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.