The Irish Government has decided to proceed with building the M50 Southern Ring Motorway section in Dublin which will pass through part of the archaeological site of Carrickmines Castle. The Irish Government has decided to proceed with building the M50 Southern Ring Motorway section in Dublin which will pass through part of the archaeological site of Carrickmines Castle, a Recorded Monument as defined in the Irish National Monuments Act of 1994.
An Environmental Impact Assessment (EIA) on the Southern Ring Motorway (M50), including the Carrickmines section, was undertaken in 1997 (producing an Environmental Impact Statement (EIS)) , and a public inquiry held in 1998. The scheme was approved later that year. €million of European Cohesion Fund money was approved by the Commission in April 2001.
Following the EIS, an archaeological dig began on the site in August 2000. This excavation lasted until August 2002 and uncovered evidence confirming that this site is of much greater historical and archaeological significance than indicated in the EIS. The site is known to have a well-preserved 13th century Norman castle wall enclosing two areas totalling 3 acres of buildings, workshops, houses, kilns, wells, and numerous defensive ditches. The surrounding area of up to 5 acres also contains much material of archaeological significance but only a small part of it has yet been excavated, all of which will be affected by the motorway. The Castle represents one of the border castles of the Norman Angevin Empire, who ruled parts of France, Britain, and Ireland. Very few of these early border castles have been excavated.
An Taisce (Ireland's National Heritage Trust) claims that the appraisal of the site prior to construction of the road commencing was inadequate and did not comply with the Environmental Impact Assessment Directive. Furthermore, it has now emerged that a 1983 Foras Forbartha (National Institute For Physical Planning and Construction Research) Report carried out by Mr. P Healy on Carrickmines Castle concluded that it was "an important outpost, and although little survives of the buildings, the earthworks are quite exceptional and are worthy of preservation."
That 1983 Foras Forbartha report recommended that any new road "if...placed on the south side of the farm...would avoid any interference with the sites." Taking this report into account the Local Authority at that time agreed a road alignment avoiding the site.
This information was not properly brought to the attention of the public during the preparation of the M50 alignment or at the public hearings which took place as part of the planning process and which concluded in 1998.
Mr. Healy's surveys for An Foras Forbartha are a seminal and obvious source for any study of archaeological monuments in County Dublin. The bibliography of the Sites and Monuments Records for County Dublin (SMR) 1988, includes a select bibliography of 12 publications. Mr. Healy's work for An Foras Forbartha is included.
Further, a coin hoard found in 1995 and recorded in the Irish Antiquities Division archive of the National Museum was found to the east of Glenamuck Road - an area which shows no archaeological remains in the EIS. had the archives of the National Museum of Ireland been consulted the evidence of the Carrickmines coin hoard would have alerted the compilers to the possibility that the monument extended to the east of the Glenamuck Road.
The failure to consult - or to include in the EIS - records held by the National Museum of Ireland or the sites and Monuments Records for County Dublin (1988) constitutes the most serious failure of the EIS.
The 1998 M50 alignment was altered from the route determined in the 1993 County Dublin Development Plan which avoided the Carrickmines Castle site so that it now crosses site. The outcome of the planning process allowed time for an archaeological dig for a one year (extended eventually to two years) while construction continued of the M50 at each end of the site. Up to 130 people were involved in the dig at the time it was brought to a halt on 30 August 2002, and it is estimated that up to 12 months more would be needed to complete that work. More than 90,000 artefacts were found to date.
Because of public outcry about the proposed destruction of this site the Minister for Transport has produced what he describes as a compromise proposal and has expressed himself 'uneasy' with the decision he has made. The variation to the scheme, which was prepared privately within his department and claims to "save" 60% of the site, is not being subjected to a public planning process.
In fact upwards of 35% of the site remains to be excavated and it is estimated this includes upwards of 5000 artefacts. 75-80% of the excavated areas are to be destroyed. This includes all of the areas with the remains of the workshops, wooden houses, mill, kilns, most of the wells and nearly all of the unique and incredibly well preserved 'Revetted Fosse' which runs for 237m.
The EIS of 1997 is in our view invalid and it is therefore improper for Cohesion Funds to be used on this road project as it is based on a document that was fundamentally flawed. If the Irish authorities wish to continue to avail of EU funds for this project they must be obliged to prepare new plans, prepare a full Environment Impact Assessment, including the desk studies that are omitted from the current EIS. Further, there must be a reassessment of the balance between regional development and the cultural heritage of a unique site which has produced the largest assemblage of medieval pottery ever found in rural Ireland.
We request the Petitions Committee of the European Parliament in view of the above information:
To express its concern at the imminent destruction of this archaeological site which is an irreplaceable part of Irish and European heritage and to urge an immediate stop to road construction work which encroaches on the site or which may render it impossible to avoid destroying most of the site.
To call for the completion of the full archaeological dig on the entire site which will require an extension of the completion deadline by at least 12 months.
To call on the Commission to suspend Cohesion funding pending a review of the EIA for this project, and its compliance with Council Directive 85/327 EEC on the Assessment and Effects of Certain Public and Private Projects on the Environment and Council Directive 97/11 EEC, Amending Directive 85/327 EEC.
To call on the Minister for transport to submit his current amendments to the scheme to the full public planning process including a new EIS as they are a substantial variation of the scheme already approved.
Tony Lowes, Director, Friends of The Irish Environment
Professor Sean Duffy, Chairperson, Friends of Medieval Dublin
Re: Complaint P2002/4957 concerning the proposed construction of the South East Motorway in the Dun Laoghaire/Rathdown area of County Dublin and its impact on the archaeological remains of the Carrickmines Castle Complex.
Allihies, County Cork, Ireland
Legal Affairs Division B.3,
The European Commission,
Environmental Directorate XI,
Rue de la Loi, 200,
B-1049, Brussels, Belgium,
February 18, 2003
Re: Complaint P2002/4957 concerning the proposed construction of the South East Motorway in the Dun Laoghaire/Rathdown area of County Dublin and its impact on the archaeological remains of the Carrickmines Castle Complex.
Dear Mr. Cashman;
We write in reference to the above and seek to provide supplementary evidence in relation to point 2 of your letter to the Irish complainants, dated 10 September, 2002.
This point raised the concern that
'in the light of Articles 5(2), 6 and 8 and Annex Ill of Directive 85/337/EEC on the assessment of the effects of certain public and private projects on the environment, the information presented by the developer was manifestly deficient with regard to the archaeological impact of the motorway project and as a result constituted an inadequate basis for public consultation and decision-making.'
To support this statement, we wish to draw your attention to reports we have received under Freedom of Information prepared specifically for this project and the recent affidavits of the Consultant Archaeologist and of the Director of Transport for Dun Laoghaire-Rathdown County Council. These clearly demonstrate that the consultants who compiled the EIS did not themselves properly assess the information available and nor did they provide critical reports, maps, and archaeological records which would have allowed the public to make an informed assessment themselves.
Affidavits were sworn by Valerie J. Keeley, Consultant Archaeologist and author of the EIS and by Eammon O'Hare, Director of Transportation employed by Dun Laoghaire Rathdown County Council in the Irish High Court on 12 February, 2003. [Dominic Dunne and Gordon Lucas [Plaintiffs] and Dun Laoghaire-Rathdown County Council [Defendant] Record No. 1574P/2003]
The reports, studies, meeting notes, and memos relied on below were received under the Irish Freedom of Information Act from the National Museum and from Dun Laoghaire-Rathdown County Council from September 2002 to date.
1. Failure to provide archaeological studies
The Commission should have been provided with the following eight reports which the consultants state are the components of the EIS: [Affidavit of Valerie J Keeley, 10 February, 2003].
September, 1992 Archaeological Paper Survey South Eastern Route Feasibility Study;
April, 1993 Archaeological Survey, Environmental Impact Study, South Eastern Route Motorway;
November 1993 South Eastern Motorway Modified Route B and Route A, Archaeological Draft Report 1;
February, 1996 Archaeological Assessment of Routes A, B and 5, South Eastern Motorway (Final Draft);
April, 1996 South Eastern Motorway Sites Identified in EIS on the Basis of New Maps;
October, 1996 Additional Archaeological Assessment of Route A and 5 South Eastern Motorway Volume;
May, 1997 - Archaeological Assessment Topographical Survey Site 16 South Eastern Motorway;
May, 1997 - Archaeological Assessment Additional Areas Relating to the South Eastern Motorway.
None of these documents were provided with or included in the EIS for public inspection.
None of these documents were provided to the Site Archaeologist to inform his work, and as they were not available in the EIS they could not assist in the correct assessment of the proposed roadway.
In the words of the Assistant Keeper of Irish Antiquities in a memo to the Keeper of Antiquities about the EIS, "The study [EIS] is extremely difficult to evaluate properly because of the very summary level of information presented. [Report dated 16 September, 2002.]
Yet as late as 1 May, 2002, Valerie J. Keeley argued at a 'Meeting on the Completion date for Carrickmines Castle' that 'initial investigations were carried out on the site including aerial and topographical studies and that the site was not questioned during the public enquiry. She is anxious to formalise the time scale.'
It was not possible for the public to question the archaeological aspects of the proposed motorway, as the relevant reports were not made available to the public.
As if the failure to provide these reports as part of the EIS was not in itself such a serious matter, the later use of reports which were not properly reviewed or available to the public to seek a termination of the excavations further undermined the decision making process.
2. Failure to provide relevant documents and archaeological records
Further, three key documents/records were not provided with the advertised EIS.
2.1 Ordinance Survey 1832
The 1832 Ordinance Survey map shows the extent of the Castle grounds as extending into the triangular field omitted in all the subsequent studies. Because the Glenamuck Road was subsequently moved, the later and current editions of the Ordinance Survey map truncate the extent of the castle and only the first edition is accurate. This edition was not referenced in the EIS.
In her Affidavit to the High Court Valerie J. Keeley states 'While the site of Carrickmines Castle is marked on the first edition Ordnance Survey map (1837), it is questionable whether the significant archaeological remains were known at the site since the date, nature and extent of the archaeological remains were determined through the current archaeological investigation and excavation.'
This is simply not true.
2.2 Healy Report
Further documentation to support the 1837 map did exist, in the form of the 1983 Healy Report from An Foras Forbatha to which we have already drawn the Commission's attention.
We have now ascertained that Dun Laoghaire-Rathdown County Council did not hold a copy of this report and in response to our request provided a copy of the Report downloaded from our website which we posted on 16 September, 2002. ['I wish to confirm that the 3 pages as supplied to you as a result of your original request is the full content of the copy of this report as held by this authority. This report was downloaded from the Friends of the Irish Environment website.' Letter from Charles MacNamara, Director of Culture, Community Development & Amenities, Dun Laoghaire-Rathdown County Council, 4 December, 2002.]
2.3 Coin Hoard
Physical evidence was also available at the National Museum of the find of a coin hoard in the triangular field across the Glenamuck Road. The failure of the compilers of the EIS to consult the National Museum archive and so include in their assessment the existence and the significance of the find and the need to excavate this area is a fundamental error.
2.4 Absence of References
When the National Museum received the EIS for the first time in 2002, the Assistant Keeper of Antiquities was asked to analyse the EIS. He wrote:
'A feature of the EIS is the complete absence of any reference either to the National Museum of Ireland or to the Sites and Monuments Record and/or Record of Monuments and Places. One can only assume, in the absence of any evidence to the contrary, that these fundamental documents were not consulted. If this assumption is correct, it constitutes the most serious failure on the part of the compilers.' [Italics added].
'Had the archives of the National Museum of Ireland been consulted, the evidence of the Carrickmines coin hoard would have alerted the compilers to the possibility that the monuments extended east of the Glenamuck Road. Similarly, has the SMR (including the information contained in Paddy Healy's Foras Forbatha study) been consulted, it could have alerted the compilers to the extent of the monument, especially on the north-west side. The original SMP volume for County Dublin (1988) contains a select bibliography of 12 publications, of specific reference to County Dublin, including Mr. Healy's study for An Foras Forbatha. It is not unreasonable to think that had even the SRM volume been consulted, it would have pointed the compilers in the direction of Mr. Healy's work.'
'While it is easy to be wise in hindsight, I do not think it unfair to suggest that a more through approach in the compilation of the EIS could have resulted in a much more accurate assessment of Carrickmines Castle. This, in turn, could have helped prevent the most unsatisfactory position in which we now find ourselves.' [Dr. Andy Halpin, Assistant Keeper of Irish Antiquities, 16 September, 2002.]
3. Failure to correctly assess the Geomagnetic Survey
The most critical failure and the source of much of the later 'unsatisfactory position' was the failure to properly assess or provide for the public to assess the 1996 GeoQuest report prepared using geomagnetic imaging. [Volume II Geophysical Surveys on the Route of the Proposed South Eastern Motorway Dublin, GeoQuest for Valerie J. Keeley, 1996]
The aim of geomagnetic surveys is to reveal remains in the subsoil. Considerable contrast is derived from the fact that disturbance for features such as pit and ditches encourage microbial activity from enrichment after burial and iron oxide production in the topsoil.
The results for this site showed clearly a section of an underground feature, which continued to the limit of the survey - the Glenamuck Road. The failure to continue the survey to determine the extent of this fosse - which is the very fosse scheduled for removal and reconstruction as part of the archaeological salvage operation - is inexplicable. As a result of this failure, the correct surveys were not ordered until 12 February, 2001, when excavation revealed what the geomagnetic survey had shown 5 years before.
That this survey was not properly assessed is clear from the Affidavit of Valerie J. Keeley when she replied to the affidavit of Dr. Sean Duffy, Fellow of Trinity College, Dublin and senior Lecturer in Medieval History at Trinity College. Dr. Duffy states that 'it appears that experts retained by the county council were of the view that the Glenamuck Road constituted the boundary of the Castle. This was a fatal mistake'.
Valerie J Keeley responds that 'Thorough assessments and surveys were conducted by this firm (see paragraph 21) and no distinctive feature was noted which would warrant inclusion in our report as constituting part of the castle outworks in this area. [Italics added] The existence of the structures underlying this area was recognised during the excavation and could only have been established in this way [Italics added] as referred to above.'
Not only was the key 1996 Geomagnetic Survey not included in the information available to the public, but the local authority informed us when we first sought this report under FOI that they did not possess a copy. ['I wish to confirm that at the time of your FOI request that the transportation department did not have a copy. This was a factual statement at that time. However the Senior Engineer Road design section has now informed me he has obtained a copy of this report last week.' Letter from Charles MacNamara, Director of Culture, Community Development & Amenities, Dun Laoghaire-Rathdown County Council, 4 December, 2002.]
This fatal error in the assessment process further undermined the mitigation proposed through excavation, as the Geomagnetic Survey was not supplied to the Site Archaeologist, Dr. Mark Clinton, to inform his work in planning the excavations [pers. com.].
This failure to interpret the Geophysical Survey and understand its importance is evidenced by Valerie J. Keeley's sworn statement that the extent of the castle 'could only' have been determined 'by site excavation'.
That this error is shared by the developer, Dun Laoghaire-Rathdown County Council, is made clear in the Affidavit dated 10 February, 2003 of Eammon O'Hare, Director of Transportation employed by Dun Laoghaire Rathdown County Council who has responsibility for the completion of the South Eastern Motorway: In this affidavit he states simply: 'It is only through the nature and extent of the excavations on site that the extent and importance of the site has been identified.'
The consequence of the failure to correctly read the geomagnetic survey and thus to become aware of the extent of the fosse and so the true perimeter of the Castle Complex was that this important area was not identified by the archaeological team until 12 February, 2001.
On that date, Dr. Clinton wrote to the National Museum
"It is now clear that the southern stone-revetted fosse (the "curtain-wall") is extending into the field to the east of Glenamuck Road. How far to the east we just don't know. What is clear is that the site has now got to expand accordingly.
'Until we find the extent of the eastward thrust of the revetted-fosse, and in particular at what point it turns to the north (and the river), as it must, we will not be able to establish the overall dimension of the castle site and to calculate the necessary amount of time required to resolve the enclosed area.'
The plan of action he proposed included a 'geophysical survey of the entire field in question to see if there is any external activity.'
4. Failure to provide details of mitigation
Further, flawed as it is, the 1996 Additional Assessment which considers the Geophysical Survey reaches the following conclusion:
"The possibility of taking measures to alter the design of the scheme in this area should be addressed, the series of junctions and associated roads covers a very large area and will obliterate the complex. If minimal impact could be achieved this would minimise the scale, time, and expense of conducting the excavation programme now envisaged for the entire site. This is made as the maximum possible recommendation."
Additional Archaeological Assessment of Routes A & 5, South Eastern Motorway, 1996, page 52
This recommendation is the correct assessment for Carrickmines Castle Complex and indeed has proved to be prescient, as the local authority has now spent a total of €6 million on excavations and related costs that would have been rendered unnecessary if the recommendation had been accepted. [Minister for Transport, Press Release, 16 September 2002.]
The public, however, was not provided with this report either.
They were provided instead with a summary EIS which omits the words "obliterate the complex" and states simply that the site will "warrant excavation". The EIS does, however, suggestion that 'The possibility of taking measures to alter the design of the scheme in the area should be addressed'.
This was met with the statement 'consequent on this recommendation Carrickmines Interchange was redesigned to retain the Castle remnant as an open area as possible and to cause the minimum disruption to the more significant areas. It is not reasonably possible to relocate the motorway elsewhere', a comment that appears to be without foundation or substance and is not detailed in 'Alternatives'. [EIS page 260, Table 17.2.1, Site 17].
The dates of the October 1996 recommendations, however, come after the route was identified as part of the EIS process [April 1996]. The 'new maps' were prepared in April of 1996. The recommendation to move the road was contained in the October 1996 Additional Assessment - six months after the route was selected - and a year before the EIS was published. Further, there is no 'Castle remnant' as the site of the Castle remains undiscovered.
The lack of clarity as to the response of the authorities to the recommendation to alter the design is made quite clear in Valerie J. Keeley's Report dated November 2000 entitled 'Archaeological Investigations Carrickmines Great South Eastern Motorway Co. Dublin' [00E0045, the 'Brady Report']. This states in 4.4 'It is understood that the road design is to leave the standing medieval masonry intact and to landscape the area around it so it will be a feature of the public interest within the interchange complex. The details of the landscaping design are not available at present and as such it is not possible to comment on the nature and degree of impact that the work will have on the archaeological landscape.'
If any genuine mitigation by design took place in 1996, why were they not clear to the consultants in November 2000? Further, why did the Minister on 16 September of 2002 announce just such mitigation, calling them 'comprehensive proposals' when ipso facto any proposals which significantly alter change the impact would require a new EIS and the possible changes had been made, according to the EIS?
Even in her recent Affidavit, the consultant states: 'There is no physical evidence of the Castle structure. The Castle was destroyed in or around 1642 and it is to be expected that only subsurface remains exist. Nonetheless these, should they exist, are deemed to be in the area that will not be affected by motorway construction.'
If the site of the castle itself remains undiscovered it is not possible to 'deem' them to be in an area unaffected by this development. [Affidavit of Valerie J Keeley, 10 February, 2003]
Further, substantial documentation exists to suggest that the Castle was not destroyed in 1642 as is repeatedly claimed in the EIS. This documentation includes two contemporary accounts and a 'description in the Civil Survey of the "Walles of a Castle" as being extant in the mid 1650s. In addition, the Down Survey Map would seem to indicate the presence of an apparently complex structure at this site. Again, Rocque's 1760 map of the area illustrated the site as containing a fairly substantial building with two forward projecting end-wings.' [Excavations at Carrickmines Castle: Working Report, Dr. Mark Clinton, 8 November, 2002]
The archaeologist who compiled the EIS has stated in her affidavit that 'It is my professional opinion as an Archaeological Consultant that the archaeological procedures implemented at the Carrickmines site have been shown to be not only proper but most successful.' [Affidavit of Valerie J Keeley, 10 February, 2003]
On the contrary, the information presented by the developer was manifestly deficient not only in not providing for public inspection the eight archaeological assessments listed above, but also in its failure to refer in the EIS itself to the 1832 Ordinance Survey Map, the Healy 1983 Report, the record of the coin hoard, the historical records indicating the site was not levelled in 1642, or the anomaly in the GeoQuest geomagnetic Survey showing the fosse intersecting with the Glenamuck Road.
Had these documents and records been made available, the evidence on cost grounds alone for moving the road would have been clear. It was not possible for the public to appreciate the significance and extent of the Carrickmines Castle Complex on the information provided. Nor was it possible for a decision maker to properly assess the project.
This failure continues today in that the without identification of the castle site itself, the loss of archaeological heritage can not be mitigated.
We respectfully urge the Commission to bring proceedings against Ireland for its failure to adequately assess the impact of the Community funded South Eastern motorway on our archaeological heritage and to suspend funding of this motorway until the matter is resolved in accordance with European law.
The excavation of the Carrickmines Castle Complex began in August 2000 with 20 archaeologists, and ran until August 2002 when it had reached a final complement of some 130. The excavation of the Carrickmines Castle Complex
Border Castles in the Twilight Zone
The Carrickmines Castle Complex
The excavation of the Carrickmines Castle Complex began in August 2000 with 20 archaeologists, and ran until August 2002 when it had reached a final complement of some 130. The size of the site was completely unexpected, encompassing over 8 acres, 3 acres of which were internal Castle area. The basic layout saw two connected 1.5 acre enclosures with the probable main castle 'keep' in the central unexcavated zone. There was also an abundance of associated external features in the remaining 5 acres. The excavation produced over 90,000 finds of every imaginable form, as well as numerous banks and ditches, stone buildings, workshops, remains of wooden buildings, kilns, wells, storerooms and a well.
The reason for the construction of such a large defended area becomes clear when the abundant historical sources are consulted. It was a Norman Castle, probably founded in the 13th Century. It's primary function was to protect the main routeway from the Gaelic held Wicklow Mountains into the Norman (later English) held Dublin area. This was its function from its foundation until its fall. It endured some 400 years of semi- constant warfare, as shown by its refortifications in the 14th and 15th Centuries. It was also subjected to siege up to three times in the 15th Century, attacked once in 1599 and finally in 1642 was besieged and destroyed.
The Carrickmines Castle Complex is a unique site, which has produced the largest assemblage of medieval pottery ever found in rural Ireland, the site of a mass grave, the first major study of a border Castle and the first major study of the external associated settlement and remains of a Medieval/Early Modern Castle. Coupled with this, the 1.5 acre 'Revetted Fosse' enclosure with its revetted wall and three defensive ditches is unique in Irish archaeology. This site is not just of national significance, but is of major relevance to both British and Continental Castle Studies.
Upwards of 35% of the site remains to be excavated. Current estimates based on what we have found already would suggest something in the region of 5,000 medieval finds still in the ground. This is mainly due to outer ditches in various areas only being sectioned, i.e. not fully dug. As well as this, some crucial areas containing structures and buildings are not fully resolved.
The vast majority of the Castle Complex is to be destroyed, even with the Minister's proposals. His statement refers to the Gatehouse and the 'island', under which the core of the Castle probably lies. However, this area has always been an island on the road plan, and therefore excavation has not been carried out. The continuing insistence in placing this area in the 'look!, we're saving this' category is ridiculous, as it was never under threat.
Some 75-80% of the EXCAVATED areas are to be destroyed. This includes all of the areas with the remains of the workshops, wooden houses, mill, kilns, most of the wells and nearly all of the unique and incredibly well preserved 'Revetted Fosse' which runs for 237m. A total of 50m of this is to be saved (most buried under the roundabout), as well as a 'representative section' to be lifted and placed elsewhere. This removal is a ridiculous plan, as the stonework of the 'Revetted Fosse' is below ground level and associated with a bedrock cut ditch - how do you accurately represent that elsewhere?
Carrickmines is of international importance for a number of reasons. It is not as spectacular as some European examples, but it is its situation that is the key. It represents one of the border Castle's of the Norman Angevin Empire, who ruled parts of France, Britain and Ireland. Very few of these early border castles have ever been excavated.
Carrickmines was in the 'twilight zone' between two cultures, a situation repeated in the Welsh Marches, the Scottish Borders, and indeed all over Europe. The site demonstrates how this large European power (which later became the English power) dealt with this trouble on its borders. The site is not just a Castle, its a Complex. It demonstrates how these people defended themselves and managed to eek out a living under such harsh conditions.
A lot of the more impressive Castles in Europe were built as status symbols. Carrickmines is unique because of the practical necessities, which caused its construction. This may explain unique features like the 'Revetted Fosse' enclosing 1.5 acres and highly defended. The ancilliary settlement patterns around the Castle are also of huge importance, as this has never been explored in Ireland before, and there are not many European examples where such a complete picture of a medieval castle is known. Everything relating to the Castle located in the immediate area around it has been uncovered (not all fully excavated). This allows a unique picture of this Castle in operation to be built up. That is most certainly of International importance.
LETTER FROM THE EUROPEAN COMMISSION TO IRISH COMPLAINANTS ON THE CARRICKMINES CASTLE COMPLEX CARRICKMINES CASTLE COMPLEX
LETTER FROM THE EUROPEAN COMMISSION TO IRISH COMPLAINANTS ON THE CARRICKMINES CASTLE COMPLEX
Directorate D -Implementation and enforcement
ENV.D2 -Legal implementation and enforcement
10 October 2002
To Irish Complainants:
We refer to your complaint P2002/4957 concerning the proposed construction of the South East Motorway in the Dun Laoghaire/Rathdown area of County Dublin and it's impact on the archaeological remains of the Carrickmines Castle Complex.
The Commission has recently written to the Irish authorities seeking the following information, in order to investigate the issues raised in your complaint:
1. any general or specific comments they consider appropriate on the claims made;
2. in the light of Articles 5(2), 6 and 8 and Annex ill of Directive 85/337/EEC. on the assessment of the effects of certain public and private projects on the environment, comments on the claims that the information presented by the developer was maI1ifestly deficient with regard to the archaeological impact of the motorway project and as a result constituted an inadequate basis for public consultation and decision- making;
3. comments on why, in the light of Articles 5, 6 and 8 and Annex III of Directive 85/337/EEC on the assessment of the effects of certain public arid private projects on the environment, the environmental impact statement (EIS) apparently contains no information on the previous alignment advised by An Foras Forbatha, or information on the reasons for choosing the current alignment, having regard to the archaeological effects;
4. information on why the alignment was apparently changed from that advised by An Foras Forbatha;
5. details of all the archaeological investigations undertaken that informed the EIA;
6. information on whether, during the preparation of the EIS or during the subsequent decision-making process for the project, there were any expert submissions or representations on the Carrickmines Complex by archaeologists or historians, in particular by Duchas, and, if so, details of same and comments on how they were taken into account in the process;
7. details of the claims made and current knowledge of the extent and significance of the archaeological remains situated there, including expert comments by the nationally competent authorities, D??chas and the National Museum of Ireland, on the archaeological significance of the Carrickmines Complex and the aspects of unexcavated remains and extent of proposed destruction of the site;
8. details of the latest measures proposed to avoid or mitigate the effects of the motorway project on the Carrickmines Complex, and information on why it is not considered possible to undertake a more complete excavation and/or more extensive site preservation.
Today the two townlands of Carrickmines Little and Carrickmines Great are located in the parish of Tully within the Dublin barony of Rathdown. Originally, though, Carrickmines belonged to the northern half of the Irish kingdom of U?? Bri??in Chualann, a land that straddled the modern Dublin and Wicklow border. A much disputed land: Carrickmines and the Dublin marches