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.
The Minister's Guidelines on Windfarms published today are a further attempt by the present Government to systematically undermine the little environmental protection there is in Ireland.
INFRINGES EU DIRECTIVES
While everyone welcomes alternative energy, it cannot be at the cost of obligations to protect habitats and species under European Directives. The Guidelines suggest that National Climate Change Strategy and compliance with the Kyoto protocol on climate change can override European designations of Special Areas of Protection for Birds and Special Areas of Conservation. But these designations cannot be undermined by national Guidelines no matter how worthy the intention. No matter how carefully designed, wind turbines are incompatible with environmental protection in many areas of Ireland. If these Guidelines are implemented as they stand, their failure to respect European conservation designations will inevitably lead to more legal infringement proceedings against Ireland.
FAILS TO ALLOW FULL ASSESSMENT OF IMPACTS
Further, the separation of the transmission infrastructure, which can be extensive and invasive - from the planning application for wind turbines has not been addressed. This leaves residents unable to properly assess the impact of the whole development on their property when considering a planning application.
We are appealing the County Council's decision in this case. Here's £120
FIE is an env campaigning organisation. We are strongly in favour of windmills and other renewable energy sources. Ireland is very suited to windmills. But
they can't be sited with no attention to the environment. We're very worried
about this plan
Grounds of appeal:
1 damage to landscape
2 damage to SAC
3 lack of EIA
4 lack of study on other sites
5 damage to image of windmills
Three others objected to the applications. We recommend to the Bord to
read the letters on the planning file.
Re: Wind Monitoring Mast et allia., at Knocknafallia, Mount Mellory, Knockmealdowns.
Dear Senior Planner;
Friends of the Irish Environment have taken an active interest in the development of community based developments in renewable energy. We support green energy.
We have, however, recently appealed the decision of Galway County Council to permit three wind turbines on the Aran Islands on much the same grounds that we believe the local community is justified in opposing the proposals for Knockmeadown:
¬® The development is not community based in the sense that the community does not financially control the project through suitable structures. It structures investments from outside interests through tax incentives to capitalize on an environment that belongs to the community and is not therefore in the interest of the common good, to which the planning authority must confine its decisions.
¬® The development of wind turbines on a case-by-case basis makes no sense in advance of a national spacial plan. These plans will identify areas which are suitable for alternative energy and areas which must be protected and is promised in the new planning legislation - and so the development is premature.
¬® The government's National Development Plan projects a 32% increase in CO2 emissions instead of the Koyoto target of 13%. Isolated rural areas should not have to bear the impact of failed national targets to control emissions.
¬® There are extensive areas where the impact on the landscape of wind turbines would be acceptable and even other degraded landscapes where they would have a positive impact. Any turbines at this location would be visible over a wide area where the landscape is open and unspoiled, making the development incongruous and intrusive in a place of natural beauty so great that legend has it men wished to be buried upright.
¬® The proposal is contrary to the provisions of the County Development Plan in terms of general protection of visual amenities and we understand in the new Draft Plan specifically favoring single turbines and small groups as opposed to this proposal, which would set a precedent for untrammeled exploitation.
¬® There is no indication in the proposal of the location of the pylons and power lines that will require planning permission, implying the application is in fact "project splitting". Project splitting of this nature if permitted will have the effect of concealing from the public the full impact on the environment of the consequences of a development consent for this proposal.
¬® This proposal if built would be so incongruous that it would indeed give wind energy a bad name. For the sake of alternative energy's future development in Ireland, our organization urges the developers to seek a more appropriate location for their otherwise admirable proposal and the for the local authority to refuse any permission for any part of the proposed wind turbines at the Vee and the Knockmealdowns.