Ciara Conway Labour T.D. for Waterford
Gridlink 25 Submission to Eirgrid 36 Mary Street, Dungarvan , Co. Waterford 058 245 14 Ciara.Conway@oireachtas.ie
Observations in relation the Gridlink project. ➢ Alternatives to Overhead Lines (OHL) ➢ Call for Cost Benefit Analysis examining social and environmental impacts and full consideration of alternatives. Section 6.2.3 of the Stage 1 Report outlines EirGrid’s rationale in selecting the overhead line (OHL) HVAC option to progress this project, whilst Sections 6.2.1 and 6.2.2 outline the technical considerations of both the OHL and underground/sea cable options. It is noted that the report states that both the underground and subsea cable options are technically feasible, but that these were discounted on the basis of higher capital and operational costs, and due to the lack of flexibility and extendibility of same. I am of the view, and I note that Waterford County Council, in its submission, highlights that taking into account the scale, spatial extent and nature of the proposed project, and the potential impacts on the receiving environment, population, heritage and landscapes, the exploration of the electricity transmission alternatives set out in the Report is inadequate and is lacking in the specific required to allow fully informed comment. It does not appear that the case for overhead lines has been fully demonstrated by Eirgrid to be the clearly preferable option having regard to all the issues and concerns raised. I would request that Eirgrid reexamine this matter and that it would set out all of the Ciara Conway TD : Submission on Gridlink Stage 1 report- APPENDICESPage 1
transmission options available to ensure that the full merits of all technically feasible alternatives receive equal and transparent consideration. In particular a costbenefit analysis should be considered, having regard to the social and environmental costs for communities and citizens. It has been stated that it is potentially three and a half times more expensive to put cables underground where it is technically possible to do so. However, we do not know if that is the case. The Labour Party, in particular, will put a figure on the social cost and environmental impact. The Eirgrid Stage 1 report seems to give a very high weighting to financial considerations. As an elected member I would strongly argue that the investment in the Grid must certainly be environmentally sound, it not impact on the landscape or on tourism, nor should it impact on our communities and citizens
➢ Methodology used to Select Corridors The Stage 1 report, indicates that the proposed corridors were mostly chosen by GIS overlay mapping and so on. This ‘desk work’ was used to draw up the corridors as they are currently presented . This points to an absence of field work at this stage in the process. I would ask for this to be revisited, and, taking into account the situation as viewed from site visits the recommended corridors reconsidered. I also note that it is the view of Waterford County Council that sections of the heatmapping analysis do not reflect accurately on the actuality on the ground. These matters should be revisited and the situation reassessed and updated as the importance of fieldwork studies cannot be overstated. The Submisssion presented to Eirgrid from Waterford County Council makes some interesting points as regards the merits and uses of the Holford model and applying this model in the context of Waterford/ Ireland and I would echo and support these points. The Waterford County Council submission also raises questions in relation to several of the corridors and their proximity to population centres, with an OHL corridor passing straight through the residential centre of Knockanore for example, and creating other issues in that conflict with zoning elsewhere in the county. The map below was produced by tWaterford Ciara Conway TD : Submission on Gridlink Stage 1 report- APPENDICESPage 2
County Council and identifies several examples as to why the Planning Authority is not satisfied that the population constraint mapping data utilised by EirGrid in the designation of the proposed route corridors contains sufficient detail to allow fully informed decisions to be made in relation to potential adverse impacts on the existing centres of population in Waterford . Essentially , the Waterford Planning Authority, with its expert local knowledge and statistics is highlighting issues which would call into question some of the statistics and modelling used by Eirgrid . It is essential that Eirgrid will engage with the council further on these matters.
Settlement Proximity to Proposed Route Corridors
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➢ Impact on landscape and impact on Tourism Central among the concerns expressed frequently to me about the proposed corridors in Waterford is that they take in unspoilt and scenic landscape, notably the Blackwater Valley, the heritage town of Lismore, the Comeragh Mountains and the Rathgormack hinterland. I fully understand and share these concerns and have full records of email, phone and letter communications and objections which I would be willing to share with Eirgrid in order to demonstrate the volume and level of concern sparked by the prospect of OHL and pylon towers in the Comeraghs, Blackwater Valley, Lismore and Rathgormack ( to namecheck but a few particularly scenic locations). These areas are extensively used by walking groups, cyclists, camera clubs and those with a keen interest in nature such as ornithologists/birders. Note for example, the success and profile of the annual Sean Kelly Tour in the Comeragh Mountains – with more than 5000 cyclists competing in one weekend alone. Previous Irish stages of the major international cycling tours ( such as the Tour de France) have featured spectacular footage with the backdrop of the Comeraghs and the unspoilt Vee. There are future opportunities for expansion into adventure sports including hanggliding , paragliding ( bother powered and free form) and consultation with the Irish Powered Paragliding and Hanggliding Association might be advisable at this stage, given the serious obvious risks posed by OHL . Several key report have been published in recent years on Waterford’s Economic outlook and in each of these highlights tourism as growth area with the Waterford Implementation Group1 ,report on the Economic Strategy for Waterford City and County noting that a short –term goal is to : “Develop joint and cross promotion of local attractions from Waterford Viking Implementation Plan to the Minister for the Environment, Community & Local Government ‘One Waterford – Delivering Jobs, Efficiency and Growth’,May 2013 1
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Triangle, to the gardens and demesnes, Copper Coast, Comeraghs and Knockmealdown mountains, and other heritage sites such as Dungarvan, Lismore, Ardmore and Dunmore East. • Promote activity tourism and development of products for niche markets.”
The same report cites the Comeraghs and Knockmealdown mountains as central to tourism development potential and highlights the need for :
• Continued improvement and development of walking and cycling trails across the county and including the Copper Coast, with Dungarvan and the Comeraghs as a centre of walking and cycling excellence2 .
Engagement with groups from across Waterford has highlighted the importance in economic terms of unspoilt mountain views. In Rathgormack, the sweeping mountain view has featured in ad campaigns for products such as Mc Donalds, with the aim of highlighting the unspoilt natural landscape where cows are bred and fed . Such unblemished backdrops also play a role in reinforcing in the ‘green Ireland image’, a further tourism boost. Given these contexts by way of example, it is alarming to note that in the Stage 1 report the criteria used to inform the evaluation of the identified OHL route corridor options and substation sites include the “number and nature of Bord Fáilte top visitor attractions located within the route corridors”, and “areas of route corridor traversing land zoned for high amenity”. No reference is made to walking routes, cycleways or garden trails which are the keystone tourism assets in County Waterford. As previously highlighted here, and in the report to you from Waterford County Council development of appropriate recreational trails is a key tourism objective in the future development of the County Work is currently underway on a proposed Greenway along the Waterford to Dungarvan disused railway line , and the national looped 2
Economic Strategy for Waterford City & County – Final Report , Page 47
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walks in the Rathgormack. From the map opposite it is clear that the looped walks and proposed greenway are in close proximity to the proposed K9 and K18 proposed transmission routes – clearly this is undesirable Landowners – Values Householders and farmers have expressed concerns as to the impact locating OHL and tower pylons may have on their land values or property resales.
Impact on Natural Habitats County Waterford features a wide range of habitats – some of these include coastal , uplands, water corridors and wetland habitats, grasslands, woodlands and hedgerows. The value of these habitats is recognised in the high number of sites in the County designated by the State for nature conservation.
The Comeragh Mountains is a special area of conservation (SAC 001952) as is the Blackwater Valley SPA 004094 In the context of such designation effect of OHL – or any other means of power transmission requires careful consideration . Ireland is a key migration route for many bird species, so undergrounding should be considered if OHL’s are to be routed across known bird flight paths, particularly migration paths. Consideration also needs to be given to the impact OHL and associated tower pylon structures would have in areas containing unusual glacial features. These areas (in the Comeraghs) are frequently visited by residents of Waterford and the South East , in addition to being a destination for walking groups and mountaineering clubs
Consideration should also be given to the provisions of Article 10 of the EU Habitats Directive in terms of the importance of sites of local biodiversity interest and ecological corridors connecting prime sites of nature conservation.
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➢ Historical sites – Archaeological impact The following sites of historical and archaeological interest are important in terms of historical interest and tourism value. The impact of OHL must be balanced in the context of their significance The historic sites on the Lismore & The Vee Drive are Lismore Castle with its Contemporary Art Gallery and Gardens, St. Carthage's Cathedral, St. Carthage's Parish Church, Lismore Hotel and The Library, all in Lismore. Lismore is a heritage town ,as previously outlined.
Cappoquin House in Cappoquin and Mount Mellary Abbey, outside Cappoquin.
Mothel Abbey (13th c.) near Rathgormack is a noted historic site. As are Ormond Castle & Manor House, (16th c.) and Old Carrick Bridge.
Molana Abbey (12th c.) near Glendine, Mount Mellary Abbey, Tourin House & Gardens near Cappoquin and Ballyduff Castle, near Ballyduff, are the main attractions on the lovely Blackwater Valley Scenic Drive. ➢ Health Frequent among the concerns presented to me on the Gridlink project, is that of health. A more extensive public information campaign and engagement on this aspect of the project would be desirable
By way of concluding remarks I would add that I would prefer to see undergrounding of lines where possible ,with the possibility of using the natural corridors already provided by the motorways/ road network investigated in full. A full cost benefit analysis with strong weighting on social impact is needed. I share oftenexpressed concerns regarding the visual impact of OHL and transmission towers areas in areas of unspoilt scenery, notably through
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the Comeraghs, the Blackwater Vally , in Rathgormack and the impact of such structures on the heritage town of Lismore.
APPENDICES
STATEMENT BY CIARA CONWAY T.D. ViceChair, Oireachtas Committee on Health and Children Labour, Waterford. 3rd December 2013
Private Members Business Speech I thank the Minister for giving me some of his time to speak in this very important debate. He is correct; for such a significant infrastructural project it is of concern that we have not had an opportunity to discuss it heretofore. There is much opportunism in the House, in particular on the Opposition side because the reality is that one cannot dismiss the consultation process. Given that it is not even finished, I question how one could presume or guess what the outcome will be. The closing date for the receipt of submissions from the public is 7 January.
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I welcome the amendment proposed by the Minister to the motion. Two points are of particular note. There is a reference to EirGrid fully engaging with potentially affected communities. In his response to the motion the Minister expressed disappointment with the grave concerns expressed by Members on all sides about the consultation process to date. I hope EirGrid and those watching the debate will take cognisance of this. The difficulty for public representatives and our constituents is that we believe we are not being heard. In his response the Minister has outlined how EirGrid has stated it will consider undergrounding cables where it is technically possible, taking into consideration population density, visibility, biodiversity and water catchment areas. However, this has not been explained to people and it is not their understanding. I call on those who are carrying out the consultation process to take cognisance of this. When I engaged with EirGrid on undergrounding cables, I was dismissed. The Minister also referred to an impartial examination of the case for achievable engineering solutions. People would really like to see a cost-benefit analysis of the case for undergrounding cables. We have heard that it is potentially three and a half times more expensive to put cables underground where it is technically possible to do so. However, we do not know if that is the case. The Labour Party, in particular, will put a figure on the social cost and environmental impact. As a Government we have taken decisions to extend measures over months and years. If it is technically possible to do it, the Government should make the investment in the grid to ensure it is environmentally sound, does not impact on the landscape, the environment or communities. We should embrace a process that would allow us to examine such issues because that is what people seek. I join the Minister and other speakers in calling on people to ensure they engage with the process and make their submissions before 7 January. From engaging with communities along one of the proposed routes, stretching from the Blackwater near Lismore, where the pylons would be potentially disastrous, down through the Comeragh Mountains and up through Rathgormack, I noted their great concern is that not enough people knew about the matter. Concerned citizens engaged in a door-to-door information campaign to ensure engagement with the process. That community groups have taken this on shows us that the consultation process has not been successful. I welcome the communities' approach, however. I encourage communities and other groups to ensure that they make submissions to EirGrid on or before 7 January. I was glad to hear the Minister say Fáilte Ireland is now engaging with EirGrid on the Grid25 programme. I was not aware of this. I was very concerned given that this is the year of The Gathering, which has been a great success. People have come to our shores to engage with us partly because of Ireland's natural beauty. I am glad of the Minister's statement and thank him for it.
Appendix 2 : Protected Areas Ciara Conway TD : Submission on Gridlink Stage 1 report- APPENDICESPage 9
Protected sites with particular relevance www.npws.ie/protectedsites Comeragh Mountains SAC 001952 Features of Interest ●
Shining sickle moss (Drepanocladus vernicosus) [1393]
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Oligotrophic to mesotrophic standing waters with vegetation of the Littorelletea uniflorae and/or of the Iso�toNanojuncetea [3130]
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Water courses of plain to montane levels with the Ranunculion fluitantis and CallitrichoBatrachion vegetation [3260]
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Northern Atlantic wet heaths with Erica tetralix [4010]
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European dry heaths [4030]
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Alpine and Boreal heaths [4060]
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Calcareous rocky slopes with chasmophytic vegetation [8210]
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Siliceous rocky slopes with chasmophytic vegetation [8220]
SITE SYNOPSIS SITE NAME: COMERAGH MOUNTAINS SITE CODE: 001952 The Comeragh Mountains are situated approximately 11 km southwest of Carrickon Suir. They consist of a plateau of Old Red Sandstone whose edges have been deeply scarred by recent glaciation. Corries and deep valleys are cut into the eastern and western sides leaving a central ridge whose width is reduced to 270 m at its narrowest point. The rocks, which are horizontallybedded, stand out as a series of terraces around these corries, which often house small mountain lakes such as Coumshingaun, the Sgilloge Loughs, the Coum Iarthar Loughs and Crotty's Lough. The central plateau is at an altitude of about 700 m and supports areas of blanket bog. The peat is up to 2 m deep in places and is rich in Cottongrass (Eriophorum angustifolium and E. vaginatum), Deergrass (Scirpus cespitosus), Heather (Calluna vulgaris), Crowberry (Empetrum nigrum) and mosses (Sphagnum spp., Polytrichum spp.). North of Coummahon, the blanket bog has suffered from erosion, in many places down to the underlying bedrock. Eroding channels, hummocks and flats of loose peat are also present. Heath vegetation grows on the welldrained rock debris of slopes and moraines, but also secondarily on eroded areas. Typical species include Heather, Bell Heather Ciara Conway TD : Submission on Gridlink Stage 1 report- APPENDICESPage 10
(Erica cinerea), Bilberry (Vaccinium myrtillus), Tormentil (Potentilla erecta), Fescues (Festuca spp.) and Bents (Agrostis spp.). On the northern and eastern sides of the site Bracken (Pteridium aquilinum) is abundant, with some colonisation by Common Gorse (Ulex europaeus), Holly (Ilex aquifolium) and Rowan (Sorbus aucuparia). The cliff flora contains many mountain species, including several for which this is their only station in Waterford. St. Patrick'scabbage (Saxifraga spathularis) grows at Coumshingaun where there are also records for such plants as Mossy Saxifrage (Saxifraga hypnoides), Dwarf Willow (Salix herbacea), Cowberry (Vaccinium vitisidaea), Roseroot (Rhodiola rosea) and the ferns, Hymenophyllum wilsonii and Cystopteris fragilis. Coumshingaun Lough, which is located on the eastern slope, is an excellent example of an ultraoligotrophic lake. Unlike most corrie lakes the water is exceptionally clear. It contains a stonewort, Nitella flexilis and also Bog Pondweed (Potamogeton polygonifolius) but only down to the relatively shallow depth of 5 m. Shining sicklemoss (Drepanocladus vernicosus), a species listed on Annex II off the EU Habitats Directive, has been recorded at Sgilloge Loughs. Peregrine, a species listed on Annex I of the EU Birds Directive, breeds within the site, as does Raven. Hen Harrier, also listed on this annex, is found on the site as is Irish Hare, a Red Data Book species. Arctic Char has been recorded from the Comeragh Lakes, though not since 1930. This species is listed in the Red Data Book as threatened in Ireland. The integrity of the remaining areas of blanket bog and the general habitat diversity of the site are under threat from landuse pressures such as grazing, burning, afforestation and leisure activities. This large site has a diverse range of habitats, including blanket bog, heath, upland grassland, scree, exposed rock, lakes and streams. The blanket bog represents the southeastern extremity of its range in Ireland. There are many corries, most of which have associated oligotrophic lakes. 10.12.2001
Blackwater Callows SPA 004094 Features of Interest Whooper Swan (Cygnus cygnus) [A038] Wigeon (Anas penelope) [A050] Teal (Anas crecca) [A052] Ciara Conway TD : Submission on Gridlink Stage 1 report- APPENDICESPage 11
Blacktailed Godwit (Limosa limosa) [A156] Wetlands & Waterbirds [A999]
SITE SYNOPSIS SITE NAME: BLACKWATER CALLOWS SPA SITE CODE: 004094 The Blackwater Callows SPA comprises the stretch of the River Blackwater that runs in a west to east direction between Fermoy and Lismore in Counties Cork and Waterford, a distance of almost 25 km. The site includes the river channel and strips of seasonallyflooded grassland within the flood plain. Sandstone ridges, which run parallel to the river, confine the area of flooding to a relatively narrow corridor. The river channel has a welldeveloped aquatic plant community, which includes such species as Pond Watercrowfoot (Ranunculus peltatus), Canadian Pondweed (Elodea canadensis) and a variety of pondweeds (Potamogeton spp.), watermilfoils (Myriophyllum spp.) and waterstarworts (Callitriche spp.). The site is a Special Protection Area (SPA) under the E.U. Birds Directive, of special conservation interest for the following species: Whooper Swan, Wigeon, Teal and Blacktailed Godwit. The E.U. Birds Directive pays particular attention to wetlands and, as these form part of this SPA, the site and its associated waterbirds are of special conservation interest for Wetland & Waterbirds. The site is of high ornithological interest on account of its wintering waterfowl populations. Whooper Swan occurs in numbers of international importance (212) all figures are mean peaks for the five winters 1995/96 to 1999/2000. Bewick’s Swan were regularly recorded at the site up to the mid1990s; however, in the winters of 1997/98 and 1998/99 only four and two individuals respectively were recorded, and the species is no longer considered to be a regular visitor. This decline is in line with a national decrease and a marked contraction in range. The site supports nationally important populations of Wigeon (2,313), Teal (898) and Blacktailed Godwit (251). Other wintering species that occur include Mallard (398) Shoveler (26), Lapwing (191), Curlew (457) and Blackheaded Gull (311). Little Egret uses the site throughout the year as there is a nearby breeding colony downstream. The river system provides an important feeding area for these birds. The Blackwater Callows SPA is of importance for its populations of wintering waterfowl, including an internationally important population of Whooper Swan and nationally important populations of Wigeon, Teal and Blacktailed Godwit. The presence of Whooper Swan, as well as Little Egret, is of particular note as these species are listed on Annex I of the E.U. Birds Directive. 29.9.2010
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