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