Wind turbines

 FIE has lodged a comprehensive objection for what could be the largest wind farm in the State.

The proposal is for 45 wind turbines 126 metres in height located at Shragh near Doonbeg in County Clare, where 13 turbines have been constructed or approved already.

The development does not comply with the Wind Farm Strategy 2011 - 2017 of the Clare County Development Plan, the National Wind Farm Guidelines, the EU Guidance on wind energy development in accordance with the EU nature legislation, the Strategic Environmental Assessment for the area, the Birds and Habitats Directives and the Wildlife Acts.

'For developers to continue to press proposals that are against the specific assessments undertaken by the Local Authority is a return to the bad planning free-for-all that has cost the country dearly over the last decade.'


States largest windfarm opposed

 

A comprehensive objection for what could be the largest wind farm in the State has been lodged with the Planning Appeals Board by Friends of the Irish Environment [FIE] under the Strategic Infrastructure Act.

 

The proposal is for 45 wind turbines 123 metres in total height located near Doonbeg in County Clare, where 13 turbines have been constructed or approved already.

 

FIE submissions states that 'the proposed very large wind farm is an inappropriate development as it will have a significant adverse visual impact on the landscape, ecological and on rare and protected species with an adverse effect on tourism and the local economy'

 

The submission claims that the development does not comply with the Wind Farm Strategy 2011 – 2017 of the Clare County Development Plan, the National Wind Farm Guidelines, the EU Guidance on wind energy development in accordance with the EU nature legislation, the Strategic Environmental Assessment [SEA] for the area, the Birds and Habitats Directives and the Wildlife Acts.

 

FIE claims that the SEA for Wind Farms in County Clare specifically limits wind farms to one more in the area and that has already been granted.

 

"For developers to continue to press proposals that are against the specific assessments undertaken by the Local Authority is a return to the bad planning free-for-all that has cost the country dearly over the last decade.

 

'Because of the substantial payments involved to participating land owners, developers can split rural communities with long term social consequences.'

 

The group claims that "The biggest mistake of all was the Government's failure to conduct a national Strategic Environmental Assessment as all counties in Ireland have areas with sufficient wind speeds to make them economically viable. The national requirement for 40% of energy to be produced by renewable resources can be adequately addressed without the necessity of non-compliance with the Strategic Environmental Assessment carried out by the Local Authority for its Wind Farm Development Strategy.

 

FIE quotes a Heritage Council study which showed that 46% of the respondents were opposed to wind farms of more than 25 turbines. It claims that the Tullaher Loop and the Doonbeg Loop walking routes have been developed through the area of bog lands upon which the proposed development will be sited and tourism will be adversely affected.

 

The submission also quotes a European Court Judgment detailing Ireland's failure to protect the foraging area of certain bird species, noting that Hen harrier, Whooper swan and the Greenland white-fronted geese all use the site for foraging.

 

The group refers to the recent EPA 'Boglands' Report which confirms the National Wind Farm Guidleines recommends that this scale of the proposed wind farm is more suited to the industrial cutover bogs of the midlands.

 

January 6 is the closing date for submissions.

 

Read the full objection

http://www.friendsoftheirishenvironment.org/cmsfiles/files/library/shragh_windfarm_submission_24dec11.pdf

 

Verification and comment: Caroline Lewis, 027 74771

Rockchapple in the north Cork Mountains is already known as the Sitka spruce capital of Ireland. Now, developers who already have permission for wind turbines in these mountains are seeking to construct a further 13. They have split these into two applications, doubling the costs for objectors.

The proposed site is located in a designated Special Protection Area for the hen harrier. This developer already has permission for nearby turbines - but only on condition that a study on the interaction of the turbines and hen harriers was carried out on site.

As this wind farm is not yet constructed the study can not be done.

Thus the cumulative impact of these developments on the range and scale of foraging areas critical to the survival of the Hen harrier remains unknown. To grant permission now risks a developer investing in a multi-million development and subsequently being required to cease development on the grounds of the adverse impact on the habitat of an protected species.

Read the Objection.



January 29, 2009

Planning Department,
Cork County Council,
County Hall,
Cork.

RE: 08/ 10249
Development: Erection of 5 wind turbines, 3 borrow pits and construction of internal site tracks and associated works at Tooreenmacauliffe, Rockchapel - Applicant: SWS Energy

Dear Sir/Madam,

Friends of the Irish Environment would like to make a submission on the above named planning application.

The Proposed Site
The proposed site is located in a designated Special Protection Area of special conservation interest for the hen harrier (SPA 004161, Stack's to Mullaghareirk Mountains, West Limerick Hills and Mount Eagle) and as such comes under the EU Bird Directive on the Conservation of Wild Birds (79/409/EEC). The hen harrier is an Annex 1 species of this Birds Directive, and the area supports the largest concentration in the country.

Cork County Development Plan
The operative Development Plan is the Cork County Development Plan 2003. The policy on Environment and Heritage is set out in Volume 1, Chapter 7. Objective ENV 2-1 states that it is a general objective to seek the conservation and wise management of areas of natural environmental value. It is also indicated that where development is proposed, appropriate assessment of the risk to the hen harrier will need to be made. An appropriate assessment has not been carried out on this site.

Interaction of wind farms and the hen harrier
The proposed development has potential for adverse impacts on hen harriers from disturbance, displacement and collision. The position regarding the interaction of wind farms and the hen harrier has not yet been scientifically established.

A nearby wind farm development by the same developer (Ref: 04/8534, PL 04.210685) was granted planning permission on condition that a study on the interaction of wind farms and hen harriers was carried out on site. A research study was to be established on this site.

This research study would apply in the pre-construction and post-construction period. As this wind farm is not yet constructed, this study cannot be complete.

In relation to this study, in a similar case permission was refused by An Bord Pleanala, the Inspector commenting:

‘In considering granting permission in this development it is difficult to see how mitigation measures can be put in place if the study referred to identifies whether at the post permission / pre construction phase or the post construction phase that the development has a significant adverse impact. It is also difficult to consider what conditions could be included in a grant of permission to address this issue as this would be tantamount to granting permission, the developer subsequently investing in a multi million development and then the possibility of requiring the development to cease on the grounds of the adverse impact on the habitat of an Annex 1 species.' [ABP 03/6946, Inspector's Report, page 16]

This is particularly relevant in the Rockchapel area, as there area large number of large scale wind farms with planning permission. Most of these wind farms area likely to be constructed over the next two years.

The cumulative impact of these wind farm developments in this area, on the basis of current knowledge and research, are unknown. They are almost certain to have implications for the range and scale of foraging areas for protected species. The retention of foraging areas is critical to the survival of the Hen harrier. Therefore in the absence of this study being completed, it is premature to allow any further windfarm development within the proposed SPA.

Summary
The hen harrier species would be adversely affected and to grant permission would be in contravention of Article 6.3 of the EU Directive as we cannot be sure that it "will not adversely affect the integrity of the site concerned". This is a clear case where the precautionary principle should apply, and we submit that the application should be refused.

As previously mentioned precedence for refusals on these grounds have been set by An Bord Pleanala [ABP PL04 .207910, Rockhill and Rockhill West, Rockchapel, Co. Cork 03/6946].


Respectfully yours,

 

Tony Lowes

 

 

 

Friends of the Irish Environment are supporting the residents of the Ahenny and the Lingaun valley in South Tipperary against their designation as 'open to consideration for wind developments'. The Landscape Policy of South Tipperary, the South Tipperary County Development Plan 2003, and Variation No 7 (adopted by South Tipperary County Council on 4 September 2006) relating to telecommunications masts all argue that these developments must avoids important scenic and archaeological areas like this valley.

FIE supports wind energy development, but only in suitable locations.

See this submission to the South Tipperary County Development Plan.

And our submission on The Department of Environment's Planning Guidelines on Wind Energy Development.
Friends of the Irish Environment are supporting the residents of the Ahenny and the Lingaun valley in South Tipperary against their designation as 'open to consideration for wind developments'. The Landscape Policy of South Tipperary, the South Tipperary County Development Plan 2003, and Variation No 7 (adopted by South Tipperary County Council on 4 September 2006) relating to telecommunications masts all argue that these developments must avoids important scenic and archaeological areas like this valley.

FIE supports wind energy development, but only in suitable locations.

See this submission to the South Tipperary County Development Plan.

And our submission on The Department of Environment's Planning Guidelines on Wind Energy Development.

January 29, 2009

Planning Department,
Cork County Council,
County Hall,
Cork.

RE: 08/ 10249
Development: Erection of 5 wind turbines, 3 borrow pits and construction of internal site tracks and associated works at Tooreenmacauliffe, Rockchapel - Applicant: SWS Energy

Dear Sir/Madam,

Friends of the Irish Environment would like to make a submission on the above named planning application.

 


The Proposed Site
The proposed site is located in a designated Special Protection Area of special conservation interest for the hen harrier (SPA 004161, Stack's to Mullaghareirk Mountains, West Limerick Hills and Mount Eagle) and as such comes under the EU Bird Directive on the Conservation of Wild Birds (79/409/EEC). The hen harrier is an Annex 1 species of this Birds Directive, and the area supports the largest concentration in the country.

Cork County Development Plan
The operative Development Plan is the Cork County Development Plan 2003. The policy on Environment and Heritage is set out in Volume 1, Chapter 7. Objective ENV 2-1 states that it is a general objective to seek the conservation and wise management of areas of natural environmental value. It is also indicated that where development is proposed, appropriate assessment of the risk to the hen harrier will need to be made. An appropriate assessment has not been carried out on this site.

Interaction of wind farms and the hen harrier
The proposed development has potential for adverse impacts on hen harriers from disturbance, displacement and collision. The position regarding the interaction of wind farms and the hen harrier has not yet been scientifically established.

A nearby wind farm development by the same developer (Ref: 04/8534, PL 04.210685) was granted planning permission on condition that a study on the interaction of wind farms and hen harriers was carried out on site. A research study was to be established on this site.

This research study would apply in the pre-construction and post-construction period. As this wind farm is not yet constructed, this study cannot be complete.

In relation to this study, in a similar case permission was refused by An Bord Pleanala, the Inspector commenting:

‘In considering granting permission in this development it is difficult to see how mitigation measures can be put in place if the study referred to identifies whether at the post permission / pre construction phase or the post construction phase that the development has a significant adverse impact. It is also difficult to consider what conditions could be included in a grant of permission to address this issue as this would be tantamount to granting permission, the developer subsequently investing in a multi million development and then the possibility of requiring the development to cease on the grounds of the adverse impact on the habitat of an Annex 1 species.' [ABP 03/6946, Inspector's Report, page 16]

This is particularly relevant in the Rockchapel area, as there area large number of large scale wind farms with planning permission. Most of these wind farms area likely to be constructed over the next two years.

The cumulative impact of these wind farm developments in this area, on the basis of current knowledge and research, are unknown. They are almost certain to have implications for the range and scale of foraging areas for protected species. The retention of foraging areas is critical to the survival of the Hen harrier. Therefore in the absence of this study being completed, it is premature to allow any further windfarm development within the proposed SPA.

Summary
The hen harrier species would be adversely affected and to grant permission would be in contravention of Article 6.3 of the EU Directive as we cannot be sure that it "will not adversely affect the integrity of the site concerned". This is a clear case where the precautionary principle should apply, and we submit that the application should be refused.

As previously mentioned precedence for refusals on these grounds have been set by An Bord Pleanala [ABP PL04 .207910, Rockhill and Rockhill West, Rockchapel, Co. Cork 03/6946].


Respectfully yours,

 

Tony Lowes

 

 

 

To: The Secretary,
Forward Planning Section
Planning Dept
County Hall
Clonmel
Tipperary,
19 October, 2006


Observations on Proposed Variation Number 1 to South Tipperary County Development Plan relating to Wind Energy Development for South Tipperary: Ahenny and the Lingaun valley
Dear Secretary;

Friends of the Irish Environment [FIE] is an environmental organisation created by conservationists in Ireland in order to monitor the full implementation of European environmental law, to work for changes in the Irish planning laws, and to pursue concerns and cases in both the built and the natural environment.

FIE has a long standing interest in renewable energy and specifically in wind energy. We supported the development of the Department of the Environment's Planning Guidelines on Wind Energy Development and took part in the consultation process.

In our submission, however, we noted that there were locations which must be considered 'no-go' areas for wind development. The Ahenny and the Lingaun valley is an example of such a location and we write to support residents seeking to have the designation of this important scenic and archaeological area protected from the impact of wind turbines.

We would also draw the attention to the decision makers to the impact of the transmission pylons and wires that are required to connect these installations to the national grid as in themselves these can be inappropriate and intrusive at sensitive locations.

National policy rightly seeks to provide 15% of Irish energy requirements from renewable sources and planning authorities rightly must have regard to this policy. However, the Landscape Policy of South Tipperary, the South Tipperary County Development Plan 2003, and Variation No 7 (adopted by South Tipperary County Council on 4 September 2006) all argue that these developments must avoids important scenic and archaeological area.

Further the Development Plan states that 'In assessing the potential of the landscape to accommodate windfarm developments, the Council will adopt a precautionary approach. It is difficult to assess the impact that windfarm developments will have on the landscape, especially in scenic areas and particularly to what extent such development will alter the image that people have of certain landscapes.'

The recent Variation No 7 to the Development Plan cited above in fact specifies that telecommunications installations, which have many magnitudes less impact that wind turbines, should 'not be located in

(i) Highly scenic areas or areas specified as such in any landscape character assessment carried out for the County;
(ii) Within significant views of national monuments or protected structures'

The Landscape Policy of South Tipperary classifies the Lingaun Valley as a "highly sensitive landscape." It states "the conservation values of the Lingaun Valley Landscape Character Assessment are of a "consistently high level of importance at a local level. Its enclosure by Slievenamon and the rim of hills to north and south, the scenic views within the area and the intimacy and scale of much of its landscape pattern result in significant aesthetic and potentially recreational amenity value, as yet untapped."

In turn, the South Tipperary County Council County Development Plan 2003 states that Key Landscape aims include:

(i) To sustain, conserve and enhance the landscape diversity, character and quality of the County;
(ii) to protect sensitive areas from development that would detract from or be injurious to the amenity of the area;

In terms of heritage, The Heritage Plan notes that 'South Tipperary is a county rich in heritage of all types, from the sweeping vistas of Slievenamon and the Glen of Aherlow to the distinctive high crosses and use of slate in Ahenny. In history and archaeology the county boasts the seat of the kings of Munster at Cashel and the site of the first shots of the War of Independence at Soloheadbeg.'

This pride must rightfully encompass the unique 9th century High Crosses in the Lingaun Valley and conservation status of the villages of Ahenny and Ninemilehouse.

We respectfully request the Planning Authority to have the Ahenny/Lingaun Valley area changed from its current status - open to consideration for wind developments - to a No-Go Areas zone which, in the word's of the County Development Plan is for 'areas, which due to their scenic, ecological, historic or tourism values are unable to accommodate wind developments'


Yours, etc.,

Tony Lowes,
Director


FIE Submission on The Department of Environment's Planning Guidelines on Wind Energy Development
http://www.friendsoftheirishenvironment.org/friendswork/index.php?do=friendswork&action=view&id=459