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.