Kilkenny City and County Draft Development Plan 2021-2027

We would like to Kilkenny County Council to consider our submission to zone the remaining portion of the site, Folio No KK12927 (7 acres at Norelands Road, Stoneyford) .

Approximately 5 of the 7 acres is currently zoned, however, 2 acres remains un-zoned.

My wife and I would like to build in Bennettsbridge as we have been renting here for over 4 years now. We have made many good friends in the area and sought planning permission locally but found out as neither of us were born in the area that we cannot build here. I would like the criteria for building in an area reviewed and would like to see a proper system for deciding who can and cannot build in an area based on fairness and equality and not just the "luck" of where you were rared!!

Dear planners please do not disrupt the light for knockroe passage tombs by putting up windmills

Regards

Nuala cuffe

To whom it may concern

I am writing to express my views particularly with regard to the wind energy zoning proposed for the areas around the Knockroe Passage Tomb and the Linguaun Valley.

Apart from the marring effect on our beautiful countryside views generally, I am particularly concerned about the detrimental consequences which the construction of Wind Turbines would have on the Passage Tomb and other local historical treasures in the area. We must not erase our valued past - those ancient and truly marvels of art and engineering (for their time in history),  by the impact of modern development on the visual environment.

On the morning of December 21st the sun rises over the slopes of the Kilmacoliver/Owning hill, lightening up the eastern chamber of Knockroe - this alignment is currently protected in the present Kilkenny Development Plan as an area not considered suitable for Wind Turbines. And marvel of marvels, as the only passage tomb in Europe, with alignments both with morning and evening sun, the Western Chamber is also lit - from the Carrigadoon Hill, from the west. What a Kilkenny treasure!

It is our privilege and responsibility to safeguard and preserve all that enhances our treasured monuments for our own enjoyment - and showcase them to the generations to come. These heritage structures, historic artefacts and features,  are our precious inheritance from our revered ancestors and are paramount in any, and all planning. 

 Kilkenny County Council members, in your new development plans, please ensure that the Knockroe Passage Tomb and the surrounding landscape in County Kilkenny are safeguarded and considered unsuitable for Wind Turbines, thus providing protection for this sacred, historic and revered site.

Thanking you for the opportunity to contribute my thoughts.

Margaret Tobin

Wind Energy

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.”

Landscape Character/Views

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,

Daniel O'Mahony

Knockroe Passage Tomb 

I enjoyed your presentation last week on the sustainability aspects of the Kilkenny City and County Draft Development Plan 2021-2027. I look forward to seeing the detailed cycling plan when its available. The overall goal of 10mins to the city centre for most whether walking, cycling or public transport is very welcome.

I really want to focus on some energy aspects which I think need some extra work.

District Heating

Somebody mentioned that this is included under renewable energy – it was not obvious to me in the draft plan. I would argue in any event it should have its own heading. It was noted on the night that the overall goal for wind generated electricity in the County is 100% of the total. I did notice another figure of 70% in the draft – the latter figure is more in line with national aspirations. Anyway, the real point is that electricity only makes up about 25% of overall energy consumption. The other big sectors are of course transport and heat – roughly equally divided – and thus are substantial portions of overall energy consumptions in their own right. District Heating (DH) is very established in Denmark and has truly struggled to get going here. There are some small developments like Cloughjordan village using woodchip central boilers and Charlestown Shopping Centre using mainly CHP/gas boilers - to name a few. However, its time has now come for a number of reasons:

• Need for clean air in towns, cities and to displace solid fuel firing
• Heat pump (HP) technology developments can drive DH systems

I think most people think that DH means wood firing – this is now totally changed. London has hugely adopted DH in recent years using mostly CHP drivers. Most of the new ones there are now HP using air to water or water to water sources. The water source is often the local river. I feel the Abbey Quarter has missed this opportunity as its located right beside the Nore.

Also, there are moves at national level to properly fund these systems and have them retrofitted in our towns and cities. The DH option will be always be one of the most expensive heating options – but with proper funding I am convinced it will be become the norm for many developments both new and upgrade type. I think Paddy Phelan of 3CEA may have reiterated this view on the night.

Eco Village

To whom it concerns,

Please find attached a submission to the Draft Kilkenny City and County Development Plan 2021-2027 on behalf of Tullahought Community Development Ltd. (Tullahought Tidy Towns)

Regards,

I wish to comment on the Kilkenny City & County Draft Development Plan 2021-2027 Vol 2,

Ref “6.8.6 Recreation and Sporting Facilities

There are significant built recreation and sporting facilities provided throughout the City through a mix of public, private clubs, schools, community facilities and

voluntary organisations.  Hurling and equestrian pursuits are of considerable importance to the county. 

Outdoor facilities include playing pitches, golf courses, pitch and putt courses, and athletic running tracks.  Some of these facilities also combine other uses – such as the walking tracks developed around playing pitches and some facilities also combine locations with indoor facilities including swimming pools, gyms and community and sports halls catering for indoor sports – such as at the Watershed in Kilkenny City.

The Council will co‐operate with local development organisations, community groups, sporting organisations and other stakeholders in the development of active recreational facilities throughout the City and to enter into joint venture arrangements where appropriate for the provision of such facilities.”

While on paper it may appear that Kilkenny City has “significant built recreation and sporting facilities”, in fact it doesn’t…. Most of the facilities listed on KRSP website directory are either private hotel gyms & leisure centres or traditional halls with a sprung timber floor, outdated for the modern Multi-Purpose Sports Facility.

When you search for “Multi-Sport Facility” on KRSP website Facility Directories, three (3) facilities are returned,

1. Garringreen Neighbourhood Park, which is an outdoor playground,

2. St. Kieran’s College Gym, which is owned & run by the school, has a traditional timber floor & limited access to sports clubs.

3. The Watershed, which as its name suggests is primarily an indoor pool, with gym facilities & a timber floored hall

All the above are not suitable for the modern-day Multi-Purpose Sports Facility, they cannot cater for any Wheelchair Sports or In-line Hockey or any other “roller” sport (without significant damage to timber floors).

Many other Minority sports like Volleyball, when you look at the KRSP website for their facilities, two are given, both outdoors!!

Other minority sports played in Kilkenny and that will come under the Kilkenny City Minority Sport and Recreation Trust, are not even listed on the KRSP website. They are making do with renting industrial units, derelict warehousing, damaged community halls in complete disrepair, unsafe and not fit for purpose.

While Kilkenny thrives on the Hurling and Camogie pitch, we equally excel on the Hockey Rink for example, abet with limited or no suitable facilities.

All young sports participants should be viewed equally, no sport should be made to feel any less than any other, (is a World U18 Kettlebell Medal any less valuable than an All-Ireland Minor Hurling Medal?.........not to the person who competed for it) and shouldn’t be from a society that supports & a Council that serves its citizens…..equally.

Multi-Use Sports Facility

To meet our growing community’s needs, we (Kilkenny Sports Complex CLG) are proposing a Multi-Use Sports Facility focusing on minority sports primarily, which will complement the existing facilities & add to the capacity to cater for the increasing demand for suitable indoor sports space & facilities. The facility would consist of two full size indoor In-line Hockey pads with retractable tiered seating or bleachers to create an “Arena style setting” on one of the pads, These two “pads” would be multi-functional in design & surface to accommodate an array of minority sports already played in Kilkenny & with the provision to encourage other sports that are not yet played.  The proposed facility would be located on land that the Council owns at Breagagh Valley or Loughmacask and would balance the city Community & Recreational facility spread in line with the “10min City Concept”.

We have been discussing the possibility of such an indoor sports facility space for over 15 years now, so it is long overdue and needs to be included in the new Kilkenny City Plan 2020 to 2027.

A growing population and an increase in diverse cultures, attitudes and citizens in Kilkenny City, deems this space essential  to meet the needs of our growing community’s demand for a Multi-Use district wide space to accommodate a broad range of indoor sport and recreation pursuits like but not limited to:

In-line Hockey, Seasonal & Competitive Ice Hockey, Indoor field Hockey, Wheel Chair Basketball / Rugby, Taekwondo, Kettle Bells, Korfball, Lacrosse, Figure Skating, Basketball, Frisbee,  Netball, Futsal, Roller Derby, Tag Archery, Handball, Badminton, Racquetball,  Indoor Bowls, Table Tennis & so much more.

Opportunities are likely to arise for Regional, National & International tournaments in any of the above listed sports.

There is also a preference to incorporate centralised space for a fitness gym along with associated exercise classes, a sports injury & medicine clinic, sports administration, sports coaches, meeting and conference space for local clubs and community groups. The facility would incorporate spectator seating around the perimeter of “Pad No 1” using retractable seating & Bleachers for around 500 people.

In response to demand for space, we are proposing to start design of the facility in July 2021 and it is expected that the building will be available for community use within 3 years of design commencement.

We will work with Kilkenny County Council and Kilkenny Recreation & Sports Partnership on the development and design of a Multi-Use Sports Facility with regard to a Heads of Agreement for the management and operation of the facility, with no ongoing operational costs to the Council.

The following description of the building is from Richard McGowan (Warren and Mahoney Architect & Consultants on Multi-Use Sports Facilities): “The New 2 Pad Facility is perhaps unique in its siting and its potential to provide a vibrant focus for Minority Community Sports. While the building principally (and necessarily) should be designed to be efficient, cost effective and functional, it should occupy a key site and be visible and a focal meeting space to the community it services. All facades should be visible, which provides excellent opportunities for direct engagement with the community in every direction. The opportunity to deliver a stand-out facility is very much enhanced by the proposed location and setting offered by the new development sites, from which the building can act as a billboard for a community’s aspiration. The building should be designed to fulfil Kilkenny City’s present needs, but also with an eye directly to the future. It must be energy efficient and spatially efficient; the arrangement of internal functions should produce attractive proportions and an identifiably civic sense of place & community. Indoor spaces should be flexible and reconfigurable. Claddings should be robust and highly insulated, with good natural daylighting and provision for PV panels for on-site electricity generation.

Operating Model

The concept is that the facility would be operated by Kilkenny City Minority Sport and Recreation Trust (the Trust) who would have a formal operating agreement with the Council. The Trust would meet all operating costs for the facility and pay an annual contribution to the Council. The Trust would supply all the equipment necessary to operate the facility. The details of this are yet to be formally agreed among the partners of the Trust but the concept is that this would include payment for all of the items necessary for the operation of the building such as retractable seating, basketball/netball hoops etc. If Kilkenny County Council supports the inclusion of the funding in the Draft for operating equipment, Trust officials will work with the Council to formalise an agreement on what would be required and the operating and management of the facility and the funding that the Trust will contribute.

The Planning Department,

Kilkenny County Council,

County Hall,

John Street,

 Kilkenny,

Co. Kilkenny R95 A39T.

Draft Kilkenny City and County Development Plan

To whom it may concern,

Thank you for this opportunity to comment on the Draft Kilkenny City and County Development Plan.

I am writing this submission on behalf of a local Action Group.  I am writing to express my opinion, on behalf of our group as we are extremely concerned at the proposed changes to the wind energy strategy in the Draft Document in the south west Kilkenny area adjoining the south east of county Tipperary. It is our strong belief that the area of Ahenny and any areas surrounding it, including in South Kilkenny, should be zoned as unsuitable to wind farms.

Firstly, we firmly believe that any industrial development should not be allowed in a sensitive landscape. From 2006-September 2016 the area surrounding Ahenny was zoned as ‘unsuitable for wind energy developments’ by South Tipperary County Council. We are amazed by the decision in 2016 to rezone it as ‘open to consideration’, given its protection status of ten years. The Lingaun Valley hosts two heritage sites of national and international significance, namely the Ahenny High Crosses and the Knockroe Passage Tomb.

While the Government guidelines on wind turbine proximity to dwellings suggest 500 metres as being an acceptable distance between a wind turbine and a residence, we believe this is both inadequate and unfair. Any such development would alter our views and interrupt our peace and quiet forever. We need to protect our most vulnerable citizens and this includes our children with autism and sensory processing issues, who would be negatively affected by the low grade noise and humming from these machines.

Secondly the entire area of the Slievenamon Mountain Mosaic and the nearby Lingaun Valley is a very sensitive landscape.  The iconic Slievenamon Mountain with an historic cairn at the summit needs to remain unspoilt. Similarly the Lingaun Valley hosts the world famous Ahenny High Crosses. These areas and monuments are part of an ancient setting and the entire area is highly sensitive and incapable of absorbing change, most especially change in the form of an industrial development. It would be highly undesirable for tourists if their attention was drawn towards giant turbines instead of the historic monuments. A windfarm would be in conflict with the existing environment, i.e. the ancient historic heritage sites on our doorstep. These views of ours are in line with the Tipperary policy TWIND 4.8 which states that ‘All applications will have regard to the impact of any proposal for wind energy development on surrounding tourism and recreational related activities and the compatibility of same will be carefully considered in the assessment of any planning application.

The Lingaun Valley comprises, among others, the townlands of Ahenny, Faugheen, Grangemockler, Garrymorris, Garyduff, Attyjames, Killinch, Oldcastle, Tiroe, Curraheen, Clashnasmuth, Coollarkin,  Kiltrassy, Hardbog, Castlejohn, Frankford, Mellamore,Knockroe, Windgap, Tullahought, Ballinlina, Barnatrasna, Poulmallen, Bawnreigh, Killmacoliver, Birchwood, Slatequarries, Slievenamon Valley, Rathclarish.

It is used largely for intensive beef and dairy farming and equine activities.

The Lingaun Valley stretches from the eastern slopes of Slievenamon through the conservation villages of Ninemilehouse and Ahenny. The river Lingaun forms the boundary of the counties of Tipperary and Kilkenny and between the provinces of Munster and Leinster. Throughout the Lingaun Valley, there are outstanding views of Slievenamon.

It is an area rich in megalithic, Bronze Age and medieval sites. The region has been classified, in the past, as Sensitivity Class 3, a highly sensitive landscape.

It is bordered by the Slievenamon mountain mosaic, defined as Sensitivity Class 4 or special landscape. 

According to the South Tipperary Landscape Policy (2.6), the conservation values of the Lingaun Valley LCA are “consistently of a high level of importance at a local level.”

“It’s enclosure by Slievenamon and the rim of hills to north and south, the scenic views within the area and the intimacy and scale of much of its landscape pattern result in significant aesthetic and potentially recreational amenity value, as yet untapped. Due to a lack of recognition and thus active conservation and development of these values, the area has not yet realised its potential for the development of a regional landscape resource.”

The Landscape Policy thus acknowledges the high scenic and recreational values of the Lingaun Valley.

It suggests that as well as having high potential socio-economic value in tourism, forestry and rural housing, the area has “particular wind energy development value which might be sensitively harnessed without due impact on the LCA or the neighbouring Slievenamon.”

There are a number of fundamental and legitimate reasons why the construction of giant wind turbines in such an intimate scenic landscape could not occur without due impact on the LCA or neighbouring Slievenamon.

We argue that the area’s untapped potential recreational amenity values should be safeguarded and enhanced and that should be the objective of all further management of the area. 

Ahenny is one of six designated conservation areas in the South Tipperary County Plan.

It is home to two unique 9th century High Crosses, the oldest of their kind in the country. Linked to the nearby Killamery and Kilkieran High Crosses, they form part of the Ossory group and are national monuments in State care. The Irish High Cross is the earliest example of Irish sculptural achievement and is Ireland’s enduring contribution to Medieval European Art. As such, the crosses at Ahenny are a source of fascination to many visitors to Ireland and a valuable lure for tourists to the Lingaun Valley and Carrick on Suir.The graveyard at Ahenny is also home to a souterrain chamber or underground passageway, and the remains of an ancient monastery.

Other protected structures in Ahenny, a rare example of a Welsh mining village in Ireland and labelled Ireland’s smallest village by some travel correspondents,  are a series of single storey slate roofed cottage at Vickers St and another at Moore Street. These tiny cottages were the homes of miners who worked in the nearby Victoria Slate Quarries and are a popular tourist attraction in the area.

Ninemilehouse, a neighbouring village at the other end of the Lingaun Valley, is also a member of the group of six conversation areas.

Within Architectural Conservation Areas, the Council pledges to have regard to:

 A) the impact of a proposed development on the character and appearance of the Conservation Area in terms of compatibility of design, colour and finishes, and massing of built form;

B )the impact of the proposed development on the existing amenities, character and heritage of these areas.  

In Policy Env 43, the Council pledges to protect “the existing amenities, character and heritage of conservation areas from unsuitable developments.”

To locate wind turbines in the countryside around the High Crosses and in the valley between the two conversation villages would be a breach of this Conservation Policy and contrary to proper planning. It would have a hugely detrimental effect on the historic and scenic amenity of the Lingaun Valley. It would adversely affect the striking views of the Lingaun Valley from the summit of Slievenamon.

The south Tipperary Heritage Plan

The Heritage Plan (2.1.7) pledges to raise public awareness, understanding and enjoyment of South Tipperary’s heritage and its significance among the general public, locally, nationally and overseas.

Specifically, 2.1.7 promises

“To promote archaeological landscapes and complexes, including those which straddle the County border: the High Crosses of South-East Tipperary and West Kilkenny.”

Policy ENV 45 on Archaeology states it is the policy of the Council to protect all monuments in the Record of Monuments and Places. The Council also promises to protect “the setting” of these monuments.

Standing at 185m, wind turbines are machines of huge proportion, taller than most urban skyscrapers and Dublin’s Millennium Spire

The intrusion of such a development in a rural setting is not just the turbines, but includes pylons, access roads, concrete bases and cables.

To allow a wind plant in this landscape would be a breach of the Heritage Plan in that it would be gravely injurious to the specific ancient archaeological landscape the local authority has pledged to promote.              

The Caiseal at Knockroe

Beautifully situated on the banks of the river at Knockroe, the Lingaun Valley’s Stone Age monument, known locally as the Caiseal, is a megalithic passage tomb of national importance. It is the most southerly passage tomb in Ireland and its relatively recent excavation in the 1990s is an indication of the huge archaeological significance of the area.Prior to its discovery, Baltinglass Hill in Co. Wicklow was believed to be the site of the most southerly passage tomb.Archaeologists involved in the excavation of the Caiseal call it the Newgrange of the South and say there is no reason why it could not become a tourist attraction of the stature of the Meath tomb. This tomb is rich in megalithic art, with about 30 decorated stones. Like Newgrange in the Boyne Valley, the face of the cairn flanking the eastern tomb is decorated with a frieze of quartz. Although four distinct kind of megalithic tombs have been recorded in Ireland, passage tombs appear to have had special significance. They were always built where they could dominate significant areas of the landscape, overlooking rivers, as in the Boyne Valley. The Knockroe site is situated on the banks of the river Lingaun.           

On December 21st, the day of the winter solstice, the passage tomb is filled with the rays of the sun behind the ancient hill of Carrigadoon. Every year, this mysterious phenomenon, which gives us such a fascinating insight into the lives of the Stone Age people, attracts more and more tourists to the area.

If wind turbines were constructed in this landscape, this fascinating process of illumination at the Caiseal would inevitably be injured and possibly lost. This would represent a grave breach of proper planning and policies within the South Tipperary County and Heritage Plans that pledge to protect and promote archaeological structures and landscapes.

The Lingaun Valley  - a “Highly Sensitive Landscape”

Schedule 1: Landscape Policy in Relation to Wind Energy Developments classifies the Lingaun Valley as a “highly sensitive landscape.”

It states “the conservation values of the Lingaun Valley Landscape Character Assessment are of a “consistently high level of importance at a local level. Its enclosure by Slievenamon and the rim of hills to north and south, the scenic views within the area and the intimacy and scale of much of its landscape pattern result in significant aesthetic and potentially recreational amenity value, as yet untapped.”

Allowing a wind plant in this area would be to show disregard for the Landscape Policy, which recognises the scenic values of the area and the significant aesthetic and recreational amenity still untapped.

Respecting and Enhancing High Sensitivity Zones

Schedule 1: Landscape Policy states ‘areas of high sensitivity are defined as areas which may be suitable for wind energy development where the existing character and value is established and is respected/enhanced by the proposed development.’

The degree of potential impact on the environment must be low and subject to proper planning and development considerations and guidelines as set out in policy.”       

By virtue of the scale of individual turbine units soaring to 180m in height and casting giant revolving shadows and flashing lights in an otherwise static and unlit landscape, it is inconceivable that the character of such an ancient, rural landscape could be respected or enhanced by such a development. To allow them would be a breach of this pledge to respect the existing landscape, as guaranteed in the Landscape Policy.       

A field report for monuments in the Lingaun Valley as compiled by the Archaeological Survey of Ireland, National Monuments and Historic Properties Service shows an abundance of fulacht fiadh, standing stones and Bronze Age enclosures.  (see Ordnance Survey 6 inch maps 72 and 79).

There are 13 recorded monuments in the Curraheen/ Clashnasmuth townlands in Ahenny and many unmarked field monuments.

The conviction grows that undiscovered archaeological sites are almost certainly present in the area, including a further passage tomb as they are rarely found in isolation as in Newgrange, Knowth and Dowth.  Nearby Templeorum and Owning districts contain the richest store of ancient remains dating from Neolithic to Anglo-Norman times of the whole of Kilkenny.

On Kilmacoliver Hill in Tullaghought, Windgap, an extensive circle of stones marks the hill top location of a megalithic gravesite. The structure is aligned with the setting solstice sun and visited by groups on mid-winter and mid-summer day.

Overlooking Ahenny to the west, the hill of Carrigadoon in the Lingaun Valley boasts one of just 60 hill forts in the country. The highest hill in the area, it is also the place where John O’Mahony’s rebels camped during the 1848 Famine Rebellion. 

 Protected Structures

The Lingaun Valley is rich in protected structures.

 Under Policy Env 44, it is the policy of the Council to protect structures listed for protection by resisting “developments that would adversely affect the setting of a protected structure.”

To allow industrial wind farms in this area would have an adverse effect on the setting of these protected structures and thereby breach proper planning. 

Protected structures in the Lingaun Valley are listed in the South Tipperary County Plan (2009-2016) as follows:

AHENNY One of a series in two rows of single storey slate roofed houses at S149

Vickers Street, Ahenny.

Area designated the Ahenny Architectural Conservation Area

AHENNY One of a row of single storey slate roofed houses at Moore Street, S150

Ahenny.

Area  designated the Ahenny Architectural Conservation Area

AHENNY Two High crosses in Old Ahenny graveyard S376

AHENNY LITTLE Slate' slab topped roadside wall, unique design S374

Castlejohn

AHENNY LITTLE One of a series of slate quarrymen's cottage part of three terraces. To be S375

included as Ahenny Architectural Conservation Area ACA

CLASHNASMUT Victoria slate quarries. South east of Grangemockler S418

CASTLEJOHN Farmhouse, with older structure possible a tower house incorporated in S373

later structure, yard, bowed slate roof Nr. Ahenny

CASTLEJOHN Attractive farmhouse single storey 3 bay and outbuildings on Kilkenny S419

border Castlejohn. East of Grangemockler

CASTLEJOHN Castlejohn S540

CURRASILLA Aughvaneen House, 3 bay 2 storey. Hipped roof, 2 small chimneys. Sash S377

UPPER windows Adjoining houses to form Aughvaneen Architectural

Conservation Area ACA east of Grangemockler

CURRASILLA Currasilla House. Late 18 early 19 century farmhouse with outbuildings S420

UPPER adjoining houses to form Currasilla Architectural Conservation Area east of Grangemockler

GRANGEMOCKLER George V letterbox set into roadside boundary wall at Cardinal Browne S147

GRANGEMOCKLER Hogan Memorial on pier at Church gate. Grangemockler S421

KILHEEFERNAN Kilheffernan House. S172

NINE MILE HOUSE Multi era structure at Nine Mile House crossroad North east much S378 altered now a guest house attributed to 1690 attractive garden

The Victoria Slate Quarries, Clashnasmuth

The slate quarries of the Lingaun River Valley have always been renowned where there were quarries on both sides of the River Lingaun in Counties Tipperary and Kilkenny.

In the Middle Ages, Lingaun Valley Slates were used to roof the priory of Kells, County Kilkenny.

The first slated houses in Carrick-on-Suir Main Street were covered in the slates dug near the Lingaun in 1680 by the Dutch woollen merchant Groninx, the founder of the town’s woollen industry.

The last load of slates to leave the quarries by the Lingaun was a consignment for Achill Island in 1947, which were sent to roof a school, according to local tradition. (Dr Patrick Power, Carrick on Suir Town and District.

Instead of allowing the quarry fall into disrepair, today it is a well-kept local amenity used for walking, riding and art exhibitions. The cliffs that hang over the Lingaun River in the quarry are striking. There are also various modern megalithic sculptures around the site. Its position beside the Knockroe passage tomb and the Ahenny High Crosses makes it an appealing addition to visitors on tours of the area.

There is substantial potential to promote the Slate Quarries and the miner’s cottages as a tourist amenity, giving as they do a fascinating insight into Ireland’s mining heritage.

The Boreens Of Ahenny

To facilitate a wind plant, major infrastructural changes and new access roads would have to be built throughout the area. Our tiny boreens and country lanes form an integral part of the appeal of the Lingaun Valley and to attempt to widen or alter them significantly would change the character of this ancient rural landscape.

Environmental Nuisance

Policy ENV 25 on Environmental Nuisance states the Council will resist developments that give rise to unacceptable levels of noise and light affecting areas beyond the site boundary, or to air or water pollution.

In Europe, noise from windplants is a notorious and well-documented nuisance.

Other well-documented nuisances associated with wind plants are

·         shadow flicker: turbine blades cast moving shadows across the landscape when the sun is shining. This flicker effect can travel into houses in ways that may affect surrounding properties at a considerable distance.

·   ·         lightning and power surges: wind turbines themselves may cause irregularities in the power supply as wind speed changes. When the wind gusts, there may be power surges.

·      ·          ill health: people who live within one mile of wind farms can suffer side effects including headaches, migraines, nausea, dizziness, palpitations, sleep disturbance and depression.

In terms of visual impact, a wind power plant development would also contravene Policy LH2: Protection of Visual Amenity and Character of Primary and Secondary Amenity Areas especially points A and B

A)   Developments should avoid visually prominent locations and be designed to use existing

topography to minimise adverse visual impact on the character of primary and secondary amenity areas.

b)  Buildings and structures shall ensure that the development integrates with the landscape

through careful use of scale, form, finishes and colour.

It is the strong view of our group that any wind turbines in the vicinity of the Ahenny High Crosses or the Caiseal (Knockroe passage tomb) would impact very negatively on this area. The location of wind turbines, usually on a hill would make industrial turbines very prominent and unmissable. They would potentially also be viewed from the neighbouring village of Tullahought. Similarly any turbines in Tullahought would be seen from the Ahenny High Crosses. From the viewing Tower at Tullahought, there is a protected view across to Carrigadoon hill, protected by Kilkenny County Council. The turbines would be huge and very imposing. They are usually grey in colour and could not be camouflaged or hidden. They could not possibly be integrated into the existing landscape, as they are industrial looking and would be a visual eyesore. They could not be missed, regardless of their final shape or form. 

‘Heritage is not so much a thing of the past but of the present and the future’ according to  Michael Starrett, the Chief Executive of the Heritage Council. We could not agree more. That is why we will continue to fight to protect our heritage for the future generation. Industrial wind turbines are simply incompatible with this landscape.

Yours sincerely,

Genevieve Cooney on behalf of

Mairead, Teresa and John Sheehan (Clashnasmuth)

Kay and Leo Cody (Ahenny)

William Cody (Ahenny Little)

Mark Lonergan (Clasnasmuth)

Ed O’Shea (Clashnasmuth)

Pat Power (Knockroe, Co Kilkenny)

Dear Sir/Madam,

Please find attached a copy of TII’s observations, including related attachments, on the Draft Kilkenny City and County Development Plan 2021-2027.

22nd February, 2021.

Planning Section 

Kilkenny County Council, 

County Hall, 

John Street, 

Kilkenny R95 A39T

Dear Sir/Madam,

rE: Draft Kilkenny County Development Plan submission

Thank you for the opportunity to comment on the Draft Kilkenny County Development plan. This submission from Port of Waterford  follows submissions made on the RSES and on the Kilkenny County Development Plan Issues Papers. Port of Waterford appreciates Kilkenny County Council’s ongoing support for the strategic development of Belview Port and its associated port infrastructure and strategic land requirements.

Port of Waterford welcomes the content of the draft plan and commends the Council on a comprehensive strategy and a close alignment with the direction provided by Regional Spatial & Economic Strategy. We would however highlight a number of areas where further consideration and clarity could be provided in the plan. These relate to issues associated with the strategic clustering of employment and business activity at the Belview Strategic Enterprise Area, the need for the plan to address the availability of zoned land, the new opportunities for port expansion related to the servicing of the offshore wind sector and the delivery of the ongoing improvement programme for the N29, national primary route. 

Looking at each of these in further detail: 

1. Belview Strategic Enterprise Area- availability of zoned lands.

The Belview Strategic Enterprise Area, i.e. the IDA lands for Foreign Direct Investment (FDI) and the Port Zone, has seen significant development in the area over recent years. In the Port Zone this development has more recently focussed on business with direct Port activities. There is opportunity to expand the footprint of the Enterprise Area through the zoning of additional lands for the purpose of related activities, for example, storage and distribution centres, engineering and educational facilities in support of the off-shore renewable energy sector and a range of other associated businesses and services.

There is also an opportunity for the County Development Plan to address the issue of the availability of developable land, which in contrast to the area of zoned land, is limited.  This issue requires specific measures to be included as part of the review of the Ferrybank-Belview Local Area Plan supported by broader policy within the County Development Plan. 

1. Belview Strategic Enterprise Area- general office use. 

 The supporting narrative under paragraph 5.3.1 of the plan which describes the clustering of economic activity at Marine Point in Belview (The Belview Strategic Enterprise Area) as including the IDA lands for Foreign Direct Investment (FDI) and the associated port-related business sector, is fully consistent with RSES approach to clustering of economic activity in the region (page 101).  The clustering of economic activity at the port, however, will require a range of office accommodation related to supporting wider port-related activity, including FDI and their related logistics and supply chains, for which a general office use provision would be most appropriate. We would submit that the plan requires to adopt a more flexible approach to the accommodation of more general office use as part of this strategic designation. We would suggest an additional objective (5K) is added to compliment Objective 5J, (To continue to work with Transport Infrastructure Ireland to finalise an approach for access to the zoned lands along the N29 at Belview) on page 57 of the plan as follows: 

5k – ‘To facilitate the strategic clustering of business activity within the Belview Strategic Enterprise Area, a general office use will be permitted at Marine Point alongside port related uses and foreign direct investment.’ 

1. Opportunities for Offshore Renewable Energy (ORE). 

 Off-Shore wind investment is a key component of the Climate Action Plan and support for off-shore installations represents a significant opportunity for the Country over the coming decades. The Port is actively involved in facilitating on-shore wind installations, is highly aligned with the industry and should be seen as a significant enabler. Port investment will be required and strategy alignment between the Southeast Ports on this issue is highly desirable. This opportunity will require the acceleration of some or all of the projects identified in the Port of Waterford Masterplan. 

In-line with RSES RPO 85 ‘Renewable Offshore Energy’ (see RSES page 129), the Port has identified an opportunity to develop its potential in servicing and supporting the offshore wind sector in projects in the Irish Sea and Celtic Sea regions. The plan should make reference to the potential of this sector for regional economic development and the potential for Belview Port to develop an operational capacity to support this in the form of a strategic investment zone for off-shore development. Typically, this would include landside storage and assembly of turbine components, educational and certification facilities, landside fabrication and a servicing hub for the maintenance and infrastructure management fleet. This provision would further strengthen Belview Port’s role as a key economic driver for the South-Eastern Region.  

1. N29 access improvements. 

We would like to restate the importance of strategic port access via the N29 and are keen to see the delivery of the stated N29 Port Road roundabout. The Port welcomes the acknowledgement of this in the draft plan under Objective 12U ‘Construct a roundabout on the N29 at the L3412 (Rathculliheen) junction’ and we look forward to completion of this project in due course.

We welcome the County Council’s consideration of this submission.

Yours sincerely

A Chara,

Attached is a submission to the Draft City and County Development Plan on behalf of the Caiseal Conservation Committee.

Wind energy zoning 

Inclusion of lands in the settlement boundary

Wind Energy Strategy

Wind Energy Strategy

The Planning Department,

 Kilkenny County Council,

 County Hall,

John Street,

Kilkenny,

Co. Kilkenny R95 A39T.

Draft Kilkenny City and County Development Plan

To whom it concerns,

Thank you for this opportunity to comment on the Draft Kilkenny City and County Development Plan.

I am extremely concerned at the proposed changes to the wind energy strategy in the Draft Document in the south west Kilkenny area adjoining the south east of county Tipperary.

This is an area renowned for its historic sites from our recent history and dating back 6,000 years. These historic and cultural gems are dispersed throughout the area creating a rich tapestry set in terrific scenery.

To those of us living in the area on both sides of the valley there is a natural enclosure which we feel should be protected.

Historical, cultural and environmental interconnectivity between counties Kilkenny and Tipperary include:

• Slievenamon Mountain which dominates the valley and the circle of hills which form a natural enclosure of the area.
• The Lingaun River which rises on the slopes of Slievenamon and flows through the valley the bounding line between parishes, counties, provinces and Dioceses.
• The Knockroe Passage Tomb (5,200 BC) which has a winter solstice sunrise alignment on the hills in county Kilkenny and a sunset alignment on the Tipperary hills.
• The Kilmacoliver Passage Tomb (5,000 BC) which is aligned across the valley with the Cairn on the summit of Slievenamon.
• An abundance of Fulach Fia, Standing Stones and Dolmens.
• The Western Ossory High Cross’s (8th century) which span the Lingaun River. The predominant views from The Ahenny High Crosses are across the county border to the Kilkenny hills. The Killamery and Kilkieran High Crosses are on the Kilkenny side of the border.
• Carraigmoclear Hill (Tipperary) where a group of United Irishmen were ambushed by Crown forces in 1798, the slain rebels are interred in the nearby Killamery churchyard in county Kilkenny.
• The historic Ormonde and Victoria Slate Quarries (19th/20th century) located on both banks of the Lingaun River.
• A strong equine industry with prominent horse breeding and training facilities located in the valley in both counties.
• The Lingaun Valley Tourism Group whose members are drawn from both counties and who work to promote and protect the heritage sites of the area and develop it’s tourism potential

Other sites of interest in the area include the (Michael Hogan and Tom Kiely memorials in Grangemockler and Ballyneale, Kilcash Castle in Tipperary) and the Windgap Grotto and Lamogue Ogham stones in Kilkenny).

This natural enclosure is created by Slievenamon ant its foothills to the north to Nine Mile House and to the south over Faugheen is mirrored in Kilkenny as the hills complete a circle from Nine Mile House via Windgap, Brown Mountain, Owning and Baunfree.

These hills are currently zoned unsuitable for turbines in both counties and this must continue to be the case, furthermore the area enclosed inside these hills should also be protected.

Living by choice in a quiet rural area, I am amazed that anyone would consider allowing these giant turbines in such a beautiful and historic area.

The impacts of these giant wind turbines are well documented:

Visually destructive to the landscape.

Noisy and obtrusive due to intermittent shadow flicker.

Health risks especially to those vulnerable such as autistic children including our daughter, Ava Cody.

Killers of the bird and bat populations.  

Producers of harmful Infrasound.

Detrimental to the equine industry. 

Devaluation of property prices.

Destroys tourism potential of the area.

I believe that the Kilkenny hills overlooking Killamery, Windgap, Lamogue, Kilmoganny, Hugginstown, Templeorum, Owning and Tullahought and the area enclosed by these hills and the Tipperary border should be zoned as being unsuitable for wind turbines.

Kind Regards,

Genevieve and William Cody

I submit in the strongest terms that the lands that are the subject of the above mentioned wind farm proposal should NOT be redesignated as "Acceptable in Proposal" or "Preferred" for wind farm development. 

The reasons for my submission are as follows:

• There has been no meaningful consultation with members of the public or local residents by the developers. There have been no open public meetings, online or offline. There has instead been an extremely cynical attempt to take advantage of the restrictions that have resulted from the ongoing pandemic. Due to Covid 19, concerned residents have not been able to gather to discuss the matter and as a result many people are ignorant as to the scale and magnitude of this proposed development and the far reaching implications it would have on the region. Although the plans are available for inspection at Thomastown planning office, the office is officially closed because of Covid 19 and consequently, citizens are not able to inspect these plans freely and at their convenience and instead, have to make an appointment to do so. And of course, because of fears for their own safety, many people would not venture out to make such an inspection. Furthermore, concerned parties have been denied the right to make submissions in relation to this planning application at local level and have to submit directly to An Bord Pleanala. 
• I note that the Renewable Energy Strategy aims to have Kilkenny generating 100% of its electricity needs by renewable sources by 2030. I would not dispute this aim. However, as far as wind energy is concerned, it is clear that Ireland should be pursuing a policy of offshore wind farms, in line with the rest of the world. And it is highly probable that the electricity produced from an industrial sized wind farm such as the one proposed would be exported via the Celtic Interconnector to France. The intention appears to be to turn Ireland into a battery for the rest of Europe at the expense of the beauty of the Irish countryside and the tourist industry, on which the country is heavily reliant.
• The area the subject of the proposed development is upper bogland. In the past few years, there have been at least three signifcant land slides at similar locations in Ireland: The 2003 peat slide at Derrybrien in the Slieve Aughty Mountains in South Galway,

  the 2008 landslide in the Kielduff/Lyrecrompane area of County Kerry, and the 2020 bog slippage at Meenbog Wind Farm in Ballybofey, County Donegal. It does not seem just and equitable that Kilkenny citizens should be subjected to such a threat to their health and safety.

• There is a significant danger to the integrity of the well water of the households surrounding the proposed development. In addition, the capacity of the water table is likely to be reduced during construction and there is also likely to be a detrimental effect on groundwater quality, which may cause ecological damage.

• There is much evidence to support the fact that shadow flicker causes heightened stress to the general population. This can have a significant impact on mental health. Shadow flicker is a known risk factor in relation to epileptic seizures. The sensory impairment linked to autism is also heightened by shadow flicker

• I contend that the negative impact on the landscape will be huge. 21 turbines at a height of 185 metres with a blade span of 155 metres is a highly dominant visual presence which will have a majorly adverse visual impact. The proposed development would be visible from miles around, straddling The South Leinster Way and easily seen from the picturesque Arrigle Valley. 

• I strongly dispute that noise is not a factor once a home is situated 500 km away. The mandatory minimum is woefully inadequate due to the Wind Energy Guidelines of 2006 being completely outdated and unfit for purpose. In the peer-reviewed report by Nina Pierpont M.D., PhD of John Hopkins University, she identifies a condition known as ‘Wind Turbine Syndrome’ which commonly affects those living within a two kilometre radius of turbines. This syndrome occurs as a direct result of the turbine infrasound and low frequency noise. This particular development proposes turbines as close as 750m to homes in the community. Furthermore, the unacceptable level of noise caused by turbine infrasound and low frequency noise is known to cause sleep disturbance and migraines.Diminishment of normal and natural enjoyment of property, both inside and out, would result from this development. There would be prolonged and extensive noise and disturbance resulting from the construction of the turbines and all its associated infrastructure. People who are on the autistic spectrum are more susceptible to the mechanical noise and infrasound associated with wind turbines

• The area in which the development is proposed is home to bats, red squirrels, pinemartens, hares, foxes, deer, pygmy shrews, frogs, toads, lizards, owls, buzzards, kestrels, numerous butterflies and many native species of wild flowers and plants. All these species would have their habitats irretrievebly damaged. There are also many stud farms in the region.

• There are sights of significant historical importance on or around the area development, notably St Molin's Well and St Molin's Cave. 

• This proposed development would be a profoundly negative element on our landscape. I strongly dispute the contention of the developer that this proposed wind farm would be of enduring economic benefit to the locality. How could it be when the the house valuations of the 141 households within a 2 km radius would be slashed by one third? This figure is supported by many studies and confirmed by local auctioneers. The promise of walkways and cycleways through an industrial sized wind farm is nonsensical. Why would anybody want to walk or cycle through an industrial sized wind farm when there are currently many beautiful walks available in Kilkenny's-thus far-beautiful countryside?

For the above reasons, I respectfully submit that the designation of the land which is subject to this proposed development is NOT changed to "Acceptable in Principle" as it is completely unsuitable for large scale wind farm development.

Tara Heavey

• Planting more trees in our rural towns and villages can help mitigate the effects of climate change. A big effort should be made to plant more in towns with a low tree count . As well as removing carbon from the air, trees also provide shade during warm weather, help prevent excess run off of water into our rivers, and can help prevent damage to homes during storms by acting as a wind barrier.
• Rewilding native forests and bogs can help boost biodiversity as well as help slow the run off of water into our streams and rivers therefore helping reducing the risk of flooding in our villages and towns. They also store large amounts of carbon. Supporting the re-wilding of our landscape will bring many benefits to the county. 
• Working with and incentivising farmers will be important for the re-wiliding of our landscape.
• Promoting the health benefits of walking and cycling, and improving cycling and walking infrastructure in our towns can help towards reducing car emmissions. 
• Having car free zones outside schools during drop-off and pick up times have proven to be popular in Dublin and their introduction in Kilkenny would be a big positive. Idling car emit excess emissions as well as increase air pollution at schools during drop off and pick up times. 
• Micro-Forests, or Miyawaki Forests, are an increasingly popular way of planting trees in urban areas across Europe. The technique used to plant micro forests allows the trees to grow faster than traditional methods, and allow the trees to take more carbon from the atmosphere than through traditional methods. They are great for biodiversity also. They would be a good addition to suitable areas of Kilkenny city.

• A reduction of the speed limit to 30 km/h should be introduced in our town centres and outside all of our schools. This makes it safer for pedestrians and reduces the chances of accidents.
• Protected cycle lanes should be constructed in our rural towns especially on roads close to schools.
• Suitable bicycle parking infrastructure needs to be constructed in our towns.
• Many of our towns, like Castlecomer, have car park spaces that are frequently unused. Removing even a small number of spaces would allow more space for outdoor seating or space for bicycle parking. 
• A rural bus scheme connecting our rural towns to each other and Kilkenny City would be a big step towards reducing dependency on cars. 
• "Walking Buses" are a great idea and encourage active travel from a young age. The majority of our rural towns are small enough that children living in them should be able to walk or cycle to school. 

• The "Town Centre First" policy which is a commitment in the current Programme for Government can unlock the potential of our rural towns.
• Getting people living in the centre of our towns will be a boost to local businesses.
• Efforts should be made to convert unused space above shops and businesses on the main streets of our rural towns. 
• The widening of footpaths will allow restaurants and cafes to have seating outside, boosting footfall.
• Upgrading or renovating derelict buildings helps prevent the sprawl of our towns and reduces the carbon footprint that the construction of a new building creates. 
• Investment in active travel will reduce car dependency, reduce traffic, and will boost the health of the countys citizens due to greater air quality in our towns. 

• Fully supportive of the 10 minute city strategy
• Fully supportive of the installation of protective cycling infrastructure being constructed.
• Pedestrianisation of more of Kilkennys streets needs to be implemented. This provides more space for pedestrians and provides space for restaurants and cafes for outdoor seating. 
• An awareness campaign about the benefits of active travel and the ten minute city would be a great step. 
• A map showing the cycle routes in the city and the times it takes to cycle to various locations from the city centre would be a useful aid.
• A bike sharing scheme would help boost cycling as a legitimate way of getting around Kilkenny.
• Introducing filtered permeability on residential streets can help reduce rat running and car dependency. 
• Improved cycling and walking infrastructure will help reduce car dependency and car ownership levels, especially for households with two or more cars.  

On behalf of the Suit Valley Environmental Group, whose membership has  concerned citizens from many areas of the Suir Valley / Sliabh na mBan , Knockroe area. We have a large membership from areas including Kilsheelan,Kilcash,Grangemockler,Ballyneale,Faugheen ,Newtown Upper, Ahenny, Tullahought,Fethard,Clonmel,Carrick-on-Suir, Clogheen, Piltown and many other areas.

I wish to make the following submission:

The Draft Plan states,

''11.5.1 Current Status and Targets

In line with the Climate Action Plan, this Renewable Energy Strategy aims to enable Kilkenny to generate the equivalent of 100% of its electricity needs from renewable sources by 2030, including wind energy.  According to the SEAI[1], by 2030 the electricity demand for County Kilkenny is expected to be 633GWh. The gap to meeting the target through renewable energy is currently 500GWh, equivalent to approximately 48 new 4.2MW turbines, representing 201 MW. Kilkenny currently has approx. 76 MW of installed wind energy, generated by 39 turbines.  It is however expected that the renewable energy target will be met by a mix of renewable energies, in which solar will play a significant role (see solar below), thus removing dependence on wind and reducing the number of wind turbines required significantly.''

There is an assumption in this statement that adding more wind turbines will automatically increase the available electricity to the required 500GWh. But adding more intermittent unreliable wind power only adds to the difficulty of a stable supply. As wind turbines only produce electricity 30% of the time when wind speeds are suitable, these times may not and most often do not correspond to the times of the day when maximum supply is needed. Its not much fun sitting down to watch television or have your warm meal only to discover because the wind isn't blowing  you may have to do with raw bacon and cabbage and a blank screen. All Wind Energy needs a spinning reserve of a fully reliable electricity generation to be able to take over when the wind doesn't blow. So we need allmost double the generating capacity to accomodate wind with all the additional massive cost of billions of euro for generation and transmission from dispersed wind turbines. So the reduction in CO2 emissions is far less than envisaged.Dr Fred Udo also explains this with figures from our grid operators Eirgrid

The basic point is that Wind Energy is a very variable and unstable way to produce electricity and as such should not be seen as free electricity. I would refer you to the following  by highly renowned Dutch Wind Scientist Dr Fred Udo who explains the pitfalls in the following extract from his presentation. He states :

The efficiency of wind to decrease CO2 emissions was calculated to be less than 40% compared to the Nominal Saving. This number is based on the CO2 emissions calculation of Eirgrid.  This calculation has some serious deficiencies, which are discussed in section 5.

Note.Eirgrid published the 15’ data in the period 2010 to 2014. The data are not anymore available on the Eirgrid website.

5c. Grid operation analysis with and without wind.

The fuel saving due to wind power in the Irish electricity grid has been investigated by the Sustainable Energy Authority of Ireland (SEAI) for the year 2012.

The title of the report is:

Quantifying Ireland’s Fuel-and CO2-Emissions Savings from Renewable Electricity in 2012

The report analyses the influence of 15,2% wind contribution on the performance of the fossil fuel generators in the All Island area. It is readily available on the website of the SEAI.()

The SEAI 2012 report describes the performance of the complete All-Island grid in 2012. It then compares the performance of the grid with a scenario in which the wind contribution is removed. This work was done with the help of the Plexos program. This is a program used by many electricity companies around the world to analyse the performance of distribution grids.

The main SEAI result is quoted on page 29 of the report:

“Figure 15 shows, that the levels of wind on the system in 2012 had the effect of reducing the total electricity system emissions intensity by 12% relative to a case where all wind generation was removed.”

The contribution of wind was 15,2% according to the SEAI definition, so the efficiency for saving fuel is the ratio of these two numbers. This results in 12% / 15,2% = 0,79 of the Nominal CO2 Saving.

Here the report writes history, as this is the first time a government body admits that the “Nominal CO2 Saving” is not attained in practice.

The full presentation which was organized by the Suir Valley Environmental Group is available on the following link :

fredudo.home.xs4all.nl › Zwaaipalen › Home

PROTECTING OUR HERITAGE:    It is essential in any County Development Plan to recognise in a definitive way the wonderful natural God given beauty that is our inheritance and to see and value what we are blessed to possess and not to in any way ruin or destroy what is the breathtaking beauty that is ours to enjoy. It is our duty to pass it on to the next generation in an enhanced  condition  while guarding its natural beauty, protecting its glorious historical features  for all who live in,  visit or pass through this mystical wondrous, fertile and enthralling Counties of Kilkenny and Tipperary which we are most fortunate to call our home.

To those of us living in the area on both sides of the Lingaun valley which is both County and Provincial and Diocesan border there is a natural enclosure which we feel should be protected. 

Historical, cultural and environmental interconnectivity between counties Kilkenny and Tipperary. Slievenamon Mountain which dominates the valley and the circle of hills which form a natural enclosure of the area.

• The Lingaun River which rises on the slopes of Slievenamon and flows through the valley the bounding line between parishes, counties, provinces and Dioceses.

The Knockroe Passage Tomb (5,200 BC) which has a winter solstice sunrise alignment on the hills in county Kilkenny and a sunset alignment on the Tipperary hills.kenny and Tipperary include:

• The Kilmacoliver Passage Tomb (5,000 BC) which is aligned across the valley with the Cairn on the summit of Slievenamon. 
• An abundance of  Fulach Fia, Standing Stones and Dolmens. 
• The Western Ossory High Cross’s (8th century) which spans the Lingaun River. The predominant views from The Ahenny high crosses are across the county border to the Kilkenny hills. The Killamery and Kilkieran high crosses are on the Kilkenny side of the border. 
• Carraigmoclear Hill (Tipperary) where a group of United Irishmen were ambushed by Crown forces in 1798, the slain rebels are interred in the nearby Killamery churchyard in county Kilkenny.
• This whole area which is protected in the previous plan should continue to be protected as it is a wonderful rich historical area which is dominated by the wonderful Sliabh na mBan and encompasses all the surrounding hills which are all associated with the mystery and beauty of this mountain.
• Nobody in their right mind would consider allowing the parkland of Kilkenny Castle to be eligible for wind turbines so why should Sliabh na mBan / Lingaun Valley / Knockroe area be any less protected, as its historical significance has far greater timespan.

I believe that Sliabh na mBan mountain and surrounding foothills, Kilkenny hills overlooking Killamery, Windgap, Lamogue, Kilmoganny, Hugginstown, Templeorum, Owning and Tullahought and the area enclosed by these hills and the Tipperary border should be zoned as being unsuitable for wind turbines and should be fully protected in any future Kilkenny Development Plan

Thank you for the opportunity to contribute to the The Kilkenny City and County Development Plan,

Milo Power

(Chairman Suir Valley Environmental Group)
 

Please find planning submission for inclusion of lands in Gowran Settlement Boundary. 

Dear Kilkenny Local Authority

Carlow Kilkenny FC was an Initiative between the Kilkenny District League and the Carlow & District Juveniles League in 2017. It was agreed that a Club Independent of both Leagues would be formed to provide a pathway to National League Football for all our young players and allow them to stay in their local areas to do so. We affliated an Under 15 side to compete in the National League in 2018 and since then we have grown incrementally to include underage girls teams. In the 2021 we will have 5 teams competing across Under 14, Under 15, and Under 17 Boys and Under 17 and Under 19 Girls. We also have plans in place for 2022 for an Under 19 Boys team to complete our Underage squads. 

Our ultimate goal is to have a Senior Men’s and Ladies Team playing in the League of Ireland and in order to do that we would require a UEFA Standard Stadium. Currently there is a Stadium which has the basic infrastructure, Buckley Park, which is in Private Ownership. Buckley Park is currently zoned for Sporting/Community usage it is imperative that this remains the same.    It must also be noted that Public funding through Sporting Grants went into the Football Ground through the years which was the home of EMFA/Kilkenny City FC who playing in the League of Ireland from 1985-2007. Grant aid would have been based on the fact there was a sporting and community need then now and into the future.

In order to ensure that Kilkenny can have a quality football/soccer facility for players of all abilities including elite players, it would be good if all the stakeholders, Carlow Kilkenny FC, Buckley Park site owners, FAI, Kilkenny and District League, Sport Ireland and Kilkenny County Council could come together to secure a long term future for Buckley Park. Carlow Kilkenny FC would welcome this development as we could provide the most important key ingredient an Anchor Tenant. As the site is near the Western Environs project there is capacity to grown a League of Ireland Club as with the building of  new Schools and Homes that would be a potential supporter base that could be developed over the coming years.

 In order for any of this to happen Buckley Park, Tennypark, Derdimus, Callan Road County Kilkenny needs to remain zoned for sporting use.

Regards

Paul Brophy

PRO Carlow Kilkenny 

--

Paul Brophy

Inclusion of serviced clusters in Rural Nodes 

Wind Energy Zoning

Stoneyford Area Plan 

Please find attached my submission regarding the Draft Development Plan with regard to the Draft Wind Energy Strategy.

• Rath Ullórd is located at the outer urban edge of Kilkenny City and presents as an attractive low density residential area adjoining the outer boundary of the City (N77 Ring Road) and alongside extensive rural lands to the NE and the Kilkenny Golf Club amenity to the NW.

◦ Section 6.5 of the Draft Plan (Housing Strategy) supports low density residential uses: 'Although not precluded but discourged from central areas, lower density three to four bedroom semi-detached and detached family homes are best suited towards the urban periphery...It is important that private households are able to find a range of opportunities to express their lifestyle needs through housing within the City's boundaries and town and villages and not only through one-off rural houses'.

• A number of planning permissions exist which seek the consolidated development of a predominately low density landholding. A change to permissible densities via the new proposed land use zoning objective will undermine this overall plan for the site through subsequent applications for high density development.

• The dilution of an established low density residential estate will not accord with the following provisions of the Draft Plan:

◦ Section 13 of the Draft Plan strategic aim: 'to conserve and build upon positive elements in the built and natural environment, and to protect amenities'

◦ Section 13.3 – The Council seeks to: 'ensure that all new developents enrich the qulity of its surroundings which means encouraging a distinctive response which complements the setting...Creating a distinctive sense of place, taking into account site history and setting, is important.'

• Lands not suitable for higher residential density given the relative distance to the City Centre and lack of significant public transport investment.:

◦ There is no frequent public transport directly from Rath Ullórd to the City Centre which would be required to support a higher population density.

◦ Rath Ullórd remains outside the '10 minute' walkable City and is thus not suitable for high density of development.

• National Guidance remains that residential development should be planned and provided in close proximity to the main employment generators where possible with some low-density

Overall, changing the developemnt plan for this estate mid development undermines every resident within the estate and what they were sold. As a Kilkenny county Coucil local authority employee i am fully aware my responsibilities to the public whom i serve, Kilkenny County Coucil should be very aware of this when they decide on the future of this estate and it resients who they are taked to serve and not enforce upon. No, local aothority or developer should be allowed to diverge drastically from what they set out to do at the start which would completly alter what current resients were pormised and sold. 

St Johns FC 

Dear Sir/Madam,

Please find attached observations on behalf of the Department of Transport in relation to the Draft Kilkenny City and County Development Plan 2021-2027.

Dear Sir/Madam

I attach a submission to the Draft Kilkenny City & County Development Plan 2021-2027 on behalf of the Trustees of St. Kieran's College, College Road, Kilkenny.

To whom it may concern,

I am writing to express my opinion on the Draft Kilkenny City and County Development Plan.
I am extremely concerned at the proposed changes to zoning in the Draft Document in the south west Kilkenny area adjoining the south east of county Tipperary.
I refer in particular in this email to the area of Ahenny. I live in Ahenny and have always admired it's beauty and uniqueness.              

The High Crosses of Ahenny are famous throughout Ireland and are attractive to many tourists to the area. Any monstrous wind turbines would have a detrimental visual impact over the entire village and surrounding areas, even turbines overlooking Ahenny from Tullahought or nearby areas. The ancient mining village of Ahenny is very scenic and there is no room for an industrial power plant out here or anywhere in this vicinity. In fact, I am personally working extremely hard, on a voluntary basis, on the local Tidy Towns committee at the moment, to ensure the village remains beautiful.There is also the Coshel to consider (Knockroe) We would never allow these ancient sites steeped in history to be destroyed by the appearance of giant industrial turbines.

The shadow flicker effect upon our homes would be extremely harmful. This can become a nuisance to people who live in homes that are directly next to the wind turbine because they will frequently experience the flicker of shadows through their windows at various times of the day. This can become very annoying because the shadow flicker can cause strains in vision or even headaches to the people who are affected. This is a serious health concern and extremely annoying at the very least.
I would question the logistics of even considering any industrial sized turbines to be allowed into our area when the roads are so narrow. Indeed, it is extremely difficult for cars to fit and many residents complain of having nowhere to pull in when two cars are passing.
I support renewable energy and would sincerely hope that Ireland meets it’s targets but I believe that offshore is the correct location for these giant turbines and not on top of people’s homes and villages.
To protect our beautiful and ancient village, it is vital that the entire area surrounding Tullahought and Ahenny be deemed unsuitable for wind turbines.

Thank you for the opportunity to contribute to the consultation on the draft Kilkenny City and County Development Plan.

Yours Sincerely,

Edmond Cody

 

Please see attached our submission to the Draft Kilkenny City Development Plan 2021-2027 on behalf of IMC Cinemas, Astor House, 29 Lower George’s St. Dun Laoghaire, Co. Dublin who own the Old Mart Site in Kilkenny City.

Newpark upper/Eastern Environs area of Kilkenny City 

Awaiting revised submission at the request of John Dumecz Chairman Newpark AFC Kilkenny

To whom it may concern

I attach herewith submissions in relation to the Draft Plan on behalf of my client Mr Michael Anglim and his lands at Callan and Thomastown.

Feargall Kenny  

The Planning Department, Kilkenny County Council, County Hall,

Draft Kilkenny City and County Development Plan

To whom it concerns,

Thank you for this opportunity to comment on the Draft Kilkenny City and County Development Plan.

I am extremely concerned at the proposed changes to the wind energy strategy in the Draft Document in the south west Kilkenny area adjoining the south east of county Tipperary.

This is an area renowned for its historic sites from our recent history and dating back 6,000 years. These historic and cultural gems are dispersed throughout the area creating a rich tapestry set in terrific scenery.

To those of us living in the area on both sides of the valley there is a natural enclosure which we feel should be protected.

Historical, cultural and environmental interconnectivity between counties Kilkenny and Tipperary include:

· Slievenamon Mountain which dominates the valley and the circle of hills which form a natural enclosure of the area.

· The Lingaun River which rises on the slopes of Slievenamon and flows through the valley the bounding line between parishes, counties, provinces and Dioceses.

· The Knockroe Passage Tomb (5,200 BC) which has a winter solstice sunrise alignment on the hills in county Kilkenny and a sunset alignment on the Tipperary hills.

· The Kilmacoliver Passage Tomb (5,000 BC) which is aligned across the valley with the Cairn on the summit of Slievenamon.

· An abundance of  Fulach Fia, Standing Stones and Dolmens.

· The Western Ossory High Cross’s (8th century) which span the Lingaun River. The predominant views from The Ahenny high cross’s are across the county border to the Kilkenny hills. The Killamery and Kilkieran high cross’s are on the Kilkenny side of the border.

· Carraigmoclear Hill (Tipperary) where a group of United Irishmen were ambushed by Crown forces in 1798, the slain rebels are interred in the nearby Killamery churchyard in county Kilkenny.

· The historic Ormonde and Victoria Slate Quarries (19th/20th century) located on both banks of the Lingaun River.

· A strong equine industry with prominent horse breeding and training facilities located in the valley in both counties.

· The Lingaun Valley Tourism Group whose members are drawn from both counties and who work to promote and protect the heritage sites of the area and develop it’s tourism potential.

Other sites of intrest in the area include the (Michael Hogan and Tom Kiely memorials in Grangemockler and Ballyneale, Kilcash Castle in Tipperary) and the Windgap Grotto and Lamogue Ogham stones in Kilkenny).

This natural enclosure is created by Slievenamon ant its foothills to the north to Nine Mile House and to the south over Faugheen is mirrored in Kilkenny as the hills complete a circle from Nine Mile House via Windgap, Brown Mountain, Owning and Baunfree.

These hills are currently zoned unsuitable for turbines in both counties and this must continue to be the case, furthermore the area enclosed inside these hills should also be protected.

Living by choice in a quiet rural area I am dismayed that anyone would consider allowing these giant turbines in such a beautiful and historic area.

I believe that the Kilkenny hills overlooking Killamery, Windgap, Lamogue, Kilmoganny, Hugginstown, Templeorum, Owning and Tullahought and the area enclosed by these hills and the Tipperary border should be zoned as being unsuitable for wind turbines.

Thanking You.

Kind regards

Mairead Sheehan

Wind energy strategy

To Whom it concerns,

Please confirm receipt of submission.

Regards

Seamus Norris

To whom it may concern, 

I am emailing to be another person heard saying that Kilkenny badly needs a Multi-purpose sports facility.

Our wonderful city is growing but the lack of facilities is really seen in the city specially for the children who play minority sports. Three of those children belong to me and they play ice /inline hockey with kilkenny Storm club. They love it and are very good at it. The club provides really good coaching and there are many many opportunities for competitive games. 

Currently we travel to Longford or Cork to play as there is nothing nothing suitable in Kk. 

Please, please take a look at what could be offered for minority sports in kilkenny and ģive my children and so many others a safe place to train. They are training in St Canines Hall which is not suitable. 

Do what is right and give more credence and funding to minority sports.

Warm regards

Nicki Ward

My proposal is in support of a local Multi-sports facility that caters to the minority sports sector.

Attached are photos of my son. The 1st shows his very first day training with Kilkenny Storm Ice & Inline club, aged 7. The 3rd shows him in Liege, Belgium where he spent his Transition Yr, schooling there and playing ice hockey for Liege Bulldogs. What a life experience for a boy of that age!

This oppertunity was only available to him as a direct result of Kilkenny Storm Hockey club. Shortly after the 1st pic was taken in OLoughlin Gales Hall, KK Storm was told they were no longer welcome as the facility had received a grant to upgrade flooring ect and our sport would cause damage to the new interior. Training then moved to St Canices Community Hall, Granges Rd. Whilst we are grateful for this venue it is substandard and remains unsuitable.

Additionally, because of his involvement in Ice & Inline hockey our son was offered a fully paid scholarship to private Marist High School, Chicago last Sept. Unfortunately due to covid this could not happen but we are hopeful that he will start this Sept.

All these amazing opportunities because of his involvement with Kilkenny Storm.

How many other children could avail of these amazing opportunities, in various minority sports, if a decent facility was available for them to develop their skills and love of sports?

Even if the children do not achieve the level if success our son has, just the involvement & oppertunity to try sports that are not mainstream. These sports have facilities in abundance.

Kilkenny is growing in population and sporting facilities need to grow too. A Multi-Sports facility that accomodates minority sports is long overdue.

Yours sincerely

Marilyn Young

◦ Section 6.5 of the Draft Plan (Housing Strategy) supports low density residential uses: 'Although not precluded but discourged from central areas, lower density three to four bedroom semi-detached and detached family homes are best suited towards the urban periphery...It is important that private households are able to find a range of opportunities to express their lifestyle needs through housing within the City's boundaries and town and villages and not only through one-off rural houses'.

• A number of planning permissions exist which seek the consolidated development of a predominately low density landholding. A change to permissible densities via the new proposed land use zoning objective will undermine this overall plan for the site through subsequent applications for high density development.

• The dilution of an established low density residential estate will not accord with the following provisions of the Draft Plan:

◦ Section 13 of the Draft Plan strategic aim: 'to conserve and build upon positive elements in the built and natural environment, and to protect amenities'

◦ Section 13.3 – The Council seeks to: 'ensure that all new developents enrich the qulity of its surroundings which means encouraging a distinctive response which complements the setting...Creating a distinctive sense of place, taking into account site history and setting, is important.'

• Lands not suitable for higher residential density given the relative distance to the City Centre and lack of significant public transport investment.:

◦ There is no frequent public transport directly from Rath Ullórd to the City Centre which would be required to support a higher population density.

◦ Rath Ullórd remains outside the '10 minute' walkable City and is thus not suitable for high density of development.

• National Guidance remains that residential development should be planned and provided in close proximity to the main employment generators where possible with some low-density

In conclusion, altering the plan for this estate betrays every resident living in the estate and what they were promised through planning. Developers or councils should not be allowed to diverge from the orginal plans.

Wind Energy Strategy

• Rath Ullórd is located at the outer urban edge of Kilkenny City and presents as an attractive low density residential area adjoining the outer boundary of the City (N77 Ring Road) and alongside extensive rural lands to the NE and the Kilkenny Golf Club amenity to the NW.

◦ Section 6.5 of the Draft Plan (Housing Strategy) supports low density residential uses: 'Although not precluded but discourged from central areas, lower density three to four bedroom semi-detached and detached family homes are best suited towards the urban periphery...It is important that private households are able to find a range of opportunities to express their lifestyle needs through housing within the City's boundaries and town and villages and not only through one-off rural houses'.

• A number of planning permissions exist which seek the consolidated development of a predominately low density landholding. A change to permissible densities via the new proposed land use zoning objective will undermine this overall plan for the site through subsequent applications for high density development.

• The dilution of an established low density residential estate will not accord with the following provisions of the Draft Plan:

◦ Section 13 of the Draft Plan strategic aim: 'to conserve and build upon positive elements in the built and natural environment, and to protect amenities'

◦ Section 13.3 – The Council seeks to: 'ensure that all new developents enrich the qulity of its surroundings which means encouraging a distinctive response which complements the setting...Creating a distinctive sense of place, taking into account site history and setting, is important.'

• Lands not suitable for higher residential density given the relative distance to the City Centre and lack of significant public transport investment.:

◦ There is no frequent public transport directly from Rath Ullórd to the City Centre which would be required to support a higher population density.

◦ Rath Ullórd remains outside the '10 minute' walkable City and is thus not suitable for high density of development.

• National Guidance remains that residential development should be planned and provided in close proximity to the main employment generators where possible with some low-density

Overall, changing the developemnt plan for this estate mid development undermines every resident within the estate and what they were sold. Kilkenny County Coucil should be very aware of this when they decide on the future of this estate and it's residents who they are tasked to serve and not enforce upon. No, local authority or developer should be allowed to diverge drastically from what they set out to do at the start of any project or residential planning scheme which would completly alter what current residents were promised and sold.

Wind Energy Strategy