Mr. Ian Lumley:

The Valletta Convention is one of a number of Council of Europe conventions. There were parallel conventions on landscape and architectural heritage. The Granada Convention on architectural heritage in 1985 was very effectively transmitted into Irish law in 1999 and incorporated into the 2000 planning Act. Despite having adopted the 1992 Valletta Convention in 1997, we have not adopted its key provisions. Like a lot of international conventions, the Valletta Convention is simply named for the place where, in this case, the final signatory meeting took place. It takes its name from the remarkable, historic, fortified city of Valletta in Malta. The convention expanded on previous archaeological conventions in putting new emphasis on the overall context of setting up monuments. I have a copy of the convention here. In particular, Article 1 iii makes specific reference to defining the architectural heritage as not just structures and features themselves but their context, whether situated on land or under water. The wider context is the land or physical setting of the monument. Article 5 iii sets out the principle of the environmental impact assessment process and states that it should involve full consideration of archaeological sites and settings.

An Taisce is one of the many prescribed consultee bodies for archaeology under the planning legislation. I have had oversight of that function for quite a long time. When we get applications of a particular sensitivity, we call in local members, people with expertise, academics and others in particular on more complex projects like road schemes. What we found is that over the years there has been a systemic failure to consider the wider landscape setting and context of a monument or the relationship of monuments and features to their being part of a wider complex, like Tara and Rathcroghan, which I cited in our submission. There was in fact a significant court judgment on this about 30 years ago concerning a dump on the sensitive area of the megalithic complex at Carrowmore in County Sligo. The court judgment concerned the impact on the setting of the archaeological monuments in the landscape. The court recognised that it was not just the archaeological features that were of significance - the structure that could be clearly seen on the ground – but the wider context and setting. That has been increasingly recognised in the archaeological world.

As an article in the magazine, Archaeology Ireland, showed, the drought in 2018, when we had that low rainfall period, dramatically revealed through drone footage and aerial photographs previously unknown sites, and showed that many isolated archaeological sites and features were in fact part of larger complexes surrounding them. This recognition of the setting of complexes that relate to each other, and the setting of monuments, needs to be properly addressed and incorporated into legislation. Looking at planning applications, there is this unwritten rule about 20 m, and there is an emphasis on test trenching and examining the individual site, but not enough consideration is being given to the setting and context of the site. That applies to all categories of development, whether these are big infrastructure or the building of a farm shed structure near a ringfort, where the landscape setting is simply not being properly addressed.