We have been instructed by Michael Collins, Philip David, Declan Foley, Catherine Lowther, Petra Muths, Michael O'Callaghan, Roderic O'Connor, Searles O'Dubhain, and Victor Reijs, to appeal the decision of Sligo County Council on 11 July 2002 to grant permission to the Department of Arts, Heritage, Gaeltacht and the Islands (Dúchas / the Heritage Service).
This Proposed Development materially contravenes the Sligo County Development Plan. The Sligo County Development Plan was upheld by Chief Justice McCarthy in the case McGarry and Others v. Sligo County Council, and there has been no amendment to the plan concerning this site since.
The site is unsuitable for septic tank sewage disposal as it is of high precocity.
The proposed development will interfere with an archaeological site of international importance.
BACKGROUND OF THE CASE:
The Carrowmore National Monument complex is part of an extensive megalithic landscape situated close to Sligo town on the Cúil Irra peninsula between Carns Hill and Queen Maeve's cairn on the summit of Knocknarea celebrated in poetry by W.B. Yeats. Located in a spectacular setting overlooking Sligo Harbour and Ballisodare Bay, the complex is the largest cluster of megalithic sites in Ireland. It forms a 1km long x 600m wide oval-shaped cluster of megalithic monuments originally featuring approximately 60 sites (including chambered cairns, passage mounds, dolmens, standing stones, and stone circles). It is considered to be the largest concentration of such monuments in the world, one of the very earliest habitation and burial sites in Ireland, and one of the most important archaeological sites in the State.
The Carrowmore complex is also of extreme antiquity. Professor Göran Burenhult of Gotland University in Sweden, who has carried out extensive archaeological research at Carrowmore, has obtained radio-carbon dates of 5,400 BCE from samples found within the complex, placing Carrowmore well into the Mesolithic era, two millennia earlier than Newgrange in Co. Meath.
University of Galway archaeologist Dr. Stefan Bergh, (whose doctoral thesis on Carrowmore involved extensive surveys, morphological studies, and contextual spatial & landscape analyses of the area), has stated that Carrowmore was also one of the major ritual centres later on, during the Irish Neolithic period.
According to Dr. Bergh:
"The estimate of c. 60 sites is based on the accounts given by Petrie and Wood-Martin in the 19th century, which reflects the state of preservation at Carrowmore some 200 years ago (Bergh 1995). Our knowledge of the history of destruction and change at Carrowmore during the more than 5000 years prior to Petrie and Wood-Martins time is therefore very limited.
This lack of knowledge, together with the fact that the record of sites/features besides the existing and highly visible megalithic monuments is close to non-existent, underlines our limited understanding of the internal structure and context of Carrowmore. Even though some recent Geophysical surveys have been made with the aim to located destroyed megalithic monuments (Burenhult 1997; 1998), no systematic survey or excavation have been made to understand Carrowmore beyond the megaliths (see e.g. Burenhult 1984)."
The proposed development would involve the construction of the following items inside the boundary of this site which is protected under the National Monuments Act:
a sewerage treatment plant next to an existing car park;
a percolation area (measuring c. 30m x 15m, approximately 30m East of the present visitor centre) in a field where a number of monuments are located;
two different extensions of existing buildings at the Visitor Centre.
In his Pre-Development Test Excavation Report (License no. 01E0668, Planning Register no. 00 / 996, Archaeological complex SL014-209, Carrowmore td, Kilmacowen parish, Co. Sligo) dated November 2001, the archaeologist Dr. Bergh has pointed out that although:
GROUNDS OF THIS APPEAL
"No part of the development has any direct physical impact on earlier recorded monuments, the actual location of the Visitors Centre within the central part of the Carrowmore megalithic complex, means however that the whole area has a high archaeological potential regarding previously unrecorded archaeological features or remains."
"The long-term impact on the ritual landscape of Carrowmore, caused by the present location of the Visitors Centre and its future development, should be assessed."
[It has not been assessed.]
"Even though no archaeological monuments/features were known in the immediate vicinity of the planned development, the area has a high archaeological potential., as neither destroyed megalithic sites, nor non-megalithic structures or other prehistoric activity could be ruled out within this significant area of Carrowmore."
Professor Gabriel Cooney at the Department of Archaeology of University College Dublin considers the entire Carrowmore complex to be an integral part of Sligo's extensive megalithic landscape, like the Brú na Bóinne UNESCO World Heritage Site in Co. Meath (see page 163 in Cooney, Gabriel, Landscapes of Megalithic Ireland, Routledge, London, 2002. ISBN 0-415-16976-3). The Carrowmore complex is therefore best understood not a collection of individual monuments but as a complex system whose architectural design integrity, interconnecting sight lines and astronomical alignments function as an integrated whole. Damaging any part of such immensely ancient and important archaeological evidence in the name of tourist dollars it not acceptable.
The location of the proposed development is clearly within the core area of the Carrowmore complex, being situated approximately 50 meters inside its Northern perimeter as indicated on various survey maps including those made in the 19th century by George Petrie, and in the 20th century by Professor Göran Burenhult. As such, it deserves the same general protective measures including the appropriate conditions for planning permission recommended by Meath County Council on page 31, section 4.11.2 of the Brú na Bóinne Draft Management Plan published by the Department of Arts, Heritage, Gaeltcacht and the Islands in December 2001. These appropriate conditions include:
"a policy of refusing permission for new development within the core area of Brú na Bóinne apart from modest works such as small-scale extensions to existing domestic dwellings." [emphasis added]
University of Galway archaeologist Dr. Bergh believes the visitor centre lies within a ceremonial avenue ritually used to approach the 45 meter wide decorated cairn C51 known as Listoghil, which forms the central feature of the whole complex (see page 123 of Bergh, Stefan. Landscape of the Monuments: A Study of the Passage Tombs in the Cúil Irra Region, Co. Sligo, Ireland. Riksantikvarieämbetet, Stockholm, 1995. ISBN 91 7192 945 2).
A geophysical survey involving resistivity and magnetometry carried out in 1997 over a 100m x 20m area South of the Visitor Centre has revealed two circular shaped magnetic anomalies with a central feature less than 10 metres West of the proposed development, which match the layout and dimension of other stone circles and dolmens at Carrowmore (Burenhult 1997a, Fig. 2) and (Flynn, Leo. The Swedish Archaeological Excavations at Carrowmore, Co. Sligo, Ireland. Excavation Report 1997, Prospecting Supplement. University of Stockholm).
In his Pre-Development Test Excavation Report (opus cit.), Dr. Bergh observed that:
"These anomalies could indicate remains of destroyed monuments not recorded in previous accounts of Carrowmore. Even though no archaeological monuments/features were known in the immediate vicinity of the planned development, the area has a high archaeological potential., as neither destroyed megalithic sites, nor non-megalithic structures or other prehistoric activity could be ruled out within this significant area of Carrowmore."
Construction and excavation work so close to this area clearly poses a risk of destroying important archaeological evidence.
Although the Department of Arts, Heritage, Gaeltacht and the Islands appears to justify its development by claiming that test excavations at (and to the East of) the location of the proposed sewerage system revealed nothing of archaeological interest, these excavations did not include the circular region of magnetic anomalies described in paragraph 4 above.
Any construction at Carrowmore may well interfere with local geographical alignments between the monuments both within the Carrowmore complex and between it and other outlying monuments on the Cúil Irra peninsula and beyond in the surrounding extensive megalithic landscape. Dr. Bergh has established that these spatial aspects of siting, orientation, directed visibility, and intervisibility of the monuments form an extremely important feature of the Cúil Irra monuments (see Bergh, Landscape of the Monuments, page 119-121). The particular alignments in question include:
(a) lines of sight between monuments located within the Carrowmore complex (most of which converge on the central Listoghil cairn (C51) and
(b) approximately a dozen lines of sight from the Listoghil cairn and other monuments within the Carrowmore complex to inter-visible monuments in the surrounding megalithic landscape, including:
(i) the two cairns on Carns Hill to the East;
(ii) Queen Maeve's cairn (together with its satellite monuments) which are prominently visible on the nearby summit of Knocknarea to the West, and
(iii) various monuments at the Carrowkeel megalithic complex 18 miles away.
Altough the precise function and ritual meaning of these alignments is not fully understood, it is clear that they form an intentional and integral part of the Cúil Irra megalithic complex and should therefore never be blocked by intervening buildings.
The Heritage Council has recognised the need to protect the geographical alignments on the extensive megalithic landscape of the Cúil Irra peninsula (including Carrowmore) in its Submission to Sligo Co. Council on Telecommunications Tower at Cairns Hill, Co. Sligo, dated 29 May 1997, available online at www.iol.ie/~sec/Cairns%20Hill.html.)
The Heritage Council's submission stated that:
The proposed development would severely detract from the amenity of the megalithic tomb cemetery on Cairns Hill, and the archaeological landscape in which it is situated. The complex consists of 2 passage tombs, which form an extension of the great megalithic cemetery of Carrowmore / Knocknarea. The closest passage tomb is just 1700m away, close to the Garavogue River, in Abbey Quarter townland. The positioning of these monuments and the aspects of siting and intervisibility are an integral component of the archaeological landscape. Our knowledge of this complex of monuments is increasing and recent work carried out by Stefan Bergh (1995 Landscape of the Monuments: A Study of the Passage Tombs in the Cuil Irra Region, Co. Sligo Ireland. University of Stockholm) has highlighted the fact that an important aspect of the tombs on Carns Hill are their siting and their directed visibility. The Carns Hill West tomb (RMR 14:231) has directed visibility to the west into the central part of the Cúil Irra peninsula. The tomb in Carns Hill East (RMR 14:232) has directed visibility to the west and north-east. Any development which degraded this aspect of the tombs would not just have a localised affect on the Carns Hill site but would degrade the whole of the Cúil Irra passage tomb complex.
The positioning of the 36.5m high tower would alter the integrity of the landscape in this area and render it impossible for the public and specialist alike to fully appreciate the siting of the Cúil Irra passage tomb complex. The net result will be to degrade one of the most important heritage landscapes of the country. On the basis of the above the Heritage Council advises that Sligo Co. Council reject the application.
In view of the fact that Sligo County Council accepted The Heritage Council's comments and rejected that application, there seems to be one rule for the public and a different one for Dúchas. An Bord Pleanála should now reject the application for the proposed extension to the Visitors Centre because the latter would also damage the integrity of the megalithic landscape in this area, render it impossible to fully appreciate the siting of the monuments, and further degrade one of Ireland's most important heritage landscapes which has already lost over half of its megalithic monuments in recent centuries.
Furthermore, any new construction may also block the lines of sight of possible astronomical alignments which if confirmed to exist at Carrowmore would be amongst the earliest known evidence of astronomical practice in the world, and of immense interest to scholars investigating the history of science.
Although such astronomical alignments are the subject of academic research in universities abroad, they are not yet fully acknowledged and remain the subject of heated controversy in Irish archaeological circles. A growing body of evidence from anthropology, mythology, folklore, literature, art history, astronomy, and field observations in situ suggests that they constitute a deliberate design feature of many Irish megalithic complexes. The precautionary principle therefore suggests that, while the debate on this subject continues, no evidence of such aligments should ever be damaged in any way or blocked by intervening buildings (see www.astroarchaeology.org for details).
According to eyewitness reports, the chamber of the Listoghil cairn at the heart of the Carrowmore complex (which is adorned with petroglyphs similar to astronomically designed monuments in other parts of Ireland) may be oriented like Newgrange to the Winter Solstice sunrise. Because the astronomical aspect of the Carrowmore complex (and of Irish megalithic monuments in general) requires more research before it is fully understood, it is especially important to conserve the evidence, including sight lines.
Dúchas can not be trusted to guarantee this protection, because it has a track record of denying or downplaying the existence of astronomical design features in Irish megalithic sites. For example, it allowed the entrance to the Eastern passage of the central cairn at Knowth to be blocked with a slab of concrete in 2000, preventing the sun from entering that mound at dawn around the Spring Equinox, and causing over 1,100 people from 26 countries to sign an appeal to stop this kind of vandalism (see www.astroarchaeology.org/context/appeal.html for details). Furthermore, according to the Irish Times of 15 February 2000, Dúchas has also damaged the Listoghil cairn at Carrowmore when its so-called "restoration" work involved the following:
replacing the original cairn stones which surrounded the central chamber (removed during Burenhult's excavation to determine if the cairn contained a passage) with unsightly rectangular cube wire cage gabions filled with quarry stones;
this work was carried out by OPW without supervision by an archaeologist;
the vehicle used to transport the gabions from the road to the cairn dug ruts so deep that the 5000 BCE + strata were disturbed;
a pit was created around the chamber in such a way as to prevent the sun from reaching the surface of the chamber orthostats at sunrise on the Winter Solstice.
According to the above-mentioned Irish Times article,
"Dúchas has been forced to suspended reconstruction of a passage mound at Carrowmore, Co Sligo, following complaints that its heavy machinery could damage the site. A Dúchas spokesman confirmed that due to concerns raised work had been suspended 'pending an archaeological review of the operation.' (...) Dr Stefan Bergh, a Swedish archaeologist who completed his doctoral thesis on Carrowmore, visited the site yesterday and said he was horrified at the way the ground had been dug up by the movement of machines. 'I, as an archaeologist, would have to apply for about 10 licences to do tracks like that,' Dr. Bergh said. 'If you decide to reconstruct a monument of this scale there should be a definite plan and archaeologists should be present to ensure no damage is done. Neither of these two things have been done in this case,' Dr. Bergh said. The rectangular chamber of the cairn is still intact, but because of the way Dúchas has done the reconstruction it is now deep in a pit surrounded by gabions [i.e. wire baskets] of stones similar to those used in embankments. This takes greatly from the impact of the chamber, he said. 'This chamber looked great from the ground and there was important art-work on the stones, but now people will not be able to see it from that view.' Dúchas said because of heavy rainfall the machines had caused ruts along the route to the tomb. The sides of the tomb had been supported by stone gabions and was 'in accordance with standard practice'".
In his Pre-Development Test Excavation Report (License no. 01E0668, Planning Register no. 00 / 996, Archaeological complex SL014-209, Carrowmore td, Kilmacowen parish, Co. Sligo) dated November 2001, Dr. Bergh states the following:
"The aim of the test excavation... was to determine whether any archaeological remains were going to be affected by the planned development. The test excavations have not revealed the existence of any archaeological remains in situ within the area planned for development. The existence of some pieces of worked chert in the lower part of the topsoil/upper part of the underlaying clay, indicates that Neolithic activity was present in the general area, but the frequency is too low to indicate that any substantial activity has been present within the area now planned for development. So, no archaeological remains will be physically affected by the planned development.
In a broader perspective it is however critical to draw attention to the fact that the planned development is located in the central part of Carrowmore, and thereby also well within the defined area of the Archaeological Complex SL014-209. In this respect all developments at the Visitors Centre are affecting the archaeological landscape of Carrowmore.
The megalithic complex of Carrowmore is the very centre in one of the most important ritual landscapes in Neolithic Ireland, including the Cúil Irra peninsula and its hinterland. This is therefore an extremely sensitive and important place for the understanding of how these landscapes were constructed and conceived, not only in Ireland but in a general West European context. The importance of the very complex interplay between monuments, people and the physical landscape has started to emerge due to recent excavations and research.
In this light any kind of development within the defined space that constitutes the ritual landscape of Carrowmore, is highly unsatisfactory. In a long term perspective the present location of the Visitors Centre will greatly restrict any future development to meet the increased number of visitors to Carrowmore. [emphasis added]
From an archaeological point of view the best long-term solution for the Visitors Centre would be to relocate it to the existing quarry located c. 150 west of the present Visitors Centre. This is a far less sensitive location which does not intrude to the same extent on the landscape of Carrowmore, and would make future needs for expansion possible as no archaeological features would be affected within the already quarried area."
I would like to draw your attention to a conflict of interest which may arise should you seek further comment on any of the points raised in this appeal. Section 3 (b) of the Schedule of Conditions (P744 / 02, PL 00 / 996) attached to the Notice of Decision to grant permission states:
"Should archaeological material be found during the course of monitoring, the archaeologist may have work on the site stopped, pending a decision as to how best to deal with the archaeology (preservation in situ, or excavation). The Planning Authority shall be advised by Dúchas / The Heritage Service, with regard to these matters."
The conflict of interest lies in the fact that the advisory body, Dúchas, is a subsidiary of the Department of Arts, Heritage, Gaeltacht and the Islands, which is the body requesting planning permission. As Mr. Victor Reijs pointed out in his letter of 16 February 2001 to Sligo County Council, "The fox is guarding the hen-house!" Any further comment on this appeal should therefore be obtained from a qualified independent third party with no financial or institutional ties to either Dúchas / The Heritage Service or to the Department of Arts, Heritage, Gaeltacht and the Islands.
If a larger visitor centre is really needed to accomodate the present number of visitors, the existing one should be moved from its current location in the old cottage within the core area to a more appropriate location that does not risk damaging or interfering with any of the features of this extensive megalithic landscape, and which is acceptable to the local community stakeholders.
We refer you the decisions of the Board in the cases of the Luggala and Burren appeals.
Dr. Bergh's recommendation to relocate the Visitor Centre to the existing quarry west of the Visitors Centre seems like a possible solution, since building at this location would not destroy any archaeological evidence, and it also provides the option of further enlargement should this be required at some future date. Dr. Bergh has stated that a far better location would be the large quarry east of the monument C26. A location outside the core area would be ideal.
This Proposed Development should be refused permission because it is a requirement of the County Development Plan to preserve the integrity of this site. This Proposed Development will damage the integrity of the megalithic landscape in this area, render it impossible to fully appreciate the siting of the monuments, and further degrade one of Ireland's most important heritage landscapes which has already lost over half of its megalithic monuments in recent centuries.
Peter Sweetman and on behalf of: