Conservation The Grid Link Project

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The Grid Link Project proposes major investment in the electricity transmission grid linking Leinster and Munster and will consist of a new overhead power line linking Cork, Wexford and Kildare.  The project is at an early stage and EirGrid opened a public consultation on the publication of their Stage 1 Report identifying 1 km wide feasible corridors for the project in Autumn 2013.  The Irish Georgian Society has made a submission to EirGrid raising concerns about the failure to take proper account of architectural, archaeological, cultural and natural heritage in the identification of those feasible corridors.  The submission can be read here.

The Grid Link Project Manager

EirGrid

PO BOX 12213

(Free Post Licence No F5007)

19th December 2013

Re. The Grid Link Project

Dear Sir or Madam,

The Irish Georgian Society welcomes this opportunity to comment on the Grid Link Project Electricity Transmission Scheme linking Leinster and Munster.

The Irish Georgian Society is a membership organisation, which encourages and promotes the conservation of distinguished examples of architecture and the allied arts of all periods in Ireland. These aims are achieved through our education programmes, by supporting and undertaking conservation works, publishing original research, planning participation and fundraising. The Society has had a marked and widely acknowledged impact on the conservation of built heritage in the state and has wide experience of the problems associated with the restoration, repair and maintenance of the fabric of historic property.

It is understood that this phase of consultation comprises focussed consultation on the Stage 1 Report.  In particular, EirGrid’s Information Brochure 3 (Autumn 2013) calls for feedback on the following specific issues:

 The work that has been carried out to date;

  • Factors that should be considered when determining the least constrained corridor;
  • Other local constraints that should be considered;
  • Other information that should be considered when developing this project.

 The comments of the Irish Georgian Society in relation to each of these matters are set out below.

 The work that has been carried out to date

 (1)        Methodology used in undertaking the work to date

The work that has been carried out to date follows the methodology set out in EirGrid’s Project Development and Consultation Road Map.  This provides that feasible corridor options are identified at Stage 1 on the basis of what is a primarily desktop analysis.  The preferred route of the project is then chosen from within one of the “feasible 1 km wide corridors” (i.e., the Roadmap states that EirGrid will identify an “indicative line within corridor”).  It is not until Stage 2 that “initial survey” is carried out.  The Irish Georgian Society has serious concerns about the adequacy of this methodology for the reasons set out below.

In circumstances where the project requires an environmental impact assessment, as is the case with the subject Grid Link project, it would appear that it is intended that the work carried out at Stage 1 (i.e., information gathering, identification of constraints and identification of feasibility corridors from which the final route will be chosen) comprises the basis for the consideration of alternatives in the EIS.  Indeed, the clear implications of the Roadmap methodology are that:

 (i)      After Stage 1 has been completed, no alternative feasibility corridors will be identified – the final route of the project will fall within one of the three feasibility corridors; and

(ii)      There will be no further amendment to the alignment of the feasibility corridors identified in Stage 1.

 In relation to the Grid Link project specifically, it would also appear from statements made in the Stage 1 Report and Information Brochure 3 that the consideration of alternative processes is complete and the line will be entirely or, for the most part, an overhead line. That these decisions appear to have been made indicates that the identification of alternatives (i.e., alternatives for the siting and location of the route and for the design of the project with overhead lines being the clear preference) was largely complete with the publication of the Stage 1 Report.

 Given the advanced stage of the design of the project, the Society is gravely concerned that the identification of these feasibility corridors has been based solely or primarily on the findings of desktop analysis of existing datasets in circumstances where EirGrid acknowledges that many of these datasets are incomplete.  For example, while it is clearly acknowledged that one of the most significant impacts of the project will be on landscape, EirGrid would appear to have effectively completed the consideration of alternative routes without carrying out any independent analysis or study of landscape considerations, including historic landscape characterisation. This has occurred in circumstances where the Lead Consultant’s Stage 1 Report acknowledges that the information available on landscape character was insufficient. Similarly, the National Inventory of Architectural Heritage, the Record of Monuments and Places and the Record of Protected Structures do not provide an exhaustive list of heritage structures and sites, with many sites of regional, national and international importance excluded from those lists – historic mapping analysis, research and field survey is always required to identify other relevant sites of importance.

 The methodology chosen by EirGrid for the implementation of the Grid Link Project, therefore, appears to be inconsistent with the statutory Guidelines on the Information to be Contained in Environmental Impact Statements prepared by the Environmental Protection Agency (2002), which states that:

 “The sequence and timing of the design process should be structured to allow environmental factors to be accommodated at appropriate stages. In the early stage of the design this may mean that siting and layout will need to be adjusted to avoid environmental vulnerabilities, such as designed landscapes, ecological, architectural or archaeological heritage.”

 In addition to this, the Society submits that the way in which constraints related to architectural, archaeological and cultural heritage have been categorised is flawed.  Specifically, the Record of Monuments and Places (RMP) is the most widely applying provision of the National Monuments Acts.  The Register of Historic Monuments is a partial and incomplete list of monuments and sites, including places identified after the publication of the RMP.  It is, therefore, unjustifiable to suggest that the Register of Historic Monuments would be a primary constraint, while the RMP and SMR would be a secondary constraint.  Similarly, it is unclear why Architectural Conservation Areas, which offers a lesser level of protection under the Planning and Development Act 2000, as amended, and frequently include structures that are not listed in the Record of Protected Structures, constitute a primary constraint, while protected structures are a secondary constraint.  It is further very difficult to understand which NIAH historical gardens would only constitute a “consideration” in circumstances where visual impact is accepted to be one of the primary issues with the project.  Any categorisation of architectural, archaeological or cultural heritage constraints must come from an assessment of the relative heritage value of the site or structure and its likely sensitivity to the development proposed: the impact of the architectural heritage of erecting a pylon within 50 m of a protected Ordnance Survey trigonometrical marker will be markedly different from erecting a pylon within 50 m of a large Georgian country estate set in a historic, designed landscape or within 50 m of a complex of medieval religious sites.  

 (2)        Adequacy of work carried out to date

The Grid Link Project Lead Consultant’s Stage 1 Report (prepared for EirGrid by RPS Group in September 2013) sets out the work carried out to date in identifying “feasible 1 km wide corridors” and is the subject of this phase of public consultation.  The Society acknowledges that there are a very significant number of factors that must be considered in the categorisation of constraints and the identification of “feasible” 1 km corridors. While these factors have been identified in Appendix 2 of the Lead Consultant’s Stage 1 Report, it is clear that a large number of these constraints were not considered in the identification of the “feasible routes”, which form the basis of this consultation.

 Even the most cursory desktop review of ordnance survey mapping indicates that each of the “feasible routes” cuts through or passes in close proximity to individual and clusters of monuments, protected structures, heritage buildings and historic landscapes of major local, regional, national and international importance.  Having regard to the deficiency of the methodology alluded to above and the failure to take account of sites and structures of major heritage importance in categorising constraints, it is submitted that the work undertaken to date is not an appropriate basis on which to identify “feasible 1 km wide corridors” within which the final route of the Grid Link project will be chosen.

 Factors that should be considered when determining the least constrained corridor

As outlined above, sites, structures and landscapes of architectural, archaeological and cultural importance likely to be sensitive to the development of the Grid Link project must be considered both in the identification of “feasible 1 km wide corridors” and when determining the least constrained corridor.

 Much of Ireland’s most distinguished architectural heritage is to be found in its landscapes, whether it be National Monuments or protected structures, ecclesiastical buildings and ruins or country houses, whether grand or modest in scale.  What is distinctive for all of these structures is their siting and setting.  Furthermore, their associated lands and/or demesnes had been designed, elaborated, planted and inhabited to enhance the setting.  Rivers, loughs, hills, magnificent valleys and mountains are all engaged and embraced whether as framed views or as elements within the designs.

 The gardens and designed landscapes of the 17th through to the 19th century were extensions of the plan of the house, to be experienced through all the senses as one inhabited outside spaces or moved along walks or rides.  House and landscape were often a single coherent design.  Ancient monuments and sacred places along with ruins and churches have been engaged in a visual dialogue across the land with country houses and their designed landscapes, each renewing their importance and redefining their significance.

 In the attendant landscapes of country houses, ancient woodlands have been greatly valued.  Individual groups of trees, avenues, boundary zones and new woodlands have been planted for both utility and amenity value.  They have created microclimates, providing shelter for buildings and productive land.  They have heightened the experience of the setting, and they have composed views, framing significant natural and manmade features.  Natural watercourses and features were augmented with man made versions for utility and beauty and water was managed for supply and productivity in a way that contributed to the landscape.  These landscapes, large and small, along with the fields enclosed with walls or banks and planted with hedgerows that now contain mature trees, all coalesce to make collective creations of singular importance.  Through this pastoral scene EirGrid intend to position the transmission lines and their supporting 60 metre-high pylons, out of all proportion and scale to the structure and detail of the landscape.

 Woodlands, wooded valleys, boundary planting and hedge rows form important ecological corridors and networks, so important not only to maintain biodiversity but also in their contribution to carbon sequestering.  How much of these woodlands and how many of the veteran and mature trees will be removed or made more vulnerable by the construction process and deemed detrimental to safety and security of the transmission lines and their supporting structures?

Other local constraints that should be considered

The great landscapes of the Greese Valley in Kildare, the Blackwater in Waterford, those of the Waterford Wexford Carlow borders, the Brandon Hill and the Comeragh or Blackstairs Mountains all have been admired by foreign visitors from the 18th century to the present.  They have been cherished, maintained and protected over the centuries by toil and investment.  As detailed in the section below, the landscape is one of Ireland’s most important and most valuable physical assets.

 A few examples from the multitude will serve to illustrate what is at stake.

 The early-eighteenth century house and designed landscape of Castle Martin, Co. Kildare was approached along the still-extant long avenue of lime trees.  The so alignment is such that the terminating landscape feature of the avenue seen from the house is none other than Dun Ailinne.  Dun Ailinne, a prominent topographical feature, has been identified as a ‘royal site’ and, the group of the sites at Dun Ailinne, Hill of Tara and Navan Fort in Co Armagh, have been proposed as a World Heritage Site.

 The alternative preferred routes for the power lines, D17 and D12 tightly encircle Dun Ailinne.  Here too, D12 is centred on the National Monument of the early ecclesiastical site of Old Kilcullen, which also affords a prominent viewpoint, giving a panoramic view of the Wicklow mountains and west to the plains of Kildare and Offaly.

 Castletown Cox, begun in 1767 and set in the imposing valley of the Suir is one of the best built eighteenth-century buildings in Ireland. House and out buildings have recently been immaculately restored to the highest conservation standards.  The designed landscape of the demesne has been reassembled and restored by the current owner.  Water features have been repaired and extensive planting and replanting carried out.  The building and designed landscape demonstrate the coordinated and reciprocal design of house and landscape and the exploitation of its natural setting, making this ensemble a national treasure.  The principal rooms of the house look south across the Suir valley to the Comeragh Mountains.  If the proposals for route K9 are realised, 60m high pylons will dominate the view from every window as they stretch the transmission lines across the middle distance just south of the demesne after they have advanced over the Comeragh Mountains.  The alternative Route K2 approaches the demesne from the west, where the house and gardens look along the valley and are overseen by Slievenamon and the line of small hills that line the valley.  The 1km corridor of K2 is positioned through this landscape and slices through the designed demesne landscape, intersecting avenues and carving through woodland.

 Options K21, K16 and K22 cross the Blackwater valley at a particularly spectacular location.  The mainly wooded steep banks let down to the tidal stretch of the river.  This is a Special Area of Conservation.  The picturesque quality and the richness of the habitat have attracted and stimulated the development over the centuries of a string of historic houses and demesnes: Strancally Castle, Tourin House and Gardens (open to the public), Headborough House and Dromana House.  As elsewhere, the demesnes have contributed to the survival of this intact special place, enhancing its ecological quality.  The 19th century Strancally Castle was sited and designed to add romantic drama to this most picturesque of places, while at the same time, itself commanding stunning views both up and down the valley.  Each house and their attendant designed landscape has been subjected to substantial investment either by the owners or the State (by way of Section 482), investment that sought to secure this ensemble of natural and cultural heritage for the future.  The construction works for the power lines and their future operation at any one of the proposed crossings pose a serious a threat and an affront to the valley’s ecology and cultural heritage.

 On a more modest scale, the Irish landscape is studded with many smaller buildings, sites and demesnes of significant heritage importance.  Burtown House and its attendant grounds is one such building. An early-eighteenth century house with attractive 19th century additions, it lies directly beneath the centre-line of the D18 Corridor.  This house and garden has recently been the subject of considerable investment to secure the fabric of the house and outbuildings and to development of the gardens, making it an important additional destination for tourism.

 Another modest gem of heritage significance, whose setting nestles into the beautiful folded terrain of west Wexford, is Berkeley Forest.  A seventeenth house remodelled at the end of the 18th century, it has its main rooms located on the first floor maximising the impact of the views from the windows, looking down over its miniature parkland and focussing on the conspicuous topographical feature of Brandon Hill.  This prospect is framed to the left by the sheltering boundary planting of majestic mature beech trees that hold the ridge.  The house and demesne sits within the D9 corridor.  If the proposal follows this corridor, it may appear over the ridge to the south, Lacken Hill, a designated landscape of greater sensitivity as designated in the County Wexford Development Plan, inflicting a broad gash through the beeches, resulting in significant negative visual impact on the centuries-old views from the house.  In addition, like so many places Berkeley has significance for the intellectual cultural heritage of Ireland.  The name of the place reflects the long history of the site’s association with the Berkeley family from medieval times.  A member of this family, the eighteenth-century Bishop George Berkeley is probably Ireland’s greatest philosopher of international stature.

 It is worth remembering that as one of the signatories, Ireland ratified the European Landscape Convention. The convention notes “that the landscape has an important public interest role in the cultural, ecological, environmental and social fields, and constitutes a resource favourable to economic activity and whose protection, management and planning can contribute to job creation”. It acknowledges “that the landscape is an important part of the quality of life for people everywhere: in urban areas and in the countryside, in degraded areas as well as in areas of high quality, in areas recognised as being of outstanding beauty as well as everyday areas”. Furthermore, it puts forward the belief “that the landscape is a key element of individual and social well-being and that its protection, management and planning entail rights and responsibilities for everyone”.

 We will allow Bishop Berkeley to have the last word.  The public perception of the procedures of EirGrid and its confidence in its proposals for the Grid Link Project would put Berkeley’s ironic words into their spokesperson’s mouth:

 “So long as I confine my thoughts to my own ideas … , I do not see how I can be easily mistaken.”

On the other hand, the aspiration and determination of the Irish Georgian Society in this matter is expressed in another of Berkeley’s cogent sentences:

 “The same principles which at first view lead to skepticism, pursued to a certain point, bring men back to common sense.”

Other information that should be considered when developing this project

The Stage 1 Lead Consultant’s Report makes no reference to the asset value of Ireland’s heritage or the implications of potential negative impacts of the Grid Link project on that heritage for the Irish economy.

 Heritage and Ireland’s historic environment is estimated to account for €1.5 billion or 1% of the State’s Gross Value Added (GVA) and some 2% of overall employment (approximately 65,000 employment positions).  The Society refers EirGrid to the Heritage Council’s 2011 publication Economic Evaluation of the Historic Environment Ireland for further details on the importance of heritage to the Irish economy.

 It is of crucial importance that the design of the proposed Grid Link project take account of the special contribution made by architectural heritage to the Irish economy and ensure the protection of that architectural, archaeological and cultural heritage into the future.

 Conclusion

In conclusion, it is the opinion of the Irish Georgian Society that:

  • Any methodology employed in the identification of the “1km wide feasible corridors”, which is solely or primarily based on desktop analysis of incomplete datasets, is grossly deficient.  Any part of an environmental impact statement based on that methodology is, therefore, defective within the meaning of the legislation and statutory guidance on environmental impact assessment.
  • The methodology employed in the identification of heritage constraints on the proposed “1km wide feasible corridors” was overly reliant on the existence of datasets and involved little or no qualitative assessment of heritage assessments within the study area.
  • The categorisation of heritage constraints is defective in that incomplete datasets (such as the Register of Historic Monuments) and designations affording a lower level of protection (such as Architectural Conservation Areas) were categorised as primary constraints, while more complete datasets (such as the Record of Monuments and Places) and designations affording a greater level of protection (such as the Register of Protected Structures) were categorised as secondary constraints.
  • Any categorisation of architectural, archaeological or cultural heritage constraints must come from an assessment of the relative heritage value of the site, landscape or structure and its likely sensitivity to the development proposed.
  • It is of crucial importance that the design of the proposed Grid Link project take account of the special contribution made by architectural heritage to the Irish economy and ensure the protection of that architectural, archaeological and cultural heritage into the future.

The identification of preferred or feasible corridor options for public consultation is, therefore, premature, pending the carrying out of an adequate level of assessment of environmental constraints.

The Society would welcome the opportunity to meet and discuss the issues outlined above. If we can be of any further assistance to this importance initiative, please not hesitate to contact us.

Yours sincerely,

Donough Cahill

Executive Director

Irish Georgian Society