Section 7.5: Wind Energy
In Paragraph 2 of Section 7.5 of the Draft CDP it is stated that the Wind Energy Strategy “has been prepared in accordance with the provisions of the Department of the Environment, Heritage and Local Government’s Draft Guidelines for Planning Authorities on Wind Energy Development (2019)”. There are further references to the Draft 2019 Guidelines in Section 15.11.1 and in the Wind Energy Strategy.
We would respectfully request that text referencing the 2019 Draft Wind Energy Development Guidelines for Planning Authorities is amended to reference the 2006 Guidelines and “any subsequent update of these Guidelines” in the interests of clarity and consistency with national policy. The text could be amended to mirror that included in Policy EC P4 with one minor change (in red) as follows:
“EC P4: Have regard to the Department of the Environment, Heritage and Local Governments ‘Guidelines for Planning Authorities on Wind Energy Development’ (2006) (or any subsequent updates) ……..”
Section 7.5: Wind Energy – Objective EC O15
We note the proposed inclusion of Objective EC O15 with respect to the inclusion of decommissioning and site rehabilitation plans as part of any wind farm development application. Decommissioning is currently addressed as part of the Environmental Impact Assessment Report for projects that exceed the EIA threshold. While we welcome the statement that disposal of end-of-life blades to landfill will not generally permitted, we do have concerns, given the circa 30 year life span of Wind Farm developments, that developers will not be able to provide specific details at planning application stage with respect to the recycling facilities and/or wind turbine repurposing facilities that will be used at end of life. We would respectfully suggest that this wording should be amended to state that sustainable waste management solutions should be explored for wind turbine components at end of life in compliance with the waste management hierarchy and the legislation and policy in place at that time.
Section 7.10: Strategic Energy Zones
Bord na Móna welcomes the inclusion of Policy EC P9 and Objective EC O35 with respect to the identification of Strategic Energy Zones in the County in co-operation with the Eastern and Midland Regional Assembly (EMRA).
It is stated in RPO 7.35 of the Regional Spatial and Economic Strategy (RSES) for the Eastern and Midlands Region that the Eastern Midlands Regional Assembly (EMRA), in conjunction with Local Authorities in the Region, will identify Strategic Energy Zones as “areas suitable for larger energy generating projects, the role of community and micro energy production in urban and rural settings and the potential for renewable energy within industrial areas”.
Bord na Móna believe that cutaway bogs play an important role in the generation of renewable energy and will continue to do so into the future. It is our intention to continue developing renewable energy projects on our bogs and our goal is to be the largest producer of renewable electricity in Ireland. Our sites 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 integrated[1] renewable energy projects and associated developments.
The suitability of cutaway peatlands for renewable energy developments in particular wind energy has been highlighted in theNational Planning Framework (Project Ireland 2040) and in the aforementioned RSES which states that “Bord na Móna peatlands …. have potential for beneficial uses including renewable energy, biodiversity, amenity uses, water storage and other infrastructure”. The RSES also states that “In the consideration of development on peatland areas, the following Guiding Principles should apply: Consideration of the potential contribution of peatlands to climate change mitigation and adaptation including renewable energy production”.
It is our view that the finalised CDP should be consistent with the National Planning Framework and the RSES for the Eastern and Midlands Region and that Chapter 7 should therefore call out and support the suitability of cutaway peatlands for renewable energy projects. By acknowledging this potential the Council would stand positioned to support appropriate commercial and industrial development on Bord na Móna lands secure in the knowledge that given the scale and spread of our landbank that suitable commercial and industrial development can be harmoniously co-located within a biodiverse and ecologically rich rehabilitated peatland landscape: as demonstrated by our wind farm at Mount Lucas in County Offaly and as proposed in the recently consented Bord na Móna/ESB Solar Farm project on Timahoe North Bog and as proposed in our wind farm development plans at Ballydermot Bog on the Kildare and Offaly border.
The development of renewable energy projects on these lands has the potential to make a significant contribution to national policies and objectives across a range of sectors including renewable energy, industrial development and job creation in rural areas, ecosystem services and biodiversity as well as tourism, amenity and recreation. As outlined previously in many cases a number of these uses can be co-located thereby providing enhanced economic benefits to the areas in which such developments are located through direct and indirect employment opportunities. The optimisation and the realisation of the full potential value of the company's land bank is dependent on national, regional and local planning.
[1] In this sense, ‘integrated’ includes where appropriate a combination of complimentary generation technology, energy storage, electrical transmission/distribution infrastructure, potential onsite large volume off-takers (e.g. data centres).