To: The Secretary,
Forward Planning Section
Planning Dept
County Hall
19 October, 2006

Observations on Proposed Variation Number 1 to South Tipperary County Development Plan relating to Wind Energy Development for South Tipperary: Ahenny and the Lingaun valley
Dear Secretary;

Friends of the Irish Environment [FIE] is an environmental organisation created by conservationists in Ireland in order to monitor the full implementation of European environmental law, to work for changes in the Irish planning laws, and to pursue concerns and cases in both the built and the natural environment.

FIE has a long standing interest in renewable energy and specifically in wind energy. We supported the development of the Department of the Environment's Planning Guidelines on Wind Energy Development and took part in the consultation process.

In our submission, however, we noted that there were locations which must be considered 'no-go' areas for wind development. The Ahenny and the Lingaun valley is an example of such a location and we write to support residents seeking to have the designation of this important scenic and archaeological area protected from the impact of wind turbines.

We would also draw the attention to the decision makers to the impact of the transmission pylons and wires that are required to connect these installations to the national grid as in themselves these can be inappropriate and intrusive at sensitive locations.

National policy rightly seeks to provide 15% of Irish energy requirements from renewable sources and planning authorities rightly must have regard to this policy. However, the Landscape Policy of South Tipperary, the South Tipperary County Development Plan 2003, and Variation No 7 (adopted by South Tipperary County Council on 4 September 2006) all argue that these developments must avoids important scenic and archaeological area.

Further the Development Plan states that 'In assessing the potential of the landscape to accommodate windfarm developments, the Council will adopt a precautionary approach. It is difficult to assess the impact that windfarm developments will have on the landscape, especially in scenic areas and particularly to what extent such development will alter the image that people have of certain landscapes.'

The recent Variation No 7 to the Development Plan cited above in fact specifies that telecommunications installations, which have many magnitudes less impact that wind turbines, should 'not be located in

(i) Highly scenic areas or areas specified as such in any landscape character assessment carried out for the County;
(ii) Within significant views of national monuments or protected structures'

The Landscape Policy of South Tipperary 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."

In turn, the South Tipperary County Council County Development Plan 2003 states that Key Landscape aims include:

(i) To sustain, conserve and enhance the landscape diversity, character and quality of the County;
(ii) to protect sensitive areas from development that would detract from or be injurious to the amenity of the area;

In terms of heritage, The Heritage Plan notes that 'South Tipperary is a county rich in heritage of all types, from the sweeping vistas of Slievenamon and the Glen of Aherlow to the distinctive high crosses and use of slate in Ahenny. In history and archaeology the county boasts the seat of the kings of Munster at Cashel and the site of the first shots of the War of Independence at Soloheadbeg.'

This pride must rightfully encompass the unique 9th century High Crosses in the Lingaun Valley and conservation status of the villages of Ahenny and Ninemilehouse.

We respectfully request the Planning Authority to have the Ahenny/Lingaun Valley area changed from its current status - open to consideration for wind developments - to a No-Go Areas zone which, in the word's of the County Development Plan is for 'areas, which due to their scenic, ecological, historic or tourism values are unable to accommodate wind developments'

Yours, etc.,

Tony Lowes,

FIE Submission on The Department of Environment's Planning Guidelines on Wind Energy Development
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