To whom it concerns,
It has recently been brought to my attention that the area zoned as unsuitable for wind turbines in my locality is being proposed for alteration in the draft County Development Plan 2021-2027. Unfortunately it appears that nearly all of the area that is currently zoned as unsuitable for turbines is being changed to 'acceptable in principle' with the remainder of the landscape falling into the category, 'open for consideration' (see attached map). The zone proposed as 'suitable' spans a huge area of prominent hills running east from the Kilkenny side of the border near Ballyvogue/ Ninemilehouse as far as Hugginstown and from Kilmoganny south to Owning Hill. When viewed next to the area currently zoned by Tipperary CoCo as unsuitable for wind turbines (covering Slievenamon and the two ridges of hills running east towards the county border) the inconsistency and lack of joined-up thinking is clearly evident. To follow through with this plan may set an worrying precedent for our neighbouring county to follow.
This inconsistency is further highlighted by the submission made by the Kilkenny CoCo planning policy and projects unit in relation to the Pre-Draft of the Tipperary County Development Plan:
“Heritage/Archaeology The draft Kilkenny Plan has regard to the archaeological landscapes which may require an impact assessment for development which could have a significant impact on the identified landscape. Three landscapes were selected throughout County Kilkenny, the most relevant to Tipperary being the Lingaun River Valley, which runs along the county boundary between Tipperary and Kilkenny and includes specifically the Megalithic monuments within it and the relationships between them. This area includes the Knockroe passage tomb and Ahenny High Crosses. From prehistoric times the landscape has influenced the siting of these monuments and the visual links between the sites are significant.
Knockroe, along with other archaeological sites at Mangan, Co. Tipperary, and Frankfort and Baunfree, Co. Kilkenny, form the eastern perimeter of a prehistoric landscape focused on Slievenamon to the west.
· It is aligned to the rising sun on mid-winter day.
· The wider context of Knockroe extends to a second cluster of passage tombs located 60 kilometres to the west and flanking the Aherlow River. Both Shrough in the Aherlow Group and Baunfree in the Linguan Group are aligned directly to the cairn on the summit of Slievenamon.
· From Knockroe, the passage tomb on the crest of the Baunfree Hill is visible.
The OPW has prepared a Conservation Plan for Knockroe to inform its conservation and management. The Plan identifies that the protection of Knockroe monument, site and setting will involve “some synchronisation of policies” between Kilkenny and Tipperary County Councils.
Having regard to the significance of the setting of the above archaeological heritage sites and their relationship to additional archaeological sites within Tipperary and with Slievenamon, it is considered that significant developments, such as wind farms, in this area have the potential to have a significant negative impact on these protected sites and the historic landscapes in which they are sited. We would request that Tipperary County Council should satisfy itself that the wider policy context within its development plan can address these potential impacts which are cross boundary.”
The Landscape Character Assessment of the current Kilkenny County Development Plan 2014 – 2020, (see below) identifies landscape character types and protected views throughout County Kilkenny. There are 2 protected views designated within County Kilkenny that look towards County Tipperary. They are defined as:
- V15 – views west into Co. Tipperary from the Callan/Clonmel Road, N76 and
- V18 – view west into Co. Tipperary on Kilmacoliver/Scough Road, LS5097.
- It also includes an area specified as being ‘highly scenic/visually pleasing’ located within County Kilkenny along the regional road R6971.
It would be useful if in any revised Wind strategy, the archaeological and landscape designations in Kilkenny could be given recognition either in terms of text or by way of illustration.”
In these passages (key sentences area emphasised in bold) the planning unit clearly demonstrates an awareness of the significance of the ‘visual links’ between the sites while requesting their Tipperary counterparts to be cognisant of their importance in relation to the delineation of areas suitable for wind energy. Further to this I would add that the view from Slievenamon looking east towards the various archaeological monuments mentioned is of equal importance and this view would be compromised by the construction of wind turbines on the Kilkenny side of the border.
“In relation to the areas bordering County Tipperary, having compared Map 11 of the Tipperary Wind Energy Strategy and the proposed Draft Wind Energy Map of the Kilkenny Draft Plan, there appear to be two areas of juxtaposition of policy. Section 5.1.1 of the current Tipperary wind energy strategy identifies inconsistencies with adjoining county strategies. Having regard to the significant changes included in the proposed Draft Kilkenny County Development Plan Wind Energy Strategy, it is recommended that this be reviewed.”
This paragraph is somewhat confusing as the section (5.1.1) referenced within the Tipperary wind energy strategy (2016) states that the ‘area in Kilkenny is zoned unsuitable because it is a High Amenity Area. Considering this, parts of the adjoining area in Tipperary will be precluded from consideration as a preferred area for wind energy development, but will be considered as open for consideration and parts of the uplands areas have been designated as unsuitable for wind energy development.’ Do the ‘significant changes’ in the Draft Kilkenny County Development Plan Wind Energy Strategy referred to by the Kilkenny planning unit here amount to making this no longer a ‘High Amenity Area’. If so does this not undermine the spirit of this very submission made by the Kilkenny planning unit?
“The definition of areas identified as being ‘open for consideration’ in the current Tipperary Wind Energy Strategy states that wind energy development may or may not be appropriate in these areas, depending on the character of the landscape and the potential impact of the proposed development. It is suggested that further clarification in this definition could be given in the light of the factors highlighted above to ensure that the protected views, heritage sites and sensitive landscapes of the adjoining areas in County Kilkenny are fully addressed in the development plan policy.”
In relation to this paragraph, I would ask the same of Kilkenny CoCo in this instance.
The previous classification of 'unsuitable' was based on the grounds of the environmental and cultural value of the Lingaun Valley area. Furthermore, the Preliminary Audit of Archaeological Landscapes in County Kilkenny carried out by the Kilkenny County Council in 2019 highlighted the Lingaun Valley as an area of 'priority for protection' particularly due to the presence of several nationally significant megalithic tombs, most notably the two at Knockroe which are aligned to the winter solstice sunrise and sunset. Furthermore, the national programme for government emphasises offshore windfarm rather than inland and much emphasis has been put on natural and cultural heritage for tourism (e.g. Ireland’s Ancient East).
I am of course very much in favour of renewable energy and try to resist a 'not in my backyard' attitude towards things. However, it is my belief, along with others in the community, that wind turbines would severely hamper the cultural integrity of the area due to their sheer size and thus wide ranging visual impact in a landscape where view and line of sight is so historically significant - the ancient megalithic monuments in the valley were all deliberately constructed within view of each other. As such I would highly recommend reconsidering these proposed areas of ‘suitablility’ and further to that I would request that both councils constitute the Lingaun Valley region as unsuitable for wind turbine development entirely.
Yours with thanks,
To have the Lingaun Valley and surrounding hills zoned as unsuitable for wind energy.
Due to the significance of views and sight lines in and around the valley in terms of cultural heritage and tourism.