Wind Energy Development

Uimhir Thagarta Uathúil: 
KK-C63-CDP18-22
Stádas: 
Submitted
Údar: 
Cormac O'Sullivan
Líon na ndoiciméad faoi cheangal: 
0
Teorainneacha Gafa ar an léarscáil: 
Níl
Údar: 
Cormac O'Sullivan

Observations

Wind Energy Development

Caibidil: 

Dear Mr. Malone

We appreciate the opportunity to respond to the Pre-Draft Issues Paper for the Kilkenny County Development Plan 2020 – 2026.

1. Introduction

This submission is made on behalf of ART Generation Limited. ART Generation has a proven track record in the delivery of renewable energy projects in County Kilkenny and has developed wind farms in Mullinavat (Ballymartin/Smithstown) and in Tullaroan (Ballybay & Foyle).

In responding to questions raised in the Issues Paper, this submission;

 Acknowledges and supports the evident intent of Kilkenny County Council to encourage the renewable energy industry by means of the new County

Development Plan in accordance with national policy objectives.

 Reiterates that it is national policy to move towards a low carbon economy and to promote renewable energy generation at scale at appropriate locations

 Identifies where wind energy generation at a large scale is feasible in County Kilkenny.

 Identifies the constraints placed on wind energy generation at a large scale in the current Wind Energy Development Strategy (WEDS) for County Kilkenny

along with recommendations on how this might be addressed.

 Acknowledges the growth of the digital economy and the 'Government Statement on the Role of Data Centres in Ireland's Enterprise Strategy' and the link to

renewable energy. Digitalisation means electrification.

2. Renewable Energy; National and Regional Planning Policy

Project Ireland 2040, The National Planning Framework (NPF) is very supportive of the renewable energy industry.

National Policy Objective 55 is to

“Promote renewable energy use and generation at appropriate locations within the built and natural environment to meet national objectives towards achieving a low carbon economy by 2050.”

The NPF states that;

“The forthcoming Renewable Electricity Policy and Development Framework will aim to identify strategic areas for the sustainable development of renewable electricity projects of scale, in a sustainable manner, compatible with environmental and cultural heritage, landscape and amenity considerations.” (NPF, P122)

It is a national objective for Ireland to transition to a low carbon energy economy by the year 2050 and National Policy Objective 23 is to;

“Facilitate the development of the rural economy through supporting a sustainable and economically efficient agricultural and food sector, together with forestry, fishing and aquaculture, energy and extractive industries, the bio-economy and diversification into alternative on-farm and off-farm activities, while at the same time noting the importance of maintaining and protecting the natural landscape and built heritage which are vital to rural tourism. (NPF, P78)

This Objective will be progressed through the National Mitigation Plan and the National Climate Change Adaption Framework and an aggregate reduction in carbon dioxide emissions of at least 80% of 1990 levels by 2050 is aimed for across the electricity generation, built environment and transport sectors. (NPF, P119)

The development of the Wind Energy Guidelines and the Renewable Electricity Development Plan are also envisaged to facilitate informed decision making in relation to onshore renewable energy infrastructure. To support the National Policy Objectives in the National Planning Framework, the Southern Regional Assembly will prepare the Regional Spatial Economic Strategy (RSES) and in the RSES Issues Paper “Future proofing energy grid capacities and power generation assets” is identified as a requirement.

It can be expected that the Draft RSES, which is due to be published soon, will support enhancement of the electricity grid infrastructure to transport electricity from locations renewable energy is generated to urban areas/high use locations.

It is generally accepted that the decarbonisation of the electricity system is the easiest way to deliver a decarbonised society and economy as it also enables the decarbonisation of transport and the heating of buildings. The 2020 - 2026 County Development Plan should be cognisant of this and contain policies and objectives to allow the renewable energy sector to contribute to Ireland meeting its targets in relation to the reduction of greenhouse gas emissions.

Wind Energy Development

Ábhair: 

Section 3: Economic Development and Employment

Question: What are the rural growth industries and how can the Development Plan support them?

Supporting Development and Employment.

The rural growth industries are agriculture, tourism, green gas, biogas, energy storage, data centres, solar and wind.

This Development Plan can support rural growth industries by having the appropriate locations for development identified and by having coherent well defined policies consistent with national and regional planning objectives.

For instance, a large wind farm would represent an investment of €150m and would bring c.40 jobs to an area at construction stage and support up to 20 jobs at operational stage. Furthermore it will increase the disposable income in the area arising from land rents paid to landowners. It is estimated that 40% of income generated in an area is spent within the area.

Under the Draft Renewable Energy Support Scheme (RESS) published by Department of Communications, Climate Action & Environment (DCCAE), there is a strong emphasis on community participation whereby a pre-qualification criterion for a project’s participation in the RESS will be that “the community” has been offered an opportunity to invest in that project. In addition, the rates payable to the Local Authority could bring in excess of €1m per annum to the economy1.

The Development Plan should encourage renewable energy generation in rural areas and planning policies should recognise that wind turbines are a legitimate and positive element in a manmade landscape.

Wind Energy Development

Ábhair: 

Section 4: Rural Development

Question: What role can the Development Plan play in ensuring that sustainable agricultural production is supported and enhanced?

Supporting Rural Development.

The Development Plan can play a role in ensuring that sustainable agricultural production is supported and enhanced by designing complementary policies in rural tourism and rural diversification industries. This can be achieved by supporting complementary industries. The encouragement of renewable energy generation by groups of landowners is a form of rural diversification that can help increase farm incomes. In some cases, wind farms have supported and tied-in with walking/cycling tracks, thus strengthening local tourism and recreational amenities. There are a number of existing walkways and treks that could be further developed e.g. the South Leinster Way. In addition, renewable energy providers bring ‘community gain’ in the form of regular financial contributions to rural community clubs and organisations. Investment in local projects strengthens rural communities and the provision of additional amenities can make a valuable contribution towards the long term sustainability of the area. Generally wind farms have been very supportive of rural communities.

ART Generation has experience, in conjunction with landowners and state agencies such as Coillte, in structuring community benefit schemes to provide financial support to local clubs and organisations or to ensure access for public amenities such as walking trails or other tourist facilities. This has resulted in a positive experience of wind farm development in the host communities and encouragement for further projects.

Wind Energy Development

Section 6: Environment and Climate Change

Question: Should the Development Plan give positive support to the development of renewable energy at the expense of other considerations?

Question: How can Kilkenny best tailor its policies on renewable energy to support the renewable energy industry but also protect the landscape’s amenity and ecology

Renewable energy at the expense of other considerations

The Development Plan should give support to the development of renewable energy but does not need to be supported through the dilution of amenity or environmental considerations. It can be carried out in harmony with such considerations at suitable locations. A wind farm is an environmental asset in itself and as an example, a 100MW wind farm would reduce carbon emissions by 140,000 tonnes (per annum) and contribute significantly to Ireland’s national and EU targets for a low carbon economy and towards security of energy supply.

Kilkenny County Council can best tailor its policies on renewable energy to support the renewable energy industry but also protect the landscape’s amenity and ecology by assessing the landscape character and receiving environment. The positive aspects of a wind farm need to be balanced against visual impact considerations in sensitive locations but, by and large, Kilkenny’s landscape is manmade and seasonally changing and the County’s natural landscapes mainly comprise lowlands along the River Nore and the River Barrow.

For example, a landscape and visual impact Statement prepared by MarcroWorks Ltd for ART Generation Ltd, found the current wind energy to be overly cautious and excessively constrained for certain parts of the county. For some areas, they concluded that the land form and land use context could readily accommodate much larger wind energy developments (than currently provided for). Similar assessments should ensure that Kilkenny County Council can tailor its policies on renewable energy while protecting the landscape’s amenity and ecology.

Wind Energy Development

Caibidil: 

Section 9: Infrastructure

Question: How can the County Development Plan support the relevant external agencies in the provision of electricity, gas, water and wastewater, renewable energy and telecommunication and broadband infrastructure?

Support the relevant external agencies in the provision of renewable energy;

Kilkenny County Council can support external agencies by devising policy and creating strategic zones where value added is created. This can be achieved by combining the external agencies assets and interests in one area, especially where they overlap with national roads and areas with high potential for renewable energy. This could take the form of an enterprise zone and could be used for example to attract data centres. Please see recent Government statement 'Government Statement on the Role of Data Centres in Ireland's Enterprise Strategy'2.

Clean and green energy is now a primary enabler for foreign direct investment (FDI) and is becoming a 'must' condition for RE100 companies3. Kilkenny can be uniquely positioned to capture the spill over business (especially in data centres) from the greater Dublin area by assessing suitable areas for enterprise zones in proximity to renewable energy developments, along with gas, water and wastewater, telecommunication and broadband infrastructure. Kilkenny is a vibrant, attractive city with heritage and cultural amenities and is well positioned to attract FDI investments.

In addition, several state bodies have long involvement in rural communities and rural development and over time they have created man made landscapes over large areas. This can be seen with Bord na Mona in the case of harvesting the bogs and with Coillte in the case of rotating forestry. Such agencies should be encouraged to use their resources and land to also generate renewable energy. Project Ireland 2040 notes that forests play an important role in helping with climate change mitigation. Forestry is a major carbon sink and in combination with the generation of renewable wind energy could make a significant contribution towards national targets. We also understand that there are plans afoot for utilisation of farm biogas.

4. Feasibility of wind energy generation at scale in County Kilkenny

ART Generation has long experience of promoting and developing renewable energy projects and has methodically assessed the potential of all 22 areas identified as being suitable for wind energy generation in Kilkenny in Appendix J of the County Development Plan 2014 - 2020, ‘Wind Energy Development Strategy’ (WEDS).

By objective assessment of the wind resource, ease of grid connection, synergy with existing wind farms, separation distances from houses, landscape and environmental considerations, areas that have development potential for the development of small and large wind farms should be identified. Assessments undertaken by ART Generation found that there are a number of sites in the county that meet the criteria for the development of small and large wind farms. The identified areas with most potential comply with the following site selection criteria:

* Areas with a good wind resource.

* in relatively close proximity to the national grid where there is capacity to accommodate a wind farm and where it is straight forward to connect, ideally via

an existing 38kV sub-station.

* Area that is sparsely populated allowing good separation distances between houses and turbines.

Area that achieve significant setback distances to local and recreational amenities.

* Upland areas comprising mostly commercial forestry interspersed with pockets of marginal agricultural land, i.e. manmade landscape and does not contain

any of the protected views or highly scenic areas identified in the County Development Plan.

* Areas with generally modified habitats and not designated as being of ecological significance. Ground conditions and topography are favourable due to the

absence of steep slopes and deep peat.

* Areas with good road access for the transportation of major equipment.

Wind Energy Development

5. Planning Policy constraints on wind energy generation in County Kilkenny

We are heartened that ‘Kilkenny County Council supports the low carbon economy and the use of renewable energy for a cleaner future’, P25, (g) Renewable Energy.

However, in the current County Development Plan, although 22 areas in the county are identified as having wind speeds of 8m/s or more, 12 of the areas are deemed to be unsuitable for wind energy development, only 5 areas are designated as ‘preferred areas’ for wind energy development and the remaining 5 areas are designated as ‘open for consideration’. Kilkenny County Council policy to date has been successful in developing a number of wind farms, however the 'preferred areas' are now mainly optimised as regards their potential capacity and constraints. The main constraints are grid capacity.

Therefore ART Generation suggests;

 an assessment to re-designate and extend a select number of areas from 'open for consideration' to 'preferred'.

 assessment of additional areas as ‘open for consideration’.

 Removal of the 5 turbine and 5 MW thresholds in areas designated 'open for consideration'.

Wind farms in the areas open for consideration are “in usual circumstances” limited to 5 turbines or a capacity of 5 MW This is very restrictive and explains why no wind farms have been developed in the areas designated as ‘open for consideration’ in the current County Development Plan.

ART Generation sees no benefit in imposing a limit on the size of wind farms within the areas open for consideration but consider that environmental impact assessment and adherence to the Wind Energy Development Guidelines should be part of the determination of proposed wind farms with greater capacity than 5 MW in any area.

Wind farm developers are able and willing to undertake environmental impact assessment of their projects and do so in any event at project feasibility study stage.

6. Conclusion

The new Kilkenny County Development Plan can reflect the national policy objectives set out in the National Planning Framework (NPF), as well as European and national policies that aim to improve Ireland's renewable energy output and reduce carbon emissions in accordance with the EU objective of a low carbon society by 2050.

For example, the Department of Communications, Energy and Natural Resources ‘Strategy for Renewable Energy 2012- 2020’ and White Paper entitled ‘Ireland's Transition to a Low Carbon Energy Future, 2015-2030’ recognise that renewable energy development is central to overall energy policy in Ireland, as it has the potential to reduce dependence on fossil fuels; to improve security of supply; and to reduce greenhouse gas emissions, thereby creating environmental benefits while also delivering green jobs to the economy, thus contributing to national competitiveness.

Within this context, Ireland is legally obliged to ensure that by 2020 at least 16% of all energy consumed in the state is from renewable resources. The Irish Government has set an electricity target of 40% electricity consumption from renewable sources by 2020. An ambitious political agreement on increasing renewable energy use across Europe has just been reached in Strasbourg between negotiators from the EU Commission, the European Parliament and the Council (announced 14th June 2018). This agreement sets a binding renewable energy target for the EU for 2030 of 32% with an upwards revision clause by 20234.

To date Kilkenny County Council has overseen a number of of wind farm developments based on a balanced approach. Most of the sites originally identified as suitable for wind energy development have been harnessed and optimised in relation to grid capacity. There are now only a limited number of suitable sites available for wind energy development. As a result, due to certain constraints (e.g. grid capacity, land availability and access) there are only a limited number of sites that remain undeveloped. In order that Kilkenny County Council can continue to support Government policy regarding the promotion of renewable energy and reducing atmospheric pollution ART Generation suggests the following:

1. Reassess the existing areas designated 'Open for Consideration' and reclassify to 'Preferred' subject to compliance with the new Kilkenny County

Development Plan, DEHLG Wind Energy Development Guidelines 2006, or any subsequent related Guidelines (or as may be amended), and where

suitable grid capacity is available.

2. Expand the areas designated 'Open for Consideration' and 'Preferred' in order to harness the available resource in all suitable lands subject to compliance

with the new Kilkenny County Development Plan, DEHLG Wind Energy Development Guidelines 2006, or any subsequent related Guidelines (or as may

be amended), and where suitable grid capacity is available.

3. Remove the 5MW threshold for areas designated 'Open for Consideration' as standard turbines are and will be 4MW in size due to improvements in

technology. Turbines less than 1MW are no longer the norm.

4. Identify new sites as 'Open for Consideration' subject to compliance with the new Kilkenny

County Development Plan, DEHLG Wind Energy Development Guidelines 2006, or any subsequent related Guidelines (or as may be amended). Due to improvements in technology, lower wind speeds are no longer a constraint and sites with average wind speeds <8m/s are now viable.

It is generally accepted that the decarbonisation of the electricity system is the easiest way to deliver a decarbonised society and economy as it also enables the decarbonisation of transport and the heating of buildings. ART Generation hopes that the 2020 - 2026 Kilkenny County Development Plan will contain policies and objectives to allow the renewable energy sector to further develop in the county and contribute to Ireland meeting its targets in relation to the reduction of greenhouse gas emissions.

Yours sincerely,

CORMAC O’SULLIVAN

Architect/Planner

BLUETT & O’DONOGHUE ARCHITECTS

Faisnéis

Uimhir Thagarta Uathúil: 
KK-C63-CDP18-22
Stádas: 
Submitted
Líon na ndoiciméad faoi cheangal: 
0
Teorainneacha Gafa ar an léarscáil: 
Níl

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