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HomeMy WebLinkAbout2560400 - Submission - Micahel BeaganPLANNING SECTION Michael Beagan Cladowen Newbliss Co. Monaghan Date: 28/10/2025 Planning Department Monaghan County Council County Offices 1 Dublin Street Monaghan, Co. Monaghan 28 SEP 2026 Re: Further Submission Objection to Planning Application for Single Wind Turbine Development at Carneys Island & Altartate, Clones, Co. Monaghan Planning Reference Number: 2560400 Dear Sir/Madam, I previously made a submission concerning the above planning application. I now make this further submission following my review of the applicant's Further Information, including the updated ecology, bird and bat monitoring, flood -risk, water -environment, noise, shadow -flicker, engineering and Appropriate Assessment screening material. I acknowledge that the Further Information provides additional detail. However, it also confirms significant environmental constraints and relies extensively on future monitoring, turbine shutdown, curtailment and adaptive management. In my view, the information does not demonstrate with sufficient certainty that the development is suitable for this location or that effects on residential amenity, protected wildlife, watercourses, flood risk and downstream European sites will be adequately avoided. I respectfully request that Monaghan County Council refuse planning permission. I further submit that likely significant effects on European sites have not been excluded on the basis of complete and objective scientific information and that a Stage 2 Appropriate Assessment is required before any decision is made. 1. Significant ecological sensitivity and bat collision risk The updated Bat Mitigation and Monitoring Plan records high activity by Common pipistrelle, Soprano pipistrelle and Leisler's bat. The applicant identifies these as species at high risk of collision with wind turbines. The plan provides for post -construction monitoring, mortality searches, annual review and adaptive mitigation, including blade feathering and possible curtailment. The proximity of the turbine to the adjoining plantation woodland is also relevant because the woodland edge forms part of the habitat setting used in the bat assessment. Any future felling or management undertaken to accommodate turbine operation could change the environmental baseline assessed. These measures may assist in responding to impacts, but they do not establish before consent that significant mortality or disturbance will not occur. Where high activity by collision -sensitive species is already recorded, post -construction monitoring should verify a robust assessment rather than substitute for certainty in that assessment. 2. Bird risk remains dependent on future monitoring and shutdown The updated Bird Mitigation and Monitoring Plan identifies collision, barrier, disturbance, displacement and habitat effects as potential pathways. Whooper Swan, other waterbirds and raptors are identified as receptors for collision risk. The plan proposes continued monitoring of Bishop's Lough, nearby feeding areas and flight paths, together with precautionary shutdown and possible programmed curtailment if risk is later identified. The adjoining plantation woodland forms part of the wider habitat mosaic surrounding the turbine. The application does not clearly explain whether future forestry -management requirements have been factored into the ornithological assessment. The Department of Housing, Local Government and Heritage previously regarded the original winter survey effort as a significant constraint on determining collision risk for wintering waterbirds beyond reasonable doubt. The Department also identified Bishop's Lough, approximately 400 metres from the turbine location, as part of the wider wetland network and habitat that may be used intermittently by Whooper Swan during the life of a permission. The absence of sensitive species during particular survey occasions does not demonstrate that they will not use Bishop's Lough, surrounding floodplain grasslands or flight routes across the site during the proposed 35 -year operational period. This material uncertainty should be resolved before consent rather than through post -consent monitoring. 3. Shadow -flicker exceedances and dependence on shutdown The updated Shadow Flicker Report identifies 56 receptors within the study area. 28 receptors may experience shadow flicker, and 14 are predicted to exceed 30 minutes in a day under the modelled worst - case scenario. The report states that no receptor is expected to exceed 30 hours per year in the "expected shadow" scenario and proposes an automatic control system to shut down or curtail the turbine when relevant conditions occur. The word "expected" reflects a modelled scenario based on assumptions concerning sunshine, turbine operation and wind direction. The Planning Authority should distinguish this from the worst -case outcome and should not assume that predicted exceedances are resolved merely because a future automated shutdown system is proposed. The need for shadow -flicker shutdown, bird -related shutdown and possible bat curtailment indicates that multiple operational restrictions are required to make the location acceptable. This supports concern that the site is intrinsically constrained. 4. Residential separation distances and assessment methodology The Shadow Flicker Report refers to my dwelling as being approximately 611 metres from the proposed turbine. This appears to be a centre -to -centre measurement between the turbine location and the dwelling rather than a measurement to the nearest point of the rotor -swept area. The proposed turbine has a rotor diameter of approximately 133.2 metres, meaning that the rotor extends approximately 66.6 metres from the hub. My annotated plan in Figure 1 below indicates an approximate distance of 498 metres from the rotor edge towards my property and approximately 444 metres from the rotor edge towards a dwelling to the west. These measurements are indicative and should be independently verified using surveyed coordinates and the final turbine geometry. I am not relying on the proposition that a universal statutory 500 -metre setback automatically applies. My concern is that centre -point distances can materially differ from rotor -edge proximity and may not transparently communicate the relationship between the rotating blades and nearby residences. I request that the Planning Authority verify: 1. the precise start and end points used for each quoted residential separation distance; 2. whether the same methodology was used consistently in the noise, shadow -flicker, landscape, ecology and safety assessments; 3. whether those assessments remain valid when the rotor radius and nearest blade -tip position are clearly identified; 4. the verified nearest distance between the rotor -swept area and each surrounding dwelling and residential property; and 5. whether residential proximity has been fully considered in relation to amenity, safety, shadow flicker and operational controls. Figure 1 - Plan View with Dimensions 5. Noise assessment and enforceable compliance The applicant states that my property is included in the revised Noise Impact Report and predicts compliance with the adopted limits. The conclusion nevertheless depends on modelling assumptions and the acoustic characteristics of the selected turbine. The absence of independent commissioning and compliance testing, an enforceable complaints procedure and defined operational controls leaves the potential noise effects insufficiently resolved. The possibility of substituting the turbine model creates further uncertainty unless a revised receptor -specific assessment demonstrates an equal or lower sound -power output. These matters should be resolved before determination and, in their absence, support refusal rather than being deferred to conditions. 6. Turbine dimensions and assessment consistency The drawing titled "Turbine Details 1 of 2" records a tower height of 75 metres, hub height of 78 metres, rotor diameter of 133.2 metres and overall tip height of 143.8 metres. The Construction and Environmental Management Plan refers to a Nordex N133 on a 71.5 -metre tower, while the landscape material has also used a rotor -diameter figure of 131.6 metres. These are substantive dimensional differences, not merely different descriptions of tower height and hub height. The Planning Authority should establish one definitive turbine specification and confirm that all technical assessments use identical inputs for tower height, hub height, rotor diameter, ground level and overall tip height. Turbine geometry directly affects shadow flicker, landscape and visual effects, collision risk, blade and vegetation clearance, and residential proximity. Any assessment relying on inconsistent inputs should not be accepted without correction and reassessment. 7. Woodland proximity, forestry clearance and environmental assessment I am concerned that the proposed turbine is located immediately beside plantation woodland. See Figure 2 below with the woodland area highlighted. The turbine has a rotor -sweep radius of approximately 66.6 metres, and the application expressly includes tree felling, landscaping and reinstatement works. The application does not clearly establish: • the full extent of forestry clearance required during construction; • whether additional tree removal will be required to facilitate safe turbine operation or maintenance; • whether future tree growth has been considered in the siting and operational design; • whether vegetation management is required to maintain blade clearance or the stated bat buffer; or • whether all potential woodland removal has been included in the ecological, ornithological, landscape, visual, carbon and biodiversity assessments. This concern is reinforced by the updated Ecological Impact Assessment, which refers to a recommended buffer between the rotor -swept area and vegetation corridors and states that structured vegetation will not be permitted to establish at relevant locations during operation. The potential operational vegetation - management area should therefore have been clearly mapped and quantified. Any additional woodland removal could materially affect bird habitat, bat activity, visual screening, landscape character, carbon storage and the baseline conclusions of the submitted assessments. The extent of woodland clearance necessary for construction, operation and future forestry management remains unclear. This uncertainty is a further reason why permission should be refused. Figure 2 - Highlighted Woodland Area Turbine_ Loran h'an 8. Flood risk and access infrastructure in Flood Zones A and B The Flood Risk Assessment identifies fluvial flooding as a significant mechanism and confirms that a portion of the proposed access route near the R183 lies within Flood Zones A and B, while the turbine and substation are stated to lie in Flood Zone C. The development requires a raised access route, a new bridge crossing and permanent drainage infrastructure in an acknowledged flood -risk environment. The Planning Authority should not accept the development unless it is demonstrated that raising the access route, constructing the bridge and altering drainage will not displace floodwater, obstruct flow paths, increase flood levels or extents, affect adjoining land, increase erosion or sediment movement, or create unacceptable maintenance risks. The unresolved uncertainty supports refusal. 9. Drainage design, road runoff and cited drainage guidance The site -layout notes refer to drainage measures being designed in accordance with the Greater Dublin Regional Code of Practice for Drainage Works and SuDS principles. The application should demonstrate why this guidance is appropriate for the rural County Monaghan catchment, the site soils, local watercourses and the acknowledged fluvial flood setting, together with compliance with any Monaghan -specific and national requirements. Although typical drainage details have been submitted, the information should provide site -specific longitudinal sections, cross -sections and outfall details showing how runoff from each access -road section will be collected, conveyed, treated and discharged. The applicant should demonstrate that road runoff cannot reach the adjacent stream without adequate treatment. The location, capacity, freeboard, maintenance, bypass behaviour and performance of settlement ponds, silt fences and other sediment controls during extreme rainfall and flood conditions should be demonstrated rather than deferred to construction -stage management. 10. Water quality and downstream hydrological connectivity The works include a bridge crossing, access -road construction, excavation, concrete works and permanent drainage near watercourses connected to the River Finn catchment. The need for cut-off drains, settlement features, buffered outfalls, level spreaders and pollution controls confirms that credible pathways exist for sediment or contaminants to reach the receiving environment if controls fail, are incorrectly installed, are not maintained or are overwhelmed. The applicant proposes cessation of works and removal of plant, materials and fuels in advance of a predicted severe flood. The reliability of this approach depends on warning time, authority to stop works, protection of exposed soil and partially completed works, and the performance of temporary systems during sudden or extreme events. These matters remain material to the acceptability of the proposal. 11. Appropriate Assessment screening and the need for Stage 2 AA An Appropriate Assessment screening report has been submitted. The issue is whether it contains sufficient objective scientific information to exclude likely significant effects on every relevant European site, alone and in combination with other plans or projects. The updated screening report acknowledges a hydrological pathway through the Finn River to Lough Oughter and Associated Loughs SAC. This must be reconciled with the bridge crossing, floodplain works, drainage network and the range of measures intended to prevent sediment or pollution reaching downstream waters. The screening conclusion appears to depend materially on construction management, clean -water and dirty - water separation, settlement systems, buffered outfalls, fuel controls and other pollution -prevention measures. The Planning Authority should examine the actual purpose and function of each measure and determine whether likely significant effects can be excluded without relying on measures intended to avoid or reduce effects on a European site. The ecological assessment also relies on future monitoring, adaptive management, operational restrictions and potentially future forestry -management measures. These mechanisms may manage effects after commencement, but they also indicate that uncertainty remains concerning the actual environmental effects of the development. In those circumstances, it is difficult to conclude that all scientific uncertainty has been removed at screening stage. I request that the Planning Authority determine whether: 6. all surface -water and ecological pathways to potentially connected European sites have been identified and assessed; 7. bridge construction, floodplain works and drainage discharges have been assessed under realistic adverse conditions; 8. the screening conclusion depends improperly on mitigation or avoidance measures; 9. the ornithological information is sufficiently complete to exclude effects beyond reasonable scientific doubt; 10. the conservation objectives and qualifying interests of all relevant European sites have been considered using current information; and 11. in -combination effects have been assessed comprehensively. If likely significant effects cannot be excluded on the basis of complete objective scientific information, the application must proceed to Stage 2 Appropriate Assessment before any decision is made. 12. Reliance on monitoring first and mitigation later A recurring feature of the Further Information is reliance on future monitoring, shutdown procedures, curtailment measures and adaptive management. Monitoring can identify impacts after development commences, but it cannot substitute for a robust assessment demonstrating that those impacts are unlikely to occur in the first place. Limited weight should therefore be attached to arguments that defer environmental certainty until after the turbine becomes operational. 13. Archaeology and built heritage The Department of Housing, Local Government and Heritage recommended licensed pre -development trenching and a metal -detection survey. It also required that no site preparation or construction proceed until the archaeologist's report is submitted and written permission to proceed is received from the Planning Authority in consultation with the Department. The presence, extent and significance of subsurface archaeology will therefore not be fully established at the decision stage. Given the proposed excavation, access works, cable route and demolition of two ruinous vernacular buildings, the outstanding testing represents a material information gap. This uncertainty should not be deferred until after consent and supports refusal of the application in its present form. 14. Aviation lighting and rural amenity The Department of Defence requested medium -intensity fixed red obstacle lighting with a minimum output of 2,000 candela, visible in all directions and operating continuously, together with near -infrared output. The bird -monitoring material, by contrast, seeks to 6inimize lighting to reduce attraction or disorientation. The residential, landscape and ecological implications of the final lighting arrangement should have been fully assessed before determination. As the lighting specification and its effects remain unresolved, this uncertainty supports refusal and should not be deferred until after consent. 15. Community engagement The applicant refers to a project website and community liaison arrangements. Residents attempting to access the website encountered browser security warnings that could reasonably discourage access. See Figure 3 below. A number of technical questions were also redirected to the Planning Authority rather than substantively answered through the engagement process. The existence of a website or contact address does not, by itself, demonstrate meaningful consultation. The claimed engagement does not resolve the substantive environmental and residential concerns set out in this submission. X v Privacy er... < Q Your connection is not private Altar,krr:, nmq'rt iu Ifylnq in rtrtd yom udotmanon from cloneawIndfarm.com (for ex., ple, password+;, nu�s,)gec ur crcdd c,ad:;), Un Ilo r tr urc d(wt this warNily NI 1. 1 ma to It! UAII INvd! N 9 To on en steed protcctiaq to jot Chromes highost level of securely Advanced Figure 3 - Security Warning Before Entering the Website 16. Safety, turbine certification and emergency arrangements Although serious turbine failures are uncommon, a turbine blade failure occurred at Drumlins Park Wind Farm, Co. Monaghan, on 22 April 2026, resulting in blade fragments being dispersed onto surrounding land. The application should therefore clearly demonstrate the certification and design standards applicable to the definitive turbine model, together with its lightning and fire protection, overspeed protection, ice -control measures, inspection regime and emergency arrangements. These concerns are further amplified by the residential separation -distance issues discussed in Section 4. 17. Decommissioning and long-term restoration The development is proposed to operate for 35 years. The Construction and Environmental Management Plan indicates that foundations and parts of the hardstanding may remain beneath the ground and that the access track may remain. This does not amount to demonstrated full restoration of the site. The application does not provide sufficient certainty concerning complete decommissioning, restoration and the financial security required to deliver those works. The absence of an independently costed restoration plan and secured financial provision, together with the proposal that foundations, hardstanding and access infrastructure may remain, represents a further reason why permission should not be granted. 18. Conclusion and request When considered cumulatively, the matters raised are not isolated concerns. They involve ecological uncertainty, unresolved ornithological impacts, flood risk, hydrological connectivity, woodland -clearance uncertainty, residential proximity, inconsistent turbine dimensions, reliance on future mitigation and insufficient certainty concerning European -site protection. Collectively, the applicant has not demonstrated that the development can proceed without unacceptable environmental and residential effects. For the reasons set out above, I respectfully request that Monaghan County Council refuse planning permission. The unresolved deficiencies and uncertainties are material to the acceptability of the development and should not be deferred to post -consent monitoring, later agreement or planning conditions. I further submit that the Planning Authority cannot currently exclude likely significant effects on European sites beyond reasonable scientific doubt and that a Stage 2 Appropriate Assessment is required before any decision is made. Yours faithfully, Michael Beagan