The mooted breaking up of Dúchas, the Heritage Service, has been described by the trade union representing its professional staff as a "deeply flawed" approach to the management of Ireland's heritage.
Mr Tom Hoare, assistant general secretary of IMPACT, also warned that it would have "major direct cost implications, other long-term ongoing costs in managing the extra layers of bureaucracy, internal legislative changes and a new set of confusions" for the public.
In a nine-page critique of the review of Dúchas ordered by the Minister for the Environment, Mr Cullen, IMPACT's members made it clear that they opposed any break-up of the service, especially as it had been established as a single entity "only a few years ago".
Describing this as a "visionary and forward-looking decision", they said the built and natural heritages of the Irish landscape were "inextricably linked" and it was "not possible to understand the history of places outside of their context and setting in the natural landscape".
They said the review, by suggesting that historic properties might be hived off to the Office of Public Works, failed to recognise the trend throughout Europe to integrate heritage, in line with the European Landscape Convention which Ireland signed in March 2002.
Dúchas staff are also opposing any transfer of its functions to local authorities, arguing that these were not in a position to take on extensive new heritage responsibilities and even had difficulties "doing what has been assigned to them at the moment".
The document complains that a number of issues were overlooked by the review, including the possible conflict of interest between the Minister's role in supervising the planning system and commenting, through Dúchas, on individual planning applications.
