HomeMy WebLinkAbout2560400 - F.I. Received Doc. - FI Response Report
Further Information
Response Report
Project:
Clones Single Turbine Wind Farm,
Co. Monaghan
Applicant:
Art Generation Limited
Date of Report 1st Issue:
02nd September 2026
Document Ref. No.:
22790-FI Report-P2 RECEIVED: 04/09/2026
Document Ref. Number: 22790-FI Report-P2
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Table of Contents
1.0 Introduction ........................................................................................................................ 2
1.1 FI Extract .................................................................................................................................... 3
2.0 Response to FI Items ......................................................................................................... 4
2.1 FI Item 1 ..................................................................................................................................... 4
2.2 FI Item 2 ..................................................................................................................................... 8
2.3 FI Item 3 ....................................................................................................................................10
2.4 FI Item 4 ....................................................................................................................................12
2.5 FI Item 5 ....................................................................................................................................14
Appendix A – Response to Submission by Sinead Hughes ............................................................... i
Appendix B – Response to Submission by Fintan Morgan ................................................................. ii
Appendix C – Response to Submission by Martin Beagan ............................................................... iii
Appendix D – Response to Submission by Micheal Beagan ............................................................. iv
Appendix E – Response to Submission by T. Barmley & E. Sheridan .............................................. v
Appendix F – Response to Submission by Gregory Sheridan ........................................................... vi
Appendix G – Response to Submission by DoHLG&H .................................................................... vii
Appendix H – Response to Submission by Dep. of Defence ........................................................... viii
Appendix I – Response to Irish Aviation Authority Submission ........................................................ ix
Document Control
Author(s) Date Revision
Status Issue Date Comment Name Signature
02/09/2026
P2 02/09/2026 Issued as part of
FI response
M.Mulroy
Civil Engineer
Mr. E. Roche
Senior Engineer
02/09/2026
Reviewed by Review Date Name Signature
02/09/2026
Mr. B. McGinn
Chartered Engineer
RECEIVED: 04/09/2026
Document Ref. Number: 22790-FI Report-P2
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1.0 Introduction
This Further Information (FI) Response Report has been prepared by Mable Consulting Engineers on behalf of Art
Generation Limited (the applicant) in response to a FI request issued on foot of planning application reference number
25/60400 by Monaghan County Council on 01st December 2025.
The planning application is for a 10-year planning permission from Monaghan County Council for a proposed 4.8 MW
Single Turbine development, within the townlands of Carney’s Island, Altartate Glebe, Legarhill, and Clonevilla, County
Monaghan (the Development).
An extension to the Further Information response period was requested and granted by Monaghan County Council to
facilitate additional ornithological survey work.
Below is a list of drawings and documents produced and submitted as part of the FI response. All drawings and
documents should be read in conjunction with one another.
Documents:
Document Name: Document Reference:
Further Information Response Report (This Report) 22790-FI Report-P2
Ecological Impact Assessment Report (Version 2) 2026.08.27 Clones SWT EcIA_V2
Ecological Impact Assessment
Appendix 1: Bat Mitigation & Monitoring Plan
2026.08.27 Clones SWT Bat Mitigation and Monitoring
Plan V2
Ecological Impact Assessment
Appendix 2: Bird Mitigation & Monitoring Plan
2026.08.27 Clones SWT Bird Mitigation_Monitoring
Plan_V2
Screening Report for Appropriate Assessment 2026.08.28 Clones SWT Screening Report V2
Noise Impact Report (Version 2) Clones Noise Report_68 houses Version 2
Shadow Flicker Report (Version 2) 7234 Clones Shadow Flicker_Final Version 2
Flood Risk Assessment M02218-04_FR01 Clones Wind Farm_RFI_FRA Rev 01
Water Environment Assessment M02218-04_ENV01 Clones Wind Farm RFI_Water
Environment Assessment Rev01
Drawings:
Drawing Name: Drawing Reference:
Site Layout Map – Key Plan 22790-101-P6
Site Layout Map ‘A’ 22790-102-P5
Site Layout Map ‘B’ 22790-103-P5
Site Layout Map ‘C’ 22790-104-P4
Site Entrance Arrangement 22790-110-P4
Site Entrance Sight Lines 22790-111-P2
Proposed Bridge Detail 22790-154-P2
RECEIVED: 04/09/2026
Document Ref. Number: 22790-FI Report-P2
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1.1 FI Extract
FI request items are extracted below:
1. A submission has been received from the Department of Housing, Local Government and Heritage. The
applicant is requested to review this submission and provide further information on the potential for
ornithological impacts arising from the proposed development and further details on the assessments
conducted including observational data.
2. Section 15.22.8 of the Monaghan County Development Plan 2025-2031 states that development should be
restricted and/or limited in areas which are at risk of flooding, unless it can be demonstrated that the proposed
development has addressed the flooding concerns which exist.
The Office of Public Works flood maps indicate that part of the application site is vulnerable to fluvial flooding.
In this regard, the Applicant shall submit a Flood Risk Assessment for the proposed development, completed
by a competent professional with hydrological experience, confirming that the development:
• Will not be at risk of flooding
• Will not exacerbate flooding in the immediate vicinity or wider area.
• Will not obstruct or impede important flow paths
• Will not result in residual risks to the area and/or development that cannot be managed to an
acceptable level.
The flood risk assessment shall also clearly demonstrate proposed management of any residual risks.
3. Submit a revised site layout plan indicating how a clear and unobstructed visibility splay of 120m in each
direction onto the Regional Road (R-183-4)) can be achieved at the proposed entrance. The required visibility
splays should be provided from a point in the centre of the entrance, 2.4 metres from the road edge at a height
of 1.05 metre above ground level measured to the nearside road edge in both directions. The submitted revised
site layout plan should demonstrate all necessary site work, including the extent of the front boundary hedge
and trees which would be required to be removed/trimmed, re-grading of side banks etc to achieve these sight
distances. The Area within the visibility slays shall be cleared to provide a level surface no higher than 250
mm above the level of the adjoining carriageway and shall be retained and kept clear thereafter. Any pole or
column materially affecting visibility must also be removed.
Where visibility splays cross over land not in the ownership of the applicant, legal agreements with adjoining
landowner/s giving their consent for the removal, and or setting back of hedgerow/s, and or, maintenance of
hedges to provide the required sight distance shall be submitted to the Planning Authority.
4. It is noted that a ten year planning permission is sought. No justification has been provided for this. In this
regard, and in the context of RED III provisions, the applicant shall justify why it is considered a ten year
permission is appropriate.
5. The Planning Authority has received a number of third-party submission in respect of the proposed
development. The applicant is invited to review the content of same and provide a detailed response to the
issues raised.
RECEIVED: 04/09/2026
Document Ref. Number: 22790-FI Report-P2
__________________________________________________________________________________________________________________
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2.0 Response to FI Items
2.1 FI Item 1
Extract:
“1. A submission has been received from the Department of Housing, Local Government and Heritage. The
applicant is requested to review this submission and provide further information on the potential for
ornithological impacts arising from the proposed development and further details on the assessments
conducted including observational data.”
Department of Housing, Local Government and Heritage Submission Extract:
Item 1
1.Par 1
Nature Conservation
The Department acknowledges the findings of the AA screening report and Ecological Impact
Assessment (EclA) supporting the application. The following observations are provided;
Item 2
2.Par 1
Matters relating to ornithological assessments
Attention is drawn to the ornithological assessment of the proposed development as
described within the EclA, noting that the recommended 36 hours of vantage point surveys
(NatureScot, 20251) were not conducted in this case, instead having been scaled down to a
total of 21.5 hours. However, the report does not provide further details regarding the
decision-making process in coming to this determination for the reduction in survey effort
and is deemed to lack weight.
2.Par 2 In addition, there appears to have been only very limited survey effort during the 2023/2024
winter period, restricted to a combined total of 7 hours vantage point (VP) surveys on the
12th October 2024 and 7th February 2024. This is considered to be a significant constraint
for making any determination on the collision risks involving wintering waterbirds in the
vicinity of the proposed development beyond all reasonable doubt, most notably for
Whooper Swan (Cygnus Cygnus) and Greenland White-fronted Goose (Anser albifrons
flavirostris), both listed under Annex I of the Birds Directive (Directive 2009/147/EC).
Waterbird abundances typically peak during the December-January window and could not
have been adequately considered in this context.
2.Par 3 The recommended 36 hours of VP survey effort over two breeding and two non-breeding
seasons is considered as good practise by the Department as part of ecological surveys for
any onshore wind energy development. It is recommended that data presented within the
mapping interface 'Bird sensitivity to wind energy developments' mapping interface2 should
be used as guidance only and not as a definitive likelihood for the presence/absence of
species sensitive to increased risks from collision with such developments. Whilst this
proposed development is noted to be comprised of a single turbine, the overall blade tip
height of 149.61m is considered to have a higher ornithological impact potential than smaller
developments of a comparative type. RECEIVED: 04/09/2026
Document Ref. Number: 22790-FI Report-P2
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2.Par 4 The Department also notes that, in spite of the small scale of the proposed development
within an agricultural landscape, no wider ornithological assessments of the surrounding-
waterbodies appear to have been undertaken in considering the wider implications for
species commuting between sites for roosting and foraging purposes. The primary habitat
ype as identified within the EclA as 'improved agricultural grasslands within a wider farmed
landscape' does not preclude the potential for wildfowl to utilise this habitat type for foraging
in suitable areas, e.g. low-lying grasslands including the floodplains of suitable river valleys.
For example, the Kilroosky Lough Cluster SAC (site code: 001786) is situated 1.5km from
the application site, whilst the closest waterbody is Bishop's Lough, situated approximately
400m to the south east from the location of the proposed turbine, is situated within the wider
wetland network and forms part of the Finn River watershed
2.Par 5 The Department refers to the EclA which states that "Areas of higher value habitat for birds
in the surrounding locality such as at Bishops Lough and Altartate Lough and the
surrounding wetland will not be affected by the projec. The EclA also states that no sensitive
species were found within the vicinity of the project, but provides no further details to
elaborate on these statements. The Monaghan County Development Plan 2019-2025
identifies Bishop's Lough (MFS-12) as a site of biodiversity importance at the county scale
and may provide suitable habitat for intermittent usage by Whooper Swan during the lifetime
of any planning consent.
2.Par 6 The Department recommends that further information is provided on the potential for
ornithological impacts arising from the proposed development and further details on the
assessments conducted, including observational data.
Item 3
3.Par 1
Archaeology
It is noted that an archaeological assessment report by Martin Fitzpatrick, Archaeologist has
been submitted with this application. This Department concurs with the recommendations as
outlined in this report and recommends that archaeological Pre-development trenching be
carried out at this site and included as a condition in the granting of any planning
permission.
3.Par 2 Pre-development testing shall consist of the following;
The applicant is required to engage the services of a suitably qualified archaeologist
(licensed under the National Monuments Acts 1930-2004) to carry out pre-
developmenttesting at the site. No sub-surface work shall be undertaken in the absence of
the archaeologist without his/her express consent.
3.Par 3 The archaeologist is required to notify the Department of Housing, Local Government and
Heritage in writing at least four weeks prior to the commencement of site preparationsd. This
will allow the archaeologist sufficient time to obtain a licence to carry out the work.The
archaeologist shall carry out any relevant documentary research and may excavate test
trenches at locations chosen by the archaeologist, having consulted the proposed
development plans. RECEIVED: 04/09/2026
Document Ref. Number: 22790-FI Report-P2
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3.Par 4 Archaeological Test Excavation shall be informed and supplemented by licensed metal
detection survey.
3.Par 5 Having completed the work, the archaeologist shall submit a written report to the Planning
Authority and to the Department of Housing, Local Government and Heritage.
3.Par 6 Where archaeological material is shown to be present, avoidance, preservation in situ,
preservation by record (excavation) and/or monitoring may be required, the Department of
Housing, Local Government and Heritage will advise the Applicant/Developer with regard to
these matters.
3.Par 7 No site preparation or construction work shall be carried out until after the archaeologist's
report has been submitted and permission to proceed has been received in writing from the
Planning Authority in consultation with the Department of Housing, Local Government and
Heritage.
3.Par 8 Reason: To ensure the continued preservation (either in situ or by record) of places, caves,
sites, features or other objects of archaeological interest.
Response:
Item 1 - Nature Conservation, and Item 2 -Matters Relating To Ornithological Assessments
In response to FI Item 1, Doherty Environmental Consultants Ltd. (DECL) was commissioned to review the matters
raised by the Department of Housing, Local Government and Heritage and to undertake additional ornithological
assessment of the proposed Development. This included further onsite vantage point and transect surveys, targeted
consideration of wintering waterbirds, additional assessment of Bishop’s Lough and surrounding agricultural feeding
habitat, and a review of the wider wetland network and available ornithological records.
The additional survey work has substantially increased the ornithological dataset available for the site. The updated
EcIA records a total of 51 hours of vantage point monitoring, together with additional transect surveys and targeted
observations of Bishop’s Lough. A total of 29 bird species were recorded, including seven target species during VP
surveys. The assessment has also been informed by available NBDC and I-WeBS records and bird survey information
from wind energy developments in the wider area, including consideration of the occurrence and distribution of wintering
swans and other waterbirds.
The additional survey effort, observational data and assessment of potential ornithological impacts, including specific
consideration of Whooper Swan and Greenland White-fronted Goose, have been incorporated into the updated
Ecological Impact Assessment (Document Reference: 2026.08.27 Clones SWT EcIA_V2), which is submitted as part
of this FI response.
Particular consideration has been given to the potential ecological function of Bishop’s Lough, including its potential for
intermittent future use by Whooper Swan and Greenland White-fronted Goose and the potential for movements between
the lough, surrounding agricultural feeding areas and other wetlands. The assessment distinguishes between current
recorded use and potential future use and considers habitat loss, disturbance/displacement, barrier effects and collision
risk on a precautionary basis.
RECEIVED: 04/09/2026
Document Ref. Number: 22790-FI Report-P2
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The updated EcIA concludes that, based on the additional survey work and available observational data, there is no
evidence of regular Whooper Swan and Greenland White-fronted Goose use of Bishop’s Lough, regular feeding use of
the surrounding agricultural lands, or a regular flight corridor through the proposed turbine location. The current collision
risk is therefore assessed as Low and Not Significant. The assessment nevertheless recognises that Bishop’s Lough
could be used intermittently by Whooper Swan and Greenland White-fronted Goose during the operational life of the
Development and has adopted a precautionary approach to this potential future use.
Notwithstanding the findings of the assessment, a Bird Mitigation and Monitoring Plan (Appendix 2) has been prepared.
The Plan provides for continued pre-construction and construction-phase monitoring, targeted monitoring of Bishop’s
Lough and surrounding feeding areas, operational VP and collision-fatality monitoring, incident reporting and adaptive
management. Where monitoring identifies an elevated collision risk, measures include increased survey effort,
shutdown-on-demand and, where required, programmed curtailment. The Plan also establishes defined monitoring
triggers and an annual reporting mechanism to the Planning Authority and NPWS.
The updated EcIA is also supported by a Bat Mitigation and Monitoring Plan (Appendix 1), which provides for five years
of operational bat activity and mortality monitoring together with an adaptive mitigation framework, including operational
curtailment where required.
Accordingly, the updated EcIA, together with the Bird Mitigation and Monitoring Plan and Bat Mitigation and Monitoring
Plan, provides the additional survey information, observational data, assessment and precautionary mitigation required
to address the Nature Conservation matters raised by the Department. With the implementation of the identified
mitigation and monitoring measures, the updated EcIA concludes that the proposed Development will not give rise to
significant negative residual impacts on habitats or fauna.
Item 3 - Archaeology
The Archaeology items above are noted and accepted. The Applicant will engage the services of a suitably qualified
archaeologist, licensed under the National Monuments Acts 1930–2004, to undertake the required pre-development
testing, including relevant documentary research, test trenching and licensed metal detection survey, and will notify the
Department of Housing, Local Government and Heritage at least four weeks prior to commencement.
A written report will be submitted to the Planning Authority and the Department, and where archaeological material is
identified, the Applicant will comply with any requirements for avoidance, preservation in situ, preservation by record
and/or monitoring. No site preparation or construction work will commence until the archaeologist’s report has been
submitted and written permission to proceed has been received from the Planning Authority in consultation with the
Department.
Further responses in relation to Ecology and Archaeology are contained in the attached Appendices A to I.
RECEIVED: 04/09/2026
Document Ref. Number: 22790-FI Report-P2
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2.2 FI Item 2
Extract:
“2. Section 15.22.8 of the Monaghan County Development Plan 2025-2031 states that development should be
restricted and/or limited in areas which are at risk of flooding, unless it can be demonstrated that the proposed
development has addressed the flooding concerns which exist.
The Office of Public Works flood maps indicate that part of the application site is vulnerable to fluvial flooding.
In this regard, the Applicant shall submit a Flood Risk Assessment for the proposed development, completed
by a competent professional with hydrological experience, confirming that the development:
• Will not be at risk of flooding
• Will not exacerbate flooding in the immediate vicinity or wider area.
• Will not obstruct or impede important flow paths
• Will not result in residual risks to the area and/or development that cannot be managed to an acceptable
level.
The flood risk assessment shall also clearly demonstrate proposed management of any residual risks.”
Response:
In follow-up to FI 2, McCloy Consulting were commissioned to undertake a detailed assessment of flood risk and the
water environment associated with the proposed Development. A Stage 3 detailed site-specific Flood Risk Assessment
was prepared to address the flood risk matters raised by the Planning Authority. A Water Environment Assessment was
also prepared to assess the potential effects of the proposed Development on surface water, groundwater, water quality,
drainage and watercourses.
The FRA was undertaken in accordance with The Planning System and Flood Risk Management – Guidelines for
Planning Authorities and the requirements of the Monaghan County Development Plan 2025–2031. The assessment
included detailed site-specific hydraulic modelling of the relevant watercourses and floodplain, including climate change
and culvert blockage scenarios.
The site-specific hydraulic modelling supersedes the indicative OPW NIFM mapping and confirms that all highly
vulnerable elements of the proposed Development, including the wind turbine and substation, are located on higher
ground within Flood Zone C and outside the modelled flood extents. Accordingly, these elements are not considered to
be at material risk of fluvial flooding.
A section of the proposed access route adjacent to the R183 passes through Flood Zones A and B and crosses the
Legarhill Watercourse; however, the hydraulic modelling confirms that the proposed access route and watercourse
crossing will result in no measurable effect on flood levels, no material change to flood extents and no adverse effect
on flood risk at the site or elsewhere.
The assessment also considered the residual risk associated with blockage of existing and proposed watercourse
structures and confirmed that this would not result in a material change to flood risk.
Following completion of the FRA, the modelled flood lines were incorporated into the revised Site Layout Drawings. The
proposed access track and bridge levels were updated. The proposed access track will be raised above the relevant
flood levels to provide dry access and egress to the Development, and the proposed watercourse bridge crossing has
been designed to provide the required opening and freeboard in accordance with OPW Section 50 requirements.
RECEIVED: 04/09/2026
Document Ref. Number: 22790-FI Report-P2
__________________________________________________________________________________________________________________
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The Water Environment Assessment also considered the drainage and water quality requirements associated with the
proposed Development. A SuDS drainage approach has been incorporated into the design, including clean and dirty
water cut-off drains, settlement features, buffered outfalls and level spreaders, with no direct discharge of collected
surface water to existing drains or streams. Measures are also included for works within the floodplain during the
construction phase, including that no plant, materials or fuels will be parked or stored within the floodplain and that
works will cease and potential sources of contamination will be removed from the floodplain in advance of a severe
flood event.
On the basis of the assessments undertaken and the design measures incorporated, the proposed Development will
not be at unacceptable risk of flooding, will not exacerbate flooding in the immediate vicinity or wider area, will not
materially obstruct or impede important flow paths, and any residual flood risks can be managed to an acceptable level.
The Flood Risk Assessment (M02218-04_FR01) and Water Environment Assessment (M02218-04_ENV01) are
submitted as part of the FI response.
The following reports and drawings are submitted in support of the FI Item 2 response:
Reports
Flood Risk Assessment
o Doc. Ref.: M02218-04_FR01 Clones Wind Farm_RFI_FRA Rev 01
Water Environment Assessment
o Doc. Ref.: M02218-04_ENV01 Clones Wind Farm RFI_Water Environment Assessment Rev01
Drawings:
Site Layout Map – Key Plan
o Drawing Ref.: 22790-101-P6
Site Layout Map ‘A’
o Drawing Ref.: 22790-102-P5
Site Layout Map ‘B’
o Drawing Ref.: 22790-103-P5
Site Layout Map ‘C’
o Drawing Ref.: 22790-104-P4
Proposed Bridge Detail
o Drawing Ref.: 22790-154-P2 RECEIVED: 04/09/2026
Document Ref. Number: 22790-FI Report-P2
__________________________________________________________________________________________________________________
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2.3 FI Item 3
Extract:
‘3. Submit a revised site layout plan indicating how a clear and unobstructed visibility splay of 120m in each direction
onto the Regional Road (R-183-4)) can be achieved at the proposed entrance. The required visibility splays should
be provided from a point in the centre of the entrance, 2.4 metres from the road edge at a height of 1.05 metre
above ground level measured to the nearside road edge in both directions. The submitted revised site layout plan
should demonstrate all necessary site work, including the extent of the front boundary hedge and trees which would
be required to be removed/trimmed, re-grading of side banks etc to achieve these sight distances. The Area within
the visibility slays shall be cleared to provide a level surface no higher than 250 mm above the level of the adjoining
carriageway and shall be retained and kept clear thereafter. Any pole or column materially affecting visibility must
also be removed.
Where visibility splays cross over land not in the ownership of the applicant, legal agreements with adjoining
landowner/s giving their consent for the removal, and or setting back of hedgerow/s, and or, maintenance of hedges
to provide the required sight distance shall be submitted to the Planning Authority.”
Response:
In response to FI Item 3, a detailed topographical survey of the public Regional Road (R-183-4) in the vicinity of the site
entrance was commissioned. The survey information was used to update the Site Entrance Arrangement drawing
(Drawing Ref.: 22790-110-P4) and to prepare a new Site Entrance Sight Lines drawing (Drawing Ref.: 22790-111-P2).
Drawing 22790-110-P4 was updated to incorporate the topographical survey information into the proposed site entrance
arrangement. Drawing 22790-111-P2 shows plans of the existing and proposed arrangements, including the required
visibility splays, together with longitudinal profiles along the sight lines – in accordance with the requirements of the
above FI request.
The drawings demonstrate that clear and unobstructed visibility splays of 120m in each direction measured from a point
in the centre of the entrance, 2.4m from the road edge and at a height of 1.05m above ground level, measured to the
nearside road edge - are achieved.
The drawings demonstrate that the required visibility splays are achieved without removal or alteration to the existing
hedgerows or existing trees. The drawings also demonstrate that no works in private lands are required to accommodate
visibility splays.
The areas within the visibility splays comprise the proposed site entrance, the grassed public road verge and the
nearside edge of the public road. The topographical survey confirms that the proposed site entrance and the majority
of the grassed public road verge meet the requirement for a level surface no higher than 250mm above the level of the
adjoining carriageway.
A small number of localised areas of the grassed public road verge are currently more than 250mm above the level of
the adjoining carriageway. These areas are identified on the Sightline Elevation detail contained in Drawing 22790-111-
P2 and will be locally regraded as part of the proposed entrance works.
On completion of the localised regrading works, the full area within the visibility splays will provide a level surface no
higher than 250mm above the level of the adjoining carriageway and will be retained and kept clear thereafter.
RECEIVED: 04/09/2026
Document Ref. Number: 22790-FI Report-P2
__________________________________________________________________________________________________________________
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The information set out above, together with the submitted drawings, demonstrates that the visibility splay and clearance
requirements of FI Item 3 can be achieved and maintained.
The following drawings are submitted in support of the FI Item 3 response:
Drawings
Site Entrance Arrangement
o Drawing Ref.: 22790-110-P4
Site Entrance Sight Lines
o Drawing Ref.: 22790-111-P2
RECEIVED: 04/09/2026
Document Ref. Number: 22790-FI Report-P2
__________________________________________________________________________________________________________________
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2.4 FI Item 4
Extract:
“4. It is noted that a ten year planning permission is sought. No justification has been provided for this. In this
regard, and in the context of RED III provisions, the applicant shall justify why it is considered a ten year
permission is appropriate.”
Response:
A 10-year planning permission is sought to allow an appropriate period for the commencement and completion of the
proposed Development following the grant of permission. This period is separate from the proposed 35-year operational
lifespan, which would commence on the commissioning of the Development.
Section 41 of the Planning and Development Act 2000, as amended, allows a Planning Authority to specify the period
during which a permission is to have effect, having regard to the nature and extent of the development and any other
material considerations.
The Wind Energy Development Guidelines for Planning Authorities (2006) specifically recognise that permission for a
duration longer than five years may be appropriate for wind energy development, including to ensure that the permission
does not expire before a grid connection is granted. Although not adopted, Section 7.22 of the Draft Revised Wind
Energy Development Guidelines (2019) contains the same provision.
In the case of the proposed Development, a number of interrelated processes must be progressed before the
Development can be constructed and commissioned, including:
A. Grid Connection
The Development will require connection to the electricity network. The grid connection process may involve
technical studies, confirmation of network capacity, connection agreements, detailed electrical design, and the
programming and delivery of associated network works. The timing of these processes is not entirely within the
control of the Applicant and may extend over a number of years.
B. Route to Market and Project Financing
A commercially viable route to market will be required before the Development can proceed to construction. This
may include participation in renewable electricity support arrangements, a Power Purchase Agreement or other
commercial arrangements. The timing of these processes is directly linked to project financing and the ability to
proceed to construction.
C. Procurement and Construction
The Development requires the procurement and delivery of specialist wind turbine and electrical equipment.
Turbine availability, manufacturing lead-in periods, electrical equipment procurement and contractor availability
can influence the programme for commencement and completion of the Development.
The requested 10-year permission is also consistent with the operation of RED III. RED III and the relevant Irish
transposing provisions introduce timelines intended to expedite the permit-granting procedure for renewable energy
development. These timelines do not limit the period within which an approved development may subsequently be
implemented. In particular, Article 16(8) of Directive (EU) 2018/2001, as amended by RED III, provides that, except
where it coincides with another administrative stage of the permit-granting procedure, the duration of that procedure
does not include the time during which renewable energy plants, their grid connections and related necessary grid
infrastructure are being constructed.
RECEIVED: 04/09/2026
Document Ref. Number: 22790-FI Report-P2
__________________________________________________________________________________________________________________
13
Accordingly, the 10-year permission does not seek to extend or delay the planning determination process. Rather, it
provides a reasonable period following the grant of permission within which the necessary grid connection, route-to-
market, financing, procurement and construction processes can be progressed and completed.
This is also consistent with established planning practice for wind energy development in Ireland, where 10-year
permission periods are commonly granted having regard to the extended lead-in periods associated with grid
connection, financing, procurement and construction.
Having regard to the provisions of Section 41 of the Planning and Development Act 2000, as amended, the Wind Energy
Development Guidelines (2006), the consistent approach contained in the Draft Revised Wind Energy Development
Guidelines (2019), the distinction under RED III between the permit-granting procedure and the subsequent construction
period, and the particular implementation requirements of the proposed Development, a 10-year planning permission
is considered reasonable and appropriate.
RECEIVED: 04/09/2026
Document Ref. Number: 22790-FI Report-P2
__________________________________________________________________________________________________________________
14
2.5 FI Item 5
Extract:
‘5. The Planning Authority has received a number of third-party submission in respect of the proposed
development. The applicant is invited to review the content of same and provide a detailed response to the
issues raised.
Response:
In response to FI Item 5, all submissions and observations received in respect of the proposed Development were
reviewed in full. As a number of the matters raised related to more than one technical discipline, the relevant members
of the project design team and specialist consultants were consulted, and responses were obtained from each
applicable discipline.
The responses were then reviewed and compiled into a separate table for each submission, identifying the paragraph
or issue raised, the relevant discipline and the corresponding response. Where an observation covered a number of
disciplines, the individual responses were combined into a coordinated response. The detailed responses are contained
in Appendices A to I to this report.
As part of the response to FI Item 5, the Screening Report for Appropriate Assessment (2026.08.28 Clones SWT
Screening Report V2) has been updated to address matters raised in the third-party submissions. The updated
Screening Report is submitted as part of this FI response.
As part of the response to FI Item 5, the turbine setback distance has been reviewed and are illustrated in Figure 1
below. Section 6.18 of the Draft Revised Wind Energy Development Guidelines (December 2019) proposes a visual
amenity setback of four times the turbine tip height, subject to a minimum setback of 500m. For this Development, the
setback distance corresponding to four times the Turbine tip height is 575.2m.
As illustrated in Figure 1, all dwellings in the vicinity of the proposed Development are located outside the 575.2m
setback, with the exception of the dwelling associated with the participating landowner. Section 6.18.2 of the Draft
Revised Wind Energy Development Guidelines provides for reduced setback requirements where agreement has been
reached with the relevant property owner. We confirm that this agreement is in place with the relevant dwelling owner.
RECEIVED: 04/09/2026
Document Ref. Number: 22790-FI Report-P2
__________________________________________________________________________________________________________________
15
Figure 1 – Turbine Set-back
The following appendices are included with this report, and the following reports and drawings are submitted
separately, in support of the FI Item 5 response:
Appendices
Appendix A – Response to Submission by Sinead Hughes
Appendix B – Response to Submission by Fintan Morgan
Appendix C – Response to Submission by Martin Beagan
Appendix D – Response to Submission by Micheal Beagan
Appendix E – Response to Submission by T. Barmley & E. Sheridan
Appendix F – Response to Submission by Gregory Sheridan
Appendix G – Response to Submission by DoHLG&H vii
Appendix H – Response to Submission by Dep. of Defence
Appendix I – Response to Irish Aviation Authority Submission
Reports
Ecological Impact Assessment Report (Version 2)
o Doc. Ref.: 2026.08.27 Clones SWT EcIA_V2
Ecological Impact Assessment Appendix 1: Bat Mitigation & Monitoring Plan
o Doc. Ref.: 2026.08.27 Clones SWT Bat Mitigation and Monitoring Plan V2
Ecological Impact Assessment Appendix 2: Bird Mitigation & Monitoring Plan
o Doc. Ref.: 2026.08.27 Clones SWT Bird Mitigation_Monitoring Plan_V2
Lands Forming Part of the Development RECEIVED: 04/09/2026
Document Ref. Number: 22790-FI Report-P2
__________________________________________________________________________________________________________________
16
Screening Report for Appropriate Assessment
o Doc. Ref.: 2026.08.28 Clones SWT Screening Report V2
Noise Impact Report (Version 2)
o Doc. Ref.: Clones Noise Report_68 houses Version 2
Shadow Flicker Report (Version 2)
o Doc. Ref.: 7234 Clones Shadow Flicker_Final Version 2
Flood Risk Assessment
o Doc. Ref.: M02218-04_FR01 Clones Wind Farm_RFI_FRA Rev 01
Water Environment Assessment
o Doc. Ref.: M02218-04_ENV01 Clones Wind Farm RFI_Water Environment Assessment Rev01
Drawings:
Site Layout Map – Key Plan
o Drawing Ref.: 22790-101-P6
Site Layout Map ‘A’
o Drawing Ref.: 22790-102-P5
Site Layout Map ‘B’
o Drawing Ref.: 22790-103-P5
Site Layout Map ‘C’
o Drawing Ref.: 22790-104-P4
Site Entrance Arrangement
o Drawing Ref.: 22790-110-P4
Site Entrance Sight Lines
o Drawing Ref.: 22790-111-P2
Proposed Bridge Detail
o Drawing Ref.: 22790-154-P2 RECEIVED: 04/09/2026
Document Ref. Number: 22790-FI Report-P2
__________________________________________________________________________________________________________________
i
Appendix A – Response to Submission by Sinead Hughes
RECEIVED: 04/09/2026
22790 - Appendix A - P2
Paragraph Observations/ Point Response By Response
Item 1
1.Par 1
Environmental Reasons
This site is in an area rich with birds and wildlife. The proposal
could have an impact on the habitat and species of many
animals and migratory birds which are protected under the EU
Birds & Habitats Directive. Has there been an Environmental
Impact Assessment done on this project?
Doherty
Environmental
Consultants Ltd.
Mable Consulting
Engineers
One of the triggers for a project to require an EIA under the European Union's Environmental Impact
Assessment Directive is that it falls within the categories set out in Annex I or Annex II. The proposed
Development does not meet the applicable criteria requiring EIA and, following screening, an EIA is not
required.
In accordance with the Planning and Development Regulations, 2001, Part 10 - Environmental Impact
Assessment, Schedule 5, Part 2(3)(i) an Environmental Impact Assessment (EIA) is not required for this
Development as it comprises fewer than 5 turbines and has an output less than 5 megawatts.
1.Par 2 I emailed the Liaison address that was provided in the Intention
notice to apply with several queries but as yet I have not received
a reply.
Art Generation
Ltd.
The email in question was received 08/10/2025 and a response was provided on 22/10/2025. The
response noted that it would be more appropriate to addressed technical related questions to the
planning authority.
1.Par 3 The noise, vibration and shadow flicker may disturb the breeding
or roosting areas for the wildlife on the neighboring lake. There is
also the possibility of turbine collision and displacement effects
on the birds – for example buzzards and bats. The proposed site
lies along a known bird migration corridor.
Doherty
Environmental
Consultants Ltd.
The potential effects to fauna arising from the proposed development are set out in the Ecological Impact
Assessment (EcIA) that accompanies the planning application for the proposed development. The EcIA
assesses the potential impacts to fauna arising from these effects as sets out measures to ensure that
significant effects to fauna are avoided.
1.Par 4 Lighting, turbine height, and blade tip speed may further increase
collision risk. The construction and maintenance of the turbine
would require a lot of excavation, andheavy machinery access
across three townlands and alongside a canal which would
destroy hedgerows, habitats, and nesting areas. The
development could fragment wildlife corridors, isolating
populations and reducing biodiversity. The noise and vibration
from operation could disrupt sensitive fauna, especially at night.
The development requires significant site clearance and road
upgrades that will result in the loss of hedgerows and mature
trees, which are essential for nesting birds and as bat flight
corridors. This would result in a permanent loss of ecological
connectivity in the area.
Doherty
Environmental
Consultants Ltd.
The potential effects of the proposed development to habitats and fauna are set out in the EcIA. The
assessment examines the potential impact to fauna and habitats arising from potential effects such as
collision; fragmentation; habitat loss and disturbance. Mitigation measures are set out in the EcIA that,
when implemented in full, will avoid the potential significant effects to biodiversity receptors.
Observer: Sinead Hughes - Letter Dated 19/10/2025
RECEIVED: 04/09/2026
22790 - Appendix A - P2
Paragraph Observations/ Point Response By Response
Observer: Sinead Hughes - Letter Dated 19/10/2025
1.Par 5 We also feel that the turbine’s m height would visually dominate
an otherwise unspoiled upland landscape, reducing its
ecological and recreational value and conflicting with Monaghan
County Development Plan policies on landscape protection.
Macroworks Ltd. Some of the observations relate to the scale and height of the proposed turbine and that it will ‘dominate
the landscape’ and will ‘dramatically alter the landscape’. With regard to the proposed development it
includes for a single wind turbine development rising to a height of 143.8m. Whilst this is a sizeable built
form, it does not represent the largest turbines within the surrounding landscape or throughout the
island of Ireland. Indeed, the nearest turbines to the proposed development relate to the Drumlins Park
Wind Farm turbines, which rise to a maximum height of 180m and are viewed in an almost identical
rolling drumlin context.
Furthermore, whilst the proposed turbine will present as a prominent built feature within the local
surrounding landscape, its slender nature heavily diminishes its overall perceived scale and visual
prominence. In addition, the receiving landscape context also aids in diminishing the perceived scale of
the development, with the surrounding rolling drumlin hills and intervening mature hedgerow vegetation
and tree-lines often screening or partially screening views of the proposed development. This is also
reflected in the Zone of Theoretic Visibility (ZTV) mapping (refer to figure 1.7 of the submitted LVIA)
provided for the proposed development, which presents with a ‘sand-ripple’ like pattern, which is
reflective of drumlin landscapes, where the principal areas of turbine visibility relate to the most elevated
parts of the surrounding rolling drumlin hills, which tend to be more sparsely populated than the lower
intervening lands between these rolling land forms.RECEIVED: 04/09/2026
22790 - Appendix A - P2
Paragraph Observations/ Point Response By Response
Observer: Sinead Hughes - Letter Dated 19/10/2025
1.Par 5
Cont.
In addition to the above, the visual impact appraisal in the submitted LVIA indicates residual visual
effects ranging between Moderate and Imperceptible, which are deemed Not Significant. The most
notable visual effects will occur at the nearest surrounding receptors along the surrounding local,
regional and national road network, which includes viewpoints VP5, VP6, VP8 and VP10 within the
submitted LVIA report. Whilst the proposed single turbine presents at a prominent scale from some of
these viewpoints and will be one of the principal built features here, the perceived scale of the turbine
tends to be slightly diminished by the combination of intervening terrain and vegetation screening that
often conceals the lower parts of the proposed turbine tower. Whilst the turbine will be a prominent
feature at these locations it does not present with any sense of overbearing and is typically viewed in a
clear and comprehensible manner. Several elevated views and scenic designations are also located
throughout the wider study area (Refer to VP1 and VP2 in the submitted LVIA report). Whilst the turbine
will be visible from these elevated locations, it will have little effect on the scenic amenity afforded from
here and is viewed in the context of the surrounding robust working landscape context.
Overall, whilst the proposed single turbine development will present as a prominent built features in its
immediate surroundings, it does not present with any sense of overbearing nor is it considered to be a
highly dominant features within the local surrounding landscape. Indeed, turbines of a notably larger
scale exists within 5km of the proposed development in an almost identical landscape context.
Furthermore, the central study area presents as a robust rural landscape, which can well accommodate
a single turbine development of this scale and nature without undue landscape and visual effects.
1.Par 6 The proposal is contrary to Policy NH 4 of the Monaghan County
Development Plan, which seeks to protect habitats and species
from inappropriate development. The siting of a turbine in this
ecologically sensitive area does not align with sustainable
planning principles.
Mable Consulting
Engineers
The proposed Development has been subject to an Appropriate Assessment Screening and a detailed
Ecological Impact Assessment. The assessments identify the project footprint as being characterised by
habitats of low ecological value, with the Development not located within any statutory nature
conservation designation. The development has been designed to mitigate effects on habitats or fauna.
Accordingly, the siting of the turbine is not considered to conflict with the objective of protecting habitats
and species.RECEIVED: 04/09/2026
22790 - Appendix A - P2
Paragraph Observations/ Point Response By Response
Observer: Sinead Hughes - Letter Dated 19/10/2025
1.Par 7 For the reasons outlined above, I respectfully request that
Monaghan County Council refuse permission for this
development. The proposal would have an adverse effect on the
character of the area, residential amenities, and the proper
planning and sustainable development of the locality.
Mable Consulting
Engineers
The request for refusal is not supported by the findings of the assessments submitted with the Planning
Application. Residential amenity, landscape and visual effects, biodiversity, noise, shadow flicker,
archaeology, drainage and construction impacts have been assessed, with mitigation incorporated
where required. The LVIA concludes that significant landscape or visual effects are not expected, while
the ecological, noise and shadow flicker assessments similarly conclude that significant residual effects
are not anticipated with mitigation. The proposed Development is therefore considered capable of being
accommodated without an unacceptable effect on the character or amenities of the area.
1.Par 8 We are disappointed to see that hedge clearing has already
begun in the proposed area which surely is not in keeping with
the entire application process.
Mable Consulting
Engineers
The Applicant confirms that no Development works have been carried out on the site.RECEIVED: 04/09/2026
Document Ref. Number: 22790-FI Report-P2
__________________________________________________________________________________________________________________
ii
Appendix B – Response to Submission by Fintan Morgan
RECEIVED: 04/09/2026
22790 - Appendix B - P2
Paragraph Observations/ Point Response By Response
Item 1
1.Par 1
Shadow Flicker Concerns
The flicker analysis provided in the application is flawed and
lacks credibility. My home is within the affected zone, yet no
reliable mitigation strategy has been outlined. The mapping
errors and inconsistent data raise serious doubts about the
accuracy of the report. See screenshots below showing the
inaccuracy of the report.
Jennings
O'Donovan
The house labelling on Figure 1 of the Shadow Flicker Report was mislabelled. All the data contained
within Table 1.1 and Table 1.3 of the Shadow Flicker Report and the data used in the Shadow Flicker
modelling are correct. The labelling on the map contained a misprint arising from the updating of
labelling values in the mapping software ArcGIS, with the house label misnamed, meaning it did not
match up with the distances in Report Table 1.1 from the turbine location to the listed receptors. The
updated Shadow Flicker Report, Figure 1 contains the updated map with the revised house labelling,
which corresponds with the labelling in Table 1.1 and the results in Table 1.3 of the Shadow Flicker
Report.
See Shadow Flicker Report (Version 2), Doc. Ref.: 7234 Clones Shadow Flicker_Final Version 2, Page 9,
Figure 1.
This map addresses the issues raised in relation to the house labelling shown on Figure 1. The use of
mislabelled house references on Figure 1 does not impact the findings of the Shadow Flicker modelling.
The mitigation strategy is outlined in Section 1.2.8 of the Shadow Flicker Report, where it is proposed to
install a shadow flicker control system to mitigate potential shadow flicker. The shadow flicker control
system, consisting of light sensors and specialised software, will be installed on the wind turbine. The
control system will be calibrated to restrict the maximum amount of shadow flicker which can occur in
any given day to less than 30 minutes per receptor and 30 hours per year in compliance with the shadow
flicker thresholds set out in the 2006 Wind Energy Guidelines (WEDGs).
Item 2
2.Par 1
Noise Disturbance
The noise assessment fails to include real-world measurements
near residential areas. With dozens of homes nearby, including
mine, the absence of a noise control plan is unacceptable. Night-
time noise is especially worrying.
Noise & Vibration
Consultants Ltd
The predicted noise level at this location is 33.5dBA, which is below the conservative fixed LA90 40
dB,10min limit adopted in the Noise Impact Assessment for both daytime and night-time. These limits
are for outside the house. With a bedroom window ajar noise levels inside a room are lower that this, and
with the window fully closed the noise levels are reduced by a greater level.
Observer: Fintan Morgan - Letter Dated 24/10/2025
RECEIVED: 04/09/2026
22790 - Appendix B - P2
Paragraph Observations/ Point Response By Response
Observer: Fintan Morgan - Letter Dated 24/10/2025
Item 3
3.Par 1
Visual and Landscape Impact
I chose to make my home in this peaceful rural setting because
of its natural beauty and tranquillity. The introduction of a large
wind turbine would dramatically alter the landscape, replacing
scenic views with industrial infrastructure.
Macroworks Ltd. Concerns have been raised within 3rd Party observation that the proposed single turbine development
has the potential to ‘significantly’ alter the prevailing rural character of the area and adversely affect the
perceived sense of rural tranquillity. In this regard, it is important to consider both the existing landscape
context and the findings of the LVIA. The receiving landscape is characterised as a working rural
environment comprising agricultural land uses, dispersed farmsteads, an established road network,
overhead utility infrastructure and existing wind energy development within the wider landscape context.
As such, the landscape cannot be described as pristine or untouched, but rather as an actively managed
and evolving working rural landscape in which agricultural and energy-related infrastructure already
forms part of the established baseline landscape character. Indeed, as set out in the submitted LVIA,
“landscape sensitivity with the central study area is deemed to be Medium-low, with localised areas of
marginally higher sensitivity”, reflecting the robust working character of this landscape context where
landscape values relate mostly to productivity and subsistence of the rural economy, rather than
naturalistic or scenic values.
Whilst the proposed turbine will introduce a new vertical element into the landscape, the submitted LVIA
and photomontages highlight that visibility is moderated by the rolling drumlin landform and the
extensive pattern of mature hedgerows and tree lines that are located throughout the surrounding
landscape. The ZTV mapping indicates that views of the turbine are typically intermittent and frequently
filtered, with more open visibility largely confined to elevated drumlin ridges, which are generally less
densely settled. Consequently, the development will not result in widespread or uniform landscape
change, but rather a localised and somewhat contained areas of visual exposure.
In terms of rural character, wind energy development is not an unfamiliar feature within the wider
receiving landscape or throughout the island of Ireland, with turbines of a notably greater scale already
present within approximately 5 km of the site and experienced within an almost identical landscape
setting. The introduction of a single turbine of comparatively lesser height does not therefore represent a
fundamental change to landscape character, nor does it alter the underlying agricultural land use,
settlement pattern or landscape structure that define the rural character of the area. Instead, the
development would be perceived as an additional element within an already robust and evolving working
rural landscape.RECEIVED: 04/09/2026
22790 - Appendix B - P2
Paragraph Observations/ Point Response By Response
Observer: Fintan Morgan - Letter Dated 24/10/2025
3.Par 1
Cont.
With regard to rural tranquillity, it is recognised that perceptions of tranquillity are influenced by a range
of factors including movement, built form and existing infrastructure. The proposed development
comprises a single turbine and will increase the intensity of built development within the local
surrounding context. Nevertheless, whilst the development will marginally detract from the degree of
rural tranquillity perceived within some localised areas surrounding the site, these effects are deemed to
be Not Significant. As demonstrated in the LVIA, predicted visual effects range from Moderate to
Imperceptible and are primarily experienced at the nearest visual receptors. At greater distances, the
turbine is typically perceived as a small-scale feature within expansive views and does not materially
interrupt the overall sense of openness or remoteness experienced within the wider landscape,
especially the more scenic elevated landscape to the north. As a result, whilst the turbine may introduce
a perceptible change in certain views, it is not considered to significantly diminish the prevailing sense of
rural tranquillity.
Overall, having regard to the established landscape context, existing wind energy development in the
surrounding area, the contained nature of predicted visibility and the scale of the proposal as a single
turbine development, it is considered that the proposed development would not significantly alter the
prevailing rural character nor will it heavily detract from the degree of rural tranquillity within the local
surrounding landscape. The landscape is considered sufficiently robust to accommodate the proposed
development without resulting in unacceptable landscape or visual effects.
Item 4
4.Par 1
Wildlife and Habitat Disruption
The site supports diverse bird and bat populations. Habitat
removal and turbine operation pose serious risks to these
species. No adequate ecological safeguards have been
proposed.
Doherty
Environmental
Consultants Ltd.
The potential effects to fauna arising from the proposed development are set out in the Ecological Impact
Assessment (EcIA) that accompanies the planning application for the proposed development. The EcIA
assesses the potential impacts to fauna arising from these effects as sets out measures to ensure that
significant effects to fauna are avoided.
Item 5
5.Par 1
Environmental Screening Deficiencies
The site's connection to sensitive habitats has not been properly
assessed. The lack of a Stage 2 Appropriate Assessment is a
major oversight.
Doherty
Environmental
Consultants Ltd.
A Screening Report for Appropriate Assessment has been completed for the proposed development. The
Screening Report for Appropriate Assessment has examined in detail the potential for the proposed
development to result in likely significant effects to European Sites. Following this examination it has
been concluded that the proposed Development will not, alone or in-combination with other plans or
projects, have the potential to result in likely significant effects to European Sites. RECEIVED: 04/09/2026
22790 - Appendix B - P2
Paragraph Observations/ Point Response By Response
Observer: Fintan Morgan - Letter Dated 24/10/2025
Item 6
6.Par 1
Heritage and Cultural Impact
Historic structures are at risk, and the proximity to protected
heritage sites has not been properly considered. No detailed
heritage impact study is included.
Through Time Ltd. The Planning Application includes a detailed Archaeological Impact Assessment, which considered the
archaeological, architectural and cultural heritage of the site and surrounding area, including recorded
monuments, protected structures and their settings.
The assessment identified no recorded monuments within the proposed Development site, confirmed
that no recorded monuments, protected structures or features of architectural significance will be
directly impacted, and found no previously unrecorded archaeological features during the site
inspection.
As a precautionary measure, the report recommends pre-development archaeological testing, supported
by a metal detection survey, to identify and appropriately manage any previously unknown sub-surface
archaeology. Accordingly, the potential effects on heritage and cultural assets have been specifically
assessed and appropriate mitigation has been identified.
Item 7
7.Par 1
Flooding and Drainage Issues
The proposed access route crosses flood-prone land. No flood
risk assessment or hydrological modelling has been provided.
McCloy
Consulting
A site-specific Flood Risk Assessment dated April 2026 has been provided as Further Information. This
includes detailed linked 1D–2D hydraulic modelling based on site survey information and assesses
present-day, climate-change and blockage scenarios. The modelling confirms the extent of flooding
affecting the proposed access and demonstrates that the proposed raised access and watercourse
crossing will not measurably increase flood levels or materially alter flood extents or flow routes.
Item 8
8.Par 1
Light Pollution
Aviation lighting on the turbine will be visible from light pollution,
affecting my quality of life.
Art Generation
Ltd.
The proposed Development does not include general site illumination. Any lighting installed on the
turbine will be limited to aviation warning lighting and will be provided in a pattern acceptable to the Irish
Aviation Authority (IAA) & the Department of Defence for aviation safety purposes. The lighting will be
located on top of the turbine nacelle for the purpose of identify the turbine as an obstacle to aviation
receptors. Accordingly, it will not be designed to cast light downwards towards ground level, thereby
reducing the potential for notable effects on nearby ground-based receptors.
The Landscape and Visual Impact Assessment (LVIA) assessed the visual effects of the proposed turbine
from representative viewpoints throughout the study area and concluded that the Development would
not give rise to significant landscape or visual effects, with residual visual effects not exceeding
Moderate significance. Accordingly, while aviation warning lighting may be visible from some locations at
night, it will be limited to that required for aviation safety and, in the context of the existing lighting
environment and absence of general site illumination, is not considered likely to result in an
unacceptable effect on residential amenity, visual amenity or quality of life.RECEIVED: 04/09/2026
22790 - Appendix B - P2
Paragraph Observations/ Point Response By Response
Observer: Fintan Morgan - Letter Dated 24/10/2025
8.Par 1
Cont.
Macroworks Ltd. It is important to note the visual amenity is at its lowest during dark periods, as views across the
landscape are inhibited by the low levels of visibility. Thus, the proposed aviation warning lighting will
have a minimal effect on the visual amenity afforded in this landscape context, as the lighting will only
ever be visible during periods of darkness.
It is also important to note that the proposed lighting is located on top of the proposed turbine nacelle, as
its principal use is to identify obstacles in the sky for aviation-based receptors. Thus, the lighting included
will not cast light down towards the ground, which diminishes the potential for any notable effects to
occur at ground-based receptors. Whilst the flashing lights have the potential to be discerned from
ground-based receptors, the study area and local surrounds of the site are not located in a designated
dark sky area.
It is also worth noting that the central study area is influenced by light spill emanating from existing light
sources in residential areas in nearby centres of populations. The N54 national secondary route and
R183 regional road are also contained within the central study area and are another notable existing
source of potential visible lighting.
Item 9
9.Par 1
Lack of Public Engagement
No consultation was held with affected residents. The planning
process has lacked transparency and inclusivity.
Art Generation
Ltd.
Consultation was held in the form of an online dedicated website,
https://cloneswindfarm.com/index.html
This dedicated website for the proposed Development was launched on 16 September 2025
The purpose of the website was to inform the local community and all interested stakeholders about the
single turbine proposal, its community benefit fund, and to provide contact details for the Development’s
Community Liaison Officer.
This approach to community engagement is consistent with that adopted by the Developer on other
similar-scale renewable energy projects in Ireland, providing local residents and interested stakeholders
with access to project information and a direct point of contact through the Community Liaison Officer.RECEIVED: 04/09/2026
22790 - Appendix B - P2
Paragraph Observations/ Point Response By Response
Observer: Fintan Morgan - Letter Dated 24/10/2025
Item 10
10.Par 1
Failure to Consider Alternatives
No evidence has been provided that alternative sites or
technologies were considered. Solar energy could offer a less
intrusive solution.
Mable Consulting
Engineers
In accordance with the Planning and Development Regulations, 2001, Part 10 - Environmental Impact
Assessment, Schedule 5, Part 2(3)(i) an Environmental Impact Assessment (EIA) is not required for this
Development as it comprises fewer than 5 turbines and has an output less than 5 megawatts.
An EIA Screening Assessment was undertaken, having regard to the criteria set out in Schedule 7A of the
Planning and Development Regulations 2001 (as amended), including the characteristics of the
proposed Development, its location, and the nature and characteristics of potential impacts. This
assessment confirmed that the proposed Development is not likely to give rise to significant effects on
the environment.
Art Generation has developed a number of wind energy projects throughout Ireland. As part of its
development process, potential sites are subject to an initial screening and site-selection exercise
having regard to development potential, environmental and planning constraints, access, grid
connection and other relevant considerations. A number of alternative sites were considered as part of
this wider development process, with some progressed further and others deemed unsuitable. The
Clones site was identified as having favourable development potential having regard to the
environmental and planning constraints identified.
While a full EIA was not required for the proposed Development, the design process considered the
suitability of the site and the potential environmental effects of the proposal. Alternative renewable
energy technologies, including solar, were not considered to represent a directly comparable alternative
to the proposed single wind turbine, having regard to the specific nature, scale and purpose of the
Development.
Item 11
11.Par 1
Cumulative and Long-Term Impacts
The application lacks a cumulative impact assessment and a
clear decommissioning plan.
Mable Consulting
Engineers
Potential cumulative effects were considered as part of the environmental assessments undertaken for
the proposed Development, notwithstanding that a full EIA was not required. The long-term effects of the
Development were also assessed, including its operational lifetime, decommissioning, and the
restoration of the site following cessation of operations.
Item 11
11.Par 2
The proposed 10-year planning window does not reflect the
turbine's 35-year lifespan.
Mable Consulting
Engineers.
The proposed 10-year planning permission relates to the period within which the Development may be
constructed and does not represent its operational lifespan. The turbine’s anticipated 35-year
operational life would commence following construction and commissioning and is therefore separate
from the duration of the planning permission for construction.RECEIVED: 04/09/2026
22790 - Appendix B - P2
Paragraph Observations/ Point Response By Response
Observer: Fintan Morgan - Letter Dated 24/10/2025
Item 12
12.Par 1
Conflict with Local Planning Policys
The proposal contradicts several policies in the Monaghan
County Development Plan, including those protecting residential
amenity, biodiversity, and landscape character.
Mable Consulting
Engineers
The Planning Application does not conflict with the policies of the Monaghan County Development Plan.
The proposed Development is consistent with the relevant policies and objectives of the Development
Plan, including those relating to residential amenity, biodiversity and landscape character, as
demonstrated by the assessments submitted in support of the application.
In particular, Renewable Energy Objective REO 5 of the Monaghan County Development Plan 2025–2031
supports and encourages small-scale wind energy development and single turbines in urban and rural
areas, subject to the protection of environmental quality, landscape, built heritage, wildlife and habitats,
and residential amenity. The proposed Development is considered consistent with this objective.
Item 13
13.Par 1
Procedural Flaws
The application contains outdated data, lacks technical detail,
and fails to meet transparency standards.
Mable Consulting
Engineers
The Planning Application does not rely on outdated data, lack technical detail, or fail to meet
transparency standards. It is supported by relevant and appropriate environmental and technical
assessments and provides sufficient information to allow the proposed Development and its potential
effects to be fully considered by the Planning Authority.
Item 14
14.Par 1
Conclusion
Given the numerous concerns outlined above, I respectfully urge
Monaghan County Council to reject this planning application, The
proposal fails to meet environmental, residential, and procedural
standards and poses significant risks to the local community.
Mable Consulting
Engineers
The proposed Development does not fail to meet environmental, residential or procedural standards and
does not pose significant risks to the local community. The Planning Application adequately addresses
the potential environmental and residential effects of the proposed Development, complies with the
relevant planning requirements, and provides sufficient information to support a positive determination
by Monaghan County Council.RECEIVED: 04/09/2026
Document Ref. Number: 22790-FI Report-P2
__________________________________________________________________________________________________________________
iii
Appendix C – Response to Submission by Martin Beagan
RECEIVED: 04/09/2026
22790 - Appendix C - P2
Paragraph Observations/ Point Response By Response
Item 1
1.Par 1
Shadow Flicker Impact:
The Shadow Flicker Assessment identifies 13 homes exceeding
the 30 minutes/day threshold, contrary to national guidelines. No
engagement has taken place to allow me to highlight my
concerns and the possibility of flicker effects on this area of
proposed development.
Jennings
O'Donovan
As stated in the shadow flicker report, mitigation measures outlined will be applied to ensure no
exceedances at the 13 receptors identified which exceed the 2006WEDGs threshold of 30/min/day and
30/hours/year.
Accordingly, with the proposed mitigation in place, shadow flicker is not considered to give rise to a
significant impact.
Item 2
2.Par 1
Noise Pollution:
The Noise Impact Assessment lacks site-specific baseline data
and fails to address tonal or impulsive noise. With 67 homes
potentially affected, the absence of a curtailment strategy is
concerning. My future home would be exposed to these risks.
Noise & Vibration
Consultants Ltd
The Noise Impact Assessment does not fail to adequately assess potential noise effects. Rather than
relying on background-dependent limits, the assessment adopts a conservative fixed operational noise
limit of 40 dBA for both daytime and night-time and assesses all 67 identified residential receptors within
1.5 km, with predicted noise levels at every receptor remaining below this limit at all assessed wind
speeds.
Observer: Martin Beagan - Letter Dated 24/10/2025
RECEIVED: 04/09/2026
22790 - Appendix C - P2
Paragraph Observations/ Point Response By Response
Observer: Martin Beagan - Letter Dated 24/10/2025
Item 3
3.Par 1
Visual Intrusion:
The turbine will dominate the landscape and disrupt the rural
character of the area. Photomontages exclude views from
sensitive receptors and future dwellings.
Macroworks Ltd. Concerns have been raised within 3rd Party observation that the proposed single turbine development
has the potential to ‘significantly’ alter the prevailing rural character of the area and adversely affect the
perceived sense of rural tranquillity. In this regard, it is important to consider both the existing landscape
context and the findings of the LVIA. The receiving landscape is characterised as a working rural
environment comprising agricultural land uses, dispersed farmsteads, an established road network,
overhead utility infrastructure and existing wind energy development within the wider landscape context.
As such, the landscape cannot be described as pristine or untouched, but rather as an actively managed
and evolving working rural landscape in which agricultural and energy-related infrastructure already
forms part of the established baseline landscape character. Indeed, as set out in the submitted LVIA,
“landscape sensitivity with the central study area is deemed to be Medium-low, with localised areas of
marginally higher sensitivity”, reflecting the robust working character of this landscape context where
landscape values relate mostly to productivity and subsistence of the rural economy, rather than
naturalistic or scenic values.
Whilst the proposed turbine will introduce a new vertical element into the landscape, the submitted LVIA
and photomontages highlight that visibility is moderated by the rolling drumlin landform and the
extensive pattern of mature hedgerows and tree lines that are located throughout the surrounding
landscape. The ZTV mapping indicates that views of the turbine are typically intermittent and frequently
filtered, with more open visibility largely confined to elevated drumlin ridges, which are generally less
densely settled. Consequently, the development will not result in widespread or uniform landscape
change, but rather a localised and somewhat contained areas of visual exposure.RECEIVED: 04/09/2026
22790 - Appendix C - P2
Paragraph Observations/ Point Response By Response
Observer: Martin Beagan - Letter Dated 24/10/2025
Item 3
3.Par 1
Cont.
Macroworks Ltd. In terms of rural character, wind energy development is not an unfamiliar feature within the wider
receiving landscape or throughout the island of Ireland, with turbines of a notably greater scale already
present within approximately 5 km of the site and experienced within an almost identical landscape
setting. The introduction of a single turbine of comparatively lesser height does not therefore represent a
fundamental change to landscape character, nor does it alter the underlying agricultural land use,
settlement pattern or landscape structure that define the rural character of the area. Instead, the
development would be perceived as an additional element within an already robust and evolving working
rural landscape.
With regard to rural tranquillity, it is recognised that perceptions of tranquillity are influenced by a range
of factors including movement, built form and existing infrastructure. The proposed development
comprises a single turbine and will increase the intensity of built development within the local
surrounding context. Nevertheless, whilst the development will marginally detract from the degree of
rural tranquillity perceived within some localised areas surrounding the site, these effects are deemed to
be Not Significant. As demonstrated in the LVIA, predicted visual effects range from Moderate to
Imperceptible and are primarily experienced at the nearest visual receptors. At greater distances, the
turbine is typically perceived as a small-scale feature within expansive views and does not materially
interrupt the overall sense of openness or remoteness experienced within the wider landscape,
especially the more scenic elevated landscape to the north. As a result, whilst the turbine may introduce
a perceptible change in certain views, it is not considered to significantly diminish the prevailing sense of
rural tranquillity.
Overall, having regard to the established landscape context, existing wind energy development in the
surrounding area, the contained nature of predicted visibility and the scale of the proposal as a single
turbine development, it is considered that the proposed development would not significantly alter the
prevailing rural character nor will it heavily detract from the degree of rural tranquillity within the local
surrounding landscape. The landscape is considered sufficiently robust to accommodate the proposed
development without resulting in unacceptable landscape or visual effects.
Item 4
4.Par 1
Ecological and Wildlife Risks:
High bat activity and diverse bird species are documented near
the site. Habitat fragmentation and collision risks are
inadequately addressed. The development could disrupt local
biodiversity, affecting both existing and future residents.
Doherty
Environmental
Consultants Ltd.
As per the response to Submission No. A above the EcIA has examined in detail the potential for habitat
fragmentation and collision risk to bats and birds. Specific mitigation measures have been set out,
including a Bat Monitoring and Management Plan and a Bird Monitoring and Management Plan, both of
which, when implemented in full will provide safeguards for bats and birds throughout the lifetime of the
proposed development. RECEIVED: 04/09/2026
22790 - Appendix C - P2
Paragraph Observations/ Point Response By Response
Observer: Martin Beagan - Letter Dated 24/10/2025
Item 5
5.Par 1
Flooding and Drainage Risks:
The proposed access route crosses flood-prone land and
construction could exacerbate local flood risks.
McCloy
Consulting
The site-specific Flood Risk Assessment dated April 2026 expressly assesses the proposed access
through the floodplain. The proposed access and watercourse crossing have been represented in the
hydraulic model, which predicts no measurable increase in flood levels and no material change in flood
extent or flow routing. Construction-stage flood and pollution controls are also specified in the Water
Environment Assessment, including cessation of works and removal of plant, materials and fuels from
the floodplain in advance of a predicted severe flood.
Item 6
6.Par 1
Light Pollution:
Aviation lighting from the turbine would add to existing light
pollution from nearby wind farms. This would negatively affect
night-time amenity for future residents.
Art Generation
Ltd.
The proposed Development does not include general site illumination. Any lighting installed on the
turbine will be limited to aviation warning lighting and will be provided in a pattern acceptable to the Irish
Aviation Authority (IAA) & the Department of Defence for aviation safety purposes. The lighting will be
located on top of the turbine nacelle for the purpose of identify the turbine as an obstacle to aviation
receptors. Accordingly, it will not be designed to cast light downwards towards ground level, thereby
reducing the potential for notable effects on nearby ground-based receptors.
The Landscape and Visual Impact Assessment (LVIA) assessed the visual effects of the proposed turbine
from representative viewpoints throughout the study area and concluded that the Development would
not give rise to significant landscape or visual effects, with residual visual effects not exceeding
Moderate significance. Accordingly, while aviation warning lighting may be visible from some locations at
night, it will be limited to that required for aviation safety and, in the context of the existing lighting
environment and absence of general site illumination, is not considered likely to result in an
unacceptable effect on residential amenity, visual amenity or quality of life.RECEIVED: 04/09/2026
22790 - Appendix C - P2
Paragraph Observations/ Point Response By Response
Observer: Martin Beagan - Letter Dated 24/10/2025
6.Par 1
Cont.
Macroworks Ltd. It is important to note the visual amenity is at its lowest during dark periods, as views across the
landscape are inhibited by the low levels of visibility. Thus, the proposed aviation warning lighting will
have a minimal effect on the visual amenity afforded in this landscape context, as the lighting will only
ever be visible during periods of darkness.
It is also important to note that the proposed lighting is located on top of the proposed turbine nacelle, as
its principal use is to identify obstacles in the sky for aviation-based receptors. Thus, the lighting included
will not cast light down towards the ground, which diminishes the potential for any notable effects to
occur at ground-based receptors. Whilst the flashing lights have the potential to be discerned from
ground-based receptors, the study area and local surrounds of the site are not located in a designated
dark sky area.
It is also worth noting that the central study area is influenced by light spill emanating from existing light
sources in residential areas in nearby centres of populations. The N54 national secondary route and
R183 regional road are also contained within the central study area and are another notable existing
source of potential visible lighting.
Item 7
7.Par 1
Lack of Community Engagement:
No consultation was undertaken with residents or those planning
to build nearby. This lack of engagement has prevented me from
raising my concerns with the developer.
Art Generation
Ltd.
A dedicated website for the proposed Development was launched to inform the local community and
interested stakeholders about the single turbine proposal and the associated Community Benefit Fund.
The website also provided contact details for the Development’s Community Liaison Officer, thereby
providing residents and other interested parties with a direct means of raising queries or concerns with
the developer throughout the planning process.RECEIVED: 04/09/2026
22790 - Appendix C - P2
Paragraph Observations/ Point Response By Response
Observer: Martin Beagan - Letter Dated 24/10/2025
Item 8
8.Par 1
Failure to Consider Alternatives:
No evidence of alternative sites or technologies (e.g., solar PV) is
presented. This limits public and planning authority evaluation of
less impactful options.
Art Generation
Ltd.
In accordance with the Planning and Development Regulations, 2001, Part 10 - Environmental Impact
Assessment, Schedule 5, Part 2(3)(i) an Environmental Impact Assessment (EIA) is not required for this
Development as it comprises fewer than 5 turbines and has an output less than 5 megawatts.
An EIA Screening Assessment was undertaken, having regard to the criteria set out in Schedule 7A of the
Planning and Development Regulations 2001 (as amended), including the characteristics of the
proposed Development, its location, and the nature and characteristics of potential impacts. This
assessment confirmed that the proposed Development is not likely to give rise to significant effects on
the environment.
While a full EIA was not required for the proposed Development, the design process considered the
suitability of the site and the potential environmental effects of the proposal. Alternative renewable
energy technologies, including solar, were not considered to represent a directly comparable alternative
to the proposed single wind turbine, having regard to the specific nature, scale and purpose of the
Development.
Item 9
9.Par 1
Cumulative Environmental Impact:
The application lacks a cumulative impact assessment,
especially in relation to existing wind farms and future residential
growth.
Doherty
Environmental
Consultants Ltd.
The EcIA provides a cumulative impact assessment with respect to other wind energy projects as well as
residential projects in the wider surrounding area.
Item 10
10.Par 1
Planning Duration vs. Operational Lifespan:
The 10-year planning window does not align with the 35-year
operational lifespan, raising concerns about long-term oversight
and decommissioning.
Mable Consulting
Engineers
The proposed 10-year planning permission relates to the period within which the Development may be
constructed and does not represent its operational lifespan. The turbine’s anticipated 35-year
operational life would commence following construction and commissioning and is therefore separate
from the duration of the planning permission for construction.RECEIVED: 04/09/2026
22790 - Appendix C - P2
Paragraph Observations/ Point Response By Response
Observer: Martin Beagan - Letter Dated 24/10/2025
Item 11
11.Par 1
Conflict with Monaghan County Development Plan:
The proposal contradicts key policies (EP1-EP8) on residential
amenity, landscape protection, biodiversity, and public
consultation.
Mable Consulting
Engineers
The application has been assessed against the relevant Development Plan policies, including those
relating to residential amenity, landscape and visual protection, biodiversity, environmental protection
and renewable energy development, with the supporting technical assessments demonstrating that the
proposal is consistent with these objectives. Community engagement was also undertaken through the
dedicated project website and the provision of contact details for the Development’s Community Liaison
Officer, providing interested parties with a direct means of engaging with the developer.
Renewable Energy Objective REO 5 of the Monaghan County Development Plan 2025–2031 supports and
encourages small-scale wind energy development and single turbines in urban and rural areas, subject
to the protection of environmental quality, landscape, built heritage, wildlife and habitats, and residential
amenity. The proposed Development is considered consistent with this objective.
Item 12
12.Par 1
Procedural Deficiencies
Outdated mapping, lack of technical detail, and absence of
consultation undermine the credibility of the application.
Mable Consulting
Engineers
The Planning Application does not rely on outdated data, lack technical detail, or fail to meet
transparency standards. It is supported by relevant and appropriate environmental and technical
assessments and provides sufficient information to allow the proposed Development and its potential
effects to be fully considered by the Planning Authority.
Community Engagement was facilitated through the dedicated project website and the provision of
contact details for the Development’s Community Liaison Officer. Accordingly, the application is
considered to provide an adequate and transparent basis for assessment.
Item 13
13.Par 1
Dangerous Precedent:
Approving this application without robust scrutiny would set a
precedent that disregards future residential development and
weakens planning safeguards.
Mable Consulting
Engineers
The application has been subject to the relevant planning process and is supported by environmental
and technical assessments addressing residential amenity, landscape and visual effects, ecology, noise,
shadow flicker, archaeology and cumulative effects. Existing residential development was also
considered as part of the site selection process and in determining appropriate turbine setback
distances. Any decision by the Planning Authority will therefore be made having regard to the specific
circumstances of this proposal and the applicable planning and environmental requirements, and would
not in itself establish a precedent that diminishes future planning safeguards.RECEIVED: 04/09/2026
Document Ref. Number: 22790-FI Report-P2
__________________________________________________________________________________________________________________
iv
Appendix D – Response to Submission by Micheal Beagan
RECEIVED: 04/09/2026
22790- Appendix D - P2
Paragraph Observations/ Point Response By Response
Item 1
1.Par 1
1. Shadow Flicker Impact
• The Shadow Flicker Assessment confirms that 13 residential
receptors will experience shadow flicker exceeding the 30
minutes/day threshold. This is contrary to the DEHLG Wind
Energy Guidelines (2006) and the Draft Revised Guidelines
(2019), which recommend zero shadow flicker. The proposed
mitigation relies on a control system, but no technical
specifications or enforceable guarantees are provided.
Jennings
O'Donovan
A shadow flicker control system, consisting of light sensors and specialised software, will be installed on
the wind turbine. The control system will be calibrated to restrict the maximum amount of shadow flicker
which can occur in any given day to less than 30 minutes per receptor (i.e. the 2006 WEDGs thresholds).
The control system will calculate, in real-time:
• Whether shadow flicker has the potential to effect nearby sensitive receptors, based on pre-
programmed co-ordinates for the sensitive receptors and turbine;
• Wind speed (can affect how fast the turbine will turn and how quickly the flicker will occur);
• Wind direction; and
• The intensity of the sunlight.
When the control system detects that:
1. the sunlight is strong enough to cast a shadow,
2. the shadow falls on a sensitive receptor or sensitive receptors, and
3. the pre-set max daily occurrence of 30 minutes is reached
The turbine will then automatically shut down; and will restart when the potential for shadow flicker
ceases at the effected sensitive receptors. Such systems are common in many wind farm developments
and the technology has been well established.
Observer: Micheal Beagan - Letter Dated 24/10/2025
RECEIVED: 04/09/2026
22790- Appendix D - P2
Paragraph Observations/ Point Response By Response
Observer: Micheal Beagan - Letter Dated 24/10/2025
1.Par 2 • The report is fundamentally flawed due to inaccurate house
numbering and inconsistent location data, which severely
compromises its reliability. As evidenced by the subsequent
figures. House H1 is listed as being 562 meters from the turbine,
while House H53 is recorded at 1330 meters. Yet, Figure 2 clearly
shows H53 positioned closer to the turbine than H1. H53 co-
ordinates should be Easting ITM:652445, Northing ITM:825863
as can be seen from Figure 3. Figure 3 also has the imputed co-
ordinates from Figure 1 below which shows the inaccurate house
numbering and inconsistent location data. This blatant
discrepancy reveals that the report's spatial analysis is not only
misleading but factually incorrect undermining its reliability.
Jennings
O'Donovan
The house labelling on Figure 1 of the Shadow Flicker Report was mislabelled. All the data contained
within Table 1.1 and Table 1.3 of the Shadow Flicker Report and the data used in the Shadow Flicker
modelling are correct. The labelling on the map contained a misprint arising from the updating of
labelling values in the mapping software ArcGIS, with the house labels misnamed, meaning they did not
correspond with the distances in Report Table 1.1 from the turbine location to the listed receptors. The
apparent discrepancy between H1 and H53 therefore relates to the house labelling shown on Figure 1
and not to the receptor locations or data used in the modelling. An updated map has been prepared with
the revised house labelling, which corresponds with the labelling in Table 1.1 and the results in Table 1.3
of the Shadow Flicker Report. The use of mislabelled house references on Figure 1 does not impact the
findings of the Shadow Flicker modelling.
The Shadow Flicker Report has been updated accordingly to incorporate the revised house labelling and
the updated report is included as part of this FI submission, see Doc. Ref: 7234 Clones Shadow Flicker.
1.Par 3 • From the planning documents, 53 homes may be affected by
shadow flicker, yet no meaningful mitigation or engagement has
been proposed.
Jennings
O'Donovan
The mitigation strategy is outlined in Section 1.2.8 of the Shadow Flicker Report, where it is proposed to
install a shadow flicker control system to mitigate potential shadow flicker. The shadow flicker control
system, consisting of light sensors and specialised software, will be installed on the wind turbine. The
control system will be calibrated to restrict the maximum amount of shadow flicker which can occur in
any given day to less than 30 minutes per receptor and 30 hours per year in compliance with the shadow
flicker thresholds set out in the 2006 Wind Energy Guidelines (WEDGs).
The proposed automated shadow flicker control system represents established best practice within the
wind energy industry and is a commonly applied mitigation measure for wind energy developments,
including through planning conditions requiring compliance with specified shadow flicker limits.RECEIVED: 04/09/2026
22790- Appendix D - P2
Paragraph Observations/ Point Response By Response
Observer: Micheal Beagan - Letter Dated 24/10/2025
Item 2
2.Par 1
2. Noise Pollution and Lack of Site-Specific Assessment
• The Noise Impact Assessment relies solely on manufacturer
data and does not include any baseline monitoring at nearby
homes.
Noise & Vibration
Consultants Ltd
The predicted noise level at this location is 37.2dBA which is well below the night-time limit of 40dBA
given for wind turbines. Furthermore baseline monitoring will not effect the predicted level except where
a baseline line can be carried out to validate the noise level from the operating turbine.
The predicted level of 37.2dBA is taken from Table 8 of the Noise Impact Assessment. The adopted LA90
40dB,10min daytime and night-time limit is set out in Section 1.3 and is based on the lower limits in the
Wind Energy Development Guidelines (2006). The assessment also follows ETSU-R-97, the IOA Good
Practice Guide and ISO 9613-2, representing established best practice for wind turbine noise
assessment.
2.Par 2 • There is no assessment of tonal or impulsive noise, and the
uncertainty margins are not robustly justified.
Noise & Vibration
Consultants Ltd
The turbine is designed to operate without tonality/impulsive noise emissions and if the turbine exhibit
tonality then the turbine would be turned off until the problem was corrected as that is established best
practice.
2.Par 3 • 67 homes are potentially affected by noise, yet no curtailment
strategy or operational noise control plan is provided.
Noise & Vibration
Consultants Ltd
The predicted noise levels are well below established day and nigh-time limits and the specific turbine
can operate in many different modes thereby reducing the noise emission. The predictions are based on
maximum noise output.
2.Par 4 • As a nearby resident, I am deeply concerned about the
potential for noise disturbance, especially during nighttime
hours.
Art Generation
Ltd.
The predicted noise level at this location is 33.5dBA, which is below the conservative fixed LA90 40
dB,10min limit adopted in the Noise Impact Assessment for both daytime and night-time. These limits
are for outside the house. With a bedroom window ajar noise levels inside a room are lower that this, and
with the window fully closed the noise levels are reduced by a greater level.
Noise & Vibration
Consultants Ltd
There are many appliances inside a modern home which emit electromagnetic emissions such as
routers, phones, Bluetooth, house appliances such as fridges, washing machines, electrical
infrastructure such as televisions, electronics, transformers in chargers etc. Noise levels from the small
housed 20kV substation would be inaudible at less than 20dBA at the nearest receptor more than 360m
away.RECEIVED: 04/09/2026
22790- Appendix D - P2
Paragraph Observations/ Point Response By Response
Observer: Micheal Beagan - Letter Dated 24/10/2025
Item 3
3.Par 1
3. Visual Intrusion and Landscape Impact
• The turbine will be visually dominant from multiple viewpoints
and lies within Landscape Character Area 4, which has medium
sensitivity.
Macroworks Ltd. Concerns have been raised within 3rd Party observation that the proposed single turbine development
has the potential to ‘significantly’ alter the prevailing rural character of the area and adversely affect the
perceived sense of rural tranquillity. In this regard, it is important to consider both the existing landscape
context and the findings of the LVIA. The receiving landscape is characterised as a working rural
environment comprising agricultural land uses, dispersed farmsteads, an established road network,
overhead utility infrastructure and existing wind energy development within the wider landscape context.
As such, the landscape cannot be described as pristine or untouched, but rather as an actively managed
and evolving working rural landscape in which agricultural and energy-related infrastructure already
forms part of the established baseline landscape character. Indeed, as set out in the submitted LVIA,
“landscape sensitivity with the central study area is deemed to be Medium-low, with localised areas of
marginally higher sensitivity”, reflecting the robust working character of this landscape context where
landscape values relate mostly to productivity and subsistence of the rural economy, rather than
naturalistic or scenic values.
Whilst the proposed turbine will introduce a new vertical element into the landscape, the submitted LVIA
and photomontages highlight that visibility is moderated by the rolling drumlin landform and the
extensive pattern of mature hedgerows and tree lines that are located throughout the surrounding
landscape. The ZTV mapping indicates that views of the turbine are typically intermittent and frequently
filtered, with more open visibility largely confined to elevated drumlin ridges, which are generally less
densely settled. Consequently, the development will not result in widespread or uniform landscape
change, but rather a localised and somewhat contained areas of visual exposure.
3.Par 2 • The photomontages are very selective in their locations and
limited in scope and do not include views from sensitive
receptors such as schools, heritage sites, or residential clusters.
There is a photo taken from the diamond in Clones but no picture
showing the view from the diamond.
Macroworks Ltd. The assessment of landscape and visual effects includes 14 representative viewpoints throughout the
defined 20 km study area. However, it is important to note that the majority of these viewpoints, 11 of the
14, are located within the central study area (within 5 km of the site), as this is where the most notable
effects are likely to occur. Indeed, 7 of the 14 representative viewpoints are located within 2 km of the
proposed development.RECEIVED: 04/09/2026
22790- Appendix D - P2
Paragraph Observations/ Point Response By Response
Observer: Micheal Beagan - Letter Dated 24/10/2025
3.Par 2
Cont.
In terms of the selection of viewpoint locations for assessment, this process is guided by GLVIA3
(Guidelines for Landscape and Visual Impact Assessment). Viewpoint selection is undertaken using ZTV
(Zone of Theoretical Visibility) mapping, which provides the basis for identifying key viewpoints from
which the visual and landscape impacts of the proposed development can be examined in detail. It is not
practical to include every location from which the proposed development may be visible, as this would
result in an unwieldy report and make it difficult to identify the key impacts arising. Instead, the
assessors have sought to select a range of location types that provide views of the proposed
development from varying distances, angles and landscape contexts.
The selected locations are considered significant as they include, for example, centres of population and
important routes, whether due to traffic volume or scenic value. An initial broad range of potential views
was identified through desk-based analysis using the ZTV mapping. Each potential viewpoint (VP) is
representative of one or more of the following receptor types:
• Key Views - from features of international or national importance;
• Tourism, Amenity and Heritage Views - from important heritage or amenity locations;
• Designated Scenic Routes and Views;
• Local Community Views;
• Centres of Population;
• and Major Routes.
It is important to note that some viewpoints (VPs) may be applicable to several receptor categories. In
such cases, they are assessed under the group that best reflects the particular sensitivities of that
location. Whilst every effort is made to select viewpoints that provide the clearest and least impeded
views of the proposed development, in some instances only partial views may be available from the
nearest publicly accessible location selected to represent the visual receptor.
Where the proposed development is substantially screened from a particular receptor, a photomontage
has been included to illustrate the degree of intervening screening between the visual receptor and the
proposed turbines. In circumstances where individual turbines, or parts of the development, are partially
screened by vegetation or other foreground elements, wireframe visualisations are used to assist in
understanding the potential visual effects and perceived scale of the development from that receptor.RECEIVED: 04/09/2026
22790- Appendix D - P2
Paragraph Observations/ Point Response By Response
Observer: Micheal Beagan - Letter Dated 24/10/2025
3.Par 2
Cont.
Macroworks Ltd. Finally, it should be noted that Macro Works seeks to utilise viewpoints that represent the most open and
realistic views available to the receptor being assessed, whether from settlements or designated scenic
routes. Assessing visual effects from locations that are demonstrably unrepresentative of potential worst-
case visual exposure would undermine the robustness of the assessment and would therefore serve no
meaningful purpose. Baseline photography was captured in April 2024.
With regard to accuracy, Macro Works prepares photomontages in accordance with current NatureScot
guidance and the British Landscape Institute’s Advice Note 01/11: Photography and Photomontage in
Landscape and Visual Impact Assessment (2011). Viewpoints are selected and high-quality baseline
photography is captured in RAW format using a digital single-lens reflex (DSLR) camera fitted with a fixed
50 mm lens, mounted on a Manfrotto panoramic head and levelling base. Viewpoint locations are
spatially recorded using a survey-grade Global Positioning System (GPS) unit with an accuracy of
approximately ±10 cm. High-resolution 360-degree panoramas are then generated from the captured
imagery. The proposed scheme is modelled using a Digital Terrain Model derived from a combination of
LiDAR data and Ordnance Survey terrain data, together with verified real-world reference points.
Visualisations are rendered in Autodesk 3ds Max 2023 using image parameters matched to those of the
baseline photography, allowing the rendered model and photographic imagery to be combined with a
high degree of accuracy.RECEIVED: 04/09/2026
22790- Appendix D - P2
Paragraph Observations/ Point Response By Response
Observer: Micheal Beagan - Letter Dated 24/10/2025
3.Par 3 & 4 • The turbine will significantly alter the visual coherence of the
drumlin landscape and negatively affect the rural character of
the area
Macroworks Ltd. Concerns have been raised within 3rd Party observation that the proposed single turbine development
has the potential to ‘significantly’ alter the prevailing rural character of the area and adversely affect the
perceived sense of rural tranquillity. In this regard, it is important to consider both the existing landscape
context and the findings of the LVIA. The receiving landscape is characterised as a working rural
environment comprising agricultural land uses, dispersed farmsteads, an established road network,
overhead utility infrastructure and existing wind energy development within the wider landscape context.
As such, the landscape cannot be described as pristine or untouched, but rather as an actively managed
and evolving working rural landscape in which agricultural and energy-related infrastructure already
forms part of the established baseline landscape character. Indeed, as set out in the submitted LVIA,
“landscape sensitivity with the central study area is deemed to be Medium-low, with localised areas of
marginally higher sensitivity”, reflecting the robust working character of this landscape context where
landscape values relate mostly to productivity and subsistence of the rural economy, rather than
naturalistic or scenic values.
Whilst the proposed turbine will introduce a new vertical element into the landscape, the submitted LVIA
and photomontages highlight that visibility is moderated by the rolling drumlin landform and the
extensive pattern of mature hedgerows and tree lines that are located throughout the surrounding
landscape. The ZTV mapping indicates that views of the turbine are typically intermittent and frequently
filtered, with more open visibility largely confined to elevated drumlin ridges, which are generally less
densely settled. Consequently, the development will not result in widespread or uniform landscape
change, but rather a localised and somewhat contained areas of visual exposure.
Item 4
4.Par 1
4. Ecological Concerns - High Bat Activity and Wildlife
• The Ecological Impact Assessment identifies high bat activity
near the turbine location, including Leisler's bat and pipistrelle
species. These species are vulnerable to collision and
barotrauma from turbine blades. The proposed mitigation
measures, including a buffer zone, are insufficient given the
consistent bat activity recorded.
Doherty
Environmental
Consultants Ltd.
A detailed Bat Monitoring and Management Plan has been prepared for the proposed development. This
plan provides safeguards for bats for the duration of the lifetime of the proposed development. RECEIVED: 04/09/2026
22790- Appendix D - P2
Paragraph Observations/ Point Response By Response
Observer: Micheal Beagan - Letter Dated 24/10/2025
4.Par 2 • No EcoBat modelling was conducted, and no turbine
curtailment strategy is proposed.
Doherty
Environmental
Consultants Ltd.
The bat data recorded demonstrates high levels of bat activity, irrespective of the use of EcoBat
modelling. A curtailment strategy is provided as part of the Bat Monitoring and Mitigation Plan
4.Par 3 • Surveys conducted for the planning application recorded a
diverse range of bird species at the site, including Buzzard,
Chaffinch, Robin, Wren, Goldcrest, Linnet, Chiffchaff, Pied
Wagtail, Great Tit, Mute Swan, Wood Pigeon, Great Crested
Grebe, Hooded Crow, Jackdaw, Grey Heron, Herring Gull, and
Mallard. These species rely on the local hedgerows, scrub, and
wetland habitats for nesting, foraging, and shelter. The proposed
removal of approximately 340 metres of hedgerow and the
clearance of conifer plantation for turbine safety buffers will
fragment these habitats, potentially displacing birds and
reducing breeding success-especially during the sensitive
nesting season. Additionally, the turbine's operation may pose
collision risks to larger birds such as Buzzards and Herons, and
disturbance from noise and movement could alter flight patterns
and feeding behaviour. The planning documents fail to
adequately assess or mitigate these risks to local avian.
4.Par 4 • Given the ecological sensitivity of the area and the presence of
protected and vulnerable species, I believe the development
poses unacceptable risks to local biodiversity.
The EcIA sets out the baseline conditions with respect to ornithology. An impact assessment is provided,
including consideration of habitat loss, disturbance and collision risk, with mitigation measures set out in
the EcIA and Bird Monitoring and Management Plan.
Doherty
Environmental
Consultants Ltd.RECEIVED: 04/09/2026
22790- Appendix D - P2
Paragraph Observations/ Point Response By Response
Observer: Micheal Beagan - Letter Dated 24/10/2025
Item 5
5. Par 1
5. Inadequate Appropriate Assessment Screening
• The site is hydrologically connected to Lough Oughter and
Associated Loughs SAC, which supports sensitive habitats and
species.
5. Par 2 • The screening report concludes no significant effects without
progressing to Stage 2 Appropriate Assessment, relying heavily
on best practice measures.
5. Par 3 • This is contrary to Section 177U(4) of the Planning and
Development Act 2000 (as amended).
Doherty
Environmental
Consultants Ltd.
The Screening Report for AA identifies a hydrological pathway. The Screening Report for Appropriate
Assessment also references ECJ Judgement C-721/21 which has established that account may be taken
of features of a project which involve the removal of contaminants and which therefore may have the
effect of reducing the harmful effects of the project on a European Site, where those features have been
incorporated into that project as standard features, inherent in such a project, irrespective of any effect
on the site.
The provision of best practice measures to prevent contamination to receiving waters are set out in
Section 2 of the Screening Report and are also set out in the CEMP provided under separate cover for the
proposed development. These measures are required to be implemented for the project, irrespective of
any effect on a European Sites. This requirement is set out in the Monaghan County Development Plan
which expressly requires the protection of the water environment during the construction and operation
phase of new development projects. Section 15.22.6 of the CDP identifies a Construction and
Environmental Management Plan incorporating soil-management and water-protection measures as a
critical component of construction-phase water protection. Section 15.30 further provides that, where
applicable, a CEMP shall include a water and sediment management plan to control surface-water runoff
and prevent silt or other pollutants from entering local watercourses or drains, together with a water-
quality monitoring and sampling plan. These requirements are reinforced by Policy CEMP 1, the water-
protection objectives contained in Chapter 8 and the requirement under Policy SWDP 1 to incorporate
Sustainable Drainage Systems into development proposals.
Given the requirements set out in the CDP these measures are incorporated into the construction and
operation phase design as standard features, inherent for such a project in Co. Monaghan, and in
keeping with the judgement in C-721/21, can be taken into account during the screening of the proposed
development. RECEIVED: 04/09/2026
22790- Appendix D - P2
Paragraph Observations/ Point Response By Response
Observer: Micheal Beagan - Letter Dated 24/10/2025
Item 6
6.Par 1
6. Heritage and Archaeological Impact
• The application proposes demolition of two vernacular
buildings recorded on historic maps without a full heritage
impact assessment.
Through Time Ltd. The application does not propose the demolition of the two vernacular buildings without appropriate
heritage assessment. The submitted Archaeological Impact Assessment identifies the two ruinous
buildings, including their presence on the First Edition Ordnance Survey mapping, and assesses the
archaeological and architectural heritage of the site and surrounding area. The report recommends that
the vernacular buildings be subject to a full descriptive, photographic and drawn survey, together with
pre-development archaeological testing supported by a metal detection survey.
Accordingly, appropriate recording and archaeological mitigation will be undertaken in advance of the
proposed works.
6.Par 2 • The archaeological report recommends pre-development
testing, but no commitment to monitoring or licensing is made.
Mable Consulting
Engineers
The Archaeological Impact Assessment recommends that pre-development archaeological testing,
supported by a metal detection survey, be undertaken by a suitably qualified archaeologist working under
licence from the National Monuments Service, Department of Housing, Local Government and Heritage.
Where archaeological material is identified, any further archaeological mitigation required, including
monitoring, will be undertaken in accordance with the requirements of the Department and Planning
Authority.
Accordingly, appropriate provision is made for both licensing and archaeological monitoring where
required.
6.Par 3 • The site is also near Bishops Court, a Protected Structure and
NIAH-listed building.
Through Time Ltd. The proximity of Bishops Court is noted. The Archaeological Impact Assessment identifies Bishops Court
as a Protected Structure and NIAH-listed building of regional importance, located approximately 230m
northwest of the proposed access road and approximately 700m from the proposed turbine.
The assessment confirms that no Protected Structures or NIAH-listed structures will be directly impacted
by the proposed Development.
Item 7
7.Par 1
7. Drainage, Flooding and Watercourse Crossing Risks
• The development crosses the Legarhill Stream, which connects
to the River Finn and downstream SACs.
McCloy
Consulting
The hydrological connection from the Legarhill Watercourse to the River Finn and the downstream Lough
Oughter and Associated Loughs SAC is acknowledged and assessed in the Water Environment
Assessment dated April 2026. The assessment considers the sensitivity and existing status of
downstream waterbodies and specifies drainage, sediment and pollution-prevention measures to
protect them during construction and operation. It concludes that the development will have no
significant adverse effect on downstream surface waters or the SAC.RECEIVED: 04/09/2026
22790- Appendix D - P2
Paragraph Observations/ Point Response By Response
Observer: Micheal Beagan - Letter Dated 24/10/2025
7.Par 2 • No hydrological modelling or baseline water quality data is
provided.
McCloy
Consulting
Detailed site-specific hydraulic modelling is provided in the Flood Risk Assessment dated April 2026. The
Water Environment Assessment provides a baseline characterisation based on field survey, current EPA
Water Framework Directive data and identified catchment pressures. The drainage plan also provides for
water-quality monitoring during construction. The assessment concludes that the development will not
cause deterioration of the Finn (Monaghan)_040 waterbody or prevent achievement of its Water
Framework Directive objectives.
7.Par 3 • No flood risk assessment appears to have been completed. McCloy
Consulting
A comprehensive site-specific Flood Risk Assessment dated April 2026 has now been provided. It
considers all relevant flood mechanisms and includes detailed hydraulic modelling of the Legarhill
Watercourse, its tributaries, the wider floodplain, existing structures and the proposed development.
7.Par 4 • The proposed access route crosses a field that is prone to
flooding, as shown in the attached photographs. Construction in
this area may exacerbate flood risk.
McCloy
Consulting
The access route has been specifically assessed in the submitted Flood Risk Assessment. The FRA
confirms that a section of the proposed access route adjacent to the R183 traverses Flood Zones A and
B; however, detailed hydraulic modelling of the proposed elevated access and watercourse crossing
predicts no measurable effect on flood levels and no material change to flood extents, and concludes
that the proposed access will have no adverse effect on flood risk at the site or elsewhere.
The access will be raised above the floodplain to provide dry access and egress, with the watercourse
crossing designed to meet OPW Section 50 requirements. Construction-phase surface water will also be
managed through the proposed SuDS measures, including cut-off drains, check dams, silt ponds and
buffered outfalls.
Item 8
8.Par 1
8. Light Pollution from Aviation Lighting
• The turbine will include aviation lighting, which is a serious
concern.
Art Generation
Ltd.
The turbine will include only the aviation obstacle lighting required for safety and regulatory compliance.
The final scheme will be agreed with the relevant aviation authorities and must also accommodate the
Department of Defence / Irish Air Corps requirements identified in consultation. This lighting serves a
specific safety function and is distinct from general site lighting. Its inclusion is therefore not, in itself,
considered a reason to refuse the Development.
8.Par 2 • I am already affected by aviation lights from the Drumlin Park
Wind Farm near Newbliss, approximately 4.5km away.
Art Generation
Ltd.
The presence of existing lights does not establish that the additional safety light associated with a single
turbine would result in a significant cumulative effect. The proposed lighting will be limited to the
obstacle-lighting scheme required by the relevant aviation authorities. The Development is a single-
turbine proposal and no general night-time illumination of the site is proposed. If the Planning Authority
requires a more detailed cumulative night-light assessment, the final lighting specification can be
provided to support that assessment.RECEIVED: 04/09/2026
22790- Appendix D - P2
Paragraph Observations/ Point Response By Response
Observer: Micheal Beagan - Letter Dated 24/10/2025
8.Par 3 • If another aviation light is placed within 0.5km north of my
home, it will directly affect my family's quality of life, especially at
night.
Art Generation
Ltd.
Aviation lighting will be restricted to the safety lighting required by the aviation authorities rather than
general site illumination. The proposed Development comprises one turbine and the lighting
specification will be controlled by the IAA and Department of Defence / Irish Air Corps requirements. The
observation does not demonstrate that the required obstacle light would cause an unacceptable
residential amenity effect. If necessary, the final lighting specification and orientation can be provided to
the Planning Authority for confirmation.
Item 9
9.Par 1
9. Lack of Community Engagement and Transparency
• A public notice was published in the Northern Standard on
18/09/2025, and planning was submitted less than two weeks
later.
Art Generation
Ltd.
Consultation was held in the form of an online dedicated website,
https://cloneswindfarm.com/index.htmlth
This dedicated website for the proposed Development was launched on 16th September 2025. A notice
was published in the Northern Standard newspaper on 18th September to advertise the website.
The purpose of the website was to inform the local community and all interested stakeholders about the
single turbine proposal, its community benefit fund, and to provide contact details for the Development’s
Community Liaison Officer.
9.Par 2 • No community engagement took place prior to submission, and
no public consultation events or feedback records have been
provided.
Art Generation
Ltd.
Following the provision of contact details for the Development’s Community Liaison Officer, Mr Michael
Beggan contacted the Community Liaison Officer regarding the Development. The Community Liaison
Officer provided to Mr Beggan details on the Development, the developer, and the proposed Community
Benefit Fund.
9.Par 3 The planning documents indicate that 53 homes may be affected
by shadow flicker and 67 by noise. It is unclear how these
residents were consulted, if at all. The absence of meaningful
engagement with the local community-especially those most
likely to be impacted-is unacceptable and contrary to the
principles of inclusive and transparent planning.
Art Generation
Ltd.
The Noise and Shadow Flicker Assessments identify study-area receptors for the purpose of assessing
potential effects; inclusion in a study area does not mean that those homes will experience a significant
adverse effect. The Noise Assessment predicts compliance with the applicable noise limit at the
assessed receptors, while the Shadow Flicker Assessment proposes an automatic control system to
eliminate unacceptable shadow-flicker effects.
Community engagement was available through the project website and Community Liaison Officer.RECEIVED: 04/09/2026
22790- Appendix D - P2
Paragraph Observations/ Point Response By Response
Observer: Micheal Beagan - Letter Dated 24/10/2025
Item 10
10.Par 1
10. Mapping Errors and Omission of Residential Proximity
• The planning documents rely on outdated mapping (circa
2015), and as a result, my home (H18EK22, Planning Ref. 17516)
is not visually shown on any of the maps submitted within the
application. This is a serious oversight, especially given the
potential development on nearby residents.
Mable Consulting
Engineers
The property referred to in the observation was included as a receptor in the relevant technical
assessments submitted with the Planning Application.
The property was assessed in the Noise Impact Report (Document Reference: Clones Noise Report_68
houses), the property is illustrated in Figure 1 on page 17 and referenced in Table 9 on page 18.
The property was also assessed in the Shadow Flicker Report (Document Reference: 7234 Clones
Shadow Flicker_Final) the property is illustrated in Figure 1 on page 9, House No. 2 and the location
coordinates and distance to turbine are given in Table 1.1 on page 11.
Accordingly, the potential noise and shadow flicker effects at this property were specifically considered
as part of the assessment of the proposed Development.
10.Par 2 • Furthermore, no drawings or maps have been provided to show
the distances between the proposed turbine and the nearest
residential receptors. Based on my own measurements, I believe
my property boundary lies within 500 metres of the proposed
turbine, which is a critical threshold for assessing impacts such
as noise, shadow flicker, and visual intrusion. The absence of this
information undermines the transpar application.
Mable Consulting
Engineers
The property referred to in the observation is located at ITM coordinates 652453, 825863.
The proposed Turbine is located at ITM coordinates 652228, 826431.
The plan distance between these coordinate sets is 611m
Item 11
11.Par 1
11. Lack of Consideration for Alternatives and Renewable Energy
Options
• The planning documentation states that "a number of
alternative sites and alternative designs/layouts were considered
before the subject site and current layout was chosen." However,
no evidence, mapping, or comparative analysis of these
alternatives has been included in the planning pack. This
omission makes it impossible for the public or the planning
authority to assess whether the chosen site is indeed the most
appropriate or least impactful option.
Mable Consulting
Engineers
In accordance with the Planning and Development Regulations, 2001, Part 10 - Environmental Impact
Assessment, Schedule 5, Part 2(3)(i) an Environmental Impact Assessment (EIA) is not required for this
Development as it comprises fewer than 5 turbines and has an output less than 5 megawatts.
An EIA Screening Assessment was undertaken, having regard to the criteria set out in Schedule 7A of the
Planning and Development Regulations 2001 (as amended), including the characteristics of the
proposed Development, its location, and the nature and characteristics of potential impacts. This
assessment confirmed that the proposed Development is not likely to give rise to significant effects on
the environment.
The provision of detail on alternatives is a feature of developments with an EIA. This project does not
require a EIA and so it is not a requirement to provide the detail mentioned in the observation.RECEIVED: 04/09/2026
22790- Appendix D - P2
Paragraph Observations/ Point Response By Response
Observer: Micheal Beagan - Letter Dated 24/10/2025
11.Par 2 • Furthermore, this project is covered by the Renewable Energy
Directive III (Directive (EU) 2023/2413), which encourages the
deployment of renewable energy in a manner that is
environmentally and socially responsible. Despite this, no
consideration has been given to the use of photovoltaic (PV)
solar technology, which may offer a lower-impact alternative.
There is ample suitable land in the area for a solar farm, which
would avoid many of the visual, noise, and ecological concerns
associated with wind turbines.
Mable Consulting
Engineers
RED III supports the accelerated deployment of renewable energy while maintaining environmental
assessment requirements; it does not require every wind-energy application to demonstrate that solar
PV was rejected as an alternative. Solar PV and wind energy have different generation profiles, land
requirements and project characteristics and are not directly interchangeable proposals. The
environmental effects of the Development actually proposed have been assessed through the submitted
planning and environmental reports. Accordingly, the absence of a separate solar-farm option does not
demonstrate non-compliance with renewable-energy policy.
11.Par 3 • The failure to present or assess alternative technologies and
layouts undermines the credibility of the planning application
and its alignment with national and EU renewable energy policy.
Mable Consulting
Engineers
The Planning Application provides sufficient information for the proposed wind development to be
assessed on its own merits. The absence of a formal alternatives chapter does not undermine the
application where an EIAR was not required, particularly where the PER records that site and layout
alternatives were considered during design. The proposal is supported by national and EU policy
promoting renewable-energy deployment, subject to appropriate environmental safeguards. The relevant
safeguards have been addressed through the suite of assessments submitted with the application.
Item 12
12.Par 1
12. Proximity of Substation to Residential Property and
Associated Risks
The planning application proposes the construction of a 20kV
electrical substation approximately 300 metres from my home
(H18EK22). This proximity raises serious concerns regarding:
• Visual intrusion: The substation compound, fencing, and
associated infrastructure will significantly alter the rural
character of the area and diminish the visual amenity of nearby
homes.
Mable Consulting
Engineers
The proposed 20 kV substation is a relatively small single-storey structure within a compound of
approximately 104m2, with the building itself approximately 55m2 and approximately 5m high. Its visual
effect must be considered in the context of the broader Development and the existing rural/agricultural
setting assessed in the LVIA.
The LVIA concludes that the Development as a whole will not give rise to significant landscape or visual
effects. On that basis, the substation is not considered to result in an unacceptable visual intrusion;
however, if required, landscaping details can be further confirmed at detailed design stage.
12.Par 2 • Noise and electromagnetic emissions: No site-specific
assessment has been provided regarding potential noise or EMF
impacts from the substation, despite its close proximity to
residential dwellings.
Noise & Vibration
Consultants Ltd.
There are many appliances inside a modern home which emit electromagnetic emissions such as
routers, phones, Bluetooth, house appliances such as fridges, washing machines, electrical
infrastructure such as televisions, electronics, transformers in chargers etc. Noise levels from the small
housed 20kV substation would be inaudible at less than 20dBA at the nearest receptor more than 360m
away.RECEIVED: 04/09/2026
22790- Appendix D - P2
Paragraph Observations/ Point Response By Response
Observer: Micheal Beagan - Letter Dated 24/10/2025
12.Par 3 • Flood risk: The substation is proposed in low-lying fields prone
to flooding, as acknowledged in the planning documents.
Construction in this area may exacerbate local flood risk.
McCloy
Consulting
Detailed hydraulic modelling confirms that the proposed substation is located in Flood Zone C and is not
affected by either the present-day 0.1% AEP flood extent or the corresponding high-end climate-change
scenario. The site-specific Flood Risk Assessment recommends a minimum design level of 49.31 m OD
for highly vulnerable development in this part of the site, while the submitted drainage plan identifies a
proposed substation finished floor level of 50.00 m OD. The substation is therefore appropriately sited
and designed with the required flood resilience.
The proposed Wind Turbine is also located within Flood Zone C, at a ground level of 57.0 m OD, and is
outside the modelled flood extents. Accordingly, the turbine is not considered to be at material risk of
fluvial flooding.
12.Par 4 • Mapping omissions: My home is not shown on most of the
submitted planning maps, despite being one of the closest
houses to the development. This omission undermines the
transparency and completeness of the application and fails to
assess the impact on nearby receptors.
Mable Consulting
Engineers
The fact that a dwelling is not depicted on the Tailte Eireann base mapping does not, in itself,
demonstrate that the substation or residential effects have not been assessed. The planning drawings
are intended to show the Development layout, while sensitive receptors are identified separately in the
relevant technical assessments. See Drawing Reference: 22790-001-G1 for turbine proximity to
dwellings.
12.Par 5 • Given the substation's location and the lack of robust
environmental and residential impact assessments, I believe this
element of the proposal alone warrants refusal.
Mable Consulting
Engineers
The submitted application contains environmental, engineering, landscape, drainage, noise and
construction assessments relevant to the substation and the Development as a whole.
The LVIA concludes that significant visual effects are not expected, and the drainage drawings/CEMP do
not show the substation within the mapped flood extent.
The noise levels from the small housed 20kV substation would be inaudible at less than 20dBA at the
nearest receptor more than 360m away.
Item 13
13.Par 1
13. Additional Environmental Impact Concerns
• Cumulative impact: The planning application lacks a
comprehensive cumulative impact assessment, particularly in
relation to existing wind energy developments in the area. The
cumulative effects on biodiversity, landscape character, and
residential been adequately addressed.
Doherty
Environmental
Consultants Ltd.
The EcIA provides a cumulative impact assessment with respect to other wind energy projects as well as
residential projects in the wider surrounding area. RECEIVED: 04/09/2026
22790- Appendix D - P2
Paragraph Observations/ Point Response By Response
Observer: Micheal Beagan - Letter Dated 24/10/2025
13.Par 2 • Construction traffic: There is insufficient detail on the potential
impact of construction traffic on local roads, including increased
wear and tear, traffic safety risks, and disruption to local
residents during the construction phase.
Mable Consulting
Engineers
A detailed Traffic Management Plan has been submitted with the Planning Application and specifically
addresses construction traffic, delivery routes, traffic-control procedures and mitigation. It provides for
an appointed Traffic Management Coordinator, designated access from the R183, advance agreement of
delivery routes with Monaghan County Council, and consultation with TII and An Garda Siochana for
abnormal-load movements. Abnormal turbine components are proposed to be delivered at night when
traffic is lightest, with escort arrangements, while a detailed construction-stage TMP will be submitted to
the Council before works commence. Accordingly, the application does not lack detail on construction
traffic or road-safety management.
Construction traffic impacts will be short-term and temporary and will be limited to the construction
phase. Having regard to the scale of the proposed single-turbine Development and the traffic
management measures set out in the submitted Traffic Management Plan, significant construction traffic
effects are not anticipated.
13.Par 3 • Decommissioning and restoration: There is no clear plan for
decommissioning or site restoration, which is essential for long-
term environmental stewardship and compliance with best
practice guidelines.
Mable Consulting
Engineers
The Planning Application does contain a clear decommissioning and restoration approach. The CEMP
states that, at the end of the design life, the turbine, substation and associated above-ground
components will be dismantled and removed, a detailed decommissioning plan will be agreed with
Monaghan County Council, and affected areas will be reinstated to their former agricultural use. The plan
will include recycling/disposal and traffic-management measures, with decommissioning undertaken
using the legislation and best practice applicable at that time. Accordingly, decommissioning and
restoration have been expressly provided for in the application documents.
Item14
14.Par 1
14. Planning Permission Duration vs. Operational Lifespan
The planning application seeks permission for a 10-year
development window, yet the proposed wind turbine and
associated infrastructure are intended to operate for 35 years
from commissioning. This discrepancy raises several concerns:
• Lack of long-term oversight: A 10-year planning permission
does not adequately account for the full operational impacts over
the 35-year lifespan, including cumulative environmental effects,
maintenance, and community disruption.
Mable Consulting
Engineers
The 10-year period sought for the permission relates to implementation of the Development, while the 35-
year period relates to operation after commissioning.
Long-term environmental effects are addressed through the submitted assessments. The 10-year
implementation period therefore does not remove long-term planning oversight.RECEIVED: 04/09/2026
22790- Appendix D - P2
Paragraph Observations/ Point Response By Response
Observer: Micheal Beagan - Letter Dated 24/10/2025
14.Par 2 • Insufficient environmental safeguards: The planning
documentation does not provide a robust framework for
monitoring and mitigating impacts over the full duration of the
turbine's operation
Mable Consulting
Engineers
The submitted documentation provides a framework for environmental management during construction
and operation, including an Ecological Clerk of Works, Project Ecologist, Project Hydrologist,
environmental audits and compliance monitoring. Operational controls are also identified, including the
shadow-flicker control system and noise-compliance measures, while permanent drainage
infrastructure is designed to be inspected and managed during operation. These measures provide a
basis for monitoring and mitigation over the life of the Development. Any additional monitoring required
by the Planning Authority can also be secured by condition.
14.Par 3 • Decommissioning uncertainty: While the application mentions
decommissioning after 35 years, there is no binding commitment
or financial security outlined to ensure responsible restoration of
the site.
Mable Consulting
Engineers
The application provides a clear commitment to decommissioning at the end of the 35-year design life
unless a further permission is obtained. The CEMP specifies removal of the turbine, substation and
above-ground components, recycling/disposal planning, traffic management and reinstatement of
affected areas to agricultural use.
If the Planning Authority considers financial security necessary, that matter can be addressed through an
appropriate planning condition.
14.Par 4 This mismatch between the planning timeframe and the actual
operational lifespan undermines the transparency and
accountability of the proposal.
Mable Consulting
Engineers
There is no mismatch between the 10-year implementation period and the 35-year operational lifespan
because they address different stages of the Development.
Item 15
15.Par 1
15. Conflict with Monaghan County Development Plan
The proposed development is in direct conflict with several key
objectives of the Monaghan County Development Plan 2019-
2025, including:
• EP1 - Protection of residential amenity from renewable energy
developments.
Mable Consulting
Engineers
The observation relies on the Monaghan County Development Plan 2019-2025, which had been
superseded by the Monaghan County Development Plan 2025-2031 before this application was
submitted. Residential amenity has nevertheless been specifically assessed through the Noise, Shadow
Flicker and Landscape and Visual Impact Assessments. Those assessments do not identify significant
residual effects that would warrant refusal with the proposed mitigation in place.
15.Par 2 • EP3 - Safeguarding landscape character and visual integrity. Mable Consulting
Engineers
The observation refers to policy numbering from the superseded 2019-2025 Development Plan.
Landscape and visual effects have been assessed through a dedicated LVIA using 13 representative
viewpoints and consideration of landscape character, topography and screening. The LVIA concludes
that significant landscape or visual effects are not expected and that residual impacts are acceptable in
the receiving landscape. RECEIVED: 04/09/2026
22790- Appendix D - P2
Paragraph Observations/ Point Response By Response
Observer: Micheal Beagan - Letter Dated 24/10/2025
15.Par 3 • EP5 - Protection of biodiversity and natural heritage. Mable Consulting
Engineers
Biodiversity and natural heritage have been assessed through both AA Screening and a detailed
Ecological Impact Assessment. The project footprint is described as habitats of low ecological value, the
Development is not located within a statutory nature-conservation designation, and no likely significant
effects on European Sites are identified. A comprehensive surface-water strategy and ecological
mitigation measures are included, with no significant negative residual effects predicted.
15.Par 4 • EP8 - Requirement for meaningful public consultation. Mable Consulting
Engineers
Community engagement was undertaken through the dedicated project website, Community Liaison
Officer contact details and a newspaper notice published in the Northern Standard on 18 September
2025. These measures provided an accessible means for interested parties to obtain information and
contact the developer.
15.Par 5 The development fails to meet these policy standards and should
therefore be refused.
Mable Consulting
Engineers
The assertion that the Development fails to meet the cited policy standards is not supported by the
technical assessments submitted with the application.
Item 16
16.Par 1
16. Procedural Deficiencies and Transparency Issues
The planning application contains multiple procedural flaws,
including:
• Mapping errors and outdated data (circa 2015).
Mable Consulting
Engineers
The planning drawings use Tailte Eireann mapping together with project-specific survey and design
information. Technical assessments, including noise and shadow flicker, also use additional receptor
mapping and data rather than relying solely on the background planning map.
16.Par 2 • Lack of technical detail in key areas such as drainage, noise
modelling, and eroloe mitigation.
Mable Consulting
Engineers
The application contains substantial technical detail in the areas identified. Drainage is addressed
through the planning drawings and CEMP, including clean/dirty water separation, settlement ponds,
buffered outfalls, watercourse buffers and construction-stage monitoring; noise is addressed through a
dedicated prediction model and receptor assessment; and ecological mitigation is set out in the EcIA and
CEMP under the supervision of an ECoW and Project Ecologist. These documents provide a detailed
framework for construction and operational environmental management. The assertion that the
application lacks technical detail in these areas is not accepted.RECEIVED: 04/09/2026
22790- Appendix D - P2
Paragraph Observations/ Point Response By Response
Observer: Micheal Beagan - Letter Dated 24/10/2025
16.Par 3 • Absence of meaningful community consultation. Art Generation
Ltd.
Community engagement was undertaken through a dedicated project website, Community Liaison
Officer contact details and a newspaper notice publicising those contact arrangements. The website
provided information on the proposal and a means for stakeholders to raise queries with the developer.
The formal planning process also allowed submissions and observations to be made directly to the
Planning Authority. Accordingly, the application cannot reasonably be characterised as having
proceeded without any opportunity for public engagement.
16.Par 4 These deficiencies undermine the credibility of the proposal and
its compliance with planning standards.
Mable Consulting
Engineers
The application is supported by detailed technical assessments, project-specific drawings and
environmental management plans, while community contact arrangements were also established. The
observations asserting deficiencies in the application and are not accepted.
Item 17
17.Par 1
18. Dangerous Precedent
Approval of this application without robust scrutiny would set a
concerning precedent for future wind energy developments in
Monaghan. It risks eroding public trust in the planning process
and weakening environmental safeguards for rural communities!
Mable Consulting
Engineers
The Planning Application has been subject to appropriate technical and environmental assessment in
accordance with the relevant planning requirements. Each future wind energy proposal will be
considered on its own merits.
Item 18
18.Par 1
Conclusion
In light of the above, I respectfully request that Monaghan County
Council refuse this application.
The proposed development is contrary to:
• Article 6(3) of the EU Habitats Directive
Mable Consulting
Engineers
The proposed Development has been subject to an Appropriate Assessment Screening specifically to
address Article 6(3) of the Habitats Directive. The screening considered the Development both alone and
in combination with other plans and projects, identified no impact pathways to European Sites and
concluded that there is no reasonable scientific doubt as to the absence of likely significant effects. A
Stage II Appropriate Assessment was therefore not required on the findings of the submitted screening.
The assertion that the Development is contrary to Article 6(3) is not supported by that assessment.
18.Par 2 •The Planning and Development Act 2000 (as amended) Mable Consulting
Engineers
The Planning Application has been prepared and submitted through the statutory planning process and is
supported by the environmental and technical information required to assess the proposed
Development. An EIA Screening, AA Screening and the relevant specialist assessments have been
provided, together with planning drawings, CEMP and Traffic Management Plan. No specific provision of
the Planning and Development Act is identified in the observation as having been breached. Accordingly,
the general assertion of non-compliance does not establish a basis for refusal.RECEIVED: 04/09/2026
22790- Appendix D - P2
Paragraph Observations/ Point Response By Response
Observer: Micheal Beagan - Letter Dated 24/10/2025
18.Par 3 •DEHLG Wind Energy Guidelines (2006) Mable Consulting
Engineers
The proposed Development has been assessed having regard to the Wind Energy Development
Guidelines 2006, including their provisions relevant to noise and shadow flicker. The Noise Assessment
applies a conservative 40 dBA operational limit and predicts compliance at the assessed receptors,
while the Shadow Flicker Assessment provides for an automatic control system to avoid unacceptable
effects. The current project documentation therefore directly addresses the principal amenity matters
covered by the Guidelines.
The Draft Revised Wind Energy Development Guidelines (2019) have also been considered. In particular,
the proposed turbine satisfies the draft visual amenity setback requirement of four times the turbine tip
height from residential properties, subject to a minimum setback of 500m. Turbins setback distances
are detailed in the FI Report, Section 2.5, Figure 1.
The general assertion of conflict with the 2006 Guidelines is not supported by the submitted
assessments.
18.Par 4 • Monaghan County Development Plan 2019-2025 (Policies EP1-
EP8)
Mable Consulting
Engineers
The Monaghan County Development Plan 2019-2025 cited in the observation had been superseded
before the application was submitted; the relevant plan is the Monaghan County Development Plan 2025-
2031. The substantive topics associated with the cited former policies - residential amenity, landscape,
biodiversity, infrastructure and community engagement - are addressed through the submitted
assessments and project measures. RECEIVED: 04/09/2026
Document Ref. Number: 22790-FI Report-P2
__________________________________________________________________________________________________________________
v
Appendix E – Response to Submission by T. Barmley & E. Sheridan
RECEIVED: 04/09/2026
Paragraph Observations/ Point Response By Response
Item 1
1.Par 1
1. Failure to Acknowledge a Permitted Dwelling
The planning application and environmental reports-including
the Noise Impact Assessment and Shadow Flicker Assessment-
fail to include our permitted dwelling, despite its location within
the 1,330-meter study area. This is a significant oversight, as:
1.Par 2 • Our house has received full planning permission from
Monaghan County Council.
1.Par 3 • It lies within the noise and shadow flicker impact zones.
1.Par 4 • It is a sensitive residential receptor that will be directly affected
by the turbine's operation.
Item 2
2.Par 1
2. Noise Impact Assessment Deficiency
Our house, at 840 meters, is not included in the receptor list, nor
is it mentioned in the predicted noise contour analysis. Despite
being within the zone where operational turbine noise is known to
be perceptible and potentially disruptive, our residence was not
included as a receptor in the operational noise modelling or
contour mapping. This is a critical omission, as:
• The report does not assess long-term operational noise
exposure at our property.
Mable Consulting
Engineers
Noise & Vibration
Consultants Ltd.
As stated above, and using the given dimension of 840m from the proposed Turbine, the dwelling is well
beyond the advisory 500m separation distance identified in the Wind Energy Development Guidelines
(2006) and the setback proposed in the Draft Revised Wind Energy Development Guidelines (2019) of
four times tip height, subject to a minimum of 500m.
The predicted noise levels at this location is for night-time are well below established night-time guide
limits of 40dbA. These limits are for outside the house. With a bedroom window adjar noise levels inside
a room are 10dBA lower and with the window fully closed the noise levels are even lower. Levels inside a
house with window closed would be inaudible. At night-time a noise level of 23dBA (with window ajar)
would be lower than normal breathing at 0.3m from a source which gives levels ranging from 23-27dBA.
Observer: Tiarnan Barmley & Evelyn Sheridan - Letter Dated N/A 22790 - Appendix E - P2
Mable Consulting
Engineers
At the time the original Noise Impact Assessment and Shadow Flicker Assessment were undertaken, the
dwelling was still at planning stage and did not constitute a permitted residential receptor. It was
therefore not included in the original assessments.
Planning permission has since been granted and the dwelling has now been included and assessed in
the updated Noise Impact Report and Shadow Flicker Report submitted as part of this FI response.
The distance between the proposed Turbine and the center of this planning-granted dwelling is 858m,
which is greater than the four-times tip-height setback requirement set out in the Draft Revised Wind
Energy Development Guidelines (2019). For this Development four times tip height is 575.2m.
The dwelling is assessed in the updated Noise Impact Report (Document Reference: Clones Noise
Report_68 houses), see Table 8 on page 15, Figure 1 on page 17 and Table 9 on page 18.
The dwelling is also assessed in the updated Shadow Flicker Report (Document Reference: 7234 Clones
Shadow Flicker_Final), see Figure 1.
The updated Noise Impact Report and Shadow Flicker Report confirm that no unacceptable noise or
shadow flicker impacts have been identified in relation to the permitted dwelling, with the proposed
mitigation measures incorporated where required.RECEIVED: 04/09/2026
Paragraph Observations/ Point Response By Response
Observer: Tiarnan Barmley & Evelyn Sheridan - Letter Dated N/A 22790 - Appendix E - P2
2.Par 2 • No baseline noise measurements or predicted sound pressure
levels are provided for our location.
Noise & Vibration
Consultants Ltd.
The predicted noise levels at this location is 33.2dBA.
2.Par 3 • No mitigation measures are proposed to address potential
impacts on our home.
Noise & Vibration
Consultants Ltd.
The selected turbine is going to be fitted with serrations trailing edge (STE) which reduces the sound
emissions.
2.Par 4 This lack of assessment is unacceptable and fails to meet the
standards of a comprehensive environmental impact evaluation.
Mable Consulting
Engineers
See 1. Par 1 above.
Item 3
3.Par 1
3. Shadow Flicker Assessment Deficiency
The Shadow Flicker Assessment identifies 53 receptors within
the study area. Our permitted house is not among
them, despite being within the zone where shadow flicker is
known to occur. This omission:
· Invalidates the completeness of the shadow flicker model.
Jennings
O'Donovan
This property (Ref: 2560318) was granted planning permission on the 05th of November 2025, after this
planning permission was submitted to the planning authority on the 07th of October 2025. The property
is located approximately 840m from the proposed turbine location. There are properties within the
vicinity of the dwelling (Ref. 2560318), and these were assessed for Shadow flicker, and it was
concluded there would be no significant effect to these dwellings with mitigation proposed. However, to
further support the view that there will be no significant effect on dwelling during any stage of the
Proposed Development, a shadow flicker assessment has been completed to assess effects. The model
was re-calculated to include this property (labelled 54 and shown in the figure below). This receptor is
expected to experience 2 hours and 52 minutes of 'expected' yearly shadow flicker which does not
exceed the 2006 WEDGs’s threshold of 30 hours of shadow flicker per year.
3.Par 2 · Fails to assess the visual and psychological impacts on our
household.
Jennings
O'Donovan
Art Generation
Ltd.
The receptor is expected to experience 36 minutes of daily shadow flicker, which exceeds the 2006
WEDGs threshold of 30/mins per day.
This represents a worst-case prediction and actual occurrences are expected to be lower, as shadow
flicker only occurs when the turbine, sun and receptor are aligned and the turbine is operating under the
required wind conditions.
An an automatic shadow flicker control system will be installed to ensure compliance with the applicable
limits. Such turbine shutdown systems are commonly used on wind energy developments and are a well-
established mitigation measure.RECEIVED: 04/09/2026
Paragraph Observations/ Point Response By Response
Observer: Tiarnan Barmley & Evelyn Sheridan - Letter Dated N/A 22790 - Appendix E - P2
3.Par 3 · Denies us the opportunity to be considered for mitigation
measures.
Jennings
O'Donovan
Art Generation
Ltd.
Proposed mitigation measures will apply to this property to ensure compliance with 2006 WEDGs
thresholds.
An an automatic shadow flicker control system will be installed to ensure compliance with the applicable
limits. Such turbine shutdown systems are commonly used on wind energy developments and are a well-
established mitigation measure.
Par 4 4. Hydrological Risks to Our Property
The pronosed develonment includes:
· Extensive earthworks and drainage alterations, including cut-off
drains, silt ponds, and buffered outfalls.
The Legarhill Stream and tributaries flow next to our permitted
dwelling, and the planning documents acknowledge that the site
is hydrologically connected to downstream watercourses via this
stream. While the application claims that best practice measures
will be implemented, it also admits that dewatering, pumping,
and over-pumping of excavations will occur, and that silty runoff
and concrete washout will require treatment.
These activities pose a real risk of altering the hydrology of the
area, which could:
McCloy
Consulting
These potential construction effects are expressly identified and assessed in the Water Environment
Assessment dated April 2026. The proposed controls include advance installation of cut-off drains, silt
fences, settlement features and buffered outfalls; a 10 m watercourse buffer; controlled permit-to-pump
arrangements for excavation water; bunded working areas; and prohibition of concrete washout near
drains or watercourses. There will be no direct discharge of development runoff to existing drains or
streams. With these measures, no significant adverse effect on the water environment is predicted.
• Increase flood risk on our land and around our permitted house. McCloy
Consulting
The site-specific Flood Risk Assessment dated April 2026 includes modelling of the proposed access,
bridge and associated changes within the floodplain. It predicts no measurable increase in flood levels,
no material change to flood extents and no alteration of existing flow-routing mechanisms. The volume
displaced by the raised access is less than 0.4% of the relevant floodplain storage volume and is
hydrologically insignificant. The development will therefore not increase flood risk to adjoining land or
property.
• Disrupt natural drainage patterns, leading to waterlogging or
erosion.
McCloy
Consulting
The proposed rural SuDS strategy is designed to retain the existing greenfield runoff response and
existing overland drainage pathways. Tracks will remain predominantly permeable, while cut-off drains,
check dams, settlement features, buffered outfalls and level spreaders will control velocities, treat
runoff and return water diffusely to vegetated ground. Existing drainage routes will not be redirected and
there will be no direct discharge to streams. Accordingly, no significant increase in waterlogging, erosion
or downstream runoff is predicted.RECEIVED: 04/09/2026
Paragraph Observations/ Point Response By Response
Observer: Tiarnan Barmley & Evelyn Sheridan - Letter Dated N/A 22790 - Appendix E - P2
• Contaminate surface water that flows adjacent to our property. McCloy
Consulting
The Water Environment Assessment identifies the potential pathways for sediment, concrete residues,
hydrocarbons and other construction contaminants and specifies measures to interrupt those pathways.
These include watercourse buffers, silt controls, settlement treatment, bunded storage and working
areas, controlled dewatering, spill-response measures and the prohibition of concrete washout near
water features. Following implementation of these controls, the assessment concludes that there will be
no significant adverse effect on surface-water quality.
Item 5
5.Par 1
5. Personal Safety and Occupational Risk
As we work daily on the family farm, We are regularly present in
and around the cattle shed located just 383 meters from the
proposed turbine. This shed is used for:
• Milking, feeding, and veterinary care of dairy cows.
• Shelter during adverse weather.
• Daily operations involving machinery and livestock handling.
The turbine's proximity poses a direct threat to our personal
safety in the event of:
• Blade throw, with debris capable of traveling over 400 meters.
Mable Consulting
Engineers
The proposed turbine will be certified to IEC 61400-1 or equivalent, as specified in the Planning &
Environmental Report. This standard addresses turbine structural integrity, design loads and
control/protection systems and provides the relevant design framework for abnormal structural failure
conditions.
Accordingly, compliance with applicable certification, manufacturer requirements and recognised
industry best-practice standards mitigates the associated risk of blade failure or blade throw to an
acceptable level.
5.Par 2 • Ice throw, particularly during winter months, Mable Consulting
Engineers
Ice accumulation is a recognised operational condition which can be managed through appropriate
turbine design and control measures. DNV-RP-0175 – Icing of Wind Turbines provides technical
requirements and guidance relating to ice detection, de-icing/anti-icing systems and turbine control and
protection systems under icing conditions. The proposed turbine will also be certified to IEC 61400-1 or
equivalent, as specified in the Planning & Environmental Report.
Accordingly, compliance with applicable design standards, manufacturer requirements and appropriate
ice-detection and control measures mitigates the associated risk of ice throw to an acceptable level.RECEIVED: 04/09/2026
Paragraph Observations/ Point Response By Response
Observer: Tiarnan Barmley & Evelyn Sheridan - Letter Dated N/A 22790 - Appendix E - P2
5.Par 3 • Structural collapse or fire, which could endanger anyone
working nearby.
These risks are not hypothetical-they are documented in turbine
failure case studies and must be taken seriously.
Mable Consulting
Engineers
The turbine will be certified to IEC 61400-1 or equivalent and designed for the environmental conditions
at the site. Structural collapse and fire are abnormal failure conditions addressed through turbine design,
protection systems, inspection and maintenance. IEC TS 61400-31:2023 specifically provides for
assessment of public risk from technical failures, turbine icing, lightning and fire, while IEC TS 61400-
30:2023 addresses wind turbine safety in design, operation, inspection and maintenance.
Accordingly, compliance with applicable certification, manufacturer requirements and recognised
industry best-practice standards mitigates the associated risk of structural failure or fire to an
acceptable level.
Item 6
6.Par 1
6. Lack of Community Engagement
There has been no meaningful engagement or consultation with
the local community regarding this proposal. As residents,
landowners, and workers directly affected by the development,
we were not informed or consulted prior to the submission of the
planning application. This lack of transparency and
communication is deeply concerning and contrary to the
principles of public participation in environmental decision-
making, as outlined in the Aarhus Convention and Irish planning
law.
Art Generation
Ltd.
Consultation was undertaken through a dedicated website for the proposed Development, which was
launched on 16 September 2025. The purpose of the website was to inform the local community and
interested stakeholders about the proposed single turbine Development and Community Benefit Fund,
and to provide contact details for the Development’s Community Liaison Officer.
In addition to this engagement, the Planning Application is subject to the statutory public participation
procedures of the Irish planning system. These procedures provide for public notification of the
application, public access to the submitted planning documentation and the opportunity for interested
parties to make submissions or observations to the Planning Authority for consideration as part of the
decision-making process.
Accordingly, the statutory planning process provides the formal mechanism for transparency,
communication and public participation in environmental decision-making, consistent with the
principles of the Aarhus Convention and Irish planning legislation. The assertion that there has been no
opportunity for community engagement or public participation is therefore not accepted.RECEIVED: 04/09/2026
Paragraph Observations/ Point Response By Response
Observer: Tiarnan Barmley & Evelyn Sheridan - Letter Dated N/A 22790 - Appendix E - P2
Item 7
7.Par 1
7. Planning Deficiencies and Grounds for Objection
The failure to include our permitted dwelling in both the noise
and shadow flicker assessments. and the lack of site-specific
hydrological modelling for our land, represent material
deficiencies in the planning application. These omissions:
• Undermine the credibility and completeness of the
environmental assessments.
7.Par 2 • Fail to comply with the principles of transparency, accuracy,
and fairness under Irish planning law.
7.Par 3 • Deny us, as a directly affected party, the opportunity to be
properly assessed, consulted, or protected.
Given these significant shortcomings, I strongly object to the
proposed development and urge Monaghan County Council to
refuse planning permission on the grounds that the application
fails to adequately assess and mitigate its impacts on all affected
parties, including our permitted dwelling.
Mable Consulting
Engineers
See 1 .Par 1 above
Mable Consulting
Engineers
See 1 .Par 1 above RECEIVED: 04/09/2026
Document Ref. Number: 22790-FI Report-P2
__________________________________________________________________________________________________________________
vi
Appendix F – Response to Submission by Gregory Sheridan
RECEIVED: 04/09/2026
Paragraph Observations/ Point Response By Response
Item 1
1.Par 1
1. Proximity to Residential and Agricultural Infrastructure
The turbine's proposed location:
• Is 860 meters from my home, where my family resides.
Mable Consulting
Engineers
Noted.
1.Par 2 • Is 383 meters from a key cattle shed, used daily farm operations such
as milking, feeding, and veterinary care.
Mable Consulting
Engineers
Noted.
1.Par 3 These distances fall well below the 500-1000 meter safety setbacks
recommended in international best practices. The turbine's proximity
poses unacceptable risks to both human and animal life in the event of
mechanical failure, blade throw, ice throw, or structural collapse.
Mable Consulting
Engineers
The assertion that mandatory 500-1,000m safety setbacks apply is not supported by the current Wind Energy
Development Guidelines 2006 or the Draft Revised Wind Energy Development Guidelines December 2019. The
Draft Revised Wind Energy Development Guidelines December 2019 propose a proposed a minimum 500m or
four-times-tip-height setback whichever is the greater. This Development's Turbine Tip Height is 143.8m; four-
times-tip-height is 575.2m. Accordingly the observation made is not accepted.
Item 2
2.Par 1
2. Animal Welfare and Dairy Productivity
Scientific literature and case studies have shown that dairy cows are
particularly sensitive to environmental stressors such as:
• Audible and low-frequency infrasound from turbines.
Mable Consulting
Engineers
The potential effects of wind turbine operation on livestock have been considered in the scientific literature. While
cattle can respond to sufficiently high levels of noise, vibration and other environmental stimuli, the available
evidence does not establish that noise, low-frequency sound, shadow flicker or ground-borne vibration from
normally operating wind turbines causes adverse effects on dairy-cattle welfare or milk production. Investigations
specifically examining reported effects on cattle near wind turbines have not established a causal relationship
between turbine operation and adverse herd health or dairy productivity.
The Noise Impact Assessment specifically considers low-frequency noise and infrasound and applies a
conservative operational noise limit of 40 dB LA90 during daytime and night-time. The assessment also references
published research indicating that turbine-generated infrasound is low relative to normal environmental
background levels. Accordingly, the predicted operational noise is not considered to give rise to an adverse effect
on livestock welfare or productivity.
2.Par 2 • Shadow flicker and visual disturbances.Jennings
O'Donovan
The Shadow Flicker Assessment identifies the potential for shadow flicker and provides for a shadow control
system to eliminate the potential for shadow flicker from the proposed Development. The available scientific
literature does not establish that turbine shadow flicker causes adverse welfare or productivity effects in dairy
cattle. Accordingly, with the proposed control measures in place, shadow flicker is not considered to present a
material risk to livestock.
2.Par 3 • Vibrations transmitted through the ground.Mable Consulting
Engineers
The Noise Impact Assessment reports operational turbine vibration below the stated human perception threshold
at 10m from the turbine, with construction vibration below that threshold beyond 30m.
The cattle shed is approximately 383m from the turbine, substantially beyond these distances. Accordingly,
ground-borne vibration is not considered to give rise to a material effect at the cattle shed.
Observer: Gregory Sheridan - Letter Dated N/A 22790 - Appendix F - P2
RECEIVED: 04/09/2026
Paragraph Observations/ Point Response By Response
Observer: Gregory Sheridan - Letter Dated N/A 22790 - Appendix F - P2
2.Par 4 • These stressors can cause startle responses, restlessness, and
avoidance behaviours, disrupting feeding and resting patterns-both of
which are critical to milk production and herd health. Any decline in
output due to stress-induced behavioural changes would directly
threaten the economic viability of my farm.
Art Generation Ltd.Published investigations into reported cattle health, behavioural and milk-production effects in proximity to wind
turbines have not established a causal relationship with turbine operation. Having regard to the predicted effects
of the proposed Development and the mitigation measures incorporated into the design, adverse effects on the
behaviour, health or productivity of the dairy herd are not anticipated.
Item 3
3.Par 1
3. Human Health and Residential Amenity
The turbine's proximity to my home raises concerns about:
• Sleep disturbance and chronic stress from turbine noise.
Noise & Vibration
Consultants Ltd
The predicted noise level of 33.2dBA is highly unlikely to cause sleep disturbance, or indeed chronic stress. The
general noise limits for night-time are normally 43dBA and higher in some instances where background noise
levels are high. The predicted noise levels inside a room with the window ajar would be 10dBA lower and at a level
where normal breathing gives higher levels in the range of 22-27dBA at 0.3m from source.
3.Par 2 • Shadow flicker, which can cause visual discomfort and psychological
stress.
Jennings
O'Donovan
Mitigation measures outlined will ensure no receptors will exceed the 2006 WEDGs thresholds.
3.Par 3 • Visual intrusion, significantly altering the rural character and
landscape.
Macroworks Ltd.Concerns have been raised within 3rd Party observation that the proposed single turbine development has the
potential to ‘significantly’ alter the prevailing rural character of the area and adversely affect the perceived sense
of rural tranquillity. In this regard, it is important to consider both the existing landscape context and the findings of
the LVIA. The receiving landscape is characterised as a working rural environment comprising agricultural land
uses, dispersed farmsteads, an established road network, overhead utility infrastructure and existing wind energy
development within the wider landscape context. As such, the landscape cannot be described as pristine or
untouched, but rather as an actively managed and evolving working rural landscape in which agricultural and
energy-related infrastructure already forms part of the established baseline landscape character. Indeed, as set
out in the submitted LVIA, “landscape sensitivity with the central study area is deemed to be Medium-low, with
localised areas of marginally higher sensitivity”, reflecting the robust working character of this landscape context
where landscape values relate mostly to productivity and subsistence of the rural economy, rather than
naturalistic or scenic values.
Whilst the proposed turbine will introduce a new vertical element into the landscape, the submitted LVIA and
photomontages highlight that visibility is moderated by the rolling drumlin landform and the extensive pattern of
mature hedgerows and tree lines that are located throughout the surrounding landscape. The ZTV mapping
indicates that views of the turbine are typically intermittent and frequently filtered, with more open visibility largely
confined to elevated drumlin ridges, which are generally less densely settled. Consequently, the development will
not result in widespread or uniform landscape change, but rather a localised and somewhat contained areas of
visual exposure.RECEIVED: 04/09/2026
Paragraph Observations/ Point Response By Response
Observer: Gregory Sheridan - Letter Dated N/A 22790 - Appendix F - P2
3.Par 3
Cont.
Macroworks Ltd.In terms of rural character, wind energy development is not an unfamiliar feature within the wider receiving
landscape or throughout the island of Ireland, with turbines of a notably greater scale already present within
approximately 5 km of the site and experienced within an almost identical landscape setting. The introduction of a
single turbine of comparatively lesser height does not therefore represent a fundamental change to landscape
character, nor does it alter the underlying agricultural land use, settlement pattern or landscape structure that
define the rural character of the area. Instead, the development would be perceived as an additional element
within an already robust and evolving working rural landscape.
With regard to rural tranquillity, it is recognised that perceptions of tranquillity are influenced by a range of factors
including movement, built form and existing infrastructure. The proposed development comprises a single turbine
and will increase the intensity of built development within the local surrounding context. Nevertheless, whilst the
development will marginally detract from the degree of rural tranquillity perceived within some localised areas
surrounding the site, these effects are deemed to be Not Significant. As demonstrated in the LVIA, predicted visual
effects range from Moderate to Imperceptible and are primarily experienced at the nearest visual receptors. At
greater distances, the turbine is typically perceived as a small-scale feature within expansive views and does not
materially interrupt the overall sense of openness or remoteness experienced within the wider landscape,
especially the more scenic elevated landscape to the north. As a result, whilst the turbine may introduce a
perceptible change in certain views, it is not considered to significantly diminish the prevailing sense of rural
tranquillity.
Overall, having regard to the established landscape context, existing wind energy development in the surrounding
area, the contained nature of predicted visibility and the scale of the proposal as a single turbine development, it is
considered that the proposed development would not significantly alter the prevailing rural character nor will it
heavily detract from the degree of rural tranquillity within the local surrounding landscape. The landscape is
considered sufficiently robust to accommodate the proposed development without resulting in unacceptable
landscape or visual effects.
3.Par 4 • These impacts would reduce our quality of life and potentially affect
the market value of our property.
Mable Consulting
Engineers
The potential effects of the proposed Development on residential amenity and quality of life have been considered
through the relevant technical assessments, including noise, shadow flicker and landscape and visual effects.
These assessments conclude that, with the proposed mitigation measures in place, the Development will not give
rise to significant adverse effects on residential amenity.
Property market value is not considered to require a separate assessment, as the relevant potential effects on
neighbouring properties are appropriately considered through the statutory planning process and the associated
environmental and amenity assessments.RECEIVED: 04/09/2026
Paragraph Observations/ Point Response By Response
Observer: Gregory Sheridan - Letter Dated N/A 22790 - Appendix F - P2
Item 4
4.Par 1
4.Par 2
4.Par 3
4. Light Pollution from Aviation Lighting
The turbine will be fitted with aviation warning lights, which will
introduce constant nighttime light pollution
into an otherwise dark rural environment. This will:
• Disrupt natural circadian rhythms for both humans and animais.
• Impact wildlife behaviour and nocturnal species.
• Create a visual nuisance for residents, particularly during low cloud
or fog conditions when light scatter is intensified.
Art Generation Ltd.The proposed Development does not include general site illumination. Any lighting installed on the turbine will be
limited to aviation warning lighting and will be provided in a pattern acceptable to the Irish Aviation Authority (IAA)
& the Department of Defence for aviation safety purposes. The lighting will be located on top of the turbine nacelle
for the purpose of identify the turbine as an obstacle to aviation receptors. Accordingly, it will not be designed to
cast light downwards towards ground level, thereby reducing the potential for notable effects on nearby ground-
based receptors.
The potential for effects on wildlife behaviour and nocturnal species has been specifically considered, particularly
in relation to bats. The EcIA identifies habitat loss/displacement, disruption of foraging activity and turbine
collision risk as relevant pathways, and records high activity for Common Pipistrelle, Soprano Pipistrelle and
Leisler’s Bat at the turbine location. A minimum 50m separation between the rotor-swept area and structured
vegetation is incorporated to reduce interaction risk, while the Bat Mitigation and Monitoring Plan provides five
years of post-construction activity and mortality monitoring with adaptive measures including habitat
management, blade feathering and operational curtailment where required. Accordingly, potential behavioural
effects on nocturnal bat species have not been overlooked and are subject to both design mitigation and ongoing
adaptive monitoring.
The Landscape and Visual Impact Assessment (LVIA) assessed the visual effects of the proposed turbine from
representative viewpoints throughout the study area and concluded that the Development would not give rise to
significant landscape or visual effects, with residual visual effects not exceeding Moderate significance.
Accordingly, while aviation warning lighting may be visible from some locations at night, it will be limited to that
required for aviation safety and, in the context of the existing lighting environment and absence of general site
illumination, is not considered likely to result in an unacceptable effect on residential amenity, visual amenity or
quality of life.
Macroworks Ltd.It is important to note the visual amenity is at its lowest during dark periods, as views across the landscape are
inhibited by the low levels of visibility. Thus, the proposed aviation warning lighting will have a minimal effect on
the visual amenity afforded in this landscape context, as the lighting will only ever be visible during periods of
darkness.
It is also important to note that the proposed lighting is located on top of the proposed turbine nacelle, as its
principal use is to identify obstacles in the sky for aviation-based receptors. Thus, the lighting included will not
cast light down towards the ground, which diminishes the potential for any notable effects to occur at ground-
based receptors. Whilst the flashing lights have the potential to be discerned from ground-based receptors, the
study area and local surrounds of the site are not located in a designated dark sky area.
It is also worth noting that the central study area is influenced by light spill emanating from existing light sources in
residential areas in nearby centres of populations. The N54 national secondary route and R183 regional road are
also contained within the central study area and are another notable existing source of potential visible lighting.RECEIVED: 04/09/2026
Paragraph Observations/ Point Response By Response
Observer: Gregory Sheridan - Letter Dated N/A 22790 - Appendix F - P2
4.Par 1
4.Par 2
4.Par 3
Cont.
• Impact wildlife behaviour and nocturnal species.Doherty
Environmental
Consultants Ltd.
The potential effects of the proposed development to habitats and fauna are set out in the EcIA. The assessment
examines the potential impact to fauna and habitats arising from potential effects such as collision,
fragmentation, habitat loss and disturbance. Mitigation measures are set out in the EcIA that, when implemented
in full, will avoid the potential significant effects to biodiversity receptors.
Item 5
5.Par 1
5. Drainage, Flooding, and Watercourse Crossing Risks
The proposed development includes:
• New access tracks, hardstands, and a bridge crossing over the
Legarhill Stream.
McCloy Consulting The potential effects of the access tracks, hardstandings, earthworks, drainage and Legarhill crossing have been
assessed through the site-specific Flood Risk Assessment and Water Environment Assessment dated April 2026.
Hydraulic modelling predicts no measurable increase in flood levels or material alteration of flood extents or flow
routes. The proposed clear-span crossing will avoid works within the wetted channel, while the rural SuDS design
will retain existing drainage pathways and diffuse runoff over vegetated ground. No significant adverse effect on
downstream land, water management or water quality is therefore predicted.
5.Par 2 • Extensive earthworks and drainage alterations. McCloy Consulting The potential effects of the access tracks, hardstandings, earthworks, drainage and Legarhill crossing have been
assessed through the site-specific Flood Risk Assessment and Water Environment Assessment dated April 2026.
Hydraulic modelling predicts no measurable increase in flood levels or material alteration of flood extents or flow
routes. The proposed clear-span crossing will avoid works within the wetted channel, while the rural SuDS design
will retain existing drainage pathways and diffuse runoff over vegetated ground. No significant adverse effect on
downstream land, water management or water quality is therefore predicted.
5.Par 3 • The Legarhill Stream flows through my land, and any disruption to its
natural flow, sediment load, or water quality could have direct
consequences for my fields, livestock, and water management
systems. I am particularly concerned about:
McCloy Consulting The potential effects of the access tracks, hardstandings, earthworks, drainage and Legarhill crossing have been
assessed through the site-specific Flood Risk Assessment and Water Environment Assessment dated April 2026.
Hydraulic modelling predicts no measurable increase in flood levels or material alteration of flood extents or flow
routes. The proposed clear-span crossing will avoid works within the wetted channel, while the rural SuDS design
will retain existing drainage pathways and diffuse runoff over vegetated ground. No significant adverse effect on
downstream land, water management or water quality is therefore predicted.
5.Par 4 • Increased flood risk due to altered hydrology and runoff patterns.McCloy Consulting The potential effects of the access tracks, hardstandings, earthworks, drainage and Legarhill crossing have been
assessed through the site-specific Flood Risk Assessment and Water Environment Assessment dated April 2026.
Hydraulic modelling predicts no measurable increase in flood levels or material alteration of flood extents or flow
routes. The proposed clear-span crossing will avoid works within the wetted channel, while the rural SuDS design
will retain existing drainage pathways and diffuse runoff over vegetated ground. No significant adverse effect on
downstream land, water management or water quality is therefore predicted.
5.Par 5 • Sediment and nutrient loading from construction activities.McCloy Consulting The Water Environment Assessment expressly considers sediment mobilisation and the existing nutrient
pressures affecting the Finn catchment. Construction runoff will be managed through cut-off drains, silt fencing,
settlement features and buffered outfalls, with no untreated or direct discharge to watercourses. The development
does not introduce a continuing nutrient source. The Water Framework Directive assessment therefore concludes
that the proposal will neither cause deterioration nor add materially to existing catchment-scale pressures.RECEIVED: 04/09/2026
Paragraph Observations/ Point Response By Response
Observer: Gregory Sheridan - Letter Dated N/A 22790 - Appendix F - P2
5.Par 6 • Potential contamination from construction materials or turbine
maintenance.
McCloy Consulting Potential contamination from fuels, oils, lubricants, concrete and other materials during construction and
operation is assessed in the Water Environment Assessment. Pollution-prevention measures include secure and
bunded storage, controlled refuelling, spill-response containment, managed concrete works, treatment of
construction runoff and ongoing maintenance of the drainage system. No plant, fuel or chemicals will be stored
within the floodplain. With these controls, no significant residual effect on surface water or groundwater is
predicted.
5.Par 7 • The planning documents ackiowledge the streani's sensitivity, yet tle
mitigation measures proposed are generic and untested in this specific
context.
McCloy Consulting The measures now provided are specific to the site and have been informed by field survey, the proposed layout
and drainage design, and detailed hydraulic modelling of the Legarhill Watercourse and floodplain. They include
defined SuDS features and outfall arrangements, a 10 m watercourse buffer, site-specific flood levels and bridge
design constraints, construction sequencing and dewatering controls, and a detailed bank-side methodology
avoiding works within the wetted channel. The assessments conclude that these measures will prevent any
significant adverse effect on flooding, hydrology or water quality.
Item 6
6.Par 1
6. Risk of Catastrophic Failure
Documented turbine failures include:
• Blade throw with debris traveling over 400 meters.
Mable Consulting
Engineers
The proposed turbine will be certified to IEC 61400-1 or equivalent, as specified in the Planning & Environmental
Report. This standard addresses turbine structural integrity, design loads and control/protection systems and
provides the relevant design framework for abnormal structural failure conditions.
Accordingly, compliance with applicable certification, manufacturer requirements and recognised industry best-
practice standards mitigates the associated risk of blade failure or blade throw to an acceptable level.
6.Par 2 • Structural collapse and fire.Mable Consulting
Engineers
The turbine will be certified to IEC 61400-1 or equivalent and designed for the environmental conditions at the site.
Structural collapse and fire are abnormal failure conditions addressed through turbine design, protection
systems, inspection and maintenance. IEC TS 61400-31:2023 provides for assessment of public risk arising from
technical failures, turbine icing, lightning and fire, while IEC TS 61400-30:2023 addresses wind turbine safety in
design, operation, inspection and maintenance.
Accordingly, compliance with applicable certification, manufacturer requirements and recognised industry best-
practice standards mitigates the associated risk of structural failure or fire to an acceptable level.
6.Par 3 • Ice throw, especially during winter, with ice fragments capable of
causing injury.
Mable Consulting
Engineers
Ice accumulation is a recognised operational condition which can be managed through appropriate turbine design
and control measures. DNV-RP-0175 – Icing of Wind Turbines provides technical requirements and guidance
relating to ice detection, de-icing/anti-icing systems and turbine control and protection systems under icing
conditions. The proposed turbine will also be certified to IEC 61400-1 or equivalent, as specified in the Planning &
Environmental Report.
Accordingly, compliance with applicable design standards, manufacturer requirements and appropriate ice-
detection and control measures mitigates the associated risk of ice throw to an acceptable level.RECEIVED: 04/09/2026
Paragraph Observations/ Point Response By Response
Observer: Gregory Sheridan - Letter Dated N/A 22790 - Appendix F - P2
6.Par 4 • Given that I and my staff are frequently working in and around the
cattle shed, the risk to human safety is unacceptable.
Mable Consulting
Engineers
Having regard to the proposed turbine certification, applicable design standards and the operational safety
measures outlined above, the presence of persons working at the nearby cattle shed is not considered to give rise
to an unacceptable risk to human safety
Item 7
7.Par 1
7. Lack of Long-Term Research and the Precautionary Principle
There is a notable lack of long-term, peer-reviewed research
specifically focused on the effects of wind turbines on dairy cattle and
rural residential health. Given this uncertainty, I urge the planning
authority to apply the precautionary principle and consider the
potential risks to animal welfare, food production, and rural
livelihoods.
Mable Consulting
Engineers
The available scientific evidence does not establish adverse effects on cattle welfare, milk production or the
health of rural residents from normally operating wind turbines. The proposed Development has been assessed
using applicable standards and conservative criteria, with mitigation incorporated where required. Accordingly,
the precautionary principle is considered to have been appropriately addressed through the assessment of
potential effects and the implementation of mitigation measures.
Item 8
8.Par 1
8. Cumulative Impact on Rural Livelihoods
Approving this turbine so close to an active dairy operation could set a
dangerous precedent for future developments in agricultural zones.
The cumulative impact on rural communities, food security, and
farming sustainability must be taken into account.
Mable Consulting
Engineers
The proposal is a single-turbine Development within an existing agricultural landscape and does not prevent the
continued use of surrounding lands for farming. The observation does not provide evidence that the Development
would adversely affect food security or the sustainability of the local dairy sector. Potential environmental and
residential effects have been assessed through the submitted specialist reports, and the relevant noise, shadow-
flicker and ecological effects are predicted to be acceptable with mitigation.
Any future development would require its own planning assessment, so approval of this proposal would not create
an automatic precedent for development in agricultural areas.
Item 9
9.Par 1
9. Lack of Community Engagement
There has been no meaningful engagement or consultation with the
local community regarding this proposal. As a resident and landowner
directly affected by the development, I was not informed or consulted
prior to the submission of the planning application. This lack of
transparency and communication is deeply concerning and contrary to
the principles of public participation in environmental decision-
making, as outlined in the Aarhus Convention and Irish planning law.
Art Generation Ltd.Consultation was held in the form of an online dedicated website, https://cloneswindfarm.com/index.htmlth
This dedicated website for the proposed Development was launched on 16th September 2025. A notice was
published in the Northern Standard newspaper on 18th September to advertise the website.
The purpose of the website was to inform the local community and all interested stakeholders about the single
turbine proposal, its community benefit fund, and to provide contact details for the Development’s Community
Liaison Officer.RECEIVED: 04/09/2026
Document Ref. Number: 22790-FI Report-P2
__________________________________________________________________________________________________________________
vii
Appendix G – Response to Submission by DoHLG&H
RECEIVED: 04/09/2026
Paragraph Observations/ Point Response By Response
Item 1
1.Par 1
Nature Conservation
The Department acknowledges the findings of the AA screening
report and Ecological Impact Assessment (EclA) supporting the
application. The following observations are provided;
Doherty
Environmental
Consultants Ltd.
Section 2.2.2.1 sets out the rationale for the reduced survey effort completed for the proposed
development up to July 2025. It is noted that further survey effort has been undertaken throughout the
spring passage and breeding season of 2026, amounting to a total of 51 hours of vantage point surveying
for the proposed single wind turbine project up to August 2026.
The EcIA has been updated to provide a detailed impact assessment for Whooper Swan and Greenland
White-fronted Geese. The EcIA makes reference to the Bird sensitivity to wind energy developments
mapping tool but does not rely on this as a definitive source for establishing the presence/absence of
species sensitive to increased risks from collision with such developments. A detailed assessment is
provided in the EcIA that considers potential impacts to avifauna, including Whooper Swan and
Greenland White-fronted Geese . A comprehensive Bird Monitoring and Management Plan has been
prepared as part of the EcIA and will be put into effect for the duration of the lifetime of the project. The
full implementation of this plan will provide safeguards for birds, including Whooper Swan and
Greenland White-fronted Geese, should they be present, throughout the projects lifetime.
Item 2
2.Par 1
Matters relating to ornithological assessments
Attention is drawn to the ornithological assessment of the
proposed development as described within the EclA, noting that
the recommended 36 hours of vantage point surveys
(NatureScot, 20251) were not conducted in this case, instead
having been scaled down to a total of 21.5 hours. However, the
report does not provide further details regarding the decision-
making process in coming to this determination for the reduction
in survey effort and is deemed to lack weight.
Doherty
Environmental
Consultants Ltd.
See 1.Par 1 Above.
Observer: Department of Housing, Local Government and Heritage - Letter
Dated 10/11/2025 22790 - Appendix G - P1RECEIVED: 04/09/2026
Paragraph Observations/ Point Response By Response
Observer: Department of Housing, Local Government and Heritage - Letter
Dated 10/11/2025 22790 - Appendix G - P1
2.Par 2 In addition, there appears to have been only very limited survey
effort during the 2023/2024 winter period, restricted to a
combined total of 7 hours vantage point (VP) surveys on the 12th
October 2024 and 7th February 2024. This is considered to be a
significant constraint for making any determination on the
collision risks involving wintering waterbirds in the vicinity of the
proposed development beyond all reasonable doubt, most
notably for Whooper Swan (Cygnus Cygnus) and Greenland
White-fronted Goose (Anser albifrons flavirostris), both listed
under Annex I of the Birds Directive (Directive 2009/147/EC).
Waterbird abundances typically peak during the December-
January window and could not have been adequately considered
in this context.
2.Par 3 The recommended 36 hours of VP survey effort over two breeding
and two non-breeding seasons is considered as good practise by
the Department as part of ecological surveys for any onshore
wind energy development. It is recommended that data
presented within the mapping interface 'Bird sensitivity to wind
energy developments' mapping interface should be used as
guidance only and not as a definitive likelihood for the
presence/absence of species sensitive to increased risks from
collision with such developments. Whilst this proposed
development is noted to be comprised of a single turbine, the
overall blade tip height of 149.61m is considered to have a higher
ornithological impact potential than smaller developments of a
comparative type.
See 1.Par 1 Above.Doherty
Environmental
Consultants Ltd.RECEIVED: 04/09/2026
Paragraph Observations/ Point Response By Response
Observer: Department of Housing, Local Government and Heritage - Letter
Dated 10/11/2025 22790 - Appendix G - P1
2.Par 4 The Department also notes that, in spite of the small scale of the
proposed development within an agricultural landscape, no
wider ornithological assessments of the surrounding-
waterbodies appear to have been undertaken in considering the
wider implications for species commuting between sites for
roosting and foraging purposes. The primary habitat ype as
identified within the EclA as 'improved agricultural grasslands
within a wider farmed landscape' does not preclude the potential
for wildfowl to utilise this habitat type for foraging in suitable
areas, e.g. low-lying grasslands including the floodplains of
suitable river valleys. For example, the Kilroosky Lough Cluster
SAC (site code: 001786) is situated 1.5km from the application
site, whilst the closest waterbody is Bishop's Lough, situated
approximately 400m to the south east from the location of the
proposed turbine, is situated within the wider wetland network
and forms part of the Finn River watershed.
2.Par 5 The Department refers to the EclA which states that "Areas of
higher value habitat for birds in the surrounding locality such as
at Bishops Lough and Altartate Lough and the surrounding
wetland will not be affected by the projec. The EclA also states
that no sensitive species were found within the vicinity of the
project, but provides no further details to elaborate on these
statements. The Monaghan County Development Plan 2019-
2025 identifies Bishop's Lough (MFS-12) as a site of biodiversity
importance at the county scale and may provide suitable habitat
for intermittent usage by Whooper Swan during the lifetime of any
planning consent.
2.Par 6 The Department recommends that further information is
provided on the potential for ornithological impacts arising from
the proposed development and further details on the
assessments conducted, including observational data.
Doherty
Environmental
Consultants Ltd.
Noted. The EcIA has been updated. (Document Reference: 2026.08.27 Clones SWT EcIA_V2)
Doherty
Environmental
Consultants Ltd.
See 1.Par 1 Above.RECEIVED: 04/09/2026
Paragraph Observations/ Point Response By Response
Observer: Department of Housing, Local Government and Heritage - Letter
Dated 10/11/2025 22790 - Appendix G - P1
Item 3
3.Par 1
Archaeology
It is noted that an archaeological assessment report by Martin
Fitzpatrick, Archaeologist has been submitted with this
application. This Department concurs with the recommendations
as outlined in this report and recommends that archaeological
Pre-development trenching be carried out at this site and
included as a condition in the granting of any planning
permission.
Mable Consulting
Engineers
Noted and accepted.
3.Par 2 Pre-development testing shall consist of the following;
The applicant is required to engage the services of a suitably
qualified archaeologist (licensed under the National Monuments
Acts 1930-2004) to carry out pre-developmenttesting at the site.
No sub-surface work shall be undertaken in the absence of the
archaeologist without his/her express consent.
Mable Consulting
Engineers
Noted and accepted.
3.Par 3 The archaeologist is required to notify the Department of
Housing, Local Government and Heritage in writing at least four
weeks prior to the commencement of site preparationsd. This will
allow the archaeologist sufficient time to obtain a licence to carry
out the work.
The archaeologist shall carry out any relevant documentary
research and may excavate test trenches at locations chosen by
the archaeologist, having consulted the proposed development
plans.
Mable Consulting
Engineers
Noted and accepted.
3.Par 4 Archaeological Test Excavation shall be informed and
supplemented by licensed metal detection survey.
Mable Consulting
Engineers
Noted and accepted.
3.Par 5 Having completed the work, the archaeologist shall submit a
written report to the Planning Authority and to the Department of
Housing, Local Government and Heritage.
Mable Consulting
Engineers
Noted and accepted. RECEIVED: 04/09/2026
Paragraph Observations/ Point Response By Response
Observer: Department of Housing, Local Government and Heritage - Letter
Dated 10/11/2025 22790 - Appendix G - P1
3.Par 6 Where archaeological material is shown to be present,
avoidance, preservation in situ, preservation by record
(excavation) and/or monitoring may be required, the Department
of Housing, Local Government and Heritage will advise the
Applicant/Developer with regard to these matters.
Mable Consulting
Engineers
Noted and accepted.
3.Par 7 No site preparation or construction work shall be carried out until
after the archaeologist's report has been submitted and
permission to proceed has been received in writing from the
Planning Authority in consultation with the Department of
Housing, Local Government and Heritage.
Mable Consulting
Engineers
Noted and accepted.
3.Par 8 Reason: To ensure the continued preservation (either in situ or by
record) of places, caves, sites, features or other objects of
archaeological interest.
Mable Consulting
Engineers
Noted. RECEIVED: 04/09/2026
Document Ref. Number: 22790-FI Report-P2
__________________________________________________________________________________________________________________
viii
Appendix H – Response to Submission by Dep. of Defence
RECEIVED: 04/09/2026
Paragraph Observations/ Point Response By Response
Item 1
1.Par 1
Following consultations with our Air Corps colleagues at
Casement Aerodrome, The Department of Defence would like to
make the following observations:
The Minister for Defence is responsible for the regulation of
military aviation, whereas the Irish Aviation Authority (IAA) is
responsible for the safety regulation of civil aviation including
aerodromes. The IAA does not have remit for military aviation or
installations. Safeguarding of military flight operations and
installations is intended to protect both current and future
aircraft operations and also to take account of the security
requirements associated with some of those operations.
• All turbines should be illuminated by Type C, Medium intensity,
Fixed Red obstacle lighting with a minimum output of 2,000
candela to be visible in all directions of azimuth and to be
operational H24/7 days a week.
Mable Consulting
Engineers
Noted and accepted.
1.Par 1 • Obstacle lighting may be incandescent. If LED or other lighting
types are used, should be a type visible to Night Vision
equipment.
Mable Consulting
Engineers
Noted and accepted.
1.Par 2 • Obstacle lighting must emit light at the near Infra-Red (IR) range
of the electromagnetic spectrum, specifically at or near 850
nanometres (nm) of wavelength. Light intensity to be of similar
value to that emitted in the visible spectrum of light.
Mable Consulting
Engineers
Noted and accepted.
Observer: Department of Defence - Letter Dated 22/10/2025 22790 - Appendix H - P2
RECEIVED: 04/09/2026
Paragraph Observations/ Point Response By Response
Observer: Department of Defence - Letter Dated 22/10/2025 22790 - Appendix H - P2
1.Par 3 • In the event of negative impacts on future military radar
systems, the owner will engage with the Department of Defence
and will provide suitable mitigations as soon as practical.
Any Irish Air Corps (IAC) requirements are separate to Irish
Aviation Authority (IAA) requirements.
Mable Consulting
Engineers
Noted.RECEIVED: 04/09/2026
Document Ref. Number: 22790-FI Report-P2
__________________________________________________________________________________________________________________
ix
Appendix I – Response to Irish Aviation Authority Submission
RECEIVED: 04/09/2026
Paragraph Observations/ Point Response By Response
Item 1
1.Par 1
In the event of planning consent being granted, the applicant
should be conditioned to contact the Irish Aviation Authority to:
(1) agree an aeronautical obstacle warning light scheme for the
wind turbine,
Mable Consulting
Engineers
Noted and accepted.
1.Par 2 (2) provide as-constructed coordinates in WGS-84 format
together with ground and tip height elevation at the wind turbine
location and:
Mable Consulting
Engineers
Noted and accepted.
1.Par 3 (3) notify the Authority of intention to commence crane
operations with at least 30 days prior notification of their erection
in accordance with S.I 215 of 2005 Irish Aviation Authority
(Obstacles to Aircraft in Flight) Order.
Mable Consulting
Engineers
Noted and accepted.
Observer: Irish Aviation Authority - Letter Dated 14/10/2025 22790 - Appendix I - P1
RECEIVED: 04/09/2026