A woman whose first child was adopted in 1979 has told an oral hearing into a planning application to build apartments and a creche in the grounds of Bessborough mother and baby home in Cork, it is wrong that a developer should propose earning money from the site.
The developer has rejected suggestions that the 3.7-acre site encroaches a children's burial ground.
Mary Slattery, from Passage West in Co Cork, was one of a number of observers who made submissions to the hearing, which is taking place virtually and is being held by An Bord Pleanála.
In her submission, she described the proposal by development company MWB Two Ltd as an abhorrent act of desecration to the memories of the babies and women who died at Bessborough.
The Commission of Investigation into Mother and Baby Homes found that 923 babies born at or associated with Bessborough died there between 1922 and 1988.
Mary Slattery said 64 mothers also died there. The burial place of most of the women and babies is unknown.
"They are missing," Ms Slattery told the oral hearing, "how awful; how hurtful is that? And these developers are proposing to build on it. That cannot happen. It has to be preserved."
Ms Slattery said the land should be transferred to public ownership and a suitable memorial created there.
"Some of my peers are living and their babies are dead and unaccounted for," she said. "For a developer to propose that they earn money from us, that is not right."
MWB Two Ltd has applied directly to An Bord Pleanála under the Strategic Housing Initiative for permission to build 179 apartments in three blocks on a 3.7-acre site in the grounds of Bessborough.
The developer says it has engaged experts in the areas of archaeological conservation and heritage and they have concluded that there is no evidence that the site contains any undocumented burials associated with Bessborough.
However, as part of the planning process, MWB Two Ltd. says it has committed to carrying out a full archaeological investigation at the site.
"Even though MWB Two Ltd says a burial ground is highly unlikely to be in the field and on our site, out of respect for the survivors and their belief, MWB Two are suggesting a mechanism for even more site investigation," Senior Counsel David Holland, for MWB Two Ltd, told the oral hearing.
Former residents, among them Cork Survivors and Supporters Alliance, say the development will encroach on an area marked as a children's burial ground in a 1950 ordnance survey map.
Several witnesses called by the developer to make submissions to the oral hearing disputed this.
Another witness who gave evidence to the oral hearing was Carmel Cantwell from Rochestown in Cork. She said she has been visiting Bessborough for the past 27 years, because her mother was told that her baby was buried in the grounds.
"Not knowing the exact place her baby was buried has caused great stress in her life," Ms Cantwell said.
She said an area adjoining the MWB site - known as the Folly - had become a place for relatives to visit to commemorate the women and children who died at Bessborough.
"We do not want apartment blocks overlooking this special place," Ms Cantwell said.
"The full truth of the burials at Bessborough may never be known but I propose in the memory of the 923 children that died along with the 19,000 girls, women and their children that went through this barbaric system of incarceration and separation should at the very least be acknowledged and honoured by keeping these grounds untouched and create a space for the community and for healing."
Ms Cantwell said the grounds of Bessborough have an historical legacy which must be respected.
"The 'Children's Burial Ground' must be preserved. Anything else would be a travesty," she said.
MWB Two Limited says the assertion that the development will encroach on the burial site is based on a fundamental misunderstanding of the map.
It says the annotation on on the map refers instead to a known burial ground adjacent to the marking, which is outside the MWB Two Ltd site.
"Even though MWB Two Ltd says a burial ground is highly unlikely to be in the field and on our site, out of respect for the survivors and their belief, MWB Two are suggesting a mechanism for even more site investigation," Mr Holland told the oral hearing.
Minister for Children Roderic O'Gorman told the hearing he wants An Bord Pleanála to take account of the findings of the Commission of Investigation into Mother and Baby Homes.
The commission's final report was published earlier this year, while an earlier interim report dealt specifically with burial places of women and children who died at mother and baby homes, including Bessborough.
"It is very clear," Minister O'Gorman told the hearing, "that there are unresolved questions about burial sites of hundreds of children from Bessborough and it is highly likely that some of them are in the lands around Bessborough, and some of those lands are included in this application."
Mr O'Gorman said he would like An Bord Pleanála to use its powers, if it grants full or partial planning permission, to ensure that a comprehensive and appropriate investigation is conducted by the developer of the site and any burial areas within it and, if human remains are found there, that the burial area would be appropriately marked and public access would be assured.
Archaeologist John Cronin said he was tasked by MWB Two Ltd with conducting an archaeological appraisal of the developer's 3.7-acre site. He said eight trenches were mechanically excavated and the material sifted and no evidence of human remains was found.
"While it cannot be ruled out that the SHD [Strategic Housing Development] site contains human remains, I believe it highly unlikely on the basis of available cartographic evidence," Mr Cronin said.
The oral hearing is taking place virtually and is expected to last a day-and-a-half.
Cartographer Mike Flynn, a former Ordnance Survey Ireland employee who spent more than two decades on field work, was called as a witness for the developer.
He said he disagreed with objectors to the plan that a marking on the 1950 ordnance survey map referring to "Childrens' (sic) Burial Ground" referred to a children's burial ground on the MWB Two Ltd site.
He said he had "no doubt" that the marking did not indicate a physical feature on the MWB Two Ltd site.
Land surveyor Paudie Barry, also called as a witness by MWB Two, said text can be positioned and re-positioned on a map to describe features but, he said, it was "basic surveying knowledge" that text describes a line on a map and the text can be positioned on either side of that line.
He said he was "100% sure" that the children's burial ground referred to in the 1950 map was describing an area outside the MWB Two Ltd site.
"Text... is never used on a map to describe location," he said.