bullock and Collier (2011, p. 975) also note a number of reasons why turf cutters are reluctant
to discontinue the practice, as well as specific reasons why the efforts to implement the
rulings of the Habitats Directive in relation to the designated bogs have failed, largely tied to
the perceived status of turf cutting as part of the heritage embodied by the cultural landscape
of the peatlands. Firstly, the authors posit that those who support domestic or household turf
cutting see it as inherently more sustainable than large scale industrial turf cutting. Secondly,
the efforts to halt turf cutting can be perceived as meddling by outsiders into the affairs of
those who have shaped the cultural landscape for generations. Specifically in relation to the
dispute under examination here, Bullock and Collier (2011, p. 976) argue that the
compensation packages have largely failed due to the costs of acceptance with regard to
standing in the community following acceptance. The power of the rural and farming vote is
also flagged as a reason why the dispute has dragged on for so long without decisive action
until the last two years.
The potential for conflict regarding the cessation of turf cutting on Irish peatlands is evident
from these studies. Valuation of peatlands by the general public as a cultural landscape based
on the social and economic benefit provided, economic dependence on the low cost fuel
provided and perceptions of meddling by outsiders into the affairs of rural communities are
emotive elements which have to be considered in relation to the management of peatlands.
These elements crop up throughout the dispute under examination here, as will be outlined in
the following chapter.

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CHAPTER 2 THE DISPUTE REGARDING DESIGNATED
RAISED BOGS – FACTS, PERCEPTIONS AND
CHARACTERISTICS
Introduction
This chapter outlines the key elements of the dispute over turf cutting on designated raised
bogs in light of the characteristics of rural resource systems and factors which generate
conflict described in the preceding chapter. Section 2.1 outlines the legislative imperative to
conserve active raised bog habitats under the Habitats Directive, as well as the impact of
continued turf cutting under the derogations. Section 2.2 outlines the key perspectives and
goals of the parties to the dispute, indicative of the range of goals which can impinge on how
a resource is used and planned for in a rural resource system. Section 2.3 outlines the structure
and progress of the Peatlands Council mediation process and details the impact that human
elements such as politics can play in exacerbating resource conflicts. The overarching
arguments of this chapter are summarised in Section 2.4.
2.1 Genesis Of The Turf Cutting Conflict
The conflict under examination here centres on the need for the Irish government to comply
with Council Directive 92/43/EEC (Habitats Directive), specifically with the designation of
active raised bogs and active blanket bogs as priority habitats. In February 1998, the then
Minister for Arts, Heritage, Gaeltacht and the Islands, Síle de Valera, declared that turf
cutting would be phased out over a period of 5-10 years on blanket bogs designated as Special
Areas of Conservation (SAC) under the Directive, while turf cutting would immediately be
banned on raised bogs with the same designation. However, following consultations with
representatives of farming and turf cutter organisations, it was announced that a derogation of
up to ten years would be introduced in respect of domestic turf cutting on the raised bogs
while an indefinite derogation was allowed for domestic cutting on the blanket bogs.
Industrial and commercial turf cutting was banned (Friends of the Irish Environment, 2011, p.
2). 31 raised bogs designated as SAC’s were granted a derogation from 1997-1999, with a
further 24 granted the same in 2002. These derogations were envisioned to end in 2009 and
2011 respectively. 75 raised bogs designated as Natural Heritage Area’s received a derogation

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scheduled from 2003-2013 (Irish Peatland Conservation Council, 2010). Appendices A-C
present a detailed breakdown of bogs affected by location and relevant derogation. A map
showing the affected bogs under the three derogations can be seen in Figure 2.1 (p. 18). The
efforts to dissuade turf cutting involved compensation packages, bog purchase and the
purchase of turbary rights under the voluntary ‘Cessation of Turf cutting Scheme’, introduced
from 1999. The 1999 Farm Agreement also stipulated that those who opted to continue
cutting must apply for a permit from the National Parks and Wildlife Service, with granting of
the permit dependent on a specification of proposed turf cutting methods until 2008 (Irish
Peatland Conservation Council, 2009).
The 2009 submission to the Interdepartmental Working Group by the Friends of the Irish
Environment provides further information on the precise terms of the derogations. Their
interpretation of the scant evidence on the derogations is that cutting for domestic use
incorporates both the cutters personal domestic use and cutting for sale to others to use in
their homes. In terms of permitting, the groups’ submission notes an exchange between
Damien English T.D and James O Connell of the NPWS in a Joint Committee for European
Scrutiny debate on 1 July 2008.
English asked ‘Must a person get permission from the Minister to cut turf,
notwithstanding the ten-year derogation? I understand people must get
permission and if the Minister does not reply, they have permission by
default’.
O’Connell replied ‘Permission is required to cut turf in a designated area.
However, in practice, where turf is being cut from existing banks, people are
allowed to do that without going through too many formalities. The difficulty
is where people wish to start cutting turf in designated areas or from new
banks. In such cases, permission must be sought and an assessment
undertaken’ (Jackson, 2009, p. 8).
The language and operation of the terms of the derogation were clearly open to interpretation.
2.1.1 The Impacts Of Continued Turf Cutting On Conservation Status Of Designated
Bogs
Monitoring of the conservation status, habitat extent and habitat quality of raised bogs in
Ireland since the introduction of the derogation and voluntary scheme would suggest that it
was an extremely ineffective tool in attempting to meet the requirements of the Habitats

17. Page | 17
Directive. Valverde et al. (2005) conducted a 10 year follow up study to a 1994/5 study in
2004/5. In the original study, 48 raised bogs were surveyed (representing 50% of the
remaining resource) to map habitats and quantify the impacts and activities affecting the
habitats. The follow-up survey was conducted to determine whether changes in habitat extent,
condition or the impacting activities had occurred. The overall aim of the follow-up study was
to determine the conservation status of raised bog habitats protected under the Habitats
Directive. To this end, 49 raised bogs occurring in 42 designated sites (2 NHA’s and 40
SACS) were surveyed (Valverde et al. 2005, p. 2) The results indicated that 25% of Active
Raised Bog (ARB) had disappeared in the ten year interval over 48 sites surveyed while
future prospects for ARB habitat were assessed as poor at 26 bogs and bad at a further 15.
This bleak outlook is largely based on the estimated impact of continued peat cutting in
lowering the water table and instigating fire damage (Valverde et al. 2005, p. 63).
The overall assessment for habitat area, structure and functions and future prospects was
designated as ‘unfavourable bad’ (Valverde et al., 2005, p. 64). Peat cutting was evident at 40
of the 49 bogs surveyed and it was noted that while a trend was evident in that there was a
reduction in the length cut, this was followed by an intensification in the amount of peat
extracted due to increased mechanisation. Turf cutting and the related activities of burning
and drainage are considered the elements most detrimental to ARB habitat (Valverde et al.,
2005, p. 64). The high rate of annual peat extraction at five raised bogs designated SAC led
the authors to believe that commercial peat cutting was on-going there, an opinion bolstered
by NPWS staff local to the areas in question. Hand cutting of peat was not a feature in any of
the raised bogs surveyed, with the Hopper being used throughout (Valverde et al., 2005, p.
48).
A more recent report by the Friends of the Irish Environment (2011) focused on randomly
visiting 33 of the 55 raised bog SAC’s to investigate levels of turf cutting activity. The sites
were visited from 12-20 May 2011 and consist of 19 of the 31 sites covered by the original
derogation and 14 of the 24 covered by the second. The report mainly consists of a
photographic survey of machinery harvesting turf on SAC designated raised bogs along with
a breakdown of current activity with regard to turf cutting on the 55 sites covered by the first
two derogations. It is shown that, in terms of evidence of cutting in 2011, extensive machine
cutting was recorded at 6 of the original 31 bogs and at 11 of the second 24 bogs (Friends of
the Irish Environment, 2011). Figures 2.2 and 2.3 (p. 19) indicate examples of the turf cutting
activity recorded during site visits. This report further notes that turf-cutting was taking place

18. Page | 18
on 117 out of 139 bogs designated under both EU and national legislation (Valverde et al.
2006 cited in Friends of the Irish Environment, 2011).
The conflict between the two resource uses, which use the same physical components of the
rural resource system in different ways, is evident here. The following sections detail the
events surrounding the ending of the first derogation, the consultative processes devised to
successfully implement the Habitats Directive and address the dispute, the elements which
shape the resource use goals of the respective parties in the dispute and the impact which
outside influences such as politics can have on resource disputes.
Figure 2.1: Map Showing Locations Of The Designated Raised Bogs Covered By The Three
Derogations (Source: Redmond, 2011, p. 42).

19. Page | 19
Figure 2.2: Spreading At Redwood Bog, County Tipperary, May 2011. Redwood Is Part Of The
Group Of 24 Raised Bogs Coming Under The Second Derogation (Source: Friends of the Irish
Environment. 2011).
Figure 2.3: Ballynafagh Bog, Co. Kildare Scorched From Burning. Bog Was Still Smoking
When Visited In May 2011. This Bog Is Part Of The First Group Of 31 Bogs To Receive The
Derogation (Source: Friends of the Irish Environment. 2011).

20. Page | 20
2.2 Perspectives Of Key Parties On Aspects Of The Dispute
As outlined in the previous section, turf cutting continued relatively unaffected by the
Directive until the end of first derogation, when those groups opposing and supporting the
decision began to publicly voice opposition to the actions of government to ensure
compliance with the Directive and end turf cutting in a manner agreeable to those who wished
to see it continue.
Then Minister for the Environment John Gormley announced in a statement in 2008 that it
‘would not be appropriate to extend the ten year derogation and turf cutting on the 32 raised
bogs designated prior to 1999 should therefore cease at the end of the current [2008] season as
scheduled’. However in March 2009, he announced that the government was ‘putting in place
a broad consultative process to prepare for the phasing out of domestic turf cutting on
designated raised bog Special Areas of Conservation and Natural Heritage Areas over the
coming years.....Cutting on all bogs during 2009 will be allowed to continue as before’
(Jackson, 2009, p.5). This consultative process took the form of a working group composed of
officials from Governmental Departments, Offices and Agencies, charged with drawing up
proposals on the administration of the cessation of turf cutting, restoration of bogs and the
practicalities of methods and costs of compensation, in consultation with relevant interests
(Department of the Environment, Community and Local Government, 2009). The group
consulted from May 2009 to May 2010 and was composed of representatives of the National
Parks and Wildlife Service; Department of Finance; Department of Agriculture Fisheries and
Food; Department of Community, Rural and Gaeltacht Affairs; Department of
Communications, Energy and Natural Resources, The Office of Public Works, The Attorney
General’s Office; and the Chief State Solicitor’s Office (Personal communication with Niall
Redmond, NPWS, Appendix H). Submissions were invited from any and all interested
parties with a closing date for receipt of July 17, 2009 (Byrne, 2009). Methods of engagement
with stakeholders are outlined in Section 4.2.1, while a full outline of the newspapers in
which calls for submissions to the Working Group were made in June 2009 is available in
Appendix H.
Submissions from a number of interested parties are enlightening in depicting the contrasting
opinions in relation to the issue of continued turf cutting

21. Page | 21
• The submission from the IPCC expressed disappointment that turf cutting had not ceased
on the 31 SAC designated bogs as scheduled in 2009 and called on the government to
rectify this before the 2010 season began. A range of proposals were also outlined in their
submission as to how the cessation of turf cutting might be successfully implemented and
monitored. Among these were proposals to aid the turf cutters transition to the use of other
fuel sources through grant-aid towards green energy projects and the establishment of a
system of arbitration to develop agreeable prices for the lifetime supply of turf to turbary
rights holders. Proposals for licencing of turf cutters were also included so that levels of
turf being could be effectively monitored. Site visits, flyovers and financial penalties were
also proposed to ensure compliance with the legislation. The incorporation of former turf
cutters into small scale restoration projects and the widespread dissemination of materials
related to the bogs affected and the impacts of continued turf cutting on raised bog
habitats were proposed as measures to maintain the traditional connection to the bogs and
ensure all stakeholders could be as informed as possible on the substantial facts and
arguments surrounding the dispute (Malone, 2009).
• The submission from the TCCA decried the lack of stakeholder involvement from the
very beginning of the process of designating bogs for inclusion as SAC’s under the terms
of the Habitats Directive. The submission noted that the bio-geographical seminars under
which sites were designated were conducted almost without their knowledge. The
submission cites the location of many of the designated sites in economically deprived
areas and cites the hardship and expense involved in converting to other forms of home
heating. The compensation offered to turf cutters is decried as derisory based on their own
valuations of potential turf by volume in plots in comparison with coal prices. The
submission refutes the involvement of the group’s members with activities which have
been shown to be detrimental to habitat status and extent, such as starting fires and
drainage. The submission posits the argument that the government has surrendered
responsibility for policy in regard to the implementation of the Directive to agencies and
bodies such as An Taisce and the IPCC. The submission also takes issue with the
Favourable Reference Ranges used by the NPWS in assessing the conservation status of
designated bogs, noting that potential rather than actual ranges were used, thus distorting
assessments (Turf Cutters and Contractors Association, 2009).
• The submission from the Friends of the Irish Environment was quite unequivocal, stating
that the derogations were unlawful under EU and Irish law and that if they were not

22. Page | 22
withdrawn they would bring judicial review proceedings against the government. In an
examination of the terms of the derogation, and noting the scant evidence on them
generally, the submission notes that cutting was allowed both for domestic use and for
sale for domestic use by others, an important point. The group sought clarification from
the Working Group on the monitoring of cutting on designated sites to ensure compliance
with the derogations and sought for the Working Group to outline its understanding of
when the derogations granted in 2002 and 2004 would actually expire. An outline of the
illegality of the derogations under Article 6 (2) - (4) of the Habitats Directive is provided.
The submission is also against relocation to nearby undesignated sites as this would not
address the environmental problems posed by continued turf cutting (Jackson, 2009).
The presentations made by representatives of Creggan/Crosswood Turbary Group, the TCCA
and the IFA to the Joint Committee on the Environment, Heritage and Local Government in
November, 2009 also highlight the perspectives of the turf cutting lobby on the issue.
Councillor Frankie Keena of the Creggan/Crosswood Turbary Group asked ‘How can people
be compensated for the loss of these traditions?’ and then answered ‘They cannot be and they
do not want to be’. The desire to continue turf cutting is posited as a desire to maintain
aspects of traditional culture. Mr Michael Silke of the IFA noted the financial hardships which
the cessation of turf cutting would impose on rural families and questioned the scientific
evidence used to portray domestic turf cutting as damaging to peatlands. Mr Michael
Fitzmaurice of the TCCA also questioned the scientific evidence used to depict domestic turf
cutting as highly detrimental to raised bog habitats, while Sile O’Connor of the same
organisation questioned the methods used to designate bogs as SAC’s, particularly in regard
to the units of measurement used by the NPWS to calculate area and range of ARB habitat. A
range of elected representatives, mainly from constituencies in which the designated peatlands
are located, pledged support for the turf cutting lobby. These pledges contained a number of
recurring themes, such as calls for discussion involving all parties before the prohibition on
turf cutting is finalised, the heavy-handedness of the NPWS throughout the dispute and the
economic and cultural importance of turf cutting (Prohibition on Turf Cutting: Discussion…,
2009).
Some of the main goals of the parties to the dispute are evident here. Those groups who value
peatlands for their natural heritage significance wish to see the stipulations of the Habitats
Directive complied with. The turf cutting lobby, who value the peatland resource due to its

23. Page | 23
associated social, cultural and economic importance, wish to see the continuation of
traditional land usage patterns.
The upshot of this consultative process was that Minister Gormley announced on May 28,
2010 that turf cutting would immediately cease on the 31 bogs covered by the first derogation,
and that any further turf cutting or drainage could not be allowed without the written consent
of the Minister. Interim funding to address immediate fuel needs of those affected was also
included (Gormley, 2010). Reaction to this decision and, more importantly from the
perspective of this work, the method by which it was disseminated, was extremely negative
from the turf cutting lobby group, with the Chairman of the Turf Cutters and Contractors
Association (TCCA), Michael Fitzmaurice, noting that he had learned of the decision from a
local radio station in Roscommon. He noted that despite partaking in the consultative process
over the preceding year, ‘they couldn’t even be bothered contacting us, but given the
arrogance they have shown to date, we are not surprised’. He further noted that he had
received phone calls from affected parties all over the West of Ireland vowing that they would
continue to cut turf on the designated bogs regardless of this announcement (Scott, 2010).
2.3 Politicisation Of The Dispute
From this point on the dispute becomes extremely heated, with turf cutters desperate to
maintain their traditional rights amid fears of fuel poverty and the circulation of
misinformation. A General Election in February 2011 ensured that this issue became a
political hot potato. A speech given by Luke ‘Ming’ Flanagan at a TCCA rally in January
2011 effectively acted as a call to arms to turf cutters to continue cutting as normal on the
designated bogs and reflected the anger within that organisation at the manner in which they
had learnt of the decision taken by Minister Gormley in May 2010 (Flanagan, 2011). A
newspaper report about a presentation given by Pat Warner, divisional manager with the
NPWS, to the Environmental and Agricultural Strategic Policy Committee of Mayo County
Council in September 2010 on the restrictions being enforced as of 2010 on the 31 SAC bogs
is enlightening in depicting the confusion which existed. When Mr. Warner clarified that only
three bogs in Mayo were actually immediately affected, one of the councillors reacted with
surprise, claiming that he had been under the impression that a blanket ban on turf cutting was
being imposed on the county (Connaught Telegraph, 2010).

24. Page | 24
Two important developments occurred in April 2011. Firstly, on April 7th
, the government
announced that it was establishing an independent Peatlands Council. The lessons of the
previous consultative campaign seem to have registered, with Minister for the Environment
Phil Hogan noting the importance of incorporating the views of turf cutters and land-owners
more fully into decision making as the ‘lack of clear direction has not served turf cutters or
conservation interests well, and has led the European Commission to commence infringement
proceedings against Ireland on this issue’. The press release announcing the new body was
laden with terminology outlining how inclusive of all needs and issues it would be,
proclaiming that the body would bring together ‘turf cutting and conservation representatives
with the relevant State officials to ensure that all interests are fully considered’ and that ‘the
genuine needs of these people [those who had cut on designated bogs] must be addressed in a
comprehensive manner’ (Department of the Environment, Community and Local Government
(b), 2011). Perhaps as a clarification for all stakeholders prior to commencement of the work
of the Peatlands Council, Minister for Arts, Heritage and the Gaeltacht Jimmy Deenihan
announced on April 12th
that the restrictions on turf-cutting under the first and second
derogations still stood, would not be revisited and that the ending of cutting on the 24 bogs
would proceed as planned after the end of the 2011 season (O’Brien, 2011).
As of June 1, 2011 all members of the Peatlands Council have agreed to the following:
1) We are committed to fully and finally resolving legal and land use issues to ensure full
compliance with the objectives of the Habitats Directive in relation to Irish Raised Bogs
2) We will work to urgently facilitate all necessary alternatives for qualifying turf-cutters.
We will also work to facilitate alternatives as a matter of priority and intensive
consultation will take place on the individual sites to identify solutions involving:
• Agreed alternatives including relocation and compensation.
• Establishing the viability of arrangements to provide fuel for the transitional phase
between the identification of and sign-up to an agreed solution and its implementation
in each bog.

25. Page | 25
• An agreed strategy for the restoration and management of designated raised bogs to be
put in place as quickly as possible providing for the full consultation and agreement of
local communities in management & restoration works.
• A small number of sites will pose exceptional issues. In these circumstances, where all
alternatives have been explored and no solutions are apparent, the feasibility of
facilitating managed co-existence of designated areas and small scale domestic turf
cutting will be explored in full consultation with the European Commission.
In order to achieve its objectives the Council also requested a commitment from the
government that sufficient financial resources would be provided, that a review of NHA
designated bogs be prioritised and that all parties continue to work within the council to build
trust and avoid delaying or destabilising the process.
Source: (The Peatlands Council, 2011)
An important point to note here is the potential for continued turf cutting, albeit in exceptional
circumstances, on the SAC designated bogs and the potential for review of the boundaries of
the NHA designated bogs coming under the third derogation.
The formation of the Council reflected government efforts to resolve the issue quickly in light
of warnings from the European Commission that accelerated action may be taken against
Ireland if it does not meet its obligations under the Directive by the end of this year. The
action was threatened if cutting was not completely stopped on all 55 SAC bogs by the end of
this year (2011). This type of action would result in fines imposed on a daily basis until full
compliance is achieved (McGee, 2011).
The second important development at this time was the announcement of a compensation
package on April 13th
. This package applied to active turf cutters on the 31 SAC bogs on
which cutting was banned from 2010 and to cutters on the 24 bogs where cutting would cease
with the end of the second derogation in 2011. The package awarded annuity payments for a
15 year period or facilitation in relocation to non-designated sites (MerrionStreet.ie, 2011).
The compensation scheme was met with some criticism in those areas most affected by the
ban on turf cutting on SAC designated sites, with the thrust of Mayo County Councillor
Michael Holmes argument being that the turf cutters were seeking to maintain the legacy and

26. Page | 26
tradition of turf cutting for future generations and that people were increasingly reliant on the
cheap fuel source during the harsh economic period (Quinn, 2011). Roscommon-South
Leitrim TD and TCCA PRO Luke ‘Ming’ Flanagan similarly asserted that the right to cut turf
was the focus of his groups work, not compensation (Shannonside, 2011).
On June 2, 2011 it was announced that agreement had been reached between the members of
the Peatlands Council that no further turf would be cut on the 31 SAC designated raised bogs
of the first derogation as of 2pm on June 3rd
, 2011. Turf that had already been cut could be
removed however, and Luke ‘Ming’ Flanagan asserted that alternative bogs must be found or
a number of the SAC designated bogs would have to be re-designated before the members of
the TCCA could commit to the agreement in the long-term (RTE News Ireland, 2011).
2.3.1 Aftermath Of The Agreement
This agreement represents a truce and an opportunity to increase efforts to find a long-term
solution amenable to all parties. The threat of large fines accruing to the country were not
abated by the deal, with a senior source in the European Commission questioning the
sustainability of an approach which did not attach any consequences to continued illegal turf
cutting. The official noted that the Commission was wary of future developments based on
the comments of TCCA PRO spokesman Luke ‘Ming’ Flanagan, outlined above (Cullen,
2011). On-going issues in relation to compensation measures also threatened the viability of
the ‘truce’. In July, Connaught Vice-President of the Irish Farmers Association criticised the
1000 annuity payments as being too low to allow transition from peat based home heating
methods and noted that turf cutters were being left in a precarious position due to delays in
finding alternative sites for those displaced turf cutters from the 55 SAC designated bogs
(Roscommon Herald, 2011).
Promises made to the turf cutting lobby during the 2011 General Election campaign were also
posing problems due to the expectations they generated as regards potential outcomes of the
mediation process. The thrust of one Roscommon County Councillor’s arguments regarding
Fine Gael electoral promises and the on-going dispute is enlightening in this regard. Paddy
Kilduff notes that the three men elected to represent the Roscommon/South Leitrim
constituency in the 2011 election claimed during their campaigns that they would reverse the
decision to prohibit turf-cutting on the designated SAC bogs. He goes on to explain that the
terms of the compensation packages outlined in April 2011 were largely welcomed by the

27. Page | 27
three representatives, yet represent no significant change from earlier compensation packages.
He further outlines how turf cutting had always been allowed under the previous government,
yet the bans were being enforced under the present government despite electoral promises
made by the two elected representatives of Fine Gael, then in opposition and now in power
(Roscommon People, 2011). In July 2011 it was reported that turf cutters felt they were being
forced to take financial packages where no alternative bogs could be found to facilitate
relocation, prompting angry and disappointed calls to the chairman of the Peatlands Council
and increasing fears that the agreement would not hold and represented a stop-gap measure
(Hough, 2011).
2.4 Turf Cutting Dispute in the Context of Rural Resource Systems and
Conflict
This dispute represents a case of competition between resource uses in a rural resource
system. The goals shaping the Habitats Directive, based on the principles of sustainability and
implemented by the legislative authorities, are based on a different valuation of the peatland
resource to that of the turf cutting lobby. The view of rural resource systems as comprised of a
mosaic of interacting resource use patterns, where human elements form an intrinsic
component, is demonstrated explicitly here. Those arguing from a conservationist standpoint
have legislative right on their side while the turf cutting lobby see their valuation of the
resource based on its social, cultural and economic importance as superior. Interaction
between human and natural elements of the resource system is clear in the factors which have
complicated the dispute further, such as the use of legitimate grievances of turf cutters to
build political capital, fears of fuel poverty in the midst of an economic crisis and public
misconceptions about the scale, extent and consequences of continued turf cutting.
The conflict here ultimately arises out of the drive to ensure moral considerations are
incorporated equally into decision making structures and policy regarding environmental
resource management, based on the principles of sustainability. While this is admirable, the
preceding sections have highlighted the problems of implementing conservation strategy
which impacts on a resource system composed of natural and human elements form a top-
down perspective through legislation. In order to marry the competing valuations of
environmental resources in management policy which adheres to the principles of
sustainability, an approach to policy formulation and decision making is required that

28. Page | 28
incorporates the range of perspectives on resources. Participatory processes involving the
range of interested and affected stakeholders represent one of the most important methods to
achieve this and avoid or mitigate conflicts such as described here. The great utility and
necessity of incorporating participatory processes into environmental decision making
structures is explored in the following chapter

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CHAPTER 3: PARTICIPATORY PROCESSES: BENEFITS,
KEY ELEMENTS AND PRACTICALITIES
Introduction
Participation can be defined as a ‘process where individuals, groups and organisations choose
to take an active role in making decisions that affect them’ (Reed, 2008, p. 2418). It will be
shown in this chapter that the extent of that role, the impact of different perspectives and
inputs on decisions and the robustness of decisions produced depends largely on the reasons
that a participatory process is used in a particular context and the methods through which it is
conducted. Firstly a brief outline of the history of the incorporation of participatory processes
into environmental decision-making structures globally and the range of benefits which are
posited to result from their use is given. Section 3.2 outlines key elements, mainly related to
perceptions of empowerment and fairness of participatory processes, necessary to the
production of robust outcomes. Section 3.3 builds on these elements, outlining practical
methods through which the elements can be incorporated into participatory processes and
leading to an outline of best practice guidelines which should underpin the conduct of
meaningful processes.
3.1 Legislative Context and Benefits for Environmental Decision Making
of Participation
Ewing (2003, pp. 15-24) provides a comprehensive account of the key international
legislative and policy documents which have led to the widespread uptake of participatory
processes into environmental decision making structures since the 1950’s. Arising out of the
participation movement of the 1960’s and 1970’s, the provisions included in the National
Environmental Policy Act (NEPA) and the 1966 Freedom of Information Act, along with the
earlier Administrative Procedures Act (1946) are cited as the foundation for public
involvement in environmental protection in the USA. The growth of recognition of the need
for sustainable development at a global scale grew from the United Nations Conference on the
Human Environment held in Stockholm in 1972 and gained widespread recognition following
the 1983 World Commission on Environment and Development, commonly known as the
Brundtland Commission. The important points related to sustainability have been summarised
elsewhere in this work, but one line from the report of the Commission is of note in the

30. Page | 30
context of participatory processes. In the concluding statement it was noted that ‘existing
decision making structures could not cope with the demands of sustainable development’
(WCED, 1987, cited in Ewing, 2003, p. 16). The need for participation was further
emphasised following Agenda 21 and the Rio Declaration. Chapter 8, section 1 of Agenda 21
advises governments to incorporate public participation into policy and decision making in
relation to the environment (Ewing, 2003, p. 17). Principle 10 of the Rio Declaration is more
explicit:
Environmental issues are best handled with the participation of all concerned
citizens, at the relevant level. At the national level, each individual shall have
appropriate access to information concerning the environment that is held by
public authorities […] and the opportunity to participate in decision-making
processes. States shall facilitate and encourage public awareness and
participation by making information widely available’ (Mitchell, 1997, p. 45).
A massive step forward in ensuring public participation was actually facilitated, rather than
aspired to, in decision-making was made through the ratification of the Aarhus Convention in
2001, of which one of the three central pillars related directly to public participation in
environmental decision making. Articles 6,7 and 8 of the Convention stipulated early
involvement of the public in decision making on specific projects likely to impact on the
environment and in the development of plans, programmes, policies, laws and regulations
related to the environment (Ewing, 2003, p. 18). An important piece of European legislation
which stemmed directly from Aarhus in relation to participation was Directive 2003/35/EC of
the European Parliament, in which the connection between the two is explicitly outlined in
Article 1. Here it is stated that ‘the objective of this Directive is to contribute to the
implementation of the obligations arising under the Arhus Convention’ (Directive
2003/35/EC). Article 2 of the Directive outlined general guidelines for how the public must
be involved in decision making processes, particularly that early and effective opportunity be
facilitated for participation and that the results of this participation be considered in the
resultant decision. Amendments to Directives such as 85/337/EEC and 96/61 EC were also
outlined to facilitate greater participation in the spirit of Aarhus (Directive 2003/35/EC). The
growth of international recognition of the need for participatory processes in light of the
potential impacts and complex nature of environmental problems is clear. Reed (2008, p.
2418) notes that disillusionment with the failings and limitations of participatory processes
followed their increased usage throughout the 1990’s due to the drive for sustainable
development. However he posits that the last decade has seen the emergence of a ‘post-
participation’ consensus on best practice based on learning from past mistakes, the results of
which will be examined in a further section reviewing literature on key elements of

31. Page | 31
participatory processes needed to ensure their success. From this a synthesised outline of best
practice can be extrapolated.
A range of claims have been advanced for the incorporation of participatory processes into
environmental resource management decision-making structures. Reed (2008, p.2420)
categorises these into normative and pragmatic claims. The normative claims emphasise the
benefits of such processes in promoting active citizenship and greater equity in decision
making. Among the arguments for such benefits are claims that environmental decisions may
be perceived as being fair and incorporative of the range of values and needs towards a
particular environmental resource where stakeholders can influence the decision (Richards et
al. 2004 cited in Reed, 2008, p. 2420). Benefits for social cohesiveness and learning are also
cited as positive outcomes of the inclusion of participatory processes. Martin and Sherington
(1997, cited in Reed, 2008, p. 2420) argue that the inclusion of those who would be on the
periphery of the decision making context promotes active citizenship by showing the benefits
of engagement with decision making apparatus. Pragmatic claims emphasise the benefits of
participatory processes in generating more durable environmental decisions. Dougill et al.
(2006, cited in Reed, 2008, p. 2420) argue that the design of plans and strategies targeting a
particular resource can be informed through participation, increasing the chance that local
needs are met and reducing long term opposition. Similarly, it is argued that negative
outcomes can be anticipated beforehand and plans adjusted accordingly through the
incorporation of the range of perspectives in the decision-making process (Fischer, 2000;
Beierle, 2002; cited in Reed, 2008, p. 2420). Richards et al (2004 cited in Reed, 2008, p.
2420) argue that the sense of ownership over decisions engendered by participation, provided
trust is established between stakeholders, induces support for and eases the implementation of
those decisions. Richards et al. (2007, p. 3,7) argue that decision-making with regard to
environmental problems must be flexible to react to changing circumstances and able to
embrace diverse perspectives in light of environmental problems which are complex, can
extend over large temporal and spatial scales and are often characterised by uncertainty and
irreversibility. Thus, they note, the use of participatory processes can help to increase
understanding of the interlinked nature of environmental problems with socio-economic
factors and can help to ease implementation of policy due to the incorporation of a range of
views in its formulation. Ewing (2003, p. 8) similarly argues that the incorporation of a wide
range of perspectives on environmental problems generates better informed decisions, which
ultimately increases the viability of projects based on the decision.

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3.2 Components Of Participatory Processes Needed To Produce Viable
Outcomes
A range of studies on the incorporation of participatory processes into decision-making
structures have been conducted which point to the key elements of the process in terms of
producing robust decisions. The positive and negative aspects of the process, sometimes
based on the perceptions of participants, can help to formulate best practice in the area
The overarching elements of stakeholder participatory processes which contribute to the
production of robust outcomes have been discussed by Moore et al. (2001) and Reed (2008).
Reed (2008) conducted a literature review using Grounded Theory Analysis and identified
eight features of best practice participation. The results indicated that participatory processes
generally must engage parties in a long-term context where they develop trust and respect and
must consider how to engage relevant stakeholders at appropriate times and in a manner
which allows them to fairly and effectively shape the resultant decisions. He goes on to say
that one of the key features of any process which can ensure it is conducted in this manner is
an underpinning philosophy which emphasises empowerment, equity, trust and learning
(Reed, 2008, p. 2422).
Equity and empowerment are also cited as being vital by Moore et al. (2001). Here, data
chronicling the activities of three Australian consultative/advisory groups was analysed using
grounded theory and pattern matched to reveal trends. The three groups chosen were quite
diverse, being involved in management planning for the Fitzgerald River National Park,
management of agriculture in Gabby Quoi Quoi and in planning for the Beenup mineral sand
mining operation. All groups were heterogeneous mixes of locals and outside parties bringing
a range of perspectives. Data was analysed to reveal patterns in elements cited by the
stakeholders as being vital to ensure their commitment to the process. The perception of
fairness in the process, in a number of guises, was routinely cited as being vital to
engendering commitment. This took the form of the belief that all interests were represented,
that all participants were making equal contributions in terms of time and money and that all
views were being heard and incorporated into the process (Moore et al. 2001, pp. 93-94). The
importance of emphasising empowerment in the process is also outlined in Moore et al.
(2001). A sense of power in the process, that it is the place to be to achieve one’s aims, was
cited as vital to ensuring initial and on-going participation. In the case of the Fitzgerald River

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National Park Group, people judged that their chances of ensuring their perspectives were
heard were higher inside rather than outside the process. In the Gabby Quoi Quoi group, the
chairing of efficient meetings has bred a sense of achievement and progress and led to the
development of a long-term shared vision among participants and a sense of confidence in
achieving aims (Moore et al. 2001, p. 94).
Reed (2008, p. 2422) notes some of the manifestations of empowerment in participatory
processes, namely that participants feel they can influence the decision and that they have the
technical capacity to engage with the decision. Education of participants where scientific or
technical knowledge is involved is vital to promote both empowerment and equity. In terms
of the promotion of equity it is noted that inequalities between participants, be it age gender or
educational background, must be overcome to allow participation on an equal footing. Chase
et al. (2004) prioritised evaluation criteria derived from theory, as to what constitutes a ‘good’
participatory process, with participants from two case studies. Several criteria were perceived
as being vital to the success of the participatory process particularly that participants felt they
could influence decisions, that all participants were treated equally, that the best scientific
evidence was incorporated and that communication and learning were promoted. Chess and
Purcell (1999) examined the extent to which outcome goals were achieved through different
participatory methods. They found that the success in meeting goals was not influenced to any
great extent by the particular type of participatory method, be it public meetings, workshops
etc., but rather by the way the discussion and group interaction within the particular method
was handled by the facilitator. Different success rates among the various case studies hinged
on aspects such as the facilitators handling of dominant individuals, attitude towards
participants and setting of clear goals. Mitchell (1997, p. 157) outlines some of the key
elements of partnerships which are necessary for successful participation and the production
of robust decisions. Among these were that respect and trust must be built between
stakeholders, mutual benefits of participation must be identified, equitable representation and
power for all participants must be assured, strong communication mechanisms are vital and
the process must be adaptable in light of complex and changing circumstances encountered in
resource management problems and decision making.
The results of the ‘Practical Approaches to Participation’ workshop, held at the Macaulay
Institute, Aberdeen in 2003 and facilitating a critical dialogue on the use of participatory
approaches in environmental decision making between policy makers, practitioners and
experienced participants, are enlightening in depicting some of the key elements related to the

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success of such processes. Here it is acknowledged that participatory processes may not be
appropriate in every decision making context and should be used selectively to avoid
consultation fatigue. Citing Cooke and Kothari’s (2001, cited in Richards et al. 2007, p. 16)
concept of the ‘tyranny of participation’, it is noted that participatory approaches may be used
to validate decisions that have already been made by providing a sheen of democracy over
them. If participatory processes are not used judicially, are not well run or participants do not
perceive any impact on the resultant decision from their involvement consultation fatigue
results (Richards et al. 2007, p. 16). This points to the importance of ensuring participants feel
they can contribute equally and that their contributions are being taken into consideration
throughout the process. Richards et al. (2007, p. 22) further outline a range of factors which
may lead to the failure of processes including that one stakeholder or group dominates, the
process lacks clear purpose or has unrealistic goals, there are imbalances in power and/or
control and that the perceived costs of participation outweigh the benefits accrued. The
International Association for Public Participation has produced a code of ethics for public
participation, which act as a set of principles to guide the actions of practitioners in the field.
Among the principles which must underpin any meaningful participatory process are that
practitioners and facilitators must undertake and encourage actions which build trust and
credibility among all participants, that they must encourage the disclosure of all information
relevant to the public’s understanding and evaluation of a decision, that they must ensure all
stakeholders have equal and fair access to the process and the opportunity to influence
decisions and that strategies which risk the polarization of interests must be avoided
(International Association for Public Participation).
A visual depiction of these key elements is given in Figure 3.1 (p. 37), while evidence from a
study conducted by Webber et al. (2007) highlights the need to engage stakeholders in
participatory processes in a long term context where they are empowered to influence the
decisions and policies emerging from the process.
3.2.1 Case Study Evidence of the Importance of Empowerment and Fairness
The importance of identifying, engaging and financially supporting key stakeholders in a
long-term process which emphasises the elements of empowerment and fairness described in
the preceding section to the success of conflict resolution in a resource management context
through participatory processes is evident in a case study from the Budongo Forest Reserve in
Uganda (Webber et al., 2007). The reserve is on the northern edge of the Albertine Rift,

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Masindi District, Uganda, comprises 435km2
and is home to six species of primate, including
one of the four remaining viable populations of chimpanzee in Uganda. It comprises the
largest mahogany forest in East Africa. Population rise resulted in the clearance of forest
fragments for agricultural purposes, with 16% of forest cover being lost between 1986 and
2001. Closure of local sawmills has left many former workers dependent on subsistence
farming. Crop raiding by primates posed problems in the villages south of the Reserve.
Baboons attracted much of the local contempt for this but the inadvertent maiming of
chimpanzees through indiscriminate crop protection methods drove efforts to both reduce
crop raids and protect chimpanzees from 2000/2001.
A live trap method was devised by the District Wildlife Management Officer comprising a
cage in which bait is placed. Captives can be killed or released depending on classification.
The Budongo Forest Project began to support the programme from 2001, with a pilot project
beginning in seven villages from 2002. Two awareness meetings were held per village and a
Vermin Control Committee selected from amongst the inhabitants. The committee was
charged with siting, maintaining and monitoring the traps in conjunction with local farmers.
The use of indiscriminate control methods such as snares was prohibited (Webber et al., 2007,
p. 178). Assessment of the project after traps had been operational for one year found that
local communities were satisfied with the traps and accepted responsibility for their
maintenance. It was shown that only a small number of those living close to the traps were
involved with the project however and the authors found problems with the methods used in
these assessments. The assessment also highlighted the fact that a number of units were not
operating as planned or had not been maintained (Webber et al., 2007, p. 179).
Webber et al., (2007) conducted a 13-month study from 2004 exploring perceptions of crop
raiding and the project through semi-structured interviews with 129 farming families in four
villages containing or sited within 1km of a trap. Approximately 70% of farmers were
interviewed per village, with 86% experiencing at least one raid during the study and 70%
entirely economically dependent on agriculture. In terms of ownership and responsibility for
traps, 44% did not know who had responsibility and only 11% recognised that the community
held both ownership and responsibility, despite the earlier assessments of the project. It was
stated by a number of farmers that they had requested assistance with repairs through local
council members but had received no help. In terms of trap locations, the majority of
respondents attributed location to outside or higher authority, rather than in a position selected
by the committee appointed at the initial awareness meetings (Webber et al., 2007, p. 180).

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Webber et al. (2007) extrapolate a number of reasons for the failure of the project based on
the study. Foremost amongst these were the fact that important local stakeholders were either
not involved in formulation or not made fully aware of obligations in design and
implementation of the project. The lack of awareness of maintenance arrangements elucidated
by the study demonstrates a failing to adequately engage important stakeholders with the
process from the outset, negatively affecting the long-term sustainability of the project. A lack
of proper initial stakeholder analysis and planning is demonstrated by the fact that those living
closest to the traps, and therefore with greater incentive to engage with the project, were not
involved with the formulation and implementation of the project at all. Responses regarding
the siting of the traps among those involved with the project reveal further disengagement and
feelings of disempowerment among key stakeholders, who perceived a lack of control and
resultant inability of the project to meet their needs regarding the crop-raiding problem. A
perception of declining benefit among those involved in the project was also key to failure,
with the perception of a benefit in the long run being vital to engendering commitment to the
outcomes of decision making through participatory processes (Webber et al., 2007, p. 183).
While availability of baboon meat had initially acted as an incentive to maintain traps,
familiarization induced avoidance of the traps and this benefit fell in value in relation to the
costs of maintenance (Webber et al., 2007, p. 182). Finally, the cessation of funding to the
project from 2002 negatively affected the sustainability of the project in the long-term as
training and maintenance could not be conducted. Participatory projects need to take a long-
term viewpoint and must be supported until they become self-sustaining (Webber et al., 2007,
p. 182). Webber et al. (2007, p. 183) note that such failures of conflict mitigation through
participatory processes should be highlighted and analysed for their contribution to a
knowledge base on such processes, as this will aid the development of more sustainable
resource conflict mitigation strategies.
The following section outlines some of the practical methods which can be used to ensure
these key elements are incorporated into participatory processes, leading to an outline of
general best practice guidelines.

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Figure 3.1: Key Elements Which Contribute to the Production of Robust Decisions From
Participatory Processes
3.3 Practicalities Of Incorporating Key Elements Into Participatory
Processes
Issues of fairness and empowerment are intrinsically interlinked in participatory processes.
The role of the facilitator is vital to the promotion of fairness in the actual discussions
undertaken and to the promotion of empowerment through the selection of methods of
engagement, stakeholder analysis and problem definition which equalise power inequalities
and ensure participants perceive they can influence the workings of the process from the
outset.

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In terms of the promotion of fairness and following Moore (2001, p. 93), perceptions among
participants that their interests are being represented and incorporated and that all participants
are making equal contributions in terms of time and money is vital to engendering
commitment to the process. These perceptions must extend from the initial engagement with
the process and thus the role of the facilitator is vital to the promotion of fairness. Reed (2008,
p. 2425) notes that the facilitator must be impartial and open to multiple perspectives. They
must ensure positive group dynamics by controlling those participants who would seek to
dominate, must encourage participants to re-examine their positions on matters to stimulate
debate and ensure progress and must seek to encourage those reluctant to co-operate.
The facilitator must also seek to incorporate as much knowledge as necessary to enable
informed decisions to be made in the different stages of the process. Reed (2008, p. 2422)
notes that technical or scientific knowledge which is relevant to a decision must be introduced
to the process in a form which is accessible to all participants to enable equitable engagement
with that information. To enable learning between participants with different knowledges, a
combination of scientific and local knowledge must be used throughout the process. Reed
(2008, p. 2426) outlines the debate on the combination of these two types of knowledge.
Scientific knowledge is understood to be systematised and widely transferable – ‘know-why’
knowledge, while local knowledge is depicted as ‘know-how’, which is informal, context
dependent and based on collective experience through generations. Stringer and Reed (2007,
cited in Reed, 2008, p. 2425) argue that the combination of the two types of knowledge can
promote stronger interaction between different stakeholders with different backgrounds and
perspectives, and thus generate more relevant policy. Decisions based on the more complete
knowledge are likely to be more robust due to the more rigorous understanding of the issues
generated (Hansen, 1994; Stringer and Reed, 2007; cited in Reed, 2008, p. 2425). Some have
suggested that local knowledges may be exaggerated or distorted (Molnar et al., 1992 cited in
Reed, 2008) and that the integration of the two will involve a compromise between
meaningful participation and scientific rigour in processes (Abbot and Guijt, 1997, cited in
Reed, 2008, p. 2426). However, no trade-off between the two types was found in a study by
Reed et al., (2008, cited in Reed, 2008, p. 2426), where a great overlap was found between
indicators of land degradation in the Kalahari outlined from both a scientific and local
knowledge perspective. Ingram (2008, cited in Reed, 2008, p. 2426) argues that the overlap
may be due to the constant assimilation of scientific techniques and knowledge into land
management practice. At any rate the utility of the combination of both types of knowledge is
increasingly being acknowledged, with Phillipson and Liddon (2007, p. 2426, cited in Reed,

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2008, p. 2426) outlining the moves towards joint production of knowledge, involving
researchers, practitioners and the public, in the context of knowledge transfer from producers
to users. In terms of participatory processes, the incorporation of all views and perspectives,
in the form of local and scientific knowledge, is vital to the cultivation of a perception of
fairness in the process, which in turn is vital to partnership building and the production of
robust outcomes. To empower participants to participate equally, knowledge must be
presented in a format which all can access. It is the role of the facilitator to ensure this takes
place.
A perception of power to influence decisions is vital to ensuring continued, meaningful
participation in these processes. One component of this is the engagement of relevant
stakeholders as early as possible in the process. Reed (2008, p. 2423) notes that stakeholders
must be involved in consultations from the concept development stage if possible so that they
will be motivated to engage with the process. Early involvement ensures that the needs and
priorities of the different stakeholders can be incorporated into the design of the process, thus
encouraging them to take ownership and not be put in a position where they feel proposals
have already been finalised. Ewing (2003, p. 9) notes that early involvement will give added
time to study issues and develop credibility in the process by the incorporation of the range of
perspectives into process design. In the long term this will avoid delays in appraisal and
implementation of policies produced. Thus, wide consultation in the stakeholder analysis and
problem definition parts of the process is vital to engendering commitment and sense of
ownership of the process and outcomes. Reed et al. (2009) outline the different methods
which can be used in stakeholder analysis, more specifically in defining the aspects of a
system likely to be affected by a decision, identifying those individuals or groups who are
affected by or can affect the parts of the system and prioritising them for involvement in the
process. The limitations and challenges posed by the different methods are also outlined,
based on evidence from case studies. Reed (2008) acknowledges that it is possible to conduct
this part of the process without stakeholder involvement where sufficient documentary
evidence exists. Levels of participation can also vary, from passive consultation where
stakeholders provide information in a one way flow of information to the facilitator to active
engagement where a two way dialogue is conducted between stakeholders and facilitators.
Whichever level is used, stakeholders are usually identified as the bounds of the system
affected are outlined and added to the analysis through an iterative process, using methods
such as expert opinion, focus groups or snowballing (Reed, 2008, p. 2424).

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The importance of early involvement with the definition of the problems to be addressed by
the process is also vital, with Reed (2008, p. 2424) noting that the diversity of opinions and
perspectives must be outlined through dialogue so that participants take ownership of the
process, partnership building begins and the outcomes will be relevant to stakeholder needs
and priorities. Once stakeholders are selected and objectives have been defined, the methods
of engagement for the process proper can be selected. While different levels of participation
and methods are appropriate to different typological participatory processes, the methods
selected must be tailored to equalise power dynamics in the group as a whole to ensure all
participants can contribute equally (Reed, 2008, p. 2424).
The practicalities of incorporating the elements which generate perceptions of fairness and
empowerment are summarised in Figure 3.2 below, which can act as a set of practical best
practice guidelines in conducting or assessing participatory processes. The role of the
facilitator is overarching as he will essentially dictate how all the other parts of the process are
conducted. These guidelines, and the elements on which they are based, have been used to
formulate both interview questions and questions with which to interrogate the extant,
available literature on the dispute under examination in this work, as described previously
(Research Design and Methodology section). The following chapter presents the results of
this research.
Figure 3.2: Practical Best Practice Guidelines Regarding the Conduct of Empowering, Equitable
Participatory Processes

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CHAPTER 4: RESULTS AND DISCUSSION: TYPOLOGIES
AND STAKEHOLDER ASSESSMENT OF PARTICIPATORY
PROCESSES
Introduction
This chapter presents and discusses the results of research conducted into stakeholder
perceptions of the Interdepartmental Working Group on the Cessation of Turf Cutting, based
on best practice guidelines outlined in the previous chapter and the methods detailed in the
Research Design and Methodology Section. The general structure and methods employed to
engage and consult stakeholders in this process has been outlined in Chapter 2, Section 2.2. A
review of typologies of participatory processes is also presented and used to classify both of
the participatory processes used in this dispute.
4.1 Stakeholder Perceptions of the Interdepartmental Working Group
Process
Representatives of turf cutting interests had negative perceptions of this process, based on
issues of fairness and empowerment. Excerpts from a speech by PRO of the TCCA, Luke
‘Ming’ Flanagan in January 2011 at a TCCA rally bear this out. Mr Flanagan noted that the
group had ‘engaged in all processes of consultation that have been put before us’. He pointed
out the disappointment and anger within the group regarding the methods through which they
had been informed of the decision reached by Minister Gormley following the advice of the
Working Group. The outcome of the decision had been disseminated through the media in
May 2010, as outlined in Section 2.2. He said:
‘Did they write to us the main stakeholders in all this to tell us of the outcome?
No they didn’t. Did they phone us? No they didn’t. What they did was they
told the national media first. What sort of a way was this to treat the very
people who in good faith engaged in a consultation process?’ (Flanagan, 2011,
see Appendix D).
Michael Fitzmaurice, chairman of the TCCA, was equally unequivocal, stating that:
“The Turf Cutters and Contractors’ Association is extremely disappointed that,
after partaking in all of the process for the last year, it’s sad to see that up to
today, we never got a press release of what Minister Gormley had to say. They

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couldn’t even be bothered contacting us, but given the arrogance they have
shown to date, we are not surprised’ (Scott, 2010).
A newspaper report notes the angry reaction to the announcement of May 2010 in Westmeath,
where the Creggan/Crosswood Turbary Group is quoted as saying (in relation to Minister
Gormley):
‘We have been ignored by him and his office for four years. He has never
listened to our viewpoint on this issue or had meetings with us. We attended a
Dáil committee on this issue where several solutions were on the table and the
willingness to deal was present but not attendance from Minister Gormley.’
(The Westmeath Independent, 2010)
The Dail Committee referred to has been outlined in Section 2.2.
The overall perception from the TCCA standpoint, based on such evidence, is of being
isolated from the decision making process, that the consultation process over the previous
year was merely designed to give a sheen of democracy to a decision that had already been
made. A perception of a lack of respect for the TCCA’s input to the process is evident in all
three sources, summed up in Michael Fitzmaurice’s statement that they ‘Couldn’t even be
bothered contacting us’ regarding the decision reached (Scott, 2010).
A more detailed outline of the perceptions of the TCCA of the Interdepartmental Working
Group process was gleaned from personal communication with the group, with the results
outlined in Appendix I. Here, the TCCA outline their perception that the government’s
position in relation to the cessation of turf cutting was non-negotiable from the outset, as
evident from the full title of the Working Group. In terms of comparative input by the range
of groups who forwarded submissions to the Working Group, the TCCA argue that their
submission was most detailed, comprehensive and relevant to the actual topic. They argue that
other submissions were short and strayed off topic into wider issues such as Global Warming.
They further argue that their submission was completely ignored. In terms of allocation of
time at the face to face meetings, the TCCA note that their interests were not proportionately
represented. While a petition containing 5,000 signatures accompanied their submission, they
argue that they were only afforded a one day meeting, the same amount of time allocated to
smaller organisations with far fewer supporters arguing from the bog conservation and
protection perspective. In response to the question of whether the perspectives of the TCCA
were incorporated into the final decision a definitive answer of ‘Absolutely not! But then that