An Bord Pleanala
64 Marlborough Street
3rd March 2021
Re: Proposed development in the townlands of Lyrenacarriga, Co. Waterford and the townlands of Lyremountain, Co. Cork
This planning application proposes the construction of up to 17 no. wind turbines with a maximum overall blade tip height of 150 metres, 1 no. meteorological mast with a maximum height of 112 metres, and associated works and structures in an exposed upland location on the borders of Counties Cork and Waterford.
The Irish Georgian Society wishes to object to this planning application as it would have an adverse effect on the sensitive landscape in which is proposed. Furthermore, together with other proposed windfarms in the vicinity it presents a cumulative threat to the special character of the Blackwater River Valley, one of Ireland’s most picturesque landscapes.
It is noted that both the Waterford County Development Plan and the Cork Country Development Plan provide for the protection of the scenic value of the area that is the subject of this planning application.
Waterford County Development Plan
The Waterford County Development (A9 Scenic Landscape Evaluation) defines the sensitivity of landscapes on the basis of the capacity of the receiving environment to absorb new development. In doing so it categorises the proposed development site as being ‘Sensitive’ and ‘Visually Vulnerable’. These landscape classifications are described in the Plan as follows:
Sensitive: Distinctive character with some capacity to absorb a limited range of appropriate new developments while sustaining its existing character.
Visually Vulnerable: Very distinctive features with a very low capacity to absorb new development without significant alterations of existing character over an extended area.
In setting out policy with regards to development in such areas the Plan states that development in landscapes designated as Sensitive “must demonstrate an awareness of… inherent limitations by having a very high standard of site selection, siting layout, selection of materials and finishes” (6.2(a)). It furthermore states that development proposals for areas designated as Vulnerable…
must be shown not to impinge in any significant way upon its character, integrity or uniformity when viewed from the surroundings. Particular attention should be given to the preservation of the character and distinctiveness of these areas as viewed from scenic routes and the environs of archaeological and historic sites. (6.1(a))
The Irish Georgian Society contends that the construction of 17 no. wind turbines in a landscape designated as Sensitive and Vulnerable would not constitute a visually sympathetic form of development but instead would see the construction of industrial structures in a sensitive rural landscape. As such, the proposal does not comply with the provisions of the Scenic Landscape Evaluation of the Waterford County Development Plan.
In considering these Sensitive and Vulnerable landscapes, the Irish Georgian Society notes that the Development Plan highlights how Waterford offers:
…an attractive tourist product that builds on the natural beauty of the County… [and] attracts discerning tourists who seek a quality product and experience. (6.11 Sustainable Tourism)
It describes the Blackwater Valley as one of the County’s principal draws and in Policy ECD 18 aims to:
continue building on the strengths of the County, giving priority to sustainably developing the tourism product etc… 6.11 Sustainable Tourism
Furthermore, the Plan states that:
Many of the top visitor attractions in the County, such as… the River Blackwater … owe their attraction to their spectacular beauty and setting. It is important to enhance these areas for their continued development in the tourism industry, while at the same time protecting and conserving the qualities that make these areas attractive in the first instance. Waterford County Council will promote a sustainable approach to the development of the tourism sector while protecting the built and cultural heritage which forms the resources on which the County’s tourism industry is built upon.
6.12 Sustainable Tourism and Recreation
Given the detrimental visual impact the proposed wind turbines would have on the landscape not just of the immediate area but also of the broader Blackwater River Valley, it would seem evident that their construction would be contrary to the stated objectives of the County Development Plan and so they should not be granted planning permission.
Cork County Development Plan
The road between Youghal and Fermoy is recognised for its scenic value in the Cork County Development Plan which designates the section of it running close to the proposed development site as a Scenic Route. It is noted that the Development Plan contains the following objectives relating to such roads:
Objective GI 7-2: Scenic Routes
Protect the character of those views and prospects obtainable from scenic routes and in particular stretches of scenic routes that have very special views and prospects identified in this plan.
Objective GI 7-3: Development on Scenic Routes
a) Require those seeking to carry out development in the environs of a scenic route and/or an area with important views and prospects, to demonstrate that there will be no adverse obstruction or degradation of the views towards and from vulnerable landscape features.
The Irish Georgian Society contends that the introduction of 17 no. wind turbines to the landscape adjoining this Scenic Route would significantly transform the character of views and prospects and would have an adverse effect on the rural landscape. It is noted that the reasons for refusal for a smaller cluster of 7 no. wind turbines at Ardglass, Co. Cork (PL04.246824) included reference to Objective GI 7-2 in the Development Plan. It specifically stated:
…it is considered that the proposed development would have an adverse impact on a designated Scenic Route, that is, Route S44, which it is an objective to protect in accordance with the Cork County Development Plan 2014 – 2020, and would, therefore, be contrary to Policy GI 7-2 of the Development Plan
Given the significant adverse effect of the construction of 17 no. wind turbines on the designated Scenic Route, the Irish Georgian Society is of the view that this development proposal would be contrary to the provisions of the Cork County Development Plan and so should be refused planning permission. It is also noted that such a decision would be consistent with a previous application determined by An Bord Pleanala for a similar though smaller proposal.
In conclusion, the Irish Georgian Society is of the view that this planning application for 17 no. wind turbines would have an adverse effect on the character of the surrounding sensitive landscape and so would be contrary to provisions of both the Waterford and Cork County Development Plans. As such, they would be contrary to the proper planning and development of the area and so should be refused planning permission.
Executive Director IGS