D60 Wind Energy

The Irish Wind Energy Association (“IWEA”) is Ireland’s leading renewable energy representative body and as such has an active interest in the potential for renewable energy, and in particular wind energy and so IWEA feels it is critically important to make a submission to the Review of the Kilkenny County Development Plan process.
IWEA welcomes the opportunity to participate in the preparation of Draft County Development Plan 2014-2020. As this document will aim to direct the future growth of County Kilkenny over the medium to long term and assist in the assessment and decision making of planning applications for wind energy developments, IWEA very much welcome the opportunity to comment at this stage and remain at the disposal of the forward planning department should you wish to contact us in relation to any issue.
Submission to the Review of the Kilkenny Country Development Plan
In recent years Ireland has become heavily dependent on the importation of fossil fuels in order to meet its energy needs, with fossils accounting for more than 90%. This high dependency on foreign energy imports is unsustainable and Ireland is currently extremely vulnerable both in terms of meeting future electricity needs and ensuring price stability. Accordingly, the Department of Communications, Energy and Natural Resources’ (DCENR) energy policy has been moving towards greater levels of self-sufficiency, with renewable energy being a key part of the Government’s Energy Policy Framework 2007-2020.
Ireland’s need to support renewable energy also stems from it’s EU commitments, namely EU Directive 2009/28/EC on the Promotion of Renewable Energy Sources which came into force in April 2009 and which establishes a binding target of 20% of overall EU energy consumption coming from renewable sources by 2020 as well as a binding 10% minimum target for energy from renewable resources in the share of transportation fuels. Ireland’s target under the directive is for renewable resources to account for 16% of total energy consumption by 2020. Failure to meet these targets could result in EU sanctions. In line with these commitments, DCENR recently announced a revised target for electricity from renewable energy sources (RES-E) of 40% by 2020.
Economic Value
Ensuring the security of energy supply is also a key part of the Government’s Framework for Sustainable Economic Revival. Having regard to the current economic downturn, the framework acknowledges the need to put the energy/climate change agenda at the heart of Ireland’s economic renewal. Every new wind farm development provides a substantial contribution to the local and national economy through job creation, Local Authority rates, land rents and increased demand for local support services in construction, operation & maintenance, legal and accounting and project management. More wind on the system will also result in lower and more stable energy prices for consumers while helping us achieve our energy and emissions targets.
Projected Capacity
As the vast majority of new renewable capacity will be provided by on-shore wind, the 40% target is a significant challenge for the Irish wind industry as a whole. In March 2013, Irelands total installed wind capacity was 1,763MW, generated from 159 wind farms and with the capacity to supply electricity to 1.14 million homes.
County Kilkenny’s share of Irelands total comprises an installed capacity of just 10.25MW (As of Feb 2013). An estimated total of 4,000 – 4,500 MW of installed capacity is required to be installed on-shore in Ireland by 2020, in order to meet our RES-E target. This equates to an additional at least 2,250 MW of capacity.
It should be noted that the large scale expansion of the Irish wind industry will be an extremely positive economic development for Ireland and will result in greater grid security and stability, job creation, lower energy prices and bring about a reduction of GHG emissions. This expansion in a relatively short period of time will present a considerable challenge for local authorities, not just in the processing of planning applications for wind farms and grid connections, but also in terms of identifying and zoning lands suitable for wind farm development.
In identifying suitable zones for development, regard should be had to, among others things, the level of the resource, the nature of landscape, and the status of the surrounding lands and the Department of the Environment’s Wind Farm Planning Guidelines 2006.
Building larger and more efficient turbines mean fewer turbines overall. For some larger commercial turbines, a 10-15% increase in turbine height can increase the energy yield by up to 50%. These more efficient turbines, increase our ability to meet targets, reduce the amount of turbines needed and reduce the amount of raw materials required. When delivering the least cost solution to society, the grouping or clustering of wind projects in relatively close proximity on sites with suitable resource is crucially important to reducing cost to both developers and consumers. Well planned cluster developments enable developers to achieve lower average connection costs and reduce the costs and timelines of infrastructure delivery for the Grid Operator.
Specific Comments on the current Draft Kilkenny County Development Plan 2014 – 2020
We have reviewed the relevant sections of the draft plan; Chapter 10 Renewable Energy Strategy and Appendix J Wind Energy Development Strategy, in the context of the previous development plan policy - Wind Energy Development Strategy (WEDS) 2008.
In particular we compared the current WEDS Map 15 where the strategic/acceptable in principle areas are marked in red, with the new draft plan Figure 10.2, where the strategic/preferred areas are marked in green. We wish to comment that there is very little expansion to these strategic areas. In addition, the areas ‘open for consideration’ – marked yellow in each map, have been substantially reduced in this new Draft Plan. These restrictions will impede wind energy development in the County and are contradictory to current policy as stated in Section 8 of the WEDS 2008 where
- The boundaries of the current Strategy Areas will be reviewed once substantial wind energy development has occurred within them – with a view to extending the designated ‘Acceptable in Principle’ areas having regard to:
D) The alteration to the landscape character of the area due to the proximity of established windfarm projects
E) The requirements for alternative energy at that time
F) The configuration and availability of grid connections
The failure to expand the existing strategic areas to in any substantial way is not compatible with the Draft Renewable Energy Strategic Aim: To promote and facilitate all forms of renewable energies.
IWEA ask that the current restrictions be reviewed.
IWEA also submit that there should be a new policy statement for applications for wind farm developments in areas adjacent to the ‘Preferred’ and ‘Open for Consideration’ areas as designated in Figure 10.2 of the Draft Plan. This policy statement should allow that applications for wind farm developments adjacent to the strategic areas be open for consideration and assessed on their own merits.
IWEA hope that this submission will inform the new County Development Plan 2014-2020. We remain at your disposal if you have any questions on our submission above or on the current wind energy development position in Ireland.
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Irish Wind Energy Association
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