An Bord Pleanála · sites of ecological importance. It states there are no significant affects...

PL 05.VA003 An Bord Pleanála of 167

An Bord Pleanála

Inspector’s Report Board Reference: PL 05.VA003. Local Authority: Donegal County Council. Scheme: Electricity Infrastructure Development New 110 kV line connecting Binbane

110kV station to Letterkenny 110 kV station, new switching station on proposed Binbane – Letterkenny line and new 110kV line from proposed switching station to new 110kV – 38kV station.

Location of Powerlines: From Letterkenny 110 kV substation to

Binbane, Glenties via a switching station at Tievebrack, Glenties and from Tievebrack to Gweedore Business Park, Gweedore, County Donegal.

Inspector: Daniel O’Connor.


CONTENTS 1.0 Introduction and Statutory Requirements p 03 2.0 Proposed Development p 05

3.0 Environmental Impact Statement p 06 4.0 Planning Context Overview p 63 5.0 Oral Hearing Report Overview p 64 6.0 Assessment p 65 7.0 Conclusion p 79

Achoimre as Gaeilge p 81 8.0 Recommendation p 83 Appendices Appendix 1 Report on Oral Hearing proceedings p 85 Appendix 2 Assessment Reports 2A Landscape and Visual p 121 2B Health Effects p 136 2C Undergrounding p 143 2D Flora and Fauna and Designated Areas p 148 2E Planning Context P 160


1.0 INTRODUCTION AND STATUTORY REQUIREMENTS

An application dated 2nd December, 2008 was made by ESBI Engineering and Facility Management Limited on behalf of EirGrid and ESB Networks under Section 182A(1) of the Planning and Development Act 2000 as amended by the Planning and Development (Strategic Infrastructure) Act 2006. The Development to which the application refers is titled the Donegal 110 kV Project. The Application lists six components namely:

1. Overhead electricity line of 110 kV single circuit construction with earthwire from an existing station at Binbane south east of Glenties via a proposed switching station (Tievebrack) in the townland of Straboy to an existing station at Listellian near Letterkenny (line length proposed 68.4 km)

2. An overhead electricity line of 110 kV single circuit construction from the proposed Tievebrack switching station to a proposed 110 kV to 38 kV station at Ardnagappary at Gweedore Business Park. (line length proposed 33.1 km)

3. An overhead electricity line loop of 38 kV from the existing Derrybeg – Gweedore 38 kV line into the proposed Ardnagappary station (line length 520 metres)

4. Tievebrack 110 kV switching station in the townland of Straboy, north east of Glenties

5. Ardnagappary 110 to 38 kV electrical station 6. Busbar section and new 110 kV line bay in existing Letterkenny

110 kV station in the townland of Listellian.

The application included application fee of €100,000, copies of notice in the Irish Independent of 27th November 2008, the Donegal Democrat of 27th November 2008, the Donegal Peoples Press of 25th November 2008 and the Donegal News of 28th November 2008. It also included documentation and mapping, a Strategic Planning Context Report and an Environmental Impact Statement (Ráiteas Tioncar Timpeallachta) in both the Irish and English languages. The applicant advised of pre-application consultations and the list of prescribed bodies which were consulted and to whom the EIS (RTT) was circulated:

• Minister for the Environment, Heritage and Local Government • Minister for Communications, Marine and Natural Resources • Minister for Community, Rural and Gaeltacht Affairs • Minister for Agriculture and Food • Údarás na Gaeltachta • Commission for Energy Regulation • The Heritage Council • An Taisce • The Arts Council • Regional Fisheries Board • Waterways Ireland • National Roads Authority


• Office of Public Works • Regional Planning Authority • Fáilte Ireland • Offices of Donegal County Council, Lifford An Bord Pleanála advised Eirgrid by letter of 31st August 2007 that following consultations under Section 182E of the Planning and Development Act 2000 as amended, that the Board was of the opinion that the proposed development fell within the scope of Section 182A of the Act as amended. It advised that accordingly the Board had decided that the proposed development would be strategic infrastructure within the meaning of section 182A of the Planning and Development Act,2000 as amended. It is considered that the application complies with statutory requirements. An oral hearing was held in Gallagher’s Hotel, Letterkenny over 5 days commencing on 31st March, 2009 and continuing on 1st ,2nd,3rd and 6th April 2009. The hearing concluded on 6th April 2009. Simultaneous translation in both the Irish and English languages was provided.


2.0 PROPOSED DEVELOPMENT

The proposal is jointly proposed by EirGrid which is the Transmission System Operator (TSO) and ESB Networks which is the Distribution System Operator (DSO). The proposal is described by the applicants as one of reinforcing the electricity transmission and distribution networks in County Donegal. The elements of the project are as follows:

• New overhead 110kV line from the existing substation at Binbane (southeast of Glenties) and Listellian (south of Letterkenny) which is 68.42 kms in length and comprises a total of 362 polesets of which 26 are lattice towers and the remainder are of two-pole timber construction with poles at 5 metres apart. This line also incorporates an earth wire.

• New switching station at Straboy, north east of Glenties on the

proposed Binbane – (Listellian) Letterkenny line and approximately one-third distance on the line measuring from Binbane. This switching station is proposed as the start point of the proposed line to Gweedore. The title of this installation is the proposed Tievebrack switching station

• New overhead 110 kV line from the proposed Tievebrack

switching station to a new 110kV / 38 kV subsation at Gweedore Business Park described as the Ardnagappary susbstation. This line is 33.1 kms in length and comprises 176 polesets of which 18 are lattice towers and the remainder are of wooden two-pole construction with poles set 5 metres apart. This line does not have an earthwire proposed.

• Proposal also includes a new 0.525 km 38 kV loop in

Ardnagappary substation and a new 110 kV line bay in the esisting Listellian (Letterkenny) substation.

The full length of wood poles is stated to be a maximum of 23 metres of which 2.3 metres would be underground. The height of the angle masts or lattice towers is indicated in drawings as being 12, 15 or 18 metres in height for the Tievebrack – Ardnagappary Line and up to 21 metres height on the Binbane-Letterkenny line. (see Appendix E, EIS)


3.0 ENVIRONMENTAL IMPACT STATEMENT 3.1 The Environmental Impact Statement is dated December 2008 and is in one

volume with 15 chapters and a number of appendices. The non-technical summary is produced as a separate volume, but also is included in a section of the main EIS before Chapter 1.

3.2 Non-Technical Summary

The Transmission System Operator (TSO) is Eirgrid and the Distribution System Operator (DSO) is ESB Networks. The Donegal 110 kV project comprises the following: - • 68.42 kilometre length overhead line 110 kV between Binbane and

Letterkenny.

• Switching station at Straboy, Glenties – to be called Tievebrack 110 kV switching station.

• New 110 kV/38 kV substation at Gweedore Business Park to be called

Ardnagappary 110 kV substation.

• 33.1 kilometre long overhead line 110 kV from Ardnagappary to Tievebrack.

• New 0.525 kilometre long overhead loop-in line 38 kV to Ardnagappary

substation.

The NTS states the development falls within the scope of Section 182 A of the Planning and Development Act 2000 and that the EIS has been prepared in accordance with the provisions of the Planning and Development Regulations 2001 – 2007. It refers to public consultations carried out between June 2005 and February 2007. It states that detailed consultations were held with Donegal County Council, the National Park s and Wildlife Service, Northern Regional Fisheries Board and the Loughs Agency during the preparation of the EIS. In describing the need for the development, the problems are described as follows: - • Security of supply for Letterkenny requires an additional 110 kV feed.

• No alternative supply for Killybegs and Kilcar which are fed from

Binbane. For this reason, it is stated that a 110 kV feed through Binbane is needed.


• The current provision of an acceptable standard of supply is possible primarily due to the closure of major industry in the Derrybeg Business Park. A replacement industry with 4 MW demand beyond 2020 would result in an unacceptable voltage level during normal operations.

• The TSO and DSO are acquired to provide connections for renewable

energy generators.

• It is stated there is a prerequisite for strengthening connections of both the Letterkenny and Derry regions to the rest of the transmission network.

It states that the failure to address problems may lead to the curtailment of further industrial and commercial development. In describing the planning context reference is made to the Government White Paper setting out the energy policy framework for 2007 – 2020. It states the proposed reinforcement of the transmission and distribution networks forms part of the electricity programme. The NTS refers to project alternatives from the transmission aspect, the line between Binbane and Letterkenny was selected because it is stated that it meets the technical requirements and complies with distribution planning criteria. It states it was also the preferred solution from a distribution point of view. The NTS states the use of underground cables was considered and ruled out as unsustainable. It states that it would have a disruptive impact on the natural environment, entail a significant land-take and interfere with drainage and watercourses. It also states that overhead lines were maintained and repaired more quickly and easily than underground cables and is not subject to damage from digging activities, which may take weeks to repair. It states the selected switching station and substation sites are located outside sensitive landscape areas and the impact on existing dwellings would be low. It states that the roots for the new 110 kV lines were selected on the basis of minimising environmental impact and impacts on residential amenity. The NTS describes the impacts on the environment and lists the headings which include: - • Human beings.

• Water.

• Flora, fauna and fisheries.

• Soil and groundwater.

• Air and noise.


• Landscape.

• Material assets.

• Cultural heritage.

It notes that the impacts were examined by considering the receiving environment, environmental impacts and mitigation measures were appropriate. It states the most significant potential impacts on the environment were identified as being visual impact of the substation and lines, water quality impacts and traffic associated with construction of the Tievebrack Switching Station. In relation to human beings, the NTS notes positive impacts being expected in relation to local economic development and it refers to the guidance reference levels for exposure to electro-magnetic fields which had been set by the International Commission on Non-Ionising Radiation Protection (ICNIRP). It notes that Eirgrid and ESB Networks would adhere to international and national standards in relation to Electric and Magnetic Fields (EMF). It states there is no evidence to support the view that the proposed development would pose a significant health risk due to adverse affects arising from electro-magnetic fields. In relation to flora and fauna, the NTS states that the lines cross limited lengths of the boundary areas of both internationally and nationally designated sites of ecological importance. It states there are no significant affects predicted in relation to designated sites and that low ground pressure machinery and temporary tracking would be utilised to minimise disturbance to peat box. It notes the proposal to use helicopters at certain locations. It also states that to reduce the risk of collision with overhead lines, bird flight diverters would be placed at pre-determined locations. Referring to water quality and fisheries, the NTS states that mitigation measures would comply with all requirements arising from agreements between the Forest Service and the NPWS with particular respect to harvesting operations in sensitive freshwater pearl mussel catchments such as the Clady and Owenea. It states that a contingency plan would be put in place to address peat movement. Dealing soils and groundwater, the NTS states that with mitigation measures, the impact due to local loss and/or compaction of the peaty soils would be slight. The NTS predicts that the impacts relating to air would be short-term during construction and that dust could be controlled using good site practice. Referring to noise, it states the nature of the project as such that noise levels that could potentially cause damage to hearing would not arise. The NTS refers to landscape and states the landscape in the area of the project could be divided into area types based on their landscape characteristics. It states the Binbane – Letterkenny line crosses four landscape character areas: -


• Open low-land hills and lakes. • Open upland hills and mountains.

• River Finn Valley.

• Letterkenny Urban/Rural Fringe.

It states that moderate negative impacts were predicted for the open upland hills and mountains and the River Finn Valley Landscape Character Areas. The Ardnagappary – Tievebrack line crosses four landscape character areas: - • Gweedore Urban/Rural Fringe.

• Open upland hills and mountains.

• Open low-land hills and lakes.

• Gweebarra River Valley.

It predicts there would be no significant landscape impacts due to the nature of the landscapes and the low levels of landscape resource change. It states that the zone of visual influence (ZVI) had been established and the extent of the visibility is limited to approximately 1-2 kilometres either side of the routes. It states that significant visual impacts were predicted at 46 residential properties and that the remaining 860 properties with the SVI would not have significant visual impacts. It refers to the County Donegal Development Plan 2006 – 2012 which indicates a number of designations and protected views throughout the area. It states there are no significant visual impacts predicted for any of the protected views. It notes that Binbane – Letterkenny line crosses an area designated as Especially High Scenic Amenity (EHSA) between regional road R250 and Tievedeevan for a length of approximately 300 metres. It states the impact is not considered significant. It states the route partially encroaches on the Ardnagappary – Tievebrack line on an Especially High Scenic Area at one location east of Crolly on the western slopes of Grogan More. The NTS states that 24 viewpoints had been assessed using photomontages. It states that the selection and location of the viewpoints followed landscape and visual appraisal and discussions with both Donegal County Council and An Bord Pleanála. The conclusion in the NTS is that when landscape and visual impacts are considered, the proposal is acceptable and the surrounding landscape and its visual resources have the ability to accommodate the changes of the type associated with the development. The NTS states that the project would have a moderate negative impact upon the land use within the area and this is considered under the heading of


material assets. It states that outside of forested areas the constructed elements of the development which comprise the angle masts, polesets and stations would be the only point of direct contact with the land and as such land loss would be minimal. It describes the project as a positive infrastructural contribution to the material assets of the county. When dealing with cultural heritage, it is stated that no previously recorded archaeological sites or built structures listed in the Record of Protected Structure would be affected by the projects.

3.3 Introduction and Planning Context – (EIS Chapters 1 and 2) The introduction indicates the scope of the project and gives the lengths of the various lines and the reference to Figure 1.1 which shows the project location on an A4 sheet.

Paragraph 1.2 describes the function of the TSO which is Eirgrid and DSO which is the Electricity Supply Board. It notes that the roles of both bodies are entirely separate to the companies that generate, distribute and sell electricity in Ireland. It states that responsibility for electricity generated in Ireland rests with the Commission for Energy Regulation (CER). It notes that the ESB has been nominated as the transmission system owner and is responsible for the maintenance of the transmission system and carrying out construction work in accordance with the transmission system operator’s development plan. Section 1.3 sets out the applicable legislation and regulations and 1.4 gives the format of the EIS and the methodology used. Paragraph 1.5 details some of the consultations carried out and notes the use of briefing notices in the local press and the use of a website. It states that business and community groups were consulted during project development. It states also that detailed consultations were held with Donegal County Council, the NPWS, Northern Regional Fisheries Board and the Loughs Agency. It also notes pre-application discussions held with An Bord Pleanála in June and August 2007. Paragraph 1.6 notes the contributors to the EIS and records that no difficulties such as technical deficiencies, lack of information or knowledge were encountered in compiling any specified information in the EIS. Paragraph 1.7 notes where and when the copies of the EIS were available. Chapter 2 describes the planning framework and refers to the energy white paper which refers to the Government Energy Policy Framework for 2007-2020 which has goals which are described as follows: -


• ensuring that electricity supply consistently meets demand;

• enhances the diversity of fuels used for power generation;

• delivers electricity and gas to homes and businesses over efficient; reliable and secure networks;

• addressing climate change;

• accelerating the growth of renewable energy sources;

• ensuring affordable energy for everyone.

This paragraph also includes references to the targets for renewable sources and regional development requirements. It refers to the All-Island Energy Market Framework 2004 which it states reflects the EU objectives for the internal energy market and regionalisation of markets and is described as the framework for delivery on an all-Ireland basis across the range of energy priorities. It states the introduction of the single electricity market in 2007 was a significant priority. Section 2.1.2 describes the national and cross-border policy context and refers to the NDP 2007-2012, stating that the reinforcement of the transmission and distribution networks which is the subject of the application facilitates and supports the key elements of the NDP. In relation to the NSS 2002-2020, it states the TSO and DSO seek to facilitate the delivery of the NSS through the provision of high quality electrical transmission and distribution infrastructure and notes that Donegal is identified as a district sub-region within the border region. It also identifies Letterkenny/Derry as a linked gateway and also provides a framework by which the spatial planning of towns, villages and rural areas could be achieved. It states the NSS indicates the particular need to strengthen energy networks in the border and north-west. Reference is made to the Regional Development Strategy for Northern Ireland 2025 (RDSNI). This strategy is stated to have objectives which include the strengthening of the role of Derry as the regional city and transport hub of the north-west and to encourage economic growth and industrial development to meet the employment needs of a vast growing population. It states the RDS does not only identify Derry as a major regional city for the north-west but also highlights the importance and potential of cross-border linkages both in the growth of the city and the region as a whole. Reference is made to the document Sustainable Development: A Strategy for Ireland (1997). This document includes the requirement to encourage efficiency in the use of energy, the securing of the protection and enhancement of the natural environment and accommodating new development needs in an environmentally sustainable and sensitive manner.


Section 2.1.3 refers to the regional policy context and reference is made here to the Regional Strategy and Regional Planning Guidelines for the Border Region (2004). The RPG are said to build on the provision of the NSS and it is stated that the reinforcement of the transmission and distribution networks would facilitate the delivery of the Regional Strategy and Regional Planning Guidelines for the Border Region. Reference is also made to the Western Development Commission (WDC) which is a statutory body promoting economic and social development in counties Donegal, Sligo, Leitrim. Roscommon, Mayo, Galway and Clare. It states the need for the development of electricity infrastructure has been highlighted over the last number of years by the WDC. Údarás na Gaeltachta is a regional development agency and issued a statement in 2006 which noted the extension of the 110kv powerlines to west Connemara and west Donegal was crucially important to underpin the development process in the two areas. Section 2.2 of the EIS describes the Donegal County Development Plan. The CDP 2006-2012 is stated to include the requirement to address the decline of traditional industries, the tackling of high unemployment, the inability of the region to compete for employment on a national or international scale, strategic and local links to Northern Ireland and infrastructural constraints and deficiencies. It also refers to the requirement to tackle rural depopulation and to seek the conservation and enhancement of Donegal’s scenic landscape. It states the Council were guided by the principles which included driving forward economic and social development, enhancing quality of life, promoting and protecting environment and heritage of high and distinctive quality and responding positively to national and regional policy. Reference is made to the County Development Plan Spatial Strategy and Objective 1 is stated to be the creation of a vibrant and fully functioning Letterkenny-Derry linked gateway and Objective 2 is the creation through urban strengthening measures of a strong urban structure at sub-gateway level. Spatial Strategy Objective 5 is the protection and enhancement of the unique cultural and linguistic resource of the Gaeltacht and Spatial Strategy Objective 6 is the safeguarding of the role of centres with special functions such as Lifford, Moville, Greencastle, Burtonport, Rosnowlagh, Downings, Rathmullen, Gweedore, Glencolumbkille and Gortahork. It states that the reinforcement of the transmission and distribution networks subject of the application would facilitate the implementation of spatial strategy objectives 1, 2, 5 and 6. It states that a reinforcement of the transmission and distribution networks would not impact on the intact routes of the old railway network and associated structures. It refers to employment generation and Policy EED1 which is to support and encourage diversification of the local economic base,


Policy EED2 is the promotion of development corridors while Policy EED3 refers to key interest centres. In addition Policy EED4 refers to land and works base, EED8 to the development of key infrastructure to facilitate employment generation and it states that the project is provided for by Policy EED8 and would facilitate the employment generation and enterprise development strategies contained within the Donegal County Development Plan. Section 2.2.5 refers to natural resources development and refers to policies in relation to forestry, peat lands, wind energy and notes that it is council policy not to favourably consider applications for wind energy developments in the Glenveagh National Park, areas classified as especially high scenic amenity and areas defined as views and prospects. Section 2.2.6 refers to the built and natural heritage and the County Development Plan contains a number of relevant policies. It states that within landscape identified as EHSA there could be small pockets which do not fully meet the definition of the designation and it notes that the onus is on the applicant for permission to demonstrate that the site does not meet the characteristics of the EHSA. It notes the council would also seek to preserve the views and prospects of special amenity value and interest. The criteria listed are: - • importance value of the view in question;

• integrity of the view being affected by existing development;

• development intruding significantly on the view;

• development materially altering the view.

It notes that the council would seek to preserve the main approach roads to Glenveagh National Park. The approach roads are stated to be the Glendown to Doochary Road, Dunlewy to Termon, Churchill to Termon/Dunlewy Road, Muckish Gap to Cabiber Bridge. Section 2.2.7 refers to tourism and the relevant policies TOU 1, and 3 are noted. Section 2.2.8 refers to the Gaeltacht and the relevant policies GCSR 8 and 13 are noted. Section 2.3 refers to other development plans which include the Letterkenny and Environs Plan of 2003-2009. Section 2.3.2 refers to a document prepared by the County Development Board entitled “An Straitéis”. This document concentrates on social, economic and cultural development while the development plan focuses primarily on land use.


Section 2.4 refers to the planning history. The EIS notes a previous planning application to reinforce the transmission and distribution network was made in 1999 and this proposed a new transformer station at Arduns and a new loop line connecting the new station to the existing Letterkenny substation and to the existing Binbane substation. Following a permission granted by Donegal County Council it was refused by An Bord Pleanála on appeal in May 2001. It notes that between 2000 and 2004, there was a significant reduction in demand for electricity in Gweedore and the Killybegs area and it states that economic activity in north-west and west Donegal is recovering since the low of 2004. In relation to the original application, An Bord Pleanála was not satisfied that the proposal was the most effective way to satisfy the electricity supply needs of the county. The EIS states that the present application was based on a thorough re-evaluation and analysis of the electricity needs of the county and a rigorous examination of the possible methods by which the TSO and DSO may meet the demands. It states it is believed that any perceived previous shortcomings have been addressed in the application. Developments permitted in the vicinity of the Ardnagappery substation include a wastewater treatment works (WWTW) to the north of the proposed substation site and this is dated January 2003. In October 2001 permission was granted by An Bord Pleanála for development works immediately to the west and north-west of the proposed substation at Ardnagappary. In Section 2.4.3, the previous electricity distribution development permitted in the vicinity of Binbane substation includes: - • January 1998, permission granted by Donegal County Council for

extension of the existing substation.

• In March 2004, permission granted for alterations to the transformer station consisting of a 110 kV to 38 kV transformers.

• January 2007, permission granted by Donegal County Council for

alterations involving a 38 kV line bay.

• April 2007, permission granted by Donegal County Council for the construction of a 38 kV overhead line from the existing 38 kV station at Kilcreen Upper Glenties to a wind farm at Lough Derryduff.

• April 2008, permission granted by An Bord Pleanála on appeal to ESB

Networks for the construction of a 38 kV overhead line from Binbane to a proposed wind farm at Corkermore.

The EIS concludes in Section 2.5 that the policies and objectives of the NDP, NSS, Policy Guidelines, Regional Strategies, RPG’s and the CDP support the provision of a secure and reliable electricity transmission infrastructure. It


states the development as proposed is in accordance with National, Regional and Local Energy and Planning and Development Policies. It states the issues raised by An Bord Pleanála in its assessment of the 2001 proposal are considered to have been addressed.

3.4 Need for the Project and alternatives (Chapter 3, EIS – 29 pages) In an overview of the existing transmission and distribution network, the EIS states there are three 110 kV lines routed through the narrow corridor connecting County Donegal to the rest of the state. It states that it has been strengthened with the construction of a new 220 kV line from Flagford near Carrick-on-Shannon to Shrananagh near Sligo. It states that two 110 kV lines run from Cathaleen’s Fall at Ballyshannon to Letterkenny 110 kV substation. It notes there are spurs of these lines to Meentycat and Golagh wind farms. It states a third 110 kV line runs from Cathaleen’s Fall, Ballyshannon to Binbane and this was refurbished and upgraded within 2005 – 2006. The EIS states that electricity from Letterkenny and Binbane is distributed through north and west County Donegal via two 38 kV lines which have been in service for some 40-50 years. It states that under normal configurations, the substations at Ballykeeran, Millford, Creeslough and Gweedore are fed from the Letterkenny station. It states the stations at Killybegs, Kilcar, Glenties, Dungloe, Clady and Derrybeg are supplied from Binbane 110 kV substation. It notes there is also a 38 kV line between Binbane and Cathaleen’s Falls 110 kV stations. It notes the requirement to have boosters at Ballykeeran and Dungloe to rectify voltage decay on the 38 kV network. It states these boosters are required to keep the voltage within standard in Creeslough and Gweedore and in Dungloe and Derrybeg. It notes that 38 kV network has recently been upgraded in the Millford area to feed growing loads. The existing 38 kV system in West Donegal is configured that the full electricity demand of the area could be supplied from either Letterkenny or Binbane 110 kV stations. It refers to Figure 3.1 which is a schematic drawing of the network. It notes that the system is connected to Northern Ireland at 275 kV and at 110 kV. It states the main Interconnector at 275 kV double circuits connects Louth station to Tandragee in County Armagh. It states there are 2 no. 110 kV connections, one of which is between Letterkenny and Strabane, while the other is between Corraclassy in County Cavan and Enniskillen. It states the purpose of the interconnections is to provide for short-term support to either system for certain conditions or in the event of an unexpected circuit outage. It states that the power transfers over the interconnectors are normally maintained at effectively zero.


The objective of the project is stated to be the reinforcement of the electricity transmission and distribution infrastructure of Donegal. It states that in line with planning best practice, the reinforcement is designed to solve multiple problems with one solution. Section 3.4 describes the problems with existing electricity networks. These include the following: - • Line overloads and lack of capacity on 110 kV lines feeding Letterkenny

Station and the east of County Donegal – it states that a third 110 kV feed to Letterkenny is needed.

• Line overloads and lack of standby capacity on the 110 kV line feeding

Binbane substation and southwest Donegal – the supply to the area is described as vulnerable to any fault on the line and a second 110 kV feed to Binbane is needed to the 110 kV station.

• Voltage and capacity problems with the 38 kV network in northwest

Donegal – the northwest Donegal 38 kV network is stated to consist of two circuits with one connected to Binbane 110 kV station feeding substations at Glenties, Dungloe and Derrybeg. The second circuit is connected to Letterkenny 110 kV substation and feeds Gortlee, Ballykeeran, Millford, Creeslough and Gweedore 38 kV substations. The EIS describes the normal operation and standby arrangements and refers to problems in the event of the loss of supply from Glenties or Ballykeeran/Gortlee. It concludes that it is imperative that the 38 kV network in northwest Donegal is reinforced immediately to provide additional capacity to facilitate social and economic development in the area including the accommodation of significant industrial projects. The DSO has requested a connection from the TSO to a new 110 kV station near Derrybeg to provide support in northwest Donegal.

• Insufficient capacity to absorb new generation – the EIS notes that the

TSO and DSO are required to provide connections for renewable energy generators and at present the capability for generation connections is extremely limited in County Donegal.

• Transfer capacity limits on Northern Ireland Interconnector – the EIS

states that the existing 110 kV Interconnector plays a vital role in providing power for short periods following a system disturbance, but it would be desirable for long-term strategic development of improved interconnection capability. It states that increased transmission capacity into County Donegal and up to the Letterkenny area is first required before improving the existing interconnection capability with Derry.

• Implications of network shortfalls. The EIS states that without the

proposed development, much of the planned growth of Letterkenny and northwest Donegal and the four designated development corridors as


envisaged by the County Development Plan 2006 – 2012 would not be possible.

Section 3.5 considers drivers of growth/pressures. Table 3.1 indicates the population and electricity load in northwest Donegal for the years 1996, 2002 and 2006. This indicates that the population has increased from 62,895 to 70,663 and the peak load has increased from 43.8 MVA to 58.8 MVA (comparing 1996 and 2006). In Table 3.2 it notes that the change in load is an increase of 34.2%. It notes the population growth has not been evenly spread and that Letterkenny is the main centre for retail, commercial and service activities. It notes there have been decreases in demand in Killybegs and Derrybeg where closures of local industries have occurred. The EIS states the forecasts of growth are based on the relationship between GDP (Gross Domestic Product) and electricity consumption. It states that the DSO applies standard distribution planning approach for distribution network using a forecasted average electricity demand growth of 3%. In relation to demand reductions, it states that the loss of demand customers in Gweedore Business Park should not be allowed to justify sub-optimal reinforcement. It states it would be short-sighted to plan facilities to this area on the basis of a static population and economic activity in the future. It states that at the time of writing of the EIS, employment numbers were rising again and this was particularly evident in the last five years. Section 3.5.4 refers new generation connections – wind farms. It states that since December 2004 renewable generators wishing to connect to the transmission or distribution systems have been subject to group processing of connection applications through a series of success of gates. It states the principles and criteria for applications are set down by the Commission for Energy Regulation (CER) and so far there have been two gates. As of 26th August 2008 under Gate 1 and Gate 2, it notes that the construction of the Binbane – Letterkenny link is critical for facilitating future gate 2 connections. It notes that in Figure 3.2 (at the end of the chapter) the locations of wind farms both connected and in the queue are shown. The EIS notes that wind generation may have a large variation over a relatively short period of time which the network must be able to cope with. Section 3.6 refers to alternative TSO and DSO solutions and in relation to the transmission alternative, there are four options considered namely: - • Option A: - 110 kV line from Binbane to Letterkenny.

• Option B: - 110 kV line from Donegal to Letterkenny and Donegal to

Binbane.


• Option C: - 110 kV lines from Coolkeeragh to Burnfoot plus systems reinforcements and Donegal to Binbane.

• Option D: - 110 kV lines from Coolkeeragh to Strabane plus system

reinforcements and Donegal to Binbane.

The following sections of the EIS examine the options and the conclusion on Option A which is the chosen option is that this particular reinforcement has been shown extremely beneficial for the export of power from the area. Figure 3.3 indicates the option and also includes an indication of the existing 110 kV and existing 38 kV lines. (It would

appear from this figure that the line passes to the east and south of

Glenties, when the actual proposal presented goes north and west of

Glenties before linking to Binbane)

In relation to Option B which is Donegal – Letterkenny and Donegal – Binbane, this option is stated to have physical and environmental constraints along the route. In particular it draws attention to the three overhead lines routed via the Barnsmore Cap and notes that on the narrowest section 2 x 110 kV lines are converted to a double circuit formation for nearly 6 kilometres. It states that the area north of the line from Lough Mourne to the eastern boundary of Glenveagh National Park has numerous archaeological sites correlating with the built up areas in the county. The option was stated to have been discounted because of the physical and environmental constraints. This option is shown in Figure 3.4. Option C which is the connection from Coolkeeragh to Burnfoot is shown in Figure 3.5. The conclusion in relation to this option is that it would be environmentally poor and of higher cost due to its overall longer line length and there would be a requirement for an additional station while providing no additional strategic benefit and therefore it was not the preferred solution. In relation to Option D which consists mainly of a connection to Strabane to Letterkenny and system reinforcements, this option is described as involving 210 kV connections with one from a 110 kV switching station near Donegal to Binbane and a connection from Strabane 110 kV station in Northern Ireland into Letterkenny 110 kV station. It states the option would entail an increase in infrastructure development with three new lines of 72 kilometres in total length and two new 110 kV stations. It states the route length to the DSO preferred solution of a new 110 kV station in the Derrybeg/Gweedore area would also be increased as the nearest termination would be either Binbane or Letterkenny. The EIS states that this option would be environmentally poor and of higher cost due to its overall longer line length and the requirement for additional 110 kV station, while providing no additional strategic benefit, made it not the preferred solution.


Section 3.8 describes the options for reinforcement of the 38 kV network in northwest Donegal. These options are set out as follows: - • Option 1: - New 38 kV circuit between Binbane and Derrybeg.

• Option 2: - Replacement of existing 38 kV lines with higher capacity

lines.

• Option 3: - Replacement of the entire 38 kV network with 110 kV line.

• Option 4: - 110 kV tail-fed station in Derrybeg/Gweedore area.

• Option 5: - 110 kV tail-fed station at Ballykeeran.

• Option 6: - 110 kV tail-fed station at Dungloe.

• Option 7: - 110 kV station at Dungloe and 110 kV station and Ballykeeran.

The EIS describes the various options and the rationale governing the chosen option. In relation to Option 1 which is the construction of new 38 kV circuit between Binbane and Derrybeg, the EIS concludes that a 330 mm2 conductor in a 38 kV line would address network problems in the medium term but the voltage would be substandard within a period of years. It states that the higher capacity 38 kV line would consist of heavy and larger double wood pole structures in line straights with steel angle mast points where the line changes direction. It states the type of line is visually almost identical to the proposed 110 kV line. It states that neither of the 38 kV alternatives would resolve the identified difficulties on the northwest Donegal network in the long term and would be dismissed. Option 2 which is the replacement of the existing 38 kV networks with high capacity lines is discussed and it was pointed out that this would necessitate sections of existing line been switched out for months at a time when rebuilding took place. It states it would break the circuit between Binbane and Letterkenny and the load would have to be supplied from either Letterkenny or Binbane, but in the event of a fault in either section, stand-by supply would not be available. It states that the building of a new line alongside the existing line would involve significant difficulties and securing an agreement with the landowners to the new route and the new structure locations. It notes the higher capacity line would consist of construction almost identical to a 110 kV line. It states that the proposal would offer an inferior solution with an equivalent environmental impact.


In Option 3, the proposal to replace the entire 38 kV network with 110 kV circuits is discussed in Section 3.8.3 and this is stated to require up to six new 110 kV substations. It states the option would be expensive and would also have significant and environmental impact as the only route available for 110 kV is already restricted, as it is occupied by the existing 38 kV line. It states that the Landscape Conservation Policy BNH5 of Donegal County Development Plan states that overhead power lines will not be permitted along the Dunlewy to Termon Road. Section 3.8.4 describes Option 4 which is the chosen solution involving a 110 kV tail-fed station in Derrybeg-Gweedore area. The description of tail-fed distinguishes the proposal from a circuit-fed solution and involves running the 110 kV line from Tievebrack to Gweedore/Derrybeg. It states the optimal location of the 110 kV substations in the Derrybeg/Gweedore area results in significantly reduced electrical losses which has a follow-on benefit of reduced greenhouse gas emissions. Figure 3.8 gives the schematic indication of the proposal. It notes also that the proposal would facilitate the connection of wind farm generation. Section 3.8.5 describes Option 5 which is a tail-fed 110 kV substation at Ballykeeran. The EIS rejects this proposal as it states it does not meet the technical criteria. Option 6 is described as a tail-fed 110 kV station in Dungloe. This option would take part of the proposed line and terminate it at Dungloe and it states that under normal feeding arrangements, the configuration would provide an acceptable voltage at all points on the 38 kV network for a minimum of 10 years. It states that under standby feed arrangements, the option does not provide acceptable voltages at all points after 2020. It states the option does not represent an orderly and efficient development of the network in northwest Donegal and would be more expensive and would require earlier reinforcement than Option 4. New 110 kV stations at Dungloe and Ballykeeran are proposed in Option 7 and the layout is described in Figure 3.11. It states that it would require two voltage – boosting transformers on the 38 kV networks. It states the continued use of boosters would imply sub-optimum network arrangements. It states that it would require the development of additional 110 kV substation and would have less emission savings than Option 4. Table 3.3 sets out the advantages and disadvantages of the alternative options and the conclusion is that Option 4 which is the tail-fed 110 kV station at Derrybeg as being the optimum solution. Section 3.9 describes future reinforcement requirements. It describes links with Northern Ireland and refers to the government target that 33% of electricity produced in the country would come from renewable energy sources. It states that new infrastructure to cater for the transfer of this power round the island to the main areas the demand would


be required. It states that given the limited links, both Northern Ireland and the Derry area can be considered as weakly connected to the rest of the system and would therefore benefit from strengthening the more robust points of the network. It states the proposed Binbane – Letterkenny line is not only a solution to the problems identified, but offers a significant increase in strength to the existing links with Northern Donegal. Section 3.10 describes the design alternative involving underground cables. The EIS states the policy and practice in relation to high voltage cable use (UGC) and list the situations as follows: - • Congested urban area.

• Area with a multiplicity of existing overhead power lines.

• A relatively wide expanse of deep water.

• An amenity or visual impact of an overhead line is considered to be

unacceptable.

• In the vicinity of an airport where an overhead line infringes on the height restricted zones as defined by the Aviation Authority. It states that as of 2006, there is a combined total of 4,643 kilometres of a 110 kV overhead lines, but only 171 kilometres of 110 kV underground cables.

Eirgrid’s policy on the use of overhead line and/or underground cable states that “if one or more technically feasible routes for an overhead line can be found, then an overhead line will typically provide the most technically acceptable and cost effective solution”. It is noted that this issue was discussed extensively in the course of the oral hearing. Section 6.10.1 gives a comparison of underground cables versus overhead lines under the headings of safety, capital costs, lifecycle costs, reliability and environmental impacts. In relation to safety, the EIS states that both companies consider UGC and OHL configurations to be equally safe. In relation to capital costs, it states that the underground cost ratio would be in excess of 5:1. In relation to life cycle costs, the conclusion is that the overhead line is the most attractive option when capital costs and operating costs are included. In relation to reliability, the EIS discusses failure rate and the availability or lack of availability of the asset. The EIS states the experience is that when transient faults on an OHL, there is virtually no effect on the average electricity customer. It states that sustained faults where damages occurred and repairs are required are quite rare on 110 kV OHLs. The statistics were given which indicated six sustained faults and 3,840 kilometres in a two year


period which had an average repair time of 31 hours. It states that underground cables do not experience transient faults and that if a fault occurs on underground XLPE cable, it would always have sustained a form of damage that requires repair. It states that there are not meaningful fault statistics for 110 kV cables as there are very little 110 kV transmission cables in Ireland. It describes the construction methodology for underground cables and states also that laying cables underground would have a very destructive effect on peat soils inside and outside of natural heritage areas. It states the off-road routing of underground cables is not a sustainable alternative. In conclusion on this section, it states that the disadvantages of underground cables when compared to overhead lines far outweigh the advantages. It states that this conclusion is supported by the findings of the independent studies carried out by ECOFYS on behalf of the Department of Communications, Energy and Natural Resources. Section 3.11 electricity generation option the EIS notes the existing embedded generation feeding into the 38 kV networks in West Donegal in the form of the ESB Hydro Electric Scheme at Clady (4 MVA) and Mount Cronalaght Wind Farm at Gweedore (5 MVA) and there are also a number of smaller wind generation facilities feeding into the network. It states that at present, it is not possible to connect additional generation to the existing networks without causing the network voltages to go beyond the levels determined by the distribution standards. Reference is made to combined heat and power (CHP) generation. It states that the settlement pattern and low density population in the area are unfavourable to development of CHP systems. The EIS concludes that embedded generation is not a realistic alternative to the proposed development and in any case does not allow the TSO or DSO to fulfil their functions.

3.5 Alternative Routes and Site Locations (Chapter 4, EIS, 15 Pages)

Alternative line routes are set out in Section 4.1 and the criteria given are as follows: - • Technical feasibility and physical constraints.

• Residential amenity and the proximity to houses and schools.

• Environmental and physical planning constraints.

• The concerns raised in An Bord Pleanála’s Inspector’s Report of May 2001.

• Economics.


Figures 4.1 – 4.9 indicate the development of the route selection and give an indication of the various constraints including conservation areas, built up areas and landscape constraints. It states that three route options were considered for the Letterkenny – Binbane route and it notes that a number of sub-options were also examined. The chosen main corridor was corridor A which runs to the east of the R262 past Glenties crossing the River Fin east of Fintown and heads to Letterkenny north of Cark Mountain. The EIS describes the constraints and their assessment in Section 4.1.3 and it concludes that option A with sub-options A4 and A7 was the recommended option. Table 4.1 gives the rating of the various options under the different issue headings. In Section 4.3 outlines further variations examined at the request of the Glenties Special Interest Group (GSIG) which developed variations LV3A and LV5A the area north and east of Glenties close to the connection with Tievebrack Switching Station. Section 4.1.4 identifies the route options for the Glenties – Gweedore line and main corridors were examined for this line. It chooses corridor D which is stated to follow an alignment that requires few changes in direction and hence needs less need for potential angle mast locations. It states that where the two routes merge, the route crosses the designated area of especially high scenic amenity at Grogan More. The EIS notes that avoidance of this landscape would have been preferable, the design has minimised potential impacts. In relation to residential amenity, the EIS states that both route options avoid significantly built areas and noted that the location of housing in the Crolly area poses severe constraints along the section and necessitated locating the line within the periphery of the area of especially high scenic amenity at Groganmore. Table 4.2 sets out the environmental and physical planning assessments for route options D and E. Section 4.2 of the EIS describes the alternative switching station and substation locations and the issues to be taken into account. It states that eight sites were identified and assessed after a preliminary desk-top study and preliminary reconnaissance of the area. These sites are shown on Figure 4.6 and include Nos. 1 – 7 in the Tievebrack general area and No. 8 is at Aurdun which is adjacent to the R253 to the north of the Owenea River. The EIS describes the sites and states that given access issues and residential amenity considerations, Option 1 was selected as the preferred location for the switching station. Section 4.2.2 gives the alternatives for the Gweedore substation locations and a total of four sites were evaluated and these were shown on Figure 4.7. In this case site 1 was selected as the preferred option and this is stated to be as suggested in the previous An Bord Pleanála Report on the basis of compatibility with existing patterns of land use, ease of access and residential amenity.


In Section 4.4, the EIS discusses alternative structures and materials and notes that double wood pole construction is the most generally used support 110 kV conductors, while angle towers are required at directional change locations. It notes that braced wood pole design would be used at structure ST233 at the King Arrow and a structure 5 on the Ardnagappary – Tievebrack line due to small angles of deviation. It notes that at sensitive locations such as Gweebarra Bay, there might be some scope for rationalising the network of lower voltage lines in the interest of reducing clutter.

3.6 Description of Project (Chapter 5, EIS – 21 Pages and 10 Figures) Section 5.1 lists the elements of the development and Section 5.2 gives the description of the line routes and site locations. In Table 5.1 the townlands are listed for the 364 polesets which include 26 angle masts of type 149E on the Letterkenny to Binbane 110 kV line. In Table 5.2, the 176 polesets which include 18 angle masts of types 136, 136E and 139 are on the proposed Ardnagappary – Tievebrack line. Pages 5.2 – 5.4 give a description of the Letterkenny to Binbane proposed line with a description of the direction and type of land being crossed for each section between angle masts. On pages 5.5 and 5.6 the same information is given for the Tievebrack – Ardnagappary proposed line. The Tievebrack Switching Station site is described as being 3.5 kilometres northeast of Glenties and comprises the land area of 3 hectares. The Ardnagappary Substation has proposed is in the town of Magheraclogher north of the R258 between Bunbeg and Gweedore and covers 1.95 hectares. Section 5.3 describes the lines design and layout which include the modifications to existing 38 kV lines at Ardnagappary. Reference is made to Appendix E for details of angle masts and polesets. (It is noted that Appendix E gives descriptions of a type 136 angle mast). Section 5.4 describes the design and layout of the switching station at Tievebrack which is shown on Figure 5.3. It also describes the substation at Ardnagappary which is shown on Figure 5.7. The substation compound layouts are shown on Figure 5.8 and 5.9, while the layouts for the switching station are shown on Figure 5.4 with sections of the station compound on Figure 5.5. Section 5.5 describes modifications required to the existing substations and reference is made to Figure 5.10. Section 5.6 describes the project construction and commissioning and refers to pre-construction phase activities which includes final design and wayleave notices and the selection of access locations. It states that access to structure locations would be carefully selected to avoid impact on the surrounding area and means of access to structures within the designated areas would be selected to avoid adversely impacting on sites. In relation to wayleaves, it states that an Eirgrid/ESB representative would conduct an interview with


landowners and point out the position of lines the structures in the ground and answer queries. In relation to land use, the EIS notes that bog occurs along 81% of the Binbane - Letterkenny route and 77% of the Ardnagappary – Tievebrack route. It notes that exposed rock occurs along 4.3% of the Binbane – Letterkenny line and 13.6% of the Ardnagappary – Tievebrack line. The EIS refers to method of gaining access including:- • Normal access in peatland to use wide tracks low ground pressure

vehicles.

• Normal access in coniferous woodland.

• Helicopter access in peatland areas with poor access and rock outcrops.

Table 5.3 indicates the likely method used for the access to the various structures. This table indicates the ground conditions expected the means of access and the number of structures and their reference numbers for each category. Page 5.14 indicates the construction method for polesets noting that the foundations would be to a depth of 2.3 metres. In relation to the Angle Towers, it notes that the foundations are constructed by anchoring each of the four corners separately below ground level in individual concrete foundation blocks. It states that the conductors for the line are delivered on drums to pre-selected locations and pulled out by either a winch factor or special stringing machinery. Section 5.6.1.3 states that the 38 kV structures would be erected using similar methods as for the 110 kV portal structures. Section 5.6.2 refers to construction works including duration and phasing. It envisages work on the Tievebrack switching station as taking 10 months for civil works and seven months for electrical works on the same time period as envisaged for Ardnagappary substation. It estimates the construction of the Binbane – Letterkenny line to take 20 months and the Ardnagappary – Tievebrack line to take 10 months with both running concurrently. The EIS states that civil construction works on the switching station and substation would require between 15 and 25 people with peak staff numbers during electrical contract work being 24. It states the average number employed during the construction of the overhead lines would be between 10 and 20. Temporary facilities would be provided for construction at the switching station and substation. Section 5.6.3 refers to construction materials and haulage. In relation to the reuse of excavated peat, it lists the options: - • Reuse within existing site for site restoration.

• Disposal and licence disposal facilities.


• Remediation of agricultural lands.

• Remediation of permitted development.

Disposal of material which could be reused is noted as being the least preferable option. It states that following assessment and consultation with the EPA and Donegal County Council, reuse of the materials the site was selected. It is estimated that approximately 500 cubic metres of rock would be involved at both the Tievebrack site and the Ardnagappary site. Storm fill, concrete and reinforcement and other building materials are also referred to in the EIS. Table 5.4 and Table 5.5 give details of estimated construction deliveries for the switching station and the substation. These involve up to 1,500 deliveries in total to each location. In relation to the lines, Table 5.6 and Table 5.7 detail the construction deliveries on the two lines. This amounts to approximately 1,000 deliveries in total. Section 5.6.3.3 refers to environmental factors and refers to traffic, noise, air, water and waste. It notes that testing and commissioning typically takes from three to six months. Section 5.7 refers to operation and maintenance with reference to the material used including water, chemicals and oil and gas for insulation purposes. In relation to emissions, the EIS notes that oil interceptors would be used for surface water discharge and proprietary wastewater treatment plant would be used for sewage effluent. It states it does not foresee noise to be a problem from the switching station and substation. It states that corona activity of the transmission/distribution lines could produce small quantities of gaseous oxidants in the air. It states that this would have no significant impact on ambient ozone levels. The EIS refers to decommissioning and states that the experience is that a life span of 50 years or more is possible for switching and transformer substations and that in relation to lines; there is sufficient experience in the country to expect a life in excess of 60 years.

3.7 Human Beings Section 6.1 of the EIS sets out the population, employment and socio-economic activity and notes the changes in population in the various towns and rural areas. Table 6.2 gives employment status and Table 6.3 details the employment sectors for the years 2002 and 2006. The EIS refers to the nature and location of economic development and refers specifically to Letterkenny which the County Development Plan suggests would increase in population from 15,000 to 35,000 by 2020. It states that Killybegs has had investment in the development of sheltered deep-water facilities. In relation to the Donegal Gaeltacht and Northwest Donegal, it notes that in the late 1990’s


approximately 1,300 people were employed in the Gweedore Business Park. It notes that a major downturn in the manufacturing sector with a figure of 434 employed in 2003. It states that up to early 2008, there were 900 employed with plans for further increases.

Section 6.1.3 refers to the impact of the development and states that

expenditure associated with the project would result in economic benefits to the national economy. It concludes that the effects from the overall socio-economic well-being of the area would be positive.

Section 6.2 refers to electric and magnetic fields (EMF) and my way of

introduction describes the hertz magnetic field and its variation in the different locations. Figure 6.1 details magnetic and electric field comparisons and notes these are measured in Microtesla (uT). Figure 6.2 indicates the electro-magnetic spectrum and notes that the term non-ionising radiation is often applied to frequencies for overhead power lines. The EIS makes reference to the Department of Communications, Marine and Natural Resources (DCMNR) and the report of March 2007 entitled “Health Effects of Electro-Magnetic Fields”. It quotes one recommendation which stated that as a precautionary measure future power lines and installations should be sited away from heavily populated areas and keep exposures to people low.

It refers also to the International Commission of Non-Ionising Radiation

Protection (ICNIRP) which it states that the World Health Organisation is non-governmental organisation advisors on non-ionising radiation matters. It refers to the guidelines of ICNIRP in 1998 which for the general public the reference levels are given as 5 kV/m and 100 uT for electric and magnetic fields respectively (this issue was discussed in much detail at the oral hearing and additional evidence was produced in relation to EMF).

The predicted strength of the electrical magnetic fields is set out under Section

6.2.2.2: -

• Binbane – Letterkenny – normal maximum operating phase current 190 amps @ 113.9 kV.

• Current carrying capacity 789 amps @ 120 kV.

• Ardnagappary - Tievebrack line normal maximum operating phase

currents 75.14 amps @ 120 kV.

• Carrying capacity of conductor 610 amps @ 120 kV.

Table 6.4 sets out the ICNIRP Exposure Guidelines Reference Levels and the predicted maximum EMF values of the proposed 110 kV line. The EIS states that the peak electric field of 1.75 kV/m occurs underneath the conductor of the 110 kV line. It states this is well below the ICNIRP Guideline Reference Level of 5 kV/m. It states the normal maximum


magnetic field underneath the 110 kV line is 5.605 uT. This compares with the guideline reference levels of 100 uT. The figures given for the Ardnagappary - Tievebrack line are 1.725 kV/m underneath the conductor and 2.158 uT is the figure given for the normal maximum magnetic field underneath the line. It states that the transmission substations produce small fields with the maximum values generally occurring where the overhead lines enter and exit the substation. It states that in all cases the electric and magnetic fields would be below the ICNIRP 1998 Guideline Reference Levels for public exposure and consequently the EU 1999 recommendation. Section 6.2.3 refers to mitigation and the policy of Eirgrid and ESB is stated as being as follows: - • To fully comply with all legal requirements relating to EMF including any

conditions set by the Commission for Energy Regulation (ER).

• Design and operate networks in compliance with legislation and guidelines of the leading expert and independent international bodies.

• To closely monitor and support engineering and scientific research in the

area.

• Provide advice and information to its workers and the general public on the issue.

The EIS states that the electric and magnetic fields would fall well below the recommended guidelines and it was also proposed to provide a separation distance of 50 metres between the overhead lines and existing houses. It concludes that there is no evidence that the proposed development would pose a significant health risk due to adverse effects arising from electro magnetic fields. Section 6.3 refers to safety and the EIS states that the Irish Transmission and Distribution Systems are designed, constructed and operated in accordance with all national and EU Safety Regulations and in accordance with best international practice. It states the lines would be sited away from densely populated areas and it notes that could be a potential hazard in relation to mountain rescue. It states there is a negligible risk of fire within the switching station and substation and that all electrical equipment would be a minimal 10 metres from the palisade fence.

3.8 Flora and Fauna – (EIS Chapter 733 pages with 9 figures) Section 7.1 is entitled introduction and sets out he methodology used and the

criteria and value estimations carried out. Table 7.2 refers to the magnitude of


potential impact and the nature conservation value of sites damaged or improved. Section 7.1.2 refers to the assessment of the Natura Network referring to the Council Directive 92/43/EEC (Habitats Directive), the Wildlife Acts of 1976 and 2000, the Habitats Regulation 1997 and 1998 and the Birds Directive (79/409/EEC).

On page 7.3 is specific reference to Article 6 of the Habitats Directive with

particular reference to subsections 3 and 4. The EIS states that the DoEHLG has not published guidelines specifically for undertaking assessment or plans or projects likely to result in significant impacts on the Natura Network in Ireland. It states the guidance used was: -

• Managing Natura 2000 sites; the provisions were Article 6 of the Habitats

Directive.

• Assessment of plans and projects significantly affecting Natura 2000 sites;

• Methodological guidance on the provisions of Article 6 (3) and (4) of the Habitats Directive 92/43/EEC.

• Habitats Regulations: A Guide for Competent Authorities, Environment

and Heritage Service, Belfast (EHS 2002).

• Guidance for Competent Authorities when dealing with proposals affecting SAC Freshwater Sites (Scottish Natural Heritage, Perth (SHN) 2006).

• Guidance document on Article A6 (4) of the Habitats Directive 92/43/EEC

and clarification of the concepts of: - alternative solutions – Imperative Reasons of Overriding Public Interest (IROPI) – compensatory measures – overall coherence – opinion of the commission.

The EIS states that the assessment was based on the guidelines and was a four-stage approach. Stage 1 – screening and test of significance which is the process which identifies the likely impacts upon a Natura 2000 site. Stage 2 – appropriate assessment – the consideration of the impact of the project or plan on the integrity of the Natura 2000 site, either alone or in combination with other projects or plans. This is in respect of the site’s conservation objectives and also the site structure and function and its overall integrity. Stage 3 – assessment of alternative solutions – the process which examines alternative ways of achieving the objectives that avoids adverse impacts on the integrity of the Natura 2000 site. Stage 4 – assessment where adverse impacts remain and is an assessment of compensatory measures where, in the light of an assessment of Imperative


Reasons of Overriding Public Interest (IROPI), it is deemed that the project or plan should proceed. Section 7.2 refers to the receiving environment. The statutory designations of SPA, SAC, NHA are all noted. The EIS deals firstly with the designated sites on the Binbane – Letterkenny. The designated sites referred to on page 7.5 and 7.6 of the EIS commence at Binbane and include the following: - • Site Code 1177 – Meenybradden Bog NHA – 67 hectares, mainly

comprised of intact blanket bog, but with some areas of cut-away. It is noted that the line includes two polesets ST17 and ST18 within the site at 7 metres and 50 metres from county roads respectively. It states the polesets occur in areas of cut-over bog and have been located as close to the roads as engineering constraints allow. North and east of the proposed line and south of Glenties is Lough Nillan Bog (Carrickatlieve) which is an SAC/SPA/NHA of 4,213 hectares. It states that blanket bog makes up the extensive habitat and there are rare and breeding and migratory birds which provides for the additional designation as an SPA. Golden Plover and Merlin are noted as are the wintering Greenland White-Front Geese which feed on many areas of the site. It notes the polesets ST8 – ST56 are within one kilometre of the site.

• Site Code 1097 – is the West of Ardara/Maas Road SAC of 7,041 hectares which is north of Ardaragh and runs towards Gweebarra. It notes that from the centre of the site and expansive blanket bog extends south-east almost to Glenties. The Owenea system and some of the tributaries including the Stracashel and Owengarve Rivers are included in the SAC. It notes there are 22 habitats present that are listed under Annex I of the Habitats Directive, six having priority status. The site is of international conservation value and it is noted that the Atlantic salmon, Freshwater Pearl Mussel and Otter have been found in the Owenea River. It notes that a wooden pole set (ST70) would be located within the SAC at 11 metres from the site boundary. It states the structure is located on a boundary of wet pastureland and blanket bog.

It notes the site of Tievebrack substation is adjacent to Stracashel River portion of the west of Ardaragh/Mass Road SAC. It notes that ST128 is located within the SAC in an area of bog between adjacent strands of forestry at 15 metres from the SAC site boundary. Further along it states that ST143 is located 12 metres within the SAC and 13 metres from its boundary with a forestry haul road.


• Site Code 2301 – River Finn Complex SAC is 5,854 hectares and contains almost the entire freshwater element of the Finn and its tributaries. It states the site has been selected for active blanket bog, lowland oligotrophic lakes, wet heath and transition mires which are all habitats listed in Annex I of the Habitats Directive. It is also selected for Annex II species Atlantic salmon and otter. The EIS notes that Lough Finn holds a population of Artic Charr. The EIS notes that a wooden pole set ST216 is located on the NHA boundary between the River Finn and the R250 regional road. It states the line crosses the Cummirk River at Kingarrow and two poles sets namely ST234 and 235 are located within the SAC.

The summary is that of 68 kilometres from Binbane – Letterkenny, 1.8 kilometres crosses SAC sites, 54 metres crosses SPA sites and 0.9 kilometres crosses NHA sites. It notes that the design requires eight wooden poles sets to be located within the boundary areas of designated sites. Page 7.7 describes the designated sites on the Ardnagappary - Tievebrack line. These are as follows: -

• Site Code 0140 – Fawnboy Bog/Lough Nacung NHA/SAC – 1,101

hectares and is stated to be of conservation interest for the occurrence of intact lowland blanket bog and good quality wet heath generally surrounding Lough na Cung. The line is stated to cross the SAC as it traverses the Clady River and a preliminary design has included one pole set structure 17 metres from the north riverbank and within the SAC boundary.

• Site Code 2047 – Cloghernagore Bog and Glenveagh National Park SAC – 33,3000 hectares includes a rich diversity of habitats and landscape features including mountains, exposed rock and scree, blanket bogs, dry, wet and alpine heath, upland grassland, wet grassland, river, lakes, scrub and woodland. There is one pole set structure on the SAC boundary on the northwestern tip of the Crocknafarragh Estate. There are two pole set located within the SAC 10 kilometres south at Crovehy.

• Site Code 2434 – Crolly Bog NHA – an area of upland blanket bog and mountain slopes of Groganmore and Groganbeg to the east of the settlement of Crolly. There are 11 pole set structures within the boundary area of Crolly Bog. It states that corrections were made by NPWS to the NHA and SPA boundaries and these were added to the website in August 2008. Reference is made to Figure 7.1 in the EIS in this regard. The EIS states that the conservation boundaries in the Crolly Bog area were correct and then show that the Crolly Bog is neither an NHA nor a proposed NHA. The EIS states that the NPWS have confirmed that Crolly Bog has


never been designated as an NHA/pNHA , but it is earmarked as a potential site for nature conservation interest in the future.

• Site Code 0142 – Gannivegil Bog SAC – area 2,262 hectares – stated to be a large expansive blanket bog made up of two former NHAs, namely Gannivegil and Galwallie Bogs. The EIS states no structures are proposed within the SAC and the closed pole set is approximately 25 metres from the southern shoreline of Lough MacHugh.

• Site Code 0197 – Ardara/Mass Road SAC – 7,041 hectares – this includes Gweebarra River as far as Doocharry Bridge. This has been described in the Section on the Binbane - Letterkenny route and the EIS notes the site is of considerable conservation value on account of the high level of habitat diversity. It states the line spans of the Gweebarra River and bankside habitats at Ballynacarrick for distance in excess of 300 metres. The EIS states the nearest structure is located more than 20 metres from the SAC boundary on the north bank at almost 32 metres distant on the south bank. The summary given is that of 33.1 kilometres from Ardnagappary to Tievebrack the 110 kV line would cross 1.46 kilometres of SAC and 1.35 kilometres of pNHA sites. It states the design requires four wooden polesets to be located within the boundaries of designated sites.

Section 7.2.2 refers to habitats and Table 7.3 details the main habitat types from Binbane - Letterkenny as evaluated in the EIS. This table notes that 53% is upland blanket bog and 33% is conifer plantation. The EIS notes that eight polesets are located within NHA or SAC lands and of those eight, five are located in upland blanket bog, two in wet grassland and one in coniferous forestry. Table 7.4 gives the main habitat types for the Ardnagappary - Tievebrack 110 kV line and this comprises 176 structures comprising 18 angle towers, one braced wood pole structure and 157 double polesets. It crosses or passes by eight main habitat types. The EIS notes that four polesets are located within an NHA in upland blanket bog. The breakdown of Table 7.4 indicates 67% as upland blanket bog and 20% conifer plantation. The EIS states Tievebrack switching station is located in an isolated area of the Annex I blanket bog habitat and is three hectares in area with a footprint of the station compound and roads at approximately 0.5 hectares. Ardnagappary substation is given as 1.95 hectares with a footprint of 0.5 hectares. The EIS describes the blanket bog habitat. It occurs by the Owentocker River, Meenalargen and Lough Deele on the Binbane – Letterkenny line. It states 172 structures are located in that habitat and 27 in the priority habitat. This refers to the Binbane – Letterkenny line, while on the Ardnagappary - Tievebrack line, there are relatively large areas where there is no scarring in


the peat acrotelm in the Grogan More area. The main land used within bog habitats are grazing, turbary and small-scale quarrying. It states there are a large number of drains associated with the turbury activity. It states that quaking bog occurs around Lough Shivnagh and along the River Finn between Lough Finn and Lough Shivnaghgh. It also says that 34% of the Binbane – Letterkenny line is conifer woodland and this habitat comprises both Coillte owned and privately owned land. On the Ardnagappary - Tievebrack line, 20% passes through plantation forestry. The EIS states that plantation forestry is categorised as being of low species abundance and ecological value as per Fossitt 2000. It states that structure ST233 on the Binbane - Letterkenny route is located at the edge of a Coillte site at Kingarrow. The EIS states heathland occurs only on slopes on a hillside above the N13 at Dooballagh. It states that on the Ardnagappary - Tievebrack line, wet heath occurs on the plateaus and gentle slopes on some of the mountains where the peat is thin. Agriculture and pasture is more common in the east of the county on the Binbane - Letterkenny line, it occurs in and around river valleys, around farmsteads and on the approach to Letterkenny. On the Ardnagappary - Tievebrack line, it typically occurs around the farmsteads and settlements such as Lough Anure, Crovehy and Gweebarra River. Wet grassland is stated to be found on flatter sloping ground in upland and lowland areas. On the Binbane - Letterkenny line is located in this Stracashel, Stranagoppoge, Scallan and Cummirk River Valleys and along the northern slopes of Cark Mountain. On Ardnagappary – Tievebrack line it is found chiefly in river valleys and with agricultural grasslands. Native woodland is stated to be encountered by the Shallogan River northeast of Glenties on the Binbane - Letterkenny line and to the south of Lough Anure in a farmed landscape at Lettercaw, Meenacairn and by Lough Macew and in Ballinacarrig on the Ardnagappary – Tievebrack line. Referring to lakes, the EIS states the Binbane - Letterkenny line passes within 300 metres of Black Lough at Binbane and within 60 meters of Lough Ananima at Glenties where the closest structure is located more than 100 metres distant. It states that the north line passes Lough Kip with the closest structure located 75 metres from the shore. It states it passes 90 metres from Lough Shivnaghgh and north of Carrig Mountain it passes 160 metres north of Lough Deele. On the Ardnagappary - Tievebrack line it passes 100 metres south of Lough Clogher Macmaghten before crossing the Clady River and also within 50 metres of Lough Anure. It passes by a series of small lakes at Oughtmeen and Loughs Garrive and Sallagh. It states that the line skirts are on the south shore Lough Machugh with no structure located within 25 metres of the water body. The Binbane - Letterkenny line crosses the Owentocker and Owenea Rivers and the Shallogan and Stracashel Rivers northeast of Glenties. It also crosses the Scallan and Cummirk Rivers north of Lough Shivnagh.


The Ardnagappary - Tievebrack line crosses the Clady River and this river is included Fawnboy Bog/Lough Nacung SAC and a structure is located 13 metres from the north bank in gorse scrub. It crosses the Gweebarra River a further 20 kilometres south where the span would be 250 metres of brackish channels, sand and mudflats which are submersed at high tide. The EIS notes that this river is included in west of Ardara/Mass Road SAC. Section 7.2.3 describes species and it is noted that flora protection order 1999 lists 68 species of flowering plant and fern that are protected. Table 7.5 lists the species entries recorded on the NPWS database. It states that no species listed on Table 7.5 were found at structure locations along the line routes. The EIS makes reference to the mammals in the study area which include badger, Irish Stoat, pine marten, fox, Irish Hare and rabbits. It notes that otter visit most river systems at County Donegal and the EIS states that crossing points on the various rivers were surveyed for 100 metres each side and also the shoreline of Lough Machugh was walked. It states that no signs of otter were observed. Section 7.2.4 refers to avifauna. It refers to Table 7.6 which lists the breeding species entries of the NPWS rare and threatened birds’ database that occur in the 10 metre grid squares through which the proposed lines pass. It refers to additional information collected from Birdwatch Ireland and the Golden Eagle Trust Limited. It notes a marked decrease in the breeding population of Golden Plover and notes that the breeding densities in Ireland are thought to be typically in the order of less than one pair per square kilometre on suitable habitat which is blanket bog and heath. It states that consultation with Birdwatch Ireland and the NPWS indicates that approximately 41 pairs of Golden Plover breed in Donegal. It notes also that there are a number of breeding pairs of Hen Harriers and suitable breeding habitat would be between Glenties and Finn Town. The EIS refers to other species of conservation importance and notes Merlin for which evidence is scarce as a few studies have been carried out. Red Grouse is referred to as is the Peregrine Falcon. The EIS states that migratory flight patterns are considered since the project comprises above ground lines supported intermittently by structures. It notes that Ireland holds over 50% of the total world population of Greenland White-Fronted Geese, Light Bellied Brent Geese, and Whooper Swans, while they over-winter. It notes that in March and April each year, there is mass migration following contours of the Irish river valleys on their way to Artic Tundra in Iceland and Greenland. The EIS states the study area is situated in a part of the country that is used by migrating birds and the EIS lists 13 species. Review of available literature is stated to give the conclusion that Greenland White-Fronted Geese would normally be flying at far in excess of the height of the overhead lines and associated structures while travelling over the study area, except under difficult wind conditions.


It states that Lough Nillan Bog SAC/SPA/NHA is of great value for birds and the upland areas of the River Finn are valuable for Golden Plover. Table 7.7 indicates the areas where the marsh fritillary butterfly has been recorded between 1995 and 2005. The EIS states no known records conflict with the proposed overhead lines or the two station sites. Section 7.3 describes the impact of the development and states the most common effect would be loss of habitats and ecological value. It states the overhead lines could include: - • Hydrological regime changes.

• Pollution of watercourses.

• Direct mortality of fauna through collision.

• Construction noise causing temporary disturbance to sensitive breeding species.

The EIS notes that the Binbane - Letterkenny line chiefly passes through disturbed peatland and forestry. It crosses 13 rivers/tributaries and more small streams, it also passes over five designated sites of which three are European Natura Sites. It notes that eight poleset structures are located within designated sites. In relation to the Ardnagappary - Tievebrack line, this is stated to pass through disturbed peatland and forestry and crosses seven rivers/tributaries and more small streams. It passes over four statutory designated sites and four poleset structures are located within two designated sites. Section 7.3.2 describes the construction phase and estimates potential habitat loss as 2,605 m2 for Binbane - Letterkenny line and 1,465 m2 for the Ardnagappary - Tievebrack line. Regarding impacts on designated sites, it states that on the Binbane - Letterkenny no towers are located within SACs or NHAs. It states that eight polesets are located within designated sites and notes that the two polesets within Meenybradden Bog occur in areas of cutover bog at the edge of the site and access can be gained by existing roads. It refers to ST40 located in Lough Nillan Bog and no significant impacts are predicted for habitats for which this site has been selected. It gives the overall impact appraisal rating as neutral. It refers to ST70 located on the edge of blanket bog/wet grassland in the SAC referred to as west of Ardara/Maas Road. It notes that ST128 is located within the SAC an area of blanket bog between coniferous forestry strands. It notes ST143 is located 11 metres from the SAC boundary and the local road and is


within blanket bog habitat. The overall impact for this site is given as slight adverse. Two polesets are proposed within the River Finn Complex SAC, one in forestry 20 metres from the river and the second in bog over 50 metres from the river. It states that although the River Finn Complex is an A-rated European Site of High Nature Conservation Value, the habitats within which the polesets are located are of local value only. It states that with appropriate mitigation the magnitude of impact upon this very high value site at Kingarrow is predicted to be minor negative. The line passes over the River Finn complex SAC across the Stranogoppoge River south of Lough Shivnagh, the River Finn between Lough Finn and Shivnagh and also the Lough Finn NHA at the same location. It notes that one poleset is located on the boundary of Lough Finn NHA and no structures are proposed within the Natura sites. The EIS refers to the impacts on the designated sites on the Ardnagappary – Tievebrack line and notes that no towers are located within the SACs or NHAs. The poleset within Fawnboy Bog/Lough Nacung SAC is setback 17 metres from the northern bank of the Clady River and is accessible from the adjacent County Council storage yard. The designation of the stretch of river is for Salmon and freshwater Pearl Mussel populations. It states that damage to the Clady River by sediments etc. could be fully avoided by careful management of the construction works. The line passes over the north-western edge of Cloghernagore bog and Glenveagh National Park in an area already damaged by bog cutting. It states that line design has ensured that no structures are located within the SAC. The EIS states that Crovehy which is 10 kilometres further south two polesets (ST81 and ST82) are located within the SAC and NHA with a third poleset (ST83) just outside the Natura boundary. It states the overall impact appraisal for the site is slight adverse. The EIS notes that 11 polesets are located within the western margins of Crolly bog with ten located within intact blanket bog and one in disturbed bog. It notes there are five polesets located within 100 metres of an existing road track on either Crockator Mountain Road or Crolly Bog Road while six are located beyond 100 metres from an existing track. It states that the peatland of Arduns and the Grogan More sits on tin soils and is not deep bog. It notes that Crolly bog is given a high nature conservation value and the EIS states that with appropriate mitigation the magnitude of impact is predicted to be minor – intermediate negative. The EIS states that should construction cause permanent rutting of the intact bog, the impact appraisal would be large adverse. ST43 poleset is 100 metres from Cronaguiggy bog NHA which is a site to the south of the Bunawack burn in Meencorwick. The EIS states that with appropriate mitigation neutral impact is predicted. There is reference to the line passing the shoreline of Lough Machugh, and notes that no structure is located within Gannivegil bog SAC. It states the line


passes above the existing canopy of woodland west of the Lough. It notes the line crosses the Gweebarra River and would be approximately 15.5 metres above the banks and up to 14 metres above the sand flats. It notes that an existing 38KV line runs parallel to the proposed 110KV line 80 metres downstream. The EIS states the nearest poleset would be setback approximately 24 metres from the river on the north shore and that the line passes above the shoreline tree canopy. It states no impact is predicted upon features on this stretch of the river. The impacts of the Tievebrack switching station and the Ardnagappary substation are referred to in the EIS. It states that for both sites significant quantities of excavated peat would result in runoff as the peat drains which must be managed adequately. It states the risk could be minimised with effective mitigation. The EIS refers to compliance with the Habitats Directive (92/43/EEC) and it states that the assessment process concludes that it is not directly connected to or necessary for the management of a European site crossed by or close the proposed overhead lines, structures and stations that are part of the scheme. It lists the impacts on each Natura site affected in Table 7.8 and these range from slight adverse to neutral. The EIS concludes that as no significant adverse effects are likely upon the Natura sites in question, the assessment process stops at stage 1 namely screening and test of significance. The impacts on the habitats by the lines is referred to on pages 7.26 and 7.27. The EIS states that by its nature the habitat is sensitive to surface changes and tracks and ruts can persist on bog surfaces for many years. It notes that County Donegal contains some of the greatest uninterrupted expanses of blanket bog habitat in Ireland. The EIS states that new tracks would result in depressions and surface disturbance within the bogs. It states that when considered in context, the access tracks would not result in a change of the ecology of the effected habitat and with application of a sensitive access strategy and appropriate mitigation measures, the impacts of blanket bog would result in a medium-term impact. The EIS states that where lines traverse plantation forestry, a 61 metre wide buffer zone of cleared land at ground level is maintained along the line to facilitate line inspection and maintenance and to reduce the risk of fallen trees damaging conductors. It states that the total length of line crossing conifer woodland is 21.8 kilometres on the Binbane – Letterkenny line and 6.5 kilometres on the Ardnagappary – Tievebrack line. It states this equates to approximately 133 hectares and 40 hectares of conifer plantation on the respective lines. It states that while a 61 metre wide strip is felled for construction this includes a 4 metre wide permanent track and by agreement of trees not exceeding 3 metres in height to allow to develop each side of the permanent 4 metre wide access strip. It states that removal of the dense conifer canopy would allow light into the buffer area where a ground floor may develop.


It states that on the Binbane – Letterkenny line, four structures are located within dry heatland habitat and on the Ardnagappary – Tievebrack line 17 structures were located within this habitat. It states that this is an Annex 1 habitat type and would be categorised as being of high nature conservation value. It notes that at Gweedore one structure is located in gorse 30 metres from the N56 national road. It states that Grogan More, three polesets occur within wet heat land just beyond Crolly bog. It also states that south of Lough Anure a poleset and a tower are located in heath and at Cloghbolie Bridge, (Meenacarn), a tower and two polesets are located in heath. The EIS notes that as with blanket bog, the wet heath is sensitive to surface pressure and this will have to be allowed for by the contractor. The EIS states the remaining terrestrial habitat types along the Binbane – Letterkenny line include quaking bog, native woodland, wet grassland and improved agricultural land. It states that of these, native woodland and quaking bog are of very high conservation value but not directly impacted upon. The impact on habitats arising from the switching station and substation would result in permanent loss of both sides of approximately 0.5 hectares of blanket bog which has been subject to disturbance. The main impact of the drawing out of the surface peat would be the replacement of sphagnum mosses by dry heathers. It states that further new habitats for native flora and fauna would be created during extensive landscaping and tree planting. In relation to the impacts on birds, the protection by the Wildlife Acts is noted. The loss of 133 hectares of conifer woodland on the Binbane – Letterkenny route and 40 hectares of conifer woodland on the Ardnagappary – Tievebrack lines are noted. The EIS predicts a minor negative magnitude of impact resulting in a slight adverse impact appraisal rating. The EIS states that consultation with the Golden Eagle trust project staff suggest that the potential impact on Golden Eagle territories and nesting sites during the construction phase would be minimal. Section 7.3.3 refers to the operational phase. The EIS states that the main potential impacts would be the risk of bird strikes arising from the presence of power lines. It states that the flight paths of the Greenland White Fronted Geese were normally in excess of 100 metres and the documented movement of Red Throated Divers in the areas suggest considerably higher flight paths during normal flight. It states the risk a bird elocution on the type of power lines proposed is considered to be extremely low. It states elocution can occur when a bird is in contact with a conductor and with either another conductor line or an earthed material. It states this potentially arises on power lines with relatively low voltage where the configuration comprises three wires positioned at the same height on a single cross arm on wire space less than 1 metre apart. The EIS states that in both Scotland and north America recorded Golden Eagle electrocutions were largely confined to power lines carrying relatively low


voltages and that high voltage transmission lines were generally not a problem because the phased conductors were spaced 3 metres of more apart. It states the minimum distance between contact points of the proposed 110KV lines is 4.5 metres. The EIS notes that the largest perching bird species that occurs in the area has a maximum wingspan of 2.2 metres. The EIS states there is no risk of electrocution to Golden Eagles. Section 7.4 deals with mitigation. The EIS states that the contractor is required to ensure minimal disturbance to the existing surface vegetation and to hedgerows when dealing with designated sites. The use of helicopters to airlift materials onto site for long stretches of blanket bog with no existing tracks it is recommended. The EIS lists the following locations:- 1. On the Binbane – Letterkenny line for ST101-113, ST146-152, ST180-

192, ST218-232, ST244-250, ST262-278, ST285-299, ST313-320, ST337-342 and ST349-356.

2. On the Ardnagappary – Tievebrack line: ST19-25, ST31-37, ST55 and

56, ST60-64, ST73-89, ST92, ST117-119, ST128 and ST160-164.

The EIS recommends an ecologist be involved during line construction to advise on vegetation removal, refining access to sensitive habitive locations and on the grounded vice regarding minimising impacts and habitat reinstatement. Table 7.9 refers to access routes to be used for structures located within designated sites. Page 7.30 refers to measures required in relation to drainage, water quality monitoring, control of vehicle types. A list of construction management measures to reserve water quality and aquatic habitats is listed on page 7.31 and the inspection of trees prior to felling to examine for potential bat roosts is also noted. Bird flight diverters are stated as requiring to be installed along the line where it passes any rivers and lakes. These locations are given in Table 7.10. Section 7.5 gives the conclusions in relation to the significant effects on habitats. It states that habitat loss due to the footprint of the proposed lines are not significant or either extent or value of habitats lost. It states no significant effects are predicted on sites designated for their nature conservation value and no significant effects are predicted on protected species or species of high conservation concern. In this chapter it is noted that figure 7.1 indicates the designated nature conservation areas while figure 7.2 shows the location of the polesets on habitat maps for both the Binbane – Letterkenny and the Ardnagappary – Tievebrack lines.


3.9 Water Quality, Fisheries and Soils, Geology and Groundwater – (EIS Chapters 8, 11 page and 9, 11 pages) The Binbane – Letterkenny and the Ardnagappary – Tievebrack overhead line routes lie within the North Western International River Basin District (NWIRBD). The River Basin District drains significant portions of County Donegal, Leitrim, Cavan, Monaghan, Longford and a portion of County Sligo. It is noted that it drains an area of approximately 12,300km2 of which 4,900 km2 is within Northern Ireland. The EIS notes that the fisheries in the River Basin district are managed by the North-Western Regional Fisheries Board (NWRF) and the Loughs Agency. Section 8.2 describes the receiving environment and lists the main rivers in Tables 8.1 and 8.2 for different overhead lines. It describes the river or tributary, the catchment and the structure numbers relevant to the rivers. Table 83 lists the lakes and associated catchments on the two lines. In total there are two lakes listed for the Binbane – Letterkenny line and six for the Ardnagappary – Tievebrack line. The EIS notes that the River Finn SAC designation partly relates to its salmon populations. It notes the Owenea River is designated for the freshwater Pearl Mussel and the Clady River is also designated for the Pearl Mussel. Section 8.2.2 gives a description of the river catchments on the Binbane – Letterkenny line and Section 8.2.3 describes the river catchments on the Ardnagappary – Tievebrack line. In relation to existing water quality, the Water Framework Directive Characterisations Assessments is described in Section 8.2.4 of the EIS. The summary of the risk assessments for the river water bodies traversed by the proposed line routes are presented in Appendix (i). The EIS states that the risk assessments indicate that most of the rivers on the Binbane – Letterkenny line were probably at significant risk from morphological or intensive land use pressures. It says most of the rivers within the Ardnagappary – Tievebrack study area are stated not to be of significant risk except for the Clady and the Gweebarra which are of risk from morphological or diffuse sources. Table 8.3 indicates the Q-ratings used on table 8.4 gives the specific classification and likely ecological status. It states that on the Finn River catchment the ecological quality ranges from high through moderate to poor. On the main Finn River system it states the Cummirk River which is a tributary of the Finn shows satisfactory ecological quality over its length. It notes that monitoring data provided by the EPA for Lough Shivnagh for 2004-2006 indicates the lake to be at oligotrophic status which indicates High Status under the WFD classification scheme. Referring to the water quality on the Ardnagappary – Tievebrack line it states the Dungloe River varies from high to poor.


In relation to estuarine and coastal waters the EIS states that the Gweebarra transitional water body was assessed as being not a significant risk under the characterisation process. Section 8.3 describes the impact of the development and breaks this between the phases with the construction phase including potential impacts from a clear felling of a forestry corridor. In relation to potential impacts from peat failure, the EIS states that given the extent of peat in the area failure has to be considered as a potential risk and it would rest in Section 9 of the EIS. In relation to the operational phase, it states there is minimal flood risk to the switching station and the substation sites and the development would not increase the flood risk in the receiving catchment. Section 8.4 refers to mitigation and reference is made to general mitigation measures in relation to water as being covered in the flora and fauna section 7.4. In relation to forestry areas, the EIS states that works will be carried out with the requirements of the guidelines published by the Forestry Service. The conclusion of the chapter is that with the combination of mitigation measures incorporated into the design, the potential impact to water quality is low. Figure 8.1 indicates the river catchment on an A3 sheet. Chapter 9 is entitled Soils, Geology and Groundwater and describes the receiving environment in Section 9.1. Table 9.2 gives a description of the lithological units on the bedrock map which is in figure 9.2. The geological units include limestone, granite, quartzite, sandstone and schist. The Tievebrack Switching Station is stated to be underlain by blanket peat and lies between two rock formations, while the Ardnagappary Substation is located in an area of blanket peat with some occurrence of weathered till and alluvium close to the site. It lies between two rock formations of quartzite and granite. The EIS states there are no geological heritage sites located along either route. It states that four locations (two on each line) were identified by the GSI for consideration as national heritage areas within 1.5 kilometres of the line route, but none are within 250 metres of the route. In relation to hydrogeology, the EIS states that the majority of the Binbane - Letterkenny line is generally unproductive except for local zones and is classified as a poor aquifer. The vulnerability map for Donegal Groundwater Protection Scheme has classified the majority of the route corridor as being highly to extremely vulnerable to groundwater pollution. In relation to the Ardnagappary – Tievebrack line, the bedrock units have been classified by GSI as locally important aquifer. The vulnerability map indicates that the groundwater is highly to extremely vulnerable to groundwater contamination.


Tievebrack Switching Station is stated to be sited in an area with a vulnerability rating of moderate, while the substation at Ardnagappary is also in an area with a vulnerability rating of moderate. Section 9.2 describes the impacts of the development at construction stage and the conclusion that the most significant potential impacts associated with the switching station and substation would be peat instability. The combined volumes of peat to be excavated would be approximately 18,000m3. It notes the construction of both stations would result in an increase of hard standing which would increase surface water runoff volumes to surrounding peat lands. Section 9.3 deals with mitigation and describes the construction phase which would include a sediment and erosion control plan and also mitigation measures against slope failure which would include: - • Assessment of the suitability of the ground in which excavated material is

to be placed prior to storage.

• Supervision of dewatering activities to be carried out by suitably qualified hydrologists/engineers.

• Dewatering not to discharge to the ground close to the excavation or on to

areas of peatland.

• Completion of excavations as quickly as possible to minimise potential effect of dewatering and the surrounding shallow watertable and slope stability.

• Work not to be carried out following extreme rainfall.

• Walkover survey to be conducted prior to the excavation to check for

breaks in the blanket peat.

• Removal of vegetation limited to the area of excavation and access roads.

• Drainage just to be constructed as required diverts natural hour man-made watercourses away from excavated areas.

• Earthworks and site drainage to be designed against potential for peat

failure. The depth of peat to be reused in landscaping berms within the stations not to exceed 1.2 metres.

• Sediment ponds and silt traps to be provided to control silt during

construction and manage any accidental spillages.

The EIS also refers to the need for the storage of creosote treated wooden poles away from local watercourses or drainage ditches.


Management methods are set out in relation to operation and the storage of chemicals and fuels. Section 9.4 states in conclusion that the development would result in a slight impact due to the local loss and/or compaction of peaty soils. Figure 9.1 indicates the quaternary geology which shows that the majority of the route is on blanket peat. Figure 9.2 gives the bedrock geology, Figure 9.3 gives the GSI well searched data and Figure 9.4 indicates the groundwater vulnerability along the route.

3.10 Air, Climate and Noise: - (EIS Chapters 10 and 11)

The EIS states the project is located in a rural area with no significant industrial emission sources and it notes the location of proposed Ardnagappary Substation site is adjacent to a business park and regional road. Section 10.2 describes the impact of the development and states that at construction stage, dust nuisance was not expected at a distance beyond 250 metres from the work activity and then only when the receptors are downwind of the construction work. Section 10.2.2 describes gaseous oxidants and refers to corona activity of the transmission/distribution lines which could produce ozone (O3) with some oxides of nitrogen. It states that in these cases a discharge of pale violet colour appears near the adjacent metal surfaces. The EIS states that ozone from high-voltage power lines does not significantly contribute to overall air pollution levels. It states that international opinion has dismissed ozone as an environmental impact of high-voltage lines, based on evidence. The EIS refers to greenhouse gases and climate and notes that there are thermal losses on long networks. It states the present network configuration and normal feeding conditions leads to approximately 3.3 megawatts in peak thermal losses on the network. It states that the new substation and associated lines when compared to the present network would lead to reduction of approximately 2.2 megawatts of losses at peak and this would reduce the power required to supply users in Donegal and an annual reduction in greenhouse gases were approximately 7,200 tonnes of CO2 per annum. The EIS states the loss of CO2 from de-forestation would be offset through reduced energy losses from increased transmission efficiency and through enablement of renewable generation. The EIS refers to sulphur hexafluoride (SF6). The EIS states that SF6 is used as an insulating gas in substations and is a powerful greenhouse gas but that the current amount in the atmosphere is small. It states the total quantity of this gas to be used in the switchgear at Ardnagappary would be 1,422 kilograms. A small quantity of roughly 30 kilograms would be used at Tievebrack Switching Station in circuit breakers. It states that gas loss to the atmosphere would be minimal.


The conclusion of this chapter is that the project would lead to a reduction in thermal energy losses on the network and would facilitate the greater use of renewable generation which would have net positive benefit in reducing carbon emissions. It states that during the construction phase, site works for the switching station and substation would give rise to dust and emissions and the impacts would be short term and could be controlled using good site practice. Chapter 11 deals with noise and Section 11.1 describes the receiving environment. Table 11.1 gives noise measurement at a number of locations on both lines. The EIS notes that noise levels indicate typical rural conditions and variations and heavily influenced by traffic on local roads, particularly at night. The Laeq varies between night time values from 35 to over 70 dBA and daytime values of 39 to 74 dBA. The EIS refers to construction noise and Table 1 gives the maximum permissible noise levels at the façade at dwellings during construction. Table 11.2 gives the sound power levels of a 250 MVA transformer. Section 11.2.3 describes power line noise including gas sparking, corona noise and aeolian noise. Section 11.2.4 gives a noise prediction and in relation to noise limits, reference is made to International Standard ISO 1996 which provides guidelines for the description of noise in community environments but does not specify limits for environmental noise. In the assessment, the EIS states that noise prediction maps include a penalty to allow for tonal noise and these indicate that for both sites the predicted level is below the background levels of the nearest noise sensitive location. Section 11.3 deals with mitigation and reference is made to landscaping and planting of trees at the switching station and substation. In relation to the overhead power lines, the EIS states that corona noise would only be audible under certain weather conditions and in close proximity to the line and so it was not expected that noise arising from corona would give rise to complaints. The conclusion of this chapter is that the project is not expected to cause any significant long-term noise impacts. Figure 11.1 gives the locations used for noise monitoring. Figure 11.2 gives a noise contour for Tievebrack and Figure 11.3 gives noise contours for Ardnagappary Substation.

3.11 Landscape: - (EIS Chapter 12, 30 pages and 28 Figures) This chapter begins with an introduction and sets out the methodology for

landscape assessment including reference to landscape sensitivity, magnitude of resource change and significance of landscape impact. It also describes visual assessment criteria and terminology. It notes the use of the term zone of visual influence (ZVI) and refers to the photographs and photomontages which are included in Appendix P.

Section 12.3 describes the receiving environment and states that the landscape

character of Donegal has been predominantly influenced by the extensive glaciations of the Dalradian Rocks from which the landscape is mainly


formed. It states the study extends from Letterkenny West to Gweebarra Bay. It states that mountain ridge lines generally run in a north-east to south-west alignment from the Derryveagh Mountains to the Blue Stack Mountains in the south. It notes the coastal areas consist of a gently undulating landscape with extensive small loughs. It notes that residential development is much more frequent with proximity to the coast. The distinctive landscape character areas are described as: -

• Open upland hills and mountains – the EIS states that mountains are the most significant component of both the landscape and visual resource of the study area. It notes the presence of wind farms, especially in the Cark mountain area south of Letterkenny. It notes that areas of especially high scenic amenity (EHSA) are within the landscape character at Grogan More to the R254 at Doochary, Boultypatrick, Aghla Mountain, Glendowan Mountain, Tievedeevan Hill, Meenirroy Hill and Tullytresna Hill. Reference is made to map 6 of the Donegal County Development Plan 2006.

• River Finn Valley – the EIS notes housing as being located in linear

fashion along the R252 that follows the route of the river closely. It states that existing electricity lines cross this landscape and the character area of the landscape has a medium sensitivity to change.

• Letterkenny urban/rural fringe – EIS states that housing is frequent and

conspicuous and the landscape character is described as having a low sensitivity to change.

• Open lowland hills and lakes – the EIS notes the area from Gweedore to

the west and south of Glenties as having undulating open landscape extending between the mountains. It states that the trees are largely absent and this landscape character is described as having a high sensitivity to change.

• River Swilly Valley – this runs in an easterly direction from the slopes of

the Glen Down Mountains to Letterkenny across the study area. The landscape area has a medium sensitivity to change.

• Glenties Urban/Rural Fringe – the EIS states that this area has been

sporadically developed for single houses. It states that housing is also spread along the N56 to the south and west of Glenties as well as the R250 and 253. It states housing is frequent and conspicuous and that existing electricity lines cross the landscape. It states that this landscape character area has a low sensitivity to change.

• Gweebarra River Valley – the EIS describes a narrow river valley

crossing the study area extending from east to west towards the Atlantic following the Gweebarra River. It states that mountain tops on either side of the valley dominate the view and create an enclosed landscape which


allows only linear views. It notes that existing electricity lines cross the landscape and the EIS describes the landscape character as having a medium sensitivity to change.

• Gweedore Urban/Rural Fringe – the EIS notes that the coastal fringe

between Gweedore and Bunbeg /Derrybeg has been extensively developed for single houses. It states that this contrasts starkly with the adjacent upland areas where housing is almost completely absent. It notes the crossing of the landscape by existing electricity transmission lines. It also notes that the N56, R257 and R258 roads cross the landscape and are important access routes for traffic in West Donegal. It states that the landscape character area has a low sensitivity to change.

Section 12.3.1.2 describes visual character which is described as open and expansive. Walking routes are stated to be located at several locations throughout the study area and reference is made to the Blue Stack Walking Route which is 47 kilometres long following the Eske River to Lough Eske and this route begins in Donegal Town and stretches to Ardara. The Slí na Rossan and Slí na Finne walking routes form part of the Donegal Way known as Slí Dun na nGall. The EIS states the Donegal Way comprises four circular walking trails, each at 50 -70 kilometres in length with a total length of approximately 280 kilometres. It notes that the locations of the walking routes are illustrated in Figure 13.4.

The EIS refers to the County Development Plan 2000 and refers to Policy No. 1 relating to conservation which divides the county into three categories of which Category 3 corresponds with the areas of especially high scenic amenity designated within the 2006 – 2012 Plan. Chapter 8 of the County Development Plan proposes to protect landscapes of highest scenic amenity and views and prospects of specific importance. It notes that policy BNH5 designates areas of especially high scenic amenity. The EIS notes that the plan proposes afford those areas of high scenic value greater protection while adopting a positive attitude to development in areas of relatively low scenic landscape quality. It notes the criteria for development which include the importance of the view, the integrity of the view, significant intrusion and materially altering the view. With respect to the Binbane - Letterkenny line, locations identified are as follows: - • R253 east and south to Gaugin Mountains.

• R252 west along the River Finn at Cloghan.

• County Road West of Cloghan looking south-west towards Crocknahamid.

• R250 south across Lough Finn.


Along the Ardnagappary – Tievebrack line the N56 east and south across Lough Anure and at Gweebarra Bridge west and east are identified. Section 12.4 refers to the impact of development and notes that the physical elements are likely to affect landscape and visual resources include temporary disturbance from construction, imposition of new vertical features and lines in the landscape and the construction of prominent new built elements in the switching station and substation. The EIS lists the impacts on the landscape character areas arising from the Binbane - Letterkenny line and these are summarised as follows: - • Open lowland hills and lakes – a total of nine steel towers are located

within this landscape character area. The EIS states the predicted magnitude of change in landscape resources low and the significance of the landscape impact is rated as slight negative.

• Open upland hills and mountain – it notes that the route of the line

crosses the landscape for long lengths between Tievebrack and Letterkenny. Regarding crossing the River Finn at Scallan Bridge, it notes the route rises on the western and northern slopes of Tievedeevan. It notes that at this point it crosses an area designated as EHSA on Map 6 of the Donegal Development Plan 2006. It notes that the portion of the landscape north of Cark Mountain has existing transmission lines. It notes from Ballystrang to Letterkenny the route passes through scattered forestry restricting wider landscape impacts.

The EIS notes this landscape assessment has categorised the landscape as exceptional quality. The predicted significance of landscape impact is rated as moderate negative in the EIS.

• River Finn Valley – three steel towers are planned in this landscape and

two are located on the western shores of Lough Shivnagh and are prominent in the enclosed landscaping directly viewed from the R252. The predicted significance of landscape impact is moderate negative.

• Letterkenny Urban/Rural Fringe – the route is stated to terminate at the

existing substation located adjacent to the N13 road. The landscape character has been identified as having a low sensitivity and the predicted significance of landscape impact is slight negative.

Section 12.4.2 refers to the direct landscape character impacts of the Ardnagappary – Tievebrack line. The landscape character areas are deemed to be impacted as follows: - • Gweedore Urban/Rural Fringe – it states that the route crosses the

landscape for a length of approximately 4 kilometres and generally follows existing electricity lines. It notes there are frequent and conspicuous urban features in the landscape which results in low levels of landscape resource


change. The predicted significance of landscape impact is slight/moderate negative.

• Open upland and hills and mountains – the EIS states the route of the

line crosses the landscape with short lengths at three separate locations namely east of Crolly on the western slopes of Groganmore where the route follows two small stream valleys while crossing the landscape. This is a category 3 landscape. The route again crosses the landscape on the western slopes of Crovehy to the east of Dungloe south of the Gweebarra River Valley the route crosses the final section of this landscape rising on the western slopes of Gafaretmoyle. It notes the two steel towers are located within this landscape on the western slopes of both Grogan More and Crovehy Mountains. The landscape character is stated to have a high sensitivity and the predicted significance of landscape impact is moderate negative.

• Open lowland hills and lakes – the EIS states the route of the line crosses

this particular landscape for lengths at three separate locations. These are east of Lough Anure, south of Dungloe and towards Tievebrack. It states a total of nine steel towers are located within this landscape character area. The EIS states the landscape quality has been identified as high and the predicted significance of landscape impact is moderate negative.

• Gweebarra River Valley – the EIS states the Gweebarra River is crossed

at Ballinacarrig and that route follows for most part an existing transmission line. It states the landscape quality has been identified as medium and the predicted significance of landscape impact is slight/moderate/negative.

The EIS refers to the Zone of Visual Influence (ZVI) and this is illustrated in Figure 12.1. It states that an assessment has taken place along the entire route of the proposed transmission line to assess the magnitude of visual impact of the scheme on residential properties that have potential views of the scheme within the ZVI. (There appears to be a typographical

omission in relation to the number of significant visual impacts, but the

EIS states there are a total 906 residential properties assessed and a total

of 860 would not be significantly affected). Table 12.3 gives a summary of visual impact with 40 rated as being substantial/negative, 135 moderate/negative and 243 slight/negative. The locations of photomontages are shown in Figure 12.1 and illustrated in Appendix P. The EIS lists the viewpoints as follows: -

• Viewpoint 1 – R262 at Binbane – no significant visual impacts predicted.

• Viewpoint 2 – county road north of Lough Namafin. The significance of visual impact is rated moderate/substantial negative and direct view of steel tower is available and transmission lines across the road overhead are seen.


• Viewpoint 3 – N56 east of Ardara – no significant visual impacts are

predicted at this viewpoint.

• Viewpoint 4 – local road at Tullyard - west of Glenties – the predicted view is that proposal is visible in the view in the form of two wooden polesets both of which are read against existing vegetation. It states the set to the left of the view is well screened at ground level by existing gorse. Overhead lines would cross the centre of the view, but would not dominate the view. The predicted significance of visual impact is moderate and the EIS predicts no significant visual impacts to occur from this viewpoint.

• Viewpoint 5 – N56 northwest of Glenties – this view is stated to be

available to local commuters, day-trippers and tourists travelling on the N56 and the viewers’ sensitivity are referred to as medium. The EIS states that no significant visual impacts will occur from the viewpoint.

• Viewpoint 6 – R250 north of Glenties – the predicted view would have the

development visible in the distance running along the slopes of Meenalargan Hill and Straboy Hill. A total of 11 wooden polesets are visible, but it states that none are prominent due to the distance of the view. The EIS states that no significant visual impacts will occur from this viewpoint.

• Viewpoint 7 – junction of the R250 and local road northwest of Glenties –

the development would be visible in the form of a number of wooden polesets and two steel towers. It states the proposals do not break the skyline and in particular the steel tower is set against the backdrop of a hillside and coniferous forestry that reduces its prominence. It states that two other wooden polesets will be partially visible within existing coniferous forestry but very difficult to discern by the casual viewer. The EIS predicts no significant visual impacts from this viewpoint.

• Viewpoint 8 – view from R250 northwest of Glenties to the north. The

predicted view is of a number of wooden polesets and one steel tower and the EIS predicts no significant visual impacts from this viewpoint.

• Viewpoint 9 – Tievebrack Switching Station. The EIS states the predicted

view would show the Tievebrack Switching Station as visible in the centre of the view. It notes two steel towers would be against the backdrop of the hillside and a third steel tower would be viewed above the skyline. The EIS states that significant visual impact would occur from this viewpoint.

• Viewpoint 10 – R253 near Clogher North – the existing view consists of

open moorland that rises to form Knockletteragh at over 300 metres OD and a predicted view is of a single steel tower in the middle distance with the remainder of the line support on wooden polesets extending off into the visible distance. The EIS states the significance of visual impact as moderate/substantial.


• Viewpoint 11 – junction of R250 and R252 east of Fintown – the existing

view is stated to be across an enclosed river valley landscape that is open to the surrounding hills. It states that two wooden polesets and one steel tower would be visible in the predicted view. The EIS states that no significant visual impacts would occur from the viewpoint.

• Viewpoint 12 – R250 east of junction with R252 – the predicted view is of

a steel tower below the skyline of Tievedeevan Hill. The EIS states that no significant visual impacts would occur from this viewpoint.

• Viewpoint 13 – from the R250 at Meenatinny – the predicted view is of

wooden polesets extending from close view into the distance. It notes that a braced wood poleset is provided at the change of direction of the line within this view. It states the wooden polesets do not break the skyline and they are red against the background of the moorland. The proposal is stated to occupy a large portion of the visible view. It states that significant visual impact will occur from this viewpoint.

• Viewpoint 14 – south from Letterkenny – the EIS states the route from

Binbane to Letterkenny is screened by intervening topography. The EIS states no significant visual impact will occur from this viewpoint.

• Viewpoint 15 – Bunbeg – the viewer sensitivity is stated to be low in this

instance. The predicted view is that a total of three wooden polesets would be partially visible and one steel tower would be visible. It states the Ardnagappary Sub- Station is located within the view, but due to intervening topography and vegetation, only the tips of the infrastructure would be visible. The EIS predicts no significant visual impacts from this viewpoint.

• Viewpoint 16 – N56 west of Gweedore – this route is stated to be used by

local commuter traffic. The viewer sensitivity is stated to be medium. The predicted view is that a single wooden poleset would be visible located to the right of the view and adjacent to the roadside. The EIS states that no significant visual impacts would occur from this viewpoint.

• Viewpoint 17 – R257 at Dore west of N56 – the existing visual resource is

stated to consist of wooden poles and overhead electricity cables and rural housing which are conspicuous in the foreground of the view. The predicted view is that a total of five wooden polesets would be visible in the background of the view and that none of the wooden polesets cross the skyline. The EIS predicts no significant visual impacts would occur from this viewpoint.

• Viewpoint 18 – county road south of Lough Anure – the prediction is to

the total of seven wooden polesets would be visible in the view and a steel tower present in the view direction would be completely screened by existing trees. It states that none of the wooden polesets break the skyline.


The predicted significance of visual impact is moderate and the EIS predicts no significant visual impacts from the viewpoint.

• Viewpoint 19 – N56 near Oughtmeen – predicted at one wooden poleset

would be visible in the centre of the view and that new overhead cables would cross the view from left to right, but due to the distance they would not be prominent and difficult to discern. The predicted significance of visual impact is slight/moderate and no significant visual impacts are predicted from this viewpoint.

• Viewpoint 20 – N56 east of Drumlaghrid 1 – the prediction is that a single

steel tower would be visible in the view and the viewer’s eye would be drawn to the structure due to the lack of other vertical features in the view. The EIS predicts no significant visual impact from the viewpoint.

• Viewpoint 21 – N56 east of Drumlaghrid 2 – the direction of this view is

290 degrees and a total of five wooden polesets and one steel tower would be visible from the viewpoint. The significance of visual impacts is predicted as moderate/substantial, but significant visual impact is not predicted from this viewpoint.

• Viewpoint 22 – Ballinacarrig – the prediction is that a steel tower would

be visible on the northern side of the Gweebarra River. The EIS states the steel tower does not break the skyline and is partially screened by vegetation and will not be prominent. It states on the southern side of the river wooden polesets would be located with the view extending into the distance. The predicted significance of visual impact is moderate and no significant visual impacts are predicted to occur from the viewpoint.

• Viewpoint 23 – Ballinacarrig with view direction 45 degrees. The

prediction is that one wooden poleset and a steel tower would be visible in the view. The wooden pole would be located at the roadside and it is located with a backdrop of two houses. It states that only the upper portion of the tower would be visible.

The EIS states that the new features read with the existing vertical elements in the existing view. It predicts no significant visual impacts from the viewpoint.

• Viewpoint 24 - local road on southern road of Gweebarra River – the view

is stated to be obtained by travelling west on the local road that extends along the southern side of the Gweebarra River. It states the existing visual resource also consists of wooden poles and overhead electricity cables and rural housing which are conspicuous on the southern and northern side of the river. The prediction is that the two wooden polesets would be visible on either side of the river and the poleset on the southern bank would be visible against the background of the river generally as a silhouette. The EIS rates the significance of predicted visual impact as


moderate and that no significant visual impacts would occur at the viewpoint.

Section 12.4.6 refers to the Development Plan designations and protected views. With regard to Binbane – Letterkenny the nearest protected views are located on the R253 south of Boultypatrick and the R252 along the River Finn. The EIS states the landscape and Visual Impact Assessment has established no change would occur to protected views or prospects.

Dealing with Ardnagappary – Tievebrack the nearest protected views are on the N56 looking east and south across Lough Anure and from the N56 at Gweebarra Bridge west and east. It states that when impacts on designated views and prospects within the CDP are considered, the landscape and Visual Impact Assessment has established no change and would occur to protect the views or prospects. It states the County Development Plan protects a series of approach roads to Glenveagh National Park and the EIS states that due to distance in intervening topography, the Donegal 110 kV project does not cause any landscape or visual impact on the protected approach roads.

Referring to ESHA or the especially high scenic amenity areas, on the Binbane – Letterkenny route at one location south of the R250 near Tievedeevan, the EIS states the route does partially encroach on the designation. It states the short section of approximately 300 metres in length crosses the periphery of this designation. It states the predicted significance of landscape impact is moderate/negative. With regard to the Ardnagappary – Tievebrack line, one location east of Crolly on the western slopes Groganmore does partially encroach on the designation. It states there are no steel towers at the location and the results in change in landscape resource are low. It states the predicted significance of landscape impact is moderate negative.

Section 12.4.7 deals with views from roads on the Binbane – Letterkenny route. It states the line crosses the county road north of Lough Namafin. It states a steel tower is required immediately adjacent to the road that would be visible when travelling both north and south. The predicted significance of visual impact is moderate/substantial negative. It states the R253 south-west of Boultypatrick does not cross by the proposals. The EIS states the R252 north of Boultypatrick follows the River Finn valley and is not crossed by the proposals and due to intervening topography, there are not direct views of the proposals. It states the N56 has crossed east of Ardara. It states the views of the proposals would be limited to a section of the N56 approximately 0.5 kilometres long. The EIS states a steel tower is located north of the N56 partially screened by forestry plantation of scattered natural vegetation.

It states the N56 is also crossed north of Glenties and the views of the proposal extend to a section of the N56 approximately 2 kilometres long.

The R250 road is crossed north-west of Glenties at Shallogan near Tievebrack. It states that two steel towers are located at a distance of over one kilometre from this route and will not play a significant role in the visual resource of the view from the road. The R253 from Glenties to Clogher North does not cross


by the proposals. The EIS states that the R250/252 roads are crossed east of their junction near Lough Shivnagh. It states the steel tower is located west of Lough Shivnagh that would be visible from the R252. It states that a small proportion of the route is affected by the proposals for a medium duration. The EIS states that the predicted significance of visual impact is moderate.

The R250 road is not crossed, but the line runs parallel for a distance of approximately 8.5 kilometres. It extends from Fintown to Rashedoge of a length of approximately 19 kilometres.

The EIS states the N13 south of Letterkenny is not crossed by the proposed transmission line, but it runs parallel for a distance of approximately 3.5 kilometres.

Section 12.4.8 deals with views from roads on the Ardnagappary – Tievebrack line. The EIS states the crossing of the N56 was the Gweedore is located at the same location as an existing electricity line across the N56. The crossing of the N56 near its junction with the R252 is similarly located on a bend on the road. The proposal is visible for only a short length of the road. It states the third crossing of the N56, east of Drumlaghdrid Hill is located on a site where an existing electricity line crosses the road on wooden poles. The predicted significance of visual impact is slight/moderate. It states that at the crossing of the R250 north of Glenties, the road is bending and undulating which is a fact that limits views to within close proximity of the proposals.

The EIS refers to walking routes and states that the Binbane – Letterkenny line crosses the Slí na Fine walking route at Kingarrow which is west of Meeniroy Hill. Slí na Fine lies south of the R250 at this location. It states there is no steel tower located at or near to the crossing of the footpath. The second crossing is south of Stracashel River to the north-west of Clogher North. It states the nearest steel tower to the walking route is located approximately one kilometre to the east. The predicted significance of visual impact is described as slight/moderate.

The Binbane – Letterkenny line crosses the blue stack alternative way walking route at two locations namely the R262, south-west of Binbane and Tievachorky immediately south-west of the existing Binbane 110 kV Substation. It states predicted significance of visual impact is moderate. The proposals also cross the blue stack way close to the Owenea River and north of the N56. It states there are no steel masts at the crossing point and low levels of visual resource change would occur.

The Ardnagappary – Tievebrack line is stated across the Slí na Rossan walking route six times between Dungloe and Gweedore. It states that the route is crossed twice within close proximity to the N56/R252 junction. The EIS states that the N56 is a significant feature of this part of the landscape as well as the existing overhead lines and wooden poles. It states the predicted significant visual impact is moderate.


The EIS states the Ardnagappary – Tievebrack line makes a further two crossings of the Slí na Rossan in the foothills of Croaghpatrick, and to the east of Craghy Lough in close proximity to each other. It also crosses the Slí na Rossan walking route south-west of Meennamarragh and Lough Anure. It states that a further intersection on the Slí na Rossan follows a county road in the foothills of Groganmore and Cronaguiggy, north-west of Lough Keel and north-east of Lough Anure.

The EIS describes construction phase impacts and notes that this is likely to be limited in duration. It states when viewed from the wider landscape the overall visual impacts during the construction phase would be slight due to limited view or exposure and low visual resource change.

Section 12.5 refers to mitigation. It states that the Landscape and Visual Impact Assessment has established that significant adverse effects occurs at the county road north of Lough Finn and at 46 residential properties along the route of the proposed line. It states the assessment of photomontages has established that five locations would have significant visual impacts namely viewpoints 2, 9, 11, 14 and 22.

Section 12.5.1 deals with specific mitigation measures and includes a proposal that planting should be used to screen the views from the county road at Tievebrack towards the switching station. It notes that between structures ST32 and ST37 and the Ardnagappary – Tievebrack line, it may be necessary to construct an access in rock outcrops and side slopes. It notes that careful tree felling is required within commercial forestry areas to avoid unnecessary wind blow effects.

General mitigation measures are described which relate mainly to site design and an Environmental Management Plan.

The conclusion of this chapter notes that the Binbane – Letterkenny line crosses four landscape character areas. It states that no significant landscape impacts have been predicted, but that moderate negative impacts are predicted for the open upland hills and mountains and River Finn valley landscape character areas.

It states the Ardnagappary – Tievebrack crosses four landscape character areas and that no significant landscape impacts have been predicted. It states that the ZVI was established and that the extent of the visibility is limited to approximately 1-2 kilometres either side of the routes.

The Donegal Development Plan indicates a number of designations and the EIS states that the assessment has established that no significant visual impacts were predicted for any of the proposed views due to distance and direction the view protected. It states that a total of 24 viewpoints have been assessed using photomontages. When views from roads were assessed, one view is significantly affected on a county road north of Loughnamaghfinn Finn and west of Binbane. It notes that specific mitigation measures have been recommended.


The EIS states the selection of the viewpoints followed discussions with both Donegal County Council and An Bord Pleanala. It states that overall when landscape and visual impacts were considered the proposal is acceptable and the surrounding landscape and its visual resources have the ability to accommodate the changes of the type associated with the development.

Figure 12.1 gives a list of the locations of the viewpoints and Figure 12.2 indicates the landscape character boundaries. Figures 12.3 A – X on A4 sheets show the individual polesets and angle masts and show the houses with the relevant impact rating as regards views. (Note that some of these maps were upgraded at the oral hearing and additional houses were added in these cases to reflect the building of new dwellings subsequent to the use of the relevant base maps used).

3.12 Material Assets, Cultural Heritage and Interactions:- (EIS Chapters 13,

14 and 15)

Section 13.1 describes land use and notes that the Figures 13.1(A-E) and 13.2(A-C) identified a poleset and angle mast locations together with a land use within the 300 metres corridor of the proposed route. The EIS notes that agricultural land is restricted to comparably small areas and the bog land is the most dominant land use within the 300 metres corridor and throughout much of the surrounding rural environment. It also refers to forestry, residential and commercial property and other land uses. The EIS notes the impact of the development and concludes that the loss of forestry land, including that owned by Coillte is the most significant impact in terms of area impact and its importance as a financial resource. Table 13.1 indicates the land use impact by the replacement of polesets on both proposed lines, while Table 13.2 is the land use impacted by the placing of angle masts. Table 13.1 is the total land take associated with polesets and angle towers. The EIS states that mitigation associated with land take/demolitions in relation to residential or commercial property is not required. The EIS concludes that the mass of forestry land, particularly that owned by Coillte, is perhaps the most significant land loss due to its importance as a financial resource. It states there would be limited impacts due to loss of agricultural lands at polesets and angle tower locations and the impact would be mitigated by the siting of structures to minimise such losses. Section 13.2 refers to traffic and discusses traffic on the national roads and the regional roads. It notes that three regional roads are traversed by the Binbane – Letterkenny route and two regional roads by the Ardnagappary – Tievebrack line. In relation to impacts, the EIS states that construction materials and equipment will be transported to the site by road and there would be an increase in traffic during the civil works phase of the development. It states the most significant traffic volumes associated with the main civil works at the switching station and substation would involve deliveries of imported engineering fill, crushed stone and concrete and reinforcement deliveries. It


states the maximum number of daily traffic movements at each site is estimated to be approximately 50 movements. In relation to the overhead line, the EIS envisages two polesets per day to be erected and the assessment assumes that installation of angle masts are carried out simultaneously, but at different locations along each aligned route. It envisages that foundation works at each angle mast would take one week to complete and that the estimated number of vehicle movements associated with each angle mast would be 15 HGV and 20 cars each day over five days. Table 13.4-13.6 gives estimates of AADT values for the national roads, regional roads with a summary of traffic impacts. In relation to traffic the EIS concludes that there would be significant traffic impacts on the local road from the R250 to Tievebrack and possibly on the R252 Fintown to Cloghan Road during the construction of a Tievebrack switching station. It states there will be significant traffic impacts on the R258 Gweedore to Derrybeg Road during construction of the Ardnagappary substation but no effects thereafter. In relation to tourism and amenities, the EIS draws attention to the census figures which show that the numbers employed in County Donegal in hotels and restaurants in 2006 was 3,834 which was a rise of 26% over 2002. It states that tourism has been identified for the key sector for the county in an stratéis which the county strategy for economic social and cultural development. Amenities are described which includes the Fintown Railway which includes a 4 mile trip alongside Lough Finn which 2.4 kilometres from the Binbane – Letterkenny line. It notes Saint Conal’s Museum located in Glenties approximately 1.5 kilometres east of the Binbane – Letterkenny line. Other centres and monuments are at a greater distance from the various lines. The main network of walking routes is Bealach na Gaeltachta and the Blue Stack Way and these are shown in Figure 13.4. It notes the Ardnagappary – Tievebrack line crosses Slí na Rossan six times and the Binbane–Letterkenny Line crosses Slí na Finne twice. It also notes that the Binbane - Letterkenny line crosses the Blue Stack/alternative way twice, once close to the Owenea River northwest of Kilrean and once at the R262 crossing immediately southwest of Binbane 110 kV station. The EIS refers to cycling, scenic touring routes, golf courses, outdoor pursuit centres and angling. It states that the lines are not close to any of the Owenea River fishery beats. Regarding tourism facilities, it notes the nearest recreation area to the lines is at Kilrean which is approximately 670 metres from the Binbane - Letterkenny line. In relation to impacts, the EIS states that the development might tend to diminish the attractions of the area, but is unlikely to have a tangible effect on the tourist industry in the area, given its location away from the coast and the seasonality of the industry. It states the project would not interfere with access to rivers, but the Binbane - Letterkenny line would pass close to sections of the Stracashel River and could result in visual impact at those locations. The


conclusion in the EIS is that the development would not result in significant adverse impacts on tourism and amenities. The EIS concludes that the development would not result in adverse impacts on air navigation safety and would have positive effects on energy supply infrastructure. Chapter 14 deals with cultural heritage and Section 14.1 describes the receiving environment. The methodology sets out the approach which involves desktop, field surveys and review of aerial photographs as well as reference to the RMP sites. It is noted that on the Binbane - Letterkenny line there is a ringfort at Clonconwal at 250 metres distant and a Cashel at Gortnacart at the same distance, while five other features are located between 300 and 500 metres distant. It states there are no recorded archaeological sites within 500 metres of the Ardnagappary – Tievebrack. It notes the Donegal County Development Plan 2006 – 2012 lists no protected structures within 500 metres of the line, but the EIS notes that eight listed structures are located in the wider environs of Ardara, Glenties and Gweedore and these are indicated in Appendix R. The EIS states the buildings would not be impacted by the project. The EIS states that it is possible that the extensive areas of bogland within the study area contain hitherto unidentified archaeological features. It states that it is less likely that any recently improved areas of grassland contained features of an archaeological nature. The EIS notes that the lines are traversed by several important river systems and it is likely that the adjacent wider areas were utilised for settlements since early times. The EIS states that an assessment of place names within the study area was undertaken to see if some townland names may refer directly to terms of cultural heritage significance. Section 14.1.4 goes through the field survey results on the Binbane - Letterkenny line. It notes that from ST37 – ST60 there are two recorded monuments in the northerly portion in the vicinity of the Owentocker River. A cottage is referred to and this would not be physically impacted on and trees surrounding the buildings serve to block any views to or from the line. Between ST60 and ST87 Lough Ananima is noted to be north-west of the line. One recorded archaeological monument which is a ringfort is stated to be circa 250 metres from the route. In ST93-124, there is a ruined cottage at approximately 100 metres from ST94 in Meenalargan townland. It notes the line would span the disused railway embankment associated with the Stranorlar and Glenties Branch of the Donegal railway system and it is noted ST124 is at Tievebrack Switching Station. The EIS continues to describe the various sections and notes that the Bellanamore railway station and level crossing are 250 metres to the east and the section ST199 – 212. The line crosses the disused railway embankment on the southern banks of the River Finn between ST212 – 215. The EIS states that Kingarrow School (disused) would not be impacted upon and a ruined cottage is noted close to the line between ST306-321. In the last section between ST345 and 364, two recorded archaeological monuments are noted and the EIS states that these would not be impacted upon. Section 14.1.5 deals with the field survey on the Ardnagappary - Tievebrack line and these also refer to Appendix R.


Section 14.2 deals with the impact of the development and states that in relation to Binbane – Letterkenny, there are no recorded archaeological sites or built structures listed in the county’s record of protected structure which would be affected. It notes there are five constraints identified and four are features of post-medieval date and one constraint is an area of fair archaeological potential. This is set out in Table 14.2. The section with potential direct impact is ST69 – ST78 in the townland of Kilrean Lower and Tullyard. It states that in this area, there is potential for archaeological remains to be uncovered and these may exist in a sub-surface or fragmentary state and would be directly impacted on by any ground disturbance works that are connected with the line. In relation to Ardnagappary – Tievebrack, it notes that the route could potentially directly affect two portions of the disused railway embankment and these are indicated in Table 14.3. In relation to mitigation, on the Binbane - Letterkenny line a recommendation for Section ST69 – ST78 is that it has archaeological monitoring carried out for the excavation of foundations for angle masts and for any wooden poles required up to the southern banks of the Owenea River. On the Ardnagappary - Tievebrack line it states that the railway embankments that traverse the line route at ST11 – 13 and ST170 should be avoided as footprint locations of any wooden polesets associated with the scheme. The conclusion is that with the application of mitigation measures, any identified impacts on the archaeological cultural heritage interests would be appropriately addressed. Section 14.5 deals with language until 14.4 gives the population at 22,335 of persons age three and over who can speak Irish and this represents 58.3% of the population for the year 2006. The EIS states that the upgrading of infrastructure in the Gaeltacht and particularly in the Gweedore would support Údarás na Gaeltachta and An Roinn Gnóthaí, Pobail,Tuaithe agus Gaeltachta in the respective development roles. It states that the Donegal 110 kV project would not directly affect the linguistic and cultural heritage of the Gaeltacht. It suggests that the development would indirectly impact on the language by facilitating development of employment, the development of modern sector employment and facilitating the development as strong urban centres. It suggests that this would strengthen the language. Figure 14.1 indicates all the cultural heritage sites referred to in the text. Chapter 15 deals with the interaction of impacts and these are listed in Section 15.1. The interactions include the relationship between water and fisheries with flora and fauna, and the interaction of soils with water quality. It states that archaeology and landscape impacts have the potential to impact on archaeological monuments. It notes that material assets and water impacts on water quality have the potential to impact on material assets including tourism. Section 15.2 concludes that there are known existing or proposed


developments other than as noted with which significant cumulative impacts would arise.

3.13 Appendices: - (EIS Appendices A – S) Appendix A: - Glossary of Terms

This appendix runs to four pages and has the description of the various terms used in the EIS, mainly relating electricity generation and transmission. Appendix B: - Bibliography This appendix consists of five pages of reference including archaeological references, information on EMF, ecology references and general topics. Appendix C – Consultations and EIA Scoping This appendix gives details of consultations with community groups and business including: - • ATP – Alternatives to Pylons Donegal.

• Cumann Forbairt Aituil, Eadan Fhionn Fraoich (Glenties).

• Choiste Forbartha Bhealach an Aird Doinn (Gweedore)

• Lough Eske Community Development Association.

• OIdeas na mBan/Fintown Environment Group.

• Airtricity.

The EIS also details the consultations carried out in relation to the EIS and the table of organisations is given on page 3 and 4 of the appendix. This appendix also contains the briefing documents produced by the proposers. Appendix D: - Description of Electricity Systems This is a two-page appendix detailing the transmission system and the operation of the national grid. Appendix E: - Structures, Polesets and Angle Towers This appendix contains drawings and sections indicating the construction of the polesets (six drawings) and angle masts. The angle masts include drawings of 18 metres height and 15 and 12 metre height towers listed as type


136, 136E, 139 and type F 38 kV masts and including two drawings of braced wood polesets. Appendix F: - Predicted Electric and Magnetic Fields This appendix consists of four pages which give graphical representation of electric fields measured against the distance from the centre line. The information presented at the oral hearing was significantly more detailed than that in the EIS. Appendix G: - Natura 2000 Sites – Appropriate Assessment Process This appendix includes a flowchart outlining the appropriate assessment process and includes site synopsis on the NHA and SAC designated sites on the two lines. Eight designated sites are included. Appendix H: - Marsh Fritillary Report This is a report on the Marsh Fritillary Butterfly carried out for ESB International by Allen & Mellon Environmental Limited. Specifically the species is listed as a qualifying interest for the west of Ardaragh/Maas Road SAC. The conclusion in this report notes that it would appear that the proposed routes would not directly traverse any known march fritillary colonies. The nearest known sites to the route are given as the Derrydruel/Dungloe and Crolly which are stated to be 2 kilometres or more from the proposed route. Appendix I: - Water Framework Risk Assessment Summaries The risk assessments for the water bodies under Article 5 of the Water Framework Directive are given for the two separate lines and their level of risk together with the likely source of the risk is given. Appendix J: - EPA Biological Assessments This appendix gives the biological assessments for a number of sites on the River Finn, Foyle, Oily, Owenea, Owentocker and Swilly Rivers on the Binbane - Letterkenny route and for the Clady, Gweebarra, Gweedore, Owena, Owenmarve and coastal waters at Dungloe. Appendix K: - Line Routes and Forested Areas This appendix consists of tables which indicate the level of maturity of the forestry, its type and the area affected in respect of both 110 kV lines.


Appendix L: - Flood Risk Assessments This report is by ESBI Engineering and Facility Management and concludes that there is a minimal risk of flooding to the Tievebrack Switching Station and also to the Ardnagappary Substation site. It states that attenuation of runoff from both sites would be provided in line with current best practice. Appendix M: - Geological Heritage Sites This appendix is a GSI extract with NHA sites indicated together with the line of the proposals. Appendix N: - GSI Well Records This consists of a table indicating the locations of the wells in the study area with their type of uses indicated. Where available, it also gives details of yield. Appendix O: - Noise This consists of graphs indicating corona noise, noise at Binbane station at night, traffic noise at Letterkenny 110 kV station. Appendix P: - Photomontages This consists of 24 viewpoints with the existing photograph on top of each page and the photomontage of the proposal on a separate photograph on the bottom of each page. Appendix Q: - Road Crossings This appendix is in chart form and describes 90 road crossings on the Binbane – Letterkenny line and 42 on the Tievebrack – Ardnagappary line. Appendix R: - Archaeology Tables and Photo Plates Table R1 in this appendix is the record of protected structures on the Binbane - Letterkenny 100 kV study area and Table R2 is the record of protected structures on the Ardnagappary - Tievebrack 110 kV study area. Table R3 is the recorded archaeological monuments within 500 metres of the proposed Binbane - Letterkenny line and Table R4 has a catalogue of artefacts retrieved from the study area. Plates 1 to 58 give various views in relation to cultural heritage, and some of these are cross-referenced to different polesets. A further list of plates 1 – 38 refer to the Tievebrack – Ardnagappary line.


Appendix 3: - ESB Codes of Practice This is an ESB/IFA Code of Practice Agreement which is entitled survey, construction and maintenance of overhead lines in relation to the rights of landowners. It is prepared by ESB International. It is noted that this is dated 7th September 1992 and agreed between the IFA and the ESB.

3.12 Conclusion

The EIS states that significant reinforcement of the electricity transmission and distribution networks is required to address limitations in the existing electricity transmission and distribution networks in County Donegal. It states that without the development, quality and reliability of supplies to existing customers would be reduced and further industrial and commercial development would be curtailed. It states the selected option constitutes the optimum solution to reinforce the electricity network in County Donegal. It states the proposed development is consistent with the pattern of existing and proposed lines in other similar peripheral areas.


4.0 PLANNING CONTEXT OVERVIEW The planning context together with an examination of the provisions of the Development Plan is described in Appendix 2E of this report and is compiled by Mr. Conor Mc Grath. It is noted that the Development Plan 2006 – 2012 includes the objective of upgrading physical infrastructure, which includes electricity, and this policy is listed as one which supports Gaeltacht Areas. Reference is made to the targeting of development in the business parks at Dongloe and Gweedore. Policy FED 8 is noted particularly in this regard. The development plan also lists a goal of harnessing wind energy potential in a way that achieves a balance between responding to Government Policy on renewable energy and the proper planning and sustainable development of the County. The development plan has a policy to maintain and where possible enhance the nature conservation value of designated sites and has also identified areas of especially high scenic amenity (EHSA) and has illustrated these on maps. The exclusion of an area east of Glenveagh National Park for the consideration of power lines is particularly noted. Conservation of archaeological heritage is also listed as a goal of the Development Plan. I concur with Mr McGrath’s assessment in relation to the planning context. It is considered that the proposed 110 kV lines are in accordance with the provisions of the Development Plan. It is noted that the exclusion of certain areas for power lines by the Council based on landscape considerations would have guided Eirgrid and ESB Networks in terms of their route selection.


5.0 ORAL HEARING REPORT The Report on the Oral Hearing is available on disc and is reproduced in both the English and Irish languages. There are a small number of cases where the record of the simultaneous translation into Irish appears to have been recorded over by the recording equipment. The translation service operated throughout the hearing and no session started without the translator verifying his readiness to commence. On a small number of occasions it was necessary to ask observers and witnesses to repeat a question or answer when the speaker was too far from the microphone being used. A written summary of the proceedings is given in Appendix 1 of this report. It would not be normal to comment on the proceedings of a hearing but it is considered relevant to note that the use of simultaneous translation did not extend the time taken for the hearing. From an Irish language point of view it introduced some new vocabulary relating to the development and its construction methods that would not necessarily be in daily usage. It was a constructive and practical use of the Irish Language.


6.0 ASSESSMENT 6.1 NEED FOR THE SCHEME AND ALTERNATIVES A. Capacity The need for the scheme is referred to briefly in the Non Technical Summary of the EIS and the main reasons listed are the need for a secondary supply, lack of alternative feed for south-west Donegal and lack of future capacity in north-west Donegal. Chapter 3 of the main EIS discusses the need for the scheme in more detail and the schematic drawing in Figure 3.1 is considered pertinent to the problems as described. In that chapter the vulnerability of supply to Binbane is highlighted as is the undesirablilty of requiring boosters on the supply to Dungloe, Creeslough and Gweedore. It is considered the case is established for the strengthening of the network based on the current unsatisfactory configuration and absence of satisfactory standby measures. The capacity of the network, both transmission and distribution cannot be evaluated purely by comparing current carrying capacity with maximum demand and such issues as optimisation of transmission losses, security of supply and reliability of standby options are considered important criteria, in addition to any consideration of current and projected loadings. However, while it is considered correct not to allow (as described in the EIS) the loss of demand in Gweedore Business Park to justify sub-optimal reinforcement it is prudent to take account of the changed economic climate. This would appear to call into question the pre-2009 estimates of growth on which the EIS is based. Dealing with projected demand, the EIS does not give an estimate for a 2020 peak load in North West Donegal, but a 3% growth rate is referred to. If 2006 was taken as base year, that estimate would be of the order of 50% higher than currently or an additional 30 MVA approximately. The ratio of capacity to the anticipated demand being proposed to cover the security of supply aspect is high. It is therefore considered that the case for the network strengthening of the type proposed is not significantly weakened by what is possibly a much lower projected peak load. Government policy in relation to renewable energy and the targets adopted are a significant part of the requirement for the increased capacity in the network. The questions put at the oral hearing and the answers given confirm this fact. Although the proposers indicate that the need to provide for wind farm connections is not a primary reason for the scheme, given the doubt about demand projections, it would appear that there is greater importance in the area of need for the network to provide for connection to proposed wind farms. From Figure 3.2 at end of chapter 3 of the EIS there are approximately 12 existing connections to what is termed “renewables” with over 30 in gates 1,2,3 and “in queue”. In relation to wind farms and the reference made by objectors to the “polluter pays” principle, this is taken to mean that wind farm operators should fund the cost of


undergrounding of cables. This is considered to be a national economic policy issue and outside the remit of this assessment. The question of undergrounding versus overhead cables is assessed in this report based on environmental considerations, but with some reference to cost implications. The Alternative To Pylons Group engaged professor O’Carroll to prepare the part of their submission relating to need for the scheme and his report was referred to also by other objectors. Professor O’Carroll made six recommendations in his report of 24th January 2009 some of which had reference to a proposed 400 kV North-South interconnector and includes a hybrid distribution solution. While line lengths are lower, the options do involve considerable lengths of either 38kV or 110 kV lines. Specifically in recommendation 6 he states that should the wind farm connections be made publicly clear and he suggests retraction of the reasoning for the project invoking “urgent need” to meet local demand. Taken together with the questions put by professor O’ Carroll and other at the hearing and the submission made, it is considered that the applicants have established the need for the project but that the role of the project in meeting the needs of renewable energy generating sets is probably greater than indicated by them. Arising from the overall economic downturn the need and timing of the provision of the Tievebrack – Ardnagappary line in the short term may merit further consideration. B Configuration ( i ) Transmission The EIS describes the alternatives considered for transmission which relates essentially to the connection of the 110 kV station at Letterkenny to Binbane which is described as Option A. The EIS sets out the arguments for four options and notes the cost, efficiency and environmental ratings of each option. The chosen option appears to succeed generally in avoiding concentrations of population. It is noted that the EIS refers to the potential to “largely minimise environmental impact” and it is on this basis that further analysis is carried out under the headings of ecology and landscape and visual impacts. However, in relation to the consideration of alternatives the options are set out in detail in the EIS and the main reasons for choosing Option A are clearly set out. ( ii ) Distribution The factors involved in the choice of distribution solution would appear to be more complex than in the case of the transmission part of the line proposal. It is noted that the chosen Option (Option 4) is a tail-fed option. While Option 4 is listed as being chosen over the other 6 options described, the matrix provided in Table 3.3 does not appear to reflect the arguments put forward in the text in that the chosen option is shown as superior to all others in relation to 3 of the 4 chosen headings. Notwithstanding this observation it is considered that the main alternatives have been described and that the main reasons for choosing Option 4 are outlined.


6.2 LANDSCAPE AND VISUAL IMPACTS A detailed assessment is contained in Appendix 2A attached to this report. I concur with the assessment and the conclusions drawn by Mr Mc Grath in relation to landscape and visual impacts. A particular feature of parts of both proposed lines is the absence of treelines which would have a potential visually shielding effect on a transmission line. It is considered that a route for either the Letterkenny – Binbane connection or the Tievebrack – Ardnagappary lines could not be routed such as to avoid open areas of countryside. Clearly visual impacts are magnified when a transmission line breaks a skyline and given the nature of the topography, this is also difficult to avoid in all cases. The difference between pylons and polesets is noted and while a long length of 20 metre high double poles could never be described as attractive, the fact that they are constructed of natural materials and their very small footprint makes their visual impact considerably less than a line of pylons. It is noted that the photomontages produced appear to omit some views of installations or parts of installations which may have significant visual impacts. As such these photomontages do not appear to indicate a worst-case scenario as they appear to be confined rather narrowly to the specific locations mentioned in pre-application consultations with An Bord Pleanála. I concur with the assessment in Mr Mr Grath’s Report (Appendix 2A) which concludes that the impacts in relation to the Binbane - Letterkenny line are such as to be considered acceptable while those on the Ardnappary – Tievebrack line are, when considered cumulatively such as to warrant a recommendation to reject that part of the proposed development. In relation to the Letterkenny – Binbane line, Mr Mc Grath’s report divides the line into 17 separate sections for assessment, of which 7 are between Binbane and Tievebrack switching station and the remaining 10 are between Tievebrack and Letterkenny. His assessment indicates areas where he has reservations on the line. One of those is immediately north east of Glenties at Meenalargan (fig 4.8 EIS). It is noted that a variation reference LV5A was chosen after local consultation in this area. It is considered that while the line is higher up the slopes below Straboy Hill, views from the local roadway over the valley to the south west would be improved. In relation to the Ardnagappary – Tievebrack line, Mr Mc Grath’s assessment covers 10 separate sections. While not all sections are considered to have unacceptable visual impacts, there are serious concerns about the impacts in the vicinity of Grogan More, Crovehy and the area south of Lettercau. Concerns arise also from the possible combined or cumulative impact in the Gweebarra area arising from existing powerlines. The Applicants did refer to the possibility of rationalisation of lines but this was not detailed at the hearing. The four angle masts in close proximity (AM 52,58,62 and 64) are also of concern in that they tend to change the nature of the


proposal in that section from a predominantly double-pole proposal to one where pylons are more dominant. Considering the scale of the need as outlined for this line and being mindful of the rare breeding birds in the Crovehy area, it is considered that the Ardnappary – Tuievebrack line should be rejected on landscape and visual grounds. When recommending rejection, there is no clear alternative line and the consideration of alternatives was stated by the Applicant’s to have taken the previous rejection of the “2000” line into consideration. I would also be conscious that some alternatives may have been ruled out by the Applicants based on their view that more serious environmental impacts would result. 6.3 HEALTH EFFECTS OF THE PROPOSED DEVELOPMENT The assessment of health effects is given in Appendix 2B of this report. I concur with the conclusions of the assessment by Mr Mc Grath. His conclusions in section 1.4, 2.0 and 3.0 of that report are endorsed. The overall conclusion is that the issues raised by objectors in respect of health effects do not give grounds for rejection of the proposed Development 6.4 UNDERGROUNDING The assessment of the underground versus overhead options is given in Appendix 2C of this report. The conclusions in that appendix are endorsed. In addition it is noted that the EIS gives a ratio of 3.25 as the cost factor for average conditions as between underground cable (UGC) and overhead lines (OHL). There were a considerable number of questions at the hearing in relation to comparative costs and factors varied from 1.6 quoted by some objectors and a factor of 6 by the applicants. It is considered that an accurate cost comparison could not be undertaken unless a detailed design was carried out for both options and in that case the relative length of UGC would in all probability be substantially longer than the equivalent OHL. The cost difference would appear to be very significant as between UGC and OHL. This assessment relates to the environmental impacts of the proposal and therefore to the UGC alternative. It is clear that to get from Letterkenny to Binbane and from the general Tievebrack area to Gweedore cables would need to be laid in roadway and that in some instances it might be necessary to duplicate the cables for security of supply. If that were the case, the volume of excavation would be very significant and as many roads are in areas of peatland, there would appear to be potentially significant impacts on soils and water quality. The submission of An Taisce in their letter of 2nd February 2009 is noted in relation to undergrounding.


The submission by ATP refers to a 6 km section of underground cable between Newby and Nunthorpe in UK in 2001 which was stated to be undergrounded based on visual considerations. It is understood that the line in question is 400 kV and as such would be carried exclusively on pylons. 6.4 FLORA AND FAUNA The assessment on Flora and Fauna, together with an examination and assessment of the potential impact on designated areas is given in Appendix 2D of this Report. It is considered that as concluded by Mr Mc Grath that there would be slight adverse impact on blanket bog habitat and that the extent of habitat loss is not regarded as significant. Potential construction damage is noted and the recommendation to employ a project ecologist is made with the intention that mitigation measures be subject to close supervision in that regard. I concur with Mr Mc Grath in relation to his conclusion that there would be no likely significant adverse impacts on fauna. It is also considered that there would not be a significant impact on the integrity of any designated site, having regard to the conservation objectives of the sites. 6.6 SOILS ,GEOLOGY AND GROUNDWATER Mr Mitchell on behalf of the Applicant gave direct evidence on soils and hydrogeology. He noted the predominance of blanket peat and stated that groundwater vulnerability was high to extreme in many locations. He referred to the specialist AGEC peat Stability study carried out in early 2009. Dr Jennings took questions on the issue of peat depths and stability and Mr E.O’Connor referred to some construction modifications needed in specific cases. While some peat depths are in excess of 4 metres the opinion expressed by the Applicant’s construction witnesses was that satisfactory construction could be achieved out in all cases. While difficult conditions clearly exist in some cases, it is considered that the Applicant is capable of safely constructing the angle masts and the pole sets and those significant adverse effects on soils, geology and groundwater can be avoided with appropriate mitigation measures of the type proposed. 6.7 WATER QUALITY & FISHERIES The potential impacts on Water Quality are described in Section 8 of the EIS and direct evidence on Water Quality and Fisheries was given by Dr. Kavanagh at the hearing. The catchments traversed are the Oily, Owentocker, Owenea, Finn, Swilly and Foyle by the Binbane –Letterkenny line and the Owenea, Gweebarra, Owenmarve, Gweedore, Dungloe (coastal) and Clady by the Tievebrack – Ardnagappary line. The existing water quality varies considerably.


The questions raised at the hearing included reference to contamination by creosote, spillages during construction and damage due to bog slides. The submission by Mr Alan Keyes of Ballinderry Fish Hatcheries, Co Tyrone on behalf of the Rosses Anglers (day1 hearing) is noted and the questions to dr Kavanagh are also noted. The mitigation measures proposed generally relate to construction management and give a high priority to the avoidance of siltation which could be damaging to aquatic fauna with particular reference to freshwater pearl mussels. It is considered the mitigation measures are appropriate and the proposed development (both lines and substations) would not have significant impacts on water quality and fisheries. While it is not an issue to be taken into account in relation to proposals, the length of experience of the ESB organisation in relation to transmission line construction is noted in relation to their expected capacity to implement the mitigation measures correctly. 6.8 AIR AND CLIMATE With reference to the EIS and the evidence and questions at the hearing, it is considered that there would not be significant adverse effects during either the construction or operational phases of the development. It is noted that there would likely be some positive impacts arising from a reduction in thermal energy losses in the network. 6.9 NOISE The evidence given at the hearing expanded on that in the EIS and explained the impacts of improved technology in relation to power transmission which was stated to have the effect of reducing noise impacts. These are stated to arise from improved performance and efficiency of transformers and switching equipment and newer designs of insulators on transmission poles. Arising from the questions put to the applicants and the information already supplied, it is considered that the proposed development would not have significant noise impacts in the operational phase. With suitable mitigation, it is considered that short term or construction noise impacts would be acceptable. 6.10 MATERIAL ASSETS The EIS lists Landuse, Traffic, Tourism and Amenities, Air Navigation and Energy supply as sub-headings for this impact group. Traffic impacts are considered manageable and acceptable as the proposed development is not major in construction terms although construction management would be very important on the narrow roads which are abundant in the zone of the proposed routes. The conclusion in the EIS that the development would not result in adverse impacts on air navigation safety is accepted.


It is also accepted that the development would have positive effects on energy supply infrastructure, both from a capacity and reliability aspect. Tourism is noted as being a key sector for County Donegal. Amenities are listed in the EIS, and all are more than 1.5 km distant from the proposed lines. It is noted that the Letterkenny – Binbane line crosses Slí na Finne twice (near Meeniroy and Graffy) and also the Bluestack Way twice (Kilrean and near Binbane) while the Ardnagappery – Tievebrack line crosses Slí na Rossan six times near N56 / R252, east of Craghy Lough, near Meenamarragh and east of Cronaguiggy. The EIS does not specifically refer to any location but states the development (13.3.4) might tend to diminish the attractions of the area. The EIS states that the development would not result in significant adverse impacts on tourism and amenities. In this regard, the views of Fáilte Ireland are noted, including the view that visitor numbers would not be reduced. The assessment as regards tourism impacts is one of whether less tourists will visit Donegal as a result of the development and this is difficult to forecast. Large powerline structures are definitely both intrusive and unattractive. The extent to which it is possible to absorb a power line into a view is examined in the appendix dealing with Landscape impacts. The difference in impacts as between wooden pole-sets and steel lattice towers is noted. In relation to land use while the EIS rightly identifies the loss of forestry land as the largest impact by area it would appear that the perceived loss by landowners is the prevention of development or development opportunities coupled with devaluation of exiting property. Impacts of this nature certainly exist but must be balanced against the common good. The balance between common good and individual disadvantage is difficult to estimate. 6.11 SUBMISSION OF DONEGAL COUNTY COUNCIL The Council note and accept the Planning Report prepared in respect of the development. The proposal is acknowledged as being important to the County, as a pre-requisite for economic viability and growth. The Planning Report recommending the development is commended to the Board with the following additional comments:

1. The Board may wish to consider the provision of a community gain sum in recognition of the landscape impacts at two specific locations, Straboy and Gweedore.

2. The bond sum identified in the Planning Report should reflect the scale of development. A sum of €500,000 may therefore be appropriate.

3. There is a need to ensure that appropriate monitoring of works in the vicinity of the old Fintown dump be carried out.

Planning Report makes the following points: • Existing infrastructural deficiencies in the area and the need for the development

are identified, as well as the policy context for the development.


• Reference is made to the planning history and the inclusion of infrastructural power corridors in the County Development Plan.

• The Senior Executive Chemist notes the potential for impacts on water quality and aquatic species including the freshwater pearl mussel. The application does not provide specific details on protection / mitigation measures in this regard. A specific risk assessment for vulnerable areas and all mitigation measures should be detailed.

• The Council have identified two areas considered to be most visually sensitive: a) Between Crolly Village and west of Gweedore Post Office, where the line crosses the N56, and b) Northeast of Glenties, at Strahboy.

• In relation to the Crolly and Arduns area, the line generally avoids EHSA areas. • The EHSA area which is crossed contains dispersed rural housing, a quarry and an

existing 38Kv line. It is within the ZVI of a windfarm and is in proximity to Gweedore Business Park. The existing land use mix in this area enables satisfactory visual integration into the landscape.

• The route of the line at Straboy will be widely visible from the R250 to the south. Following local consultation the route was revised, over the hill, and would be more visually prominent than that originally proposed. The proposed route is not inconsistent with the infrastructural corridor set out in the development plan, however.

• The proposed development will not materially or significantly impact on protected views or prospects.

• NRA had no objection to the development in principle. • NRDO have no objection in principle, subject to road improvement works on N56

not being impacted on. • Roads and Transportation section recommend that a bond be put in place. • Water, Environment and Emergency Services Section note the proximity of the

proposed line to an old town dump site for Fintown. • Northern Fisheries Board recommends conditions in relation to consultation

regarding river and stream crossings and compliance with identified mitigation measures.

• The application has no impact on property of Waterways Ireland. The report concludes that the development is consistent with the local, regional and national policy framework. The development will have some landscape impacts, with two visually sensitive areas identified. Taken in context, however, the impact is limited. Previous reasons for refusal have been addressed and the routes are consistent with the infrastructure corridors identified in the Development Plan. Having regard to the need to strengthen infrastructure in the region and the policy context, the County Council recommend that the Board consider the development favourably. 8 no. conditions are recommended for attachment to any decision to grant permission for the proposed development. It is noted that at the Oral Hearing, the planning authority had no further material comments to add to the written submission already made to the Board. 6.12 Submissions from Individual Objectors / Aighneachtaí ó dhuiní éagsúla


6.12.1 Aighneacht ó Tomás Ó Monacháin, Gaoth Dobhair (uimhir 49) Chuir and t-uasal Ó Monacháin aighneacht isteach in éadan an tionscadail agus go h-áirithe in eadan an líne idir Ard na gCeapairí agus An Taobh Breac. D’iaffraigh and t-uasal ÓMonacháin ar na hiarratheoirí mar gheall ar túr uileach uimhir ST13. Tá sé tuigthe gur féidir cuallí adhmaid snaidhmthe a cur ina h-áit. Cuir an t-uasal Ó Monacháin ceisteanna a bhí ag baint leis an fó staisiún Ard na gCeapairí agus thug an BSL tuile eolas agus learscáil a léirigh é sin. Níl sé soiléar an bfeadfar in ann coinneal a chur isteach go mbeadh Cuaillí admaid snaidhmthe in ionad túr uileach uimhir ST13. An t-uasal Ó Monacháin objected to the line between Ardnagappary and Tievebrack. In particular Angle Mast ST13 was of concern to him and he said it was understood that braced pole sets could be used in substitution. It is possible that under some circumstances a condition could be imposed which would achieve this objective but this is not clear at present. An t-uasal Ó Monacháin also received clarification in regard to layout and extent of the proposed substation at Ardnagappary. 6.12.2 Aighneacht ó Rónán Mac Aodh Bhuí, Cois Claidí, Bunbeag (uimhir 46) Bhí aighneacht scríofa curtha isteach ag an t-uasal Mac Aodh Bhuí agus leabh sé an aigneacht isteach sa taifeadh ar an tríu lá den éisteacht ó bhéal. (aighneacht glacha ag an mBord ar 30/01/2009). Tá cónaí aige agus a theaghlach trasna an bhealaigh ón fhostáisíun Ard na gCeapaire atá beartaithe. Na habhair a luaigh sé ná contúirt galair agus tioncar ar cúrsaí turaséoireachta. Go háirithe cáin sé an droch tioncair a bheas ar cúrsaí tírdreach agus an radharc a bheadh aige fhéin gach lá ón a theach i dtreo Sliabh Errigal. D’iarr sé go gcuirfí an líne faoi thalamh agus nach ligfidh an Bord Plaanála den iarrtas dul ar agaidh. Tá plé deánta ar na habhair ins an tuarisc seo faoi Shláinte agus Tírdreach. An t-uasal Mac Aodh Bhuí stated he lived in close proximity to the proposed Ardnagappary substations. He listed health effects and tourism and landscape impacts in support of his objection. Specifically he referred to the view he would have of Errigal and recommended undergrounding of the line. 6.12.3 Aigneacht ó Gearóid Ó Maonaigh ar son a theaghlaigh. (lá 5 Éisteacht ó bhéal) Dúirt an t-uasal Ó Maonaigh go raibh a theach 200 meadar ón structúr. Dúirt sé nár labhair and BSL leis mar gheall ar an forbairt. Luaigh sé imbuillí ar radharchanna, truallú ó PCB’s agus dainséar ón trácht ag an fóstáisiún. Dúírt sé freisin go raimh an t-éilimh leictreachais níos ísle ná mar a bhí sé i 2001. An t-Uasal Ó Maonaigh stated he lived 200 metres from the proposed structure. He said ESB had not consulted locally and listed impacts on views and pollution from PCB’s as grounds for his objection and made specific reference to traffic difficulties at the entrance to the substation (Ardnagappary). He noted demand for electricity was less than it had been in 2001. 6.12.4 Aighneacht ó Síle Ní Gallachóir (Lá 5, Éisteacht Ó Bhéal)


Chuir an aigneacht seo ceist ar an gá le line 110 kV a thabhairt go Gaoth Dobhair nuair a thit an éileamh sa cheantar 23.5%. Luaigh an aighneacht dochar don Timpeallacht agus do cursaí turasóireacht. Ceistigh an aigneacht caighdeán an RTT agus thugadh tuairim mar gheall ar dí-luacháil tithe agus dainséar do shláinte. Tá roinnt griangrafanna iniata leis an aigneacht. Ms Ní Gallachóir questioned the need for the scheme in the light of large reduction in demand. She listed the damage to the environment, health dangers, devaluation of houses and tourism impacts in support of her objection. A number of photographs were included with the submission. 6.12.5 Objection of Patricia and Keith Mackinson (objection reference 33) Location is on the proposed Arnagappary – Tievebrack line. The objection notes that Lettercau and Ardmeen are relatively free of ‘bungalow blight’ The objection states Donegal County Council planning principles are not met by the line through Lettercau. Mr Mackinson asked a number of questions at the hearing including questions on undergrounding and made a submission noting that there was a ‘crank’ in the line in the area of Lettercau and involved four changes of direction around Lough Anure which is unjustifiable. He submitted that there was no architectural or landscape involvement in the route selection or design of structures. 6.12.6 Objection of Eileen and Eoghan Mc Cole, Stranarva, Crolly (Objection ref 28) The location is on the Ardnagappary – Tievebrack Line in the area of Meencorwick which is south of Crolly. Ms Mc Cole drew attention to the absence of the record of some houses on the maps submitted. The Applicants submitted revised maps indicating houses not included in the original drawings. Ms Mc Cole asked questions on a number of issues including health and visual impacts and the buildability of the development. Her submission commenced with reference to health concerns, in particular referring to the potential impact on children’s health. Photographs were attached to the submission. Specifically, it was submitted that there was a failure to consider protected views, particularly from the N56 across Lough Anure. 6.12.7 Objection of Madge Mc Cole, Stranarva, Crolly (representing also Thomas and John Mc Cole) - Objection reference 28 Ms Mc Cole asked questions of the Applicant on a number of issues during the hearing. In her submission, she referred to health impacts stating that at 200 metres from a HV line there was a 69% increase in childhood leukaemia. She noted that angle mast ST52 was in Mc Cole land and that there were three parcels of land affected. Her own plans were to build a house on her land which would be 165 metres from the proposed line. The submission also referred to visual amenity, potential contamination, misleading information being supplied by applicant and to devaluation. The health issues are addressed elsewhere in this report.


6.12.8 Objection of Joan Hanlon, Tullyard, Glenties (Ref 42, submission on day 5 hearing) Ms Hanlon asked questions of the proposers in relation to many aspects of the proposals. Specifically on landscape the proposers identified the Tullyard area as being of high quality and sensitivity, while stating that the Hanlon house was 260 metres distant from the proposed Letterkenny – Binbane line (day 3 hearing). Questions were asked in relation to quaking bog and the applicants stated that they had identified only one area of quaking bog but had not had access to a number of proposed pole-set locations in the Tullyard area. The submission made augments the written submission made prior to the hearing which includes a number of photographs. It is noted that Mrs. Hanlon regards the maps supplied by the proposers during the hearing as inadequate. The issues raised in the submission are summarised in the report on the oral hearing. The issues are addressed under the various headings. 6.12.9 Objection of Louis Hanlon, Tullyard, Glenties (ref 42, day 5 hearing) Mr Hanlon included a number of articles, letters and photographs with his submission. In addition to points raised by other objectors he stated that areas of blanket bog on his land would not support either animals or persons walking over it. He specifically referred to interference with views from his residence of and towards Lough Ananima. 6.12.10 Objection of John Rodgers, Bunawack, Crolly (ref 23 and 37) Mr Rodgers submission referred to inaccurate and misleading information and he had special objection to Angle mast No 52 which is close to houses reference 192 and 193. He disagreed with the Landscape and Visual assessment of the proposers and referred also to views over Loughanure from the N56 to the East and South. He included a number of photographs with his submission. (see submission tabbed ‘R’ in

observers’ file) 6.12.11 Objection on behalf of Gweebarra Conservation Group and Alternatives to Pylons presented by Ms Patricia Sharkey (ref 41) Ms Sharkey (day 5) made a presentation accompanied by a number of slides. It was submitted that the line from Binbane to Gweedore was substantially the same as that put forward in 2000 and that there was no satisfactory map indicating the relative positions of the existing 38kV and proposed 110 kV lines. Ms Sharkey described the proposals as overkill as regards capacity and said that this had been established at the 2000 oral hearing. The submission also covered landscape and ecological impacts, health issues, archaeology and undergrounding.(It is tabbed ‘S’ on the observers’ file) 6.12.12 Objection of Una Sweeney & others Lettercau, Crolly Ms Sweeney made her submission on Day 5 of the hearing. She noted having considerable difficulty accessing information from the documentation supplied. Angle Mast AM58 was the main structure of which Ms Sweeney had complaint but noted also Structures 52, 62 and 64 which were in close proximity and represented 4 of the 18 angle Masts proposed for the Ardnagappary – Tievebrack Line. Ms Sweeney


appended two photographs indicating view towards the line in the vicinity of AM62-64 and in the region of polests 67-73 approximately. These photographs indicate an area which does not have trees or hedgerows and are of an area in which any line or structure would be very exposed. Ms Sweeney’s submission is tabbed “UV” in the Observers’ file. 6.12.13 Objection of Ms Millar, ATP (Alternatives to Pylons) Ms Millar made a submission on day 5 of the hearing and attached a number of documents. Specific to the submission was particular reference to a Preliminary Report of the European Parliament on “preoccupations concerning the effects on human health of electromagnetic fields” It is of note that this report is dated 19 Dec 2008 and calls for actions by the EU Commission and others. Ms Millar referred particularly to what she saw as the difference between what is complying with standards and what is the right thing to do. She stressed the perceived fear and anxiety of people in relation to with electromagnetic fields and their potential impacts and gave examples of where scientists had been wrong in the past. Ms Millar’s submission including other documents is tabbed JK on the Observers’ file. 6.12.14 Submission of Liam Millar Mr Millar (day 5) submitted that the development was to facilitate windfarm development and it had already caused stress to people. His submission is tabbed W on the observers file. 6.12.15 Submission of Ralph Sheppard on behalf of ATP Mr Sheppard made his submission on day 5 of the hearing and his written submission is tabbed HI in the Observers file. The written submission contains a number of aerial photographs, some of which have the line of the proposed line superimposed. Mr Sheppard referred in detail to habitats and highlighted similarities between habitats only some of which were designated. He referred particularly to Crockmeenleckanore(Ardnagappary line north of Gweebarra), Cloghercor (south of Gweebarra), Kilreen (near Glenties) and Crovehy (east of Dungloe –relevant also to a rare bird species). Mr Sheppard set out in detail some of the problems and issues relating to choices and options and gives his analysis of some of the questions and answers given at the hearing. Of note is his reference to the application of 2000 and the possible reasons for the current choice of line arising out of the decision in that case. Mr Sheppard’s conclusion (if a line is to be built) would favour undergrounding of particular stretches.

6.12.16 Submission of Charles Swingler (on behalf of Patrick Boyle and

others) Mr Swingler made a submission (tabbed ‘E’, day 3 of hearing) regarding possible alterations to the landscaping and entrance details for the proposed Tievebrack Switching station. The submission dealt with landscape and visual impacts and related also to the evidence given by the applicants in their submsions. It was submitted that there was an inappropriate choice of tree species and proposed changes to the station layout were put forward. The submission was illustrated by slides. 6.12.17 Submission of Professor O’Carroll on behalf of ATP (Alternatives

to pylons)


Professor O’Carroll asked questions in the course of the hearing and made submission on day 4. He listed his qualifications and background and described his role as he saw it to raise questions and make suggestions to help An Bord Pleanála. The submission dealt with possible options and alternative line solutions including hybrid 110kV / 38kV configurations. Specifically it was submitted that if wind-farms presented an over-riding need for the proposal, this should be made clear publicly. Reference was also made in the submission to health effects of the overhead line proposal. Additional comments were made by Professor O’Carroll and submitted by Mr Gillespie on Day 5 of the hearing further to the original submission and the questions that mere put arising from it. Health effects were raised, with particular reference to the SAGE (Stakeholder Advisory Group on ELF EMF’s) and it’s consideration of ranges of diseases. 6.12.18 Submission of Mr Gillespie on behalf of ATP, Coisde Timpeallacht Gaoth Dobhair, Rosses Anglers Associateion and John Boyle Mr Gillespie submitted that project was of a massive scale in terms of its impact. He submitted that the “land-take” was over 10 million square metres or over 1,000 hectares when the true corridor effects were taken into account. He submitted that the project would entail the taking of people’s land against their wishes when a feasible (underground) alternative was available. Submitted also that the proposed development would create huge over- provision of capacity. Mr Gillespie listed 10 areas of likely significant impacts covering landscape, fisheries, ecology, human health , dangers to people and birds , archaeology and loss of residential amenity. Mr Gillespie submitted that in relation to European sites, that permission should only be granted for reasons of over-riding public interest where there was an absence of alternative solutions.. He disagreed with the test of alternatives adopted by the ESB. Mr Gillespie disagreed with the cost estimates and comparisons between OHL and Underground Cable. He suggested UGC as costing €52.8 m as against €33m for OHL. Mr Gillespie referred to heavy financial costs incurred in a previous hearing and he wished to seek an award of costs under Section 145 of the Planning and Development Act 2000 as substitiuted by Section 28 of the 2000 Planning (Strategic Infrastructure ) Act. 6.12.19 Submission of Ms Kathleen Coyle, Binbane, (Day 4) Ms Coyle made a submission on Day 4 of the hearing to supplement her written submission made prior to the hearing. She pointed out that the line chosen, on leaving Binbane substation cross the only land suitable for development for the construction of a house for a family member and said that the ESB had refused to divert the route. 6.12.20 Submission by An Taisce Submission was made by Ms Elizabeth Muldowney, energy officer of An Taisce on Day 5 of the hearing and referred to the original written submission. Points made in the submission to the hearing included the requirement for a review of Gate 3 licence applications should be conducted to demonstrate suitability. A conclusion was that there is a need for the project but recommended that partial under-grounding be considered


6.12.21 Submission by Mr Eddie O Donnell (day 5) Mr O’Donnell submitted that line should go to Burtonport, across old railway line with underground to Arduns. Under-grounding should be re-considered Individual objections have been addressed under the main assessment chapters and appendices.


7.0 CONCLUSION

7.1 Introduction and Format.

Individual reports and assessments on Landscape and Visual Impacts, Undergrounding, Flora and Fauna with reference to designated areas and Health Issues were compiled by Conor Mc Grath, Senior Inspector with the Board.These reports are included as Appendices 2A -D and a report on the Planning Context is in Appendix 2E

7.2 Overall Assessment: The need for the overall strengthening of the Transmission Network from Letterkenny to Binbane as presented by EirGrid is considered to be established. The logic of the tail-fed option (no.4) for the Distribution Network as outlined by ESB Networks is accepted but the scale of the economic downturn on the area suggests that there may be some prematurity regarding the immediate need for the line from Tievebrack to Ardnagappary (Gweedore). When taken in conjunction with the reservations regarding other impacts, a re-evaluation of the timing of the Tievebrack -Ardnagappary line may be appropriate. The option of undergrounding all cables is not considered to be correct based on environmental grounds with particular reference to impacts on soils, water quality and habitats. Overall reliability is also considered to be inferior and a 3-day outage in South London in July 2009 was attributed (electricity provider’s website, EDF) to vandalism to underground cables. The evidence of the Applicants is accepted in relation to the impracticality of undergrounding short lengths of 110 kV cable at intermediate points. Impacts on soils, water quality, fisheries, air, climate and noise impacts are considered acceptable provided the mitigation measures proposed are carried out. The appointment of a project ecologist, with duties and responsibilities similar to that of a project archaeologist is beneficial from a flora and fauna perspective but is also of benefit for soil related impacts. Impacts on Flora and fauna are considered in conjunction with designated areas. The overall conclusion is that habitat loss would not be significant and that with mitigation as proposed, there would not be significant impact on designated sites and that the integrity of the sites would not be affected. The reservation in relation to the rare bird species at Crovehy, (Breeding ground), is one of requiring more certainty and this could be addressed in the event of a refusal of the Ardnagappary – Tievebrack line. The proposal by the Applicants to appoint a project ecologist is considered appropriate. Most of the issues raised in relation to health effects could apply to any overhead high voltage power transmission line in any part of the country and it is considered that as the proposal appears to comply with recognised industry and national standards, potential health effects are dealt with satisfactorily by the applicants. As pointed out by one of the objectors in relation to a previous report, to observe and hear concerns regarding potential health effects first hand at a hearing is necessary to


appreciate the fears and anxiety of those voicing their concerns. A further factor, namely that of having a power line placed close to a house rather than having the choice of building a house close to a power line is relevant to the people living in the area. There is a resonance in some ways with the situation regarding noise and visual impact in respect of new road construction. The distinction between doing what is right and what is legal is noted in this regard. Overall, it is considered that the issues raised in relation to health concerns do not give grounds for rejection of the proposed Development. The assessment in relation to Landscape and Visual impacts notes the difference in impacts as between wooden polesets and pylons and of particular note here are the four pylons in the general area of Lettercau in a landscape area which does not have vegetation of a height which could help to screen the visual impact. The conclusion is that the Binbane- Letterkenny line is acceptable from a landscape and visual aspect as the extent of the visual impacts are not significant in the context of a 68 km line length and the line in the sensitive areas is predominantly comprised of wooden polesets. The conclusion in respect of the Ardnagappary – Tievebrack line is that there are significant visual impacts at a number of locations and these are compounded by having a number of pylons at sensitive locations. The recommendation therefore is that approval should be confined to the Binbane- Letterkenny line and that further examination should take place in relation to the connection between Tievebrack and Ardnagappary. In making this recommendation, it is recognised that for part of that line at least there would then be two rejected routes and the potential for finding an alternative or third line would be severely limited by a rejection of the current proposal. However, it is considered that it would not be possible to devise suitable conditions in relation to the proposed Ardnagappary – Tievebrack line to mitigate the adverse effects without altering the proposal as it exists to the extent that a new EIA would not be required. The request by the Applicant for inclusion of a condition relating to the possible re-location of individual support structures which would involve prior agreement with the Planning Authority is not considered practical as no margin for alterations is proposed or defined. It is considered that the provisions of the Planning and Development Act {amendment Section 146A as per Section 30 of the Planning and Development (Strategic Infrastructure) Act 2006} in relation to modifications to permissions would be relevant in this instance. In their submission Donegal County Council suggest a number of conditions which should attach to any permission. Having examined these, it is considered that as the project is one which the stated aim is to improve the reliability of the power supply, then the concept of a condition relating to community gain does not appear appropriate. However, recommended condition No 8 relating to damage to county roads is considered appropriate in principle.


7.3 Achoimre as Gaeilge 7.4 Leagan Amach Tá tuairiscí deanta ag an cigire Mac Craith mar gheall ar measúnacht ar an Tírdhreacht, Écólaíocht, Tioncair Shláinte agus ceist na línte a chur faoi thalamh in ionad iad a beith crochta. Feach ar Aguisín 2A –2E. 7.5 Measúnacht Iomláin Meastar go bfhuil sé cruthaithe go bhfuil gá le líne nua tarchuir110 kV idir Leitir Cheanainn agus na Binne Báine. Is é EirGrid (TSO) an tOibreoir Córais Tarchuir atá freagrach i dtaobh an líne seo. Mar gheall ar an líne dáilleadh ceaptar go bfhuil gá leis an líne atá beartaithe ag ESB Networks mar DSO ach de bharr go bhfuil cúrsaí geilleagrach imithe chon donas sa mblian 2009, tá ceist ann faoin gá atá ann láithreach don líne idir An Taobh Breac agus Ard na gCeapaire. Tiosc go bhfuil deachrachtaí mar gheall ar Tírdheach ag baint leis an line seo, bféidir go gcuifí súil ar clár tógála an líne. Meastar nach mbeadh sé ceart na línte a chuir faoi thalamh tríd na gortanna mar go mbeadh droch -tioncair ar éicólaíocht, agus go mór mhór ar na portaigh agus caillíocht uisce. Glachtar le fiannaise an t-Iarratheoire nach bfhuil sé praiticiúil píosáí idirméanacha den líne a chuir faoi thalamh. Meastar go mbeadh na línte crochta níos iontaobhach ná línte faoi thalamh. Meastar go mbeadh leibhéal tioncair inghlachta I gcás itreacha, cáillíocht uisce, iascach, aer, aeráid agus torann má gcuirfear an maolú atá luaithe i bfeidhm. Meastar go mbeadh buntáistí ar fail ó fhostú Éicólaí speisialta don tionscadal, ní hamáin ag baint le flora agus fauna ach le tioncar itreacha ina theannta. Ní ceaptar go mbeadh cailliúnt gnáthóiga suntasach ag baint leis an tionsacadal. An conclúid atá ann ná nach mbeadh tionchar suntasach ar na suímh ainmithe agus le maolú nach mbeadh tioncar ar shláine na suímh ainmithe. Mar gheall ar an suíomh ghoir don éin neamhchoitianta gar do Cró Bheithe ceaptar gur féidir níos mó eolais a bailiú chun a bheith níos cinnte ina thaobh. Bheadh baint le líne crochta leictreachais in aon áit sa tír le tionchair leaghais. Meastar go gcómhlaíonn an tionscadal le caighdeáin an tionscal leictreachais agus caighdeáin náisiúnta. Dá bhrí sin meastat go bfhuil na haighneachtaí mar gheall ar cúrsaí shláinte freagartha go sásúil. Aithníothar nach bfhuil sé mar an cheanna in aigne daoine cinne a dhéanamh teach a thógaint in aice le líne crochta leicreachais agus beith ina gcónaí cheana fhéín san áit agus líne nua a thógáil congarach do tithe. Meastar nach dtugann na haighneactaí mar gheall ar dochair don shláinte cúis chun diúltiú leis an fhorbairt atá beartaithe. I rith an measúnach ar tírdhreach (Agusín 2A) tá an diffríocht idir cuaillí amhaid agus túir uilleacha curtha san áireamh. Tá an tionchar ar tírdreacht thart ar Leitir


Catha ag éirí de bharr ceithre túir uilleacha atá i gceanntar nach bfhuil dothain crainn ann chun an radharc atá ann faoi láthair a chosaint. Meastar go bhfuil an tionchar ón líne idir Leitir Ceanainn agus na Binne Báine ( Binn Bán ) inglachta o thaobh tírdhreacht de tiosc nach meastar go bfhuil na tinchair suntasach nuair a tugtar san áireamh go bfhuil an líne 68 km ar fhad. Tugtar faoi ndeara gur cuaillí go mór mhór atá in sna limistéar íogair comhshaoil atá congarach don líne. Sé an conclúid mar gheall ar an líne idir Ard na gCeapaire agus an Taobh Breac ná go bfhuil droch-tionchair suntasacha o thaobh tírdreach in áiteanna éagsúla agus go bfhuil na tionchair seo níos measa tiosc gur túir cruacha atá I gceist ins na limistéar íogair comhshaoil. Sé an moladh ná gur ceart ath-scrúdú a dheanamh ar an líne idir Ard na gCeapaire agus an Taobh Breac agus gur ceart cead teoranta a tabhairt don tioscadal a baineann don line idir Leitir Ceanainn agus na Binne Báine amhain. Aithnítear go mbeadh deacrachtaí faoi leith ag baint le bealach malartach a fháil don líne idir Ard na gCeapaire agus an Taobh Breac más rud é go mbeadh cead diúltithe cheana féin le dhá bealaí. Meastar nár féidir coinníollacha a mholadh a dtabhairfidh máolú inglachta ar na droch-tionchair a baineann leis an líne Ard na gCeapaire – an Taobh Breac atá beartaithe, gan Measúnú Tionchar ar an Comhshaoil nua a dhéanamh. (Ciallíon sé sinn go mbeadh gá le RTT nua a fhoilsiú). In a chuid aighneacht tá roinnt moltaí ó Chomhairle Chondae Dún na Gall. Meastar, mar gur aidhm an tionscadal feabhas a chur ar gréasán solathair leictreachais nach mbheadh coinníoll cuí a bhéas ag baint le tairbhe don pobail. Tá moladh do coinníoll ag baint le damáiste do bothair iniata ins na moltaí sa tuairisc seo.


8.0 RECOMMENDATION Having regard to:

• The National Development Plan 2007 – 2013 • The National Spatial Strategy 2002 – 2020 • Donegal County Development Plan 2006 – 2012 • Government White Paper “Delivering a Sustainable Energy Future for Ireland

– The energy Policy Framework 2007 – 2020 • The Environmental Impact Statement and the mitigation measures set out

therein.

It is considered that, subject to compliance with the conditions set out below, that approval should be given for the Development proposed which omits the proposed 110 kV line from Ardnagappary to the proposed switching station at Tievebrack. It is considered that the need for a future line has been established and it is therefore recommended that approval be granted for the switching station at Tievebrack, although the station would not function as a switching station until such time as a line northwards was approved. The recommended approval therefore is for the 68 km overhead 110 kV line from Letterkenny to Binbane to include the proposed switching station at Tievebrack and all necessary works at Letterkenny and Binbane substations. That the approval for the development shall be confined to the following elements of :

i. New 110 kV Line Bay at Letterkenny 110 kV substation ii. New 110 kV Overhead electricity transmission line from

Letterkenny substation to Binbane substation iii. Switching Station at Straboy townland described as the

Tievebrack Swiitching Station. For clarity, this recommendation is for rejection of the proposed 110 kV line from Tievebrack to Ardnagappary

2. That a project ecologist be appointed for the duration of the construction

period. A protocol shall be drawn up with NPWS to establish inspection and monitoring procedures.

Reason: To ensure mitigation measures in relation to preservation of habitats are carried out

3. That a project archaeologist be appointed for the duration of the construction period.

Reason: To ensure appropriate archaeological monitoring and preservation of archaeological heritage takes place.


4. Development shall incorporate all mitigation measures outlined in the

Environmental Impact Statement. A document outlining all mitigation measures to be submitted to the Planning Authority and made available for inspection at the offices of the Planning Authority

Reason: To mitigate potential impacts of the proposed development.

5. A survey of the condition of all local roads (i.e those below the classification of National or Regional Roads) used in the course of construction shall be undertaken before and after the construction of the development. The Applicant shall provide security the level and nature of which is to be agreed with the Roads Authority prior to the commencement of development.

Reason: In the interests of road safety and to maintain the integrity of the local road system.

6. Works in the vicinity of rivers and streams shall comply with the Guidance document published by the Northwestern Regional Fisheries Board.

Reason: In the interests of protecting aquatic ecology.

REASON FOR REFUSAL OF ARDNAGAPPARY - TIEVEBRACK LINE : Reasons and Considerations: The proposed 110kV distribution line between Ardnagappary and the proposed Tievebrack Switching Station should be for refused on the grounds of unacceptable negative impacts on visual amenity in the area traversed by the proposed line. The proposed substation and associated works at Ardnagappary should be refused as the line leading to the proposed substation is recommended for refusal. _______________________

Daniel O ‘ Connor Engineer Gd I September 2009


APPENDIX 1: ORAL HEARING REPORT: The Hearing commenced Tuesday 31/03/09 and lasted for five days, finishing on Monday, April 6th. The attached recording of the hearing is labelled with the time and date of each speaker noted. I refer to these times in my description of the hearing below, in order to aid the board. Applicant’s Presentation to the Hearing: Following the introduction, the applicants provided a brief description of the development. Fifteen witnesses were provided: • William Mongey (WM) ESBI Project overview. • Mark Norton (MN) (EIRGRID): Needs • David Byrne (DB) (ESB Networks): Needs • Roisin O’Donovan (RO’D): Planning context and EIS • William Mongey (WM): Route selection • Eddie O’Connor (EO’C): Construction and peat • Jim Fitzpatrick (JF): Flooding. • Raymond Holbeach (RH): Landscape • John Cronin (JC): Archaeology • James McCrorry (JMcC): Ecology • Seamus Fay (SF): Land use • Paddy Kavanagh (PK): Surface waters • Niall Mitchell (NM): Soils Geology etc. • Eugene McKeown (EMcK): Noise • Aidan Geoghegan (AG): Underground versus overhead lines,

including health and safety. • Dr. William Baily (WB): Electromagnetic fields EMF • John Gartland (JG) Electromagnetic fields EMF • Roisin O’Doovan (RO’D): Material assets and air quality. Each witness on behalf of the applicants presented a written précis of evidence to the hearing. Copies of these are attached herewith. Included in each witnesses presentation is a review of the issues raised by observes and responses thereto. 10.23am William Mongey introduction and overview of the project. 10.40am-11.25 Mark Norton – Transmission network need. Break 11.25-11.53am 11.55 Tomas O’Monachain raised issues with the treatment of the Irish language in

notices on maps submitted to the hearing. He also indicated that the translation was not accurate.

11.57 David Byrne – Distribution network need for project as proposed. 12.35 Roisin O’Donovan: Planning Context.


13:00 Break for lunch, with brief camera work on behalf of TG4. 14:18 Resumption after lunch. 14:19 Sonia Ni’Loughlin, Udaras na Gaeltachta 14.25 Roisin O’Donovan resumes. 14.49 Mary Stack, Failte Ireland.

As Ms. Stack was not to be in attendance for the remainder of the hearing, observers put a number of questions to her at this time. DO’C queried what Failte Ireland mean by “negative landscape impacts might be explored” as a mitigation measure. MS elaborated in meaning remove from N56, the recognised tourist route in Donegal, and walking routes. In response to questions from Gillespie for ATP, MS clarified that not felt that the proposal would affect visitor numbers to the area.

15:06 William Mongey, Route selection.

Mr. Mongey addressed a number of submissions from specific observers in relation to the routing of the line. Other issues addressed included adequacy of mapping and use of Bird Flight Diverters.

A number of the submissions responded to by Mr. Mongey, were in Irish and DO’C requested that copies of the responses be provided in Irish by the applicants. Mr. Gillespie requested that his witness, for the Rosses fisheries in relation to the Freshwater Pearl Mussel, be taken, due to difficulties in attending later in the week. DO’C agreed to take the witness after Mr. Eddie O’Connor.

15:54 Eddie O’Connor (Civil construction works) with comments by Dr. Jennings

regarding peat stability. 16:42 Observers: Submission from Alan Keyes, Ballinderry Fish Hatcheries,

specific submissions regarding Freshwater Pearl Mussel. This submission was taken out of sequence to facilitate attendance by the witness.

Resumption with Applicant’s submissions. 17:02 Jim Fitzpatrick, Traffic and Flooding 17:16 Ray Holbeach, Landscape and Visual Impact. 17:50 Tomas O’Monachain made observations of the visual impact of the crossing

of the N56 at Arduns, particularly on views of Errigle. 17:56 Seamus Fay: Land use The AGEC report on peat stability made was available for inspection and review. 18:11 John Cronin, Cultural Heritage Day 1 closed at 18.20.


Day 2: 01/04/09 10am. 10.01 James McCrory Flora and Fauna. Error in EIS page 7.27/33 identified. This should refer to the loss of 4.95ha of

blanket bog. Tree loss identified on page 7.26/33 may be avoided through use of alternative structures.

10.34 Niall Mitchell (RPS) Soils, Geology and Hydrogeology NM identified an error in section 9.1.6.2 of the EIS, which identified the bedrock units under the Ardnagappery – Tievebrack route as a locally important. This is actually poorly productive, as classified by GIS. A peat stability study was undertaken along route of the proposed line. Creosote: A Preservative, not typically soluble in water. EU Directive 2001/90/C indicates that the health impacts are likely to be low in industrial applications. No measurable impacts on aquatic organisms. US EPA considered the impacts and determined, subject to mitigation measures, would not present significant risk of water contamination.

10:50 Dr. Paddy Kavanagh, Water Quality and Fisheries. PK noted that since the EIS was prepared, the River Basin Management Plan for the northwest region has been published and should therefore be included. The DoEHLG have also published draft regulations for the protection of the Freshwater Pearl Mussel (FPM). These require sub-basin catchment plans to be prepared. The EIS takes account of these subsequent publications in the mitigation measures proposed. An ecologist present during construction.

11:40 Eugene McKeown, Noise Heavy 110kV cables are not conducive to aeolian noise. 11:58 Aidan Geoghegan, Underground Cable in comparison with Overhead Line 13:06 Observer’s submission from Seamus O’Connell – IBEC in support of the

project. This submission was taken out of sequence to facilitate attendance by witnesses.

Lunch 14:15 William Baily, Electric and Magnetic Fields 15:15 Roisin O’Donovan, Air and Climate, Material Assets.

RO’D noted one error in the EIS, in that the route does cross one fishing beat on the Owenea River.


CROSS-QUESTIONING On conclusion of the applicant’s presentations, questions were put to the witnesses by the Inspectors and observers. Witnesses were grouped by topic where appropriate. WITNESSES: Mark Norton, William Mongey, David Byrne, Aidan

Geoghegan Questions from Inspector: 16:13 MN confirmed that by 2010, in the event of the failure of one of the existing

110kV lines to Letterkenny failing, the remaining line would not be of sufficient capacity to meet minimum criteria. By 2015, there would be a network collapse.

16:14 MN clarified the nature of restrictions on use of the existing NI interconnector at Letterkenny. It would link two weak systems together, placing both at risk of collapse in the event of a failure in the networks. Would apply a risk to the networks. In their 7-year statement from 2006 for NI, the Sysetm operator note severe restrictions on demand and generation without reinforcement on the network. There are no firm proposals for reinforcement.

16:16 Upgrade of one 110kV Letterkenny line to 220kV, would not address problem. It would require the upgrade of both sets. Even in the event of increased interconnection, a reinforcement of the nature proposed would still be required.

16:19 MN confirmed that TSO obliged to accommodate renewable generators if directed by CER. DB confirmed that both lines would facilitate the acceptance of more renewable energy into the system.

16:21 DB noted that growth in demand in the western area, despite decline in industry in Derrybeg, was due to natural growth, both residential and commercial, but also growth in consumption, which offsets any decline in demand at Gweedore.

16:22 WM clarified that B-L line would use earthwire structures while A-T line would use earthwire lines at start (1.8km) and end of the line (4.7km).

Existing more modern 38kV lines use single poles. Older design (1960/70’s) used portal structures.

16:24 DB confirmed that the development would not result in any redundancy of existing 38kV lines.

DB noted that there may be opportunities to underground sections of the 38kV network in sensitive areas. This could also apply to 10 and 20kV lines. No detailed examination to date, but consideration given to this on the approaches to Ardnagappery Sub-station. Not proposed to use existing pole structures to carry other voltage line. Line would be retired and undergrounded. MV and HC lines are not strung on the same pole due to technical requirements. WM noted that minimum separation between 38 and 110kV lines would be approx. 30-50m apart, depending on length of paralleling.

16:29 AG advised that longest stretch of AC cable in Ireland is approx. 20k in Dublin City of 220kV cable. Distances required in Donegal would be exceptional.

38kV line may be subject to greater weather damage than 110kV lines.


16:32 AG describes process for fault identification on UGC, which can take many days.

16:34 Applicants requested to clarify the corridor of the application 16:37 Questions from Michael Gillespie (MG) (ATP, Coiste Timeallacht Gaoth

Dobhir, Rosses Anglers Association and John Boyle):

MN noted that there has been a thermal upgrade of part of the 110kV lines to Letterkenny. DB noted that there was a new circuit from Binbane-Killybegs and west from Letterkenny. DB noted that industrial closures have reduced loading at Derrybeg and Letterkenny which has provided capacity for the growth which has occurred since the last application. All stations, except Derrybeg have shown growth from 2000-2008 (Gweedore +55%, Dunglow +14%, Creeslough +31%) which appears to have arisen from growth in individuals consumption rather than population growth. DB noted that the existing 38kV network will encounter problems in near future. In event of a fault, load will have to be shed. Proposed development will address deficiencies until beyond 2020. The network is not robust enough to accommodate new industry and if new infrastructure is not provided, there will be no possibility of attracting industry to the area, notwithstanding the economic climate.

16:47 MG noted that the NSS promotes the implementation of physical infrastructure corridors and that other utility providers provide cables along roads. In response DB noted that the county development plan infrastructure objectives support this project. WM confirmed that Eirgrid made submissions to Draft County Development Plan regarding the identified infrastructure route corridor.

16:53 Donegal County Council confirmed that they examined route options and submissions made to the draft plan in determining the strategic route corridors.

17:00 AG noted that UGC does not provide as good performance as OHL. In determining the feasibility of providing OHL’s, AG noted that this is based on achieving a viable route / a physical corridor. An UGC route can be achieved almost everywhere.

17:12 AG did not regard the Askon report as relevant to this project. AG noted that if you lay two parallel cables to overcome reliability issues you double the cost. The two trenches would need to be adequately separated trenches (5m) and two UGC’s could not be provided in a single trench.

17:17 UGC is generally maintenance free. While OHL maintenance is greater the overall cost is not prohibitive.

17:23 MN confirmed that the original drivers for the development remained the principle need but that the proposed reinforcement will accommodate generation by renewables, which is to come on-stream.

17:27 MG argues that alternatives not adequately examined. 17:29 Patricia Sharkey (PS) Questions

DB noted that peak demand in northwest Donegal is 67MW. Load in the Cresslough, Derrybeg, Dunglow, Gweedore circuit is 13.8MW (2008), up 12.1MW from 1996. Glenties load is 4.5MW.


The proposed development would provide capacity of 31MW at Ardnagappery and the whole Ardnagappery-Tievebrack line would have capacity of 120MVA. To feed the 110kV line the capacity would be 120MW. The existing 38kV line has capacity of 20MW. Demand is 18MW. What is proposed is to reinforce the existing 38kV circuit which has capacity of 20MVA currently. The existing 38kV lines will be looped into new station to create two new circuits with 20MVA in either direction. They will also provide stand-by to that sub-station. Capacity will be reduced due to voltage drop incurred in feeding load along line, by up to 17-18%.

17:35: ESB don’t have local generating units or CHP units. ESB Networks and

Eirgrid not charged with generation. DB explained the legal relationship between the applicant organisations and ESB. Local generation is possible but presents difficulties due to reliability.

17:41 AG clarified the issue of reliability of UGC and the time taken for repairs, requiring specialist repair crews, while OHL’s can be repaired by local crews.

17:47 AG indicated that ducting of cables along roads was not previously considered in the design of the scheme and confirmed that it was not considered in the Ecofys report. Not aware of above ground ducting use anywhere.

17:49 MN noted that charges for windfarm operators connections to distribution system to their facility are on a least cost options. CER sets the criteria. These are not assets dedicated to renewable generators.

17:53 DB noted that micro-generation not considered in the project. 17:54 DB noted that renewable generation is up to individual developers. CER

operate Gates / licensing to connect to system. 17:56 DB had no figure for the value of assets in Donegal. 17:57 Question From Inspector:

Mark Norton clarified page 12, para 4.2.5 and 4.2.6 of oral hearing submission: This reinforcement is primarily for load demand. Worst period of load demand would be summer peak, which requires higher redundancy to allow for maintenance. In winter, higher peak demand requires less redundancy. Generally problems with load demand occur at this time. For export of generation, when load is at its lowest, local load will soak up power produced and the excess will have to be passed onto rest of the system. In this case, load demand goes up and load problem are worsened. Paradoxically, summer valley min load goes down and more diff to export power out. i.e. It is the relationship between the inputs and outputs.

Correction: Page 23 of statement para. 4.13.2.4.2, line 4, table referred to should read 4.13.2.3

18:00 Ms. McCole Questions

WM clarified max height of poles as 23m, with 2.3m of that below ground.


18:02 Ms. Madge McCole WM addressed separation of the Ardnagappery sub-station from a playground at Derrybeg and undertook to provide further clarification in this regard.

18:03 Mrs. Hanlon Questions

Mrs. Hanlon raised questions on the similarities / overlap of the proposed developemt with previous route from 2000 and in relation to compliance with CDP.

18:06 Tomas O’Monchain Questions

Chuir an t-uasal Ó Monacháin ceisteanna ar na h-iarrathóirí mar gheall ar an méid talamh a bhí ag teastáil uathta le haghaidh an fóstáisiún i Ard na gCeapaire agus an staidéar a rinne said sul ar phioc said an súiomh. Ardnagappery sub-station too large. Can applicants show that station cannot be sited next to existing station at Tullyban? What other sites were explored? WM referred to site selection process in the EIS and identified sites.

18:12 Keith Makinson Questions

AG noted that partial undergrounding of a line is possible but is limited for technical and operational reasons. A mix of overhead and underground is permissible but only a short length of cable at either end, normally on the run-in to a station. The poorer operating performance of the UGC section, will reduce the performance of the overall line. The advantage of an OHL over UGC, the ability to auto-reclose in the event of a transient fault. This cannot be done with an UGC so partial undergrounding involves a calculated risk. The risk is that a transient fault occurring will not be on the UGC due to the short length used. If a transient fault occurs on the short UGC, as opposed to the OHL, and the circuit breaker auto-recloses on it as it would do on an OHL, the fault will be worsened. Lengths of cable are kept to less than 1km out from sub-station and are never installed at intermittent points on a line, only at the ends. If OHL not feasible on any section of line, a long length of cable would be required with a ground compound, enabling protective equipment to be installed at the junction of the cable and the OHL, effectively a small sub-station. This equipment would allow differentiation between fault on OHL and UGC allowing circuit breaker to close or not. Long length of cable would comprise more than 1km. Undergrounding under major roads at intermittent locations on lines would only occur for 38kV lines but not for HV lines. Compound might comprise termination tower, transformers, surge arresters fencing and in an area of approx. 50x50m. The introduction of undergrounding would introduce the need for greater level of redundancy into the system.

18:22 Prof. O’Carroll

In response to questions, DB indicated that a double circuit line would require steel towers for entire route to Gweedore, while the current proposal is on wood poles. There is no requirement for a double circuit.


18.26: Housekeeping

WM advised that line deviations referred to in 5.2 of the EIS would be minor in response to ground conditions. Glossary of technical terms used by Dr. Baily circulated. Irish versions of briefs of evidence from WM were circulated. MN advised that in their 7-year statement, NIE include reference to 275kV line from Coolkerragh station to elsewhere in their network to strengthen the network in that area.

Day 2 of the Hearing concluded at 18.30pm on 01/04/09.


Day 3 Thursday 02/04/09, 10am WITNESSES: William Baily, John Gartland 10.01 Inspector sought clarification on the technical terms used and the

measurements used in Dr. Baily’s submission. John Gartland (JG) noted that the load on the A-T line will be lower than the B-L line, with resulting lower fields. A thicker conductor will be used on the B-L line so that A-T line could achieve same loading. WB noted that the electric field is too easily blocked / attenuated to be of concern, as opposed to the magnetic field. Studies reveal no health effects from electric fields. At some level of exposure, both electric and magnetic fields can produce harmful or unpleasant effects. At very high levels, electric fields can have effects on nerve stimulation. Guideline levels are therefore imposed for electric fields to minimise exposure to high levels which may have stimulatory effects and to reduce perception effects and spark discharge. The voltage of the line is not directly related to the magnetic field. It depends on the loading of the line. Configuration of the conductors affects the magnetic fields. WB explained the basis of the guideline exposure levels. The relevant agencies have not determined that there is no persuasive evidence that there are adverse health effects at lower levels. The most effective way to attenuate magnetic fields is in the characteristics of the source itself, either through double circuit lines, where the phasing of each line is adjusted to cancel the other out or by increasing distance from the source. Shielding is not effective due to nature of materials required. ICNIRP is affiliated to WHO. Guidelines were reviewed in 2003 and WHO adopted the standards in 2007 based on their review.

10.24 Prof. O’Carroll questions:

WB discussed the nature of studies undertaken in relation to Childhood Leukaemia, particularly in relation to possible bias in selection. WB suggested that the Board is best served by referring to a body of evidence reviewed and assessed by a multi-disciplinary group for guidance, rather than relying on views of an individual or the results of an individual study. WB indicated that he was not aware of an average UK domestic exposure of 0.05uT, as measured by NRPP. This is half the suggested exposure of the line. WB indicated that the level of 0.119uT can be measured at a location in a house, but is not an average figure. Most exposure already exists in the home.

10.51 Michael Gillespie questions:

MG and WB discussed the potential for health risk from OHL’s. WB disagreed that EMF emissions from UGC are virtually non-existent. He indicated that the emissions may be similar to OHL or higher / lower. The strength of the magnetic field for either OHL or UGC depends entirely on design and location of the installations. There is no recommended separation / safety distance from UGC’s for residences. WB noted that UGC has no electric field emissions, but that electric field exposure do not raise health concerns. WB confirmed that he has worked for WHO. WB unaware of investigation which indicates that EMF cause of any clusters.


11.15 JG noted that ESB have undertaken, funded and contributed to independent research and investigations. As an engineering organisation, they are not qualified to undertake medical studies, however they have co-operated with health organisations in this regard. Previous studies in Ireland into cancer clusters indicate that the causes were not common. Reference to a book “Electro-Magnetic Man”, not a new publication. This recommended a separation of 150m on each side for 400kV lines.

11.21 Maura Miller ATP questions:

Discussion on use of lay literature in coming to a conclusion on the development. WB conceded that people’s reaction to imposed infrastructure is different from that to which they have a choice. It was agreed that standards have changed for many health areas in response to new evidence.

11:30 Patricia Sharkey questions

PS queried bias in the WHO in adopting the guidelines levels. WB refuted such bias and referred to supporting opinions and conclusions from expert panels in the Netherlands, Canada and UK. WB declined to offer opinion on the funding of ICNIRP.

11:59 Submission: Ronan Mac Aodha Bhui. Tá tuairisc ar aighneacht ón t-uasal Mac Aodh Bhuí luaithe faoi alt 6.11 thíos.

Submission taken from RMcB taken out of sequence, in order to facilitate observers participation. Concerned about the visual impact of the Ardnagappery sub-station and the lines. Tourist appreciation of the area will be affected. Tourism is one of the few industries left in this area. Health risks are of concern and cause stress to those in the area. The lines should therefore be put underground, despite the expense. The approach of ESB is unsatisfactory and would appear to be based on financial gain. The development will be of no benefit to the area.

12:07 Eileen McCole questions WB discussed advances in research since initial studies. 12:08 Joan Hanlon questions

WB advised that he had not reviewed the Dec. 2008 report to the EU parliament, Commission on Environment, Public Health and Food Safety: “Preliminary report on Preoccupations concerning the effects on Human Health of EMF”. Maura Miller indicated that copies of this report would be provided as part of their submission. WB confirmed he had no knowledge regarding the applicant’s insurance indemnification in relation to EMF effects of OHL’s and UGC’s.

12:15 Submission: Charles Swingler, for Patrick Boyle and others

(Copy of submission received) Submission taken out of sequence, in order to facilitate observer’s participation. The submission related to the proposed Tievebrack switching station and in particular to screen planting proposed for the station. It was indicated that the


position of the percolation area and the entrance and access road would expose large areas of the station to view. Similarly, the areas under OHL’s and pylons will not be screened. It was suggested to relocated the proposed entrance located to the west and curve it around to enter compound on left western hand side. Tree cover could then block views from entrance. The percolation area could be easily relocated. Under the lines, it was suggested that some planting might be possible. Planting should be entirely evergreen. The observer queried whether the station could be located further back from the public road, noting that this would be facilitated within landholding. Edward O’Connor (applicants) confirmed that some tree planting might be possible up to 3m height under lines. Luan O’Braonain noted that the suggested revisions would be looked at and responded to.

12:29 Witnesses: Raymond Holbeach, Seamus Fay, Roisin O’Donovan Landscape and planning.

Inspector’s questions: RH described how the viewpoints identified at pre-application stage were examined and incorporated into the visual assessment for the EIS. The routes examined at Meenalargan involve travel higher up the hillside, further away from residential properties, without breaking the skyline. RH noted that the route selected (LV5A) would have increased visual impact over the low-lying route originally proposed in October 2006. The October 2006 was regarded as a good route. Parallel lines at Shallogan would be preferable to running lines separately through the landscape, with wider impacts. RH described the Derkbeg / Shallogans section as being of high sensitivity. The rationalisation of lines was not considered in landscape impact mitigation. Existing lines crossing Gweebarra lower its sensitivity. There would be benefits in rationalisation of the lines but these were described as being slight, in terms of mitigating the impact of this development. RH confirmed that application of bird diverters was considered in the visual assessment contained in the EIS. Separation of line from N56 at Drumlaghdrid will mitigate the visual, however, a single crossing of the N56 with the 38kV line would be beneficial. Ground level activities can have visual impacts due to works on slopes, however, such impacts were assessed in the visual assessment for the EIS. RH noted significant routing restrictions in the Grogan More area, including the more densely populated area to the west and EHSA to the east. The route selection was described as a balance to avoid residential visual impact, minimise the use of steel towers, making use of topography and keeping EHSA crossed to the minimum.

12:56 Gillespie questions:

David Byrne confirmed that anti-climbing devices not normally used in rural areas. The situation will be assessed at the time.


RH submitted 2005 aerial photographs of the area adjoining the junction of R252 / N56, south of Dunglow, illustrating immature forestry at the location of Tower 96, which was confirmed to be 13.6m high. A discussion of the visual impact on this area and adjoining houses ensued, particularly in relation to the property of John Boyle. RH submitted a photo of Mr. Boyle’s property, (ref. 252) 80m from the proposed line.

14:40 RO’D addresses strategic planning context and compliance with the policies ad objectives of the County Development Plan, including the infrastructural corridors outlined in the plan. It was noted that where transmission lines need to connect two points, some other utilities need to be adjacent to properties being served. The adequacy of alternatives considered was discussed. RO’D outlined the difficulties in constructing the UGC option, noting that only approx. 30m of pipe ducting can typically be constructed in a road by one team in one day. In response to questions from Maura Millar RO’D confirmed that there were consultations with the PA at Draft Development Plan stage. The issue of compensation to landowners was discussed, particularly in relation to the property devaluation and visual impact. LO’B indicated that property devaluation was not a planning issue and that the Board was restructured to considering the environmental impacts and proper planning and development of the area.

14:56 Colman McHiginn, Donegal County Council, outlined the manner in which

the infrastructural corridors were incorporated into the development plan. 15:13 Raif Shephard (RS) questions

RS queried the adequacy of the landscape impact assessment. RH suggested that the view travelling on N56 south from Gweedore toward Crolly, is predominantly toward to the sea away from the route. RS disagreed and suggested that the view is toward Grogan More and argued that the impact on views on the N56 should have been considered in more detail. RH suggested that views from houses to west of N56 are away from the proposed line. Similarly, those houses interrupt views from the N56 to the mountains.

15:22 Patricia Sharkey questions

RO’D addressed the inclusion of areas included in 2001 route and indicated that there was no other way to get between Binbane and Gweedore, without passing those areas, due to the constraints. Inadequacies in the availability of maps over Donegal internet connections was raised, while general queries raised in relating to maps covering the Gweebarra crossing. PS questioned the omission of houses from the line maps, particularly at Cloghercor, on the southeastern bank of the Gweebarra. The applicants undertook to provide maps of the area of concern. PS queried the choice of locations for photomontages, e.g. at Meeniroy, illustrating views from Hugh McMonagle’s house (ref. 346). A further discussion in relation to maps in the Gweebarra area arose, with references to residential properties omitted from the maps.


RO’D advised that there was no direct consultation with local walking groups in the area. Further queries were raised in relation to tourist facilities and accommodation in the area. RO’D outlined the basis for the structure numbering.

15:52 Eileen McCole questions:

EMcC raised queries regarding houses omitted from the maps showing visual impacts on residential properties. RH advised that the visual impact maps are a summary of impacts not a quantification of the impacts. There was a discussion of the predicted impacts on EMcC property, ref. 421. EMcC argued that there were deficiencies in the photomontages submitted. In particular View 16 omits views toward Errigal. RH argued that the view was representative of the view at that location. EMcG noted that forest clearance at crossing of the Clady River not assessed. RH referred this matter to the design team. RH argued that Viewpoint 18 at Loughanure is more representative than that from the N56, being closer and more direct views to the proposed line. EMcC argued that the view from the N56 should be assessed, given its protected status.

16:02 Madge McCole questions Choice of route is constrained by the hills to east / EHSA and residential areas around Lough Anure. There is no alternative route. MMcC queried RO’D assessment of the landscape impacts on their area.

16:09 Joan Hanlon questions SF clarifies the land take for the whole project being 0.407ha for pole sets angle masts and 3.1ha and 1.9ha for station sites. SF differentiated between development footprint and wayleaves. The corridor only relates to forestry where trees will be restricted to 3m in height. Wayleave only applies to forestry land in terms of keeping land clear and covers 173ha of forestry. There is no requirement to keep the land clear. WM clarified that the wayleave is right to construct over land. WM outlined the legislative basis for the wayleave. Building is permitted within 23m of line subject to agreement. Compensation may be payable in respect of restrictions on development. JH raised concerns regarding the impacts of the development on the activities of people who have been cutting turf in these areas for many years. SF clarified that no impact on turbury rights arises, except under poleset footprint. Peatland loss will be approx. 0.25ha in total. WM noted that turf cutting may be restricted up to pole bases, to be assessed on a case-by-case basis. Compensation may be payable in specific cases. JH argued that compensation could not make up for impact on such activities. JH raised the conclusions of the previous appeal and Inspectors Reports on the 2000 application. The applicants provided maps provided to JH in response to specific queries about the Glenties areas (Sheet 7 and 8 1:2500 covering Kilrean and Tullyard).

4.30 Break


17:00 On resumption, maps were supplied to JH and PS and Mr. Hugh McMonagal. A discussion followed on the availability and nature of maps submitted. JH raised queries on map 12.3.C. WM clarified to JH that not all owners of properties shown on the maps have been identified. Only those owners directly affected by the wayleaves have been identified. RH clarified that the Hanlon house (ref. 86) would be 260m from nearest point of line and that the visual impact would be slight due to the sloping ground toward the lake. JH indicated that the drawings downloaded from the web did not contain all of the relevant information. WM offered suggestions as to how this arose and advised that the maps on the website were correct. SF clarified that the term used in the land use map Rough Grass is defined as unimproved agricultural land. JH queried the protected views which were assessed in the EIS and argued that the view from the local road at Tullyard to Lough Ananima is protected under the general provisions of the development plan. RH identified the Tullyard area as being of high quality and high sensitivity. RH outlined the basis of the assessment of the visual impact of the development in the Tullyard area and the impact of new house construction on the area. RH advised that the route crosses two EHSA’s at Tievedeevan and Grogan More. RO’D discussed impacts on tourist attractions and accommodation in the area, including walking routes. Finntown railway is 2.4km from B-L line. The applicants advised that the maps available on the application website were correct.

17:54 Tomas O’Monachain questions:

TO’M queried the description of housing at N56 crossing at Gweedore as a linear settlement. Landscape impacts queried, particularly in relation to views on Errigal and arising from AM13. Can AM13 be provided as a wood pole structure? New maps requested showing existing 38kV and proposed line. Impact on views on R258 travelling west queried.

18:18 Hugh McMonagle questions

WM clarified the level of consultation undertaken. Luan O’Braonain / WM addressed the restrictions on the use of land under the line. The only restriction is on tree planting. WM clarified that McMonagle house 150m from line.

18:24 Keith Makinson questions Shane McLoughney addressed the turn in the A-T line south of Lough Anure, at Lettercau. RO’D made reference to the previous inspectors report under PL05.119713, which raised concerns about a route to west of Lough Anure. Constraints also include one-off housing to west of the lake. The proposed route is a route which one can get through.


RH noted that tree cover in this area aids in the integration of the proposal in the landscape in this area. McGrorry confirmed that no trees would be lost between pole-sets 58-59. LO’B clarified that feasibility in relation to provision of an OHL comprised a number of factors feeding into the decision, including environmental factors.

18:57 Joe Rogers questions RH clarified separation from the subject dwellings (house) 193 to be 90m to AM52. LO’B advised that insurance availability is not a planning issue. SF clarified the code of practice of ESB in relation to development impacts arising from poleset 57 which may impact on lands bought for development at Lettarcau. LO’B clarified the procedure involved in compensation. RH indicated that there are significant impacts at this location.

19:11 Charles Swingler questions:

Discussion with RH regarding the character of landscape v’s geological formation and approaches to the assessment of landscape.

19:14 Brian Ferry questions

WM confirmed that existing 38kV line to Derrybeg industrial estate will be broken at new substation and then continue on to industrial estate on existing poles. Drawings were then circulated showing separation of the Ardnagappery sub-station (approx. 970m) from playground and existing sub-station, in response to earlier questions from Madge McCole.

19:20 Patrick Roarty questions

SF noted 7 no. polesets on Roarty lands with no grazing impacts, apart from construction. RH noted separation from N56 and intervening topography, reducing the impact of the development. Signposted scenic route at this location but not included in the development plan. McCrory noted the sensitivity of a lake on the lands which hosts a protected breeding species. Unable to identify location as this is protected information under the Birds Directive. PR also noted that the lands include 2 no. potential development sites McCrory confirmed his awareness of the nature of the site and that the assessment of impacts of the development carried out in the EIS took account of this fact. Birdwatch Ireland (Stephen Newton) and NPWS were consulted. McCrory confirmed that he did not consider that the development would have a significant adverse effect on that species.

19:42 Tomas O’Monachain questions

TO’M raised queries regarding mapping. WM indicated that he would address the position of the sub-station relative to the approved wastewater treatment plant at Derrybeg, on the following day.


Maps circulated in response to earlier questions as well as information in relation to the funding of ICNIRP.

Day 3 concluded at 19:53


Day 4 03/04/09 9.30am 09:32 Submission by Prof J. O’Carroll – revised written submission received.

JO’C addressed the strategic choices made in the design of the proposed development and expressed caution in relation to Corporate decision making. Cordial relations with ESB were noted. The alternative approaches to the development should not be viewed in isolation and the combinations suggested by himself were not fully considered in the EIS. A longer term view than 1-15 years should be considered. The Gweedore spur will vulnerable after 2020, due to the lack of a stand-by supply and the prospect of a second 110kV line should be considered. The need for a new 110kV Binbane to Letterkenny line is accepted but it is not required to directly connect them. While Option C would solve transmission problem, although not provide the most effective distribution option, it might be considered with other distribution measures. The suggested dedicated Coolkeragh –Burnfoot connection was not fully considered by the applicants. Option C may also facilitate the gateway role of Derry. It was accepted that parallel 38kV lines were not an appropriate solution. An Ex-Ballykeeran outage could be resolved by parallel support to Cresslough along N56, or from Millford to Creeslough, on a 38kV spur, with no-stand-by, supported by 110kV to Ballykeeran. These options would allow removal of lines at Errigal. The balances between the criteria used in comparing route options should be quantified for comparison purposes. A hybrid 38 / 110kV solution could be considered, with 110kV to Dunglow and Ballykeeran. Parallel 38kv – Dunglow to Derrybeg, and Balykeeran to Cresslough, would allow removal of section through National Park. The 38kV Glenties to Binbane would not be required in normal operations. This obviates the need for boosters. The any additional costs arising with alternative solutions are not a basis for objection. Under the hybrid system, any additional industry in Derrybeg after 2020, would not be required although it may / may not be advisable. The responses of the applicants to the alternatives were negative. The table on page 10 of the EIS show poor information flow and demonstrates a negative approach generally. Partial undergrounding should not be discounted and is easier and cheaper for lower voltage lines. Ducting would avoid dig-in’s. Intermediate undergrounding of 400kV for 6km was undertaken in Yorkshire, approx. 15km from a substation, following a refusal on grounds of visual amenity. Consideration should be given to other options, including a tunnel under the Gweebarra River, or at the switching station approaches. An urban area is not required to absorb a switching station. They could be located in open expanse. There are conflicting views on EMF. The science is not to be assessed, but the balance of views should be noted. JO’C has served on a number of committees in this area. “Best Available Option” is a term used in the SAGE, referred to by Dr. Baily, which involves restricting building along a corridor along power lines. Contrary to Dr. Baily’s comments, the SAGE report does support the use of corridors and considers health effects other than Leukaemia.


JO’C noted error in Baily submission, in defining magnetic flux density, which does actually refer to per square meter per cross section area. A single-circuit line such as this does not allow emissions to be reduced, as in a balanced double circuit line. There should be a distinction between precaution and limits. Reference was made to publications, Bio-initiative report and the European Environment Agency “Late lessons from Early Warnings”. There are conflicting scientific views in regard to the health issues. While the recommendations of the submission were considered at the hearing, no.5 and 6 have not been properly addressed Recommendations 5 of submission, a Combined Solution which balances operational requirements and environmental impacts. Recommendation 6 is that renewables should pay for undergrounding.

10:45 WITNESS: James Fitzpatrick,Traffic

In response to questions from the inspector, JF confirmed that pole-set construction activity would be approx 0.5 days and the likelihood of damage to roads is unlikely. Arrangements with DCC for payment of a bond in this regard have been discussed. Helicopter access to pole-set locations have been identified at preliminary basis.

10:48 WITNESS: Eugene McKeown, Noise

In response to questions from inspector EMcK advised on the reductions in noise emissions arising from current technology.

10:54 Joan Hanlon questions

EMcK outlined the basis for noise measurements and the locations used as baseline measurements. Continuous noise would not be an issue. Aeolian noise impacts due to high winds or impacts from gap sparking would be significant. Construction impacts will be short-term and in day-time hours only. EMcK noted the difficulties with construction with UGC noise in the granite ground conditions in Donegal. It is not comparable with OHL due to the different construction noise impacts. Noted that some people are more sensitive to noise impacts than others, but that this is not a windfarm proposal. EMcK confirmed that noise measuresments were taken at Derrybeg.

11:08 Questions to Prof. O’Carroll from Applicants

In response to questions from Luan O’Braonain, O’C noted that acknowledged the engagement and discussions with Eirgrid prior to the hearing. He elaborated on the advice to exercise caution in dealing with corporations. O’C noted that sealing-end compound at intermediate undergrounding locations is not a sub-station and is not the same in visual terms and conceded that balance needs to be exercised in determining these matters. JO’C acknowledged that his alternatives have been considered either in EIS or in discussions at the oral hearing.


Agreed that it is not possible to forecast beyond 2020 in an affirmative way, but account of potential development should be taken. The SAGE report suggested a 60m corridor for 275kV and 400kV lines. JO’C noted that 30m for 132kV was also suggested, but for balanced double circuit lines. It is not unreasonable that 50m separation from 110kV line would reasonably consistent with, or a bit better than, SAGE.

Break 11:24. Resumption 11:56 11:59 WITNESSES: Paddy Kavanagh, James McCrory and Edward

O’Connor In response to questions from the Inspector, JMcC confirmed that NPWS advised that bird flight surveys were not necessary. The location for installation of bird flight diverters were chosen on basis on known or potential flight paths, or along river courses and water bodies near the line, based on published data and data provided at scoping stage. Locations were specifically discussed with Golden Eagle Trust and with NPWS. The diverter to be used is that illustrated in the submission of William Mongey. The specific diverter has not been used previously in Ireland. EO’C confirmed that at permanent track will not be installed / required along the route. Slopes may require temporary works, based on a risk assessment for access, yet to be carried out. At Lettercau, retention of trees by shooting the line over the canopy, would necessitate 23m high poleset and with a slightly higher angle mast. The structures would not be materially different to those previously proposed. McCrory confirmed that no tree felling will be required on the northern shore of the Gweebarra, although tree surgery may be required. Height of the line over the Gweebarra to be confirmed. JMcC did not consider that the cumulative impact on bird passage of the line with the existing 38kV line was assessed, would not be significant, with mitigation in place.

12:12 Gillespie questions

Discussion of alternatives and mitigation measures. JMcC noted that there are few locations where the prevailing ground conditions would place construction vehicles in danger. EO’C noted that peat depths under both lines are generally less than 1m, but that they may run up to 3.5-4m deep. JMcC confirmed that its is not possible to construct the pole-sets by hand only. The impacts of vehicle access to pole-sets, across blanket bog, are considered in EIS. Negative effects arising will be permanent at pole-set locations and long-term in terms of compression, in access areas. Paddy Kavanagh noted the conservation status of the Freshwater Pearl Mussel catchments as unfavourable. There are a lot of landuse activities impacting on the mussels, which contribute to their decline. The proposed works will not affect the sub-basin management plans, subject to appropriate mitigation measures.


An ecologist will oversee works in sensitive locations and advise contractors of the requirements. Consultation will be undertaken with statutory bodies. JMcCrory noted an error in table 7.9 of EIS, which relates to structures within designated sites, such that the polesets are out of sequence by 2, i.e. pole-set 126 should read pole-set 128 etc. JMcCrory advised that the construction and operational effects o the development on the breeding place of a bird on List 2 of European Directive, on Patrick Roarty lands at Crovehy, have been considered. Frequent flight movements are between the loughs and the sea, to west of the line. Development involving installation of underground cable would have different impacts and a different assessment to the proposed development.

12:45 Raif Shepherd questions

JMcC identifies the effects of compression to be medium term; 5-10 years. The extent of damage would be localised, with similar vegetation on arising both sides of the track areas. EO’C noted that an environmental manager will be appointed and clarified that low-pressure vehicles would be used in construction. Other mitigatin measures would include use of bog-mats. JMcC noted that proposed line is 500m east of bird site on Patrick Roarty lands. The flight path is typically high, and the bird is a strong flier. In response to the question whether the bird be manoeuvrable enough to avoid line and will it fly lower as it approaches the lake, JMcC noted that the likelihood of a collision is low. The line crosses a designated cSAC, but JMcC argued that the impact of the development would not be negative / adverse on the integrity of the site, and need not therefore be notified to the commission. Negative effect is not same as an adverse finding on integrity of the site, under the terms of the Directive. RS suggested that the level of risk is a question of values. JMcC noted that the risk was low and the finding that there is not a significant effect on a Natura Site, and this was agreed with the Department of the Environment, Heritage and Local Government. JMcC described the methodology used in the habitats survey of the lines. The search for protected species was an additional layer to phase 1 survey, which was carried out in accordance with Heritage Council guidance. The route constraints prevent complete avoidance of annex 1 habitats (blanket bog), except where such habitats are designated. Blanket bog is too extensive to avoid. PK agreed that the development would produce some impacts on Freshwater pearl Mussel, but such impact would not impair the species. The cumulative impact of the development, with existing state of the rivers would not significantly contribute to pressure on the mussel species.

13:11 Sharkey questions

EO’C confirmed that no tree felling will be required in Cloghercor, south of Gweebarra River. Where the line is shot over a tree canopy it will be visible. The lines will be sliver in colour, dulling with time. No green lines coloured are proposed for use.


Poles will be from 1 tonne to 4.5 tonnes in weight, depending on the pole height. Some sinkage of the poles can occur, and sleepers will be placed under poles in certain locations, which would necessitate a greater amount of excavation. The construction timeframe is 9-12 months, subject to weather, with ecologist on every site where warranted. Five persons per crew. The contractors for the line have not yet been identified. The areas of difficult topography where helicopter access will be used are identified in table 5.3 of the EIS. Pole will be transferred to the site and raised into position.

Break for lunch 13:23 14:19 Eileen McCole questions

EO’C confirmed that the suitability of all candidate access tracks for construction purposes has not been assessed on the ground. These would be assessed by the contractors in consultation in landowners if permission was granted. EMcC noted that the tracks adjoining their own dwellings at Meencorwick are not suitable for construction traffic.

14:23 Madge McCole questions

PK advised that measures to protect water supplies would be agreed prior to construction commencing. In the event of disruption or contamination of any water supply, the applicants would ensure a continuous supply of water. This is commonly done by water tanker.

14:27 J. Hanlon questions

JMcCrory noted that no structures are proposed in quaking bog (mat of

vegetation over wider substrate of deep peat). Only one area of quaking bog has been identified under the propsed line. JH asked JMcC about quaking bog in the Tullyard / Glenties area, advising that the quaking bog occurs in this area, as these areas cannot be grazed or walked on. The line (ST76 and 77) is 109-112m from Lough Ananima. Paul Jennings (AGEC) advised that ground conditions at these pole-set were not assessed due to access difficulties, however, peat depths of 0.5-2.9m are estimated in this area. JH queried the rating and assessment of the rural environment by the applicants. JMcC rated habitats in the Tullyard area as being of high or very high on an international standard. Designated sites cannot be entirely avoided in routing the lines. JMcC noted that permanent loss of some habitat, including, priority 1 habitat, blanket bog, is necessary. The conclusions of the DoEHLG in relation to the project were noted. The reduction of impacts by mitigation measures cannot be quantified. Specific construction methods do reflect the nature of the impacts.

14:54 Submission Kathleen Coyle, Binbane


Due to difficulties in attendance, the submission from KC was taken at this time.

• Written submission lodged to application. Coyles lands adjoining Binbane sub-station

• The proposed line will, as it leaves the sub-station, cross the only lands suitable for development for construction of a house for a family member.

• Alternative route options have been suggested, which could avoid this land but ESB have refused to divert route.

14:55 J. Hanlon questions resume JMcC clarified the difference between negative effect and an adverse impact on the integrity of the site, as outline in the Habitats Directive. JmcC noted that these particular design of bird flight diverter have been used elsewhere previously, but not in Ireland. Published studies shows their effectiveness. EO’C indicated that poles, previously delivered by helicopter to the site, will be placed in hole using a hoist / Jin pole, which do not necessarily require machinery on the site. Other options on blanket bog include use of low-pressure vehicles.

15:06 Elizabeth Mudowney, An Taisce questions

JMcCrory advised that the applicants had made no further response on the issue of siltation from sub-station works, arising from the written submissions of An Taisce. JMcC noted that effect on GWFG was discussed in EIS but no additional submissions in this regard.

15:10 John Rogers questions

Mr. McLoughney confirmed that the actual site of IMP52, to the rear of Mrs. Rose Roger’s house, at Bunawack Lough Anure, was not visited to confirm ground conditions. Roadside surveys only were conducted, at a distance of approx. 120m from the site. EO’C indicated that if the project was confirmed, consultation with the landowner would occur to inform the construction process. House no. 192 at Bunawack, Lough Anure, is 125m from IMP52. House no. 193 is 87m from IMP52. IMP 52 is 15m high, weighing approx. 2 tonnes. Foundations would be 2.6-3m depth typically, being 2.5-sq.m. up to a possible 4.5-sq.m. for each leg of the mast. In response to poor ground conditions, EO’C noted that alternative construction methods could include special foundation design or use of piles. EO’C referred to past experience of piling for pylons in poor peat conditions, of up to depths of 24m (Mount Lucas, Offaly). Alterations to the line in order to find ground conditions might be possible but only at angle mast locations, due to up and downstream impacts on the line. PK noted that prevention of silt run-off to streams and lakes would be down to construction practice.


Luan O’Brainain submitted revised screening proposals for Tievebrack Switching Station in response to submissions from Mr. Swindler and a map was supplied to Ms. Sharkey.

15:43 P. Sharkey questions

JMcC noted that there is no contingency plan for habitat loss. WM confirmed that ST144 on the northwest bank of the Gweebarra is 23m high. ST145 on the southeast bank is 20m high, resulting in a line height approx. 13.3m over the river. JMcC noted that the risk of electrocution of birds was almost non-existent. JMcC confirmed that the use of deflectors would be effective, in consultation with Golden Eagle Team. There are no deflectors on the existing 38kV Gweebarra crossing and no collisions have occurred. JMcC had regard to guidance on the use of Creosote and its impacts has been fully considered. PK considered the impact of phosphates due to tree felling to facilitate the line, on watercourses and freshwater pearl mussel.

16:06: Una Sweeney questions

Discussion regarding retention of trees at Lettercau at ST58, in recognition of the value of the landscape. WM confirmed that ST58 would be a 15m angle mast and ST59 would be a 23m high poleset, in order to raise line over tree canopy. The specific design of the structures was identified. JMcC confirmed that the EIS states that an ecologist would be present. EO’C advised that in extreme rainfall events, construction works would be likely to stop.

16:14 Hanlon questions

PK noted that one main crossing of the Owenea River will occur, with numerous crossing of its tributaries. One crossing of the Claddy will occur. PK noted obligations to comply with regard to water supply or pollution. M and EMcCole confirmed that water supply in Meencorwick area is by surface water abstraction and that the Gweedore sewerage scheme has not been implemented. JH advised that there is a mains water supply in Tullyard.

Tomas O’Monachain raised queries in relation to maps supplied. Thug BSL freagraí do na ceisteanna sin.

Day 4 concluded.


Day 5 06/04/09 10am

Inspector put questions to the applicants on matters of peat and soil stability report (AGEC report). Dr. Jennings noted that peat depths of up to 4.7m have been recorded along the route. EO’C confirmed that beyond 4m depth, a special foundation would be required, usually installing sleepers, requiring additional construction impacts. Dr. J noted an historic peat failure at Tievedeevan. Peat depths are shallower on the Ardnagappery-Tievebrack line. The proposed use of helicopter for construction access at A-T ST39-52, is due to the remoteness of the site, rock outcrops, slope etc., rather than peat depths. AM140-143 (north of Gweebarra) Tievebrack to Binbane encounters deeper peat depths. Peat thins as one moves up slopes.

Witnesses: John Cronin, Edward O’Connor, William Mongey, Niall Mitchell /

Dr. Jennings 10:20 P. Sharkey questions

JC opined that there is no agreed protection buffer around national monument. No archaeological features were identified along the route, but there is potential for sub-surface features. JC noted that there is a general scarcity of features in Donegal. The specific features and sites identified in Sharkey written submission are not regarded as being of archaeological significance. No excavation licence was sought and a total walkover was not conducted. JC indicated that he was not aware of island Crannog’s on Owenmarbh River upstream of the line, north of Drumlaghdrid. An 18th C ferry house on the eastern shore of the Gweebarra River was not assessed. A stone Cashel on the western shore was noted but the potential impacts thereon, did not warrant assessment. NM advised that environmental emergency plans, particularly for water quality impacts have not yet been prepared to date.

10:33 Tomas O’Monachain questions

A question was put regarding the effect of the development at Dore and whether thought was put to provision of the line underground at Arduns.

10:38: Gillespie questions

NM advised that the risk of peat slide arises only in areas of 2% slope, and only in conjunction with adverse conditions. In the event of waterlogging of excavations, dewatering to suitable outlets may be required. Any measures in this regard would be site specific. NM noted that EPA highlights that creosote does not pose a risk to surface waters. Any impact from creosote on poles would occur within 60cm of the pole and all poles would be 15m from watercourses. EO’C confirmed that in relation to UGC, increased insulation requirements contributes to the increased costs. General discussion on costs of UGC took place. EO’C confirmed the tree felling corridor is 61m, as agreed with commercial forestry operators.


EO’C advised that in the event of agreement with landowners regarding access not being reached, the matter will be referred to mediators.

10:59 Eileen McCole questions

In relation to comments regarding deficiencies in the drawings submitted, WM advised there was no intention to mislead the public in the manner of description of mast structures.

11:01 Joan Hanlon questions

JH queried where specific investigations of ground conditions occurred. Discussion of construction activity in peat areas. EO’C confirmed that the March 2009 walkover survey was carried out to complement previous surveys and provide overview of the overall project. EO’C indicated that they are satisfied with the information available in relation to ground conditions along both lines.

11:16 Dr. Jennings classified the route as being of a low risk of peat failure. There are less relatively fewer peat failures in Donegal due to the shallower peat depth on higher slopes and higher peat strength values arising. Peat failures won’t occur on valley floor due to the lower slopes.

Break 11:22 until 11:47am Resumed with Joan Hanlon questioning.

Dr. J noted that he surveyed the line and classified the risk of peat failure as low. The features indicating higher probability of failure were not present. It is only in the event of the adverse combination of a number of factors that gives to the risk of failure. The features include, deep peat, weak peat measured in terms of shear strength (2-3kPA), topography, drainage on the slope, slope angle. No strengths along the route of this weak level were measured. Strengths of 7-15kPA were encountered and is therefore considered to be strong. Dr. J confirmed that weak peat may occur, but at the valley floor. Two scars arising from peat failure were noted in the area. These erosion features were not considered to be of recent origin or represent high risk. EO’C noted that there is some flexibility to move poles forward or backwards to facilitate landowners. NM confirmed that in general water supplies along the route are from abstraction. NM confirmed that not all wells were surveyed along the route. Detailed surveys and mitigation measure will be formulated prior to construction, to protect wells. Water protection zones, as defined by the GSI, do not arise along the route. Rivers used for abstraction do occur along the route. No poles or angle masts will be located within 15m of watercourses or wells, which separation has been stipulated by the County Council. NM advised that subject to mitigation measures identified in the EIS, the risk to ground water would be low, given ground conditions arising. Sub-stations sites are defined as being of moderate vulnerability, giving rise to a low risk to ground water.


John Cronin agreed that areas along the line may have been subject to historic human habitation and advised that these were considered in the assessment. This gives rise to archaeological supervision of excavation works. John Cronin noted that there are areas of high archaeological potential in the Kilrean Lower, Tullyard area and Meenlackanore, Drumlaghdrid. While line may cross identified archaeological features, no ground disturbance is proposed in these areas, eg. crossing disused railway.

12:12 Madge McCole

Dr. Jennings noted that risk to peat stability at AM39 was low, but that no site specific study was undertaken due to access restrictions. MMcC advised that ground conditions in this area are poor, resulting in vehicles sinking in the ground. NM advised that ST46 and 47 are a minimum 15m from streams. EO’C addressed the potential for relocation of the line or its support structures. IN response to a subsequent question from Joan Hanlon, EO’C described temporary guard structures, in the form of a goalpost, to protect roads and properties during construction.

OBSERVERS SUBMISSIONS: 12:28 Ralph Sheppard (ATP): See written submission. Concerned primarily with ecological impacts. General issues raised include: • The descriptions of the habitats along the route are inadequate. • Areas particularly identified include Crockmeenleckanore, Cloghercor bog, bogs

around Glenties and the hils north of Glenties. Bogs at Kilrean and Tullyard include a bog pool system which shold have been located within the cSAC.

• In avoiding designated sites, the wider landscape, including priority habitats, is to be sacrificed.

• Routing through a designated site at Crovehy is proposed as the Board previously considered a route around Craghy Louth to the east to be unacceptable. This designated site is the site of a rare breeding bird.

• Greater weight should have been given to ecological concerns. • Partial undergrounding of the route would address problems in this area. • The development would have “adverse” impacts on the designated site at Crovehy

and compensatory measures would necessitate replacement habitat which is not possible. NPWS cannot therefore admit that the impact of the development would be adverse.

• Further encroachment into designated areas should be resisted. • Concerns regarding the impact on the freshwater pearl mussel expressed by Alan

Keys should be heeded. • The landscape, as a network of habitats and sites, should be protected. • Development should not be kept from the main tourist routes and forced into

natural landscapes. • The crossing of Grogan More will have significant impacts on views between

Gweedore and Crolly.


• Impacts of the Binbane-Letterkenny route should not be ignored due to the lack of objectors thereto, particularly at Meeniroy.

• The need for export of wind energy from the area is now a relevant consideration. • Alternative route options should be considered, including a southern link from

Binbane to Letterkenny. A solution to the problems of the western area should be devised, not based on industrialising Gweedore.

• There are breeding Whooper Swans at Lough Shivnagh. There are only 2/3 pairs of these annex 2 birds in the country.

• If necessary, only partial undergounding of the route could be considered. Greater weight should be given to ecological and environmental concerns.

Break 13:06 14:14 Patricia Sharkey See written submission. General issues raised, including landscape, ecology, culture. A power point presentation accompanied the submission. • A commentary on views, particularly in the Gweebarra area, was provided,

including protected views from Gweebarra bridge. • The line is substantially the same as that previously refused permission. The

existing 38kV lines is sufficient of local needs supplemented by local generation. • Little analysis was undertaker of the impact on the March Fritillary butterfly. • Difficulties in accessing the website information and the maps included in the

application were identified. • The use of the name Tievebrack, which is not the local town name, is misleading. • Renewables are now a driver for the development and windfarm operators should

pay for undergrounding. Existing impacts and landscape degradation is due to the previous actions of the ESB.

• Meeniroy and Meenaboll are areas of historic interest. • If undergrounding is good for Dublin it is good for Donegal. • Alternatives were not adequately considered in the EIS. • Cultural impacts of the development should be also considered. The route is

almost entirely within Gaeltacht areas. Landscape has contributed to the music from the area.

• The development will over-provide for the electricity demands of the region, even if the factories in Gweedore were in operation.

• Underground cables have better weather resistance to weather and is not common technology worldwide. The ESB are a large profitable organisation and could afford the additional costs involved. The reason for not undergrounding is a cost not a technical issue.

• No technical reason for the upgrade of the line apart from facilitating windfarms has been given. Wind farm developers should pay for undergrounding.

• The landscape of the area should be protected for future generations. • Derryloghan / Cloghercor was the site of the first state forestry in the area in 1947. • Undergrounding will overcome many of the impacts of the development. • PS discussed health concerns arsing from the development. Concerns expressed

by professionals are enough to warrant invoking the precautionary principle. • The WHO are subject to bias in setting guidelines for EMF. • Health issues were also expressed regarding the use of creosote.


• The EIS is inadequate in relation to flora, fauna and habitats and the development may be subject to a challenge in Europe. Particular impacts on the Golden Eagle were raised, notwithstanding proposed use of bird flight diverters.

• There are a significant number of dwellings in proximity to the proposed line, which area not indicated on the maps submitted with the application.

• Tourism impacts were not adequately addressed in the EIS. • The conclusions of the previous inspector in relation to visual impacts of the

development remain true. • The impact on bees of EMF have not been considered in the EIS. • There was no consultation with the angling clubs along the route or other river

users. • Impacts on water supplies have not been adequately considered. • The development will give rise to noise impacts on residents and animals. • Unrecorded archaeological sites in the Gweebarra area, which have been notified

to the National Museum, were not adequately considered in the EIS. Given the extent of other new finds in the county, test excavations should have been undertaken.

• No actual impacts on the noted archaeological features are identified. • The line is similar to that previously refused. • There was no consultation or engagement in relation to this application. • Fears of real or perceived health risks would be alleviated by a refusal of

permission. The submission is accompanied by a number of visual images and commentary. 15:03 Moira Miller, ATP, Coiste Timpeallacht an Gaobh Dobhair See written submission. Concerned primarily with health issues and risk reduction. • There are conflicting opinions on the effects of EMF and it is acknowledged that

applicants would be operating within current standards. • The fear and anxiety caused by the proposed development cannot be measured,

however. Research on the effects of EMF cold be spent reducing these impacts. • Some individuals are more susceptible to the effects of EMF than others. • Science has been wrong in the past and standards change with new evidence. • The Board should err on the side of caution. • While there is no obligation on EU member states to take measures in relation to

ELF, there is nothing to prevent member states adopting more stringent standards to protect the public than those prescribed, as in 9 other EU countries.

• Reference made to the Bio-Initiative Report: A rationale for a Biologically-based Public Exposure Standard for EMF.

• This report recommends that new regulatory limits for ELF are warranted. • The UK Sage report recommends a magnetic field limit for habitable space

adjacent to power lines and a precautionary limit for outdoor exposure. The written submission is accompanied by extracts from a number of publications including, Green Facts, WHO Volume 80 Non-Ionising Radiation., European Parliament Preliminary Report. 2008,On Pre-occupations Concerning the Effects on

Human Health of Electromagnetic Fields, Prof. Henshaw, university of Bristol, “A

Preliminary Assessment of Health Risks Associated with living near High Vltage

Powerlines in the UK.”. Also included were copies of original written submissions on


the application, a submission entitled, “Comments on the Applicant’s EIS, Health and Safety Aspects” and extracts from previous ABP reports on a 110kV line in Donegal. 15:23 Keith Makinson See written submission. Principally concerned with the area of Lettercau. • Mr. Makinson argued that the development would have a substantial impact on his

property, as it passes to the south-eastern and south-western faces thereof. • This area comprises a small intimate landscape and valley. The line will impact

physically on one side of this valley and visually on the other. • The line route, with four changes of direction around Lough Anure is

unjustifiable. • There was no architectural or landscape involvement in the route selection or

design of structures. • The application is incomplete and inadequate. • A revised solution involving a multi-disciplinary team, elegant structures and

using undergrounding where necessary, should be pursued. 15:28 Solr. Michael Gillespie See written submission. Issues raised include: • The scale and impact of the project has been understated by the applicants. The

effect of the separation corridor along the entire route should be considered. • An UGC proposal would be more acceptable to landowner and be in the best

interests of the county. • The development will provide over-capacity which will be used to export power

from wind farms. • Likely significant impacts include, landscape and visual impacts, devaluation of

property, damage to fisheries and aquatic species, risk of electrocution, risk to aviation, noise impacts and archaeological impacts.

• The EIS fails to adequately consider alternatives, particularly undergrounding of the line and is therefore inadequate.

• Cost estimates for the UGC option are not satisfactory and do no take account of the benefits arising in terms of operating costs and environmental impacts.

• Even if permission is granted, local people will resist this development, resulting in additional costs and delays for the developers.

15:45 Thomas O’Monachain Tá an t-uasal in éadan an line idir Ard na gCeapaire Gus an Taobh Breac. Deacracht faoi leith le AM13 See written submission. 16:40 Gearoid O’Maonaigh teach thart ar 200 meadar ón structúr. Níor labair BSL le daoine. Imbuillí ar radharcanna, truallú, trácht ag úsaáid and fó-stáisíun. Éilesamh ar leichtreacas níos ísle ná 2000. Cóir go gcuirfí an line faoi thalamh • Observers house is 200m from an structure at Ardnagappery. There were no

previous discussions with the applicants despite their contention. The substation site is elevated with views to Errigal impacted on by the development. The


existing OHL impact on this view and this impact will be exacerbated. Alternative sub-station sites considered should be available.

• The entrance will create a traffic hazard on the regional road. • Demand in the area is down and there is no requirement for the development. The

costings provided for not account for land devaluation. • The approach to the Irish languages was deficient. • Concerns are expressed regarding health impacts and pollution concerns. • This county is poor and renewables are the main driver for the development,

which also have landscape impacts. There are few natural resources in the area and landscape is the last such resource. The line should therefore be underground.

16:54 Eileen McCole See written submission. Issues raised include: • Health concerns arising from emissions. • Visual impact on adjoining houses and the assessment of such impacts. • Omissions of houses adjoining the line from assessment maps. • Deficiencies in the manner in which the information was presented in the EIS,

particularly in relation to the description of pole structures. • Landscape impacts of the development. • Deficiencies in the photomontages provided and failure to consider protected

views, particularly from the N56 across Lough Anure. • Failure to adequately assess the suitability of construction access tracks. • Contamination of rivers due to tree felling. • Visual impact of tree felling and increased exposure of the development arising

thereform. • Impact on walking routes in the area. • Water contamination will be unavoidable, with impacts on domestic supplies and

fisheries. • Inadequate consideration has been given to undergrounding. • The development is driven by the need to accommodate renewable generation. Enclosed with the submission are a number of photographs and extracts from the EIS. Also submitted is extract from the pre-application discussions and a copy of a newspaper article. 17:13 Madge McCole See written submission. Issues raised include: • Impact on views from house. • Health concerns arising from emissions. • Devaluation of due to visual and health impacts, as well as impact on development

land. • Inadequate provision for impact on water supplies to adjoining dwellings. • The lines should be placed underground. Any additional costs should be paid by

renewable operators. Accompanying the submission is a photograph, taken looking across Lough Anure. 17:21 Joan Hanlon


JH noted that maps submitted were inadequate and that the hearing should not conclude until satisfactory information is produced in the interests of public participation. 17:23 Louis Hanlon See written submission. Points raised include: • Impact on farm and property rights. • Interference with views to Lough Ananima and surrounding area from home. • Property devaluation due to visual impacts and restrictions on development

potential. • The developments presents a risk to humans and animals from EMF and

electrocution. It would not be safe to work below or around the lines. • Impact on compliance with REPS. • Who will insure landowners against the ill effects of high voltage overhead lines? • There area features of archaeological and cultural interest on the observers lands

at Tullyard. • The name for the switching station, “Tievebrack” is misleading as this relates to a

townland some distance from the site. • Areas of blanket bog on the observers land will not permit persons or animals to

walk across them. • Dissatisfaction with the manner in which the applicants answered questions put

was expressed. • The proposed lines should be paced underground. • Overhead lines will not be permitted to cross the observers property. The submission is accompanied by a number of articles and letters, as well as a number of photographs. 17:41 John Rogers See written submission. Points raised include: • Inadequate investigations into ground conditions have been carried out by the

applicants, particularly at the location of Angle Mast 53 at Bunawack. • Ground at this location is march / swamp ground. • The view east and south across Lough Anure is a protected view. • The lien and AM52 will be clearly visible in this view. • There is no comparison with existing wood pole structures in the landscape. • The applicants suggest that a forestry plantation will restrict views of the tower,

however, this is 90m from the structure. • The area around AM52 comprises unspoilt landscape rather than having human

interventions as described by the applicants. Similarly there has been no development since the last application.

• Structure 55 will be located on top of a hill at Ardveen, Bunawack / Lettercau contrary to the applicant’s description of the route.

• A number of houses are omitted from the maps of residential visual amenity and the maps provided are incorrect.

• The application is based on inadequate information. The submission was accompanied by a number of photographs.


17:54 Patricia Sharkey, for Mr McMonegal Access to lands for any construction works will not be granted. 17:54 Elizabeth Muldowney, An Taisce • A review of Gate 3 should be conducted to demonstrate suitability for

development for future renewable provision. • Replacement tree planting should be provided as compensatory measure for tree

felling, which would go beyond monetary compensation. • The application does not go beyond the minimum requirements of codes of

practice etc. • Renewable fuels should be used in the construction phase. • A review of the costs of the project versus UGC should be carried out. Local

interest in project in the area is noted. • There is a need to increase renewable contribution to power generation. The An

Taisce position on wind energy / renewable energy is set out in the An Taisce magazine provided. This is in support of wind energy developments. There are time constraints, due to lack of gas in the system.

• Local consultation is required in this project. • The project is vital and has benefits in terms of supply to the area and will assist

renewables. This will require trade-offs on both sides. Innovation is required. • There is a need for such a project but recommend that the design be reconsidered

and that partial under-grounding be considered. 18:11 Una Sweeney See written submission. Points raised include: • Impact of steel angle mast no. 58 on property at Lettercau and on the landscape of

the county. • The development is not comparable to the impacts of existing human

interventions such as dwellings or forestry on the landscape. • Four of the 18 no. total steel angle masts will be located in this local area, which is

unfair. • There are dwellings missing from the maps of residential visual impact and the

assessment of such impacts is inaccurate. • The development will impact on the landscape character of the area and its

associated walking routes and scenic roads. • There is concern about construction access and contractor behaviour. • Deficiencies in the maps and manner of presentation of information were raised. • A proper assessment of alternatives to the routing of the line through this area has

not been carried out The submission was accompanied by extracts from the application maps and by photographs. 18:23 Liam Miller See written submission. Points raised include: The development is not for the benefit of the people of this area but to facilitate windfarm development, which should pay the costs of undergrounding. The development has already given rise to stress for local people, which is accepted as having a negative impact on health.


Local people should not have to prove that the development will give rise to a cancer risk, as they are not the proposers of the development. This unnecessary development will impact on tourism growth. The impact of the development on the landscape and culture of the people who live there cannot be measured. 18:29 Moira Miller • Third parties are at a disadvantage, due to location of the hearing. The weight

given to third parties is inequitable. • The drawings are inadequate and exclude currently occupied houses, described as

ruined. Describing areas as urban areas undersells the impacts. • Cumulative landscape and health, impact of existing and proposed development

should be considered, particularly in Gweebarra area. The impact of existing manmade intrusions into the landscape would be exacerbated by the development.

• If the development does give rise to noise, despite evidence, what will ESB do? • The development will impact on REPS farming. • The SIA act is unfair to 3rd parties. • Health concerns arise from the use of creosote in poles. • Will the board engage consultants to assess the need for the development? • The permission sought will allow the applicants to relocate poles and angle masts

to meet their requirements. • The 1927 Electricity act need updating. • The costs of under-grounding would be reduced in this economic climate. 18:40 Sile Ui Gallachoir Ceist ar gá don forbairt toisc go bfhuil ísliú ar éileamh ar leictreacais. Ceistíodh caighdeán an RTT. Dochar don timpeallacht, cúrsaí turaseoireachta, daiseár do shláinte agus dí-lucaháíl tithe. See written submission. 18:56 Joan Hanlon See written submission. Points raised include: • There is a fear that the development will give rise to peat failure and landslides. • The habitats classification is deficient. • The development will cross and impact on extensive areas of blanket bog, which

comprise Annex 1 habitats. These areas are also archaeologically sensitive. • An Taisce consider that development should not be permitted on blanket bog. • The development will impact on tourism development, which is based on

landscape attractions and walking routes, as well as river based tourism. • The view from the Tullyard Road, which is part of a marked walking route, to

Lough Ananima is protected under the provisions of the development plan, which aim to protect views between roads and lakes.

• Views to Lough Ananima from the observers house should not be interfered with. Views in this area were identified as important in the previous inspectors report.

• In 2000, An Taisce deemed OHL to be unacceptable. Partial undergrounding was recommended.


• The assessment of visual impacts was inadequate. • The recommendations of the ASKON report are applicable to this county given

the weather and landscape conditions and the proposal should be undergrounded to address other impacts, including visual.

• Undergrounding is safer, more reliable,more environmentally friendly and more cost effective.

• Lough Ananima is a wildlife sanctuary in an NHA. • The development does not address the visual impacts on areas highlighted in the

previous inspectors report and should be rejected. • There have been no problems with electricity supplies in this area since the last

application / appeal. There has been no increase in population / industry in this time.

• There was no open public consultation prior to route selection and there was no agreement with the applicants as suggested.

• There is sufficient scientific evidence in relatin to EMF to apply the precautionary principle. The cumulative impact with further HV lines in the area should be considered.

• The development should be considered in conjunction with existing and proposed windfarm developments in the area, and the noise impacts arising therefrom.

• Maps contained in the application and provided at the hearing are incorrect, omitting large areas and features including Lough Ananima, parts of the owenea River and large numbers of houses.

• Concerns with public participation or transparency were expressed. • Deficiencies in the photomontages were identified. • The manner in which the information was presented and made available to the

public was inadequate. • Gortnacart school is quite close to the line and is not identified. • The development cannot interfere with turbury rights, which could not be

exercised safely under the lines. • The development will adversely impact on the integrity of designated sites,

particularly the West of Ardara / Maas Road SAC. The alternative of undergrounding would protect endangered species and habitats.

• Landscape and habitat protection is important to maintain tourism potential. • The development will render some areas barren of certain wildlife species. • A number of species protected flora and fauna have been recorded along the route,

including aviafauna. • The Marsh fritillary has been seen in the Tullyard area and this species was not

adequately considered in the EIS. • The development will potentially impact aquatic species including the freshwater

pearl mussel. • Conservation and preservation of rives and fish is necessary and essential. No

OHL should be permitted. • The Tullyard road is marked walking route and is not a cul-de-sac. • The development will give rise to construction and aeolian noise impacts on

residents, while construction activities will have traffic impacts. • Some people are more sensitive to the effects of windfarm development than

others. • The use of creosote presents health risk and a risk to waters. • Undergrounding would address the risk of overhead lines falling during stormy

weather.


• The values of the local people, which include the natural beauty, peace tranquillity of the area, as well as human and property rights, are not the same as the applicants.

• JH contended that the process was unfair and not transparent, referring to the provisions of the Arhaus convention. A lot of information was said to be not forthcoming.

• The applicants should provide proper maps and identify those persons residing along the route.

• Who is to take responsibility for the ill effects of overhead lines on property. 19:33 Eddie O’Donnell Queried what proposals there are to replace any tourism collapse arising from the proposed development. Were surveys of household water along the route carried out? Line should go to Burtonport, across old railway line, and underground to Arduns avoiding hills. There will be less demand for power in the future. Reconsider undergrounding. 19:41 Applicants Submission: Luan O’Braonain. • See written submission, which includes a suggested condition in relation to

alterations to location of individual structures. Additional comments include: • Need has been established by a number of submissions to the hearing. This is not

a repeat of the 2000 application. UGC was not identified as a refusal in that case. Both options are equally safe but operational performance not the same. Both have different impacts. Cost is a factor. Partial under-grounding presents a risk and only short lengths are permitted at the end of a circuit not at intermediate points.

• Water quality impacts are not significant and can be mitigated. UGC would have a greater impact.

• Devaluation of property is not a planning issue. • Copies of maps requested have been provided. The question is whether any

deficiencies in such maps affected observer’s engagement or assessment of the EIS. There was no intention to mislead and they do not affect the jurisdiction or function of the Board.

• No costs should be awarded. Hearing Closed 20:31 06/04/09


APPENDIX 2: Supplementary Reports: • Appendix 2 A : Landscape and Visual Impacts. • Appendix 2 B : Health Effects of the Proposed Development. • Appendix 2 C: Undergrounding. • Appendix 2 D : Flora and Fauna. • Appendix 2 E Planning Context Report


Appendix 2A LANDSCAPE AND VISUAL IMPACTS 1.0 EIS Impact Assessment: Section 4.1 of the EIS identifies the following criteria for the selection of line routes and substation sites: • Technical feasibility – physical constraints. • Residential amenity – proximity to houses and schools. • Environmental and physical planning constraints. • Concerns raised in previous ABP Inspectors report (May 2001). • Economics. Chapter 12 of the EIS deals with Landscape. The assessment of landscape impacts is carried out on the basis of the following landscape character areas. • Open Upland Hills and Mountains • Open lowland hills and lake landscapes • River Finn Valley. • Letterkenny fringe. • Gweedore finge. • Gweebarra River Valley. A level of landscape quality and sensitivity is attached to each character area. Factual descriptions of the landscapes types are provided, while a broad assessment of the magnitude of change and impact significance for each landscape character area is identified. I consider that, in considering the landscape impacts in terms of broad landscape character types, the EIS fails to adequately characterise and assess the specific local impacts of the development on the areas through which it is proposed to run. A separate assessment of visual impacts is carried out, which uses a ZVI to assess the area of influence of the development. The assessment is based on a residential visual impact assessment, an examination of road crossings and an examination of 24 no. selected photomontages. In relation to the assessment of impacts on residential properties it transpired at the oral hearing, that a number of residential properties along the route were not identified or included in that assessment, although revised submissions for sections of the line were submitted by the first party at the hearing. For the purposes of determining visual impacts on residential properties, however, the data presented can be regarded as a general guide to the assessed visual impacts of the development. In this regard the omission of houses, which presented difficulties for third parties, is not regarded as a fundamental flaw in the overall EIS. I have some reservations in relation to the assessment of visual impacts of the development, which I consider relies too heavily on point views identified in the photomontages and views from residential properties. At the oral hearing the first party indicated that the photomontage views were not intended to be comprehensive and were submitted to be representative of key views to allow impacts on other similar locations to be determined. I note, however, that in a number of cases the quality of the photomontage views contained in the EIS was poor and the views illustrated appear to be selective in a number of cases.


2.0 SPECIFIC ROUTE COMMENTARY 2.1 BINBANE – LETTERKENNY: Binbane sub-station is located approx. 8.5km south of Glenties and approx. 10.5km southeast of Ardara, on the R262. This is an existing 110kV station with a 38kV feed northwest toward Glenties and southwest to Killybegs. This station is fed by a 100kV line from Cathleen Falls, north of Ballyshannon, with two 38kV lines exiting the station site. There are a number of houses located adjacent to the sub-station. Leaving Binbane Sub-station, the proposed line crosses the R262 to the south which comprises part of the Alternative Bluestacks Way. Having regard to the nature of the existing sub-station infrastructure, it is not considered that the proposed works at the sub-station would have significant additional impacts on the visual amenities of the area. I note, however, the submission of adjoining residents, Coyle family, in relation to the development at Binbane. This submission raises concerns about the impact on the development potential of their landholding, rather than visual and landscape impacts. EM1 –AM19 The 1999 application proposed a new 110kV line northwest from the station over the shoulder of Binbane toward Sir Arthur’s Bridge and on toward Glenties. This route was considered to be unacceptable on grounds of visual amenity and impacts on a designated site. The current proposal runs southwest and west from Binbane to AM19. This area is characterised by undulating peatland and forestry plantations. There are extensive views across this landscape from the adjoining roads, however, the landscape is already traversed by double pole 38kV lines and is not regarded as being of high visual sensitivity. The most sensitive section lies between AMP16 and AM19 at Meenybradden, where the line passes close to the junction of two county roads, close to an existing dwelling. The EIS proposes planting of willow to screen Angle Mast 19 at Meenybradden (see Viewpoint 2 of the EIS), subject to the agreement of the landowner. The effectiveness of such screening for this angle mast, which is located close to the road, is uncertain, however. AM19 – IMP40 From AM19, the line runs northwest across undulating agricultural and forestry lands at Meeenybradden and Carrickatlieve, to AM37. These lands are situated at a lower level than the adjoining county road to the east and the proposed development would not constitute a significant visual element in the landscape. The route crosses the county road at IMP40, which structure would occupy a relatively prominent position on the approach from the southwest. The relocation of this structure further away from the road edge would be restricted by the boundaries of the adjoining SAC site (Lough Nillan). Existing coniferous planting to the north would aid the assimilation of the remainder of the line, however. IMP40 – AM60 From IMP40 the line crosses a low hill and enters a shallow valley running north to Snugborough / Gortnacart Glebe. Landform in this area will aid in the integration of


the line into the landscape, which is traversed by existing electricity lines. The line crosses a local road at Gortnacart. The line traverses the side of Crocknaslowra hill before crossing the Owentocker River at Kilrean Lower, just south of the N56 (Ardara – Glenties). IMP59 will be located immediately alongside the N67, however, the topography of the area will reduce its prominence, particularly if travelling east along the N56. I do not consider that the landscape impacts of the development will be significant, having regard to the undulating topography and varied landscape in this area. AM60 – AM78 The line turns northeast at AM60 toward Glenties, traversing low-lying ground and forestry as far as Tullyyard and Lough Ananima, crossing the Owenea River. The route crosses the Bluestack Way walking trail in this area. The route of the line in this area is generally similar to that proposed in the 2000 appeal to the Board and was then considered to have adverse visual impacts. A number of wooden pole sets will be sited to the northwest of the local road at Tullyard. Three polesets will be sited in the area between Lough Ananima and the local road, located approx. 109m from the lakeshore. The EIS does not consider the Tullyard area in detail. The area is generally referred to as being of medium quality and high sensitivity, however the basis for the application of a “low magnitude” resource change is not set-out. The routing of the line through Kilrean and Tullyard and the constraints on the route choice were discussed at the oral hearing and witnesses for the first party described the area as being of high quality and high sensitivity. The development plan states that, development proposals situated on lands between roads and lakes or rivers shall be considered on the basis of the following criteria: • Importance value of the view in question. • Whether the integrity of the view has been affected to date by existing

development. • Whether the development would intrude significantly on the view. • Whether the development would materially alter the view. The plan notes that a reasonable and balanced approach shall be implemented to ensure that the policy does not act as a blanket ban on developments between the road and the sea, lakes and rivers. Views toward Lough Ananima are not identified specifically for protection in the development plan. I note the third party submissions relating to this section of the line. I would comment, however, that the visual impacts are restricted to a relatively short section of road and that this section of the development will not have longer or wider landscape impacts. The visual impact in this area is not regarded as being unduly significant. While I consider that the development will have visual impacts in this area, I am of the opinion that the overall route constraints, including the fixed location of Binbane Station and presence of designated sites in the area, are such that alternative route options are likely to have similar, or greater visual and environmental impacts. AM78-AM93 From Lough Ananima, the route traverses coniferous woodland, passing southeast of Lough Kip and traversing the N56 northwest of Glenties. Existing overhead lines traverse this area. The route then crosses an area of relatively low lying ground at


Stranaglough. This area is not of great visual sensitivity and I do not consider that the development would have unacceptable visual impacts on this area. AM 93- AM 114 From AM93 the route turns north east and climbs toward Meenalargan and Straboy Hill, crossing one county road. The route then traverses the contours of Straboy Hill as far as Shallogan Bridge. The landscape and visual impacts of the development at this location were identified as being of concern at pre-application consultation stage. I note that the impact of the development on a housing development site, owned by Pat McGill, at Meenalargan was discussed at the hearing. The alternative route suggested to overcome development impacts would result in the route traversing higher ground and having greater visual impacts that the proposed route. I do not therefore favour the alternative route option considered in this regard. The landscape assessment in the EIS fails to note that the route crosses an area of Open Upland Hills and Mountain, at Straboy and only considers that this landscape category occurs between Tievebrack and Letterkenny. Section 12.3.11 of the EIS describes this landscape category as having a high sensitivity to change. The route between Meenalargan and Shallogans is exposed and visible over considerable distances, particularly from the R250 to the southeast. A number of alternative route options were examined in this area, which are identified in Figure 4.8 of the EIS – Glenties Route Variations. The route originally examined by the applicants ran along the lower ground from Stranalough, parallel to the R250 to the southeast and the ridgeline to the northwest. This route was altered following local consultations and directed up and along the hillside. In terms of visual amenity, this route alteration results in significant additional visual impacts. The reduced visual impact of the route originally selected is acknowledged in the EIS and in evidence presented at the hearing. I consider that the linear nature of the development crossing the hill would be detrimental to the visual amenities of the area, particularly when viewed from the R250. It would also have significant local impacts where it crosses the local road at Meenalargan. Photo view 6, contained in the EIS refers to this section of the line. Having regard to the above, I cannot agree with the EIS assessment of the impact of the development on the area as slight / moderate. I acknowledge, however, that the revised route may result in lesser impacts on views southeast from the local road at Meenalargan, although traffic volumes on this road are low. AM114 – AM124 (Tievebrack Switching Station) As noted above the line will descend from Straboy Hill to Shallogan Bridge and will feature in views from the R250 travelling west. The visual impacts of the development would be increased by the routing of the Tievebrack – Ardnagappary line through this area. The EIS (viewpoint 8) suggests that no significant visual impacts will occur. I do not concur with this assessment and consider that the cumulative impact of this line must be considered with the Ardnagappery-tievebrack line which will also traverse this area. The line travels southeast from AM114, crossing the R250 and descending to forestry adjacent to the Shallogan River. The route turns southwest through forestry to reach the site of the sub-station. South of the R250, I do not regard the visual impacts of the development in this area as significant.


Tievebrack Switching Station The site of the switching station comprises an area of blanket bog, adjoining coniferous woodland. Lands in this area fall north to south toward the Stracashel River. Lands on the southern side of the river are in forestry use and large areas have recently been cleared. The proposed switching station will not itself be visible in wider views from the north, east or west. I note that the photomontages submitted with the application fail to adequately identify the visual impacts of the station at this location. I do not, however, consider that the development will have significant wider landscape impacts. The station will however, by its nature be a locally significant feature. At the hearing, an alternative planting mix was proposed in order to obviate some of the third party concerns regarding the impacts of the station. These proposals may go some way toward mitigating the local visual impacts of the development, however, such landscaping should be appropriate to the landscape and setting of the site. AM125 – AM156 On leaving the switching station, the route follows the enclosed Stracashel river valley as far as Graffy Bridge. While there are a number of dwellings in this valley, much of the route runs through coniferous forestry and would not be visually intrusive. At the western end of the valley, the line climbs the shoulder of Stralinchy Hill, in which area there will be skyline impacts. These impacts will be local and will be restricted by the topography of the area. AM156 – AM180 From Graffy Bridge the route follows the Stracashel River Valley east, to Clogher East. At Clogher North, west of Boultypatrick, the line crosses Sli na Finne, part of the Ulster Way. There are a number of dwellings in this valley along the road to the southeast of the line. Topography, vegetation and field boundaries break up the landscape of the valley, mitigating the impacts of the development. The landscape impacts on this area are not considered to be unacceptable. AM180 – AM212 From AM180 the route enters a shallow open valley, northwest of Boultypatrick, through which the Glasagh River flows in a northeast direction. The open and homogenous nature of the landscape of the valley is less able to accommodate linear features such as this development, however, the line will be located at a lower elevation than the road to the northwest and there is an existing overhead line running through the valley. These powerline routes should rationalised, where possible. While the development will have a negative impact on the landscape character of this area, I do not regard the overall impact of the development to be unacceptable. At the north-eastern end of the valley, the route turns northwest and crosses a large coniferous plantation, emerging to cross the Stranagoppogue River and two local roads at Montymeane. The development would have locally negative impacts on the visual amenities of this area, particularly due to the proximity of polesets to public road, in particular IMP207. I note that the boundaries of adjoining designated sites may restrict the possible relocation of this structure away from the road, however.


From IMP209 to AM212 the route crosses areas of pasture, falling north toward Lough Shivnagh. Where possible IMP210 should be relocated further away from the road. I note that photomontage no. 10, is incorrectly identified on map 12.1 of the EIS. AM212 – AM220 This section of line follows the route of the disused railway along the southern side of Lough Shivnagh. Such development should not have significant impacts on the wider landscape character, due to rising ground to the south. From AM215 the route turns north, crossing the River Finn, west of Lough Shivnagh, and the R252 on the northern side of the lake. IMP217 is located between two houses on this road. Given the backdrop and spacing between support structures, the impact at the river crossing may not be considered unacceptable. Separation from the house to the west of ST217 is approx. 75m and the impact on this dwelling is likely to be significant. The route climbs from the road toward the low ridge to the north toward Tievedeevan, into what is designated in the County Development Plan as an EHSA. The route will have skyline impacts in views from the south, which are considered to be significant. Travelling northeast along the R250, the line largely retains higher ground in the background, which would reduce the impact of the line. AM220 – BP233 This section of the line is designated as an EHSA in the development plan. The route initially follows a small river valley, before rising toward an immature coniferous plantation at Tievedeevan. When viewed from the north from the R250, the development would have skyline impacts as it crosses Tievedeevan, however, the impact of the EHSA crossing will be reduced by existing forestry. The development plan indicates that within an EHSA there may be small pockets which do not fully meet the definition of that landscape designation e.g. where coniferous afforestation has occurred. Similarly the plan indicates that public development within the EHSA’s will be facilitated where it occurs within the identified infrastructure corridors. From Tievedeevan the route falls toward the Cummirk River at Kingarrow, where there is a cluster of dwellings. The impact of this section of line is not regarded as unacceptable. BP233 – AM265 From Kingarrow, the route rises toward an extensive area of blanket bog, at Meenatinny, which is broken by large areas of coniferous woodland at Meenirroy. The line will again cross a section of Sli na Finne at Meenatinny, northeast of Kingarrow.Large scale felling works are underway at Meeniroy. New coniferous planting at Meenatinny will aid in the assimilation of the line into this area over time. Photo Viewpoint 13, supplied by the first party, demonstrates the long range landscape impacts of the development on views travelling south along the R250, which I regard as significant. There are also likely to be skyline impacts on views from the R250 at Meeniroy. The linear nature of the route crossing the homogenous rounded slopes of this area would have a detrimental impact on visual amenities, particularly when viewed from the north, however no angle masts are proposed within this section of the line. I note that alternative routes were considered in the EIS for


this section of the line. Route Option A6 was apparently ruled out following consultation with Donegal County Council. I note that this route would involve greater crossing of designated sites and EHSA landscape and would not follow the infrastructural corridors identified in the development plan. The route crosses Meeniroy Bog travelling north to Altinierin. The visual amenities of this area are degraded by the extent of coniferous forestry undertaken to date. These mature trees are currently being felling. I do not consider that the northern part of this section will have significant negative impacts. AM265 – IMP279 The route turns southeast from Altinierin toward Tullyhonour. This section of the route is not highly visible from wider areas. Topography and the varied nature of the landscape reduces its sensitivity. At Tullyhouour, the route passes close to a number of dwellings and where the route crosses the local road, there will be some local impacts. IMP279 – IMP312 From Tullyhonour, the route crosses a small elevated river valley, to an upland area centred around Lough Deele and Cark Mountain. This area is characterised by coniferous forestry on blanket bog and a high concentration of wind energy developments, particularly south of Lough Deele. These wind turbines are the dominant visual features in this area. Topography, combined with forestry and wind energy development, ensures that the impact of the development views east from Tullyhonour will not be significant. Lough Deele is an attractive mountain lake in an area of blanket bog, with views to Errigal. This landscape is not designated for scenic amenity in the development plan the area to the south and east of the lake has been subject to extensive wind turbine development. While the development will impact on the character of the lake, this is not a pristine landscape and the line will not be the most dominant feature in the area. East of Lough Deele, the route follows a shallow river valley through forestry plantation and rough pasture to a local road at Ballystrang. While the line will feature in views from the east, windfarm development will continue to dominate the landscape and it is not considered that the development would have unacceptable visual of landscape impacts on this area. IMP312 – IMP336 This section of the line crosses Ballystrang. Although crossing elevated ground, the skyline impacts will not be significant due to the existing wind turbines on this hill. AM321 is located adjacent to a rough forest track which is not subject to significant traffic. From Ballystrang the route passes along the northern side of a low ridge, which varies between rough low vegetation and coniferous forestry. An existing double-pole 38kV line runs parallel to part of the proposed route. It is not considered that this section of line would have significant negative visual impacts. The local road at Stralongford appears to be a relatively busy route, connecting the R250 with the N13. The proposed line crosses this road into an area of forestry to the east. While the line will be visible to the west of the road, I do not regard such local impacts as unacceptable. IMP336 – AM345 / Letterkenny Substation


The route traverses an area of upland blanket bog which is relatively heavily forested. While sections of the line will be visible, set against the backdrop of forestry and having regard to the proximity of the development to Letterkenny, the landscape impacts of the development would not be significant. Approaching Letterkenny sub-station from the south, the route follows a low ridge. Other existing 110kV lines are evident on the landscape, approaching Letterkenny from the south. No significant impact on views from the N13 are envisaged. Letterkenny Substation This is a large substation, with 2 no. existing 110kV lines accessing the station from the south. Leaving the station, the proposed route passes close to an existing dwelling to the west. Having regard to the extent of existing infrastructure in the area, it is considered appropriate that the line be adjusted to maximise separation from that dwelling. The additional impacts arising from either the line or the modifications to the substation are not considered to be significant, however. 2.2 ARDNAGAPPERY – TIEVEBRACK In relation to the Ardnagappery – Tievebrack line in particular, it is noted that development in the county is concentrated on the low-lying western coastal areas. The intensity of development decreases rapidly as one moves east, toward rising ground, which is largely undeveloped and of scenic value. Ardnagappery Sub-Station The proposed sub-station at Ardnagappery is located approx. 2km east of Bunbeg, on the northern side of the R258. Lands are generally flat and are comprised of low-lying peatland. To the west of the site is Gweedore Business Park. Lands to the east and north are currently undeveloped. There are proposals to develop a wastewater treatment plant to the north of the site and for the extension of the business park in this area. There is detached housing along the regional road to the south. Existing 38kV lines run east-west through this area to the existing Derrybeg sub-station, located northeast of the sub-station site. Reference to forestry to the east of the substation site, contained in section 12.5.2 of the EIS is inaccurate. This general area was previously identified as an appropriate location for a sub-station in the 2000 appeal file and I would generally concur with this assessment. I note the submissions of the third parties regarding the visual impacts of the development on the amenities of the area and of properties therein. Having regard to the pattern of development in the area and the set-back of the development from the public road, and subject to appropriate planting, design and layout, I do not consider that the proposed sub-station would have undue or significant negative impacts on the landscape or visual amenities of the area. EM1-AM13 On leaving the sub-station site, the route travels east, crossing the regional road (R258) between IMP4 and BP5. The road crossing is located close to the existing 38kV crossing and adjacent to a two-storey, commercial premises on the northern side of the road. There are existing views toward Errigal from the regional road, however, subject to the relocation of IMP4 away from the road and having regard to the pattern of development in the area, I do not consider that these impacts would be unacceptable.


To the south of the R258, the line traverses a low-lying area adjoining the Clady River, which is traversed by existing double-pole 38kV lines. The route runs parallel to the river for a stretch, south of a County Council depot, before crossing the river between IMP6 and IMP7. It is not considered that the development will have significant negative visual impacts on the area. Between AM11 and AM13, the line crosses the canal, which runs between Lough Nacung and the power station to the southwest, and the N56. The crossing is located immediately west of the existing 38kV crossing and will require the removal of an area of coniferous planting on the northern side of the canal, increasing the prominence of this power corridor in views north from the N56. Photomontage 16 contained in the EIS fails to adequately consider the principle visual impacts of the development in this area and I refer to the photo contained in Eileen McCole’s oral hearing submission in this regard. The N56 generally travels in a northerly direction before turning east for Gweedore at Arduns. While longer views to the line may be restricted by the alignment of the N56 in this area, there are clear views to Errigle in the vicinity of the proposed road crossing. The impact of the development in this area is not reflected in the photomontage views submitted with the EIS. I note the suggestion by third parties that Angle Mast 13, on the southern side of the N56, be replaced with a braced wooden pole-set. Such a measure would reduce the impact of the development on views from the N56, however, the angle at the change of direction is too severe to accommodate a braced pole-set and revision to the overall line layout may result in significant additional impacts in this area. I do not therefore consider that this suggestion could be accommodated within the development. AM13-AM39 From the N56 crossing, the line travels south across an area of extensive open peatland, which initially rises slowly to the east, to Grogan More. There are detached houses on the northern side of the N56 in this area. At the hearing the applicants suggested that this area is not highly visible or of interest to those travelling on the N56, however, I would not agree with this contention. The area traversed by the line is open to views from the N56, between Arduns and Crolly, with Errigal just visible in the background. The slopes of Grogan More are a prominent feature in this area, above the settlement of Crolly, and comprise part of the landscape area classified as Open Upland Hills

and Mountain. The applicants suggest that routing the line along two small stream valleys will restrict visibility in this expansive landscape and that the design has minimised potential impacts. The landscape assessment in the EIS does not appear to reflect the designation of this area as an EHSA in the County Development Plan, although it does note that avoidance of this landscape would have been preferable. The Development Plan does indicate, however, that public development within the infrastructure corridors will be facilitated. The description of viewpoint 17 in the EIS understates the dominant position of Grogan More in this location and I disagree with applicant’s assessment that the poles would not comprise prominent features in this view. The linear nature of the line contrasts sharply with the generally undisturbed and open nature of the hillside. I regard the visual impacts of the development at this location as significant. Southeast of Crolly, the route traverses the western slopes of Grogan More into an enclosed valley at Cronaguiggy. Development in this valley includes houses, water


treatment works and a church. Part of Sli na Rossan runs along the road through the valley. At the southern end / head of this valley, the road passes through a narrow gap. In this area the proposed line runs alongside and traverses the public road, breaking the skyline, with significant local visual impacts. Section 4.15 of the EIS states that the selected route options avoid significantly built up areas. It notes in particular that the location of housing in the Crolly area posed severe constraints along this section of route and necessitated locating the line within the periphery of the area of EHSA at Grogan More. I note that no analysis of a route option to the west of the N56 at Grogan More is provided in the EIS. Such route option would avoid significant visual impacts on intact upland areas, including Grogan More. Such a proposal would route the proposed line through the already significantly developed, and visually eroded, lowland area between the N56 and the sea. The impacts arising from the relocation of the route would need to be analysed, however, I note that a route to the west of the N56 was considered in the 1999 / 2000 application but appears to have been discounted due to proximity to housing development. AM39-AM52 From AM39, the route descends southwest toward Lough Anure, through Meencorwick and Bunawack. This area is classified as, Open Lowland Hills and

Lakes, and the EIS indicates that undulations in this exposed landscape restrict visibility of the line. This landscape unit comprises a largely empty area of blanket bog with extensive views to the west. I regard this as an important landscape resource, which should be protected from the encroachment of further development. The linear nature of the development would be out of character with this relatively homogenous landscape unit. Views northeast from the local road on the eastern shore of Lough Anure will be significantly affected by the development, although this is a lightly trafficked route. I note that photomontage / Viewpoint 18 in the EIS across Lough Anure, was taken from a local road to the north of the N56, rather than from the N56 at Lough Anure, which view is listed for protection in the development plan. The separation of the view from the proposed development would, however, mitigate the impact of the development thereon. AM52- AM64 At Lough Anure, the line turns south toward Lettercau, to the rear / west of an existing dwelling. AM52 would be located approx. 90-100m from the nearest dwelling in an area of open landscape. The line runs parallel to a local road, rising over a local high point into an area of more complex topography and vegetation at Lettercau. The landscape is more intimate and complex than that further north and may therefore have greater capacity to assimilate certain developments. At the oral hearing the applicants confirmed that existing trees could be retained in this area through the use of an amended pole-type to increase the height of the line. From AM58, the route turns west climbing a low hill and running between two houses. I consider that there is likely to be significant visual impacts on the amenities of these houses. This is reflected in the residential visual assessment contained in the EIS. The line then traverses a shallow valley to the west before crossing a local road north of Lettercau school.


The manner in which the route passes through this area would result in relatively significant impacts on its character. In particular I refer to the changes in direction requiring additional angle masts and resulting in a sense of enclosure of the area. It is noted that 18 no. angle masts, which have a greater visual impact than wooden polesets, are proposed on this line. Of these 18 no. angle masts, 4 no. are located in a relatively short length of line at Lough Anure and Lettercau. AM64-AM80 At AM64 the route turns south. This section brings the route through a well-preserved upland area over Croagh Patrick, toward Crovehy and Cloghernagore bog, traversing walking routes and local roads, which are signposted locally as a scenic drive. Development in this area is limited to a small number of houses and farm holdings and the landscape is generally undisturbed. I regard this upland are as an important and attractive landscape element. The EIS describes this landscape category, Open Hills and Mountain, as Exceptional and of high sensitivity, while the impacts of the development are described generally as moderate negative. No specific assessment of the impacts on this area is carried out, although the EIS suggests that routing along a stream valley will mitigate the impacts of the development. I have serious reservations regarding the encroachment of development into this upland area. In relation to this area in particular, I consider that the EIS has failed to adequately consider the landscape impacts of the development. I note however, that the route proposed in 2000 traversed the lower lying area to the west of the current route around Lough Craghy, and was considered to have significant landscape impacts on that area. AM80-AM96 From AM80, the route descends toward the N56, south of Dunglow. Along this stretch, topography will reduce the overall impact of the development. The line crosses a river and the N56 at Meenleckanore, which road crossing will be relatively prominent. Travelling west along the on R252, the line will be highly visible as it rises to the west of the national secondary road. The extent of forestry shown on the 1:250 route maps to the west of the N56, discussed at the hearing, comprises new immature forestry plantations, which may in time mitigate the impacts of the line. The crossing of the N56 will be relatively conspicuous and will be seen in conjunction with the impacts of the development further south on the western side of the N56. AM96 – AM122 From Meenleckanore, the route travels south across Crockmeenleckanore, roughly parallel to N56. This low rounded hill is currently afforested and the existing 38kV line is provided with a prominent corridor through such forestry. The proposed development would run parallel to that line and require another similar power corridor through this forestry. The line crosses the Owenmarve river and rises toward Drumlaghdrid. Existing 38kV lines cross the N56 from west to east in this area. The proposed route continues further south along the western side of the N56 to Angle Mast 115 before crossing the national secondary road. The N56 is the main tourist route in this area. The area to the west of the N56 at Drumlaghdrid was highlighted as visually sensitive in the previous 2000 appeal case


and at pre-application stage in this process. It is a prominent area of open bog / moor on the N56 and one which is characteristic of the landscape of this wider area. The development will have a fundamental impact on the landscape character and is considered to be inappropriate. I refer to Viewpoint 21 of the EIS in this regard and in particular the skyline impacts of the line and AM115. No attempt to mitigate the visual impacts in this location are identified. Questioning at the oral hearing did not reveal any strong basis for not rationalising the route, and road crossing, with the existing 38kV line in this area. The applicant’s witnesses agreed that in terms of visual amenity, such measures would have reduced the visual impact of the development. AM122- AM140 From AM122 south, the line crosses an area of more complex topography and vegetation, before entering a the open bogland area at Boyoughter. Views into this section of the route from the N56 are limited. At AM131, the line turns southeast across Boyoughter bog, south of Lough MacHugh, toward the Gweebarra River Valley. This is an open area crossed by existing 38kV lines, however, the two lines would be separated by between 100m and 300m in this area. Having regard to the route constraints in this area, I do not consider the visual impacts of the development to be unacceptable. AM140- AM152 This section of line includes the crossing of the Gweebarra River and a section of line through forestry at Cloghercor. The proposed river crossing is located to the east of an existing 38kV crossing of the river. I note that photomontage / viewpoint 22 of the EIS does not adequately portray the impact of the development in this location. The EIS notes that existing lines crossing the Gweebarra River reduce the level of resource change arising from this development. There is extensive ribbon development on the local road at Galwolie, on the north-western shore of the river, and views to the river from the road are limited. On the southern shore, the line traverses an area of forestry plantation. The route will be likely to result in the removal of the north-eastern edge of this plantation. Viewed from the northwestern side of the river, the actual crossing may not be a significant feature, however, the approaching support structures from the south would be intrusive features on the landscape. Viewed from the southeastern shore, the line will traverse a relatively undeveloped area, before crossing the river to an area subject to increased levels of residential development. The local road on the southeastern side of the river occupies an elevated position relative to the proposed river crossing and in this context it is not considered that the crossing itself, would feature prominently in views therefrom. I do not consider that the proposed development would feature significantly in views from the N56 bridge to the west of the proposed crossing, which view is protected in the development plan. The EIS notes that rationalisation of lines at Gweebarra crossing would be of benefit in terms of visual amenity but that the actual impact of such rationalisation would be slight. At the hearing it was confirmed that no specific proposals in this regard had been considered but that such measures would be likely to involve some undergrounding of existing 38kV lines.


AM152-EM176 / Tievebrack Switching Station The line traverses an area of coniferous forestry as it climbs the lower slopes of Gaffaretecor, on the shoulder of Gaffarretemoyle. The EIS classifies this area as Open Upland Hills and Mountain. Crossing the shoulder, the route will break the skyline, before descending toward R250 at Shallogan Bridge. I would regard this as a highly sensitive landscape and consider that the proposed development would be an inappropriate linear intervention thereon. I note that the inspector’s reports in 2000 identified impacts on this area as being of concern. Descending toward Shallogan Bridge, the impact of the line would be increased by the cumulative impact with the Binbane-Letterkenny line, approaching from Straboy. Viewed from R250, approaching from the northeast, the lines would have a significant impact on the character of this expansive landscape. In relation to the Binbane-Letterkenny line, I have already noted possible alternative route options which would reduce the cumulative impacts on this area. Crossing the R250 and the Shallogan River, the line descends through forestry toward the switching station, without significant visual impacts. 2.3 Conclusion: The proposed development comprises the erection of overhead powerlines with associated support structures across approx. 100km of County Donegal. I note that the landscapes traversed by the proposed development are varied in terms of their scenic and landscape values, as well as the degree of human intervention. Sections of the route traverse areas which already accommodate powerline infrastructure. Such existing infrastructure may in some cases, reduce the visual impacts of the development or may result in unsatisfactory cumulative impacts, depending on the qualities of the landscape and routing of lines. It is clear, however, that it would not be possible to provide development of the nature proposed without some visual impact. The alternative of undergrounding, is considered elsewhere in this report, however, it is noted that addressing visual impacts through such a measure is likely to give rise to different issues. Avoidance of impacts can otherwise be achieved by re-routing the lines. Such alternative routes would be likely to place the proposed lines within or closer to more developed areas in a number of cases and I note that an alternative line was previously rejected in 2000. The visual impacts arising from such development must be viewed against the necessity for such infrastructure in order to support community and economic activity generally. The assessment of the overall need for this project is contained elsewhere in this report and the strategic context in which it must be viewed. It is also worthy of note that the proposed development is to be carried predominantly on wooden polesets, with steel angle masts provided at significant changes in direction. There is a significant difference between steel pylons, which are used to carry higher voltage lines, and wooden pole structures proposed in this case, in terms of their visual impact. This relates both to the size of the structures and to the effect of time on the materials used. Wooden structures are considered to have a significantly reduced impact over steel pylons.


Donegal is a highly scenic county, with development largely concentrated on the periphery of the county, while the central areas of the county generally comprise upland / mountainous areas. The current County Development Plan identifies areas of Especially High Scenic Amenity (EHSA). There is no other landscape designation and large parts of the county are not covered by such designation. The proposed route crosses designated EHSA’s at two locations,. • At Tievedevan on the Binbane – Letterkenny line (approx. 2km). • At Grogan More on the Ardnagappery – Tievebrack line (approx. 3km). It is useful to compare the current landscape designation map with those produced in the previous, County Development Plan in 2000. That plan identified three categories of landscape. The current EHSA’s account for the Category 3 landscape. I note however, that much of the remainder of the western half of the county was identified as a Category 2 landscape and was therefore of some merit. In their previous decision in 2002, the Board referred to the extent of the line crossing category 2 landscapes. The conclusion to be drawn therefore, is that avoidance of EHSA’s does not imply avoidance of landscapes of visual interest. In relation to the Binbane and Letterkenny line, there are a number of areas where significant impacts are envisaged, in particular: • Tullyard • Straboy Hill. • Meeniroy, Meenatinny – Tievedeevan. Impacts at Tullyard are acknowledged, however, the line routing in this area is subject to conflicting requirements and constraints. I consider that in the overall context of this line the relatively local impacts of this line in this area are acceptable. The routing of the line at Strahboy has been discussed earlier and it is noted that, in terms of visual and landscape impact, the route originally considered by the applicants would have less impact that the route proposed in the application. The area of greatest landscape and visual impact would be an approx. 4km stretch of line in the area of Meeniroy, Meenatinny – Tievedeevan. This area is not, however, designated as an EHSA in the County Development Plan. I note also that in the previous (2000) County Plan, the area was designated as a category 1 landscape, the lowest landscape rating in that plan. The proposed route also follows the Strategic Infrastructure Corridor for ESB reinforcement identified in the 2006 County Development Plan. Alternative route options for this area which were examined in the EIS would likely involve similar or greater impacts than the proposed route. I would consider, however, that greater separation from the R250 at Meenatinny could be achieved, which would reduce the impact of the line on views from the road. In this context and having regard to the regional need for the project identified elsewhere in this report, the development is regarded as generally acceptable. In relation to the Ardnagappery and Tievebrack line, there area a number of areas of concern in terms of visual and landscape impacts. I consider the most significant areas of concern to be: • Shallogan Bridge to Cloghercor. • West of the N56 at Drumlaghdrid. • Crovehy – Croaghpatrick • Lettercau-Bunawack / Meencorwick.


• Grogan More. The landscape through which this line passes differs from that of the Binbane – Letterkenny line, being generally more open and without the benefit of screening topography. While this line is shorter than the Letterkenny line, it is considered that the cumulative impact of the proposed development in the areas identified above is such that this line would have significant adverse impacts on the visual amenities and landscape character of this part of County Donegal. I note that Gweedore business park has performed an important economic function in the past, retaining employment in this area. Its continued role in this regard would necessitate ongoing support and infrastructural improvements. The reinforcement of such infrastructure would be in accordance with the policies of the development plan and with regional and national economic policies. Such support should not, however, result in significant adverse environmental impacts. I consider that the proposed routing of the Ardnagappery-Tievebrack route would result in significant adverse visual and landscape impacts, which would not appear to be offset by the economic or community benefits to the area at this time. In considering the economic arguments, regard should also be had to the long-term local economic benefits arising from the quality and accessibility of the landscape as a resource. This can be regarded as a sustainable and location specific resource, whose economic value is recognised in the NSS and is considered to be worthy of protection.


Appendix 2 B HEALTH EFFECTS OF THE PROPOSED DEVELOPMENT 1.0 Electric and Magnetic Fields Concerns regarding potential health effects arising from the proposed high voltage line are raised in many of the observer submissions on the application. Many of these submissions refer to specific reports and studies into such effects. 1.1 Policy Review I note that similar issues were considered in the previous planning application and appeal in relation to a 110kV development in Donegal in 2000. In that instance, Mr. Don Menzies, advised the Board on the potential health effects of the development. Since 2000, a number of reviews and policy documents have been published which provide a better context for the consideration of these issues. I have identified these below and outlined briefly some of their conclusions: 1.1.1 Report of the Expert Group on the Health Effects of Electromagnetic Fields,

Dept. of Communications, Marine and Natural Resources (March 2007). This report was compiled by a group of experts on EMF, established and funded by the Dept. of Communications, Marine and Natural Resources. The report provides science-base information on non-ionising radiation, with particular reference to EMF. It includes recommendations to Government on how best to deal with EMF and planning issues. The report notes that the conclusions of the expert group are consistent with those of similar reviews conducted by national and international agencies. Chapter 3 is presented in the form of responses to a series of questions, with supporting information following. Question 2: Are there any harmful health effects from living near power lines and using electrical appliances? Response: The International Agency for Research on Cancer (IARC) concluded, on the basis of limited evidence in humans that ELF magnetic fields are a possibly human carcinogen. This does not mean that ELF magnetic fields are actually carcinogenic, simply that there is that possibility. Epidemiological studies into the association between ELF magnetic field exposure and childhood leukaemia are insufficient either to make a conclusive judgement on causality or to quantify appropriate exposure restrictions. Apart from this there are no other identified harmful health effect from ELF exposure, where such exposures are below the international limit Observing International guidelines (ICNIRP,1998; IEEE, 2004) provides adequate protection against established acute effects. Question 5: Is electromagnetic hypersensitivity (EHS) caused by exposure to electromagnetic fields? Response: No. No studies have established that EMF exposure leads to the subjective symptoms reported by EHS individuals. Question 6: Why do reports of scientific studies often appear to reach different conclusions on EMF health effects?


Response: Three main reasons: o Studies that report positive findings will always receive more publicity than

reports whose findings are negative. o Studies whose findings are negative face more difficulty getting published in

scientific journals. o Differences in the results of broadly similar scientific research are to be

expected, given differences in study methodology, analytical techniques and the experience and expertise of the researchers involved.

Science advances on the basis of weight of evidence as represented by studies published in the most authoritative (peer-reviewed) journals. This weight of evidence is not necessarily reflected in popular reports. Question 7: The ICNIRP guidelines apply only to short-term exposure. How can they protect against long-term exposure? Response: When the ICNIRP guidelines are drafted, the totality of the scientific evidence is assessed. Studies on both short-term and long-term exposures are evaluated to reach conclusions on health effects. Only short-term acute health effects have been established by the scientific evidence. However the ICNIRP limit values apply to all exposure situations, including long-term exposures. The lowest established threshold levels for an adverse health effect become the basis of the guidelines. To allow for uncertainties in science, this lowest threshold level is reduced further to derive the limit values for human exposure. ICNIRP reduces the level of the threshold by 10 times for the occupational limits for workers and by 50 times to arrive at the exposure limits for the general public. Question 8: Should precautionary measures be adopted in relation to EMF exposure? Response: There is no doubt that the prudent use of precautionary measures would help reassure many in Ireland who have concerns over EMF exposure. WHO’s EMF Project has been working to develop guidance for Member States who want to adopt precautionary measures and it is hoped these will be available soon. Given that there is still uncertainty about whether long-term exposure to ELF magnetic fields could cause childhood leukaemia, use of precautionary measures to lower people’s exposure, that are low or no cost, would therefore appear to be warranted. Chapter 4 presents a Science Review. Section 4.2 notes that a number of authoritative reviews, undertaken in this area since 1996, all agreed that there were no established adverse health consequences arising from exposure to ELF at levels below the limits set out in the ICNIRP 1998 guidelines. IARC, a specialised WHO agency established to investigate cancer risks, classified ELF magnetic fields as a “possible human carcinogen”. This denotes an agent to be one for which there is limited evidence of carcinogenicity in humans and less than sufficient evidence of carcinogenicity in experimental animals. This classification is the weakest of the three categories used by IARC to classify potential carcinogens based on published scientific evidence. Following the classification by IARC of ELF magnetic fields as a possible human carcinogen, ICNIRP issued a statement indicating that the evidence for these fields causing leukaemia in children was too weak to recommend any changes to their


exposure guidelines (ICNIRP, 2001). The European Union has also continued to recommend and use the ICNIRP. 1.1.2 Environmental Health Criteria 238: Extremely Low Frequency Fields,

World Health Organisation, (June 2006). This report represents the collective views of an international group of experts and addresses the possible health effects of exposure to ELF electric and magnetic fields. It’s main objectives was to review scientific literature on biological effects. Summary and recommendations of the report include the following points: • None of the direct mechanisms considered appear plausible causes of increased

disease incidence at the exposure levels generally encountered by people. • Evidence suggests that hypersensitivity symptons are unrelated to EMF. • There is inconsistent and inconclusive evidence that exposure to ELF electric and

magnetic fields causes depressive symptoms or suicide. Evidence is inadequate. • Data does not indicate that ELF electric / magnetic fields affect the

neuroendocrine system in a way that would adversely impact on human health. • Evidence for an association between ELF exposure and Alzymers is inadequate. • Evidence does not support an association between ELF exposure and

cardiovascular disease. • Evidence for an association between ELF exposure and effects on the immune or

haemotological system is inadequate. • Evidence for an association between ELF exposure and developmental and

reproductive effects is inadequate. • No studies published since the IARC review in 2002 change the classification of

ELF magnetic fields as a possible human carcinogen. • A causal relationship between magnetic field exposure and childhood leukaemia

has not been established. Where assumed to be causal, the incidence of cases would be very small and the impact on public health would be limited.

• Evidence supporting linkages between ELF magnetic field and diseases, including childhood and adult cancers, is much weaker than for childhood leukaemia.

• Exposure limits, based on scientific evidence, are essential. • Given the uncertainties regarding the link with childhood leukaemia, use of a

precautionary approach is warranted, without reducing exposure limits to an arbitrary figure. Such precautionary measures should be at a very low cost.

1.1.3 Information on Electric and Magnetic Fields, Eirgrid (Jan 2008) This is a general booklet produced by Eirgrid on electric and magnetic fields. • The electric field to which members of the public may be exposed from a power

line is strongest directly under the line where the conductors are nearest the ground. This is usually near the middle of the span between two adjacent support structures. By moving away from a power line the strength of the electrical field decreases rapidly.

• The normal maximum electric field strength at ground level 30m from the centre of the lines is 0.08kV/m for a 110kV line.

• Magnetic fields produced by power lines are strongest directly under the line where the conductors are nearest the ground. Typical magnetic flux densities at 30m from transmission lines are 0.2µT for a 110kV line.


• The method of construction of underground cables means that they do not produce external electric fields. An underground high-voltage cable will produce a greater magnetic field directly above it than an overhead line will produce at ground level.

• Magnetic fields fall more rapidly with distance to the side of UGC’s. Typical magnetic flux densities at 5m from underground cables in Ireland are 0.5µT for a 110kV cable.

• Transmission substations produce small fields with the maximum values generally occurring where the line(s) and/or cable(s) enter and exit the substation.

• Since the 1970s thousands of studies have been undertaken all over the world to assess any potentially harmful effects from power lines, electrical appliances and domestic wiring. Despite this no conclusive evidence has been found to date proving that electric and magnetic fields are harmful.

• In June 2007 the WHO EMF Task Group concluded that there are no substantive health issues related to ELF electric fields at levels generally encountered by members of the public.

• ICNIRP have produced reference levels for electric and magnetic fields. If exposure is greater than the reference level, this does not necessarily mean that the basic restriction is exceeded. An evaluation needs to determine whether the EMF levels are likely to induce a current density of 2mA/m2,i.e. to produce the basic restriction in the body.

• Calculations from Dimbylow in 2005, endorsed by the UK’s Health Protection Agency, show that an electric field level of approximately 9kV/m and a magnetic field level of 360µT corresponds to an induced current density of 2mA/m2. These figures can be considered to represent the basic restriction levels for EMF exposure and compliance with the ICNIRP restrictions can be assumed at those levels.

As can be seen above, there has been a considerable level of review of the potential health effects of electric and magnetic fields. The conclusions of these reports are consistent, in relation to the lack of evidence of any adverse health effects. I note the acceptance in a number of these reviews of the application of low-cost precautionary measures in the light of some uncertainties in relation to these effects. 1.2 Environmental Impact Statement: Section 6.2 of the EIS refers to electric and magnetic fields. Section 6.2.2.1 identifies the ICNIRP reference levels of 5kV/m and 100uT for electric and magnetic fields respectively. Section 6.2.2.2 predicts the field strengths for each length of the proposed development, based on normal operating criteria and on the carrying capacity of the conductor. Based on these calculations, it is apparent that the development will produce field strengths significantly below the international reference levels, even when measured directly underneath a line, which is operating at it’s maximum carrying capacity. 1.3 Oral Hearing: Dr. William Baily for the applicants made a presentation to the oral hearing in relation to Electric and Magnetic Field Issues. Dr. Baily responded to the observers


submissions on the potential health effects of the development, in particular outlining the need for a scientific basis to studies and reports referenced in submissions Deficiencies with many of the studies cited by the observers and the conclusions stated, were identified by Dr. Baily, with reference to published opinions from international bodies. The particular diseases and health effects identified by observers were also considered in this submission to the hearing. Dr. Baily opined that the development would be unlikely to change / increase long-term exposure to EMF, however, the separation of the line a minimum of 50m from house, on grounds of visual amenity, would reduce exposure to very low levels. At 50m from any part of the development, field levels under normal maximum operating conditions, would be 0.36% and 0.19% of the ICNIRP guideline reference levels for electric and magnetic fields respectively. Dr. Baily noted that the application of the precautionary principle has been considered in Europe, as ‘a political measure to take actions to maintain an “acceptable” level of risk for society, where “potentially dangerous effects deriving from a phenomenon, product or process have been identified and that scientific evaluation does not allow the risk to be determined with sufficient certainty.” The steps taken should be proportional to the perceived level of risk associated with the exposure. The WHO recommend that low cost measures / procedures be implemented to reduce such exposure. Dr. Baily also noted at the hearing that the European Commission asked the SCENIHR, attached to the Directorate-General for Health and Consumer Protection, to re-examine the safety of EMF. The conclusions and precautionary recommendations of the SCENIHR are reportedly the same as the WHO. Implementation of a corridor along a route as a precautionary measure was considered by HPA (Health Protection Agency) in UK in 2007, in response to the SAGE (Stakeholder Advisory Group ELF EMF) report. This noted that a corridor separating powerlines from houses etc was not supported in cost-benefit analysis and such measures should be weighed against other health benefits obtainable from the same resources. I note that Prof. O’Carroll queried a report by Garcia et al in relation to Alzheimer’s disease, published after the 2007 WHO report. Dr. Baily was unable to comment on that study, however, reviews of this study in relevant journals appear to raise issues in relation to the nature of the research data used. 1.4 Conclusions: The concerns expressed by observers in relation to perceived health effects of ELF / EMF are understandable and there is no doubt that there is conflicting information available in relation to such effects. In this regard, the distinction may be drawn between persons who choose to reside in proximity to certain infrastructures / sites and those who have such infrastructure / sites imposed upon them. Therefore, while I have heard and understood the submissions of the third parties, any decision in relation to development such as that now proposed must be based on scientific evidence and relevant guidance provided by health auhtorities. I refer, in particular, to the 2006 Expert Group report for the Dept. of

Communications, Marine and Natural Resources. The findings of this report are consistent with other, more recent, publications identified above. The proposed


development would be consistent with the advice contained in that report and the referenced guidelines limits would not be exceeded. Observers have made reference to the adoption by a number of EU countries of stricter limits for exposure of the public to electromagnetic fields, than those recommended by ICNIRP. I note, however, that based on the normal current carrying capacity, as advised in the EIS, those stricter exposure levels would not be exceeded by the proposed development. I note that undergrounding of the lines would still produce magnetic fields, however, the strength of such fields would diminish with distance more rapidly that for OHL. Having regard to the comments set out above, however, there would not appear to be any established health on which to require that the line be provided underground. On the basis of the application documentation, submissions on the file and those made to the hearing, as well as national and international guidance on this matter, I do not consider that there is a justifiable basis for the proposed powerline to be either rejected wholly or partly on the basis of risk to public health. I note the comments from observers at the hearing, in relation to perceived risks. I note also comments in published documents regarding the application of the precautionary principle in relation to OHL’s and EMF. The applicants indicate that design criteria for the line include the achievement of a minimum separation of 50m from dwellings. While this is stated to be for grounds of visual amenity, I consider that this separation provides an in-built precautionary approach beyond that which might be otherwise justified scientifically on health grounds. 2.0 Creosote Observers have raised concerns about the use of creosote for the treatment of poles in the development and potential contamination of ground and surface water. At the oral hearing Niall Mitchell, for the applicants, described creosote as an oil-based preservative, used to preserve timber in wet conditions. It is typically not soluble in water. Reference is made to EU Directive 2001/90/EC, which indicates that the health risks from the use of the substance in industrial applications is likely to be low. The US EPA advise that, subject to certain mitigation measures, its use meets the statutory standards. These measures include restrictions on its use on residential sites. In questioning at the hearing, the applicant’s witness advised that US EPA advised that use of Creosote does not pose a risk to surface waters. Any impact from its use on poles are localised, occurring within 60cm of the pole and all poles would be located at least 15m from surface features. Based on the evidence presented and compliance in its application with relevant statutory requirements, there appears to be no basis on which to reject the development or poles treated with creosote. I therefore regard the use of poles treated with creosote in the proposed development as satisfactory. 3.0 Effluent The proposed development is primarily comprised of overhead power lines. It is also proposed to construct a new substation and a new switching station, which will be provide with staff toilet facilities. In this regard, effluent treatment plants will be


provided discharging to percolation areas. No design details have been provided in this regard. I note, however, that such facilities are not fundamental to the principle of this development and consider that any requirements in order to protect public health can be appropriately conditioned.


Appendix 2 C UNDERGROUNDING Many third party submissions received I relation to this application propose that the development be provided underground, in order to avoid identified impacts. A number of participants at the oral hearing elaborated that such undergrounding should be provided along existing roads and that a cross-country underground route would not be acceptable. As noted in section 3 of this report, the EIS considers the alternative deign option of placing the proposed 110kV line underground. This alternative option was discussed at the hearing at length. While I note that the Board must adjudicate on the project presented to it, the points raised in this regard provide a context for the determination of the application. At the oral hearing, the advised that it is Eirgrid policy that Underground Cable (UGC) will be used only of it passes a four point test: 1. An Overhead Line (OHL) is not feasible. 2. A technically and environmentally acceptable route for UGC can be found. 3. The relatively poorer operating performance of UGC is tolerable. 4. The relatively high cost of UGC can be justified. At the hearing, the term “feasible” in point no. 1 above was queried. It would appear that feasibility relates to achieving a viable route / a physical corridor for OHL. While an UGC route can be achieved almost everywhere, in this instance the applicants suggested that, UGC would only pass test no. 2 if laid along public roads, rather than cross-country. Section 3.10 of the EIS sets out a comparison of Underground Cable (UGC) and Overhead Lines (OHL). The issues described are; • Safety • Capital costs • Life cycle costs, • Reliability and • Environmental impact. Safety: Both technologies are regarded as being equally safe. This matter is considered further in section 6.3 of this report, Health and Safety. Capital Costs: The EIS gives a figure of 3.25 as the cost factor for average ground conditions as between underground cable (UGC) and overhead lines (OHL). This may rise to 5:1 in difficult ground conditions as may be encountered in Donegal. There were a considerable number of questions at the hearing in relation to comparative capital costs and factors varied from 1.6 quoted by some observers to a factor of 5 or 6 by the applicants. It is considered that an accurate cost comparison could not be undertaken unless a detailed design was carried out for both options and in that case the relative length of UGC would in all probability be substantially longer than the equivalent OHL. It can be concluded, however, that the cost difference between UGC and OHL be significant. Life Cycle Costs: It is argued by observers that electrical losses suffered by OHL during operation increase the operating costs and that when the lower losses


encountered by UGC are considered, the increased construction costs of UGC would be reduced / balanced out. This appears to be based on a system operating at a high level / maximum carrying capacity. It appears however, that due to the operational loading of the Irish system, at less than 50% capacity on average, the difference in electrical losses between the two systems will be negligible. The life time cost of OHL would therefore remain optimal. This conclusion is supported in the ECOFYS report (see below). Reliability: The applicants argue that the reliability of UGC is less than OHL. While OHL’s are subject to more faults these are generally transient in nature, with no disruption to customer supplies. Sustained faults, disrupting supply, are stated to be rare. In the 6 no. sustained faults in the transmission network between 2006 and 2007, the applicants identify repair times of between 3 and 48 hours, which repairs can be undertaken by local crews. Weather damage tends to affect lower voltage lines more than higher voltage lines due to restrictions on tall trees in their vicinity. Most weather related faults on 110kv lines are due to lightning strikes and are usually transient. The life of an OHL is probably in excess of 40-60 years, subject to good maintenance and refurbishment, and is possibly unlimited. While OHL maintenance is greater than UGC, the applicants indicate that overall cost of such is not prohibitive. UGC’s do not suffer transient faults. Any faults occurring are sustained faults requiring significant time for fault identification and repairs, requiring specialist crews. On average, therefore UGC would have less availability than OHL and is therefore regarded as less reliable. In order to overcome the issue of availability, two parallel cables may be provided, however, this has increased capital and environmental costs. UGC is generally maintenance free, however refurbishment of UGC is not possible and replacement is required when it is no longer fit for service. Environmental Costs: The applicants argue that contrary to observers comments, the quantity of materials required for construction of UGC would be far greater than for OHL, with greater carbon footprint. While UGC would obviate most of the visual impacts associated with powerlines, it would still give rise to some impacts due to felling of trees and vegetation removal. Apart from visual, UGC installation would give rise to different but still significant environmental impacts. The Ecofys report carries out a comparison of the environmental impacts of UGC ad OHL. Ecofys Reprt In May 2008, a study was prepared by Ecofys for the Dept. Of Communications, Energy and Natural Resources entitled, “Study on the Comparative Merits of

Overhead Electricity Lines Versus Underground Cables”. This report considered electricity at voltages of 110kV and above. The report describes the technologies and carries out both a techno-economic comparison and an environmental comparison of the two optiosn. A number of case studies are also identified. I note the following overall conclusions identified in the report: Technical performance of UGC • The size and number of existing UGC projects is limited and conditions are

comparable to common transmission projects only to a limited extent. The track


record is insufficient for deriving significant statistical data and generalising experience.

• The expected Forced Outage Rate of UGC is estimated by a variety of sources at least one order of magnitude higher than that of OHL. This is a severe limitation for UGC. From a transmission adequacy perspective both technologies do not yet offer the same performance and, hence, are not equivalent.

Economical performance of UGC and OHL • From a capital cost point of view OHL is the most attractive option. This does not

change significantly when operating costs are included to give a whole life cycle analysis.

• The cost estimates for UGC, however, rely on performance assumptions derived from limited experience and provisional information from industry (e.g. technical life and reliability of assets). Hence, the estimates of UGC costs include uncertainties which may further increase the cost difference between UGC and OHL.

Environmental Impact • The construction and/or operation of either OHL or UGC will have some impact on

the natural and human environment. The degree of impact on individual factors addressed in this report will vary on a case by case basis.

• When making a decision on transmission systems (OHL or UGC), particular consideration should be given to the main environmental issues raised by the public submissions. These are Communities, Land Use and Ecology & Nature Conservation. It is noted that these public submissions are generally related to the perceived adverse impacts of OHL. However, it is clear from the assessed effects of the installation and operation of OHL and UGC addressed in this report that both OHL and UGC impact the environment. The relative impact is a function of the resource in question. Therefore, both proven and perceived impacts should be taken into account when decisions are made on transmission systems.

• The comparison between OHL and UGC is complex, and impacts are often interrelated. Mitigation measures range from where no practical mitigation is possible to where mitigation is likely to avoid discernible impact. The most significant mitigation measures can be taken during the planning and construction phases.

• Exposure to electro magnetic fields (EMF) is different for OHL and UGC. Directly above an UGC field strength may be higher than under an OHL, but the corridor with relevant exposure levels is much narrower. With additional measures it is possible to decrease the magnetic fields related to UGC transmission to negligible levels. With dedicated tower design, exposure to magnetic fields can be reduced also significantly in the case of OHL, though not to such low levels. By nature no electrical fields are created outside a cable, whereas the corridor under an OHL is always characterised by an electrical field.

Askon report Observer’s submissions refer to the Askon report, prepared by the NEPP (North East Pylon Pressure group) in relation to the proposed Meath – Tyrone 400kV interconnector project. That report indicated that the installation of two separate parallel 400kV UGC circuits, in lieu of the single proposed 400kV OHL, would overcome the poorer operating performance of UGC and offer improved grid


performance, security and reliability. This report is discussed in applicant’s submissions on the file and was discussed further at the oral hearing. The applicants identify a number of errors and deficiencies in the Askon report, noting that while the provision of two separate 110kV UGC circuits to overcome reliability issues in this case, would double the already expensive UC alternative. The findings of this report in relation to operating costs and electrical losses were also considered. Partial Undergrounding: The viability of partially undergrounding the line was raised at the oral hearing. In response the applicants noted that partial undergrounding of a line is possible and is done regularly for road crossings for lower voltage 38kV lines. Its use for higher voltage lines is limited for technical and operational reasons, however. The advantage of OHL over UGC, is the ability to auto-reclose in the event of a transient fault. This cannot be done with an UGC so partial undergrounding / mixing OHL and UGC, reduces the overall performance of the line and introduces risk to the network. This reduced performance will also introduce the need for greater level of redundancy into the system. Linking an underground cable section with overhead line, requires a new sealing compound at the junction, measuring approx. 50m x 50m in area Where such a mix is permitted it is normally only for a short length of cable at either end of the line, normally on the run-in to a sub-station. Lengths of cable are kept to less than 1km and are not installed at intermittent points on a line. A long length of line in this scenario would be regarded as approx. 1km. During the hearing, the applicants advised that longest stretch of AC underground cable in Ireland is approx. 20k of 220kV cable in Dublin City. Its use in this scenario is possible due to the level of redundancy / other linkages in the network in this area. Observers submissions make reference to an underground line in Bantry, Co. Cork. I note that that situation is not comparable to the proposed development as that case involved a 38kV line connecting a windfarm to the distribution network. The only development which would be affected in the event of any fault on that line would be the windfarm itself. At the oral hearing, Prof. O’Carroll refered to an intermediate undergrounding (6km) of a 400kV line between Nunthorpe and Newby in Yorkshire. This related to a project previously refused on visual amenity grounds and it is understood that the 400 kV line would be carried exclusively on pylons. The difference between pylons and wooden polesets is noted and is referred to under the consideration of Landscape and Visual Impacts. Conclusion The proposed development comprises the development of a 110kv OHL and this is the project on which the Board must made a determination. Observers have sought to have the proposed development placed underground to obviate a number of real and perceived impacts arising from the proposed development. It is clear that both OHL and UGC have potentially significant, if different, environmental impacts. Having regard to the nature of ground conditions and the sensitivity of much of this part of Donegal, it is likely that that to achieve the objectives of this application, cables would need to be laid in / alongside roadways


and that provision of parallel cables may be a requirement to ensure security of supply. Although UGC was not subject to EIA in this case, it would appear likely that such option would give rise to significant impacts on soils and water quality. In considering such environmental impacts submission of An Taisce in their letter of 2nd February 2009 is noted, wherein it is indicated that OHL is the best alternative for this project. The technical obstacles to the provision of UGC in this case appear to be compelling and I refer to the content and conclusions reached in the Ecofys report of May 2008 in this regard. Having considered the submissions on the file and these made at the hearing, I consider that there is a sufficient strong case for the use of OHL in this instance. The specific impacts of this option are considered elsewhere in this report. Where the board considered it appropriate, the examination of partial undergrounding of the line might be feasible, however, this is outside the remit of this report.


Appendix 2D FLORA AND FAUNA. Chapter 7 of the EIS deals with flora and fauna, including designated sites and habitats. At the oral hearing evidence was presented by Mr Mc Crory and questions were asked on this topic, mainly on day 4 of the hearing. The issues raised involved responses from a number of witnesses for the Applicant. The lines cross or pass by nine main habitat types, including a number of Annex 1 habitats, namely Blanket Bog (a priority habitat where it is undisturbed), Quaking Bog, Dry Heath, Oliogotrophic lakes. Section 7.3.2 describes the construction phase and estimates potential habitat loss as 2,605-sq.m. for Binbane - Letterkenny line and 1,465 m2 for the Ardnagappary - Tievebrack line. The EIS notes that the Binbane - Letterkenny line chiefly passes through disturbed peatland and forestry. Approx. 53% of the Binbane – Letterkenny line crossss through blanket bog habitat, with the loss of 1,485-cu.m1. of this habitat. 172 no . structures are located on the annex 1 habitat, while 27 no. of these were located in a priority blanket bog habitat. It states that of the remaining terrestrial habitat types along the line, native woodland and quaking bog are of very high conservation value but not directly impacted upon. The line crosses 13 rivers/tributaries and more small streams, it also passes over five designated sites of which three are European Natura Sites. It notes that eight poleset structures are located within designated sites. In relation to the Ardnagappary - Tievebrack line, this is stated to pass mainly through disturbed peatland and forestry. Approx. 67% of the line crosses on blanket bog, with 1,005-cu.m. of habitat loss, and crosses seven rivers/tributaries and more small streams. Dry heath would also be impacted, however, the EIS notes that this is not a particularly good example of this Annex 1 habitat type. Of the remaining terrestrial habitat types along the line, the EIS identifies native woodland as being of the most value for biodiversity but that impacts will be temporary and overall neutral. This line passes over four statutory designated sites and four poleset structures are located within two designated sites. 107 no. structures are located in the annex 1 habitat, of which 10 no. are located on priority habitats. Substation construction will result in the permanent loss of approx. 0.5ha of blanket bog at each site. The EIS notes that the bog in these locations has been subject to disturbance and turf cutting in the past. The development and excavation of the sites will have impacts on adjoining bog areas due to drying out. The drying out of surface peat will result in replacement of sphagnum moss with heathers / dry heath. Peat excavated from the sites will be used to create landscape mounds, which are to be planted. The EIS suggests that the landscaping and creation of new dry heath habitat, will mitigate the loss of the degraded bog. Under the terms of the Habitats Directive, there is a requirement to maintain the habitats listed in the Directive in favourable conservation status. To ensure

1 Use of cu.m. relates to extent of peat excavated to carry out construction (EIS page 7.26/33).


favourable conservation status of the habitats in Annex I and the species in Annex II, the Member States are required to set up a “coherent European ecological network of special areas of conservation under the title Natura 2000”. The EIS predicts that the development will have a slight adverse impact for blanket bog habitat. The principle habitat affected by the development is blanket bog and the EIS notes that County Donegal contains some of the greatest uninterrupted expanses of blanket bog habitat in Ireland. It is clear in the information presented that avoidance of designated sites was a key criteria in the route selection process that where avoidance was not possible, the minimisation of impacts was sought. Section 7.4 of the EIS deals with mitigation measures and notes the need to ensure minimal disturbance of existing surface vegetation and hedgerows in sensitive habitats. Sensitive habitats are defined as designated sites, blanket bog, quaking bog, heathland and stream and river crossings. From a long term impact perspective, the potential damage to blanket bog habitats which are subjected to surface damage / compression would be of greatest concern. In order to minimise impacts on sensitive areas it is proposed to use helicopters to access sections of the line. On the Letterkenny – Binbane line, the EIS lists 119 polesets requiring use of a helicopter including 5 separate areas of between 13 and 17 polesets in sequence. In the case of the Ardnagappary – Tievebrack line, 48 locations are listed of which one location (ST 73-89) includes 17 no. polesets. Approximately 30% of all polesets, and some angle masts, on both lines require use of a helicopter to effect construction. The areas where a high number of polesets in sequence require a helicopter noted in the EIS are:

1. Letterkenny – Binbane No. ST 101 -113 ref 12.3d/e North of Glenties Straboy Hill 13 ST 180-192 ref 12.3g Knockletteragh13 ST 218-232 ref 12.3h sth of L Shivnagh N / Scallan Br 15

ST262 -278 ref 12.3i/j Tullyhonour 17 ST285 -299 ref 12.3j/k nth of L Deele Cronamuck 15

2. Ardnagappary – Tievebrack ST73- 89 ref 12.3s/t nth R252/N56 Crovehy 17

The means of access in designated sites is otherwise identified in table 7.9 of the EIS. At the oral hearing, errors in this table were identified, wherein poleset numbering in the table was out of sequence by two pole-structures, i.e. pole set ST126 should read ST128. The EIS recommends an ecologist be involved during line construction to advise on vegetation removal, refining access to sensitive habitats and on the ground advice regarding minimising impacts and habitat reinstatement. Ground vegetation is to be restored to its original state in sensitive habitats following completion of construction as recommended by the consultant ecologist. It would be appropriate that the ecologist would have a similar working arrangement to that used in the case of archaeology. It is considered that the actual protocol for construction should be agreed in advance and a condition is recommended in that regard. Polesets are to be located a minimum of 15m from watercourses. The use of settlement ponds at the site of sub-station and switching stations is proposed to


prevent silt run-off to adjoining water courses. No emission limit values were identified for the settlement ponds in the EIS. During the oral hearing, however, Dr. Paddy Kavanagh for the Applicants, stated that the design of the settlement ponds would ensure a suspended solid level of 35mg/l in the outflow, which would not give rise to silt impacts on gravel beds or on freshwater pearl mussels. In the event of any decision to approve the proposed development, conditions referring to such emissions limits in this regard would be appropriate. I would also recommend conditions regarding supervision of such works, and the carrying out of water quality monitoring as identified in the EIS, by an ecologist. This matter is also considered under the section on Water Quality and Fisheries. I do not regard the mitigation measures proposed as being out of the ordinary, requiring significant new information, or that they would not be amenable to conditions. The extent of habitat loss arising from the proposed development is not regarded as significant, particularly having regard to the extent of such habitats in the county. Impacts on the hydrology of blanket bog are not likely to be significant, particularly in areas where turf cutting is undertaken. The greatest footprint of development would arise at the substation and switching stations sites. The primary area of concern relates to construction impacts, which it is considered, can be adequately mitigated subject to appropriate conditions. Operational impacts will not be significant due to the small footprint of the development and the mitigation measures identified. The NPWS have identified the risk of bird strike as the principle area of concern and the applicants indicate that consultations have been undertaken with the service. The EIS concludes that Greenland White-fronted Geese, and other large-bodied species are likely to fly far in excess of the height of the proposed lines and structures. Section 7.10 identifies the location for installation of bird diverters, which measure would appear to satisfactorily address the potential risk to bird life from the proposed development. Disturbance of birds arising during construction will be short-term, however, it should be timed to avoid the breeding season in sensitive locations. Fieldwork and searches undertaken in suitable habitats, encountered no species of protected flowering plant or fern identified by NPWS as occurring in the 10km grid squares through which the lines pass. The information presented, based on surveys along the route, indicates that significant negative impacts on other fauna species are not likely.

APPROPRIATE ASSESSMENT An appropriate assessment is an assessment of the potential adverse or negative effects of a plan or project, in combination with other plans or projects, on a European Site. These sites consist of Special Areas of Conservation (SACs) and Special Protection Areas (SPAs) and provide for the protection and long-term survival of Europe’s most valuable and threatened species and habitats. The requirement for an appropriate assessment is outlined in Article 6(3) and 6(4) of the Habitats Directive. Article 6(3) of the Habitats Directive requires that:-

“Any plan or project not directly connected with or necessary to the

management of the site but likely to have a significant effect thereon, either

individually or in combination with other plans or projects, shall be subject to


appropriate assessment of its implications for the site in view of the site's

conservation objectives. In the light of the conclusions of the assessment of the

implications for the site and subject to the provisions of paragraph 4, the

competent national authorities shall agree to the plan or project only after

having ascertained that it will not adversely affect the integrity of the site

concerned and, if appropriate, after having obtained the opinion of the general

public.” Under Article 6(3) the assessment is confined to implications for the site in view of its conservation objectives. An examination of possible alternatives or mitigation measures may make it possible to ascertain that, in the light of such solutions or measures, the plan or project will not adversely affect the integrity of the site. A site’s conservation objectives are established by listing the Annex 1 habitats and Annex II species native to the site. The reason for the designation of the site is the protection of those habitats and species. The integrity of the site relates to its conservation objectives and to the “coherence of the sites ecological structure and function across its while area, or the habitats, complex or habitats and / or populations of species for which the site is or will be classified”. The EIS identifies potential impacts on Designated Sites and concludes that there would not be significant effects on protected species or species of high conservation value and also that there would not be significant effects on sites designated for their nature conservation value. Section 7.3.2, page 7.25/33, concludes that “as no significant adverse effects are likely upon the Natura sites in question, the assessment process stops at Stage 1: Screening / test of Significance”. STAGE 1: A description of the proposed development is set out in Chapter 5.0 of the EIS and in Section 3.0 of this report. The specific elements of the development affecting Natura 2000 Sites are identified below. A total of 12 no. wooden polesets are proposed to be located within the boundaries of designates sites along the entire development. There are no angle towers located within designated sites. Foundations for wooden polesets are generally 2.3m deep, being approx. 1m x 1m wide. Once the pole is placed in the hole it is backfilled, using aggregate where necessary. Additional stability aids may be required in areas of poor ground conditions. The project is not directly connected with or necessary for the management of any designated sites affected by the development. Consultation The EIS details the level of consultation undertaken in relation to the project. The submission to the Board from NPWS notes the following points: • The Dept. is satisfied that the EIS qualities as an appropriate assessment as

outlined in Article 6(3) f the EU Habitats Directive 1992. The Department is of the view that the proposed development as described will not significantly impact on the integrity of any Natura 2000 site. Furthermore the mitigation is adequate to ensure that there will be no significant adverse impact to nature conservation / natural heritage.


The submission from the Northern Regional Fisheries Board notes the following points: • Require compliance with the mitigation measures identified in the EIS. • Consultation between the Board and the project ecologist prior to works relevant

to river and stream crossings and protection of aquatic habitats. An Taisce note that • Removal of blanket bog Annex 1 priority habitat is not in keeping with the

requirements of Article 6 of the Habitats Directive. • It is not appropriate to grant consent without a survey for bat roosting sites and

compliance conditions cannot be used to compensate for an incomplete EIS. • The impacts on Greenland White-fronted Goose at Lough Nillan SAC / SPA were

not fully assessed in the EIS. • The is assessment of the impact of the construction or maintenance of structures

on peat stability or the maintenance of favourable conservation status of annexed bog habitats and species.

• The following information has not yet been submitted or agreed: 1) The management plan for restoration and peat storage. 2) Detailed design of settlement ponds, river crossings for protected river habitats and species. 3) Bat survey and, if necessary, associated mitigation measures.

NATURA 2000 Sites The Binbane – Letterkenny line passes by or close to through five designated sites including three Natura sites. • Meenybradden Bog pNHA • West of Ardara / Maas Road cSAC / NHA (6739.1ha) • River Finn Complex SAC, including Lough Finn NHA (1,290ha) • Lough Nillan Bog (Carrickatlieve) SAC/SPA/NHA (4157.8ha) The Ardnagappary – Tievebrack line crosses or passes close to four designated, European NAtura, sites. • Fawnboy Bog / Lough Nacung SAC. (1105.4ha) • Coghernagore / Glenveagh NP SAC (3346.2ha). • Glanivegil Bog SAC (2154ha). • West of Ardara / Maas Road SAC. (6739.1ha) BINBANE – LETTERKENNY SITE DESCRIPTION: MEENYBRADDEN BOG NHA This site comprises and area of lowland blanket bog and includes Lough Namafin. This previously extensive blanket bog system has been degraded through peat cutting activities. Damaging activities associated with peat cutting and grazing include drainage and enrichment of Lough Namafin. This small site contains a diversity of habitats and species and is one of the few intact bogs in this area. The line includes two polesets ST17 and ST18 within the site at 7 metres and 50 metres from county roads respectively. It states the polesets occur in areas of cut-over bog and have been located as close to the roads as engineering constraints allow.


Significant Impacts: This site is not a Natura 2000 site. The footprint of development and extent of habitat loss in the site is not significant and the two polesets located within the site are located on areas of cutover bog. Construction impacts will be the most significant impact. Having regard to the proximity of one of the polesets to the adjoining public road and the mitigation measures identified in the EIS it is not considered that the development give rise to a significant change in value or that it would impair the long-term maintenance of the habitat. SITE DESCRIPTION: LOUGH NILLAN BOG (SAC/ SPA/ NHA) (4157.8ha): Blanket bog is the most extensive habitat and ranks as an Annex 1 Priority Habitat due to the fact that it is predominantly intact and undisturbed. Mosses are common, with orchid, sedge and sphagnum recorded. Great value for birds, including merlin, feeding for Greenland white fronted Geese (only flock in region feeding on traditional bog sites). It is of international conservation importance Two mammals listed in The Irish Red Data Book, Badger and Irish Hare, have been recorded. Parts of the site are being eroded through overgrazing and turf-cutting, and forestry is an ever present threat. Large areas of formerly extensive, intact bog have been afforested adjacent to the site, resulting in habitat fragmentation. Despite this, the size of the remaining blanket bog, and the fact that it is predominantly intact and undisturbed, gives the area national conservation importance. The presence of rare breeding and migratory birds adds to the value of the site. Significant Impacts: The DoEHLG (NPWS) indicated their satisfaction that the proposed development will not significantly impact on the integrity of any Natura 2000 site. Birdwatch Ireland indicate that impacts on the species of interest, particularly Greenland White-fronted Geese, for the SPA have not been fully considered. The EIS refers to discussions with NPWS regarding the movement of the species to intensive grassland sites for feeding in recent years. The applicants also note the trend of decreasing numbers recorded on the site to regionally important levels. The applicants argue that birds may approach the site from any angle along its 55km perimeter and that the line comes within 250m of the site for approx. 0.78km. The risk of collision is not therefore regarded as significant, and will be further reduced by the proposed mitigation measures. The EIS predicts a neutral impact. The development has no footprint in the site, however, the line crosses the north-western corner of the site and ST40 is located approx. 5m from the site boundary. Section 7.3.2 of the EIS predicts no significant impacts for habitats for which the site has been selected. Construction impacts are short-term and disturbance of bird species will not be significant. Works should be timed to avoid the breeding season in sensitive locations, however. The development will not result in any habitat loss from the site or fragmentation thereof. Impacts on water quality in the site are unlikely due to the limited extent of development works and the drainage pattern in the area. Works should subject to supervision by the consultant ecologist however. I note the mitigation measures to avoid bird strikes were regarded by NPWS as adequate. It is not considered that the proposed development will adversely affect the integrity of the


SITE DESCRIPTION: WEST OF ARDARA / MAAS ROAD SAC (6739.1ha): This extensive site contained twenty-three Annex 1 Habitats, including blanket bog, machair, dunes, grassland. The site contains eight Annex II species including Slender Naiad, Freshwater Pearl Mussel, Marsh Fritillary, Petalwort, Atlantic Salmon, Common Seal, whorl snail and Otter. Bird species identified in Annex I of the Birds Directive include Barnacle and Greenland White-fronted Geese at Sheskinmore, Merlin, Peregrine, Hen Harrier, Terns, Whooper Swan, Red-throated Diver, Corncrake and Chough. Significant Impacts: Third parties argue that the development will result in impacts on aquatic species for which the site is designated. The DoEHLG (NPWS) indicated their satisfaction that the proposed development as described will not significantly impact on the integrity of any Natura 2000 site. The line traverses the Owenea River with no development footprint in the site. Pole-set (ST70) is located within the SAC on a boundary of wet pasture and blanket bog and is accessible by a track. Tievebrack sub-station is located outside but adjacent to the designated site close to the Stracashel River. Exiting the station, the line crosses the river / SAC, with no development footprint therein. ST128 will be located in an area of bog between stands of forestry within the site. ST 143 is also located within the SAC 13m and is accessible from a forestry haul road. The EIS predicts slight adverse impacts for the site. The development has a limited footprint in one Annex 1 habitat type, Blanket Bog. The extent of habitat loss arising from the development is minimal, particularly in the context of the extent of this site. While there will be some, minor, deterioration in the habitat, it is not considered that the development give rise to a significant change in value or that it would impair the long-term maintenance of the habitat. Construction impacts will be short-term and only one poleset site is not currently accessible by a track / road. The development does not give rise to direct impacts on water quality or on aquatic Annex 1 species, including otter and salmon. Excavation at Tievebrack switching station site at will give rise to potential silt run-off into the Strahcashel River, particularly through the adjoining drainage ditches which could be damaging to aquatic fauna with particular reference to freshwater pearl mussels. The EIS includes mitigation measures in relation to construction management, which give a high priority to the avoidance of siltation. I note, in particular, the proposal to comply with the guidance published by the Northwestern Regional Fisheries Board for works at river sites. I note also the evidence presented at the oral hearing in this regard. It is considered the mitigation measures are appropriate and the proposed development (both lines and substations) would not have significant impacts on water quality or fisheries. The proposed mitigation measures were regarded by NPWS as adequate and it is not considered likely that the development will adversely affect the integrity of the site. SITE DESCRIPTION: RIVER FINN COMPLEX CSAC (1,290ha) The site is a candidate SAC selected for active blanket bog, lowland oligotrophic lakes, wet heath and transition mires all habitats listed on Annex I of the E.U. Habitats Directive. The site is also selected for Atlantic Salmon and Otter, Annex II species.


Golden Plover, Peregrine and Merlin, threatened species listed on Annex I of the EU Birds Directive, breed in the upland areas of the site. A Red Listed species Red Grouse occurs on the site, while the scarce Ring Ouzel, another Red List species is also known to occur. Significant Impacts: The DoEHLG (NPWS) indicated their satisfaction that the proposed development as described will not significantly impact on the integrity of any Natura 2000 site. The line passes over Stranogoppoge River south of Lough Shivnagh and River Finn. Poleset (ST216) is located on the NHA boundary between River Finn and R250, on marshy grassland. The line also crosses Cummirk River at Kingarrow. Two pole-sets (ST234 and 235) are located within the site in wet grassland / bog 20m from the river and forestry plantation 50m from the river respectively. With appropriate mitigation, the EIS indicates that the access track created for these structures will leave minimal imprint for surface habitats. The EIS notes that the polesets are located within habitats of local value only and impact on the high value site at Kingarrow are predicted to be minor negative. Overall impacts are slight adverse. The line also crosses the site at the Stranogoppoge River and Between Lough Finn and Shivnagh. No structures are located within the site at these locations. One poleset is located on the boundary of the Lough Finn NHA and structures are located within 20m of rivers within the sites. The development has a limited footprint in one Annex 1 habitat type, blanket bog. The extent of habitat loss arising from the development is minimal, particularly in the context of the extent of this site. While there will be some, minor, deterioration in the habitat, it is not considered that the development give rise to a significant change in value or that it would impair the long-term maintenance of the habitat. There is potential for disturbance of birds at construction stage, although such impacts would be temporary. The presence of powerlines creates a risk of collision for birds. I note the proposed mitigation measures were regarded by NPWS as adequate. Construction impacts will be short-term, however, they should be timed to avoid the breeding season in sensitive locations. The development does not give rise to direct impacts on water quality or on aquatic Annex 1 species, including otter and salmon. An Taisce argue that the EIS is inadequate as it contains insufficient detail in relation to the design of settlement ponds, river crossings for protected river habitats. In this regard I note, in particular, the proposal to comply with the guidance published by the Northwestern Regional Fisheries Board for works at river sites and the evidence presented at the oral hearing. I do not regard the mitigation measures proposed as unusual and note that NPWS considered them to be adequate. It is not considered that the development will adversely affect the integrity of the site. ARDNAGAPPARY – TIEVEBRACK LINE SITE DESCRIPTION: FAWNBOY BOG / LOUGH NACUNG SAC (1,105.4ha): The site is of conservation importance primarily for its blanket bog, an EU Annex I priority habitat. The bog occurs in association with wet heath, rock outcrop and a number of oligotrophic lakes. The most extensive tract of blanket bog occurs to the east of Lough Nacung. Lough Nacung itself is notable for the occurrence of the


aquatic Pillwort (Pilularia globulifera), protected under the Flora Protection Order, 1987. The site supports a population of Pearl Mussel (Margaritifera margaritifera), an Annex II species. Greenland White-fronted Geese and Red-Throated Diver are Annex I species under the EU Birds Directive, which add value to the site. Significant Impacts: The DoEHLG (NPWS) indicated their satisfaction that the proposed development as described will not significantly impact on the integrity of any Natura 2000 site. The proposed line crosses the river Clady and the development locates one poleset, ST6, within the site, 17m north of the river Clady, with other pole sets adjacent to the site. There is access to ST6 from the adjoining Co. Co. depot. The development has a limited footprint in one Annex 1 habitat type, Blanket Bog. The extent of habitat loss arising from the development is minimal. While there will be some, minor, deterioration in the habitat, it is not considered that the development give rise to a significant change in value or that it would impair the long-term maintenance of the habitat. Lands beyond the banks of the Clady River are designated in order to prevent seepage of pollutants into the river and protect the quality of waters. The development will not have direct impacts on the aquatic environment and appropriate construction management to prevent silt or other pollutants reaching the watercourse will result in a predicted neutral impact. An Taisce argue that the level of detail provided in relation to such mitigation measures is inadequate. I do not regard the mitigation measures proposed as remarkable and note in particular, the proposal to comply with the guidance published by the Northwestern Regional Fisheries Board for works at river sites. I note also the evidence presented at the oral hearing in this regard and that the NPWS considered the measures to be adequate. While the impact of the development on freshwater pearl mussel was considered in detail in the EIS and at the oral hearing, subject to the implementation of identified mitigation measures, the development will not contribute to the decline of identified species or reduce the natural range of the species. There is potential for bird strikes and bird diverters are proposed in this area. The development is remote from the breeding area of the Red throated Diver and appropriate mitigation measures are identified. The NPWS regard the mitigation measures as satisfactory and the project will not adversely affect the integrity of the site. SITE DESCRIPTION: CLOGHERNAGORE / GLENVEAGH NP SAC This large inland site is a candidate SAC selected for blanket bog, a priority habitat and for lowland oligotrophic lakes, floating river vegetation, alpine heath, dry heath, wet heath, Molinia meadows, old Oak woodlands, Rhynchosporion, all Annex I. The site is also selected for the following species listed on Annex II of the same directive – Killarney Fern, Freshwater Pearl Mussel, Atlantic Salmon and Otter. Bird Life is well represented with several Red Data Book species, listed on Annex I of the EU Birds Directive, breeding within the area, namely: Red-throated Diver, Golden Plover, Merlin and Peregrine. A small flock of Greenland White-fronted Geese, also listed on Annex I of the EU Birds Directive, feed on some of the bogs in winter.


Significant Impact The DoEHLG (NPWS) have indicated their satisfaction that the proposed development as described will not significantly impact on the integrity of any Natura 2000 site. The proposed development crosses the northwestern corner of the site at Crocknafarragh, with one poleset located in this area on an area of blanket bog already degraded by turf-cutting. The line also crosses the site at Crovehy, where two polesets are located within the site on an area of blanket bog. Potential impacts include habitat loss and risk of bird collision. The development has a limited footprint in one Annex 1 habitat type, Blanket Bog. This area includes the area around Cloghernagore, which the site synopsis identifies as constituting the most extensive blanket bog system remaining in the north-west of Ireland. The extent of habitat loss arising from the development is minimal, particularly in the context of the extent of this large site. While there will be some, minor, deterioration in the habitat, it is not considered that the development give rise to a significant change in value or that it would impair the long-term maintenance of the habitat. Significant impacts on water quality are not likely in this location. The development has the potential to impact on a species of bird identified in the Birds Directive. The impacts of the development in this regard are not examined in detail in the EIS. At the oral hearing the applicants advised that the confidentiality requirements of the NPWS prevent the identification of this bird and its breeding location. I note that the line in this area is to be provided with bird deflectors and is stated to be located away from likely flight paths of the identified species. The applicants confirmed, nonetheless, that the impact of the development on this species of bird were considered in the design of the development and that the NPWS were consulted in preparing the EIS. The consultant for the applicants has presented his opinion that the development, at a minimum of 500m distance from the breeding site, with diverters installed, would not have a significant effect on the breeding capability of the species. It is stated that there is a risk of collision but that this is not likely. Third parties argue that given the rarity of this species the level of risk is not acceptable. Based on the evidence presented, I would differentiate this site from others potentially affected by the proposed development, based on the sensitivity of the bird species and the small numbers of breeding pairs in the country, and the proximity of the line to its location. While the information available on the file indicates that there may not be an impact, I cannot state that the integrity of the site will not be affected in this regard. While the NPWS indicate that the proposed development will not significantly impact on the integrity of any Natura 2000 site, no specific comment is provided in relation to this species. There are difficulties in terms of the secrecy surrounding this species and the level of information provided in the application. In order satisfy the requirement to ensure that there is no adverse effect on the integrity of the site, I consider that additional information would be required. Given the sensitivity of the information in this regard, it may be necessary that confirmation that the integrity of the site would not be adversely affected be obtained from the NPWS specifically in relation to development at this location.


SITE DESCRIPTION: GLANIVEGIL BOG SAC The predominant habitat within the site is lowland blanket bog, an Annex I priority habitat. On higher ground the Annex I habitat wet heath forms a mosaic with blanket bog, which grades into dry heath on the steeper slopes and hill summits. A number of oligotrophic lakes, an annex I habitat, occur. The lakes, pools and water courses within the site provide excellent habitat for Otter, listed under Annex II and IV. Annex I bird species for which the site is designated are Greenland White-Fronted Goose, Golden Plover, Merlin. Significant Impact: The line passes over the western extremity of the site, however, no tree removal is required in this area. No structures are proposed within the site and the development will not result in a loss of habitat. One poleset is located 25m from the southern shore of Lough MacHugh. While bird strikes are a potential impact of the development, it is proposed to provide bird deflectors along the line in this area. The development will not give rise to a significant change in value or impair the long-term maintenance of the habitat. The development will not result in any direct habitat loss of disturbance thereof. Construction impacts will be short-term and there is limited potential for impacts on water quality. The NPWS regard the mitigation measures as adequate and that the development will not adversely impact on the integrity of the site. SITE DESCRIPTION: WEST OF ARDARA / MAAS ROAD SAC (As above): This site includes the Gweebarra River and is of interest due to the high level of habitat diversity. Significant Impacts: The DoEHLG (NPWS) indicated their satisfaction that the proposed development as described will not significantly impact on the integrity of any Natura 2000 site. The line spans 250m of the Gweebarra River (West of Ardara / Maas Road SAC). No structures are located within the designated site. The nearest structures are located approx. 20m distant on the northern bank and 32m on the southern bank. At the hearing it was indiacted that the line will hang approx. 13.3m above the river. The EIS predicts that the development will not impact on the features of this stretch of river which contribute towards its selection at an SAC, i.e. otters or salmonids. The installation of bird deflectors is proposed. At the hearing it was confirmed that consultations with the Golden Eagle Team were undertaken in this regard. It was also noted that there are no deflectors on the existing 38kV Gweebarra crossing and no collisions have occurred. There will be no loss of habitat arsing from the development. There may be some disturbance during construction activity, which would be short-term. The development will not adversely impact on the integrity of the site. CONCLUSION: The proposed development crosses, or passes close to, a number of Natura 2000 site. The EIS contains an assessment of the impacts on flora and fauna and section 7.3.2 o concludes that as no significant adverse effects are likely upon the Natura sites in question, the assessment process stops at Stage 1: Screening / Testing of


Significance. I note that in their submission to the Board, the National Parks and Wildlife Service indicate their satisfaction with the assessment of impacts on designated sites. Having regard to the mitigation measures identified in the EIS, I would generally concur with the assessment contained in section 7.3.2 of the EIS and the findings of NPWS, that the development will not adversely affect the integrity of the identified designated sites. The one area of concern remaining, however, relates to that part of the line at Crovehy, crossing Cloghernagore / Glenveagh NP SAC. I do not consider that adequate information is available to the Board on the impacts of the development on the breeding site of a protected bird species at this location. As noted above, specific comments from the NPWS may be required in this regard. It is otherwise recommended that monitoring by a project ecologist of all works within and potentially affecting the identified Natura 2000 sites and other sensitive habitats be undertaken, in order to ensure compliance with the recommended mitigation measures.


Appendix 2E Planning Context Donegal County Development Plan 2006-2012 Key issues identified in Chapter 1 include: • The need to address the decline of traditional industries such as textiles, clothing,

agriculture and fishing, with an emphasis on rural diversification, eco-tourism and promoting indigenous start-up businesses.

• Tackling the high unemployment rate relative to the rest of the country. • Inability of the region to compete for employment on a national or international

scale. • Strategic and local links to strong urban centres in Northern Ireland. • Infrastructural constraints/deficiencies throughout the County and in particular the

absence of a strong east-west road link. • Weak urban structure and the need to strengthen the role of the towns and villages

which serve the expansive rural population. • Tackling rural depopulation and maintaining the strong cultural identity of the

Gaeltacht areas. • Strengthening the infrastructural links within the County and to regional centres. • The need to seek the conservation and enhancement of Donegal’s scenic

landscape, natural development and heritage. Objectives of the spatial strategy set out in Chapter 2 include: 1. The creation of a vibrant and fully functioning Letterkenny – Derry linked Gateway as the principal driver for the development of the region. 2. The creation, through urban strengthening measures, of a strong urban structure at the sub-gateway level, which would consolidate the development of the Gateway as well as ensuring that the benefits of the spatial policy are spread evenly. 3. The management of growth in close proximity to the linked gateway, through urban support measures. 4. The creation or vibrant rural areas, which are key drivers of a changing rural economy, by providing support for rural villages and rural communities. 5. The protection and enhancement of the unique cultural and linguistic resource of the Gaeltacht through a process of urban strengthening, urban support and rural support. 6. Safeguarding the role of centres with special functions: such as Lifford, Moville, Greencastle, Burtonport, Rossnowlagh, Downings, Rathmullan, Gaoth Dobhair, Glencolumbkille, and Gortahork. 2.7 Support for Gaeltacht areas • Upgrading of Physical Infrastructure (Sewerage, Water Supply, Broadband, Road

network, Electricity etc), to the necessary standard to allow for continued economic growth thereby strengthening Gaeltacht areas.

• Working closely with all relevant government organisations and Non Governmental Organisations in attracting inward investment.

• The provision of social and cultural infrastructure such as: Leisure facilities, Arts Centres etc.


• The active promotion of the Irish Language and Culture through implementing the policies laid out in this Plan and working closely with relevant agencies and organisations.

• Improving the quality of the built environment and the regeneration of obsolete areas.

• Improvements in public transport so as to ensure that those working outside of Gaeltacht areas can remain living in Gaeltacht areas.

• Developing and improving access to the regional airport at Carrickfinn as a key means or improving overall access to the Gaeltacht.

• Guiding development in a more sustainable manner. In particular developing more compact urban forms able to sustain a range of services

• Ensuring the affordability of housing through the strategic land use planning • policies and the provision of social and affordable housing. • Restrictions on the proliferation of holiday homes where such developments

would lead to the considerable influx of a non-Irish speaking population. • Work in partnership with County Development Board substructures to assist in the

implementation of proposals included in An Stratéis, the County Development Board Strategic Plan for the period 2002-2012 to assist in economic, social and cultural development of the County.

Chapter 4 deals with Employment Generation and Enterprise Development Strategies. Section 4.3 refers to Creating the conditions for Enterprise Development in Donegal, including: a. Infrastructure Weak infrastructure in the County resulting from decades of under investment represents a barrier to the economic development of the County. The Council will seek significant increases in funding for infrastructure to provide an integrated package of infrastructure to meet the needs of enterprise and employment. A North-South co-operative approach to the provision of infrastructure for the Letterkenny-Derry Gateway and for other key linkages is proposed including: Energy The overall adequacy of the County’s electricity supply is in question and there is a very important issue related to the 110Kv ESB supply into and within the County. Northern Ireland however, has excess capacity. In this context there is potential to develop an All-Ireland energy market and an All-Ireland electricity grid and this would benefit the local economy in Donegal. POLICY EED 1: Employment Generation It is the policy of the Council to seek new job creation and enterprise development opportunities through …… range of interventions, (including): 5. Support for employment generation developed at locations within, throughout and adjacent to the Gaeltacht, exploiting the employment opportunities arising from the development of the distinctive, cultural, traditional and linguistic attributes and strengths of the area. POLICY EED 3: Key Interest Centres The Council will continue to co-ordinate with the relevant enterprise development agencies, to provide for the development of a number of Key Interest Centres throughout the County. The Key Interest Centres policy will be pursued through


(a) Development of a more pro-active and focused involvement in the tourism industry. (b) Development, with relevant agencies of a limited number of key centres which can compete nationally and internationally for inward investment and significant added value indigenous industry, such areas are likely to be located close to the fibre-optic elecommunication backbone of the County. Locations likely to be targeted include • Business and Technology Park, Letterkenny • Consolidation and Expansion of Gweedore Business Park • Business and Industrial Park at Dungloe. POLICY EED8: The development of Key Infrastructure to Facilitate

Employment Generation. The Council will continue to address the issue of infrastructure, by designating infrastructural corridors within and into the County, providing for in particular broadband, telecommunication, energy, electricity, gas, road, air, water and rail access, water supply and waste water disposal. Electricity, broadband, telecommunications are singled out as essential basic infrastructural requirements to assist the development of economic regeneration. As the functional hinterland of Donegal transcends the natural boundary of the County, the cross border element in regeneration is crucial in telecommunications, broadband, electricity and gas as supported in the National Spatial Strategy and the Regional Planning Guidelines. (1) Electricity Infrastructure From within the State, it will be important to facilitate and support the provision of renewable energy and the E.S.B.’s or other utilities attempts to upgrade the 110KV electricity network. Electricity Infrastructural Corridors are very important in this regard, in order to provide the policy base, to support any potential future planning proposals by the ESB during the lifespan of the Plan and Map 3, at the end of this chapter outlines and indicative line of the ESB reinforcement route. The Policy base for such energy corridors is provided for in both the National Spatial Strategy and the Regional Planning Guidelines. The National Spatial Strategy indicates the particular need to strengthen energy networks in the Border and the North West, indeed it considers the advantages of streamlining the co-ordination of infrastructure, by provision of different types of infrastructure in one physical corridor. The National Spatial Strategy notes that in relation to the transmission and distribution networks, that a major programme of work is underway to reinforce the National Grid to International supply standards and key elements of the programme to 2007/2008 will be to upgrade existing lines, installation and/or upgrading of transformer stations and the provision of new lines. The National Spatial Strategy further notes, that it is vital that this investment programme is integrated both at Regional and Local level, particularly in the Development Plan to support the timely commissioning of the transmission infrastructure. Furthermore, the Regional Strategy and Regional Planning guidelines, also focus on the strategic strengthening of the electricity grid, serving particular clusters of employment related demand in peripheral areas and also to highlight energy deficits in the region as a whole Chapter 7 Natural Resource Development.


Wind Energy GOAL: The Council seeks to harness the wind energy potential of the County in a way that achieves a balance between responding to government policy on renewable energy and the proper planning and sustainable development of the County. POLICY NRD35: Promote County Donegal as a source for renewable energy production and for the research, development and transit of renewable energy technologies. Chapter 8 Built and Natural Heritage Goal: To conserve and protect the County’s natural, built and cultural heritage for future generations while encouraging appreciation and enjoyment of these resources at present. Objectives include: • Seek the conservation and wise management of areas of natural environmental

value. • Protect, and where possible enhance, plant and animal species and their habitat,

which have been identified under the EU Habitats Directive, EU Birds Directive, the Wildlife Act and the Flora Protection Order.

• Protect landscapes of highest scenic amenity and views and prospects of specific importance.

• Adopt and encourage a sustainable approach for the management of the County’s natural, built and cultural heritage.

POLICY BNH1: Designated Nature Conservation Sites (Habitats) • Maintain, and where possible enhance, the conservation value of the all pNHAs,

cSACs and SPAs, as identified by the Minister for the DoEHLG, as well as many other sites that may be proposed for designation during the lifetime of this Plan.

• Ensure development proposals do not destroy or damage any sites of international or national importance, designated for their wildlife/habitat significance, including pNHAs, cSACs and SPA’s.

POLICY BNH 5: Landscape Conservation The areas of especially high scenic amenity (EHSA) in the County have been identified and illustrated on the map attached. These areas are of the highest landscape quality in the County, characterised by wilderness and few, if any, man made structures. They include the high cliffed coastal zones and upland mountain areas. The core principles underlying the Council’s policies for landscape conservation, are to give the highest degree of protection to the areas of highest scenic landscape quality and to adopt a positive attitude to development proposals in areas of relatively low scenic landscape quality. Accordingly only very limited development will be considered in the areas of especially high scenic amenity. Within this landscape identified as EHSA there may be small pockets which do not fully meet the definition of the designation e.g. where small clusters of dwellings exist or coniferous afforestation has occurred. Such anomalies in landscape designation shall be considered individually should an application for development be submitted with them. The onus shall be on the applicant to demonstrate that the site does not meet the characteristics of the EHSA and that any development applied for shall not


adversely affect the landscape value of the wider EHSA within which the site is located. The Council will also seek to preserve the views and prospects of special amenity value and interest, in particular, views between public roads and the sea, lakes and rivers. In this regard, development proposals situate on lands between the road and the sea, lakes or rivers shall be considered on the basis of the following criteria: • Importance value of the view in question. • Whether the integrity of the view has been affected to date by existing

development. • Whether the development would intrude significantly on the view. • Whether the development would materially alter the view. In operating this policy, a reasonable and balanced approach shall be implemented so as to ensure that the policy does not act as a blanket ban on developments between the road and the sea, lakes and rivers. Identified policies include: • Limit new residential development within the areas of Especially High Scenic

Amenity (EHSA) in accordance with the policies set out in the Chapter 5 (Housing Section). Public development tied to a fixed resource or which falls within the strategic infrastructural corridors will be facilitated.

• Not consider favourably Natural Resource Development (wind quarries) in EHSA. Other Natural Resource Developments within EHSA will be assessed on their own merits, having regard to policy guidance.

• Protect the character of the approach roads to Glenveagh National Park through the development management procedure. These approach roads are � Glendown to Doochary Road � Dunlewy to Termon Road � Churchill to Termon/Dunlewy Road � Muckish Gap to Cabiber Bridge

• Overhead power lines will not be permitted along these roads. Archaeological Heritage Goal: To conserve and protect the County’s archaeological heritage for future generations while encouraging its appreciation and enjoyment. Policy BNH 16: It is Council policy to: (i) Protect and enhance the integrity of archaeological monuments and their settings and all subsequent monuments/sites identified within the Plan period and also to secure the preservation (in-situ or, as a minimum, by record) of all archaeological monuments included in the Record of Monuments and Places and of sites, features and objects or archaeological interest generally. (iv) Work in partnership with the National Monuments Section, Department of the Environment, Heritage & Local Government and the Office of Public Works to protect, preserve, promote and enhance archaeological heritage and National Monuments. Also to consult with the DoEHLG in relation to any proposed developments adjacent to designated archaeological sites or resources and to adopt the ‘precautionary principle’ in reviewing such developments. Also to promote public awareness of the rich archaeological heritage of County Donegal.


(v) To seek archaeological assessments as part of a planning submission when proposed development could affect a Recorded Monument, a Zone of Archaeological Potential or their settings, also to require an archaeological assessment (including visual impact assessment) to be submitted detailing the potential impact of any development on both upstanding and buried structures/deposits when considering development in the vicinity of all upstanding remains. Ch. 10 The Gaeltacht, Sport and Recreation Policy GCSR 13: Support Údarás na Gaeltachta and An Roinn Gnóthaí Pobail, Tuaithe agus Gaeltachta in their respective development roles. REGIONAL PLANNING GUIDELINES – BORDER REGION The proposed development all falls within sub-region 1 as defined in the guidelines. The key settlement of this Sub Region is the linked Gateway of Derry and Letterkenny. This part of the Border Region enjoys the Atlantic Ocean and rugged coastline of the North West of the Country and majestic mountain scenery, and is a part of the Region which can be classified as having outstanding natural beauty. It is culturally distinct, with a large part of north West Donegal being a Gaeltacht. The importance of the Gaeltacht to this part of the Region is recognised, and the development of the language and the cultural heritage of the area is emphasised. The Sub Regions strengths centre around the development of Letterkenny, with its strong socio economic and physical links with Derry and Sligo in the South. Issues which the Sub Region needs addressing include its peripherality, the necessity for key infrastructural links being a priority. Cross border fiscal distortions also provide pressure and need careful consideration. The development of the Linked Gateway at Letterkenny/Derry will provide key opportunities for this part of the Region with strengthening opportunities for many of the other settlements. Section 2.8 makes recommendations which could be considered for advancement of the Gaeltacht in County Donegal including: • enhancing the attractiveness of rural settlements; • the promotion of indigenous small businesses and natural resources, light industry,

technology and services; • local enterprise centres; • the maintenance of the N56 as a key access route to peripheral areas; • improvements to the water supply and waste water network; • strengthening the resilience of the energy network and facilitating the provision of

communications infrastructure such as broadband; • promotion of the Irish language and culture. Ardara, Glenties, Dunglow, Bunbeg / Derrybeg are all identified as regionally strategic towns. Letterkenny is identified as a Linked Gateway with Derry. Section 6.5 considers Energy Infrastructure. The National Spatial Strategy has identified reliable and effective energy systems such as gas and electricity to power industry and services as key prerequisites for effective regional development. Prime considerations relevant to the Border Region are the development of energy


infrastructure on an all - island basis and the strengthening of energy networks in the West, North West, Border and North Eastern areas in particular. Renewable Energy needs special status and the development of Wind, Biomass and Water have particular regional potential. Priorities include the improvement in reliability of supply to the NorthWest and Border and North Eastern parts of the country and strategic strengthening of the electricity grid serving particular clusters of employment related demand in peripheral areas. NATIONAL SPATIAL STRATEGY 2002 - 2020 Section 3.7 notes that achieving spatial balance by developing the potential of areas will depend on enhancing capacity for the movement of people, goods, energy and information between different places. Physical networks of infrastructure such as roads, public transport, energy and communications are of particular relevance to the NSS. 3.7.2 identifies prime considerations in terms of spatial policies relating to energy: • Developing energy infrastructure on an all-island basis. • Strengthening energy networks in the west, north-west, border and north-eastern

areas. • Enhancing both the robustness and choice of energy supplies across the regions,

through improvements to the national grids for energy and gas. Strategic Energy infrastructure priorities identified in section 3.8.2 include: • Improving reliability of electricity supply in western, northwestern, border and

north-eastern areas through enhanced access to the national griod. • Strengthening the electricity supply networks to and within proposed gateways

and hubs. • Strategic strengthening of the electricity grid serving particular clusters of

employment related demand in peripheral areas, e.g. in west Donegal. Section 4.2 outlines how the border region will participate in the NSS. The northwestern area, mainly Donegal, is identified as a sub-region. Letterkenny is identified as a Gateway in the strategy, linked with Derry. The strengthened role and contribution of the Gateways is critical to drive development through enhanced critical mass, accessibility and capacity for development. Villages in remoter areas where the urban structure is weak, play an important role in delivering services and supporting employment in physically remote and peripheral areas. This role should be acknowledged and supported through improvements in accessibility and supporting opportunities for development. The north-west is largely identified as a revitalising region, characterised by remoteness from the largest population centres and the poor quality of its agricultural land. It also includes outstanding mountain, lake and coastal scenery, rich in flora and fauna. The prime consideration for this area is recognising that its resource potential lies in the sheer quality of its environment and that in its economic development, this quality can help to compensate for the disadvantages of its remoteness.


The economic realisation of this resource will depend on: • A discriminating tourism product. • Attracting enterprises and people with stills and expertise for whom the smaller

towns and villages offer a quality of life which they seek. • Advanced communications infrastructure which can extend the range of economic

activities undertaken. 4.0 CONCLUSION Local, regional and national policy documents note the infrastructural deficiencies in the region and the need to strengthen energy infrastructure. Particular emphasis is placed on supporting the role of Letterkenny, as a Gateway town, and of other identified settlements, including Gweedore. The need to improve infrastructure within the Gaeltacht area in order to facilitate economic growth is recognised is also identified in the policy documents, as is the need for network strengthening to facilitate increased renewable energy generation. The proposed 110kV overhead lines generally follow the infrastructural corridors for ESB reinforcement identified in the County Development Plan, and avoid the exclusion areas for overhead lines identified in the plan. It is also noted that the Development Plan indicates that public development within EHSA’s will be facilitated where it falls within these strategic infrastructural corridors. The proposed development seeks to address identified infrastructural deficiencies in the region and can be regarded as complying with the relevant strategic policy documents. Notwithstanding this conclusion, however, it is noted that the NSS acknowledges the economic resource which the landscape and scenery of the region comprises. Regard should, therefore, be had to the economic value of this resource in considering the impacts of the proposed development.

An Bord Pleanála · sites of ecological importance. It states there are no significant affects...

Documents

Transcript of An Bord Pleanála · sites of ecological importance. It states there are no significant affects...