Wind Energy

The Planning Department, Kilkenny County Council

Draft Kilkenny City and County Development Plan

To whom it may concern,

Thank you for this opportunity to make a submission to the Kilkenny City and County Draft Development Plan.

I am extremely concerned at the proposed re-designation of areas across the county for wind energy (section 11.5) specifically Castlebanny (area 18). In the Kilkenny City and County Draft Development Plan there appears to be a vast specific region within South East County Kilkenny re-designated as 'Acceptable in Principle' for large scale wind industry.

I reside in Ballytarsna and I believe that Castlebanny and the surrounding townslands of South County Kilkenny need to be protected for their natural herigate, biodiversity and rich landscape. Therefore I am requesting that Castlebanny (area 18) is Not re-designated as ‘Acceptable in Principle’ for wind energy developments.

• The Castlebanny area is designated as ‘Open for Consideration’ to Wind Energy in the County Kilkenny Development Plan. This carries a category allowance of ‘Small Scale Wind Development’, that can comprise of no more than 5 turbines at a height of less than 65m and max. output of 5MW. It is quite concerning that a company with commercial interests have recently managed to sidestep the area designation set by the development plan and bypass Kilkenny County Council for planning permission. The proposal called ‘Castlebanny Wind Farm’ (ABP-309306) was submitted directly to An Bord Pleanala seeking to construct 21 turbines at a height of 185 metres each, a 100 metre mast, an onsite substation, several ancillary buildings and three onsite borrow pits for rock. It is quite concerning that the proposal for turbines 4 x times the quantity and 1.5 x times the height of the allowance set by the development plan has managed to side step Kilkenny County Council. There are countless concerning details surrounding the proposal called ‘Castlebanny Wind Farm’ including a lack of public consultation strategy, a plan to place the 185 metre high offshore scale wind turbines within 750 metres of dwelling houses and within 2.8km of Ballyhale Pre School and National School, a plan to drill the Special Area of Conservation within the Natura 2000 Network for cabling, a plan to blast three onsite borrow pits for rock in a Sandstone Quarts area of Kilkenny. There is no public water supply in rural Kilkenny with each home having their own private well for potable water. Should a very real risk of pollution to the aquifer occur through the immense scale of construction required, how do the people of South Kilkenny acquire clean drinking water? Three river sources begin in Castlebanny, should the very real risk of pollution occur to these river sources, what are the consequences for the Natura 2000 Network and the EU Annex I and II protected species?
• A number of areas in County Kilkenny have been identified as being of exceptional importance for biodiversity at a national and/or international level and are protected through national and European legislation. Natura 2000 sites form part of an EU network that are ecologically significant. The Castlebanny area includes the Natura 2000 Network of the River Arrigle Special Area of Conservation (SAC), selected for the conservation and protection of plant and animal species and habitats listed in Annex I and Annex II of the EU Habitats Directive and the River Nore Special Protection Area (SPA) selected for the conservation and protection of rare birds and their habitats designated under the EU Birds Directive. Both the SAC and SPA of the Natura 2000 Network are within in the Castlebanny area re-designated as ‘Acceptable in Principle’ in the Kilkenny City and County Draft Development Plan. The River Arrigle SAC was selected to protect the Freshwater Salmon and Otter under Annex II of the terrestrial and coastal & inland species and the River Nore SPA was selected for the protection of the Kingfisher under Annex I of the EU Birds directive.
  All of which are living and breeding within the Natura 2000 Network in South Kilkenny. The Castlebanny Area is home to many species of Mammal, Bats, Birds, sensitive insects and butterflies and is rich in habitat vegetation. Many of which are protected under Irish and EU legislation.
• The defective fish pass that was granted planning permission and completed on the River Nore in 2004 saw fresh water salmon stocks decimated in the years that followed. Salmon on the River Nore were prevented from swimming upstream to spawning grounds, blocked by the new weir which was installed as part of a flood prevention scheme. It was called a "fish pass", but for the salmon supposed to use it in one of Ireland's most famous rivers, it was barrier as it only worked when the river level was unusually high. After travelling all the way from the North Atlantic to spawn upstream in the Nore’s tributaries and having survived predators, trawlers, drift-nets, poachers and anglers - a man-made weir was to prove their end. Fish who did not make it were found dead downstream. Remedial works were carried out and completed in 2006. It was reported afterwards that the cost of the engineering works, designed to prevent flooding in Kilkenny was originally estimated at €13 million but had risen to approx. €50 million. The River Arrigle (SAC) was selected for the protection of Freshwater Salmon and Otter under Annex II of the terrestrial and coastal & inland species. Can Kilkenny afford to pose another biodiversity risk to the Natura 2000 Network and the EU protected Fresh Water Salmon?  With the recent report that Irelands National Biodiversity Plan Failed to Halt Loss of Life, Ireland now needs to repair its reputation as a leading protector of Biodiversity in line with this National Plan. County Kilkenny is well placed to play a vital role in this recovery. It is most important that we are observed to be doing all we can to promote and protect Biodiversity within the county.  Industry on a large scale in an unspoiled naturally biodiversity rich area within County Kilkenny would ultimately promote loss of life through habitat degradation.
• Large scale wind industry in Castlebanny would have a highly dominant visual presence on a vast area within County Kilkenny and within the South East, being visible into counties Wexford, Waterford and Tipperary. Castlebanny and indeed South Eastern Kilkenny is most famous in natural and historical Heritage. Locations that attract National and International visitors each year to the county such as Mount Juliet Estate, Jerpoint Abbey, Jerpoint Park, Woodstock Estate and Gardens. Irelands National Trail The South Leinster Way is internationally recognised. It is a 105km trail that spans county Kilkenny from its borders East to West and traverses Castlebanny. The idyllic views that greet visitors to the South Leinster Way as well as Ireland’s Ancient East, The Nore Valley, The Arrigle Valley, the Waterford Greenway, the Foothills of the Backstairs Mountains and Brandon Hill should not be replaced by the sight, sound and shadow flicker of commercial wind turbines.
• The South Eastern Uplands of Kilkenny is a landscape rich in heritage and includes historic settlements, monuments and medieval, religious and secular sites. The area is rich in historical sites listed by the National Monuments Service on the Record of Monuments and Places. There is a particular concentration of megalithic structures such as ringforts, standing stones, Fulacht Fiadh and Megalithic tombs in the surrounding landscape of Castlebanny. Located within Castlebanny is St. Molings Well and Cave. St Moling, who lived there in the 7th Century later founded the monastery in St. Mullins and ultimately became Lord Bishop of Ferns. People travel from far and wide for the healing waters from the well. Both structures are very important heritage locations in Kilkenny. County Kilkenny’s Heritage is envied throughout Ireland. It should not be replaced by mass industrialisation.
• Geology Mapping reports show the Castlebanny area bedrock is Sandstone Quartz. Crystalline Silica is a hazardous component of sandstone quartz dust, a known carcinogen, recognised by the Internationally and by the Health & Safety Authority to cause Silicosis and can lead to cancer. Crystalline Silica Dust particles as small as .01 to 100 μm in diameter and 10 microns or less in length are a significant health concern and are generated during construction work such as excavating, blasting, drilling, crushing and haulage of stone that can disperse the dust in the air for many kilometres onto public and private property, onto skin, inhaled into lungs. The fine Crystalline Silica dust can be washed into watercourses and also permeate the aquifer thus potentially creating a high level of pollution to potable water. Extensive and intensive construction in Castlebanny should be avoided for this reason.
• The thoroughbred horse industry in Ireland directly employs over 14,000 people and thousands more indirectly, making an economic contribution of more than €1 billion each year. The effects of wind turbines on thoroughbred horses has been widely documented. In section 11.5.3.6 Wind Energy Development Management & Guidance of the Kilkenny City and County Draft Development Plan it states “In particular, the provisions of the Wind Energy Guidelines in relation to noise and flicker will apply to registered thoroughbred stud farms” . Stud Farms in Kilkenny are a multi million Euro industry for the County. Foreign investors in the bloodstock industry have previously warned that developments of electro turbines are not conducive to the raising of top quality bloodstock in the areas in which they are built, and that windfarms in Ireland would affect foreign investment. There is a particular concentration of prominent thoroughbred stud farms and equine facilities in South Kilkenny with four listed on the Stallion Trail. One of which is placed within 2km of Castlebanny. It is important that this industry is safeguarded within the County.
• Kilkenny has an opportunity to pave the way as Ireland’s leader in more efficient sustainable energy solutions. Specifically sustainable energy that utilises resources by our geographical location. County Kilkenny currently has 13 approved solar farm developments, each potentially providing 4 to 5 MW of power and four of these Solar Energy Farms have been granted permission within the Castlebanny area: 2 in Kiltorcan and 2 in Derrynahinch. Due to Castlebannys geographical location in the sunny south east, Solar energy is the preferred and sensible form of sustainable energy generation for the locality over wind energy. Solar sites have little or no landscape visual impact as Solar arrays are generally 2-3m in height and can be easily screened with hedgerows. They causes no emissions to air, soil or water and causes no noise and are typically inert, with a negligible environmental impact. Electricity is produced at low voltages and therefore poses no health risks to the public or livestock. The absence of fertilisers and chemical based substances on the land also allows flora and fauna to thrive and enhances biodiversity. Little or no concrete is used in solar farm construction making them easy to reverse. The land can be restored, generally in a better condition, with enhanced biodiversity. Solar farms support agricultural activity such as grazing small livestock and increase and diversify farming by providing a stable source of revenue over the lifetime of the solar project. This in turn ensures the viability of farming for decades to come and encourages the next generation of farmers to keep farming the land. It makes no sense to clear and excavate thousands of acres of biodiversity rich vegetation, disturb EU protected habitats and blight the beautiful landscape of County Kilkenny with a large scale wind farm when a more efficient and biodiversity friendly alternative to sustainable energy is available for the county.
• The re-designation of lands in the Kilkenny City and County Development Plan is premature in the absence of a firm National Wind Energy Strategy. There can be no change to the current development plan without a National Plan.

The Castlebanny area is currently designated as ‘Open for Consideration’ to Wind Energy. This must continue to be the case. Furthermore the St. Molings Well and St. Molings Cave should be listed as protected structures.

I am formally requesting that Castlebanny (area 18) is Not re-designated as ‘Acceptable in Principle’ for wind energy developments.

County Kilkenny has a reputation as one of Irelands finest and most respected heritage locations.

Let’s keep it that way.

Regards,

Catriona Carroll