Bord na Móna Submission - Renewables, Rehabilitation and Recycling

Uimhir Thagarta Uathúil: 
KK-C162-336
Údar: 
Bord na Móna
Stádas: 
Submitted
Líon na ndoiciméad faoi cheangal: 
0
Teorainneacha Gafa ar an léarscáil: 
Níl
Údar: 
Bord na Móna

Litir Chumhdaigh

Planning Office,

Kilkenny County Council,

County Hall,

John Street,

Kilkenny

R95 A39T

12th March 2021

Re: Submission on the Draft Kilkenny County Council Development Plan 2021 – 2027.

Dear Sir/Madam,

Bord na Móna welcomes the opportunity to make a submission in relation to the Draft Kilkenny County Development Plan 2021 - 2027.

Since its foundation Bord na Móna has been part of the socio-economic and cultural fabric of County Kilkenny. The company has circa 590 hectares of landholding in the county and has contributed to economic development and employment in the county and in doing so supporting many communities throughout the County.

As a global community we are faced with the challenge posed by climate change and as a society we have acknowledged the need to meet this challenge. In keeping with this, Bord na Móna is committed to decarbonising its business and while we have embarked on this journey some time now, the pace of this transition has increased in recent years and continues to increase at pace. In January 2021, the company announced the cessation of industrial peat extraction across all of its lands. This is a very significant step for Bord na Mona. The impact this transition is having on the communities which we support, and the wider economy and social fabric of Kilkenny is not lost on us. As we continue this challenging journey we are committed to repurposing and applying our assets, not least our land assets, to support and develop the future economy of Kilkenny.

However, with these challenges come opportunities, some which we have identified such as in the area of renewable energy, more of which are in development such as biogas and more still at an early stage of internal assessment. In finalising the new County Development Plan, it is important that we not close the door to the range of future commercial and job creation opportunities which may be supported by Bord na Móna’s land and property assets within the county.

In this context it is important to reflect on the nature and uniqueness of our landholding. While somewhat fragmented in geographical spread, much of the company’s estate is characterised by large tracts of land. This is a somewhat uncharacteristic feature in the context of Irish landholding and therefore offers unique opportunities for a multitude of uses not readily suited to smaller dispersed landholdings. Most of our peatland has been utilised for industrial peat extraction for decades and consequently much of the overlying peat deposits has been cutaway. The cutaway will be stabilised through the implementation of a rehabilitation programme with significant portions of these lands rewilding and supporting biodiversity and other ecosystem services. We believe that it is possible to successfully integrate this emerging biodiverse and amenity rich landscape with other commercial, industrial and employment generating uses.

This is exemplified in the transformation of Templetouhy bog on the Kilkenny, Tipperary and Laois border. This site has changed from a site with a single use (peat harvesting) to one hosting a rich mosaic of complimentary activities. Over the last decade the 42MW Bruckana Wind Farm has been developed at this site and supplies over 25,000 homes with renewable electricity while providing a sustainable income which in turn supports significant local community investment. With the wind assets occupying a mere 5% of the overall site footprint, this rehabilitated cutaway has helped significantly mitigate carbon emissions and also developed into a rich ecosystem with a range of different habitats for native plants and animal species.

In 2011 Bord na Móna published its long-term land use strategy, Strategic Framework for the Future use of Peatlands. Much of the strategy outlined in this framework document still holds true and is relevant; however, with the significant and accelerated change that has taken place in the intervening period and with the emergence and identification of new potential future land uses, we have engaged in a review of this framework. We expect to publish a revision of the Strategic Framework in the coming months and it will be made available to all stakeholders.

The consultation process for the Draft Kilkenny County Development Plan invites submissions across a broad range of important topics and we believe Bord na Móna can make significant positive contributions across many of these areas. In particular, we believe we have a significant role to play in delivering on climate action, energy policy (in particular the provision of decarbonised energy), supporting biodiversity, growing tourism, fostering the establishment of new, sustainable industrial and commercial development and supporting rural and urban regeneration.

This submission will provide commentary on the Draft Plan in addition to information on how Bord na Móna is working to support and deliver National, Regional and Local policy, objectives and targets.

Yours Sincerely,

Lisa Kealy

Bord na Móna Land Use Manager

Observations

Bord na Móna welcomes the content and policies outlined in Chapter 2 which sets out Kilkenny County Councils commitment with respect to Climate Change, Decarbonisation and transitioning to a low carbon and climate resilient County.

 

We welcome the Councils strategic objectives with respect to climate change, in particular:

2A: To support and encourage sustainable compact growth and settlement patterns, integrate land use and transportation, and maximise opportunities through development form, layout and design to secure climate resilience and reduce carbon emissions.

2B: To support the implementation of the National Climate Action Plan and the National Climate Action Charter for Local Authorities, and to facilitate measures which seek to reduce emissions of greenhouse gases by embedding appropriate policies within the Development Plan.

2C: To promote, support and direct effective climate action policies and objectives that seek to improve climate outcomes across the settlement areas and communities of County Kilkenny helping to successfully contribute and deliver on the obligations of the State to transition to low carbon and climate resilient society.

Bord na Móna has supported the above objectives in relation to climate change with its lands in Co. Kilkenny (Templetouhy, Derryville and Baunmore Bogs). 

  • Bruckana Windfarm was developed on cutaway at Templetouhy, which is partially in Co. Kilkenny.   This is an example of sustainable land-use that supports the National Climate Action Plan. Bruckana Windfarm is an excellent example of how renewable energy infrastructure can be integrated into a cutaway landscape.  While renewable energy infrastructure does require drainage, re-wetting is still feasible and there are several examples of re-wetted areas adjacent to renewable energy infrastructure at Bruckana.  
  • Bord na Móna carried out a rehabilitation programme across its Littleton properties in 2018-2020.  Cutaway in Co. Kilkenny including at Templetouhy, Derryville and Baunmore bogs has been re-wetted and rehabilitated.   These sites are now revegetating and in time will develop naturally. Templetouhy is an excellent example of the new cutaway peatlands landscape that will develop in the future, which will be a mosaic of bog woodland, re-wetted peatland habitats and renewable energy infrastructure. Re-wetting residual peat reduces carbon emissions from these areas.  These bogs are not expected to develop as carbon sinks in the short-term and will develop as reduced carbon sources. There are indications that carbon sinks could develop at Templetouhy (development of small amounts of Sphagnum-rich vegetation).  
  • Bord na Móna are working with Coillte on a native woodland project that could be applied to those areas of cutaway that cannot be re-wetted, or where it is not appropriate to re-wet (marginal lands and headlands).  The key objective of this project is to establish and accelerate the development of native woodland that would have climate action benefits.  The Bord na Móna/Coillte Native Woodland Project is currently carrying out native woodland establishment trials in Baunmore bog and it is planned to expand the native woodland footprint at this site in the future.        

 Many of the strategic objectives are very closely aligned with the objectives of the aforementioned ‘Strategic Framework for the Future Use of Peatlands’ document and previous commitments made by Bord na Mona in the National Peatlands Strategy and other national policy and strategy documents, and our ongoing transition to diversify into new sustainable business areas in order to strengthen the company and support jobs in the midlands into the future.

Central to this sustainable transition is the use of our land bank for a range of beneficial commercial, environmental and social uses such as renewable energy, industrial uses (including but not limited to data centres), biomass cultivation, aquaculture, herb cultivation, ecosystem services and biodiversity as well as recreation and tourism. In many cases these uses can be co-located thereby providing enhanced benefits to the areas in which such developments are located.

 

Future commercial and industrial potential

Bord na Móna has played, continues to play and has the potential to play a significant role in the economic development of the County. As set out earlier, with the unique nature of our landholding, industrial, remote and with access to key infrastructure; opportunities exist to support industries that require scale which is not readily achievable elsewhere in the country let alone the county.

As part of the land transition programme, Bord na Móna is continually reviewing its property strategy to determine future industrial uses for the holdings. Whilst buildings such as workshops and stores comprise a small portion of the holding, these buildings present opportunities for the re-purposing of these facilities for new sustainable industries. In recent months, the company has repurposed its former briquette production facility in Littleton in County Tipperary as a plastics recycling facility supporting 40 new jobs. Similar opportunities will exist for more of our facilities as we exit peat extraction and in this regard we welcome the intent of policy CPO10.23 which seeks to “support the repurposing of the Lough Ree Power Station and Bord na Móna Mount Dillon infrastructure and associated work depots for alternative uses in association with the Just Transition process”.

Where possible the industrial potential of Bord na Móna’s property will be harnessed to support job creation, whether a proposed project requires the provision of buildings, sites, infrastructure, green energy or other industrial uses.

 By acknowledging this potential the Council should stand positioned to support appropriate commercial and industrial development on Bord na Móna’s land and can do so secure in the knowledge that suitable commercial and industrial development can be harmoniously co-located within a biodiverse and ecologically rich rehabilitated peatland landscape: as demonstrated by our property at Mount Lucas in County Offaly and as proposed in our wind farm development in Bruckana.

 

Brown to Green Strategy

We welcome the policies and objectives relating to open space and recreation and in keeping with our Brown to Green strategy Bord na Móna through its land holding in County Kilkenny has the potential to enhance tourism and community amenity initiatives by providing connectivity and access to a rehabilitated landscape. This is addressed later in our submission in the section entitled ‘Heritage and Culture’

Now as we transition away from peat extraction further significant opportunities to enhance expand and develop an integrated network of greenways across our peatlands will emerge. In some cases, future company commercial and renewable opportunities will first need to be considered but the potential exists to provide links with the broader network across the county. Our experience to date demonstrates how both Greenway Infrastructure (amenity) and renewable opportunities can co-exist successfully, for example our Mountlucas facility in Co. Offaly where an 84MW Wind Farm project co-exists alongside rehabilitated cutaway and 10km of walking/running/cycling tracks for people living in the local communities.

Rehabilitation of our Peatlands

9.2 Natural Heritage and Biodiversity

Bord na Móna carried out a rehabilitation programme across its Littleton properties in 2018-2020.  Cutaway in Co. Kilkenny includes Templetouhy, Derryville and Baunmore bogs.  In addition to re-wetting residual peat and reducing carbon emissions, new naturally functioning peatland habitats are in development.  Already, Baunmore Bog has significant biodiversity value and is being used by breeding waders under pressure in the wider landscape, such as Lapwing and Ringed Plover.    This site is also an important wetland in the winter and is used by roosting Whooper Swans.  Marsh Fritillary Butterfly has also been recorded recently in Baunmore Bog (on the Killkenny side) and is just one indicator of the high biodiversity potential of these developing peatland habitats.  Some drained bog remnant at Clonsaul Townland (Baunmore Bog has particularly high biodiversity value as it is secondary fen habitat and supports a diverse range of plant and animal species.  This area (in BnM ownership) was also recently restored (drains blocked) as part of the Bord na Móna Littleton Bog Rehabilitation programme.  

The connectivity between these bogs also provides significant green infrastructure potential that can be developed in future.  There are several proposals for amenity development along the old bog railway and this can be positively integrated into the cutaway landscape without significant trade-offs to the other ecosystem services (climate, biodiversity, water).    

Bord na Móna have an extensive baseline ecological survey of its lands with detailed habitat maps already prepared.   Rehabilitation Plans have been developed for each bog that highlight specific areas of high local biodiversity value.   

Bord na Móna are working with Coillte on a native woodland project that could be applied to those areas of cutaway that cannot be re-wetted, or where it is not appropriate to re-wet (marginal lands and headlands).  The key objective of this project is to establish and accelerate the development of native woodland that would have climate action benefits.  Baunmore Bog has been selected to be part of this project.  In addition to delivering climate action benefits, the development of native woodland will also provide significant new habitat for a wide range of species.   

 

9.2.8 Peatlands:

We refer to the following text in Section 9.2.8 of the Draft Plan:

“Damage to peatlands can occur from domestic peat extraction, afforestation, wind farms, recreational activities  and  invasive  species”.

and

“The Council will protect peatlands from inappropriate development having regard to their amenity and biodiversity value and their visual sensitivity.”

It is our view that cutaway peatland sites are particularly suited to renewable energy development. In that context, we would encourage that the importance that cutaway bogs have in terms of renewable energy generation is recognised. These lands are brownfield in nature, have limited environmental constraints and are largely removed from large numbers of sensitive receptors. They are also in close proximity to the national grid and have good road access. These factors make them prime sites for the development of large scale renewable energy projects and we feel that this should be reflected in the finalised County Development Plan in order to ensure consistency with the objectives and policies of existing National and Regional Plans.

As outlined previously Bruckana Windfarm was developed on cutaway at Templetouhy, which is partially in Co. Kilkenny.   This is an example of sustainable land-use that supports the National Climate Action Plan and National and Regional policies. Bruckana Windfarm is an excellent example of how renewable energy infrastructure can be integrated into a cutaway landscape.  While renewable energy infrastructure does require drainage, re-wetting is still feasible and there are several examples of re-wetted areas adjacent to renewable energy infrastructure at Bruckana.  

Water Framework Objective

We welcome the Councils strategic objective with respect to the Water Framework, in particular:

10.1.8 Water Framework Objective: 10B

It is an objective of the plan to implement the measures of the River Basin Management Plan, including continuing to work with communities thought the Local Authority Waters Programme to restore and improve water quality in the identified areas of action.

 

Peatland rehabilitation and re-wetting also has other ecosystem service benefits, including to water quality of the downstream catchments.   The decision of Bord na Móna to cease peat extraction in the Littleton Bog area supports the goals and objectives of both the National River Basin Management Plan (Water Framework Directive) and the NoreVision Project.  While Knockahaw Bog is in Tipperary, bog restoration at this site indirectly supports the NoreVision Project, as this is partially in the River Noe catchment.  Bog restoration at Knockahaw was completed in 2018. 

The National Transmission/Distribution network

 

10.3 Energy 

We agree with the text outlined in Section 10.3.1 with respect to The National Transmission/Distribution network.

In order to achieve European and National objectives for a competitive, low carbon, climate-resilient and environmentally sustainable economy by 2050, new energy systems and transmission grids will be necessary for a more distributed, renewables-focused energy generation system, harnessing both the considerable on-shore and off-shore potential from energy sources such as wind, wave and solar and connecting the richest sources of that energy to the major sources of demand.

EirGrid has a significant programme of transmission projects in various stages of development required to facilitate the connection of contracted large-scale renewable projects, which will play a vital role in meeting our targets. However, it is also clear that further large-scale transmission projects will be required to:

1. Facilitate the connection of additional on-shore and off-shore renewable projects; and

2. Connect major sources of demand to renewable energy.

It is our view that demand side management and the electrification of heat and transport coupled with small scale renewables will bring a limited amount of control at a local level. In that context transmission development will continue to be required to facilitate the connection of projects of scale. Similar to other leading countries in terms of renewable penetration, there should be a focus on delivering grid access to the best renewable projects in those locations with the optimum capacity factor. Investment in grid development for a project occurs only once, whereas supporting projects with inferior capacity factors can lead to higher costs to the consumer over the life of a project.

In many cases investment in grid development in remote or rural areas could have a twofold benefit:

1. Providing grid access for the most efficient renewable projects; and

2. Developing grid access to a level suitable for large demand outside of the 5 main cities.

 

Renewable Energy targets and constraints

11.5.2. Wind Energy Development Strategy

The National Climate Action Plan (CAP) 2019 has set out an ambitious 70% target for renewable energy production out to 2030. To meet this target, the amount of electricity generated from renewables will have to be doubled on current figures.

The Wind Energy Development Strategy is a strategic document and at that level it is appropriate to apply high level assumptions. However, from our experience with developing wind energy projects and the associated detailed environmental reports and assessments that are required, it is evident that often areas that have been identified at a high level as not being suitable for wind energy development would benefit at a site specific level from the same characteristics as an area considered suitable. This is also evident in the reverse.  In this context, careful consideration needs to be given to the zoning of areas for renewable energy development going forward, so as not to constrain out any areas which may have renewable energy potential, particularly for wind generation. Such an approach will assist developers in bringing projects forward to contribute towards the 70% target for renewable energy production out to 2030.

Section 4.1 of the Wind Energy Development Strategy addresses wind speeds and makes reference to the Sustainable Energy Authority of Ireland (SEAI) Wind Atlas 2013. It is our view, given advances in turbine technologies over recent years, that the SEAI Wind Atlas or any similar general wind resource data should not be used as a constraint for zoning areas for renewable energy development. This is a constraint that should be assessed on a project by project basis. As technologies have advanced, turbines have been developed which can yield the same energy from lower wind sites than their older counter parts.

On a similar note, we also request that in parallel with the development of a Renewable Energy Strategy, that the Council reviews the Landscape Character Assessment for the County to ensure a consistent approach to the determination of lands that are suitable for the development of wind energy projects in the County. This parallel review will result in greater clarity regarding the suitability of lands for wind energy development and will assist developers eliminate uncertainty at project inception stage.

 

Revised Draft Wind Energy Development Guidelines (2019)

11.5.3 Development Management Guidance

While we welcome and concur with the content and many of the policies and objectives outlined in Chapter 11, which support renewables projects in County Kilkenny we are concerned that the draft plan relies on the requirements of the Revised Draft Wind Energy Development Guidelines (2019) which have not yet been adopted. When these Guidelines were published in draft form for public consultation in 2019, the Wind Industry raised serious concerns about some elements of these guidelines. An updated version has not yet been published. It is our view that the finalised County Development Plan should not directly lean on the detail of these draft Guidelines until such time as they are formally adopted. Therefore, we would respectfully suggest that the finalised plan includes the following wording:

“All planning applications for wind energy developments shall be assessed against the DEHLG’s publication Wind Energy Development Guidelines, 2006, (and any subsequent update of these guidelines) and the County Council’s Wind Strategy.”

Faisnéis

Uimhir Thagarta Uathúil: 
KK-C162-336
Stádas: 
Submitted
Líon na ndoiciméad faoi cheangal: 
0
Teorainneacha Gafa ar an léarscáil: 
Níl

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