Public consultation is now LIVE in relation to a retrospective application for road extension which is part of the turbine development at Knock Iveagh. We are now asking our supporters to take action, and contact ABC Council Planners in respect of this development. It is essential that planners and ABC Council face up to their obligations, not only in regards to their own plans and policies, but also in respect of European & NI Environmental Legislation. This blog attempts to explain some of the major problems associated with the road, and the development of which it is a key part. It is designed to help you understand and respond to the ongoing development at Knock Iveagh. It is not necessary to include all the information below with your objection to the road, but the sections in bold italics may be copied and pasted to save you time! Objections carry significantly more weight if you add in some of your own thoughts, but 'I don't like it' won't cut much ice, so specific legislative and policy-based reasons for refusing this road application are given below! It is actually vital that you add in your own comments, so that the Council will treat it as an individual response. Please feel free to copy in ABC councillors, and other elected representatives into your emails so they also know how you feel.
itThank you for taking the time to do this! The application number is LA08/2017/1734/F and objections can be sent via the NI Planning portal, and also directly to [email protected] A full list of councillors, with whom this decision on revocation ultimately rests at present, is here: https://www.armaghbanbridgecraigavon.gov.uk/team-showcase/councillors/
This road (and other key works directly related to the wind turbine development) [INFO: extensive 'earthing' trenching, electricity cabinets which themselves create a 'moderate to major impact' on the setting of the monument, earthworks, cabling, different model of wind turbine!] was not specified in the original application. This contravenes European Environmental legislation. More information on how this legislation relates to wind turbine development can be found here and also below.
a) the wind turbine associated with this retrospective road application exceeds 15m in height & is located in an area of archaeological/ cultural importance, therefore we believe an EIA should have been required. See: Planning Regulations Northern Ireland (2017), Schedule 2: section 2, subsection 3 'Energy Industry' and Schedule 3: section 2 'Location of Development': c:viii b) The cumulative impact of the whole development at Knock Iveagh has never been assessed under Annex II of EU Directive 2014/52/EU on Environmental Impact Screening. INFO: The development has been allowed to be split into five distinct applications, of which this road is one. Three of these elements are subject to enforcement cases at present. Splitting large developments such as this one into smaller component parts avoids looking at the larger environmental impact, and this is why this environmental legislation exists (Directive 2014/52/EU). The legal status of the earthing trenching has not yet been confirmed, yet the developer continues to dig extensively. Annex II of the European Environmental Directive 'on the assessment of the effects of certain public and private projects on the environment' requires environmental screening of applications to be undertaken based on information provided by the developer before works commence: 'including in particular: (a) a description of the physical characteristics of the whole project and, where relevant, of demolition works; (b) a description of the location of the project, with particular regard to the environmental sensitivity of geographical areas likely to be affected' c) The impact of this development on a landscape of cultural and archaeological significance has never been considered. This is also necessary under EU 2014/52EU point 16. There have been numerous opportunities where we believe an EIA determination should have been carried out by planners. This includes: at the time of the original turbine application, at the time of the cabling application, and at the beginning of each of the subsequent planning enforcement cases (including the enforcement case relating to the differing model of wind turbine). This is required under the Planning (Environmental Impact Assessment) Regulations (NI) 2017, Section 34. It is not apparent, based on the publicly available information, that any such screening has taken place. This new retrospective road application should now trigger a full EIA under section 33 of these Regulations, in order to assess the cumulative impact of all development at Knock Iveagh, to comply with EU environmental legislation designed to protect and promote cultural heritage, and to avoid 'job splitting'. Knock Iveagh is clearly an area of archaeological and cultural importance as the setting for ritual and burials extending over a millennia. There is no doubt that the visual impact of this entire development on the historic hillside of Knock Iveagh has been significant. Knock Iveagh is also a unique piece of our ancient and indigenous cultural heritage, and a place which was considered of great importance over thousands of years. As such it warrants the fullest protection under this legislation. Knock Iveagh has been a centre of important human activity, including ritual use, for millennia. It has also been a place of recreation, inspiration and a valued local landmark for generations. The failure of planners and others to recognise the importance of this site has resulted in a significant loss to the public. The potential of Knock Iveagh in relation to culture, recreation and tourism with local, national and international appeal has never been assessed. For more information on European Landscape policies, please see here. 'For the protection and promotion of cultural heritage comprising urban historical sites and landscapes, which are an integral part of the cultural diversity [...] it is important to address the visual impact of projects, namely the change in the appearance or view of the built or natural landscape and urban areas, in environmental impact assessments' ABC Council planners appear not to have taken any of this European legislation into consideration despite the cultural and archaeological importance of Knock Iveagh. This is a time of great risk for Northern Ireland's heritage, not just at Knock Iveagh, but elsewhere too. Never before in our history have our historic landscapes and heritage sites been in such danger. Let's make this a line in the sand....
No to any further destruction of our irreplaceable heritage!
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AuthorThe Friends of Knock Iveagh Archives
September 2019
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