16/06/2026
Here is the write-up of Day 19 of the Public Inquiry, which you may have noticed was missing.
There can only be admiration and gratitude for those who took this on. It is a real service to the community when there is no formal record of proceedings. Thank you, Niall Mc Aleer and Emmet McAleer - Independent.
All of these write-ups are also available on our website (link in the first comment below).
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𝗗𝗮𝘆 𝟭𝟵
𝗖𝘂𝗹𝘁𝘂𝗿𝗮𝗹 𝗛𝗲𝗿𝗶𝘁𝗮𝗴𝗲 (𝗖𝗛) - 𝗗𝗮𝘆 𝟭 𝟬𝟮/𝟬𝟲/𝟮𝟲
Following an identification of all parties intending to speak and prior to Cultural Heritage questioning commencing, a third party objector Niall Mc Aleer asked the Commissioners if opportunities to return to unresolved issues within the Roads element of the inquiry would be provided at a later stage in the inquiry, highlighting the visibility spay issue at the Camcosy Road access to the explosive store as an example. Commissioner Donaghy noted that this matter was closed out last week, with the objector requesting that the Commissioners revisit their notes on the subject as third parties understood that the sub-standard sight-line in question had not been responded to by DfI Roads – who had advised this was being checked rather than confirming any dimensions.
Commissioner Donaghy outlined the topics to be covered under Cultural Heritage: Applicant’s assessment methodology; sense of place + cultural identity; archaeological issues; ASSI/ Beaghmore Stone Circles; Cumulative assessment; Green Road (historic significance of route); Linguistic Heritage; Folk, memory + associative heritage; sub-surface archaeology (& peatland under same); Human Rights considered intrinsic throughout, with a catch all question at end. Commissioner Donaghy advised there was no need to cover everything submitted in writing, noting a pressing need to conclude this section in the three days allowed.
Q1. Commissioner Donaghy asked applicant to respond to third party views that the Applicant’s cultural heritage assessment methodology is flawed; understanding of heritage outdated (physical assets only); & failure to adopt correct HIA.
Mr Beattie (Counsel for Dalradian) referenced the written methodology as an accepted approach, and did not accept that this was outdated, too narrow or inconsistent with current standards.
Mr Long (DGL Consultant: Gahan & Long) stated that the written methodology approach considered accepted as HED did not challenge this, noting that a HED guidance document on ‘setting’ was followed. He noted that the scope of the study was set out in 2017 ES submission (Appendix A2: P.15 of 17 & Appendix A1. Section 2.10 P.64 of 116). Mr Long proceeded to read from the submissions, noting desktop exercises undertaken on behalf of DGL. Historic records reviewed, review of historic monuments within 1-2km of the infrastructure site, review of industrial archaeology within 1-2km of site, review of historic gardens over site area & 1-2km of site boundary; review of documents held by PRONI (for development area only); Review of Ordnance Survey photographs (for development area only); Detailed ‘walkover’ survey to assess archaeological assets ‘both unknown & known’. Without identifying any survey tools beyond visual observations this statement raised questions.
Mr Long drew the Commissioners attention to a HED response to the PAD consultation dated 24/02/16 noting they were content with Gahan & Long’s cultural heritage assessment.
Mr Long asserted G&L assessment complied with HED April 2019 guidance document on Archaeological Works in the Planning Process and drew comparisons to 2021 CiFA, Principles of Cultural Heritage Impact Assessment in the UK document in TBR15 (P7) to refute outdated methodology challenges: referencing 2 principles of Cultural Heritage: A) understanding assets, describing + attributing importance and B/ understanding the impact of change. Mr Long then referenced use of 3km search beyond the site boundary, as part of a desktop survey exercise, noting 34 known archaeological sites identified (8 considered regionally important), 2 listed buildings, 32 industrial heritage sites & 9 vernacular buildings. Grading of sites from world heritage sites, to scheduled monuments and lower classifications set out in ES Appendix C15, Table 3 P.14, with severity of change levels included in Table 4 P.15
Commissioners then intervened to query references to both drilling and tunnelling within the Environmental Statement (ES) and how the impacts of this were assessed. Mr Beattie (DGL) stated that no surface drilling was proposed in the exploration area, all underground (not to come within 100m of surface). Commissioners recognised this is a contrary position to what was proposed in ES and pressed for clarification. Mr Beattie on behalf of DGL, thought this was clear – noting that any sub-surface activity will not come within 100m of surface. Dr Gordon (Turley for DGL) referenced an update to mine design parameter statement in TR1 Project Overview, Annex A, Section 13, Exploration Methodology P.27 (which notes ‘The exploration drives/ tunnels will be excavated into fresh bedrock below the transition layer of weathered rock at a depth of 100m or greater’.) Commissioner Mc Parland queried the contradictory content across the submission, asking does it expressly say no drilling or are you inferring it Dr Gordon? Dr Gordon reiterated the statement, which inferred this outcome. Commissioners voiced their intentions to consider this matter further between themselves. References to drill bays & drill holes were noted in Appendix E9, Project Description Update (October 2020).
Mr Beattie (Counsel for DGL) attention to DfI’s Draft Conditions without prejudice (contained within DfI SoC on Main Mine Application) MD8 Mine Design Statement, MD9 Mine Development Plans & MD10 Retrospective mine survey of work already done as a means to control this, adding if this is not of interest, we would be open to a (standalone) condition.
Mr Long (DGL) considered his assessment to also address intangible cultural heritage, referencing CIFA July 2021 guidance & HED guidance Guidance on Setting and the Historic Environment (Feb 2018). His explanation cited points within this HED document but failed to give any account of how these were applied/considered or discounted in the context of this application. 2.3 The Extent of Setting; 2.4 Aspects of Setting - Settings can be complex and multi-faceted – any assessment of the setting of a heritage asset should include, as a minimum, consideration of the following aspects, although other, often intangible aspects such as ambience, may also be considered: 2.4.1 Physical, 2.4.2 Visual, 2.4.3 Functional. Functional aspects of setting include the aesthetic, architectural, commemorative, historical, social, spiritual, symbolic, technological, traditional knowledge and/or other tangible or intangible values associated with human activity. Mr Long noted CIFA (2021) doesn’t provide specifics on how to assess intangible cultural heritage in response to third party challenges this was not adequately addressed.
Attention then turned to physical views at ‘regionally important monuments in the search area’, Mr Long stated there was no intervisibility between monuments and the infrastructure site & Owenkillew valley. Mine infrastructure site not visible at monuments, including Beaghmore Stone circles ASSI in the Applicant’s assessment – ES 2017, C15 Appendix 6, Pages 66-73 referenced.
Mr Long understood the International Council on Monuments and Sites (ICOMOS) 2022 Guidance and Toolkit for Impact Assessment applied to World Heritage Sites, noting only 4 sites on the island (Brú na Bóinne , Skellig Michael, Giant's Causeway & Gracehill Moravian Settlement) and did not believe this an appropriate standard to be applied in his assessment.
Mr Orbinson (Counsel for NIE) was invited to speak next, noting broadly the same issues highlighted by third parties on Mr McGonigle’s (John Cronin Associates) CH assessment. Mr Orbinson noted the assessment had been found adequate by HED; drawing commissioner’s attention to methodology set out in section 2 of RPS Technical Report 4 (Appendix A – Heavy Duty Powerline App) and Chapter 6.2 Archaeology & Built Heritage in DfI SoC for Main Mine Application.
Mr McGonigle (Archaeologist for NIE) advised that he completed a desktop survey of all archaeology and cultural heritage sites within 200m corridor of powerline route; assessment of all heritage monuments within 1km of proposed route; sites & monuments records; industrial heritage; defence heritage; historic gardens; historic cartographic surveys; and previous excavations. A field survey – route ‘walkover’ following alignment of proposed powerline was carried out and identified 2 further potential archaeological sites nearby. Assessment conducted to consider impact on setting (HED guidance followed), this involved creation of photomontage views. No archaeological sites records in SMR (Scope & Methodology Report?); 5 industrial heritage sites recorded within study area (200m route corridor), 3 scheduled monuments within 100m corridor, with 2 further possible sites found as noted above. Mr McGonigle noted the scale of mitigation measures were set out within Cultural Heritage Report and were agreed with HED to be adequate.
Commissioners then invited HED to respond. Mr McAleenan (HED Senior Archaeologist) noted that in terms of adequacy of scope, in 2017-2018, HED did agree to the proposed ES scope, however 8-9 years later, ‘we would consider some elements too narrow. Our approach to assessing large scale development, & other extensive developments along with recent policy changes (have) moved beyond individual sites to consider wider settings, broader& more landscape scope assessments, intervisibility, wider landscape relationships… scope of assessment now expected to locate at a larger geographic scale. We recognise this thinking has evolved in recent years, since 2017-18’.
Commissioner Donaghy pressed Mr McAleenan for specifics/ professional recommendations around this. Mr McAleenan noted that in terms of assessment scope, where 3km zone around a development site may have been accepted in 2017, nowadays studies should extend 10-15km beyond development limits to ensure a comprehensive and robust assessment. On other aspects Mr McAleenan noted impacts on peatland – how hydrology affects that, impacts of peat removal on archaeological survival. HED would expect detailed photomontages & detailed wireframes accompanied with explanations to clarify what is being shown, so all stakeholders are clear on the impact on wider historic setting.
Commissioner Donaghy queried have these concerns been relayed to the Department & Applicant previously. Mr McAleenan stated that the Peatland aspect had been clearly relayed to the Applicant and noted further information was requested around settings issue has been raised in Department’s SoC.
Dr Strecker (SOS Expert) questioned the methodology used by Gahan & Long: noting that their first report was based on CiFA guidance, which set out guiding principles rather than being prescriptive. This wouldn’t be as methodologically robust as ICOMOS document referenced by HED.
Dr Strecker drew attention to paragraph 1.10 CiFA Principles of Cultural Heritage Impact Assessment in the UK (July 2021), which notes ‘this document sets out a language and framework for understanding and assessing the effects of a proposal on cultural significance. This document does not seek to offer prescriptive methodological guidance on CHIA (Cultural Heritage Impact Assessment). Given the breadth of what can be regarded as cultural heritage assets and the diversity of potential change that could come about from a range of different proposals, there is no ‘one size fits all’ methodology to CHIA.’
Cultural Heritage – ‘setting can transcend’ – spiritual values, literature study/ review References are made to these aspects but these were not assessed within the Applicant’s CHIA. Tyrone Folk Quest by Michael Murphy, recognised as the seminal work on folklore in Tyrone not mentioned under CHIA, no consideration of Irish language, no community consultation as part of impact assessment.
For landscape of this sensitivity adoption of a robust methodology would be expected even if it is not a World Heritage Site. Dr Strecker noted that ICOMOS (2022) standards are widely used in assessments and are taught at Masters Level in UCD as the appropriate level of consideration for regionally significant areas/ area of archaeological interest.
Dr Strecker noted that Mr McGonigle references 2011 ICOMOS methodology in his original CH Assessment in association with the Powerline application, however when this assessment was updated in 2024, it doesn’t mention the 2022 ICOMOS guidance. Dr Strecker queried this approach, noting a significant time lapse between the reports and developments in the interim in relation to policy norms & developments, an evolving framework of cultural rights and Community participation fundamental.
Dr Strecker highlighted relevant cultural rights under human rights legislation, noting the right to access one’s own cultural heritage, right to participate in decision making - Article 15 1(a) International Covenant on Economic, Social and Cultural Rights (ICESCR) & Article 27 International Covenant on Civil & Political Rights (ICCPR).
Mr C McAleer (SOS) queried the new declaration of no drilling would occur within 100m of the exploration area and draft conditions MD8 & MD9: in terms of fair assessment at this inquiry and enforceability around violations. Forward looking plans to be decided by the Applicant on an annual basis & submitted to the Planning Authority: the drilling depth to be decided, extent & location of tunnelling to be decided; areas for observation/ monitoring to be decided. There are too many unknowns, and everything can change on an annual basis. Furthermore he considered vertical drilling necessary for ventilation shafts to serve exploratory tunnelling. SOS Rebuttal statement referenced steps that should be taken in CH Impact Assessment, anyone involved in Heritage Management at a high level would know that sub-surface archaeology would be adversely affects by this proposal – noise, dust, vibration, light, impact on dark skies all connected to this.
Dr Cirefice (SOS Expert) spoke of the narrowness of CH assessments being a major concern and highlighted that central to the ICOMOS guidance is participation with local communities, as the first step. Dr Cirefice noted the importance of Ethnographic studies, site visits and engagement activities which were not included. Desktop studies do not engage with people on the ground, Dr Cirefice referenced a research project she had conducted in the Sperrins over 5 years funded by the Irish Research Council, engaging over 100 people which was approved by the Ethics Committee at Galway University and featured in Peer reviewed academic articles. The research involved creative workshops -countermapping, photovoice - ethnography, interviews, walking trips, site visits, focus groups and a wide literature review. Dr Cirefice considered the methodology, ethically & professionally speaking, to be so narrow that voices of local people are excluded. The site possesses significant value for people’s sense of place, connecting with history, the natural world and physical & mental well-being. These holistic understandings of cultural heritage and landscape, reflected in current international law standards, ICOMOS Guidelines, and ‘Principles of Cultural Heritage Impact Assessment in the UK’, were not taken into account in the cultural heritage impact assessments attached to the Applicant’s Statement of Case.
Emma Mc Aleer speaking from the public gallery, noted that built heritage is being talked about rather than cultural heritage. CH includes speech, hard-won humour rising from the land itself, noting that living culture is not ornamental, in the Sperrins this survives because the landscape remains intact.
Sinead Warnock spoke from the public gallery about the importance of the Irish Language in the area, highlighting another text: Sgéalta Mhuintir Luinigh; Munterloney Folktales: Irish Tradition from County Tyrone and well-known native Irish speakers who had lived in the area, such as Paddy Laidir Mc Cullough. The language is the basis for our culture, part of our sense of place and sense of community, with the same families living here for generations. Reducing our lived experience to limited desktop studies.
Sinead referenced Josephine Clarke (nee McCullagh) who spoke on a previous day at the inquiry, whose uncle James Kate McCullagh farmed the land now proposed for the mine infrastructure site, left Sheskinshule regularly on a bike to tend to animals. It was the granny of another local man who has spoked at this inquiry (Martin Conway - Chair of local GAA Club) who provided the water to tend animals etc at that time. The story was shared to highlight the inter-connectedness of people locally. Societal, political & environmental factors cannot be ignored, people were forced up the mountain onto the less arable land through colonisation.
Dr Peadar MacGabhann spoke on the background to Tyrone Folk Quest; in 1950’s there was a drive to create a national folklore archive, with the Irish Folklore Commission in Dublin (which later became UCD) commissioning cultural intelligence officer Michael Murphy to complete the work. Body of material covered withing book: buildings, origins of population groups, weather, elements, land, land use, farming, place names, pronunciation & meaning, ringforts, mass rocks, flora & fauna.
Local man, Sean Clarke said that Murphy and wife & children lived in Teebane east for 4years, where he met local people, with a big contribution coming from Paddy Laidir McCullough from the townland of Curraghinalt. Prior to this a German professor (Prof Wagner) came to Glenhull in the 1930’s, to study the language. Professor Wagner ended up living in Connemara, teaching people Irish.
Third Party objector Mr Haughey queried the practicality of the assertion of no surface drilling on site. He again highlighted that only 1% of the gold resource is ‘measured’ and noted that in the Cavanacaw Mine the company frequently lost sight of the seams, he was aware of 4 permission requests to drill down to find these. He considered vertical drilling with rigs essential, irrespective of the new position presented by the Applicant today.
Mr Haughey noted that TBR15 by the Applicant was only made available to third parties in February 2026 under the Transboundary Consultation, with third parties not afforded the opportunity to respond in writing, so oral responses need to be facilitated. He considered it strange that the 2021 CiFA publication, Principles of Cultural Heritage Impact Assessment in the UK was only now being referred to by the Applicant and noted the Assessment was not sufficient by any means.
Mr Haughey noted that SPPS 2nd Edition (Dec 2025) should be applied - Strategic Planning Policy Statement for Northern Ireland- citing a number of relevant paragaphs:
‘6.1 Archaeological and built heritage are an irreplaceable record which contributes to our understanding of both the present and the past and is an important economic resource.’ The Applicant’s proposal to make a record of any archaeological features found during construction is not the same as preserving, excavation in this manner is simply controlled destruction. It is a watching brief after the event. Robust assessment needed to identify material beforehand – detailed survey work should have occurred but is absent. Paragraph 6.8 notes protections not limited to scheduled monuments. If the methodology proposed by Applicant was used on sites such as Beaghmore Stone Circles or Copney Stone Circles would have been destroyed rather than preserved. Copney Stone circles (Creggan) most complex stone circles in our area, not mentioned in discussions to date. Paragraph 6.11 ‘Where a planning authority is minded to grant planning permission for development which will affect sites known or likely to contain archaeological remains, it should ensure that appropriate measures are taken for the identification and mitigation of the archaeological impacts of the development. Where appropriate, this may involve the preservation of remains in situ, or a licensed excavation, recording examination and archiving of the archaeology...’. ASAI (Areas of Significant Archaeological Interest) designation recognises the level of archaeological features in the area and the high likelihood of more yet to be discovered (Areas of Archaeological Potential - AAP). Bogs can preserve archaeology for thousands of years – DGL assessments are too focused on current recorded assets, rely too heavily on visibility/ intervisibility. High resolution airborne LIDAR scanning is needed for entire site area and wider ASAI to know what is under the ground, if DGL were serious about identifying archaeology they would have declared the intention to conduct such surveys. Mr Haughey noted peat depth modelling could be linked to archaeological potential, predictive modelling could have been done, with trial pits dug in areas of high potential – walkover surveys may indicate buried features through land surface evidence. The area is extremely rich in archaeological features, 109 cairns locally. Peat should not be disturbed to facilitate a mining company, the FODC Local Development Plan (Policy HE01 Archaeology) reinforces the use of SPPS (2nd Edition 2025), Policy L01 – Development within the Sperrin Area of Outstanding Natural Beauty reinforces refusal of this application, as could Policy MIN01 - Minerals Development.
Third Party objector Mr Donnelly, wished to make an observation on the use of drill rigs from his lived experience at Cavanacaw, noting it was 20 years post planning approval and 3 drill rigs appeared last week under permitted development rights – surface drilling was unavoidable in his view.
Third Party objector Mr Donaghy, manager of An Creagan Visitor Centre, reinforced the importance of in-depth research, noting that he was aware of 2 new archaeological sites being discovered locally in the last month. The entire landscape of the Sperrins is an archaeological site, noting that he was involved with local tour guides who possessed an in-depth knowledge of archaeology in the area.
Mr Beattie (DGL) noted that there had been no rebuttal to DGL’s Peatland response from HED to infer acceptance. He noted that Beaghmore Stone circles were 10km away from mine infratstructure site, with a 10km radius never issued from HED at any stage prior previously, also asserting that the landscaping material submitted by the Applicant picked up photomontages & wireframes. Mr Beattie noted ICOMOS 2022 standards dealt with World Heritage Sites (WHS), not candidate WHS; with each section specific to WHS. Mr Beattie stated it was unclear how this proposal is going to impact on language & folklore. Mr Long (DGL) stated whilst a literature review would provide further information on the area, it does not change the wider impact of the proposed development on cultural heritage. Mr Long remained of the view that the Applicant’s Cultural Heritage Assessment (Appendix C15 – Nov 2017) was not out of date.
Mr McGonigle (Archaeologist for NIE) noted ICOMOS 2011guidance used in their original cultural heritage assessment, he considered the 2022 toolkit applicable to world heritage sites. Mr McGonigle noted that he has since reviewed texts Tyrone Folk Quest & Scéalta Mhuintir Luinigh and noted only two references to townlands Rousky & Teebane West. A third-party objector later challenged this, noting it was inaccurate.
Historic Environment Division (HED) were asked if they wished to make any further comment. Maybelline Gormley (Senior Archaeological Inspector) spoke to note that Mr Beattie had referenced no further comment had been made on Dr Jill Plunkett’s report for the Applicant, this was incorrect as HED had provided a Statement of Case 18/11/24 and submitted a specialist report by Dr Ellen O’Caroll (peatland archaeology specialist) on 11/04/25.
Dr Strecker (SOS) challenged Mr Beattie on his assertion that ICOMOS (2022) was applicable only to WHS, noting that world heritage conventions were not his area of expertise. These standards are not just taught in UCD, but as taught on MSc programmes around the world as best practice standards and should be applied to archaeologically sensitive sites. She noted ICOMOS Ireland & ICOMOS UK Committees would recommend this approach, which is established in world heritage practice & context.
Mr McAleenan (HED) noted that their SoC submission followed the HED Guidance document on Setting and the Historic Environment (Feb 2018), with ICOMOS used to inform best practice.
Mr Fegan (FODC Counsel) noted that Page 12 of this HED document referenced the 2011 ICOMOS document Guidance on Heritage Impact Assessments for Cultural World Heritage Properties, which ‘while focussing on World Heritage Sites, contains useful guidance on assessment methodologies which may be applied to any heritage asset’.
Commissioner Donaghy noted the Applicant had failed to address intangible cultural heritage, posing the question who scrutinises the impacts on Intangible cultural heritage?
Commissioner Donaghy asked Mr Long (DGL) to comment on Applications impact on sense of place, identity, cultural continuity & people’s relationship with landscape.
Mr Long didn’t answer directly, choosing to speak about historic monuments and DGL’s public consultation process.
Mr McGonigle stated their assessment considered cultural heritage and intangible heritage. Folklore is there for posterity and can’t be erased or removed.
HED asked same question: Are sense of place, identity, cultural continuity & people’s relationship with landscape adequately assessed within scope of Environmental Statement. Mr McAleenan noted that the settings impact would warrant further investigation here. The impact on language & wider folklore, not really in remit of HED. We assess proposals under archaeological policy requirements; impact on recorded archaeological sites & settings; sense of place should be taken into account in decision making & how ambience contributes to its experience & settings. Intangibles should be assessed & ASAI. These are not considered in a wider landscape sense, HED’s role is liited to recorded sites & ASAI (Areas of Significant Archaeological Interest). This is not something we usually comment on.
Mr Fegan (FODC Counsel) noted the need to be careful about advice just given by HED. One can see HED remit focused on a particular asset & impact on setting. Sense of place outsider their scope of impact assessment. FODC position is that sense of space is a material consideration, with a broad definition given to this in case law. There is ample evidence from others on the impact the proposed mine will have on sense of place – which clearly needs to be weighed in the Planning balance. The matter came up in Dorville inquiry, where the commissioner agreed sense of place is consideration. We would caution against any approach that sought to minimise or remove this.
Mr Elvin (DfI) noted HED Guidance Page 11 acknowledged there are wider issues to landscape character that do need to be considered.
Mr C McAleer (SOS) noted this isn’t a standard application, it is unprecedented as is the level of opposition from the community. When we think of landscape within the Sperrins, we think of a wide area, what happens in one area affects the rest. Rich archaeology in the area and the fact that there significant monuments only still being discovered. He noted Cashel Hill could be threatened by this project through unspecified drilling & tunnelling, impact on underground hydrology unknown. Cultural significance & connection of people to the monuments. Concerns continue to be undermined, explained away, marginalised by the Applicant.
Dr MacGabhann (SOS) noted the lack of reference to the value of memory, referencing connection between landscape and memory – referencing historian Simon Schama 1996 ‘Landscape + Memory’. He quoted from Monsignor Brendan Ó Doibhlin – native of Rousky – outstanding Irish & French scholar who wrote of the importance of the landscape to the people of the area.
Dr Strecker (SOS) noted that Gahan & Long’s cultural heritage strategy / engagement strategy contained a lot of misunderstanding & context missed: highlighting how promotional material is being classified incorrectly as engagement. There has been a longstanding conflation on engagement, consultation & promotional activities. Funding, tunnel tours, jobs does not constitute consultation. Citing DGL’s 2024 Responsible Business Report, P.24 Community perspectives on project – 5 quotes included, taken from SoC’s in support of application. These are from Gerry Kelly, Chair, Silent Majority Group; Joe Rice, retired engineer, Tara mine; Pearse Bradley, Geo-technican DGL; Alan Dolan, President, IMQS (Irish Mining & Quarrying Society) and Steven Kelly, CEO, Manufacturing NI. These people are not the community and the views expressed are in no way reflective of the local community who are overwhelming opposed to this application. The same report notes under SASB Standards (Page 63) ‘The engagement processes referred to relate to human rights as provisions relating to indigenous people and areas of conflict do not apply, Human rights do not apply’.
Communication through tunnel tours & Facebook does not constitute consultation, 2 information sessions held in 2016 on the applicant’s infrastructure site rather than a public venue, do not constitute consultation. We need to be really clear this is not community consultation, it does not meet the minimum standards of what consultation is.
Dr Cirefice spoke on the extensive ethnographic research she had conducted in the local area, noting that the mine application has contribute to a sense of solastalgia throughout the community, noting the narrow understanding of the issue in DGL’s Transboundary submission documentation. It is a feeling of deep helplessness around major projects, especially when communities feel they have been excluded in the decision making process. She outlined how intangible cultural heritage became the main focus of her research, noting this was intergenerational, sensory, emotive, embodied language, folklore, memories, archaeology, placenames and connection to the more than human & natural world (spiritual). She explored the relationship between people and the land, more than seeing it as an object, documenting stories, hosting events & visits from international communities. Cultural Heritage connects people with place, it is felt, sensed & heard. You have to understand how cultural assets are experienced and which can only be done through speaking to the people affected.
Another third party objector, Mr Haughey reiterated the 2016 information event could not be considered consultation. This was announced after the introduction of cyanide into the process, prior to its subsequent withdrawal. The barometer here is 50,000 objections to this proposal. DGL has not understood the sense of place attributed to this place. It is about relationships, people, townlands, religion, archaeology, farming, walking, oral history & family community. The remoteness, the darkness, the access, the silence, our dignity, cultural association, being part of an unindustrialised upland landscape. You go to the mountain to breathe in fresh air, go to the river knowing the fish in it are healthy. This is our sense of place & is what it has been for 1000’s of years. The mine proposal, infrastructure & dry stack/ waste rock store threaten this irreversibly. Lighting, dust, traffic, waste, HGVs, industrial business will change this place forever.
Mr Haughey noted the work of the Sperrins Partnership, documenting oral traditions and the development of a long overdue management plan for the Sperrins, based on retaining the Sperrins as a natural resource, as opposed to changing the area into an industrial landscape.
Mr Haughey noted An Creagan Visitor Centre was built in 1994 in the Sperrin’s AONB, tourism created around that sense of place, people come here for the tranquility. The sense of place has not been assessed.
SPPS (2nd edition) requires proper protection of archaeology, L01 in FODC LDP notes developments that adversely affect or erode special character will not be permitted – this is all sense of place.
Emma McAleer speaking from the gallery queried ‘who from DfC should be in this room to help the community defend intangible cultural heritage?’ She quoted a UNESCO definition for the subject: ‘Cultural heritage does not end at monuments and collections of objects. It also includes traditions or living expressions inherited from our ancestors and passed on to our descendants, such as oral traditions, performing arts, social practices, rituals, festive events, knowledge and practices concerning nature and the universe or the knowledge and skills to produce traditional crafts’.
She noted that funding can be a barrier to local communities protecting heritage, if this project goes ahead, a community facing a toxic mining application would be seen as high risk by funders and any publicly allocated funds would then go towards environmental monitoring, remediation & mitigation, rather than protecting and celebrating the cultural heritage of a rural community. UK & Ireland (including NI) are now developing living heritage inventories to preserve information on intangible cultural heritage. She concluded with, ‘Please consider what the community is saying here today’.
Mr Elvin (DfI) later noted that there isn’t a specific consultation body within the department for these matters. Referencing the SPPS, he stated ‘there isn’t a specific consultee that deals with this, it is accepted as a material consideration by the Department’.
Sinéad Ní Mhearnóg (Warnock) noted a simple example of this mine proposal on local folkflore – 10years ago if you typed Curraghinalt into a google search engine you would have been met with stories on Paddy Laidir Mc Cullagh, Scéalta Mhuintir Luinigh and the promotion of folklore & language led by the community, now all you get is references to Dalradian and this mining project. Language initiatives & cultural initiatives are all community driven, these wouldn’t come about if the work wasn’t done on the ground. She finished with a reference left by a visitor to the area in one of the local hospitality businesses, Pat Larry’s cottage, which read: ‘Some places are visited, some places are felt.’
SOS solicitor Mrs Brolly noted that community cohesion has been adversely affected by this application and can only be seen to get worse.
Mr Beattie (DGL) did not agree with the view of HED that the scope of the cultural heritage assessment was narrow as to how it was set out, and sought to align the applicant’s view more with FODC & DfI. Mr Beattie noted visual impact assessment at Cashel Rock was considered by Applicant, noting DGL SoC TR15 Cultural Heritage Section 4.2 Page 4. Mr Beattie drew Commissioners attention to TBR Appendix 6, Annex 2 on comparisons with Dorville and how context is different in the applicant’s view. Mr Beattie contended on behalf of DGL that the sense of community will persist with or without the proposed development.
Mr Buroni was then invited on behalf of DGL to talk about health impact assessments and solastalgia. He referred to Solastalgia as more than environmental grief, it was the erosion of sense of place, unwanted change, but that this was complex, varied at individual level & at stage of life. Mr Buroni considered this a response to dramatic & rapid environmental change linked to mines, windfarms & tourism. He went on to note the perception of change may be unfounded and heavy industrialisation may not be what is proposed here – a statement clearly outside his specialism.
Mr Buroni continued when you look at intangible aspects, concerns are linked to tangible and perceived intangible factors, perceived danger, if people are not involved in the decision making process – of which the inquiry was now playing its part. He then stated all tangibles & intangibles are already addressed, there would be no change in demography and repeated all aspects already addressed, the challenge was drawing them together.
Commissioner Donaghy directed that the inquiry would break for lunch at this point, with third party supporters to be given the opportunity to speak on resumption at 2pm, with third party objectors to be heard following this, noting many hands rising following Mr Buroni’s comments.
Mr McAvoy (Counsel for DGL supporters Silent Majority Group) introduced a local supporter Monica Coyle who wished to speak. She stated that she was born in 1945, had lived in the area in the townlands of Aughnascribba & Sheskinshule her whole life, had lived through periods of change and did not see how the mine would change the sense of place, in her view Greencastle will always be Greencastle.
Dr Cirefice noted through her research project she had documented the already felt Solastalgia and considered the issue central to the assessment of intangible culture heritage. She wished to have more clarity on the research assumptions used to inform Mr Buroni’s desktop analysis. Her research has already documented feelings of solastagia at this exploration stage around environmental change but also around the feelings of distrust towards state bodies and powerlessness around the decison making process. A Key recommendation from Solastagia literature is to: Increase participation of local communities in decision-making related to new infrastructure or development projects, resource management, restoration efforts, as well as when designing adaptation strategies
Another third party objector Mr Tracey drew comparisons with mining operations in Australia & South America and did not accept this mining proposal & monstrous waste dump would not have adverse effects on the community. He queried how Mr Buroni could conclude there would be no change to the area when considering the noise, dust, HGV increase the mine application would bring if permitted. He noted that there was extensive research to show a decline in social relations in areas that are mined, particularly where this was contested from the outset.
Multiple third parties challenged Mr Buroni’s submissions as so far removed from reality, it was meaningless. Such baseless sweeping assumptions if made by third parties would rightly be challenged by Commissioners, with one objector commenting if they were to make a statement citing health concerns that young children living in the area could develop rare cancers from proximity to this site, this would be more easily justified through worldwide examples of mining consequences than the stance presented of there’s nothing to see here.
Third party objector Mrs Byrne (SOS) noted how the people most affected by this application are the third parties, rather than the consultants brought in to help sell this application. She stated ‘I will be buried here, this is my life. I see don’t look at the Sperrins AONB as an opportunity to exploit resources. I see life, the creatures that crawl across the sphagnum moss. The Sperrins are me & I am the Sperrins. If industrial level development is permitted, it will leave the area decimated. This ancient area is unspoiled, there are structures here that predate the pyramids in Giza.
Third party objector Mr Haughey called Mr Buroni’s comments as grossly insensitive to the people of this area. Concerns will be covered in technical issues later on – that in itself shows no consideration for the people of this area. He challenged the commentary that the issues of concern are dependent on a person’s age alongside the coment that heavy industry is not what is being proposed. What planet is Mr Buroni living on – this is exactly what is proposed. A mining operation running 24/7, 365 days a year, with high levels of HGV use and Police support due to daily explosives. The third parties approach is that this should not be here. DGL representatives are coming at it from, this is coming here, this is what you have to deal with – mitigation, mitigation, mitigation, condition, condition, condition, fund, fund, fund. This is a massive industrial proposal with DGL having prospecting licenses across 122,000 ha of counties Tyrone & Derry. The suggestion that discussing it here today will remedy it, as some form of therapy for local people is outrageous. It is tragic what is happening, narrative is being framed like we are accepting this.
Emma Mc Aleer noted built heritage, natural heritage & cultural heritage all need to be taken into account. The landscape itself shaped culture, culture in turn, names & shapes landscape – in the Sperrins, the two are inseparable.
Sinéad Ní Mhearnóg talked about the ‘pull of home’ noting as an example Gerard Hollywood, who has returned from Australia with his wife and young children to build a home in Greencastle in close proximity to the proposed mine site. There is a palpable sense of place to the people of this area, this application threatens to disrupt our sense of place & spirit of home if permitted. All of us in Greencastle, Alworries, Currgahinalt, Coneyglen are extremely concerned, clearly there is an impact.
Dr Gordon (DGL) noted that the Pre-Application Community Consultation met requirements & was tested in the courts. Dr Strecker (SOS) tried to raise a point on archaeological assets in Beaghmore/ ASAI, but was not allowed to contribute again.
Mr Long (DGL) expressed surprise that HED consider scope of assessment not wide enough. He reiterated Mr Beattie’s point that Beaghmore Stone circles are included which are 10km from infrastructure site. Mr Long noted he was involved in a 2010 consultation for a gravel pit near the Beaghmore Stone Circles (I/2010/0086/F) which was granted planning permission May 2011; and a windfarm application 2.5km east of stone circles (I/2014/0413/F).
Mr Long advised that on behalf of DGL he consulted with statutory bodies on ASAI’s in July 2017, identifying views to surrounding land forms & skylines. Pre-historic, neolithic & bronze age monuments found in the area, with their significance enhanced by their relationship with each other, topography, route ways & skylines. Three main clusters or bands of monuments currently exist within ASAI: (1) North from Beaghmore Stone Circles – band on a north-south axis extending to east side of Kerrin Rd, (2) Cluster in Owenkillew Valley (basis for Mhuintir Luinigh), and (3) extending west, no monuments which overlap with mine site.
Mr Long noted that the ASAI overlaps with subterranean mine site, the boundary between the two along site fenceline, at boundary of Crockanboy, Teebane West & Monanameal townlands – the boundary follows ridgeline of Crockanboy hill. In his view, which is at odds to that held by third parties, the subterranean element cannot alter the ASAI, and mine infrastructure cannot impact on ASAI but has potential to impact on setting.
Mr Long continued to repeat the content of his written submissions, Beaghmore ASAI established through desktop & field survey considering surrounding views/ horizons of landscape, these widely encompass settings for stone circles. He argued the mine site doesn’t have any impact physically on Beaghmore ASAI, noting setting of ASAI considered through 3 methods: (1) viewpoints within ASAI, (2) monuments within ASAI – principally those within 3km of site and (3) historic landscape of Owenkillew Valley (considered in RR15).
ASAI viewpoints marked on map by Mid Ulster District Council (Figure 1, Appendix 3, Critical Viewpoints, Rebuttal submission) noted 5 critical viewpoints. Applicant put forward that the mine infrastructure site would not be visible in views 1, 3, 4 & 5, with no impact on setting. Mr Long noted Kerrin road considered one of the most scenic driving & walking routes in locality, and ‘dry stack facility’ (mine waste) potentially visible from viewpoint 2. However considered this to not intrude significantly to compete in landscape across ASAI; and contended the infrastructure site would not be visible at inter-related views to landscape within ASAI.
Mr Long then moved to discuss content of his rebuttal submission (RR15 – Cultural Heritage) drawing the Commissioners attention to his challenge to the document/findings of Dr Paul Logue & Déaglán Ó Doibhlin, Pages 6-8 of same and Figure 7 on Page 31 showing the location of mine infrastructure site in relation to archaeological monuments and points of interest as identified by Logue and Ó Doibhlin.
Dr Gordon (DGL) talked about the importance of the Crockanboy Hill ridgeline being recognised in the Applicant’s Design & Access statement and trying to place buildings within existing trees, referencing a LUC drawing (LUC 6335 LP PLN 001 Rev H) which showed trees to be retained to the north of the site relative to the ridgeline.
Mr McGonigle (NIE) invited to comment on Powerline relationship to ASAI- noted the closest pole set is located over 2.5km away to west of stone circles & closest pole set to Dun Rhuadh (TYR 019:004) 5.4km away. Mr McGonigle noted the proposed powerline will not impact on primary views of Dun Rhuadh & associated monuments & stone circles.
HED invited to comment – Mr McAleenan noted that ‘impact has not been clearly demonstrated to date’ adding ‘impact on character of ASAI not clearly demonstrated’. Mr McAleenan added that the ASAI Development Plan updated in 2023, with Beaghmore ASAI recognised as being of regional significance. ASAI substantial expansion of previous designation – which is a statement of significance in this case. Designation encompassed multiple sites, enhanced by inter-relationships & connections to historic routeways. Further evidence is required, to date this has not been adequately addressed. This should incorporate key viewpoints and wireframes; assessment & analysis should be accompanied by understanding of historical information. Mr McAleenan noted that the Applicant (DGL) referred to rebuttal reports & accompanied 3D modelling, HED have reviewed this information but is not clear what 3D modelling is demonstrating by way of impact – HED seek clarity on what 3D modelling is showing.
Commissioner Donaghy asked does HED agree with ambit of views?
Mr McAleenan repeated that photomontages or wireframes from key monuments including Beaghmore Stone Circles were required, with accompanying detail/ descriptions of these. This is key to how the ASAI is understood.
Third parties were then allowed to comment. Mr Tracey raised the Battle of Formil and differing views on where the battle site was, considering local knowledge and topography of 3 mountain ranges & two valleys. References to this battle within Annals of Four Masters/ Annals of Ulster ‘proud were our people when we fought at Formil’.
Dr Strecker (SOS) then advised Commissioners she wished to make an oral statement on behalf of Gabriel Cooney, Emeritus Professor of Celtic Archaeology, UCD School of Archaeology. She was met with fierce objections & multiple interruptions by the Commissioners on the timing & content of this submission, despite explaining that Professor Cooney had hoped to be present on behalf of SOS an expert witness, but could not on health grounds and his comments related to issues raised in the Transboundary submissions which third parties had not yet been given the opportunity to respond to either in writing or orally.
“To whom it may concern,
I am providing this statement to the Public Local Inquiry into the proposed Dalradian Curraghinalt Project with regard to the potential impact of this proposed project on the Beaghmore Area of Significant Archaeological Interest (ASAI).
I am an Expert Member of the International Committee on Archaeological Heritage Management (ICAHM) of the International Council on Monuments and Sites (ICOMOS). I sat on the World Heritage Panel of ICOMOS 2018-2022 assessing candidate World Heritage Properties. On behalf of ICOMOS I have carried out Technical Reviews of Historic Impact Assessments (HIAs) of potential impacts on World Heritage and other historic properties.
I should disclose that I was chairperson of the Historic Monuments Advisory Council (HMC), a statutory advisory body to the Department for Communities, Historic Environment Division (HED), when the Beaghmore ASAI was extended. The Historic Monuments Council supported this extension and wrote to Fermanagh and Omagh District Council (FODC) in July 2017 expressing its support for the extension and the inclusion of the extended Beaghmore ASAI, along with the Creggandevesky ASAI, in the Fermanagh and Omagh District Council Local Development Plan. This was in line with the guidance in the Strategic Planning Policy Statement (6.29) that District Councils are required to protect already designated ASAIs and to consider as appropriate the designation of further ASAIs. It is important to note that the Strategic Planning Policy Statement further outlines that HMC is to be consulted on the designation of ASAIs.
I wish to make reference here to the Technical Report (TR15) on Cultural Heritage and Reponse (TBR15) (Gahan and Long) and the Rebuttal Statement (Turley), with specific reference to the section on Cultural Heritage, submitted as part of the ongoing public local inquiry into Minerals Planning Application LA 10/2017/1249/F I PAC Ref: C005.
The focus of TR15 is on the area of the infrastructure component of the proposed development. There is some consideration of the potential impact on the setting of regionally important monuments identified with a 3km radius of the infrastructure component of the proposed development and on the potential impact on the setting of the Beaghmore Stone Circles within the Beaghmore ASAI.
However, there appear to be significant shortcomings with the approach taken. Firstly, TR15 seems to have been conducted with knowledge of the initial ICOMOS guidance on HIAs for Cultural Heritage Properties (2011). The applicant notes in TBR15 that the ES chapter methodology sets out a methodology that is comparable to standards established in the ICOMOS 2011 and 2022 guidance, referencing Table 4 of the document which sets out the definitions for severity of change using terminology similar to that contained within paragraph 5.7 of ICOMOS 2011, and referencing Table 5, which forms a significance of effects matrix based on the table set out on pages 9 and 10 of the ICOMOS 2011 document. However, there appears to be no reference to the expanded and more detailed methodology contained in Guidance and Toolkit for Impact Asssessment published by UNESCO, ICCROM, ICOMOS and IUCN in 2022.
Secondly, no detailed consideration is given to the fact that the boundary of the ASAI now directly abuts the edge of the proposed infrastructure area which includes a mine waste storage facility that would be in excess of 50 metres in height. This clearly would have a potential significant impact on the ASAI, but this is not addressed or assessed.
Thirdly, the 2022 Guidance and Toolkit for Impact Assessment specifically mentions (p.33) the International Council on Mining and Minerals ‘No-go’ commitment not to explore for oil, gas or minerals in World Heritage Properties and to ensure operations adjacent to properties are not incompatible with the Outstanding Universal Value of the property. Beaghmore ASAI is not a World Heritage Property, but the consultants who undertook the assessment for the powerlines (RPS) have quite rightly applied a HIA process used for World Heritage and other cultural heritage properties. Its designation as an ASAI recognises that it is a heritage landscape area of regional/national importance and the Statement of Significance for this ASAI recognises its sensitivity to change from large scale development, including mining.
Against this background I consider the discussion and assessment of the potential impact of the proposed development on the Beaghmore ASAI as somewhat limited and inadequate.
Section 3.34 to 3.42 of the Rebuttal Statement deals with the Historic Environment. By contrast with TR15 this focuses on the potential impact of the proposed development on the Beaghmore ASAI. In 3.37 it should be noted that the Rebuttal Statement appears to agree with the characterisation of the ASAI landscape as particularly sensitive to change. However, the Rebuttal Statement is clearly incorrect in stating that the ASAI is beyond the ridge to the north of the surface infrastructure site. Figure 6 in TR15 clearly shows that the edge of the proposed infrastructure site directly abuts the boundary of the ASAI. This means that the statement in 3.42 that the project will not adversely affect the Beaghmore ASAI has not been demonstrated.
I have restricted my comments here to the assessment of the potential impact of the proposed infrastructure component of the proposed development. Clearly the underground element of the proposed development is much larger and extends into the Beaghmore ASAI. There are a range of potentally serious, ongoing and detrimental impacts arising from the proposed development. However, assessment of these are not within my professional remit.
In conclusion I would agree with the consideration of the Fermanagh and Omagh District Council that the proposal is contrary to Policy HE01 of the Local Development-Plan Strategy and paragraph 6.8 of the Strategic Planning Policy Statement as it would adversely affect the Beaghmore Area of Significant Archaeological Interest.
Yours sincerely
Gabriel Cooney, Emeritus Professor of Celtic Archaeology,
UCD School of Archaeology”
Third party objector Sean Clarke, spoke next from the audience, referencing a book ‘Sites of Prehistoric Life in Northern Ireland by Harry Welsh’, quoting from page4, there are 59 individual monuments in Broughderg, 28 burial cairns, suggesting the presence of an extensive sacred area. Over 4-5000 years, tens of thousands of humans were interred here and over 50% of the area is covered in blanket bog. In the last two years, 18 additional sites discovered in Broughderg, over the whole area, he estimated this to be about 50. He then referenced speaking with David Gavaghan 27/04/26 (CE of Titanic Quarter, when this was being developed) who referred to Beaghmore as the iconic landscape unique on this island, as the future of tourism. It is a high valley, approximately 600ft above sea level, with the earliest farmers in Ireland; noting that Dun Rhuadh is the most important site of its type in Europe. Green Road believed to be 1500 years old.
Emma Mc Cullagh (Mid-Ulster District Council) also spoke from the gallery, wishing to clarify a comment by Mr Long on 5 viewpoints within ASAI. The Council did not consider these to be static viewpoints, but transient viewpoints with protected views along routes between these, asking that this impact be considered by the Commission.
Third party objector Mr Haughey spoke of his personal connection to the Beaghmore Stone Circle site, owned by his grandmother, then his parents. He now owns the adjacent farm, with the land vested in the 1980s. He recalled Dr Claire Foley (Archaeologist) describing the stone circles as just the tip of the iceberg in terms of what exists there. The historic position has always been that the safest way to preserve monuments is to leave them in the ground.
He noted there are 129 stone circles in the Sperrins region, highlighting the vast scale of known archaeology. Mr Haughey queried why DGL were repeatedly allowed to return to visual and landscape matters without challenge when these issues are to be discussed elsewhere in the Inquiry. He also questioned why Gahan & Long did not examine archaeological features between the mine infrastructure site (or 2km radius) and Beaghmore, 10km away, citing the historically significant 'C**k of the North' area as an example.
Mr Haughey noted that he can see the GAA club floodlights from his farmland beside the stone circles and therefore would also see lighting from the mine infrastructure site.
Third party objector, Mr S Tracey noted that a bronze age burial cairn was discovered this year in the Murrins Area of Special Scientific Interest, near Omagh, with photographs published in local newspapers in February / March – with the Application site clearly visible in the background of the photograph. This development will have an impact on nearby archaeological sites.
Fidelma O’Kane (SOS) noted that DGL’s evidence is based on ground water predictions which are unproven. Mining will alter the water table and impact on hydrology below ground, it is reasonable to assume this will adversely affect sub-surface archaeology, known & unknown. DGL mitigation measures are untested & may fail.
Mr Fegan (Counsel for FODC) noted that FODC put forward a draft reason for refusal in their SoC based on LDP HE01 – Archaeology, linked to maintaining the integrity of settings & reference to viewpoints; noting this concern was shared with MUDC & third parties.
FODC’s position is we don’t think either of the exceptions on HE01 are engaged. ASAI’s are particularly distinctive historic landscapes. Paragraph 5.8 notes ‘Generally, it is unlikely that ASAIs will be able to accommodate large scale development such as quarrying or mining operations, … waste disposal … as it is likely that the overall impact of such proposals could be particularly damaging’. Mr Fegan noted that DGL had objected to extension of ASAI during process. FODC took advice, consulted with historic monuments council, statement of significance produced of relevance to your assessment. ASAI takes surrounding horizons of landscape into account, stone circles & alignment considerations. The surrounding landscape shaped by farming is characterised by open vistas, distinct absence of industrial developments/ large scale development. The area is sensitive to change, which would adversely affect landscape character, contribution it makes to setting, experience – Mr Fegan noted the statement of significance goes further than ASAI test. Extensive consultation undertaken with HED, viewshed analysis, mapped out area /envelope in terms of views, & extensions of view, tested and examined these during local development. FODC considers this a breach of HE01 Policy & relevant exceptions not met.
Mr Beattie (DGL) advised that HED comments were previously picked up in the Applicant’s DfI Rebuttal 18/11/24 (Pages 169-170 referenced for 4-5 short paragraphs). Mr Beattie noted impacts raised by FODC + MUDC, whilst also noting Turley’s SoC which seeks to address issues in context of ASAI. HED consider insufficient information to allow full assessment, but don’t provide a list of outstanding items. Mr Beattie continued ‘I’m not sure if I am better informed or any wiser in what they want to be assessed or why. I don’t find HED’s intervention particularly informative.’ He responded to Professor Clooney’s oral statement on TBR 15, again expressing the view that ICOMOS (2022) is exclusively for World Heritage Sites and invited the Commissioners to apply their own judgement on this.
Dr Gordon (DGL) noted a viewshed analysis was contained within DGL’s Main Mine Rebuttal submission (RR13 Landscape, LUC Figure 1, Page 117), which shows where the mine waste facility (Dry Stack)/ infrastructure can be seen from.
He also referenced Appendix C16_2nd Addendum (2020) to the LVIA & Visualisations Appendix 1and viewpoints from Stone Circles pages 94-100. Dr Gordon contended that this night time visual from carpark at stone circles focused on sky glow, and the conclusion from Miss Oxley (LUC) was no significant impact at that point.
Dr Gordon also referenced LUC analysis within DGL SoC submission TR 13 Landscape & Visual (paragraphs 211 – 217, Pages 73-79). Noting that a screenshot showed low levels of visibility of plant roof & 3D model of development located below ridge (Crockanboy Hill).
Mr Long (DGL) challenged FODC’s response to HE01as containing no analysis of Beaghmore ASAI viewpoints and provided a planning reference for an extension to a gravel quarry within the ASAI granted in July 2002 as justification of existing industrialisation (I/2001/0023/F). Mr Long noted that monuments within Owenreagh Valley were not assessed unless they fell within 3km of infrastructure site radius. This was in response to third party assertions that the Owenreagh Valley would arguably be more impacted by the mining project than the Owenkillew Valley.
A third party objector Niall McAleer, wished to challenge the repeated references that the retention of small areas of existing trees would screen buildings at the infrastructure site, noting that the processing building alone spanned 100metres in length, with 25m ridge height which would dwarf any existing vegetation. He also objected to the deliberate conflation between quarrying & mining, which are in no way comparable, to make this toxic application more palatable.
Mr Haughey challenged the Applicant’s response to HED, which tried to offer the defence they didn’t tell us, so we didn’t do it. The Applicant knew this was an issue.
There was no update on timetable for the remainder of the Public Inquiry and no indication of when this will be made available. Proceedings were then closed for the day.
