20th September: FIE today made a submission to the Department of the Environment in relation to their draft guidelines on wind energy. The core points of the observation are as follows
The guidelines are being made in a situation where Ireland has no policy on greenhouse gas emissions and no policy on renewable energy.
The guidelines fail to protect the scenic landscapes of Ireland's mountains and coasts.
The guidelines should on the other hand emphasise the cutaway and cutover blanket bog which should be used for very large wind turbine arrays.
The guidelines fail to implement EU law in relation to Biodiversity protection.
Observation by Friends of the Irish Environment on Draft Planning Guidelines on Wind Energy Development
Friends of the Irish Environment welcomes the intention to provide planning guidelines in relation to wind energy. We also welcome the detailed work which has been done in relation to visual impact and aesthetic aspects. However, we are gravely concerned by a number of aspects of the guidelines.
1. Sustainable Energy Policy
Unfortunately the cart is before the horse.
The National Climate Change Strategy has been formally under review by the government for 2 years. With the abandonment of carbon taxation, the Climate Change Strategy no longer exists. We need to be specific about the requirements for the permanent shift from fossil fuels to renewable energy and plan for that transition. At the moment, we are simply adding on wind turbines to cater for some of the growth in the fossil-fuel-focussed system. This is not a strategy, not to mind an adequate strategy.
Additionally, as the draft guidelines say "A review of options for future renewable energy policy targets and programmes is currently being undertaken by the Department of Communications, Marine and Natural Resources. The review will consider indicative increases in Ireland's green energy output between now and 2020."
Amongst the issues which would be addressed in the renewable energy review would be the nature of the electricity distribution system and grid. This is something which the draft guidelines seem to take for granted. In fact, decentralised renewable generation logically lead to different distribution systems.
2. Location, Aesthetic and visual impacts
The draft guidelines seem to go out of their way not to rule out or advise against wind turbines in any location or type of landscape. This is mistaken. There are landscapes where wind turbines are not appropriate.
We are particularly unhappy with the advice in relation to two of the landscape types identified, mountain moorland and the coastal zone. Additionally we have observations on the advice in relation to peatland.
The guidelines state:
"It may be acceptable to locate wind farms on ridges and peaks. They might also be appropriate, in certain instances, in a saddle between two peaks where they will be partially contained or 'framed'. A third good location is lower down on sweeping mountainsides."
This is reminiscent of "any colour as long as it's black". As a planning guideline it is of no use.
It entirely avoids the issue of the large areas of scenic upland which both have a direct intrinsic aesthetic value and form Ireland's largest tourism resource and domestic recreational resource. These areas must be protected from wind turbines and this should be incorporated in the guidelines
The coastal zone is Ireland's other major scenic landscape. One of the very positive features of the guidelines is the inclusion of photomontages of wind farms in the various landscape categories. The photomontages of both the coastal zone and the mountain moorland show the severe impact of wind turbines on these scenic locations. We believe that the non-urbanised coastal zone should be protected from turbines. However, we would like to emphasise that a lot of Ireland's coastline is urbanised. These areas of urbanised coastline are, we believe, entirely appropriate for large-scale wind turbine development. Additionally, of course, offshore wind turbines are likely to be a very important resource.
The report is insufficiently enthusiastic about the wind potential of the large areas of raised bog in Ireland, particularly the cutaway and cutover bogs. These enormous areas are entirely suited to wind turbines on a massive scale. Contrary to the suggestion that they are "probably best located away from roadsides allowing a reasonable sense of separation," roadsides are a good location as they give access without the technical difficulties or hydrological and ecological impacts of access road construction on peatland. Additionally, there are bog railways which can be used for access on much of the cut bogs. The report should give a strong positive bias towards the use of peatland for wind generation. Including a picture of peatland wind turbines on the cover of the final guidelines could help hammer this message home.
3. Location, ecological impacts
Curiously, the guidelines refer to only the visual and aesthetic impacts under the heading "Siting and Design of Wind Energy Developments." And then goes on to discuss "Other Environmental Considerations." We would like to emphasise that ecological considerations are relevant to siting.
The draft guidelines set out a procedure for assessing potential sites in the context of the development plan including the following:
"Prepare an overlay of the landscape sensitivity and wind energy mapping together with information regarding the built and natural heritage, archaeological and amenity designations in the Development Plan. This will identify those areas affected by statutory obligations and seek to strike a reasonable balance between avoiding adverse impacts on these areas and on the natural and built heritage."
The latter sentence is meaningless as it does not indicate what the balance is with. But the more fundamental problem is that the purpose of statutory designations is to provide protection. There is no balance to be struck between complying with statutory protection for biodiversity and other objectives: the law must be obeyed. The Development Plan and these guidelines should make that clear.
A similar misstatement of the law appears later in the draft guidelines:
"Designation of a site as, for example, a Natural Heritage Area, proposed Natural Heritage Area, Special Protection Area, candidate Special Area of Conservation, Nature Reserve or other area designated under statute for the conservation of natural or geological interest does not preclude the development of wind energy projects. "
While it does not automatically preclude wind energy projects, such a designation can preclude them.
The draft guidelines continue
"Where a proposed development could impact on areas subject to national and international site designations, wind energy developments must be assessed in terms of their impact on the integrity of such sites and their natural heritage interests. The importance of the development of large wind energy projects including those proposed on designated sites must be given due consideration in view of their strategic importance in achieving the aims of the National Climate Change Strategy and compliance with the Kyoto protocol on climate change. The best results in relation to incorporation of heritage considerations into development proposals in designated sites are achieved where prospective applicants and planning authorities work together to identify whether the development may impinge upon particular aspects of heritage, with a view to agreeing on any measures that may be needed to avoid or minimise any potential adverse impacts on heritage.
The legal requirements in relation to biodiversity are clear. The guide should specify the issues which are known to arise in relation in particular to compliance with the Habitats and Birds Directives.
As the Department will be aware, Friends of the Irish Environment is fully supportive of renewable energies including wind energy. For this reason we hope that the guidelines which are produced will be guidelines which we can fully support and which comply with EU law. However, as the Department will also be aware, FIE is committed to ensuring compliance with EU environmental law. Therefore we will complain any guidelines which do not comply with EU law to the European Commission.