OBJECTIONS
GUIDANCE DOCUMENT
1. PLANNING
CONCERNS
- Planning precedent
elsewhere in Europe and globally- governments in other countries
and utility providers abroad have ceased erecting overhead pylons due
to health, environmental, economic and social costs. Overhead
pylons are not in the “public interest” but instead are non-respectful
of the landscape, visually obtrusive, economically unviable and pose
serious risks to human, animal and ecological welfare.
- Existing planning
permissions- outline and full planning permission exists on numerous
sites along the proximity of this proposed route. NIE are not
even aware of this fact and have not consulted with all land-owners/site
owners. The potential to build existing planning permissions and
future permissions will be totally stopped as NIE (if they obtain permission)
will be able to legitimately object to any future applications submitted
in the vicinity of this proposed pylon route.
- The proposed
pylons are contrary to planning policy.
Current
relevant documents:
1)
Draft PPS21- Sustainable Development in the Countryside;
- Regional Development
Strategy (available online at www.drdni.gov.uk/shapingourfuture)
- Rural Development
Strategy (available online at www.dardni.gov.uk/nirdp_2007-2013
The following
is a sample extract from the policy document draft PPS21 (which is the
most applicable strategy to all rural planning applications available
online or from your local Divisional Planning Office:
“ 3.1
The aim of DRAFT PPS 21 is to manage development in the countryside:
• in a manner
consistent with achieving the strategic objectives of the Regional Development
Strategy for Northern Ireland 2025; and
• in a manner
which strikes a balance between the need to protect the countryside
from unnecessary or inappropriate development, while supporting rural
communities.
Objectives
3.2 The objectives
of PPS 21 are:
I) to
manage growth in the countryside to achieve appropriate and sustainable
patterns of development that meet the essential needs of a vibrant rural
community;
II) to conserve
the landscape and natural resources of the rural area and to protect
it from excessive, inappropriate or obtrusive development and from the
actual or potential effects of pollution;
III) to facilitate
development necessary to achieve a sustainable rural economy; including
appropriate farm diversification and other economic activity; and
IV) to promote
high standards in the design, siting and landscaping of development
in the countryside” (extract from Page 7 of draft PPS21).
The above list
I-V of draft PPS21 are applicable planning objectives which all planning
applications are assessed against. Incorporating the above into
our objections will validate and further strengthen our objections.
CONTRARY
TO ARMAGH AREA PLAN
1) Objectives
of the Armagh Area Plan being used. For example, paragraph 3.1
of this document states “The aim of the Armagh Area Plan is to provide
a framework of land use proposals and policies which will allow the
area to maximise its full development potential in an efficient, economic
and orderly manner whilst maintaining a high standard of physical environment
and safeguarding it’s landscape quality and natural resources”.
The last line
of the above policy statement is an example of a legitimate planning
objection- “maintain a high standard of physical environment and safeguarding
its landscape quality and natural resources”.
However, if
households are to use this policy objective as a refusal reason what
is needed is for each household to make an argument in relation to how
the scheme affects their local landscape quality. For example,
within the immediate locality surrounding your home what are the local
features – this may be a local river, marshland, group of trees.
2) Another
separate policy objective of the Armagh Area Plan is “to enhance the
quality of life for the rural community”. The pylon scheme clearly
does not comply with this policy objective as all households will be
severely affected by the proposed scheme.
3) Objectives
contained in the over-arching Planning Framework for Northern Ireland
as set out in the policy document entitled “Regional Development Strategy-
Shaping Our Future”. (this document is available on www.drdni.gov.uk
).
4. HEALTH
CONCERNS
- Given that my two
children will be sleeping within 100 metres of this power line every
night I am concerned about the findings of Schuz (2001) which suggest
that the impact of EMF’s is especially detrimental to young children
during the night – even more so than in daylight hours. This
is backed up by the findings of Ahlbom et al (2000) who state that children
under five years old are most vulnerable to night time exposure of EMF.
It is their belief that if this exposure is averaged out over 24 hours
it appears inconsequential but if it is concentrated between 10 pm and
6 am then a very pronounced correlation between childhood leukaemia
and magnetic fields becomes obvious.
- Sir Richard Doll
– notoriously sceptical about EMF exposure – states that in the
UK only 4 in 1000 children are subjected to prolonged and intense EMF
exposure. The suggested route places my children within the minority
group that is subjected to prolonged exposure. Doll himself feels
that further evidence is needed in this area.
- I remain unconvinced
that a non-biased and informed examination of the issues regarding EMF
exposure has been carried out by NIE. I am not satisfied with
the standard quotes from SAGE and WHO in the face of such an abundance
of conflicting evidence. It is my understanding that the WHO EMF
project is partially funded with money provided by the utility companies.
Also the SAGE recommended exposure limits only protect against established
effects and not recognised possible effects.
- WHO and HPA (Health
Protection Agency) both agree that there is a consistent statistical
association in studies into the links between unusually high EMF fields
and increased incidence of childhood cancers.
- This is an issue
causing myself and my family considerable stress and anxiety.
The risk – or perceived risk to the health of my children is considerable
and appears to be a situation over which I have no control and am being
given no choice. I believe NIE to be reliant on selective quotation
from scientific research in order to minimise what is a considerable
risk factor.
- The largest study
into this area – Draper et all (2005) establishes a link with a doubling
of incidence of childhood leukaemia for those children living within
600 metres of the high voltage power line.
- Greenland and Sheppard
(2000) state there is an elevated incidence of childhood cancers with
proximity to power lines.
- I feel that the
main motivating factor in this proposed overhead route is an economic
one and I object to a price being put on safeguarding the health of
my children. NIE stated in Dungannon Council (11th
Feb 2008) that undergrounding this would cost Northern Ireland £217
million. The life expectancy of an underground line is 40 –50
years. Given the annual profit of NIE this amount over 45 years
is negligible. In any case potential health risks should surely
be deemed as important as financial considerations.
- On Monday 11th
Feb 2007 in his address to Dungannon Council, Mr. Clem Harvey of NIE
claimed that the proposed overhead route could be “achieved at
a cost we can all afford”.
I disagree with this statement as I feel that a huge gamble is being
taken with the health of my children and others in the area. A
significant body of scientific research would suggest that my young
children would be at least twice as likely to develop childhood leukaemia
if the overhead line goes ahead. I consider this to be a risk
that I cannot afford to take.
- Children have a
500% increased chance of developing cancer in later life if they are
raised for the first five years of life within 300 metres of a high
voltage power line. (Lowenthal, Tuck and Bray 2007)
- The Draper Report
2005 states that living within 200 metres of a high power line will
increase your child’s chances of developing leukaemia by 69%.
Living within 600 metres this chance is increased by 20%.
- The recent Cross-Party
Inquiry into Childhood Leukaemia and EMF (July 2007 www.epolitix.com) recommended that governments
consider extending the 60 metre exclusion zone to 200 metres for high
voltage power lines in line with the policy of precaution.
- Health and welfare
of employees within place of work- employers are responsible for employee’s
health and safety. The pylons directly create issues for employers
in this respect. Liability issues for owners of fixed places of
work, liability issues for building sites throughout the countryside,
farm yards, farm land etc
- Health risks - refer
to Askon report and other relevant material.
- Human Health- cancer
risks, persons fitted with heart monitor/pacemakers and similar devices
are susceptible to electric pulses from pylons affecting the performance
of their needed medical equipment. Lives may be put at danger.
Also, hearing aids are susceptible to electrical impulses. Migraine
issues resulting from electric fields, nausea, depression etc.
5. AGRICULTURAL
CONCERNS
- Sterile corridor
(60m either side at present though UK government advised to increase
this to 200m either side) through farm - massive restrictions on agricultural
activity and future planning permissions.
- The possibility
of litigation from employees or neighbours experiencing the ill effects
of exposure to high voltage power lines is a worry to many farmers.
- Potential "relayed
toxicity" through animals exposed to high voltage powerlines through
beef and dairy entering food chain.
- Buchard et al (McGill
University Quebec) carried out experiments on dairy cows exposing them
to 73kV (note ours is 400kV) - milk production decreased by 5% compared
to control group and milk fat decreased by 16%.
- No spray irrigation
or slurry spraying can take place near the line - this is especially
worrying in orchards. If a jet from spraying makes contact with the
line currents would pass down the line and through the body of anyone
in contact with the equipment. Note that slurry is an even better conductor
of electricity than water. Note also that this line is heavier and lower
than any others in NI therefore will be closer to the ground and agricultural
activity.
- Research (Rogers
and Hinds 1983 and Warren et al 1981) show that proximity to powerlines
has a negative effect on bees. Adverse effects include increased propolis,
reduced growth, increased irritability and increased mortality.
- About 5 people a
year are killed in the UK in agricultural accidents involving powerlines.
Note that electricity can "jump" so it is not even necessary
to touch the line to cause serious injury.
- During construction
overhead lines on pylons will cause lengthy disruption to affected farms.
There will be months when whole areas of farms will be out of action. Imagine
how long it will take the concrete base to set - it will involve 30-40
lorry loads. This is only one factor involved. On the other hand laying
underground cables will only take weeks if not days.
- Future expansion
plans of farms will be hindered due to a restriction corridor being
placed on both sides of the proposed line.
- Safety of farmers
and all workers is a concern as consequences of long term exposure to
EMF/ELF are unknown. Health and welfare of employees within place of
work- employers are responsible for employee’s health and safety.
The pylons directly create issues for employers in this respect.
Liability issues for owners of fixed places of work, liability issues
for building sites throughout the countryside, farm yards, farm land
etc.
- As a landowner I
am extremely concerned about the likelihood of being sued by employees
or neighbours suffering injury or loss resulting from the 400kV powerline
being placed over my land?
- Will I be compensated
in the event of loss or damage to livestock in the vicinity resulting
from the powerline crossing over my land and the resulting EMF emissions?
- Will I be compensated
in the event of any produce from my farm being degraded or deemed unfit
for sale as a result of contamination from EMF emissions?
- I feel it is unlikely
I will be able to use my land under and adjacent to the 400kV powerline
in the normal way (including slurry spreading and apple spraying within
the safe parameters of normal agricultural machinery) without risk of
injury to me or my employees?
- Can I have a confirmation
of the distance from the line that I can build a typical one storey
bungalow? Will they guarantee that this distance will not be extended
in the future?
- Can NIE guarantee
that they will not mount any telecommunication masts on the pylons or
within the area included in the permanent easement that will accommodate
this 400kV powerline?
- Can NIE guarantee
that they will not increase the electrical capacity of this 400kV powerline
in the future?
- Can NIE guarantee
that this 400kV powerline will be on sufficiently high pylons that sagging
of the line does not pose a risk to agricultural activity on my land?
- Can NIE confirm
the exact safety clearance needed underneath a 400kV powerline?
- I am concerned at
the high levels of agricultural incidents involving powerlines that
have caused damage to farm workers or machinery in the last 15 years
in Northern Ireland?
- Can NIE explain
in detail the process of placing pylons and powerlines on my land?
Will temporary roads be needed? How long will the disruption last
for?
- How will this effect
the future potential of the land- a pylon traversing our countryside
obliterates potential of our countryside for in excess of 100 years;
Farm land- A pylon scheme crossing over farm land essentially sterilises
use of the farm land in the vicinity. Also, it has become apparent
that farm produce such as poultry, milk and meat produced in the vicinity
of pylons is not allowed to enter the food chain. This vast and
important range of issues clearly affects each farmer along the line
in a different manner and each farming issue needs to be clearly detailed
in a ‘site specific’ manner. For example, a chicken or livestock
unit may be within 500 metres of the proposed pylon route.
- Animal Health- 28th
October 2008 French Civil Court ordered French company RTE (electricity
distributor) to pay almost 400 000euros to cattle farmers. This
means that the courts have established for the first time that there
is a link between the effects of EMF from a very high voltage powerline
and symptoms of disease among animals. The powerline in this case
was 400kV. The farm is in Correze and is crossed by a 400kV line.
It specialises in raising cows and pigs. The Marcouyoux family
– who run the farm- noticed breathing problems and weakened immune
systems. Other problems included abnormally low birth rates and high
incidence of infant mortality. Heifers were recorded as undersize
and suffered from genital and digestive diseases. The local farming
authority and the county veterinary services eliminated any source of
infection causing harm to the animals.
6.
ENVIRONMENTAL CONCERNS
1. The Environment
- The government of
Northern Ireland is committed to conserving and protecting both the
built and natural environment. http://www.doeni.gov.uk/index/protect_the_environment
- A strategic objective
of ‘First Steps Towards Sustainability: A Sustainable Development
Strategy for Northern Ireland’ (May 2006) DOE, is ‘to create
an attractive/high quality environment where people feel safe and which
provides the conditions for health and social well-being’.(page 73) http://www.ofmdfmni.gov.uk/sustain-develop.pdf
- One of the principal
objectives of the Armagh Area Plan (2004) is ‘to conserve and
enhance the natural and man-made environment.’ (Paragraph 3.2)
- The construction
of a North-South Interconnector would have an extremely negative effect
on both our built and natural environment. (local examples)
2. Landscape
- A strategic objective
of ‘First Steps Towards Sustainability: A Sustainable Development
Strategy for Northern Ireland’ (May 2006) DOE, is ‘to conserve
our landscape and manage it in a more sustainable way’. (page 42)
According to the Strategy, one important step is to ‘ensure the review
of the Northern Ireland Regional Development Strategy and other relevant
planning policies, reinforce sustainable development and provide for
appropriate protection of the landscape’.
- According to the
EHS/Planning Service survey of landscape character areas
within N. Ireland, the land affected by the proposed line falls within
the ‘Armagh Drumlin’ area and the ‘Loughgall Orchard Belt’. http://www.ehsni.gov.uk/landscape.htm
- The mosaic of prehistoric
monuments, traditional farms and buildings, forest plantations and wildlife
habitats all contribute to these special landscapes that are part of
our culture and heritage. The construction of a North-South Interconnector
would have a significant detrimental impact on the appearance of our
landscape. (local examples)
- Within the ‘Armagh
Drumlin’ area, there is an almost complete mantle of drumlins forming
an internationally acknowledged type example of a 'drumlin swarm'. The
area is renowned for this particular type of topography and the proposed
line would cut right through it,
- According to the
EHS/Planning Service survey of landscape character areas within N. Ireland,
new development can be ‘integrated into the landscape’ if it is
sited on the mid-slopes of drumlins, or close to the break of slope.
How can pylons between 22m – 37m high be integrated into the landscape,
when they are an eyesore threading their way through our beautiful drumlin
landscape?
- The EHS/Planning
Service survey also states that within the Armagh Drumlin area ‘scattered
development in the countryside can be accommodated if located sympathetically
between trees and hills and if constructed of traditional materials’.
Pylons hardly fit into the category of ‘traditional materials’!
- The Armagh Area
Plan (2004) is concerned with ‘maintaining a high standard of
physical environment and safeguarding its landscape quality and natural
resources’. (Paragraph 3.1) The quality of the landscape would be
degraded. (local examples)
- One main objective
of The Dungannon & South Tyrone Area Plan (2010) is ‘the
protection and enhancement of landscape features, natural habitats,
and man-made features which are of conservation importance and contribute
to the overall character of individual settlements and the wider countryside’.
(page 15) (local examples)
3. Armagh
Countryside According to the Armagh Area Plan (2004)
‘almost 22,000 or 43% of the District’s population live in the countryside
outside the main towns, villages and hamlets’ and the countryside
requires to be protected. (Paragraph 79.1)
4. Dungannon
Countryside - The Dungannon & South Tyrone Area Plan
(2010) strategy is to ‘sustain a living and working countryside whilst
protecting from inappropriate development those areas that are vulnerable
to development pressure or that are visually or environmentally sensitive’
- I am concerned at
the proximity of some very mature oak/ horse chestnut trees that will
be in close proximity to the high voltage powerline. Many of the
trees in the area have a girth of over 15 cm and can therefore be deemed
worthy of a Tree Preservation Order. (For details contact the Divisional
Planning Office.)
- I have observed
badgers/buzzards/barn owls/pheasants/grouse etc in the area and am concerned
at how their habitat will be affected by this high voltage overhead
line. (Contact Environment and Heritage Service for details –
proof required) The Ulster Wildlife Trust will also be interested to
hear of sightings of barn owls in your area.
- As a member of the
rural community I feel that my rights are being infringed. There is
no way this line would go overhead through an urban area. I would
suggest that the forthcoming Bill of Rights for Northern Ireland be
equally as applicable to rural dwellers as it will be for urban communities.
- There is a plethora
of archaeological sites and buildings of significance in the area (raths,
wells, forts etc) and it is my belief that NIE have not researched the
proposed route thoroughly enough and have failed in their attempts to
avoid such valuable historical features which add a unique character
to this area.
- I feel that this
proposed high voltage overhead powerline will interfere permanently
with the “natural features and the archaeological and built heritage,
which form part of the local identity.” (Dungannon and South Tyrone
Area Plan)
- These pylons are
visually offensive – it is irrelevant whether they are 30 metres or
60metres – they will still be a blight on the landscape. This
is a area of beautiful scenery and immense character and these pylons
cannot fit into the rural landscape of Armagh and Tyrone without taking
away from the unspoilt nature of the land that has evolved and been
protected over centuries.
- I enjoy a view of
the historical city of Armagh and in particular the Roman Catholic Cathedral
from my elevated site and this view was a key reason in choosing this
site to build on. This view will be completely spoiled if the powerline
goes overhead.
- The Mourne mountains
can be seen from my elevated site and this view will be blighted by
the erection of this high voltage overhead power line.
- I am concerned that
over the course of the next few years planning restrictions in the proximity
to power lines will become even more restrictive by law and that an
increasingly wide swathe of “sterile” land will stretch from Derrynoose
to Moy.
- The Armagh Area
Plan states that its aim is to “allow the area to maximise its full
development potential ….whilst maintaining a high standard of
physical environment and safeguarding it’s landscape quality and natural
resources.” It is my concern that this proposed overhead high
voltage powerline contravenes this objective. (Need specifics of individual
homes)
- The Armagh Area
Plan states that it aims to “enhance the quality of life for the rural
community.” This proposed overhead powerline is clearly at odds
with this objective. Even now – in the initial planning stages this
is an issue causing undue stress and anxiety in my own household and
in others along the line. The perceived threat- and indeed the
actual threat- to our homes are having a negative impact on health already.
- The Dungannon and
South Tyrone Area Plan state that one of its primary objectives is the
“maintenance and enhancement of Dungannon and South Tyrone Borough
and its distinctive urban and rural environs as an attractive and pleasant
place to live, work and visit.” I personally feel that if the
proposed overhead high voltage cable goes ahead I will be fearful of
the threat to the health of my young children – therefore denying
my family the right to live in an attractive and pleasant environment.
This plan also aims to “sustain a living and working countryside whilst
protecting from inappropriate development those areas that are vulnerable
to development pressure or that are visually or environmentally sensitive.”
Whilst I am in favour of strengthening the electricity supply of this
island by undergrounding of high voltage cables, I believe that this
proposed overhead route is a form of “inappropriate development.”
5. The
Historic Built Environment
- Some of the most
sensitive areas of the landscape along the proposed line are the settings
of numerous important archaeological sites. These are concentrated to
the south and west of Armagh and include Navan Fort, Northern Ireland’s
most important ancient monument.. Local skylines and drumlin summits
are also sensitive, particularly when they are the sites of ancient
raths.
- One of the principal
objectives of the Armagh Area Plan (2004) is ‘to preserve and
enhance the archaeological and historical heritage of the District’.
(Paragraph 3.2)
- 14 raths, 2 enclosures,
2 burial mounds, 2 ancient churches with graveyards, 2 standing stones,
1 holy well, 1 megalithic tomb and 1 cross have been identified within
a 1km radius of the proposed Line route. (Ref: Appendix 1)
- The landscape setting
of these archaeological sites must be a priority for conservation. According
to the Armagh Area Plan (2004) ‘development will not normally
be permitted which would be likely to damage or prejudice the essential
character of areas of historic landscapes, archaeological sites and
monuments or their settings.’ (Paragraph 7.0)
- The proposed line
passes close to a group of important archaeological sites north of the
Armagh – Killylea Road including Haughey’s Fort (Grid Ref:
H8351 4529) and The King’s Stables (Grid Ref: H 8388 4546).
These sites are protected under the Historic Monuments & Archaeological
Objects NI Order (1995)
- In particular, the
view west from Navan Fort, one of the most important archaeological
sites in Ireland, would be compromised.
- Lisglynn Fort (Grid
Ref: H 106 3915) is an Early Christian rath and souterrain. It’s one
of the few square forts in Ireland and the views both towards &
from it would be ruined.
ENVIRONMENT
AND HERITAGE SERVICE (DOE)
Historic
Monuments of Northern Ireland to 31 March 2007
Sites and monuments
protected under the Historic Monuments & Archaeological Objects
(NI) Order (1995) within 1 km radius of the Proposed Line route
| TOWNLAND |
MONUMENT |
GRID REF.
(SHEET NO.) |
DIST. COUNCIL |
SM
NO |
| Scheduled
Historic Monuments |
| Ballydoo |
Enclosure |
H 8246 4524 |
Armagh |
011:025 |
| Balteagh |
Large hilltop enclosure |
H 7978 4038 |
Armagh |
015:010 |
| Drumacanver |
Megalithic tomb |
H 8077 3710 |
Armagh |
015:034 |
| Drummond |
Rath |
H 8057 3583 |
Armagh |
019:001 |
| Fergort |
Rath |
H 7883 3285 |
Armagh |
019:007 |
| Lisglynn |
Lisglynn rath & souterrain |
H 8106 3915 |
Armagh |
015:019 |
| Rawes |
Rath:Rawes Fort |
H 7927 3492 |
Armagh |
019:004 |
| Tamlaght |
Burial Mound: The Doonan |
H 8073 3894 |
Armagh |
015:018 |
| Tullyglush |
Rath |
H 7928 3752 |
Armagh |
015:023 |
| Tullydowey |
Artillery Fort: Mullan Fort |
H 8395 5174 |
Dungannon & South Tyrone
|
062:001 |
| Tullydowey |
Confeacle Cross |
H 8387 5212 |
Dungannon & South Tyrone
|
062:003 |
| Other
sites of unique archaeological importance within 1km radius of the Proposed
Line route |
| Bracknagh |
Rath |
H 8147 4672 |
Armagh |
011:005 |
| Benburb |
C 17th church,
graveyard & enclosure |
H 8178 5214 |
Dungannon & South Tyrone
|
061.025 |
| Drummeland |
St Malachy’s/St Mochua’s
Well |
H7935 3229 |
Armagh |
019.009 |
| Gorestown |
Rath |
H8316 5596 |
Dungannon & South Tyrone
|
062.005 |
| Listarkelt |
Multiperiod church, graveyard
& enclosure |
H7933 3219 |
Armagh. |
019.010 |
| Doohat |
Standing Stone |
H7840 3035 |
Armagh |
019.013 |
| Drumderg |
Mound |
H 8292 5263 |
Dungannon & South Tyrone
|
061:001 |
| Drummond |
Rath |
H 8052 3698 |
Armagh |
015.027 |
| Lisbanlemneigh |
Rath |
H 8160 5464 |
Dungannon & South Tyrone
|
061:010 |
| Listarkelt |
Rath reused as tree ring |
H 7902 3149 |
Armagh |
019.011 |
| Mullyard |
Rath |
H 7962 3002 |
Armagh |
019.014 |
| Mullyard |
Standing Stone possibly megalithic
tomb |
H 7991 3110 |
Armagh |
019.012 |
| Rawes |
Rath |
H 7859 3483 |
Armagh |
019.003 |
| Tivnacree |
Rath |
H 7909 3401 |
Armagh |
019.005 |
|
For more information
about these sites and monuments, please refer to ‘The Northern Ireland
Sites and Monuments Record’ (NISMR) Database on the Environment &
Heritage Service website:
http://www.ehsni.gov.uk/built/mbr/monuments_database/mons.asp
6.
Natural Environment
A. Woodlands
- Woodlands occupy
c.2% of the Armagh Drumlin area and less than 4% of the Loughgall Orchard
Belt compared with c 5.6% for Northern Ireland as a whole.
- According to the
EHS/Planning Service survey of landscape character areas within
N. Ireland, ‘the management and ongoing planting of woodlands is essential
to conserve the special landscape character’.
- The Ancient Woodland
Inventory, carried out by the Woodland Trust, identified 3 areas
of ancient woodland potentially affected by the proposed North/South
Interconnector. These are:
- Artasooley (Grid
Ref: 8249) in the Loughgall Orchard Belt (ID:1823)
- Norton’s Crossroads
(Grid Ref: 7938) in the Armagh Drumlin Area (ID:1388)
- Norton’s Crossroads
(Grid Ref: 8038) in the Armagh Drumlin Area (ID:1389)
- The proposed line
would pass very close to these areas of ancient woodland which form
part of our precious natural heritage and provide a unique habitat for
many of our endangered species.
B. Grassland
and Arable
- The diversity of
habitats, even within the farmland dominated landscape of the Armagh
Drumlin Area, which includes damp grasslands, hedges, woods, arable
and fens, gives rise to diversity not only of plant species but also
of mammals, insects and birds. Thus several of the bird Priority Species
are recorded - bullfinch, song thrush, linnet,
yellowhammer, reed bunting and curlew; indeed curlew,
snipe and lapwing are specifically recorded from damp grasslands.
- Within the Loughgall
Orchard Belt, in the farmland generally, bird Priority Species recorded
include song thrush, spotted flycatcher, tree
sparrow, skylark, reed bunting and linnet.
C. Wetlands
and Lakes
- Within the Armagh
Drumlin Area, there are numerous small fens, which are seen as not
only of local importance for biodiversity, but also as of national importance
- Within the Loughgall
Orchard Belt, fens form a mosaic with reedbeds around
loughs, as for example at Edenderry Lough which has the most extensive
complex.
- The River Blackwater
has river water-crowfoot as well as the white-clawed
crayfish, salmon, trout and dollaghan. The
otter is widespread.
- Loughs and river
valleys, including the network of small streams that characterise the
area to be dissected by the North South Interconnector are important
components of the landscape which should be conserved, avoiding damage
through changing land uses.
- The Blackwater
River Valley is a rural, peaceful, undisturbed and unspoilt valley with
outstanding scenic qualities. The small-scale enclosed character of
the valley ensures that large scale or extensive development would be
intrusive.
7. RECREATIONAL
ACTIVITIES
A. Cycling
National Route
91 of the National Cycle Network follows the Navan Fort Road between
Armagh and Killylea. The proposed North South Interconnector would pass
over this road (Grid Ref: 81,45)
B. Road
Bowling
A traditional
Irish sport played once played all over Ireland but now played mainly
in Cork and Armagh. This is a world-famous and traditionally unique
sport which continues to attract a strong following over local country
roads in the Armagh area. Pylons will inhibit this sporting tradition
and create health risks if practiced and undermine the enjoyment of
this sport via the perceived threat.
C.
Canoeing
The Blackwater
Canoe Trail, which is 20 km long, commences at Maydown Bridge and meanders
east through the beautiful Armagh/Tyrone countryside to Blackwatertown
and the Moy. The proposed North South Interconnector would pass over
this trail (Grid Ref: 83,51) http://www.countrysiderecreation.com
D. Fishing
River Blackwater
and Edenderry Lough (Edenderry Rod and Gun Club)
E. Local
Gun Clubs and Hunting Associations
Annual hunt
day in Killylea, Madden Gun Club, Derrynoose Gun Club, Benburb
Gun Club, Tullysaryan Gun Club
F. Football
Use and enjoyment
of football fields is severely hindered by the visual intrusion of pylons
G. Walking
The ability
to walk our country roads and lanes will be destroyed to the visual
eyesore of pylons- health risks also associated with walking in
the vicinity of the pylons
8. TOURISM
- Paragraph 3.2 of
the Armagh Area Plan states as an objective to “To encourage the development
of the District’s potential”. Clearly with a pylon dissecting
our unique landscape there will be a significant negative impact on
the appearance of our landscape and ultimately tourism activity and
opportunity now and in future years. For the purposes of an objection
this may include the views from a Bed and Breakfast or the ability of
a local farmer/landowner to use his lands as a golf course.
- Existing tourism
of the area will be adversely affected- visitor numbers will decline,
potential tourists will be discouraged from visiting due to pylons,
motorists
travelling through our landscape will not advertise our area but instead
will report back to others of the unsightly appearance of pylons in
our area.
- Local features include
Navan Fort, Blackwater Valley, Ringforts, Golf courses, Pubs, Hotels,
Restaurants
- Benburb Valley Park
– One feature of note is the Benburb Valley Ecotrail which commences
in the grounds of Benburb Priory.http://www.ecotrails.co.uk
9. SCHOOLS,
CHURCHES, COMMUNITY CENTRES
A. Schools
and Community Centres
Impacts on
our children, teachers and all in any way associated with our schools;
this also will affect future children, teachers- health issues, outdoor
pursuits are hindered, nature walks. Also sports grounds and local facilities
in the vicinity of the line.
B. Churches
People attending
services and activities in church halls will be under undue threat of
pylons, health issues, enjoyment of church services curtailed due to
perceived threat,
Assembly in
graveyards and the right of assembly without undue threat of pylons
10.
OTHER EXAMPLES OF CONCERNS
i)
Visual impact of the proposal- a blight in our landscape;
ii) The
established field pattern of our countryside being obliterated- our
farming landscape has taken hundred’s of years to mature to it’s
current appearance- placing pylons through this landscape is totally
inappropriate for a rural landscape. The pylons are totally out-of-keeping
with the established land use of our countryside.
iii) Visual
intrusion of the proposal to your home- the proposal will be overbearing
and adversely affecting the residential amenity of your dwelling curtilage
(i.e it affects how you can relax within your house and your garden
as there is a perceived/real threat of adverse health effects);
this is a legitimate planning consideration and has been the reason
for many proposed mobile phone masts being refused permission due to
their proximity to residential dwellings.
iv)
Visual intrusion to public roads and assembly points- the sensitivity
of our landscape to adverse visual impact (ie too much or inappropriate
development) is exacerbated by the density of public roads which cross
our countryside; for example, between the counties of Armagh and Monaghan
we have the highest density of road network per sq. kilometre of land
in rural Western Europe. This road network will result in the
pylons being directly visible daily to 10’000’s of motorists travelling
through this landscape. This figure will increase as traffic volumes
continue to increase. This is wholly unacceptable in modern day
planning and environmental assessment.
i)
The proposal will adversely affect the setting of a nearby Rath/hillfort;
ii)
The proposal will be in the foreground of Navan Fort/Armagh Cathedrals
etc. (views of these monuments can include distances up to circa
10 miles or whatever distance the human eye can see)
iii) Another
example would be the setting of a standing stone or rath- views of these
features can extend for several miles and a pylon in the visual foreground
detrimentally affects the setting of these features.
v) future
expansion plans of farms being hindered due to a restriction corridor
being placed on both sides of the proposed line.
Expansion
of existing businesses will be hindered; new businesses seeking
to locate in vicinity of proposed pylon scheme will not obtain planning
permission; farm diversification schemes will not be viable; foreign
investment to our area will not be forthcoming
The
number of single houses in proximity to the pylon route- there is
no other rural area in western Europe which
has as many rural dwellers as our localities- circa 50 % of the population
in Northern Ireland (and 60% in southern Ireland) reside in the rural
area (ie. Outside defined settlement limits). At a local level
this equates to every single metre of this pylon being visible from
public view continuously by existing residents.
- Devaluation of property
- Future potential
of land- a pylon traversing our countryside obliterates potential of
our countryside for in excess of 100 years;
- Adverse activity
during construction stage- can take up to 9 months to complete each
pylon; no. of concrete lorries required (circa 26 loads per pylon),
crane/digger manoeuvring, laneways being created to facilitate machine
access.
- Right of way issues-
permanent easements required- this is in total opposition to land-owners
and property owners rights;
- Sustainable development-
the pylons are contrary to the underlying planning policy test of requiring
all development to be sustainable. Sustainable development is
the core policy test of relevant planning policy; in particular draft
PPS21 “Sustainable development in the countryside”.
- Wildlife- can include
migrating birds, nesting sites, Natural Heritage Areas, watercourse
damage during and post construction
- Loss of trees and
hedgerows; trees and hedgerows up to 250 hundred years old are required
to be removed, topped and obliterated to facilitate pylons and access
roads;
- Flora and fauna-
For example, a marshland or Heritage Area may be affected by the proposal.
Removal of hedgerows and mature trees along the line of the proposed
pylon is also an unacceptable scarring of the landscape. This
can be extended to include mature trees which offer a degree of character
to the local area and are perhaps worthy of a tree preservation order-
(N.b. A Tree Preservation Order can be obtained by notifying Planning
Service of the tree’s existence and then requesting that a Tree Preservation
Order be made on the tree/or group of trees. This is an effective
means of ensuring no development takes place in the area).