Eoghan Murphy TD
Minister for Housing, Planning, Community and Local Government
Department of Housing, Planning, Community and Local Government
Custom House
Dublin D01 W6X0

17 September 2018

Re. Urgent need to complete National Landscape Character Assessment to facilitate development of renewable energy infrastructure

Dear Minister Murphy,

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. The Irish Georgian Society is a strong advocate on the subject of the protection of historic landscapes and has held a number of educational events on historic gardens and landscapes, the most relevant to this consultation being the seminars entitled “Dublin’s Victorian and Edwardian Parks” (February 2013) and “Historic Landscape: Loved, lost or in limbo?” (February 2015), which were held in conjunction with the Irish Landscape Institute.

The Society advocates for sustainable development, as defined in Our Common Future (or the Brundtland Report) published by the United Nations World Commission on Environment and Development in 1987. As set out in the 2005 UNESCO publication UNESCO and Sustainable Development: “Culture is increasingly recognized as an essential dimension of sustainable development, particularly since the 2002 Johannesburg Summit”. The work of the Society in encouraging and promoting the conservation of distinguished examples of architecture, the allied arts and historic landscape in Ireland is, therefore, inextricably linked with the concept sustainable development. The Society has made numerous submissions to the Department in the past as part of policy consultations highlighting the sustainable reuse and regeneration of historic building stock as a key pillar of sustainable development. It should go without saying that the Society further supports the shift away from reliance on fossil fuels towards renewable energy for obvious reasons, but it is also worth noting that embracing renewable energy technologies can facilitate the protection of large rural demesnes of very significant heritage importance into the future. In this regard, the Society welcomes the pioneering approach to seek to support the long-term viability of the Beaulieu House and lands in Co. Louth with the sensitive development of a solar farm at an appropriate location within the demesne.

The Society, however, is gravely concerned by the haphazard approach to locating regional and national level renewable energy projects. Specifically, there is nothing in statutory planning policy, which would help to direct those renewable energy projects likely to result in significant changes to the landscape to areas of less sensitivity.

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.

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.

The Society notes that numerous applications for strategic renewable energy developments (and, in particular, wind energy developments) have been wholly or partly refused permission due to potential impacts on cultural heritage, including impacts on sensitive landscapes of heritage significance. Wind energy developments have been proposed in close proximity to some of Ireland’s most valued historic landscapes, such as the great landscape of the Blackwater in Waterford and the designed landscapes at Headfort, Co. Meath and Whitewood, Co. Meath.

There is no specific reference to the potential impacts of wind energy developments on built heritage, the historic environment or landscapes of heritage importance in the Wind Energy Guidelines 2006, or the subsequent draft revisions to those guidelines.  Indeed, the original 2006 Guidelines go so far as to highlight that heritage designations do not preclude wind energy development.  Having regard to the stronger position on heritage expressed in policy documents in other jurisdictions, such as in Wind Energy and the Historic Environment (revised by English Heritage in 2012) and the UK Planning Policy Statement 22: Renewable Energy (PPS 22), this is considered to be confusing. Aside from endangering our shared historic environment, failure to set out a clear policy for the protection of sensitive landscapes leads to uncertainty for communities, planning authorities, An Bord Pleanála, developers and investors.

National Policy Objective 61 of the National Planning Framework states that the Government will “facilitate landscape protection, management and change through the preparation of a National Landscape Character Map and development of guidance on local landscape character assessments, (including historic landscape characterisation) to ensure a consistent approach to landscape character assessment, particularly across planning and administrative boundaries.” Having regard for the potential for development, and, in particular, the development of renewable energy projects, to result in impacts and cumulative impacts on sensitive landscapes, it is essential that a detailed analysis of Ireland’s landscape is carried as a matter of urgency in order to ensure that development is directed towards appropriate locations. The completion of the NIAH Survey of Historic Gardens and Designed Landscapes will also be of significant importance in determining preferred locations for major renewable energy and energy infrastructure development.

Having regard to the matters raised above, the Society calls on the Government to take swift action to complete the National Landscape Character Assessment. The publication of a National Landscape Character Map will help to ensure the protection and management of landscape as one of Ireland’s most important and most valuable physical assets, while at the same time providing much needed certainty to developers and investors seeking appropriate locations for major new renewable energy projects as we move towards achieving a carbon-free society by 2050.

Please do not hesitate to contact us if we can be of any further assistance.

Yours faithfully,

Donough Cahill
Executive Director IGS

c.c. Josepha Madigan TD, Minister for Culture, Heritage and the Gaeltacht