Submission on the A Draft National Landscape Strategy
for Ireland 2014-2024
To begin with I am a member of the Suir Valley Action Group who are an
environmental group set up in 2013, on the back of the GridLink project, to inform
and educate local communities as to proposed infrastructure developments planned
within their environs.
What is Landscape? Is it as defined in the above mentioned document –
Landscape is a key element of individual and social well-being; it contributes to the
formation of local cultures and it is a basic component of the European natural and
cultural heritage
Heritage and culture are not independent of ecological issues and they along with the
landscape should be at the centre of any environmental thinking and planning. With
the broadening of the Landscape debate the question then arises – who should decide,
define and control what the strategy should be?
Bearing this last question in mind the EU directive to which Ireland is only now
responding is opened up to the public. This is a public who has grown weary with the
lack of enforcement of other EU directives that are meant to protect them; the
ignorance of the Aarhus convention which states that the public must be fully
informed of all planning and proposed developments that will influence how they can
use their local environment and cognisance taken of Special areas of Conservation
(SAC) and special areas of protection (SPA). We have these areas but then the public
sees An Bord Planeala riding roughshod over valid concerns raised by one of their
own as it were and allowing a wind turbine development in the Silvermines area. This
area not only is of environmental importance for the Hen Harrier but as part of out
cultural and heritage it ought not to be ignored for the sake of private developments.
The whole economy and settlement pattern of North Tipperary as part of the heritage
of the county was influenced by the Silvermines. Likewise South Tipperary has its
heritage based on the Golden Vale and agriculture, transport on the Suir, timber
production from the hills around Clonmel – these all make up the culture and the
heritage of the area and have shaped the landscape.
Here in the Suir Valley (East Tipperary / Kilkenny / Waterford borders) we are being
forced to consider the possibility of two GridLink corridors and a proposed Wind
farm development in an area that is considered in the South Tipperary Development
Plan 2009 as being a Secondary Amenity Area, an area of High Sensitivity, and the
Lignaun River valley is considered as Special Area of Conservation. The
Slievenamon Bog is considered a Heritage area and a Special Area of Conservation,
Kilcash Castle is a protected structure; Glenbower Hill is a conservation area and
there are protected views from Kilsheelan to Slievenamon and from Slievenamon to
Knockmealdowns. Although these proposed developments are not in the Special Area
of Conservation areas they will be highly visible and will impact upon the scenic
amenities of the areas in question, the habitats and the environment.
The above mentioned protections are very laudable but stroll over the border into
Kilkenny and they are far more aware of the amenity value of their landscape not only
in the heritage that it encompasses but also in the value to tourism and local
businesses in the hospitality market. Just over the river Suir and we are in county
Waterford where again a different set of constraints apply, some of which have EU
status as opposed to just of local interest. As such where in Ireland are there protected
‘Areas Of Outstanding Natural Beauty’?
Here is where there should be a contiguous strategy, just because one crosses a county
boundary it does not mean that the landscape on the other side is of any less
importance – if anything it is more important in order to retain the overall feel and
look of an area.
So here in the Suir Valley it is the entire environ that makes it a secondary amenity
area; the views from the top of Slievenamon over to the Knockmealdowns and vice
versa. The view from the Vee down the valley across to the Galtee Mountains, it is
not just the few square miles on the side of the hill – it is the entire landscape and
culture. You have to look at the entire system as a dynamic process and what happens
if you change one bit how it affects, or what happens to the whole. You have to
change your perspective not just looking locally but also seeing how local decisions
affect the national and the inverse as well.
At the moment from the top of Slievenamon, where one had a view of 10 counties
which were unspoiled, you now see Wind Turbines within 10miles and even those
over in Wexford.
Looking at the constraints maps for the county council (using Tipperary as an
example) there was and is a huge variance with what councils in North and South
Tipperary found to be of importance; similarly with Carlow and Kilkenny.
Taking South Tipperary for example the Bog on Slievenamon is protected as are the
views across the valley, photos of which are used in the amenity book that the council
produced on the local environs. Well to ensure that the bog is protected one also has
to maintain the integrity of the hinterland around it to ensure that the local habitats
and wildlife are not decimated. South Tipperary County Council, that was, just
excluded the mountain of Slievenamon from wind development however, when you
look at the bigger picture it would be criminal to put turbines in the Suir Valley due to
the diverse ecosystem that is here and the endangered wildlife that call the Suir Valley
home. This needs to be rectified so that areas are not just arbitrarily found to be
suitable for wind / other electricity generation projects without a full investigation.
Like wise the proposed development shown above sits between two environmentally
sensitive and heritage areas – on paper it looks ok if you are just looking at a map but
look beyond that and that area is a corridor for endangered species to use; it is an area
of visual amenity; it is in the middle of the cycle route that are being promoted
throughout the county for tourists; visible from ireland’s only Tudor Manor House in
Carrick-On-Suir. Where local councils and community groups are endeavouring to
maintain the natural fabric and framework of an area they need to be supported and
have sustainable guidance that they can rely on safe in the knowledge that some
‘higher power’ is not going to disregard local project and amenities.
Your landscape is what you make it, the industrial areas of Dublin and Cork have
their own equally valuable historical records of how the country has developed. Some
of this does need to be maintained rather than ripped down and the areas turned into
flats or huge warehouses thrown up.
Everyone has their own ideas of what makes the landscape; I agree that it cannot be
protected in cotton wool and there has to be some development but it has to be
empathetic to the area concerned taking cognisance of local history and possible
developments in technology in the future.
However, if an industrial development goes ahead in a rural area – let’s use wind
turbines as an example, when their life is finished there is in theory the requirement to
return the land to how it was prior to development. How can we be guaranteed that
this will happen, where is the regulator to over see this, how much power is the
regulator going to have? If down the line it goes to court and the judge feels that there
was ‘insufficient guidance’ from the regulator at the outset the company being asked
to restore the areas may get off with leaving huge buried piles of steel and concrete in
our historical bogs and sensitive areas. This is an unacceptable state of affairs.
So on reflection:
1 – How long is it going to implement this Landscape Strategy? What is the
timeframe?
2 – How is this going to be paid for? I believe funding from the EU for this may have
been re-directed into infrastructure projects which would be wholly unacceptable.
3 – Who is going to regulate the new Landscape Strategy? One would hope that it will
be an independent person and will not be left to the fox to guard the hen house.
4 – Will there be legal obligations and penalties for developers not adhering to the
Landscape Strategy? How will same be implanted and enforced and by whom? Will
members of the public be able to take a developer to task without onerous court
expenses?
5 – Will ‘Areas of Outstanding Natural Beauty’ and ‘Areas of Special Scientific
Interest’ be approved and if so will the public be able to put forward cases for the
same?
6 – Will any protected areas also receive full cognisance from An Bord Planeala and
County Councils to prevent industrialisation of same; the existing areas be maintained
and the full hinterland and ecosystems supporting the SACs & SPAs be taken into
consideration in planning applications as well.
Consequently, since there is an inadequate and unequal Landscape strategy from
county to county at the moment, I would call for a moratorium to be enforced on all
wind farm developments until the new Green Paper on Energy is fully reviewed and
the Landscape Strategy is fully implemented and integrated into all county
development plans.
Sacha Maxwell
Slievenamon Holistic Therapy
Co Tipperary