Uimhir Thagarta Uathúil: 
KK-C63-CDP18-30
Stádas: 
Submitted
Údar: 
Coillte
Líon na ndoiciméad faoi cheangal: 
0
Teorainneacha Gafa ar an léarscáil: 
Níl
Údar: 
Coillte

Observations

Coillte

Dear Sir/Madam,

1.0 Introduction

Coillte welcomes the opportunity to make a submission to the Kilkenny County Development Plan 2020-2026 Pre-Draft Issues Paper (Issues Paper). As custodians of 5% of Kilkenny County Council’s administrative area occupying some 10,850 hectares and sharing your desire to provide a robust, responsive and resilient Development Plan for the long term planning of the county, we believe that Coillte can play a key role in supporting the delivery the cross cutting issues that the Issues Paper identifies as being of both local and national significance which affects all sectors throughout the County.

We believe that Ireland is at a critical juncture in terms of the opportunity being afforded us to transform how we plan to address climate change and cater for forecasted population growth, thus providing a key building block for sustainable economic growth and competitiveness across the whole of the island. We are completely committed to Ireland’s decarbonisation agenda and the consequential requirement to reshape our economy in its entirety. Due to the nature of our land holding and our experience, we can make a signature contribution to the decarbonisation of the economy. We are also committed to supporting national and regional planning policy, including the objectives of the National Planning Framework (NPF) and the Regional Spatial and Economic Strategy (RSES) for the Southern Region.

1.1 Key Focus of Submission

In order for Kilkenny Co. Co. to realise its full potential from a social, economic and environmental perspective, we ask the Council to consider whether the current renewable energy designations inhibit or promote the core values and development objectives? As the Council starts to prepare its next Development Plan which will cover the period from 2020-2026, we ask the Council to take a fresh look at all existing renewable energy designations. More specifically, we ask the Council to review whether areas that are currently designated as Open to Consideration for wind energy development should be designated as Preferred or Strategically Suitable Areas and remove the current 5MW upper limit that currently applies to Open to Consideration Areas.

2

1.2 Structure of Submission

Our submission broadly focuses on three of the cross cutting issues that are identified in the Issues Paper, namely Sustainable Development, Climate Change and Social Inclusion. The submission is therefore structured as follows:

2.0 Overview of Coillte in context of Co. Kilkenny

3.0 Sustainable Development

4.0 Climate Change

5.0 Social Inclusion and Tourism Growth

6.0 Conclusion

2.0 Overview of Coillte in Context of Co. Kilkenny

Coillte was established as a commercial semi-state company in 1989, with a diverse forest estate of approximately 396,000 hectares of land. Over the last 29 years, the organisation has developed the forests and strategic elements of the land bank, has grown the estate to over 440,000 hectares, and today provides stewardship over approximately 7% of the total land mass of the country. During this time we have provided the public with a huge range of benefits from recreation, to critical infrastructure, to environmental services. Our Forestry business underpins a thriving export-led Forest Products Sector which support €2.31 Billion of economic activity. Coillte has approximately 900 employees across Ireland and the UK, with 180 of our employees based in Co. Kilkenny supporting indigenous employment and comprises three discrete businesses, Land Solutions, Forest and Medite Smartply (Panels) which delivered earnings (EBITDA) of €85.2 million in 2017. Our vision is to make Coillte the best forestry and land solutions company in Europe.

Renewable Energy Business

2.1 Coillte Land Solutions and Renewable Energy Businesses

Within Coillte, Land Solutions and Renewable Energy are active asset development and management businesses providing innovative commercial solutions to enable the attainment of key national policy objectives particularly those that will be prescribed by the NPF. The businesses span a wide range of industries including renewable energy, housing, healthcare, education, inward investment, infrastructure development, water, tourism and agriculture. Through a combination of Coillte’s longstanding heritage in the spheres of sustainability, recreation and community and our significant track-record in the renewable energy arena (specifically onshore wind through the development and construction of four wind farms totalling 230MW representing a total investment of over €400 million between 2010-2017), we believe that Coillte Land Solutions and Renewable Energy businesses have the experience and expertise to support Kilkenny County Council realise its vision as set out in the County Development Plan Pre-Draft Issues Paper.

Sustainable Development

2.2 Coillte’s Forest and Panels Businesses

Forestry in Ireland has the potential to double in size over the next 10 years and Coillte will play a leadership role in this growth. We use innovative technology in our supply chain and forest management practises are independently certified by FSC®2 (Forest Stewardship Council®) and PEFC™3 (Programme for the Endorsement of Forest Certification). Our forests and forestry products are also playing an increasingly important role in mitigating the effects of climate change. MEDITE SMARTPLY, our panels manufacturing business, is the market leading manufacturer of environmentally produced, sustainable timber construction panels. Exporting its products to over 30 countries, it also manufactures Smartply Propassiv in our plant at Bellview port Co. Kilkenny, which is the world’s first airtight panel, as classified by the Passivhaus Institute. In 2016 Coillte invested €60 million on innovative technology for the Smartply facility to expand both production capability and our range of products.

3.0 Sustainable Development

We support Kilkenny Co. Co.’s commitment set out in the Issues Paper that sustainability and in particular, environmental sustainability, will be central to the Development Plan. In this regard the Development Plan should prioritise and provide positive support for the development of renewable energy projects in Kilkenny, where appropriately located and in the interests of proper planning and sustainable development. Coillte is proud to be an established leading renewable energy developer in the state. To date, through our role as Landowner and developer we have enabled in excess of 40% of all operating wind farms which are delivering renewable energy to both domestic and industrial consumers. Coillte lands have enabled the development of Ballymartin, Lisdowney, Foyle and Ballybay wind farms in Co. Kilkenny. Our programme of operating wind farms provide enough renewable energy to power 300,000 homes.

Experience has proven that the profile of the Coillte’s lands possess some of the best wind regimes in Europe due, inter alia, to their altitude, expansive area, aspect and location. They are also particularly suitable for wind farms, large scale solar and energy storage projects due to their remoteness, already established accessibility for forest operations, distance from dwellings, proximity to the national grid infrastructure and the lower visibility amenity relative to areas with high scenic amenity.

Coillte lands have demonstrated multi-functional potential for co-existence use, including renewable energy, high amenity value and recreation. They provide a unique opportunity to create next generation added-value and innovative places. For example, in working to realise the potential of our estate for renewable energy developments, we carefully consider the social, economic and environmental impact a project may have on its surrounding area. As part of growing a sustainable business, we procure and afforest replacement lands to compensate for every hectare of land that may require tree felling to enable the future delivery of our projects. Coillte encourages Kilkenny Co. Co. to take this opportunity assess the potential that can be harnessed from suitable areas of the county to assist in meeting our climate change challenge and to further capture the range of benefits that follow for local communities, industry and for the broader national agenda.

Furthermore, in the context of sustainability, we recognise that the proper treatment and disposal of waste water is a key challenge to the sustainable growth and health of our nation. The existing modus operandi where approximately 400 waste water treatment facilities have no licence and are not monitored simply cannot continue and must be addressed as a matter of urgency. Integrated Constructed Wetlands (ICWs) can provide an environmentally friendly and cost effective solution to help address this problem, particularly for small agglomerations in rural locations, while also providing an enhanced recreational amenity. Certain Coillte lands can provide locations for the development of this proven technology across a range of sectors including agriculture, food, residential and rural towns.

Climate Change

4.0 Climate Change

It is well understood that urgent action is now required if Ireland is to meet the twin challenges of:

1. The growing demand for renewable generation4: Both large and small consumers are seeking greater innovative solutions to secure their renewable energy needs. Indeed, it has become particularly clear that the availability of a sustainable supply chain and particularly green energy is now a top priority for many influential companies in the commercial and industrial sector. Such as the companies which are part of RE1005. In deciding how to provide for the economic prosperity of the County, attract inward investment and provide for the employment needs of its growing population, Kilkenny Co. Co. needs consider how best to ensure that it can meet with the growing demand for renewable energy.

2. Legally-binding commitments: There are challenging timeframes within which Ireland must meet its legally-binding commitments under the existing EU and domestic legislative frameworks. In its most recent assessment, the EPA has projected that Ireland will fall significantly short of its 2020 targets under the EU Effort Sharing Decision No 405/2009/EC.6 We know that the effort required to meet our 2020 targets is substantial, particularly in terms of the heat and transport sectors. In its most recent report, the SEAI has confirmed that Ireland could fall short of the 2020 16% renewable energy target in all three scenarios modelled.7 The challenges associated with our 2020 targets are further augmented by the legally-binding commitments made under the 2030 Climate and Energy Framework. Indeed, the latest Clean Energy for All Europeans legislative package confirms and tightens our current commitments and therefore the underlying investment and effort that is required to achieve them.8 We need to adopt a step change in our approach to decarbonisation over the coming five years and beyond if Ireland is to avoid falling behind, impairing our attractiveness as an economy and diminishing our prosperity.

Coillte plays a critical role in contributing to the reduction of greenhouse gas emissions, enhancing Ireland’s energy security and contributing to a post-carbon and climate resilient economy. Our website (www.coillte.ie) contains further details regarding all of our projects. We believe that the decarbonisation of the electricity system is the single best catalyst to delivering a decarbonised social and economic environment as it fundamentally enables the decarbonisation of transport and heat through electrification, both of which have proven to be extremely challenging in the period to 2020.

As set out in Section 1.1 above, the key focus of our submission is our concern that the potential for renewable energy and specifically future onshore wind farm development in Co. Kilkenny is currently restricted by a set of criteria that initially was put in place some years ago when considering technology that has been outdated. This is supported by the fact that there are no wind farms operating in the current areas designated as ‘open for consideration’ for wind farm development in the current plan.

4 For further detail please see EirGrid’s Tomorrows Energy Scenarios 2017 http://www.eirgridgroup.com/site-files/library/EirGrid/EirGrid-Tomorrows-Energy-Scenarios-Report-2017.pdf

5 http://there100.org/companies

6http://www.epa.ie/pubs/reports/air/airemissions/ghgprojections/EPA_2017_GHG_Emission_Projections_Summary_Report.pdf

7 https://www.seai.ie/resources/publications/Irelands_Energy_Projections.pdf

8 For example, see Proposal for a Regulation on the Governance of the Energy Union (Article 27 (4) (c) at http://eur-lex.europa.eu/resource.html?uri=cellar:ac5d97a8-0319-11e7-8a35-01aa75ed71a1.0024.02/DOC_1&format=PDF

Social Inclusion and Tourism Growth

We aim to provide a positive experience for those living in the locality of a Coillte Wind Farm, not only from a sustainable energy perspective, but also from a local development perspective. To-date we have developed bespoke wind farm Community Benefit Schemes for communities close to our wind farms for the 25 year lifetime of the project. We always look to complement each benefit scheme with an enhanced recreation and tourism offering for the relevant host community of our renewable energy projects.

In Co. Kilkenny, we have identified that there are significant opportunities for this type of development in the South of the County, particularly along the South Leinster Way. There is particular merit for future sustainable development in this part of the county due to the strong infrastructure connectivity already established here i.e communications, road, grid and port accessibility.

The standards that we have set through our work on the development of ‘Community Benefit Schemes’ are recognised as being a national exemplar and a significant contributor to achieving what the NPF describes as ‘Excellence in Rural’. We are the first development company in Ireland to combine an operating wind farm, commercial forestry operations and enhanced amenity and recreation facilities with public access in one location. We are committed to being national leaders in the area of community engagement and as part of this process we have built up expertise in community engagement models, capacity building and the development of community benefit funds.

The design of the scheme is unique to each project and is moving towards a participatory model where the design is driven by the community that both administer and utilise the scheme. The scheme can include: contributing to the improvement of local recreational amenities; supporting local projects that benefit the wider community; and, engaging with local communities in enhancing sustainable energy awareness, use and efficiency. We are further innovating to find ways that enable us to support community based energy efficiency schemes and models which can support community ownership structures within future wind farm developments.

6.0 Conclusion

We have a proud heritage and exciting future. We share Kilkenny County Council’s objective to manage our resources carefully and promote sustainable growth, support our citizens in safe and sustainable communities and protect our environment. Coillte continues to remain committed to supporting and helping to deliver on these objectives.

For the reasons we have set out in Section 1.1, Section 3.0, Section 4.0 and Section 5.0, in order for Co. Kilkenny to realise its commitment to support sustainable developments, we submit that the current designations and the historical limits associated with planning designations of areas across the county need to be reassessed as part of the County Development Plan review in order to ensure we can work together to help Ireland to meet its reduction in greenhouse gas emissions targets.

We believe that Coillte lands are well placed to play a key role in the necessary and planned growth and prosperity of our nation and have proven them to have excellent multi-functional and valuable capabilities. We wish to remind you that we are a future thinking and outward looking commercial semi-state partner that is fully aligned to government and EU policy in terms of our approach to proper planning and sustainable development. In all instances and wherever the opportunity arises, we are committed to playing a pivotal role in the innovative and sustainable management of our natural resources.

We have demonstrated responsible leadership across a vast variety of projects. We are committed to the realisation of a better spatially planned nation and adding value to ‘Ireland Inc.’ through our shared aim of planning for the right development to take place in the right places at the right time. Our proven in-house capabilities and expertise can help deliver a better Ireland.

We look forward to the development of a County Development Plan that maximises your county’s potential. We would be happy to engage in dialogue with the Kilkenny County Council at any stage in relation to any specific matters arising.

Faisnéis

Uimhir Thagarta Uathúil: 
KK-C63-CDP18-30
Stádas: 
Submitted
Líon na ndoiciméad faoi cheangal: 
0
Teorainneacha Gafa ar an léarscáil: 
Níl

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