Wind Energy
Dear Sir/Madam,
Save the South Leinster Way Group welcomes the opportunity to make a submission to the Kilkenny City and County Draft Development Plan 2021-2027. As a community and natives of Kilkenny County who have no corporate, commercial or monetary interest in lands within County Kilkenny and sharing your desire to provide a robust, responsive and resilient Development Plan for the long term planning of the county, we the people of County Kilkenny can play a key role in shaping the concerns that the Draft Development Plan identifies, as having of both local and national significance that affect sectors throughout the County.
In order for Kilkenny County Council to realise its full potential from an environmental and community perspective, we ask the Council to consider whether the Draft Development Plans wind energy re-designations utilise County Kilkenny’s unique natural resources while maintaining the core values of County Kilkenny’s heritage, environmental and biodiversity protection objectives? As the Council prepare its next Development Plan which will cover the period from 2021-2027, we ask the Council to retain the current wind energy designations across the county. More specifically, we ask the Council to retain the Castlebanny area as ‘Open for Consideration’ to wind energy development and retain the current 5MW upper limit.
We request that Castlebanny (area 18) is not re-designated as ‘Acceptable in Principle’.
Our submission broadly focuses on identified issues and therefore is structured as follows:
1. Overview
2. Rationale
2.1 Environmental
2.2 Heritage
2.3 Community
2.4 Alternatives
3. Conclusion
1. Overview
Save the South Leinster Way Group was established as a non-profit community group in South County Kilkenny. We are committed to the protection of the natural heritage and biodiversity of the area and in doing so economic growth through heritage and tourism that the people of County Kilkenny have worked so hard to strengthen. We are dedicated to promoting and providing the resources and education needed to maintain Kilkenny’s natural heritage and biodiversity and to build a community where people value their natural environment and ensure others treat it with respect.
The Castlebanny area is designated as ‘Open for Consideration’ to Wind Energy carrying 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 recently a corporate company with commercial interests have managed to sidestep the area designation set by the development plan and bypass Kilkenny County Council for planning. The proposal called ‘Castlebanny Wind Farm’ (Reference No. 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 (quarries) for rock. The planning application was lodged under the designation of ‘Open for Consideration’ at the time of application, however the proposal is for turbines 4 x times the quantity and 1.5 x times the height of the allowance set by the development plan.
What is the purpose of any area designations within the County development plan if they are not adhered to?
There are countless concerning details surrounding the proposal called ‘Castlebanny Wind Farm’ including a lack of public consultation strategy, the planning application for a large scale wind energy development submitted under the area designation of ‘Open for Consideration’ in conjunction with the re-designation of lands at Castlebanny in the draft development plan, 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 River Arrigle Special Area of Conservation within the Natura 2000 Network for cabling, a plan to blast three onsite borrow pits (quarries) 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 to these river sources occur, what are the consequences for the Natura 2000 Network and the EU Annex I and II protected species within it?
2. Rationale
We seek to retain the current wind energy generation designation of ‘Open for Consideration’ in Castlebanny. We request the Castlebanny area is not re-designated as ‘Acceptable in Principle’.
The new climate emergency bill has identified offshore wind energy as the most efficient wind energy solution to Ireland’s climate crisis. Our government has committed to the rapid development of this technology early next year. It is premature to re-designate a vast biodiversity rich area within South Kilkenny for large scale wind energy generation when a more efficient and environmentally sensitive technology will be available offshore within the next 12 months.
The County Development Plan cannot not be assessed in the absence of an established National Wind Energy Strategy. There can be no change to the designations in the development plan in the absence of a National Plan.
2.1 Environmental
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. Particular plant, animal and bird species found in the county are considered rare or vulnerable and are protected by Irish and European Law. The EU Habitats Directive and EU Birds Directive provide for the conservation and protection of breeding and resting sites for rare and threatened species, and rare habitat types in a European perspective are considered to be most in need of conservation. 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. Three river sources begin in Castlebanny, should the very real risk of pollution to these river sources occur through intensive industrial construction required for a large scale wind farm, what are the consequences for the Natura 2000 Network and the EU Annex I and II protected species within it?
The green infrastructure the Natura 2000 Network provides safeguards numerous ecosystem services and ensures that Europe’s natural systems remain healthy and resilient. Castlebanny is home to many species of mammal, bats, birds, sensitive insects and butterflies and is rich in habitat vegetation. It is a vast and sophisticated network of ecologies living in harmony and which rely heavily on each other for survival. Many of which are protected under Irish and EU legislation. Save the South Leinster Way Group share in Kilkenny County Councils belief that ‘much of the biodiversity in the county occurs in the wider countryside, i.e., in areas which are not subject to legal protection under National or EU biodiversity law. These habitats and features are particularly important in contributing to the biodiversity, landscape value and sense of place of the county. They provide vital links and corridors to allow the movement of plant and animals between the network of protected sites. These features include: hedgerows, ditches and banks, stone walls, woodlands, estates and parklands, rivers, streams and associated riparian zones, reservoirs, ponds and canals. Such corridors or interconnected networks are the basis of our Green Infrastructure.’
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. Ireland is a signatory to several biodiversity laws and conventions, yet 85% of habitats have bad ecological status and two-thirds of our wild bird species are in trouble. A plan to drill the River Arrigle SAC and proposing to embark on extensive Industrial construction in an unspoiled naturally biodiversity rich area within South County Kilkenny would ultimately promote loss of life through species displacement and habitat degradation.
Save the South Leinster Way Group are committed to the Department of Communications Climate Action and Environments plan to plant twenty-two million trees each year with a target to plant 440 million trees over the next two decades to tackle climate change in Ireland. We believe that the planting of more native deciduous and CO2 absorbing trees is Ireland’s way forward for reducing CO2 and promoting biodiversity. Kilkenny can play a role in this development by encouraging and offering incentives for tree planting and land use. The proposed ‘Castlebanny Wind Farm’ EIAR identified a stand of broadleaved woodland and a group of five very mature trees approaching veteran status. They comprised two beech, two ash and one sessile oak ranging from 15-20 m in height.
The plan for a large scale development at Castlebanny would see the clear felling of 205 acres of established forest and the pouring of thousands of tonnes of CO2 loaded concrete into the natural area.
2.2 Heritage
Save the South Leinster Way Group are committed to promoting Irelands Historical Heritage while protecting South Kilkenny’s Natural Heritage. In the aftermath of the global pandemic County Kilkenny will play a key role in Ireland’s economic recovery. Natural, historical and cultural heritage and tourism in South Kilkenny go hand in hand. Tourism in County Kilkenny was estimated by Failte Ireland to be worth approximately €76m in 2015. Natural heritage is a significant asset and the County is marketed as a heritage destination. It has a large number of visitor attractions associated with both historical and natural heritage.
The National Trail the South Leinster way is internationally recognised. The 105km long trail attracts both National and International tourist to the region. Starting in Co. Carlow and finishing in Co. Tipperary it spans the entire county of Kilkenny from East to West and traverses Castlebanny for several kilometres. The South Leinster Way is a major player in tourism revenue for the county. Taking approx. 5 days to complete its normally a week long attraction for visitors to the region.
The Castlebanny area is abundant in 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.
There are two monastic structures within Castlebanny that hold international significance.
Saint Mo Ling (614–697), also named Moling Luachra, was the second Bishop of Ferns in Ireland and has been said to be one of the four great prophets of Erin. According to a manuscript in the Royal Library, Brussels, Mo Ling was descended from Cathaoir Mór, King of Leinster. Saint Moling was born in Mullennakill, Co. Kilkenny. From birth Moling stayed here, coming under the influence of Saint Brendan and the well in Mullennakill is said to be the site of his baptism. He spent his early period after conversion in that rather austere Celtic manner by living for some time in the cave, but he also spent some time gaining an education in or near Glendalough. Jerpoint Abbey is also close to this site. It was a Cistercian foundation and the monks there are credited with creating the worship around the saint. The feast day of their founder (Saint Bernard of Clairvaux) is also the 20th August. The site in Castlebanny holds significant importance for Kilkenny. The 8th Century St. Molings Gospels is held in the Early Irish Manuscripts Library of Trinity College in Dublin and St. Molings Shrine is housed at the National Museum of Ireland. Any intensive or extensive demolition work on or near this Holy site would undoubtedly cause destruction to this important monastic site in Kilkenny.
Castlebanny is of exceptional heritage importance for the county.
This special and distinctive location in Irelands Ancient East must not be overshadowed by large scale Industry.
Save the South Leinster Way Group share in the European Landscape Conventions European Wide concept centring on the Quality of Landscape protection, management and planning and we share in their recognition of the importance of all landscapes, and not just exceptional landscapes, as having a crucial bearing on quality of life and as deserving attention in landscape policy.
2.3 Community
Public Engagement is a key factor in the trust between any development and the community. Research shows that people are concerned with a fair process. People want to be invited to participate, be heard and taken seriously, and to have access to accurate information. The stage at which people are included in the process is also important. The community should be invited to participate in the process early on instead of after a plan is announced. Being open and transparent about the efficiency of wind energy as well as communicating that wind energy will not prevent our dependency on fossil fuels for energy generation is an essential precondition for genuine, honest and informed public debate. There has been a severe lack of public consultation surrounding the ‘Castlebanny Wind Farm’ proposal with a deficiency in transparent community engagement. Only homes within 2km of the development were informed of the proposals existence coupled with the submission of a planning application to An Bord Pleanala during National Level 5 restrictions the people of Kilkenny were not fairly informed of the scale and consequence of the proposal for the county. The people have been denied of any meaningful involvement. As a semi state body the developer should know that before any plans for development a thorough and full public consultation is necessary for open and involved community decision.
County Kilkenny has a proud reputation as a heritage craft county, not an Industrial county. There are 140 residential properties within 2 kilometres of Castlebanny and 5,000 residences in South Kilkenny. It is an area rich in craft businesses and forward thinking agriculture. It has been widely documented that the development of large scale industry within a natural heritage region leads to economic decline. Property devaluation has a knock on effect on local and county population and economic growth.
The re-designation of land and the development of large scale wind energy developments in South Kilkenny would devalue residential property, farms, land and business within the county, an estate agent report in line with online reports confirm. A de-valuation in the range of 30% to 40% has been conveyed.
The hospitality sector will be heavily relied upon in the aftermath of the global pandemic. Tourism in Ireland has the potential to double in size over the next 10 years and County Kilkenny can play a leading role in this growth. Surveys broadly document that visitors to County Kilkenny seek out its heritage and natural landscape as a getaway from big cities and industrial landscapes.
The re-designation of land and the development of a large scale wind energy industry in Castlebanny means that South Kilkenny would experience a drop off in visitors and tourism from those seeking out peaceful and natural retreats. The tourism and hospitality sector that the people of County Kilkenny have worked so hard to build and rely on would be affected by a down turn in property value and a drop off in visitors to the region. European surveys have found that visitors from large cities do not wish to exchange one manmade industrial vista for another and will favour regions that offer natural heritage and historical sites. The promotion of biodiversity and recreational green areas with the absence of large scale industry such as the Waterford Greenway and Tipperarys Blue Way have proved very successful in attracting tourism to those regions. This type of visitor catchment should be explored for South Kilkenny which already has a foundation rich in craft businesses and historical heritage including historic settlements, monuments and medieval, religious and secular sites.
County Kilkenny has an opportunity to build on this rich heritage foundation as an economic and population growth generator for the County but it needs to be designed in the absence of large scale manmade industrial structures that mimic high rise cityscapes.
2.4 Alternatives
We believe that Kilkenny is at a critical stage in terms of opportunity to transform how we plan to address our sustainable energy resources. Specifically sustainable energy that utilises resources by geographical location and South Kilkenny is ideally placed for this.
County Kilkenny has an opportunity to pave the way as Ireland’s leader in more efficient sustainable energy solutions. Especially 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. Four of these Solar Energy Farms have been granted permission within the Castlebanny area: 2 in Kiltorcan and 2 in Derrynahinch. Due to the geographical location of Castlebanny, Solar energy is the preferred and sensible form of green energy generation for the locality.
From an environmental perspective, a typical 5MW solar development would generate carbon savings of 1,750 tonnes per annum, the equivalent of the amount of carbon absorbed by 62,500 tree seedlings over 10 years. Solar sites have little or no landscape visual impact. Solar arrays are generally 2-3m in height and can be easily screened with hedgerows. They cause no emissions to air, soil or water and cause 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.
Solar energy is the preferred sustainable energy solution for South County Kilkenny. Large scale wind energy development would require the mass clear felling and excavation hundreds of hectares of biodiversity rich land, pouring thousands of tonnes of concrete and blighting the beautiful scenic landscape with Industrial Scale wind turbines. Why? When a more efficient, biodiversity welcoming and unoffending alternative to sustainable energy generation is available for the county in the form of Solar Energy.
Solar Energy should be promoted over wind energy across County Kilkenny. We have already set the bar in this technology by being the leader with Ireland’s largest photovoltaic solar energy installation on O’Sheas Farms in Co Kilkenny. The 960 individual solar panels installed in 2015 generate about 208,000kw of electricity per year, enough to power up to 40 homes. The solar panels on the roofs of the farm buildings help to power their refrigerated units, with the surplus sold to the national power grid. Already the biggest producer of renewable solar power in the country O’Sheas Farm was recently granted permission to install 2310 sq mts of PV solar arrays on to the roof of some existing buildings.
County Kilkenny, with its natural advantages of soil and climate, is among the most progressive farming regions in the country. County Kilkenny has an opportunity to tap into this existing resource to support and advance the solar energy strategy as a leader in sustainable energy for Ireland.
Save the South Leinster Way Group encourages Kilkenny County Council to take this opportunity to assess the potential that can be harnessed from large scale Solar energy developments to assist in meeting our climate change challenge.
We also take the opportunity to address the critical need for promotion and encouragement of energy reduction to decrease our CO2 footprint. Kilkenny County Council can shape and lower the energy use of the county by offering powerful encouragement through education, by offering notable incentives for home retrofit of solar heating and solar PV energy and by promoting energy reducing technologies.
3.0 Conclusion
We have a proud heritage and exciting future. We share Kilkenny County Council’s objective to manage our resources carefully and protect our biodiversity, support our citizens in safe communities and promote our heritage. Save the South Leinster Way Group continues to remain committed to supporting and helping to deliver on these objectives.
We believe that County Kilkenny is well placed to play a vital role in the protection of biodiversity and have proven to be central to the best of Ireland’s heritage. We wish to remind you that we are a future thinking and outward looking not for profit group with the best interest of County Kilkenny at our core. In all instances, we are committed to playing a pivotal role in protecting and preserving the County’s reputation as one of Ireland finest heritage locations that the people of Kilkenny have worked so hard to achieve.
We support Kilkenny County Councils commitment, to environmental stability which is central to the Development Plan. In this regard the Development Plan should prioritise and provide positive support for the protection of the biodiversity and ecological green infrastructure in County Kilkenny, with the interests of proper planning.
County Kilkenny can benefit from a multi-functional co-existence with green infrastructure and a high amenity value by carefully considering the social, economic and biodiversity impact a project may have on its surrounding area.
It unwise to re-designate a vast area of South Kilkenny’s heritage and biodiversity rich land to industry for large scale wind energy generation when a more efficient and environmentally sensitive technology of offshore wind energy has been identified by the new climate emergency bill, and our Government has committed to the rapid development of this technology early next year.
Corporate industrial interests should not influence the respected landscape of County Kilkenny. Premature decisions should not be looked back on with regret in the near future.
For the reasons we have set out, in order for County Kilkenny to realise its commitment to support the protection of biodiversity, natural heritage, and economic growth, we submit that the current designations associated with wind energy across the county be retained as part of the Kilkenny City and County Development Plan 2021-2027 and that the existing designation of ‘Open for Consideration’ be retained in Castlebanny.
We formally request that Castlebanny (area 18) is not re-designated as ‘Acceptable in Principle’.
We look forward to a County Development Plan that protects our biodiversity, strengthens our heritage and encourages the potential of County Kilkenny by its geographical location.
Regards,
Catriona Carroll
Save the South Leinster Way Group