WildKildare Submission on CDP (Biodiversity, Peatlands Park and Wind Energy Mapping)

Uimhir Thagarta Uathúil: 
Stephen James O'Byrne
Líon na ndoiciméad faoi cheangal: 
Teorainneacha Gafa ar an léarscáil: 
Stephen James O'Byrne

Litir Chumhdaigh

WildKildare(I am acting Chairperson) is a conservation NGO operational in the county since 2017. Bringing together individuals with deep knowledge and skills in the areas of Ornithology, Botany, Entomology etc. it was founded by the late Paddy Sheridan and has been central to key conservation projects from the county wide Swift nest box project to projects on Red Listed Bird species such as the Ballyteague Bog Curlew project. We have also undertaken a large body work in recording and education initiatives that has significantly expanded knowledge of biodiversity within the county. From our work we have identified peatlands(both intact and recovering) the majority currently managed by Bord Na Mona, as key biodivestiy hotspots and critical in the protection of the counties rarest and most threatened flora and fauna. This fact and the destructive threat of poorly planned/located renewable energy projects in these areas is the focus of our submission to the new county CDP as well as our support for the National Peatlands Park initiative. In light of this our submission focuses on the most relevant parts of the CDP in that regard


Comments on Chapter 1 as it relates to Peatland Park Proposals and proposed Wind Energy Mapping


Chapter 1WildKildare welcomes the thrust of chapter one in terms of the setting out of a Strategic Vision that mentions “enhancing our natural environment for future generation”.  The Policy Context 1.4  also   mentions key EU and international policies of relevance including EU Directives on Habitats, EIAS etc. 1.4.1 Points 1,3-7,16 and 18 all relevant and highly compatible with the Peatland Park objectives as is 2 of the 3 “Key Principles” in 1.4.3


Concerns: 1.7.3 Mentions SEA,EU Directives and AAs – was the wind energy zonings in Appendix 2 subject to these mandatory assessments??  Paragraph in AA section strongly suggests there are issues in regards to that ,which brings in the topic of what we consider inadequate buffer zones with regards to wind energy projects near environmentally sensitive areas – our concerns in this regards are further heightened by the fact that it is mentioned that such assessments are still “being carried out” despite the fact that the windfarm zonings become “official” ahead of such assessments being completed!!


SFRA(Flood assements) are still being carried out too and clarity is needed here if the findings will be included in the final CDP, especially given the apparent ongoing artificial pumping of peat silt laden water from recovering BNM bogs in parts of the county(and elsewhere as recently highlighted by the Mid Shannon Wilderness Park group on BNM bogs adjacent to the Shannon which have been shown to be damaging previously recovering vegetation and dependent red listed species such as Lapwing)


1.9 Mentions the Role of the “Planning Regulator” – an entity which unfortunately has not seen fit to ensure compliance in this area with SEA,AAs and other relevant EU Directives,  when Bord Pleanala decisions have been found to be in violation of same by the ECJ as in the Derrybrien, Keeper Hill cases etc,


WildKildare Observations on Chapter 7 as it relates to Peatland Park Proposal and Windfarm zonings


Chapter 7  WildKildare notes that ECO50, O53, O54, O55, and O56 are all of relevance to the National Peatlands Park plan with direct mention in EC A7


7.12.7 is very welcome as it recognises the potential of Kildare’s industrial peatlands in terms of Biodiversity services, wild areas, flood management, conservation etc.

Concerns EC O2  -  we would submit the objectives here haven’t been achieved based on the current wind farm sensitivity/planning  Map in Apendix 2


EC O3 – Again the aims here have clearly failed over the years with the current planning approach and national guidelines on same


EC 06  - to date developers have treated this provision with barely disguised contempt/lip service across the country ie. a cynical box ticking exercise, as highlighted by Bord Na Monas current approach to windfarm planning in regards to the Ballydermot Proposal that has ignored the vast majority of feedback on the shortcomings of its current planned scale and design. Similar issues have arisen with their treatment of communities in other parts of the country including Longford and Mayo. 


Sec 7.5 Refers to appendix 2 where key map of windfarm “sensitivity” with an explanation of the Zone 3 criteria. The concern here is that it claims to take into account the likes of wildlife, habitats, bird migration routes. This is clearly not true given what has been recorded on these matters by WildKildare and other similar NGOs within the county and what info is available on the likes of the National Biodiversity Date Base.

Wildkildare comments and concerns relating to Peatland Park Proposal and Wind Farm mapping in Chapter 12

Chapter 12:  Wild Kildare welcomes the references to key EU Directives and AAs. 12.4 mentions the EU Biodiversity Strategy and 2030 goals of which 30% of land set aside for nature is the most important. In that context the Peatland Park vision will be key to achieving such measures. Good to see reference to Aarhus Directive too given the current governments plans to weaken citizen rights in this area despite having been repeatedly warned by the EU about the roadblocks and costs to citizens seeking their environmental rights in the planning sphere etc.


12.5.3  WildKildare consider key actions here to be BI A1, BI A2 and BI A3


12.8  Policy on County Biodiversity Sites chimes with PPark aims, notably BI P5


12.14.4  Green infrastructure: BI A22 directly mentions Peatland Park and BNM role in its establishment. Includes reference to “Core Areas” to achieve this ie. off limits to windfarms presumably ??



Concerns 12.6  Discusses the Nature Network, but are policy actions like BI P2, BI O5 and BI O7 reflected in the Appendix 2 Wind Farm Sensitivity Map?? Don’t appear to be!!


12.7  Protected Habitats and Species outside of Designated Sites. This is obviously extremely important regarding Peatland Park aims and the shortcoming of current Wind Energy Land Zoning within the CDP. Key policies here include BI P4 , BI O10, BI O13 in sec 12.7.1 in terms of windfarm planning


12.11  Emphasises the importance of wetland sites that are undesignated but important for Annex 1 species and Habitats. Again this needs to be reflected better in KCC proposed windfarm location guidelines. Sites of importance mentioned in Table 12.5.  “Highly Rated” Sites of relevance include Barrow Canal, Lodge Bog, Lullybeg(BCI Reserve), Lullymore West, Grand Canal, Ballydermot, Bog Allen Nature Reserve, North of Heritage Park, Lullymore Cutaway, Killinthomas Wood, Gets deeper into these “Core Areas” mentioned above in terms of the Bog of Allen and the high biodiversity of recovering cut over peatlands in the Ballydermot complex. Mentions nature based carbon storage too but also BNM intentions in terms of Wind Farms within the same complex – obviously this is problematic given BNM current Ballydermot Windfarm design and conflicts with “Core Area” protection aims. Thankfully though it mentions a large area of key sites within the Ballydermot that are “Core Areas” incl Lullybeg Wetlands, Heritage Park, Lodge Bog etc. and nearby Canal Corridors. However this is undermined by the last sentence which states that only “50%” of the Peatland Area will remain “free from any development” – obviously this last sentence needs removal!!  Outside of the Ballydermot complex Kilberry, Narrghmore and Umeras bogs mentioned in the same context. Again though 50% figure is stated which is obviously problematic in terms of aims of Peatland Park and would be no doubt “exploited” by BNM in terms of its aggressive windfarm plans in the area!!


12.14.8  Discusses major Green Corridors like Grand/Royal Canal, River Barrow etc. but again this clashes with lack of windfarm planning set backs in Appendix 2 for these same areas!! Peatways – Mentions more substantial set backs here of 1000m but these are still inadequate given the current scale and size of wind turbines. Goes on to outline where these Peatways are to be located which matches up with Peatland Park proposals

WildKildare comments and concerns relating to Peatland Park proposal and proposed Wind Farm zonings

13.2.1 Mentions the importance of landscape views and prospect and provides for designations like Landscape Conservation Areas(LCA) and Areas of Special Amenity(ASA) to receive high priority in CDP – these should feed more into Wind Farm Appendix 2 map!!

LR O6 Usefull for Peatland Park aims and objectives as is LR O11 and LR O12




LR A1 Recognises that the 2004 landscape assessment is outdated and inadequate and commits to updating it within the next 2 years. But this is problematic as the Wind farm sensitivity Map in Appendix 2 is based on that older outdated assessment!!


LR T1 Hugely important!! and specifically mentions Peatlands Park in the context of achieving 30% EU biodiversity strategy


LR P2  Important statement here in the context of the many positive outcomes of getting the Peatlands Park over the line.     


13.6        Scenic Routes and Protected Views This section is obviously of relevance in protecting canal and bogland routes. Area Nos 7,8, 16, 18 and 34  all of relevance to Peatlands Park . Table 13.7  includes these and Canal Views of relevance                


13.6.1   Countryside Recreation     Mentions many of the activities which the Peatlands park would provide in abundance  


13.6.2 Acknowledges   the role of recovering peatlands for nature based carbon storage, biodiversity, rewilding and amenity value etc.


13.6.4 Greeways, Blueways, Peatways and Trails The value of the Western Boglands highlighted here under all those headings   




LR O38, LR O40, LRO41 and LRO42 all critical to Peatlands Park full establishment and Objectives as are LR O62 and LR O65 




13.3  Landscape Character Assessment : this may be problematic as it is based on outdated data from 2004


13.3.1 Landscape Sensitivity The highest “Sensitivity Classes” ie 3-5 lack adequate setbacks or buffer zones in relation to windfarm zonings as out lined in Table 13.2. Peatland areas outside of these Sensitivity Classes are also vulnerable to such inappropriate developments


13.3.2 Impact of Development on Landscape This is highly problematic as the buffer zones as laid out here for Class 3-5 landscapes are grossly inadequate eg. less than 300m!! in Table 13.4 when it should be 5km at least in the case of windfarm development as is the case in other countries


LR O2 Again buffer zones here are inadequate in relation to windfarm development being only 500m in this case!!

LR O13 Problematic as it doesn’t recognise the immense Biodiversity of many of these cutover peatlands




LR A1 Recognises that the 2004 landscape assessment is outdated and inadequate and commits to updating it within the next 2 years. But this is problematic as the Wind farm sensitivity Map in Appendix 2 is based on the older outdated assessment!!



WildKildares Observations and Comments on proposed Windfarm Zoning in Appendix 2


Concerns relating to Appendix 2 (Wind Farm Sensity Mapping)


Sec.1.2  Makes some claims on reneweable energy that are at variance with the facts when it comes to wind energy.


2.1.2  Refers to the “European Green Deal” but no mention of its Biodiversity targets or aims  Mentions the 2006 wind energy planning guidelines which even the government has deemed outdated. A plan that bases landscape zonings on this criteria is clearly flawed in advance of the long delayed new guidelines this government has promised


Table 1, Step 3 :Sensitity Analysis:  Has the key statement “consideration of any wind energy development in or near these areas(natural heritage) must be subject to Irelands obligations under international, EU and national legislation. There is a lot to unpick here given the number of violations committed by the state since 2000 with regard to wind energy developments. Examples include the Derrybrein and Keeper Hill cases where the European Court of Justice found against Ireland. It is highly unsatisfactory that the sensitivity map presented in Appendix 2 appears to be deficient on many of these fronts regarding this states obligations under the EU Birds, Habitats etc. Directives.


2.4.3 Landscape Character Assesment : Appears to conflict with attached Map since the Western Boglands are classed as “High Sensitivity” yet this is not reflected on Map coding in many areas


2.5.2  5th paragraph make questionable assumptions based on “data” provided by industry lobbyists WEI


2.6  Concerns history of wind planning in the county. Makes a mention of the reasons the Umeras wind farm was turned down (DOD critical low level route in support of Air Corps) yet proposed wind farm sensitivity map takes no account of this decision nor the matters raised!!


3.0  Claims that SEA abd AA processes have “informed” design of the map but this is questionable as existing data on birds and habitats etc. appears to have been ignored!!


3.2.1 WildKildare would argue that the conclusions in paragraph 3 here are outdated and deficient in terms of the need for buffer areas etc. around sensitive habitats, locations etc.


3.3.1 Problematic as it fails to include the necessary buffer areas required to protect the “qualities” of designated sites etc.


3.3.5  The conclusions here in terms of the map are not reflective of the realities in terms of what is needed to comply with the stated aims in terms of Natural Heritage etc.


3.4.2 Refers to “Aviation Constraints” yet map is not reflective of Umeras decision or the general concerns of the Air Corps


3.4.3 IMO a “Developer led” conclusion here.


4.1  “Acceptable in Principle” zone description lacks necessary reference to date on Annex 1 bird migration routes, presence etc. “Open for Consideration” again lacks the necessary safeguards referred to above or buffer zones around EU designated sites and other “sensitive” areas


4.2 Buffer zones around the likes of Canal/Barrow Blueways are clearly wholly inadequate on sensitivity MAP


4.3 Highly problematic as this proposed Zoning does not take account of the footprint of our Peatlands Park as supported and referenced in the CDP


6.22 Bats and Birds: Problematic as the factors here do not appear to have been taken into account with respect to the coding on the wind farm sensitivity map eg, no provision of buffers around sensitive/designated sites or important Annex 1 bird species flight corridors etc.


6.24 (Biodiversity Maps)Similar issues to 6.22 above in relation to flaws in wind farm sensitivity map as presented.


6.26 : Paragraph on “modified and degraded” peatland habitat fails to take into account the biodiversity richness of these sites and their potential and actual hosting of red listed bird species like Curlew and Snipe that are proven to be significantly negatively impacted by operational wind turbines. Obviously this is of particular relevance to the Peatland Park proposal that is recognised and supported elsewhere in the CDP


6.30 : Cumultative Impacts of Wind Farms: This needs firming up given the proliferation of proposed  and granted wind farms in bordering counties(Notably Offaly) that are in and around sensitive peatland sites (both intact and recovering). Again sensitivity zoning on wind farm map do not adequately address this issue, particularly in West Kildare.




6.3 Consultation with Local Community : This is failing badly in most cases eg. Umeras,Drehid, Derryadd etc. and is merely treated as a cynical box ticking exercise by most wind developers. It is also disappointing that KCC or the consultants who produced the Appendix 2 wind farm sensitivity map undertook any community or NGO consultation prior to its publication


6.31 Aviation Requirements : No apparent consultation with Air Corps here??








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