SLIABH BÁN / landscape

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Coillte's proposed windfarm development would have a devastating impact on the character of the Roscommon landscape. The site in question is 833 hectares and covers most of the mountainside of Sliabh Bán. The mountain is oriented north-south, being approximately 3km in width and up to 7km in length. The imposition of 20 turbines spread across the mountain changes utterly the character of the landscape as the natural image unit of Sliabh Bán would be dominated by the structures.

● Alternative locations
As part of the Environmental Impact Statement, the developer must consider alternative locations for the development. The limited scope of the alternatives presented in Section 2.5 and the rather arbitrary allocation of points in the scoring matrix, seriously undermines the legitimacy of the exercise and it does not appear that Coillte has made any reasonable effort to source an alternative location for this windfarm development.

 According to Section 2.5.3, Coillte owns over 445,000 hectares of land; about 7% of the land cover of Ireland and much of the best wind regimes in Ireland are on Coillte lands – and yet the EIS considers only two other local sites as alternatives to Sliabh Bán. These alternative sites are listed Option 1, 2 and 3 in one paragraph and, rather confusingly, Sites 1, 2 and 3 in Table 2.3 – Site Comparison Matrix. Interestingly, Sliabh Bán is referred to as Option 3 in Section 2.5.3 and yet Site 2 in Section 2.5.4 is scored the highest in the Site Comparison Matrix.

This sloppy approach to site comparisons further undermines the attempt at researching realistic alternatives to the Sliabh Bán. The scoring system applied to each of the three sites is confusing, unreliable and inconsistent – since Site 2 scores “highest”, we can take it refers to Sliabh Bán – yet it scores the same as Site 1 in relation to Dwellings, Grid Connection and Electromagnetic Interference.

The differences between the two sites, as described in Section 2.5.3 would indicate there are very few similarities between the feasibilities of these sites. Moreover the lack of a coherent approach to assessing alternative sites for this development raises questions about the developers' motives for selecting Sliabh Bán. The fact that Sliabh Bán appears to be a convenient site for the developers, given its access to the grid, should not override the principles of proper planning and sustainable development.

    ● Wrong sites for windfarms
The West Regional Planning Guidelines (RPG) offer some direction in relation to appropriate areas of the region with potential for development. “It is expected that wind energy will play a proportionally larger role in the energy mix in the West in the future. However, in order for this to occur there is a need to make better use of the wind resources on the western sea-board than is being done at present.”(Section 3: Key Issues and Strategic Goals). The RPG go on to say in Section 6, that “New wind farm developments must be in compliance with the principles of proper planning and sustainable development.” Part of the appraisal of a development of this magnitude should involve the investigation of realistic alternatives to the site proposed.

The Department of the Environment Guidelines on Wind Energy Developments (DoEHLG Guidelines), 2006, have been largely ignored in this planning application. Not surprising when these Guidelines warn against developments that visually dominate the landscape. This site ranges in elevation from 70m to 262m OD (Malin Head), indicating a change in height of approximately 192 metres. The 20 turbines proposed for Sliabh Bán reach an overall height of 131.5 metres arranged across the whole site. There are no mitigating factors that could possibly reduce the impact of this obtrusive and imposing development. The DoEHLG Guidelines advise that “the spatial extent of a wind energy development should be balanced and in scale with its landscape context. This involves consideration of the perceived size (extent and height) of landform, landcover and structures relative to the wind energy development” (Section 6.4). In the case of this planning application, the proposed wind farm is too spatially extensive relative to the scale of the mountain. There is no extensive mountainous range to shield views or absorb the development; a single mountain ridge like Sliabh Bán does not have the visual capacity or expanse of scale to sustain an industrial installation of this size.

As indicated in the DoEHLG Guidelines, when turbines are too high relative to the scale of the hill, this results in spatial dominance (see Fig 11 in DoEHLG Guidelines).

 The layout and spacing of the turbines is not justified in any context relating to their visual impact but the position of the turbines seems to have been largely determined by exclusion zones around dwelling houses, watercourses and transmission masts. The DoEHLG Guidelines (sections 6.6 and 6.7) encourage developers to consider layout and spacing of turbines to avoid the creation of a “visual stacking” effect. With reference to Transitional Marginal Landscapes (Section 6.9.4 DoEHLG Guidelines), which probably coincides best with the landscape around Sliabh Bán for the purposes of applying the recommendations of these guidelines, the document highlights the visual complexity of the landscape, due to the diverse landform and landcover and advises that “wind energy developments should avoid adding to such complexity due to the risk of creating visual confusion and conflict.”(Section 6.9.4) Yet Coillte propose 20 wind turbines, a communications mast, a meteorological mast, an electrical compound and substation building as well as hardstanding areas, drainage and site works on the one site.

Wrong positions for turbines
The Department Guidelines also point out that “Large wind energy development straddling two landscape character types within the same visual unit ... creates a visual ambivalence and, thus, negative tension between the two character types involved” (Figure 4c). It could be said that the proposed development on Sliabh Bán not only straddles two landscape character types (as determined by the Roscommon County Council Development Plan – Landscape Character Assessment), but also two distinct land uses as one of the turbines is proposed for farmed pasture land – at odds with the location of the remaining 19 turbines which are located in dense evergreen forestry. On the western side of the mountain, the location of this turbine in green pasture will have the effect of advancing the windfarm development down the mountainside, introducing it into a landscape more consistent with human activity and reducing the effect of the mountain as a background image unit.

One of the key tools in determining the visual impact of this development are the resources supplied by the developer such as the computer generated Zones of Theoretical Visibility and the photomontages from different view shed reference points and this is emphasised in Policy 198 of the County Development Plan. Furthermore, the DoEHLG Guidelines clearly state that for blade tips in excess of 100m (in height), a Zone of Theoretical Visibility radius of 20km would be adequate (see Appendix 3 of DoEHLG Guidelines), and yet the developer’s EIS only considers a study area with a 15km radius centred on the location of the proposed development claiming that “Visual impacts received by receptors beyond 15km from the development are not considered to be of significance” (section 11.3.2). This rather throwaway remark, not backed up by any reference, belittles the significance of Sliabh Bán has the highest peak in east Roscommon and impairs the opportunity to properly review the disastrous visual impact this development would have on the landscape.

Even limiting the Zone of Theoretical Visibility to a 15km radius, Section 11.6.3 of the EIS indicates that this development would theoretically be visible from 90.9% of the area assessed – this means that out of the 710km2 study area, the proposed turbines could possibly be seen from 645.48km2 within that area. This further compounds the argument that the scale and location of this development is inappropriate and out of character with the landscape.

Assessing the visual impact by photomontages
The DoEHLG Guidelines, also in Appendix 3, provides guidance on the procedures that should be followed in the preparation of photomontages stating that “A camera lens focal length of 50-70mm is recommended for taking photographs of photomontages” , “Panoramic photographs included to illustrate the context in which the development might be visible should be prepared by splicing photographs taken with a 50-70mm lens and not by inclusion of views taken with a wide-angle lens” and “the recommended distance at which the page depicting the photomontage should be held for viewing purposes should clearly be stated (this should not be less than 30cm).

The photomontages provided with this planning application are clearly deficient in providing the necessary detail to properly asses the visual impact of this proposed development on the landscape. The assessment of these photomontages in the EIS raises questions about the developer’s appreciation of the visual significance of Sliabh Bán as an image unit on the landscape.

Table 11.6 in the EIS attempts to rate the significance of the impact of the development, however the ratings applied are skewed in favour of reducing the perceived impact of the turbines – taking Viewpoints 2 and 3 for example, both are assigned a significance of “medium”, yet VP 2 records the visual presence as High Dominance. Further investigation of the Table shows the rating system applied is not sophisticated enough to deal with the impacts this development is likely to have on the landscape and is merely an attempt to counter the fact that, out of the 29 View Points assessed, 14 were considered to be “Highly Dominant” in terms of Visual Presence. Table 11.4 of the EIS classifies Highly Dominant as being “a loss of major change to key elements/ features/ characteristics of the baseline pre-development landscape or view; and/or introduction of elements considered to be totally uncharacteristic when set within attributes of the receiving landscape”.

Even considering the assertion that the visual presence classification is not necessarily synonymous with or indicative of adverse impact, the fact that almost half the viewpoints considered determined that the proposed development would be highly dominant in terms of visual presence, is a damning indictment of the scale and inappropriate siting of this development.

There is almost no recognition of the visual impact that the addition of red coloured aviation warning lights to each turbine will have on the night skyline. Does this mean that there would be twenty red lights atop each turbine, blinking constantly as the blades rotate in front of the hub so that even at night, the windfarm impacts on the landscape?

● Public consultation on landscape issues

Coillte’s attempts to use the consultation process to prove public support for the development are severely lacking. Reference to the consultation meetings carried out during the course of the drafting the Landscape Character Assessment for the Roscommon County Development Plan (section 11.7 of the EIS), fail to highlight the fact that at the three focus group meetings there were a total of 53 people in attendance (see Appendix 2 of the Landscape Character Assessment of County Roscommon) – therefore the comments of less than 1% of the total population of County Roscommon hardly constitutes a representative sample of public opinion in the County. Even then there were people who had a strong dislike to windfarms and Section 4.2 contains a map from one of the public consultation workshop with Sliabh Bán marked in as an area of interest in terms of walks/forest trails and geological interest. Through the course of Coillte’s own consultation process, a total of 74 feedback sheets were returned (see Tables 1.3 and 1.4 of EIS), with the overwhelming majority opposed to the development and only one single feedback sheet registering support for the windfarm. During a recent County Council meeting on September 27th 2010, a motion was passed unanimously stating that the County Councillors did not believe that Sliabh Bán is an appropriate site for a windfarm. With this level of opposition to the development, it is clearly evident that those living close to Sliabh Bán appreciate its landscape value as a reference point, an orientation point and a strong image unit on the landscape that should not be devalued as an industrial site for twenty 131.5metre high turbines.

● Protection for our natural landmark
Roscommon County Council should offer protection to the landscape values assigned to the areas around Sliabh Bán and refuse planning for this development in the interests of proper planning and sustainable development. The Landscape Character Assessment for County Roscommon designates Sliabh Bán and the Feorish Bogland Basin as a landscape of Very High Value – Roscommon County Council cannot consider it appropriate to allow 75% (15 turbines out of 20) of this development to take place within this category of designation.

The LCA description of this landscape points out that Sliabh Bán “creates a strong visual separation between the Shannon River and the remainder of the county in this area” before going on to say that “elevated views from Slieve Bawn to the east are of a highly mechanised landscape of commercial peatland and the peat burning electricity plant in the distance at Lanesborough”. It is imperative that Roscommon County Council does not allow this strong visual separation to become blurred by the imposition of twenty large wind turbines and allow the mechanised, commercial and industrial landscape to the east of the mountain to creep up and across the ridge.

Chapter 3 of the County Development Plan contains Objective 67 (page 44) which states that “Subject to normal planning considerations wind farms will only be permitted in locations that do not negatively impact upon the scenic value of rural areas” and there is no denying the proposed turbines would be overbearing on the locality and incongruous in the landscape. Their overall height and scale of the development would give rise to a visually dominant and obtrusive form on a prominent natural landmark in the region and would adversely impact on the character of the landscape and would therefore be contrary to the proper planning and sustainable development of the area.