10. Renewable Energy Strategy

10   Renewable Energy Strategy

Strategic Aim: To promote and facilitate all forms of renewable energies and improvements in energy efficiencies as a response to climate change. 

10.1   Introduction

Renewable energy sources are defined here as inexhaustible natural resources which occur naturally and repeatedly in the environment. These sources include the wind, oceans, plant life and falling water.

This Renewable Energy Strategy for the County Development Plan was prepared in conjunction with the Carlow-Kilkenny Energy Agency, having regard to the Methodology for Local Authority Renewable Energy Strategies[1].  This Strategy consists of four elements.  First, the policy context for all renewables is outlined.  This is followed by an analysis of each type of renewable energy within the county, covering three aspects as follows:

  • An analysis of the resource potential and existing operations,
  • An outline of development management guidelines including potential impacts  and
  • Policies for their future development. 

 

10.2   Carlow-Kilkenny Energy Agency

The Carlow Kilkenny Energy Agency was established to provide sustainable energy information, support and services to the people of Carlow and Kilkenny, to local businesses and community groups and to the Local Authorities.  The objectives of the Agency are achieved through five focus areas:

  1. Energy awareness and dissemination campaigns 
  2. Energy Management for the Councils 
  3. Energy efficiency and renewable energy projects 
  4. Sustainable energy training 
  5. Energy Policy Development 

The CKEA has over ten years experience in supporting energy efficient and renewable energy projects for public and private clients, in particular for community developments. 

 

10.3   Kilkenny Sustainable Energy Forum

The Kilkenny Sustainable Energy Forum was set up in early 2007, as the result of an action identified under the County Development Board Strategy 2002-2012.  This Forum is composed of various statutory bodies, non-governmental organisations and industry and construction representatives, amongst others.  The Forum aims to promote the use of sustainable energy in Kilkenny, by supporting sustainable energy initiatives, providing best practice examples and through advocacy. 

10.4   Policy context

The main driver for the implementation of renewable energy policy is the Renewable Energy Directive[2].  Ireland is legally obliged to ensure that by 2020, at least 16% of all energy consumed in the state is from renewable sources, with a sub-target of 10% in the transport sector.  This directive requires that each Member State adopt a national renewable energy action plan (NREAP) to be submitted to the European Commission.

Ireland submitted its National Renewable Energy Action Plan[3] to the European Commission in July 2010. The plan set out national targets for the share of energy from renewable sources consumed in transport, electricity and heating and cooling in 2020, with actions to meet the overall national target (Figure 10.1: National and European policy drivers). 

 

The Strategy for Renewable Energy 2012 - 2020[4] sets out the Government’s approach to the development of renewables in terms of strategic goals and key actions.  Strategic goals include progressively more energy from wind power and a sustainable Bioenergy sector.  Renewables in Ireland are supported by means of the Renewable Energy Feed in tariff (REFIT)[5].  REFIT was first announced in 2006 and three REFIT schemes have been rolled out to date, which all have provided support for renewable technologies. 

10.4.1   South East Regional Authority Bioenergy Implementation Plan

At regional level, Bioenergy Implementation Plan 2008-2013[6] has been produced by the South East Regional Authority.  This set a target of 5% of Total Final Consumption in the region to be provided by bio-energy by 2010, to increase to 17% by 2020.   This Plan is being updated at present.  The overall objective of the project is to raise awareness and to increase the production and consumption of bio-energy in the Region.

The Council will support the implementation of national and regional renewable energy targets and work with all relevant agencies to support the development of alternative forms of energy.  

10.5   Wind energy

The sun heats the earth unevenly, creating thermal air currents. In order to achieve equal temperatures around the earth these air pockets move about the earth as global wind. Energy that travels in the wind can be captured and converted to provide electricity through turbines. Turbines can be located onshore and offshore.

 

10.5.1   Current status

To date, a total of 7 wind farms have permission in Co. Kilkenny, three of which are constructed, see the table below.  

Table 10.1 Status of Wind farms in Co. Kilkenny

No.

Planning Ref. no.

Wind Farm name

Applicant

Townland

No. Turbines

Built?

Status/Gate app. ref.

1

10/145

Bruckana

Bord na Móna

Rathpatrick, Bruckana & Baunmore, Johnstown

8

Yes

Gate 3 TG 84

2

05/1256 11/461 12/378

Foylature

Art Generation

Foylature, Courtstown, Tullaroan

 

 4

 

No

Gate 3 DG157

3

02/1072

08/735 12/194

12/533

Ballybeagh

ART Generation Ltd.

Ballybeagh, Tullaroan

 

 

5

 

No

 

Gate 3 DG131

 

4

03/158507/2140

 

Ballymartin Phase 1

Bord Gáis Energy/

Paul Martin/

ART Generation Ltd.

Ballymartin, Smithstown

3

 

 

Yes

 

Built

5

07/2141 10/576

 Ballymartin Phase 2

 

Bord Gáis Energy/

ART Generation Ltd.

Smithstown, Tullogher

4

No

 

6

03/1117

07/2253 08/595

 

 

Rahora

Ecopowers Developments Ltd.

Guillkagh More, Brownstown 

 

 

5

 

Yes

Built

 

 

 7

08/151112/172

Lisdowney Community

Matt Bergin and Thomas McEvoy

Lisdowney Ballyragget

 4

 No

Gate 3 DG285

 

10.5.2   Wind Energy Development Strategy

A Wind Energy Study was first carried out by CAAS (Environmental Services) Ltd. for Kilkenny County Council in 2003.  This Study was reviewed and updated as a Wind Energy Development Strategy for the 2008 Development Plan.  As part of this Plan, the strategy has been revised; see Appendix J for the full Strategy. 

10.5.3   Development Management Guidance

All wind farm applications will be assessed in accordance with the Wind Energy Development Guidelines[7] and the Wind Energy Development Strategy, as outlined in Appendix J.  This has divided the areas of highest wind speeds in the county into three wind strategy categories, see Figure 10.2 as follows:

  1. Preferred
  2. Open for consideration
  3. Unsuitable

The 6 areas identified as ‘Preferred’ all correspond to the Hilly and Flat Farmland landscape category as outlined in Section 6.9.2 of the Guidelines, so the layout of such windfarms should correspond to the guidance. 

Pre-planning public consultation

Applicants for small or large scale wind farms shall be required to engage with the local population in the vicinity of any proposed wind farm, prior to lodging their application.  Such consultation shall follow the format of Appendix 2 of the Wind Energy Development Guidelines.  

Residential amenity

The two main impacts on residential amenity from any wind farm development are noise and shadow flicker.  These two elements must be examined as part of any application.  The Guidelines indicate that noise is unlikely to be a significant problem where the distance from the nearest turbine to any noise sensitive property is more than 500 metres.  Where any proposed distance between a wind farm and neighbouring offices or buildings is less, the Council will look for additional noise and shadow flicker mitigation. 

Ground Conditions/Geology

In accordance with the Wind Energy Development Guidelines, information on the underlying geology shall accompany any wind farm development application. 

Any impacts on birds or rare flora, mammals, amphibians and fish need to be assessed. 

Access to grid

Details of consultations with the electricity transmission operators regarding the nature and location of a proposed grid connection should be submitted as part of the pre-planning consultation.

Proximity to Roads and Railways

At a minimum, turbines shall be set back a distance equalling the blade tip height of the turbine from National and Regional roads and railways.  Set-back from other roads will be site specific and determined at application stage.

Interference with communication systems

Any wind farm applicant should contact individual broadcasters to inform them of the proposals.  A list of the licensed operators is available on www.comreg.ie.  Mobile phone operators should also be informed.  Contact should also be made with the Irish Aviation Authority.  The outcome of such consultations shall accompany planning applications. 

Landscape Impact Assessment

All applications shall be accompanied by a Landscape Impact Assessment Report, as set out in Appendix 3 of the Wind Energy Development Guidelines

 

10.5.4   Wind Energy Policy Areas

Wind energy developments can be divided into four categories depending on their scale, as follows:

  1. Individual wind turbines
  2. Autoproducer
  3. Small scale wind developments (5 or less turbines and output less than 5MW)
  4. Large scale wind developments

The county has now been divided into three policy areas for the development of wind farms, based on an assessment of viability against other considerations; Preferred, Open for Consideration and Unsuitable.  A matrix is set out below outlining which of the various category scales will be considered in each Wind Strategy area. 

Strategy area

Preferred

Open for consideration

Unsuitable

Rest of county

Project category

Individual turbine

Y

Y

Y

Y

Auto producer

Y

Y

Y

Y

Small scale wind farm

Y

Y

X

X

Large scale wind farm

Y

X

X

X

 

Detail on the project categories and policies for their development are set out below.

(a) Individual Wind Turbines

It is recognised that landowners may wish to harness wind energy for private use.  Planning applications for individual wind turbines (subject to a limit of 1 per holding) shall be considered throughout the county. 

(b) Autoproducer

An “Autoproducer” is where an industry/large energy user uses a wind turbine to feed its own energy consumption.

These will be considered throughout the county subject to the following:

  • The turbine proposed is for a significant energy user,
  • The location of the turbine is within the curtilage of the facility or immediately adjacent.
  • The site already contains significant development to reduce the visual impact of the turbine(s).

(c) Small-Scale Wind Energy Developments

In the policy areas identified as being ‘Preferred’ and ‘Open for Consideration’ in the Wind Energy Strategy Map (Figure 10.2), the following proposals will be considered:

  • Comprising no more than 5 turbines,
  • Where the total output is not greater than 5 Megawatts,
  • Turbine heights do not exceed 65m to hub height

(d) Large-Scale Wind Energy Developments (>5MW)

Large-scale wind energy developments will, in usual circumstances, only be considered in ‘Preferred’ areas.  The rationale behind this policy is to minimise the visual impacts of such large scale developments, in addition to effects on the environment of County Kilkenny as a whole, as well as to facilitate appropriate grid connections.  These will be assessed in accordance with the Wind Energy Development Guidelines

 

Note:

S.I. No. 83 of 2007[8], Planning and Development Regulations set out that a single wind turbine which meets the standards as set out (to include turbine height not more than thirteen metres, and rotor diameter of six metres and other standards as detailed in the Regulations), is considered to be “exempted development” which does not require planning permission when placed within the curtilage of a house. 

S.I. No. 235 of 2008[9], Planning and Development Regulations set out that a single wind turbine which meets the standards as set out (to include turbine height not more than twenty metres, and rotor diameter of eight metres and other standards as detailed in the Regulations), is considered to be “exempted development” which does not require planning permission when placed within the curtilage of an agricultural holding or the curtilage of an industrial or light business premises building. 

Note: S.I. No. 235 of 2008[10], Planning and Development Regulations set out that a single wind turbine which meets the standards as set out (to include turbine height not more than twenty metres, and rotor diameter of eight metres and other standards as detailed in the Regulations), is considered to be “exempted development” which does not require planning permission when placed within

 

10.6   Bioenergy

Bioenergy may be defined as the energy derived from biomass.  Biomass is defined in the Renewable Energy Directive as the biodegradable fraction of products, waste and residues from agriculture (including vegetal and animal substances), forestry and related industries including fisheries and aquaculture, as well as the biodegradable fraction of industrial and municipal waste.  Biomass can be used to generate electricity, heat and transport fuels.

In the domestic or small scale context, Biomass systems comprise of the following key components:-

- Fuel delivery

- Storage facilities

- Stoves/Boilers – to provide heating and hot water to the building

- Flue / ash extraction

- Connecting pipework

Kilkenny, as in Ireland as a whole, has significant bioenergy potential in the form of agricultural land, forestry, recycled waste from municipal treatment plants, agriculture and industrial sources. 

The SEAI publishes a mapping resource, the Bioenergy Mapping System[11], which gives information on the location of potential and actual bioenergy crops, forestry, biomass and waste locations. 

 

10.6.1   Wood Energy Supply Chain

Wood fuels are available in a number of generic forms.  These include wood wastes, forest residues and energy crops.  Some wood fuels are processed to provide a higher quality and more user friendly product such as wood pellets and wood chips.  There are considerable forestry plantations in the county, c.20,500 hectares or almost 10% of the county’s land area[12].  In Kilkenny it is likely that forestry will provide the main source of biomass for the foreseeable future. 

There are a number of non-domestic establishments in the county using wood fuels, including the following: 

  • Camphill Community  
  • There is a district heating system in place in Callan, which is fuelled by locally sourced materials.  This system serves the Callan Friary complex’s five buildings, using a 200kW centralised wood chip boiler which feeds a network of pipes that carry heated water to the end users.
  • St. Columbus Hospital, Thomastown is a HSE hospital which switched over to a 400kW wood chip boiler to provide hot water and space heating for the entire hospital. 
  • Kilkenny College, Castlecomer Road has installed a boiler fuelled by wood pellets.
  • The WaterShed (Leisure Centre) uses a woodchip boiler. 

10.6.2   Short rotation forestry

Short rotation forestry is the production of wood fuel through the cultivation of high-yielding trees at close spacing on short time rotations. Species such as willow and poplar are ideal for short rotation forestry, as they are easy to establish, fast growing, suitable for a variety of sites and resistant to pests and disease.

Statistics on the growth of willow is available from the Department of Agriculture, Food and the Marine which operates a Bioenergy Grant Scheme for Willow and Miscanthus and from the Bioenergy Map.  According to the grant statistics[13], there is very little land under willow plantation in Kilkenny (no hectares were subject to a grant between 2007-2012, with only 11 hectares applied for in 2013) and the Bioenergy map (accessed January 2013) shows that there are very few willow plantations in the county. 

10.6.3   Energy crops

The main commonly grown energy crop in Ireland is Miscanthus.  Miscanthus is a grass which can be used as a fuel in special Miscanthus boilers which are made to handle and burn it efficiently.  It can also be burnt in Biomass-Combined Heat and Power units and for co-firing in power stations. 

Between 2007 and 2010 a total of 223 hectares of land were subject to a Miscanthus establishment grant, which equates to over 7% of the entire country’s Miscanthus area.  The Bioenergy Map shows that there are numerous examples of Miscanthus plantations in the county (accessed January 2013). 

 

10.6.4   Liquid Biofuels

Liquid biofuels are derived from biomass crops or by-products that are suitable for use in vehicle engines or heating systems.Biofuels can be considered as potential replacements or extenders for mineral fuels such as diesel or petrol. They can be sub-divided into a number of categories, the principal two being:

  1. Vegetable oils/animal fats which can be used in unprocessed form or converted to biodiesel;
  2. Bio-ethanol produced from the fermentation of organic materials such as sugar beet, cereals, etc.

There is one biofuel supplier in the county; Goldstar Oils Ltd. in Oldcourt, Inistioge.This company manufactures .

 

10.6.5   Anaerobic Digestion

The process of Anaerobic Digestion (AD) involves the breakdown of organic matter by bacteria and enzymes in an oxygen-free environment.  The end product of this process is biogas which is a gas with a high methane content.  This methane can be captured and burned to produce heat, electricity or a combination of the two.

 

It is used widely in the agricultural sector in the form of small on-farm digesters producing biogas to heat farmhouses and other farm buildings. The main types of organic material feedstock used in AD are:

• sewage sludge

• farm slurry

• municipal solid waste (MSW)

 

An Anaerobic Digestion plant typically comprises of:

- a digester tank

- buildings to house ancillary equipment such as a generator, a biogas storage tank

- a flare stack (3-10m in height)

- associated pipework.

 

Plants can vary in scale from small schemes treating the waste from an individual farm through medium-sized centralised facilities dealing with wastes from several farms (potentially supplemented by crops such as maize grown specifically to feed the digester) to sizeable industrial AD plant handling large quantities of municipal solid waste. In the case of small plants it is likely that the plant can be accommodated within the vicinity of existing farm buildings. Some forms of biomass produce digestate and other end products which must be disposed of. 

The Camphill community in Ballytobin uses an anaerobic digester which performs centralised co-digestion of farm slurry with mixed food waste.  This generates energy (heat and power) to meet the requirements of the 90 people living in Ballytobin Camphill Community.  

Permission was granted recently (12/354) for an anaerobic digestor at a piggery in Piltown. 

10.6.6   Combined Heat and Power

Combined Heat and Power (CHP) is a technology that uses the energy produced in the combustion of fuel to produce both useful heat energy and electricity.  CHP can refer to gas fired CHP or to biomass CHP.  Biomass CHP is a form of renewable energy.  In Ireland most CHP plants burn gas.  CHP Systems will comprise the following key components:-

- Fuel delivery and storage facilities (if fuelled by biomass)

- Boiler/turbine

- Connecting pipework

- Heat exchanger/heat recovery generator

 

CHP plants are available in a range of scales, from micro-CHP domestic applications, small scale CHP plants, medium size plants serving an office block to large industrial applications and CHP plants serving district heating schemes.  There are no medium or large scale CHP plants in the county. 

 

10.6.7   Energy Recovery from Waste

As our need for energy increases, the recovery of energy trapped in waste materials can benefit the environment by replacing energy from non-renewable sources.  Even after extensive recycling, the residual waste stream still has a high combustible content available for energy recovery. 

The Joint Waste Management Plan for the South East Region 2006 – 2011 sets out the policies in relation to energy from waste, and a key policy of that Plan is that an integrated waste facility incorporating thermal treatment and energy recovery will be developed in the region.   (The JWMP was evaluated in 2012 and the outcome of that evaluation is that the Plan requires to be reviewed. The review will take place in 2013.)

 

10.6.8   Development Management Guidance

Possible impacts from the generation of fuel from biomass for a small or community sized plant are set out in the table below.

 

Table 10.2: Summary of potential impacts from small or community sized biomass plants

Issue

Potential impact

Visual

Impact on character of structure of an externally fitted flue

Noise

During construction and during operation from plant operation and deliveries

Light pollution

If operation is proposed on 24/7 basis

Ecology

Impact on bats from new flue installation

Air quality

Odour, dust and emissions

Traffic and transport

Increase in vehicle movements to and from the property

Architectural heritage

Impact on character of protected building from any new flue or structure

Taken from Generating your own Energy, Biomass, Welsh Assembly Government, 2011 Pages 5-7

 

The impacts from commercial scale biomass plants are similar, but include the visual impact from grid infrastructure in addition to the plant itself.  Biomass plants on a commercial scale will be directed to appropriately zoned lands, in order to reduce any impacts on residential amenity.  Another consideration is the disposal of end products from the plant.  For any such projects, the potential for traffic generation will be an important consideration.  To minimise traffic impacts, locations should be close to the point of demand and be served by public roads with sufficient capacity to absorb increased traffic flows and adjacent to transport corridors. 

Possible impacts from an anaerobic digestor plant are set out in the table below.  Proposals for anaerobic digestion will be required to specify suitable outlets for any residues e.g. land banks for landspreading, as part of a planning application.

Table 10.3: Summary of potential impacts from anaerobic digestors

Issue

Potential impact

Visual

Impact of plant and structures

Hydrology

Potential for pollution from operational procedures, e.g. spillages and from digestate

Noise

During construction and during operation from plant operation and deliveries

Air quality

Odour from storage of wastes and feedstock, digestion process, transport, and disposal of digestate, dust and emissions. 

Light pollution

If operation is proposed on 24/7 basis

Traffic and transport

Increase in vehicle movements to and from the property; use of rail freight or shipping could be considered

Architectural heritage

Impact on character of setting of protected building

Taken from Generating your own Energy, Anaerobic Digestion, Welsh Assembly Government, 2011 Pages 5-8

 

Possible impacts from a CHP plant are set out in the table below. 

 

Table 10.4: Summary of potential impacts from CHP

Issue

Potential impact

Visual

Impact of plant, storage facility, structures.

Domestic scale; Impact of flue and storage structures

Light pollution

If operation is proposed on 24/7 basis

Noise

During construction and during operation from plant operation and deliveries

Air quality

Emissions from vehicles during construction and operation 

Traffic and transport

Increase in vehicle movements to and from the property with fuel deliveries

Architectural heritage

Impact on character or setting of protected building

Taken from Generating your own Energy, Combined Heat and Power, Welsh Assembly Government, 2011 Pages 5-7

 

10.6.9   Bioenergy Objectives

Kilkenny County Council recognises the need to support the development of bioenergy resources. It will support suitable projects and recommends that anyone considering a project should consult the South East Regional Authority of Ireland’s current Bioenergy Implementation Plan

 

  • Facilitate the development of projects that convert biomass to energy.
  • In general, direct commercial bioenergy plants to locate on brownfield sites which are adjacent to industrial areas or on lands which are reserved for industrial uses in any development plan. Brownfield sites in rural areas may also be considered.
  • Ensure that any commercial bioenergy plant is close to the point of demand and is served by public roads with sufficient capacity to absorb increased traffic flows and adjacent to transport corridors.
  • Seek to respond positively to applications for waste to energy projects.  

 

10.7   Hydro Power

Hydroelectricity is electricity derived from the power harnessed from the flow of falling water, typically from fast-flowing streams and rivers, impoundment, or in the form of pumped hydro schemes.

Carlow-Kilkenny Energy Agency published a report on hydro power potential in the county, entitled Reclaiming Lost Power, Kilkenny’s Potential Hydro power sites in 2010[14].  According to that report, there was a total of 185 KW being generated through hydro power in 2010, see Table below. 

Table 10.5 Hydro power generating sites in Co. Kilkenny

Generating station

Address

Operator

Capacity (kW)

Inch Mills

Sion Road Kilkenny

Inch Hydro Ltd

40

Greenville Mill

Kilmacow

Benedict Behal

75

Drying Plant

Bennettsbridge

Nicholas Mosse Pottery

28

Milling Plant

Bennettsbridge

Nicholas Mosse Pottery

42

Total

 

 

185

Source: Reclaiming Lost Power, 2010

 

In 1985, the Department of Energy published a document entitled Small-scale Hydroelectric Potential of Ireland[15]. In this, 32 potential hydro sites were identified in County Kilkenny. Reclaiming Lost Power assessed these 32 sites and identified 20 sites for prioritisation.  These sites are shown in Figure 10.3.

 

10.7.1   Types of scheme

The flow rate in the river is the volume of water passing per second.  The gross head is the maximum available vertical fall in the water from the upstream level to the downstream level.  Two hydro projects with the same power output could be very different; one using a relatively low volume of high-speed water from a mountain reservoir and the other using a high volume of water in a slow flowing river.  As such, hydro schemes are classified as low, medium or high head schemes.

10.7.1.1   Low head schemes

Low head systems typically have a gross head of less than 10m.  Reclaiming Lost Power identified the potential of low head hydro resources existing in disused mill sites, weirs and untapped areas around the county. These low head sites (< 10 m) have the potential to create employment, revenue and further enhance the green economy for County Kilkenny.

Low head systems are generally located in lowland areas, abstracting water from rivers through the use of weirs with diversion of a proportion of river flow to a leat (millrace) and from there to a turbine house. Water is returned to the river downstream of the turbine through a tailrace. Low head schemes are very dependent on flow, and may shut down during periods of low rainfall. 

10.7.1.2   Medium-high head schemes

While there is no explicit definition, medium head systems typically have a gross head of between 10 – 50m, and high head schemes typically have a gross head of >50m. Medium and high head schemes typically, but not always, are larger in terms of installed generation capacity. In any case, there is little scope for development of these types of schemes in County Kilkenny.  Only one site, on the River Blackwater is a high head scheme and the Greenville Mill hydroelectric scheme is already in place there.  

10.7.2   Development Management Guidance

In the assessment of proposals for hydroelectric schemes the Council will have regard to the provisions of the Guidelines on the Planning, Design, Construction and Operation of Small Scale Hydro-Electric Schemes and Fisheries[16], or any amending or replacement document.  In addition, it is recommended that anyone considering a hydro-electrical project should consult the following documents (or any updates thereto);

 

In addition to the effects on fisheries as covered by the Guidelines, possible impacts from hydro energy developments are outlined in the table below. 

Table 10.6: Summary of potential impacts from hydro-power scheme

Issue

Potential impact

Visual

Impact on character of landscape, scenic views (turbine houses, embankments, structures, access routes and power lines)

Ecology

Impact on habitats, fish populations and protected species such as otters and bats

Hydrology

Possibility of pollution, effect on water quality and regime, must show compliance with River Basin Management Plan

Noise

During construction and operation

Archaeology

There may be underwater archaeology present

Architectural heritage

Many weirs and mills are protected structures

Taken from Generating your own Energy, Hydropower, Welsh Assembly Government, 2011 Pages 5-7

 

An Environmental Impact Assessment may be required for some hydro electric schemes in accordance with Schedule 5 Part 2(h) of the Planning and Development Regulations 2001.  An EIS may also be required for schemes not meeting this threshold, but where the Council considers that the potential environmental impact is such that an EIA is warranted. 

As can be seen from Figure 8.1, many of the county’s rivers are designated as SACs or SPAs (see Section 8.2).  As with all developments, for any location within or adjacent to a Natura 2000 site, an assessment under Article 6 of the Habitats Directive will be required (See section 1.3).  

As part of any planning application for a hydro electric scheme, an Environmental Management Plan will be required to address all environmental issues arising during the construction and operation of the scheme. 

The following types of scheme are likely to be detrimental to the fisheries resource and may be rejected by the planning authority:

  • New low head schemes that may cause significant obstacles to fish movement.
  • In catchments / sub-catchments of importance such as a spring salmon fishery.
  • Placing structures / weirs at the outlet of lakes or creating new impoundments.
  • The transfer of water from one catchment to another.
  • River channel sections of high fisheries value where the impacts of the proposed hydro scheme development would be unacceptable from a fisheries perspective, i.e. in an area of important spawning or nursery area
  • Where there are existing competing uses of the water resource, such as water abstractions, dilution of licensed discharges etc
  •  Where there may be an impact on river continuity, fish migration, or fish mortality.

 

10.7.3   Hydro Power Objectives

  • Facilitate the development of appropriate projects that convert hydro power to energy.

 

10.8   Solar energy

The three main forms of solar energy are Passive Solar Design, Solar Heating and Solar Electricity. 

10.8.1   Passive Solar Design (PSD)

Virtually all buildings enjoy free energy and light from the sun; the objective in PSD is to maximise this benefit by using simple design approaches which intentionally enable buildings to function more effectively and provide a comfortable environment for living or working. PSD has always been a feature of traditional vernacular architecture.  A structure employing PSD is unlikely to cost more than a structure built without the benefit of passive solar design. Design, infrastructure and site layout are key to achieving energy efficient development by optimising passive solar gain in domestic and non-domestic buildings.   PSD is a central principle of the Guidelines on Sustainable Residential Development in Urban Areas[18] and the Kilkenny Rural House Design Guide[19].

 

10.8.2   Solar Heating

A solar collector is a device that captures solar heat and transfers it to heat water, most commonly for sanitary hot water production, or in cases where a building has a very low heat demand, then often for both space heating and hot water. Larger scale active solar thermal technologies can also be used for cooling and steam production. Steam produced in this way can be used to drive turbines for electricity production.

There are two types of collector; flat plate collectors or evacuated tube.  Building-mounted flat plate collectors can be positioned both "in-roof" and on-roof due to their structure (heavy, rigid, robust box-like structure). The efficiencies of flat plate collectors make them very suitable for domestic installations or for installations where very high temperatures aren't required.

Building-mounted evacuated tube collectors can only be mounted on-roof due to their lightweight structure, which is most commonly individual tubes mounted on a frame.  Evacuated tube collectors will provide approximately 20% more yield per m2 than flat plates, which means that less installed area is required for similar heat outputs.

 

10.8.3   Solar Electricity

The production of solar electricity relies heavily on active solar technology. The most commonly encountered system for solar electricity production is solar photovoltaic.  Solar photovoltaics (commonly referred to as "PV") is the term given to the conversion of light energy to electricity and also describes the active solar technology (Solar photovoltaic systems) which produces electricity from solar radiation using solar cells joined together in panels called PV modules.

PV systems exploit the direct conversion of daylight into electricity in a semiconductor device, with the most common form being a number of semi conductor cells which are interconnected and form a solar panel or module. There is considerable variation in appearance, but many solar modules are dark in colour and have low reflective properties. Solar modules are typically 0.5 to 1m² with a peak electrical output of 70 to 160 watts. A number of modules are usually connected together in an array, the area of which can vary from a few square metres to several hundred square metres. A typical array on a domestic property might have an area of 9 to 18m², and would produce 1 to 2 kW peak output[20]

10.8.4   Development Management Guidance

The main impact from the installation of solar energy technologies is visual.  The installation of solar panels on a building can impact on the building’s character.  There are exemptions contained within the Planning & Development Regulations 2001 to 2008 (S.I. No. 83 of 2007 and S.I. No. 235 of 2008), regarding the placing of solar technology on domestic structures, and on buildings used/associated with industrial, light industrial, business and agricultural purposes, subject to certain criteria.   Planning permission is required to install solar technology on a Protected Structure. Sensitive design and location is important so that the overall character is not diminished.

Public buildings and schools are not included within the Regulations. The Council will support applications to install solar panels on these buildings within the county should the opportunity arise.

 

10.8.5   Solar Energy Objectives

  • The Planning Authority will support and facilitate the development of passive solar design proposals for the development of houses in rural and urban areas, and will draw on the recommendations of the Kilkenny Rural House Design Guide, and the Guidelines on Sustainable Residential Development in Urban Areas.
  • The Planning Authority will make available advice on Passive Solar Design in preplanning consultations for domestic and commercial buildings.
  • Consider impacts of overshadowing on the efficiency of existing solar technologies when assessing planning applications.
  • Support applications to install solar panels on public buildings and schools within the county should the opportunity arise.

 

10.9   Geothermal Energy

Geothermal energy refers to heat energy stored in the ground.  Heat is supplied to the ground from two sources, namely the hot core of the planet and the sun.  It can be classified as either ‘deep’ or ‘shallow’ depending on the depths involved.   For deep geothermal energy extraction, developments drill into the earth’s crust to reach ‘hot rocks’, such as granite whose radioactive elements generate heat at great depth.  The second source of heat in the ground is from radiation from the sun. Solar thermal radiation is absorbed by the surface of the earth each day. This energy can be regarded as stored energy which stays relatively warm throughout the year. This type of solar energy is extracted from the first few metres of the earth’s crust and can be harvested using heat pumps.

Heat pump systems extract the heat stored in the ground (ground source heat pumps), bodies of water (water source heat pumps) or air (air source heat pumps). This heat can then be used to heat the spaces in buildings, heat water or enable a building to be cooled.  Through compression, heat pumps can ‘pump up’ heat at low temperature and release it at a higher temperature so that it may be used again.  A heat pump looks similar and can perform the same functions as a conventional gas or oil boiler, i.e. space heating and sanitary hot water production. For every unit of electricity used to operate the heat pump, up to four units of heat are generated. Therefore for every unit of electricity used to pump the heat, 3-4 units of heat are produced.  The collector can be “closed loop” where the same fluid (usually water and antifreeze) always flows through the collector pipes or “open loop” where new water (e.g. from a well) flows through the heat pump. 

Ground source heat pumps (GSHP) operate on the fact that the ground maintains a constant temperature between 11oC and 13oC, several metres below the surface.  Ground source heat pumps use a 'closed loop' system of water/anti-freeze to collect the soil heat.  In general terms the ground area required for the collector is approximately equal to that of the foot-print of the house or building to be heated[21].

Air source heat pumps (ASHP) use the surrounding air as a heat source to heat a building.  Air source heat pumps can be located in the roof space or on the side of the building. They are similar in appearance to air conditioning boxes.

Water source heat pumps (WSHP) extract heat from large bodies of water or rivers.  These are generally 'open loop' collectors, i.e. the water is passed through and discarded, unlike the 'closed loop’ systems.

 

10.9.1   Deep Geothermal

In 2004, CSA Group completed a study commissioned by SEAI which aimed at identifying the potential resources of geothermal energy in Ireland.  Co. Kilkenny does not have significant potential for deep geothermal, as the study concluded that “the best proven potential for medium and deep geothermal resources in the Republic of Ireland are in the northeast (Navan area) and northwest midlands... and in the west Clare and east midlands areas”[22].

One of the outcomes of the project was to create a series of geothermal maps[23] for Ireland.  Subsurface temperatures increase from south to north in County Kilkenny.  The map below shows the geothermal temperatures at 5,000m. 

However, in the short term it is unlikely that deep geothermal will be utilised in Ireland.  The first deep geothermal plant in Ireland was granted permission by South Dublin County Council in 2011 for Greenogue Business Park in Newcastle. 

 

10.9.2   Development Management Guidance

The various possible impacts from the three types of heat pumps, and from deep geothermal are set out in the Table below. 

 

Table 10.7: Summary of potential impacts from heat pumps

Potential impact

Ground source heat pump

Air source heat pump

Water source heat pump

Visual

 

x

 

Ecology

X

 

X

Hydrology (risk of contaminating wells, aquifers and watercourses)

X

 

X

Hydrology (abstraction & disturbance)

 

 

x

Traffic & Transport

x

 

 

Noise

x

x

x

Geology

X

 

 

Archaeology

x

 

 

Architectural heritage

 

X

 

Building Design (structural impact)

x

 

x

Taken from Generating your own Energy, Heat Pumps, Welsh Assembly Government, 2011 Pages 7-11

 

Table: Summary of potential impacts from Deep Geothermal energy

Issue

Potential impact

Visual

Plant and power infrastructure, there may also be structures around any tunnels

Ecology

Habitat and species disturbance

Hydrology

Risk of contaminating wells, aquifers and watercourses

Traffic & Transport

Vehicle movements during operation and also construction & decommissioning

Noise

Noise creation from drilling

Geology

Seismic factors associated with drilling near faults, risk factors from gas pockets and other sub-surface substances. Risk of ground subsidence. 

Archaeology

There may be archaeology present.

 

10.9.3   Geothermal Energy Objectives

  • Support the development of geothermal energy and heat pumps

 

10.10   Sustainability & Energy Efficiency in Buildings

According to the EU, buildings account for 40% of total energy consumption in the Union[24].  Therefore, increasing energy efficiency in buildings has a huge role to play in meeting Ireland’s renewable energy targets.

 

10.10.1   Kilkenny Local Authorities Energy Efficiency

Kilkenny Local Authorities have adopted an Internal Climate Change Strategy and Energy Efficiency Action Plan 2010-2014 which has been developed in line with the National Climate Change Strategy 2007-2012.  An internal Climate Change Committee was established to implement this. 

Kilkenny Local Authorities have signed up to Energy Map training and an Energy Management Action

Plan delivered by Sustainable Energy Authority of Ireland (SEAI).  An Energy team was established under the Energy Map programme consisting of personnel from across the various sections.  In signing this agreement Kilkenny Local Authorities are committed to reducing their energy consumption by 33% by 2020.  It is acknowledged that only by ensuring that employees from all areas of the organisation are involved that a local authority can successfully integrate energy efficiency and management into its culture.

Objective:

To review the progress of the Climate Change Strategy, report on the progress to date, and thereafter develop a new strategy and action plan in line with national policy. 

 

10.10.2   Energy Performance of Buildings

The 2002 EU Directive on the Energy Performance of Buildings (EPBD)[25] contained a range of provisions aimed at improving the energy performance of residential and non-residential buildings, both new and existing.  This Directive was adopted into Irish law as the Energy Performance of Buildings Regulations (S.I. No. 666 of 2006).

From 2013, the EPBD will be superseded by the recast EPBD[26].  Under the recast Directive, Member States must establish and apply minimum energy performance requirements for new and existing buildings, ensure the certification of building energy performance and require the regular inspection of boilers and air conditioning systems in buildings.  Moreover the Directive requires member states to ensure that by 2021 all new buildings are constructed as so-called ‘nearly zero-energy buildings’ and by 2019 new buildings occupied and owned by public authorities are nearly zero-energy buildings.  (A zero energy building means a building that has a very high energy performance.  The nearly zero or very low amount of energy required should be covered to a very significant extent by energy from renewable sources, including energy from renewable sources produced on-site or nearby.) 

In Ireland, the Energy Performance of Buildings Regulations, (S.I. No. 666 of 2006) provides the regulatory framework for the time being.

 

10.10.2.1   Alternative Energy Systems for Large Buildings

For large buildings over 1,000m2, S.I. No. 666 of 2006 requires that due consideration has been given to the technical, environmental and economic feasibility of installing alternative energy systems in the proposed building, and that the use of such systems has been taken into account, as far as practicable, in the design of that building. 

The preferred methodology for assessing the feasibility of such alternative energy systems shall be the Sustainable Energy Authority of Ireland software tool or other acceptable methodology as defined in (S.I. No. 666 of 2006). 

This shall also apply to all new planning application for housing schemes of ten or more units. 

 

10.10.2.2   Dwelling Energy Assessment Procedure

Dwelling Energy Assessment Procedure (DEAP) is the official Irish procedure for calculating and assessing the energy performance of dwellings.  Published by the Sustainable Energy Authority of Ireland (SEAI), the procedure takes account of the energy required, for space heating, ventilation, water heating and lighting, less savings from energy generation technologies.  It calculates both the CO2 emission rate and energy consumption per annum. This is a useful tool for designers when considering and comparing options to conserve energy and reduce CO2 emission.  The right design decisions in relation to building form, dwelling layout, levels of insulation, amount and orientation of glazing, utilisation of solar energy, heating system and fuel type, use of draught lobbies, construction materials and measures to conserve potable water, can contribute greatly to sustainability. In addition these will lead to cost savings, in the long term, while raising the level of comfort for the occupants of the dwelling.

DEAP is also used to calculate the Building Energy Rating (BER) of a dwelling.  The BER is a label containing the energy performance of the dwelling, expressed as primary energy use per unit floor area per year (kWh/m2/per annum) and illustrated as an Energy Rating (A1, A2, A3, B1, B2, B3, etc) for the dwelling, it also includes a Carbon Dioxide (CO2) Emissions Indicator (kgCO2/m2/yr) associated with this energy use and an advisory report.  

Guidance and assistance on these and other matters pertaining to the sustainable use of energy is available from Sustainable Energy Authority of Ireland (SEAI) and the Carlow Kilkenny Energy Agency. 

10.10.3   Building design

The Urban Design Manual[27] sets out how sustainable energy considerations should be incorporated into all stages of the design process. 

The Building Regulations, Part L – Conservation of Fuel and Energy – set out the requirements for dwellings[28] and for buildings other than dwellings[29].   In order to ensure that the Building Regulations are fully taken into account in the design of any proposed dwelling, it will be a requirement that all planning applications be accompanied by a provisional BER cert stating that the proposed dwelling is in accordance with the current Technical Guidance Document L - Conservation of fuel and energy.

10.10.3.1   Passive Houses

A passive house1 is an energy-efficient building with year-round comfort and good indoor environmental conditions without the use of active space heating or cooling systems.  The Passivhaus Standard is a construction standard developed by the Passivhaus Institut in Germany

(http://www.passiv.de/en/index.php).  The Standard can be met using a variety of design strategies, construction methods and technologies and is applicable to any building type. 

 

10.10.4   Building Energy Performance Objectives

  • Encourage high standards of energy efficiency in all building developments and encourage developers, owners and tenants to improve the environmental performance of the building stock, including the deployment of renewable energy. 
  • Require a provisional BER certificate as part of any planning application, showing how the proposal will comply with Part L of the Building Regulations
  • To require that planning applications for large buildings, as defined by the Energy Performance of Building Regulations, demonstrate that due consideration has been given to the technical, environmental and economic feasibility of installing alternative energy systems in the proposed building, and that the use of such systems has been taken into account, as far as practicable, in the design of that building.  This shall also apply to applications for ten or more housing units. 

 



[3] Department of Communications, Energy and Natural Resources, National Renewable Energy Action Plan, 2010

[4] Department of Communications, Energy and Natural Resources, Strategy for Renewable Energy 2012-2020, 2012

[5] For further information on REFIT, see the Dept.’s website at http://www.dcenr.gov.ie/Energy/Sustainable+and+Renewable+Energy+Division/REFIT.htm

 

[6] South East Regional Authority, Bioenergy Implementation Plan 2008-2013

 

[7] Department of Environment, Heritage and Local Government, Wind Energy Development Guidelines for Planning Authorities, 2006

[13] Department of Agriculture, Food and the Marine, Bioenergy Grant Scheme for Willow and Miscanthus, statistics obtained January 2013

[16] Central and Regional Fisheries Boards, & the Department of Communications, Marine & Natural Resources Guidelines on the Planning, Design, Construction and Operation of Small Scale Hydro-Electric Schemes and Fisheries, 2007

[18] Department of Environment, Heritage and Local Government, Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas (Cities, Towns and Villages), 2009

[19] Kilkenny County Council, County Kilkenny Rural Design Guide, 2008

[20] Technical Advice Note 8: Planning for Renewable Energy, Planning Policy Wales, Welsh Assembly

Government, July 2005, Page 46-47

[27] Department of Environment, Community and Local Government, Urban Design Manual, A best practice guide 2009

 

Comments

 

A Chara,

 

I am writing to you to express my serious concern having been alerted to the fact that the protective policy in the current Kilkenny County Development Plan 2008-2014 is to be omitted from the forthcoming County Development plan 2014 - 2020.

The policy in Chapter 9, in the last paragraph of Section 9.8.3.3 Wind Energy, conditions that:

 

Wind farm development will not be allowed within 2km of any registered thoroughbred stud farm facility”.

 

Major wind energy developers have indicated that turbines proposed for the midlands will be 500 ft and 600 ft in height, which for comparison purposes is the height of Dublin’s Spire placed on top of Liberty Hall.  The blades are 120m in diameter and are akin to rotating the 120m Spire above communities. 

There are approximately 2,500 of these enormously invasive moving structures planned for the Midlands set in amongst communities, which will seriously impact on people and animal health, the landscape and livelihoods.  

 

I am particularly concerned with how the proposed plan will impact on the Irish Equine sector and their livelihood.  Both the Irish Thoroughbred and the Irish National Hunt horse are unquestionably a World Leader in the international sector and are an exceptionally important part of Irish indigenous industry.  In addition, those working in the industry including Irish horse breeders, trainers, veterinarians, grooms and jockeys are second to none, as is the equine infrastructure including Studs, equine centres, international show arenas, specialist hauliers, Irish Bookmakers and Racecourses.  

 

This proposed project threatens to be detrimental to this industry. The principle (non exhaustive) issues which threaten the industry relate to noise, shadows and shadow flicker, health of equine staff and horses, the natural constitution of horses (prey), spooked horses, handler difficulty in controlling horses with high risk of injury and / or fatality, turbine related accidents (malfunction blade throw, ice throw, collapse, etc. endangering horses and staff), infrasound and vibration (acquired flexural deformity of the distal interphalangeal joints), electro magnetic field radiation, species loss and affect on the eco system with related disease, and the industrialisation of the natural landscape. The Irish Thoroughbred Breeders Association held a meeting last month in the Tullamore Court Hotel, Co Offaly where serious concerns were voiced on the above issues.

 

Ireland’s natural landscape should not be underestimated as it was and is a very important factor in attracting Foreign Direct Investment in Irish Studs and bloodstock, particularly from Arab investors.

 

It is imperative for the protection of the equine industry that the forthcoming Kilkenny Development Plan 2014-2020 retains the existing policy condition:   

Wind farm development will not be allowed within 2km of any registered thoroughbred stud farm facility”.

 

 

 

Yours sincerely

 

_________________

Dara Reid

Shinglis Stud

 

 

Additional Information and Sources:

 

Shadows:

Shadows cast by turbines can extend up to nine kilometres from the source. 

Horses are by nature, prey animals.   They do not associate the shadow which moves across the ground as something being cast by the turbine, but rather their instinct is to identify it as a predator threat, resulting in being “spooked”.

 

Shadow flicker:

Shadow Flicker and intermittent noise spook horses and has the potential to put lives in jeopardy.  Tony Mc Coy the leading Nation Hunt jockey, who had bought a property and was granted planning permission for a new training yard and having engaged a main contractor for the Sterling £2 Million project, decided to put the entire project on hold on hearing of proposed Wind turbines for his area.  Tony McCoy submitted a detailed and planning objection as to the “spook” issue of horses and injury and possible death risks to riders and how it would jeopardise his business.  The project remained on hold until planning was denied to the Wind Turbine developer.

 

http://www.telegraph.co.uk/earth/earthnews/8982541/jockey-tony-mccoy-scraps-plans-for-racing-stable-over-fears-windfarm-will-spook-horses.html

 

 

Noise:

As described at a recent national meeting of the Irish thoroughbred Breeder’s Association (ITBA), Professor Alun Evans a leading retired Cardiac consultant from Northern Ireland whose specialist research on the effects of wind turbine noise on humans is published in the British Medical Journal, referred definitively to the adverse effect of Industrial Wind Turbines on humans and animals. See Appendix A below.

 

It was also stated at the meeting that 1500 accidents in the UK have occurred involving Wind Turbines.  This figure excludes injuries and death to animals.

 

The British Horse Society:

 

A report was carried out by the British Horse Society in 2012. The main points arising from the analysis were:

 

• Nearly 30 percent of horses reacted adversely on approach to one or more

Turbines, and 22per cent of riders had difficulty controlling the reaction. This was

not related to temperament of the horse or competence of the rider.

 

• There was correlation between the increased severity of reaction of horses and

proximity to turbines, particularly within 200m.

 

• Main sources of disturbance were considered to be the visible movement of the

blades, the movement of shadows cast by the blades and the noise of the

blades through the air.

 

• Some horses do not become accustomed to turbines even with skilful handling

and repeated exposure.

 

• Nearly 50 percent of respondents said that erection of turbines near where they

ride would adversely affect their access. The majority perceived the risk as too

great to continue riding in the vicinity.

 

Equine Staff within Prohibited Zone of Exposure:

 

The wind turbine manufacturer Vestas in their documented instructions to their employees, prohibits staff working within 400mtrs from an operational wind turbine (800m diameter) unless the work is an emergency.  However, landowners and equine staff are expected to work routinely under an operational wind turbine within that zone.  This means that the equine staff are working within the prohibited zone and are exposed to the electro magnetic field radiation and other environmental conditions emitted by the turbines, with horses more permanently located within the prohibited zone of exposure. 

 

Turbine Manufacturer Retexo RISP

 

The turbine manufacturer Retexo RISP in their appraisal of a suitable turbine site state that;

 

“Buildings, particularly housing, should not be nearer than 2km to the windfarm”

 

http://www.retexo.de/english/wind/seite5a.htm

 

 

http://www.windturbinesyndrome.com/2013/horses-get-wind-turbine-syndrome-portugal/

 

http://www.spiegel.de/international/germany/wuthering-heights-the-dangers-of-wind-power-a-500902.html

 

http://www.safesetbacks.com/styled-6/styled-9/files/turbines0026bats.pdf

 

Appendix A

 

 

http://www.westashton.org.uk/2km%20limit%20wiltshire.pdf

 

 

 

 

 

Plan has closed for submissions. Any comments will not now be considered Submissions to the plan: 
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