County Development Plan Review, Planning Policy and Projects Unit, Tipperary County Council, Civic Offices, Clonmel, Co. Tipperary. E91N512

Re: Tipperary County Development Plan Review

2022-2028 Public Consultation Submission

To whom it may concern,

I am writing this submission on behalf of a local Action Group. I am writing to express my opinion, on behalf of our group, on the Tipperary County Development Plan Review. It is our strong belief that the area of Ahenny 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. ((Redacted Personal Information), 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. 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 (Redacted Personal Information) 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

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