PRESS RELEASE 26 FEBRUARY 2001
ARAN WIND PROJECT HIT BY EU LETTER
The European Commission has informed the Irish authorities that the decision to permit three proposed wind turbines on Inis Meain on the Aran Islands infringes the European Impact Assessment Directive.
In a letter dated 8 February, 2001, the Commission notes that four complaints have been received and states that "Although the project is below the threshold for EIA of wind farms in the Irish legislation, it is evident that it will have a significant impact on a landscape of natural, historical and cultural significance."
The letter follows on a European Court Judgment of September, 1999, against Ireland. This stated that even when a project is below the threshold for an environmental impact assessment, EIA were required in some circumstances as "even small scale projects can have a significant effects on the environment if it is in a location where the environmental factors set out in Article 3 of the Directive such as flora and fauna, soil, water, climate or cultural heritage are sensitive to the slightest alteration."
Noting that the site is an SAC and an NHA as well as being listed in the Inventory of Outstanding Landscapes, the Commission writes that it has been pointed out to them that the island "is an untouched 18th and 19th century field system of major importance and irreplaceable conservation value against the backdrop of the Atlantic, and that the development will represent a gross intrusion."
The Commission states that it has received no reply from the Irish authorities to its letter about this proposal of 29 August, 2000, which was due by 29 October, 2000. If it receives no reply to this letter within two months, it may proceed to issue a Reasoned Opinion under Article 226 of the EC Treaty, the final stage before Judgment of the Court.
The project was due to receive Community co-funding. Community co-funding is not made available unless a project is in compliance with all Community legislation.
Development: 15.6 mw windfarm to include 13 turbines, 45m. high measuring mast control building, hard standing areas, compound, access etc. Inchamore, Milleeny, Coolea, Co. Cork.
The proposed development is located in the Coolea Valley, described in the South Cork Development Plan [11.8.9] as "associated in the hearts and minds of people with Irish culture and folklore and the music of the O'Riadas. The Council commits itself "in recognition of the unique contribution to Irish culture and music tradition" to "facilitate development effort within the village". It is the thrust of this Observation is that the proposed development is for an area that is very highly populated for rural Ireland and that the efforts of the residents to reverse the decline in population would be material disadvantaged by the proposal, contrary to this specific provisions of the Development Plan.
There are forty occupied dwellings with 111 residents within a 2.5km radius of the development (refer to map). No dwellings from below the Coolea school from the Coolea village or from the scenic route A27 (as designated in the County Development Plan) have been included. Additional households (not numbered) on the north side of the site would also be strongly effected by the wind turbines, especially during the construction period.
There is a further habitable dwelling within 250 to 300 of at least three wind turbines which was vacated in the beginning of November 1998 (only weeks before planning permission was applied for). The house has been barricaded and is unlikely to be renovated if the proposed development is permitted.
The Coolea valley is too small in scale and too densely populated to accommodate such a development. Noise and visual disturbance would degrade the quality of life for many individuals and would severely compromise the ability of the area to continue to attract new residents which promise new life to this remote area,
The evidence we produce for this is an examination of the proposal in the light of the guidelines published by government agencies and Irish non-governmental organizations.
The proposed development does not fulfil all the requirements of the relevant guidelines.
Irish Planning Institute- Planning Guidelines for Wind Energy
3.1 Natural resources and renewable energy potential.
This section advocates "assessment of the county's natural resources and potential for exploitation for renewable energy in general: e.g. major developments or municipal facilities with potential for combined-heat-and-power output or landfill gases exploitation: pilot projects for community-based biogas production in agricultural areas: assessment of wind energy potential of different parts of the county: areas where tidal or wave power research could be carried out. areas with small scale hydro potential etc." This section also advocates, "even smaller developments (e.g. one or two turbines located on a farm or commercial premises) might also be addressed. Such projects can be absorbed into landscapes and mixed use areas much more readily than larger ones. The enterprise could draw down electricity for it's own use and sell the surplus to the grid."
In this particular instance members of the Coolea community have expressed interest in community-base hydro power and other options. They have expressed the wish to investigate these options to the Cork County Council but no realistic study was carried out of these alternatives as the nature and location of the development was determined before any studies were undertaken.
This section advocates that "In general, windfarms should not be permitted in Areas of Outstanding Natural Beauty, National Parks, designated scenic areas, in view of designated scenic routes, or in areas where there is intervisiblity from such areas."
In this case the windfarm would be clearly visible form the A27 (a designated scenic route). There would also be intervisibilty from the following amenity areas: The Paps, an amenity area used also as a pilgrim walk, Mullaghanish , a proposed Special Conservation Area, Caherbanagh, Mangerton, A25 (from Ballyvourney to Mullanganish to Caherdowey) A26 ( between Macroom and the Derrynasagate mountains).
"Applications should generally be accompanied by environmental impact studies. These should include mapped zones of visual influence (ZVI's) and detailed analysis of views particularly affected. Photo- or video-montages on these views are recommended as a requirement."
Photo-montages supplied in the EIS were misleading, in one case containing forestry which did not exist.
4.4 Grid Connections
"Connecting lines between the windfarm and the National Grid should be subjected to close visual analysis and locational control. Conditions should be considered relating to reinstatement of land after construction of the connecting lines."
Grid connection plans were not included in the planning proposal, so have not been subjected to close visual analysis. Due consideration has not been given to reinstatement of land disturbed by pylons after construction and no analysis made of the impact of roads and their escarpments on the visual amenities of the area..
4.5 Noise Emissions
"Sites in close proximity to existing houses or other noise sensitive land uses should be avoided. A minimum distance of 500 metres is generally recommended but this may vary from site to site.
"The topography and nature of the area surrounding a windfarm site may influence the transmission of noise. In hilly terrain, background noise in a steep sheltered valley may remain lower than a hill above while turbines operating in higher wind speeds on the hill may be more audible from the valley below."
Due consideration has not been given to the effects of topography on noise. There are two residences approx. 500m, from the site which are likely to suffer greater noise impacts than recommended by guidelines.
4.7 General Operation of the project
This section advocates consultation with the Irish Wild Bird Conservancy in relation to possible impacts on bird life. There is no evidence that this consultation took place. Although a bird survey has been included in the EIS, it does not conform to the standards required to accurately assess the impact on the project of the year round bird life of the area.
Department of Environment
Windfarm Development - Guidelines for Planning Authorities
2.2 (Technology of Wind Generators)
"In order to ensure the aerodynamically efficient operation of turbines, they are required to be sited 5-10 rotor diameters apart." The turbines in this proposal are to be placed much closer together than in required for efficient electricity generation with consequent additional impact in terms of turbulence and noise.
4.7 Land-use Planning Considerations
"Planning authorities, in considering applications for wind farm developments, should, as in any other case, have regard to the proper planning and development of the area and the preservation and improvement of amenities."
This development, in such a populated area of cultural importance would impact negatively on the proper development of the area, reducing the likelihood of new developments through devaluing the land and house prices and through loss of access to unspoiled amenities. The granting of permission also fails in the "preservation and improvement of amenities" as local amenities will suffer serious adverse impact.
4.8 Visual impact
"The visual impact is among the more important considerations to be taken into account in arriving at a decision on a particular application. Wind turbines are tall and their prominence is emphasized by the movement of the rotors. Visual impact must be assessed with their particular and unusual characteristics in mind. Visual impact is influenced by:
*Form and characteristics of the landscape;
*Design and colour;
*The existing skyline;
*Layout of turbines;
*Number and size of turbines.
The landscape in the Coolea valley and surrounding mountains is rural in character. It is cultural landscape created by traditional farming practices. Seventy two metre tall industrial structures, with distracting moving parts would significantly alter the nature of the landscape.
4.9 Visual Influence
"Assessment of visual influence should have regard to both im- Mediate visual impact and views from a distance (especially from any adjacent areas of high landscape quality). Turbines should not dominate landscape features, especially views designated in the Development Plan as views of special amenity or interest which it is necessary to preserve and views from adjacent areas subject to national or international designation or designated in the Development Plan as being of high landscape quality. Turbines should not be prominent when seen against an elevated skyline background from public roads, towns or village centres."
Visually the development would have a negative impact on adjacent areas of high landscape quality, turbines would be clearly visible from public roads and from houses within the Coolea village. Given the size of the turbines and the scale of the valley, the windfarm would be inescapable in the views of residents and also those travelling along the scenic route A27.
"In sheltered positions where "wind shadow" occurs, such as leeward valleys, background noise may remain low when turbines on adjacent higher ground are operating at higher windspeed." Due consideration has not been given to the possibility of this occurring at this location which appears to lend itself to the production of such "wind shadows".
4.16 "Noise impact should be assessed by reference to the nature and character of nearby surroundings and developments. Good acoustical design of turbines and their proper location in relation to noise-sensitive properties is essential in order to ensure that there are no significant increases in ambient noise level at those properties. Generally, noise levels measured externally at any dwellinghouse should not exceed 40dB(A) leq. and tonal of impulsive qualities in the noise should be avoided."
Noise impact has not been assessed by reference to the character of the surrounding area in terms of topography, usual wind direction and speeds. It is stated in the EIS that in wind speeds of 12ms-1 noise levels at the closest dwelling are predicted to be 49 dB (A). This is in excess of the guidelines. The predicted noise levels for this dwelling would be enough to disturb sleep patterns. This is known to lead to other psychological and physiological problems.
The rotation of blades is known two distinct kinds of noise; low frequency penetrating noise and a 'thump' reminiscent of a helicopter when the blade passes the tower.
"Noise can also be harmful to wildlife, especially birds." Full consideration has not been given in the EIS to possible impacts of noise on birds and other wildlife.
4.20 "Wind farm developments, both during the construction and operational phases, may impact significantly on the ecology and heritage of an area. Consultations with the Department of Arts, Culture and the Gaeltacht, the Geological Survey of Ireland and the developers should take place at the earliest possible stage where these matters are relevant."
We can find no evidence in the planning file to show these consultations have taken place.
4.21 Ecological Impacts
"Any proposal will require an assessment of the possible ecological impacts. Consideration should be given to sensitive habitats and species, as well as any possible risk to birds, including migratory birds. Wind turbines can be a threat to the safety of bird life."
Due consideration has not been given to ecological impacts, as surveys included in the EIS are not credible.
4.29 Contribution to local economy
"Where the quality of the local environment and landscape contribute significantly to activities which support the local economy, such as tourism and outdoor recreational activities, that contribution is relevant to the proper planning and development of the area and should be considered as part of the planning process. In particular the possible noise or visual impact of the development on such activities should be assessed."
Due regard has not been given to the economic benefits of tourism in the area, neither has there been any assessment of the recreational landuse in the region. The tradition of O'Riada is not considered and the clear relationship between the love of music and the natural sounds of the Irish mountains is nowhere contrasted against the impact of the noise of the proposed wind turbines.
4.32 Construction Impacts
"Drainage implications of the development, particularly during construction, should also be considered."
Drainage impacts have not been given due consideration, as rainfall data was collected 300 metres below the top of the site and thus does not truly represent rainfall on the site.
An Taisce Wind Policy
Paragraph 6 "The EIAs should include a full photo montage from all locations from which the public may view them. Noise contour maps should be required to identify potential intrusion into amenity and residential areas. Noise levels should be tested under a multiplicity of conditions and ground conditions should be correctly factored in."
The EIS included some photomontages but the positions were not always those which showed the clearest views of the development. Noise contour maps in the EIS have not considered topography. Noise levels were not tested under a multiplicity of conditions, ground conditions were not factored in. Noise surveys were extremely limited in their time-scale and thus data collected has limited use.
Paragraph 7 "Survey of birds breeding and feeding within the impact area should be supplied for winter and summer. Grouse, wheatear, golden plover, ring ouzels, hen harriers, and merlin are all vulnerable species in this country."
No surveys of wintering birds were conducted, studies of breeding birds do not comply with international standards. Both hen harriers and merlin are known to frequent the site, and would be endangered by the development. They will also suffer loss of habitat.
Paragraph 10 "The scale of some of the proposed developments appear to be out of proportion to the ability of the landscape to absorb such developments. The economic motivation provided in Ireland through grants and tax incentives which encourages development by large concerns must not be allowed to erode those communities' long term interest. Irish energy policy should provide greater financial incentives for smaller scale community based projects as elsewhere in Europe (particularly Denmark) in order to encourage community development and greater awareness and greater public awareness of the need for energy conservation."
The residents of Inchamore and Milleeny have expressed their interest in creating a community based electricity generation system. The proposed development is not community based as the community does not control the development financially, neither do they benefit from the development. The environment belongs to the community, yet this development allows it to be altered negatively beyond their control.
This development fails to further the objectives of Agenda 21 in that it does not encourage community consultation and participation in sustainable development in their environment.
It does not satisfy sustainable development criteria; classically defined in the 1987 Brundtland Report as "development that meets the needs of the present without compromising the ability of future generations to meet their own needs."
This development would compromise the needs of future generations by loss of habitat and species diversity and by weakening the fundamental attractions of the area.
The development fails to provide a better living standard to the disadvantaged members of the community by financial incentives in any way. It fails to contribute to changing patterns of electricity consumption locally, which would facilitate future sustainability.
It also fails to promote and protect human health. Unwanted noise has been shown to cause health problems ranging from feelings of ill-ease, disruption to sleep patterns, stress and tension, cardiovascular illness and high blood pressure. Noise and vibration of construction would be severely disrupting to residents and the continuous operational noise would pose a serious long term threat to health in the area.
It does not involve managing the land sustainable, as blanket bog and wet heath (a European Priority Habitats Annex 1) would be irreversibly damaged. It does not preserve bio-diversity, further endangering rare bog flora (such as Sundews and Butterworts) and fauna (such as the Kerry slug).
The proposal does not encourage sustainable mountain development or sustainable agricultural and rural development. Socio-economically the development would have a negative impact on the area.
Even developments that are not seemingly directly connected to the cultural heritage of the area show an appreciation and relationship to the natural environment that translates into a commercial advantage. Coolea Farmhouse Cheese is an international renown sustainable local development. Economically Coolea Cheese is dependent on the tourists who come to the area to experience the semi-wilderness character and the living tradition of Irish music and folk lore. Similarly there are local crafts people and artists who draw their inspiration from the mountains and their market from tourists attracted by the mountains.
The development would inevitably lead to financial deprecation of properties in the region, thus removing the incentive for investment and ending the lure of the wilderness. Given the destructive impact of the development on the ambience of the area it is not unreasonable to suggest that the proposal if permitted could turn the positive tide of recent years into a ebb flow of the valley's life, leaving cottages again derelict and the only music the whine and thumps of the wind turbines.
Regardless of national policy, alternative energy should not be developed against the will of the people who live near a proposed location. Because the rural residents are the least able to defend themselves against well resourced outside development interests it is all the more incumbent on the planning process to ensure that their amenities are not unjustly damaged. Just as Strategic Development Zones will have to be agreed and identified on a national level for industrial development, so wind generation locations should be identified as part of national spatial planning at least at a regional or county level.
This application represents an ad hoc decision made by an under resourced planning authority working under great pressure. It will sacrifice the natural amenities upon which a culturally unique area relies and endanger the future of a living Irish heritage valued and protected in the County Development Plan.
Planning permission for a wind farm in a scenic area of Tipperary which was opposed by D??chas, the Heritage Service, has been overturned by An Bord Pleanála. Local residents and a number of environmental groups had also objected to the plans by a group of farmers to build the wind farm in the Slieveardagh Hills, near Urlingford.
South Tipperary County Council had granted permission for the development, which included 17 turbines ranging from 45 metres to 55 metres in height. The site was "only elevated in a localised context" and its impact on the visual amenities of the area would be negligible, it said.
However, a Bord Pleanála inspector, Mr Dermot Kelly, said a wind farm with blade tip heights of up to 81 metres in a prominent location, close to medieval buildings of architectural importance, would have had a negative impact.
In its appeal to the board, D??chas had expressed particular concern about the potential damage to the visual amenity of two national monuments, Kilcoole Abbey and the War House at Farranrory.
Mr Peter and Ms Faith Ponsonby, owners of the Kilcoole Abbey demesne, also appealed the council's decision, claiming the development would have been "the death knell of the area".
They claimed the noise from the wind farm would have been intrusive and the skyline as seen from the abbey would have been seriously degraded.
Friends of the Irish Environment, An Taisce, the South East Tourism organisation and the Slieveardagh Environmental Protection Group has also raised concerns.
The council said it accepted that Kilcoole Abbey had a unique conglomeration of archaeological features, which were worthy of protection. It believed the demesne, however, could co-exist with the wind farm, it told the board.
The group behind the proposal, Mr Thomas Cooke of Barna, Thurles, and others, had offered a 10 per cent stake in the operation to the local community. There would be no impact on humans, livestock or horses, it claimed.
In its decision, however, the board said the wind farm was to be located in an elevated and unspoilt exposed location, in a rural scenic landscape. The area was designated in the South Tipperary development plan as one of "secondary amenity value".
By reason of its height, scale and extent, the development would be visually obtrusive and "would significantly detract from the cultural and visual amenity and landscape setting of the medieval Kilcoole Abbey, which is a national monument in State care and a protected structure of significant heritage importance.
"The proposed development would, therefore, be contrary to the proper planning and development of the area."
Farmers lose out as Euro10m wind project turned down
A GROUP of farmers has failed in their plans to construct a Euro10m 17-turbine wind-farm.
As a result of An Bord Pleanala' decision to refuse planning in the Slieveardagh Hills near the south Co Tipperary village of Grange, community groups are set to miss out on a potential wind-fall of Euro250,000 over the 20-year lifetime of the project promised by the Knocknamuck Wind Farm Group (KWFG).
The appeals board ruled the plan, with turbines heights reaching 265ft, would be contrary to the proper planning of the area, stating it would significantly detract from the cultural and visual amenity of a protected structure of significant heritage importance, the medieval Kilcooley Abbey.
Yesterday, dairy and beef farmer, Thomas Cooke, of the KWFG expressed his "extreme disappointment" at the board's decision.
"There are five farmers involved and in all we have invested Euro60,000 in the project," he added. "We were also able to secure finance for the project, but now have nothing to show for two years work. We believed it complied with EU, National and County Development Plan policy."
While FIE supports renewable energy and wind power, its does not believe that these installations should be imposed upon rural communities against their will and in contravention of their County's Development Plan and environmental protection.
FIE has assisted communities in Cork, Galway, and Tipperary in resisting some of these developments.
Read the Inspectors Report in an important appeal which refused permission for 17 turbines in an exposed location in County Tipperary. [PDF file - an experiment on this revised site.]