Martin Kealy

WINDFARM DEVELOPMENTS.

APPLICATION PROCESSES FOR:-

PLANNING PERMISSION, GENERATION

LICENCE, GRID CONNECTION, REFIT AND

SINGLE ELECTRICITY MARKET.

ABSTRACT.

This article evaluates the procedures and issues currently effecting applications for planning permission, generation licence, grid connection and pricing mechanisms.

The project management practices of the Project Management Institute, (PMI), were examined to see how their implementation could positively effect the delivery of the project milestones. They were found to be quiet effective for stakeholder and risk management.

In the reviewing the planning application procedure, it was found that an extensive submission was required. There was also the opportunity to meet with the planning authority before submission. In a windfarm application the planning authority review and attach conditions to the following items:

· Siting, design and layout.

· Flexibility of turbines layout on site.

· Flora, fauna and habitats.

· Archaeology.

· Noise.

· Environmental impact and monitoring.

· Construction methods.

· Borrow pits and quarrying.

· Roads and access routes.

· Associated structures and equipment.

· Grid connections.

· Site management issues.

· Shadow flicker.

· Electromagnetic interference.

· Aeronautical safety.

· Windtake.

· Wind measuring masts.

The pieces of planning legislation that apply to windfarms are:

· Planning and Development Act 2000 (No. 30 of 2000), used by local planning authorities.

· Planning and Development (Strategic Infrastructure) Act 2006 (No. 27 of 2006) used on projects considered to be of national strategic importance.

Using the Planning and Development (Strategic Infrastructure) Act 2006 (No. 27 of 2006) for wind farm projects, citing national strategic importance is the wrong approach to apply for planning permission. Using this could lead to conflict with local communities and give the wind sector a bad image.

All windfarm planning applications should continue to be submitted under the Planning and Development Act 2000 (No. 30 of 2000) to ensure local people’s concerns are addressed. This allows them to maintain confident in the planning process. This will help develop local support for the windfarm.

All power generation developments are required to apply and get a generation license prior to the commencement of construction of the development. Currently the Commission of Energy Regulation is involved in the operation of the Single Electricity Market, (SEM) for all of the Ireland. There is no Renewable Feed In Tariff (REFIT) scheme for Gate 3. After 31st December 2009 no new applications were submitted to this scheme. The industry has called for the scheme to be introduced again and rules of the SEM modified to incorporate it. They have advised that without the REFIT scheme, the SEM is making windfarm non-viable commercially. REFIT 2 is with the Europe Commission for review. REFIT 2 is classed as state aid in Ireland. It is not state aid in Britain or Germany, therefore more flexible administration rules apply to the British scheme.

The closing date for application of a gird connection has passed under the Gate 3 scheme. The Transmission System Operator, (TSO – EirGrid), are currently planning the Grid Development Strategy, (GDS – Grid 25). All confirmed of connections to the Grid will be made to developers who applied under Gate 3 by June 2011.

The industry has voiced concern with all of the above. They have cited that the application procedures are too complex and processing times are to long. They have stated the complexity of the above issues is causing investment in the sector to drop. They have requested that the Government to review the implementation of the above policies. They have also stated that it is unlikely that the Government’s 40% target of all electricity demand coming from the renewable sources will be not be achieved by 2020.

Table of Contents

ASSIGNMENT SCOPE.

This article is researched and written from the prospective of managing the planning permission, generation license, grid connection and other applications required for windfarm development. The aim of this article is to identify and evaluate the key requirements and risks associated with the applications to the various statutory bodies. This article looks at:

· Planning permission.

· Generation licences.

· Application for connection to the grid.

· Pricing and wind sector support mechanisms.

Technologies employed and site layout designs are of significant concern when applications are being assessed by statutory bodies. However a full evaluation and cost benefit analysis of wind turbine generation technologies is be excluded from the scope of this article. Similarly an assessment of various windfarm layout design configurations are also excluded. This article will assume that the site for which planning permission is sought has been selected as per wind industry’s define criteria and is suitable for development.

INTRODUCTION.

General.

From a project management prospective, the applications to the various statutory bodies are considered potential major risks that could cause project failure. The planning and grid connection applications are viewed as the greatest potential risks for any new development.

Wind farmed developments are generally considered environmentally friendly as they reduce the carbon footprint and our dependence on foreign imported fossil fuel. From a national strategic point of view this is of great benefit. However there is a downside to this argument. Construction and operation of wind turbines cause environmental disruption. This is particularly relevant when the turbines are erected in very scenic areas. From a literature review of this topic, the issues of most concern are:

· Visual Impact.

· Electromagnetic interference

· Construction techniques

· Noise.

· Shadow flicker.

· Habitat disruption.

Project Management

In all projects there is risk and award. The main object of the Project Management Institute, (PMI), project management systems are to identify all the risks, stakeholders and influence of the stakeholders have over the project. The PMI system aims manage and mitigate risk, while at the time maximising return from the rewards. The PMI systems uses various tools such as project charter, scope statement, management plan, risk analysis, risk management plan, stakeholder register and management plan, quality plan, communications plan, work breakdown structure, procurement systems & contracts and a project program. All of these define the project targets and performance baselines that must be achieved to complete and deliver the project successfully

Like all business ventures, a wind farm project must have a business plan, that will determine if the developer will invest or not. Figure 1 below shows at a high level what the investor will consider in the business plan for an energy project.

Figure 1: Investor Considerations for a WindFarm, [20].

In addition to determining if the site is suitable there are a number of other project and business risks considered:

· Project Risk: Site access, connection offer, planning permission, turbine contract and program.

· Operational Risk: warranty and insurance

· Revenue Risk: Tradable volume and price, [20].

Government Policy.

Ireland’s renewable energy targets are set-out in the National Renewable Energy Action Plan submitted to the European commission under article 4 of Directive 2009/28/EC. It originated when the EU agreed new climate and energy targets in 2007. A 20% reduction in greenhouse gases, 20% improve in energy efficiency and 20% of EU energy will be from renewable sources. This lead to the formulation of Directive 2009/28/EC in which each individual state has a binding target to achieve. Ireland’s overall target was to achieve 16% from renewable sources. The directive applies across electricity, heat and transport. Each individual state was given the capacity to chose themselves how they would achieve their specific targets. Ireland’s breakdown is as follows:

1. Electricity: 40% renewable generation by 2020, (sub-target of 13% by 2010).

2. Heat: 12% of all heat generated will be from renewable sources.

3. Transport: 10% of vehicles will be electric by 2020. All oil fuesl will be blended with 4% biofuels.

The previous Fianna Fail and Green Party administration developed the policy document “Delivering a sustainable energy future for Ireland – The Energy Policy Framework 2007-2020” and integrated renewable aspects into the building the smart economy policy document “Building Ireland’s Smart Economy – A Framework for Sustainable Economic Renewal”.

The governments strategy in their promotion of energy from renewable sources it to increase energy security, reduce energy costs, increase competitiveness, develop a new export product and reduce green house gases. The last 10 to 15 years has seen a lot of changes in the electricity market, deregulation, formation of the Commission for Energy Regulation, (CER), development of the all island Single Electricity Market, (SEM), formation of the transmission system operator “EirGrid” and the sharp raise of electrical energy generated from wind turbines. The government has also committed Ireland to the 1997 Kyoto Protocol to the United Nations Framework Convention on Climate Change. An international attempt to address the issue of climate change on a global level. The Government developed the “National Climate Change Strategy, (2000)”

“The strategy sets out a ten year framework for achieving the necessary greenhouse gas reductions towards Ireland’s compliance with its 13% limitation target on 1990 emissions, within the overall EU reduction target of 8%, by the first commitment period 2008-2012. In addition to taking action now to reach this first step target, further action will be required to meet deeper level commitments. The scientific consensus developed in the Intergovernmental Panel on Climate Change is that cuts in global emissions of 60-70% over the century are needed to stabilize greenhouse gas levels in the atmosphere at concentrations that prevent dangerous human-induced impacts on global climate”, [5].

To deliver the government renewable energy strategy will require co-ordination and between relevant government departments and state bodies. This particularly applies to the Department of Communications, Energy & Natural Resources, the Department of Environment, Heritage & Local Government, the Department of Agriculture, Fisheries & Food, the Sustainable Energy Authority of Ireland, the Commission for Energy Regulation, Eirgrid (Transmission System Operator, TSO) and ESB Networks (Distribution System Operator, DSO). The government commitments to the EU on renewable energy will require an substantial increase in energy infrastructure including development of the grid. The government hopes to develop the smart grid and the increase renewable connections at the same time. Therefore Eirgrid has developed the grid extension program called Grid 25 based upon the “Gate System” application process. (Both of these will be expanded upon with further on in the article. To deliver the need for increased infrastructure will require a coordinated approach to granting of planning regulations. The two principles pieces of planning legislation are:

· Planning and Development Act 2000 (No. 30 of 2000), used by local planning authorities.

· Planning and Development (Strategic Infrastructure) Act 2006 (No. 27 of 2006) used on projects considered to be of national strategic importance.

The government is highly supportive of renewable energies and there is political support among all parties to deliver on the National Renewable Energy Action Plan. The new government are continuing with the policy of the last government in this area. All government departments and agencies are delivering on this government policy as best they can. Implementation of this policy is not as straight forward as it would seem, with the development of conflicts in unusual areas. These conflicts are making the implementation of the renewable policy on a practical level difficult to achieve, [6]

Obligation To Purchase Green Energy.

The Renewable Energy Directive (2009/28/EC) provides for Guarantees of Origin (GOs) for renewable generation. This directive places a requirement on the licensed electrical supplier with the CER, to buy a defined quantity of energy generated from renewable sources. The sole function of the directive is to provide the final customer with a guarantee that a given share of energy consumed was produced from renewable sources. This directive has been transposed into Irish law, [6].

Rate Of Progress For Renewable Connection To National Grid.

It was estimated that by the end of 2010, that approx 1,600MW of wind energy was built. This meets the original deadline to secure 1450 MW RES-E for 13.2% electricity consumed by 2010. The CER determined that 500MW of wind was completed in 2010 itself. The IWEA disagreed with this position and advised that only 300MW per year is being installed since 2010. The industry believes that to reach the CER’s targets of 2020, 500MW per year will have to be installed. It is widely viewed by the industry also that the 2020 target will not be met. That only 4,600MW will be installed by end of 2020. Nowhere near the required target.

In their estimations the CER did not include for the power from electric cars, (possible an additional 500MW) or Renewable Energy Space Heating, (estimated at another possible addition of 1,000MW). The industry believes that the CER should be refining wind energy state mechanisms, (e.g. Planning, EirGrid’s Grid 25 plan, SEM & Grants Aids), to make them more efficient, with less red tape. The industry also believes that the CER should begin to focus attention on the export potential of renewable power, [21].

LITERATURE REVIEW.

Commission for Energy Regulation.

The Electricity Act 1999, established the Commission For Energy Regulation, (CER), and define its functions. One of the functions of the CER is to grant licences for the construction of new powers station or the refurbishment of an exiting power station. To generate electricity without such a licence is an offence.

The Electricity Regulation Act 1999, (Section 18(2)), states that the Minster defines the criteria used for authorisation of a licence application for to construct or reconstruct a power station. The same criteria is used for assessing all application regardless of generator type. The criteria is matrix based upon criteria set out in SI 309 of 1999 defined as follows:

“(a) no activity carried out under it will adversely affect the safety and security of the electricity system.

(b) energy will be used efficiently in the course of any activities carried out under the authorisation.

(c) comply with any grid code or distribution code.

(d) the application relates will be constructed and commissioned within a period which the Commission shall specify in relation to each application.

(e) the generating station to which the application relates will be capable of providing an appropriate level of ancillary services being the services necessary to ensure the stable and secure operation of the electricity system, including the provision of spinning reserve, reactive power, frequency control or black start capability, as specified by the Commission in the authorization.

(f) the generating station to which the application relates will be capable of generating electricity for any minimum continuous period which is specified by the Commission in the authorisation using a primary fuel source of a nature other than that proposed to be used predominantly.

(g) the applicant is a fit and proper person to be granted an authorisation and has the financial capacity and technical skills to carry out the activities to which the application relates and to comply with the authorisation, if granted.

(h) that the applicant will be capable of complying with any order made by the Minister under section 39 of the Electricity Regulation Act, 1999 .”,[14].

Applicants are required to submit, as part of the license application:

· “Application forms.

· Two years’ accounts.

· Power purchase agreement.

· Acceptance to REFIT scheme (this will be explained in a latter section).

· Proof of financing.

· A certificate from applicant stating that no adverse change has occurred, if more than 3 months have passed since the end of the accounting year covered by the accounts submitted.

· Outline 5 year business plan.

· Maps/Marine Charts.

· Construction and commissioning program.

· Planning permission.

· Environmental Impact Statement.

· Soil stability report and confirmation of compliance with recommendations therein

· Proof of entry on water abstraction register.

· Waste license.

· Connection agreement”, [13].

One of the critical things the CER looks for is the ability of the license applicant to hold sufficient financial backing to deliver on the undertakings required by the license.

In June 2010, the CER revised the licence application procedure for generation sites of 40MW or less to reduce the administrative burden and expense on developers. The CER published a paper outline the changes. The key changes are:

· Declaration to be signed by applicants replaces the need to submit documents, unless specifically requested by the CER in a particular case.

· Declaration confirms that proposed development meets, or will meet, certain criteria e.g. that construction will not begin before connection agreement has been finalised and that statutory consents will be obtained at the appropriate time.

· Authorisation and a licence may be granted before a Connection Agreement, PPA, REFIT, planning permission and other consents are finalized. The declaration most met all statutory, license and other authorization requirements.

· Applicants must provide evidence that finance is available either internally or from a third party financier. This could comprise a letter of commitment from a financial institution or shareholders and supporting contract documents.

· The applicant licence must provide evidence of the necessary technical skills to operate the generating station. If an operator has been appointed at the time of application for an authorisation this evidence should also be provided. This might be by way of a C.V. showing the qualifications and experience of the person or company who will operate the generating station.

· Revision of application fee”, [15].

The above modifications are particularly applicable to windfarm developments as the majority of development phases for windfarms range from the 20MW to the 50MW.

Single Electricity Market, (SME).

The Single Electricity Market, (SME), is the wholesale electricity market for the entire island of Ireland. All large generators can participate in it. Application is made through the CER. The market is regulated by the Single Electricity Market Operator, (SEMO), a joint operation between EirGrid and System Operator of Northern Ireland, (SONI). The purpose of the SEM is balance Energy demand of the grid, capacity and constrains.

At a high level, the SEM operates as follows:

· A day before the physical generation, all generators submit bids to the SEMO. These bids are the price at which they will sell their electricity. Their bid takes account of the start-up costs, no-load costs, short term variable overheads, fuel costs and profit margin. (In effect they sell their electricity to the SEMO). Fixed costs associated generating each MW is not included in the bid.

· The electrical supplier provides electricity to the end-customer, and buys the electricity from the generators, (effectively the buys the electricity from the SEMO).

Figure 2: Structure of SME,[16].

· The SEMO comprises a list of bids with the cheapest bidder and their corresponding generation capacity at the top of the list. This procedure is continued until demand is met. (An all island list to meet all island demand).

· Based on this list of generator costs and on customer demand for electricity, the System Marginal Price (SMP) for each half-hour trading period is determined by SEMO.

Figure 3: Differential Price Between Generator Bids & SMP, [16]

· Generators below this price are considered in merit. Above this price considered Out of Merit.

· Out of merit generators tend to be old inefficient plants.

· Peaking plants are highest running cost but the lowest fixed costs. The costs associated with peaking are recovered in the SMP and also the fixed czost capacity payment.

· The selling of the wholesale electricity into a centralised pool is mandatory by all generators within the SEM.

· When the suppliers are buying electricity, the SEMO sells them the electricity at SMP also called the wholesale price.

· Generators can make a profit if their submitted bid is lower than the SMP. This is called the “infra-marginal rent rate”,(IRR).

· The SEMO sells the cheapest electricity first till the cheapest bidder capacity runs out. The SEMO will then move down the list the next cheapest bidder.

Figure 4: SME Pricing Structure, [16].

· The SEM facilitates the running of the cheapest possible and most efficient generators first.

· All generators will receive payments towards their fixed cost based upon their capacity based upon the low fixed costs of a peaking plant. This is called the “Capacity Payment”.

· “Infra-marginal rent is needed for most generators that are run, including modern gas plants and wind farms, because while such plants have relatively low running costs (SRMC), they have much higher fixed costs which the (relatively low) capacity payment does not fully cover. Without infra-marginal rent, it would not be economic to build modern efficient power plants or wind farms, threatening security of electricity supply and driving higher prices in the long-run. Wind farms are an example of electricity generators that have very low SRMC - the wind is free - and so typically they receive a higher rate of infra-marginal rent than other electricity generators, which in turn is needed to pay for their much higher fixed costs”, [16].

· 80% of the island electricity is from fossil fuels, so there is a dependent relationship between the SMP and daily gas prices. The higher gas prices, the higher the SMP. This is actually good for windfarm generators, the higher the SMP, high the infra-marginal rent and profitability of the windfarm development.

· The SMP is set at half hour intervals during the day. The SMP price trend follows customer demand trends. Increase in customer demand lead to an increase in SMP. SMP increases as the less efficient generators come online.

· The SMP consist of two parts, the shadow price, payment for the standard variable cost of generation. The other part is the uplift. Uplift costs are associated with start-up and no-loads to bring addition generators online to meet grid demand.

Figure 5: SMP Day Trend, [16].

· Highest SMP is estimated to be between 5-7pm in the evening.

· All costs due from the supplier’s and due to generators are calculated retrospectively based upon the SMP figures for the day of physical generation.

Under the SEM it is the SEMO that decides what generator run and for how long. This is actually very advantageous to windfarm development. The baseload demand for varying time during the day can be dealt with by renewable sources and gas plants could be used to handle peaks or days of low wind. The argument against the windfarms is that the generation capacity will have to be installed anyway, in addition to wind, so it is cheaper from a capital expenditure point of to install efficient fossil plants based upon the experience of those who take part in the SME.

The structure of the SME facilitates the integration of more hydro-storage or (other storage methods), to the grid to store wind energy or handle peak demands. Fossil generators will have a cost advantage over the Hydro-Storage plants, therefore a carbon based tax could be implemented to level out the cost advantage and promote more renewable philosophy.

To apply for participation in the SME is via the CER. The application is included on a section of the form to apply for a generation licence.

Under sections 14(1) (c) and (d) of the Electricity Regulation Act 1999, there is a requirement on electricity supplier to buy wholesale electricity from generators with Green or CHP licences, thus ensuring that a certain percentage electricity is generated from sources with extremely low carbon footprints. This is regulated by the CER though the SEM sector. The CER believes that this is an example of how the SME mechanisms are promoting renewables through market regulation. Thus ensuring the success of the renewable business case with a return on investment. This in turn provides to encourage investment and growth into the sector o reduce our dependence on fossil fuels. The industry how disagrees with this position, [16].

Gate Application Process.

The gate process is part of the Grid Development Strategy, (GDS). It is regulated by the CER and it is method chosen that allows both renewable and non-renewable energy producers to apply for connection to the national grid. The main objective of the Gate process is to facilitate EirGrid and ESB Networks to plan the development of the national grid, (both the transmission and distribution networks). Based on the confirmed offers from the gate process, EirGrid have developed Grid25, the national development plan for the grid to be completed by 2025 in an optimal long-term manner. Grid25 will be the program that will cater for anticipated demand and generation requirements in 2025, as requested in the Government’s White paper on energy. Grid25 will also determine the Incremental Transfer Capacity, (ITC).

Grid 25 plans to connect certain regions of Ireland, mainly in the west of the country, that are considered to have a greater potential for wind generation compared to others. However the grid in the regions of greatest potential is undersized for power transmission. Cost benefit studies are now underway to assess the business case for upgrading of the grid in these areas such that the potential for wind generation can be fully developed. Once such study is the “Renewable Integration Development Program” This program is examining the Northwest of the island. It is a joint venture between EirGrid, Northern Ireland Electricity, (NIE), and System Operator for Northern Ireland, (SONi).

“Grid25 anticipates current and future generation, interconnection and demand growth. It therefore marks a significant shift from current practice in that the transmission system would no longer be developed largely on a reactive basis in response to connection applications, but instead there would be more emphasis on planning and developing the system in advance to meet anticipated generation (including renewable generation) and demand requirements for the longer-term”,[19].In Germany connection to the Grid is reactive and will only occur when a wind development ha achieved planning permission, still developing the grid under a reactive basis.

It is the CER believe that “by planning and developing the transmission system to meet the anticipated demand and generation needs of the long-term, a more cost efficient, optimal and effective system can be provided for than would be the case if a more short-term and piecemeal approach were taken to grid development. This is especially the case in the context of dramatically increasing amounts of dispersed - frequently renewable - generation that will be connecting to the system over the coming years”, [19].

As discussed in this article, Ireland has a legal requirement to product 40% of our electrical energy demands from renewable sources by 2020. The majority of this 40% renewable energy will be generated from wind. In the issuing of the Gate 3 call, the CER decided to size of Gate 3 should 3,900MW for renewable. This figure is made up of 3,130MW determined as required 770MW reserved. This reserve is an allowance for speculative applications submitted due the flexibilities outlined below.

The CER estimated that ca 5,800 MW installed capacity is required for the Ireland is to meet it 40% renewable commitments. In determining the size of the renewable capacity for Gate 3 is was assumed that all contracted renewable projects up to the end of Gate 2 offers would be connected over the next few years and provide circa 2,800 MW of renewable energy. (before any consideration is given to Gate 3). The current status of Gate 2 is given in the table below.

Table 1: Current Status of Gate 2, [19].

The CER has assumed that there will be increase in biomass to 150 MW in the renewable portfolio and that the remaining renewable generation comes from wind. The CER has assumed that 2,800MW will come from Gate 2 and that 3,000MW will come from Gate 3. (Based upon the experience over the last two years of an average load factor for both Gates is assumed to be 31%). To allow for flexibility within the Gate 3 mechanisms, 770MW reserved was allowed for. However there are concerns that within the industry that the CER’s assumptions are wrong. The industry feels that the reserve should be increased to 1,200MW. It is felt that the CER have not acknowledged that there is a possibility that a significant portion of the contracted (but not yet connected) renewable projects, unsigned Gate 2 offers and projects in Gate 3 will not be built for planning and other reasons. The IWEA feels that electrical power demand will go beyond the figure predicted by the CER for 2020.

After conferring with the CER EirGrid developed a GDS model for demand/generation assumptions for 2025. 5,000 randomly generated scenarios were ran to provide a probability analysis of how the proposed new grid would handle 2025 requirements. (Issues with efficiency, safety and cost effectiveness were reviewed).

This probability analysis is a move away from the strict application of the transmission planning criteria under which generators are connected with firm transmission access on the basis of an “n-1-1” transmission planning standard. This standard includes an unplanned line outage and a line out for maintenance. Instead, the new transmission capacity assumptions and the ITC Programme operates to an “n-1” only transmission planning standard for renewable generators (though still “n-1-1” for demand), representing a more flexible and probabilistic approach to determining the future transmission build that is necessary to connect renewable generators on a firm basis This method recognises that building expensive transmission infrastructure for generators - which can take several years - may not always be the most efficient and effective solution where the anticipated level/probability of constraints is low”, [19].

The CER have allowed the following flexibilities in the Gate 3 application process:

1. Full granting of the planning application for the wind development is not required.

2. Applications are assessed on a first submitted first assessed basis. Any of the applications submitted but not processed under Gate 2, were automatically top of the list for process under Gate 3.

3. Any wind developments under discussion with the TSO between Gates 2 and 3 were next in priority for processing after the overspill from Gate 2. Schlez and Tindal suggest that a site should ideally be in good proximity to a medium voltage line. To fully assess all requirements needed to the connect the grid, talks must be held with system operator, (EirgRid), [1].

Talks conducted with Eirgrid at an early stage will determine realistic budget costings. These budget costs will be critical role in the cost benefit analysis conducted to establish if a particular site is economically viable. Key to good project management is to develop realistic and accurate budget cost baseline to control project costs against. Speaking to EirGrid to get realistic budget costs is excellent project management practices.

Applicants who spoke to EirGrid prior to the Gate call being issued were included in pre selection for the next Gate, as a reward. By doing this applicant were getting an earlier place in the queue for the processing of their grid application. Under PMI practice EirGrid is a project stakeholder. Talking to EirGrid as soon as possible in the project is good project management.

4. Agreed wayleaves for access to the sites signed by the landowner is required. This requirement is included to mitigate the potential for land access disputes which could delay Gate 3. The CER requires the applicant confirms in writing, and witnessed by a solicitor, that it has acquired any necessary landowner consent(s). This includes the land on which turbines and substation are to be located. Failure to provide this statement will mean the application will not be processed.

5. Gate 3 allows for applicant to increase their export capacity by 20%. It was excepted by the CER that some development are in the early design stage and hence the detailed performance specification would not be known by the date of application. The flexibility in the export capacity was included to cater for these scenarios. The 3,130 MW of Gate 3 allows for the additional possible increase in export capacity of an applicant.

6. When considering the order of processing applications, the applications that have the least technical complexity will be processed first. The CER believes that doing this fits with their philosophy of issuing Gate offers as quickly as possible. It is envisaged that this method will speed up connection of wind developments to the grid to meet the 40% government target.

7. Gate 3 allows the Transmission Firm Capacity, (TFC), will be available on an individual, rather than on a group or subgroup basis. For efficient utilisation of the assets, the operator may request that the developer participate in a group or sub-group. TF offers are made to individuals. Every person in the group or subgroup will have a different offer date and date of connection. The CER has outline pricing guideline for this scenario.

The closing date for the Gate 3 call was 16th November 2007. (The CER had to reopen Gate 3 in November 2008 as the Government increased the renewable target from 33% to 40% in October 2008). Any submission after this date was not processed. The CER viewed that in-line with industry feed back that a cut-off date system was fairest, consist and must robust manner in which to reach 3,900MW capacity. Within the Gate 3 regulations there is a requirement for the CER to review the transmission capacity assumptions every 2 years. Changes to obligations can be made under these regulations. The purpose of this mechanism is to allow speculative applications with confirmed offers, but where the development of the site was stopped, to withdraw from the process. It was envisaged in 2007, that refusal of planning permission for developments would be the issue that would cause the largest amount of speculative applications to withdraw from Gate 3.

The estimated period timelines from which applications will be notified of the status of their application will be from September 2009 to June 2011. The system operators have committed to issuing offers, over 18 months, until the Gate MW renewable is filled. From the Gate Process, the CER will determine how the 3,900MW renewable capacity will be connected to the grid. This distribution will be included in the ITC Program. (It is the ITC program that determines estimated firm connection dates).

The Gate 3 Liaison Group meetings monitor the offer program to help ensure that it is being adhered to. The Gate 3 Liaison Group a high-level industry group ensuring that processing rules are being adhered to. It consists of representatives from the CER, green generators like the IWEA and non green generators.

EirGrid have complex rules for physical connection to the grid and determining:

· What developer will be connected to which node.

· If an individual developer or group of developers will be connected to a particular node.

· The size and location of each node.

· If a new node will be installed.

· If an existing node will be upgraded.

The CER has advised that the rules have been devised to provide as much transparency as possible to the industry, in the initial assignment of nodes to applicants, in order to facilitate the running of the ITC Programme as part of Gate 3. The Gate 3 offer made to the developer by EirGrid will identify the specific node at which the windfarm exports to the transmission system. The exact method for connection of the development will be determined following detailed studies.

EirGrid defines each nodes as follows:

· “A node is a busbar of the appropriate voltage.

· A 110 kV node may be a 110 kV station or alternatively a 110 kV busbar in a 220 kV or 400 kV station.

· A 220 kV node may be a 220 kV station or alternatively a 220 kV busbar in a 400 kV station.

· connection to an existing lower voltage [38 kV, 20kV, 10 kV, LV] node embedded in the Distribution System, the

transmission voltage node that will used will be on the basis of the normal feeding arrangements of that lower voltage node from transmission voltage level.”, [19]

Where a developer has a MEC of less than 40MW, the system operator may prefer to install a new node at a location selected by them and considered to be the most appropriate location in their judgment.

If there are a number of applications in a given geographical area, whose total MEC is equal to or less than 40MW. If one of the applicants has a concentration that is clearly larger than others in the concentration, then EirGrid will locate the node at the site of the largest applicant.

Similarly to above the same will happen:

· For a 110kV node the applicant, (or group of applicants in an area), whose MEC is between 40MW to 177MW.

· For a 220/400kV node the applicant, (or group of applicants in an area), whose MEC is equal to or greater than

200MW.

Applicants will be assigned voltage selection as follows:

· with less than or equal to 5 MW connect to a 38 kV node.

· with more than 5 MW but less than 10 MW connect to a 38 kV node.

· with more than 10 MW but less than 40 MW connect to a 110 kV node.

· Any new 38 kV node will be assumed to connect to the nearest 110 kV node.

· with more than 40 MW or over but less than 177 MW will require a 110 kV metered supply at the generator’

substation.

· 177 MW or over will require a 220 kV or 400 kV metered supply at the generator substation.

Purely for the purposes of node assignment, extensions will be defined as those projects which have the same co-ordinates and are owned by the same legal entity as an existing development. Where the extension(s) cannot be accommodated on that line/cable then the System Operators will apply their best judgement in allocating a Transmission Node.

A gate application will consist of the following:

  1. “Initial application fee of €7,000;

  2. Legal applicant name, address and company registration number;

  3. Contact name and address;

  4. Generator address and grid coordinates;

  5. Two copies of signed confidentiality agreement;

  6. MEC;

  7. MIC;

  8. Internal network layout and major equipment location (e.g. turbines, stations, etc) on a Discovery Series 1:50000 OS Map or a similar appropriate scale;

  9. Preferred connection date;

  10. Preference for single or multiple connecting circuits; and,

  11. Signed statement from applicant that any necessary landowner consents are in place for the project and witnessed by a solicitor”

The first initial €7,000 of the fee is paid with the application. The next installment is invoice with the gate decision and to be paid within 20 days of the notification. The balance of the fee is to be paid typically six weeks before the connection date. There is no fee for connection to the distribution system.

At time of application certain detailed design and equipment performance data may not be known with typically assumed values used in the studies for transmission planning criteria. Full accurate data is requested to be submitted to the system operator one year before energisation to enable all the studies in with assumed data was used to be reran. Any studies must be completed and a modification agreement accepted 6 months prior to first energisation or first energisation may be delayed. Typical data requested would be turbine manufacturer, cable layout, protection equipment, specification of transformer.

The CER decided to allow this data be submitted at a later date rather than with the application is an attempt to enhance the flexibility of Gate application process. This follows a complain by the industry that during Gate 2, the data requested by the operator with application was to onerous on the applicant and simplification was needed. It was stated by the industry that the data may not be known at the time of application and a mechanism was needed for submitting it afterwards. For Gate 3 if the detailed design data is received during application processing but after the data of application submission, this will be handled as a modification request.

Assumed data used by the system operator for studies is detailed as part of the connection offer. Any deviation between the actual equipment parameters used in the studies and the installed can significant risk to the developer and may have adverse effects on the project. Consequences include additional works with resultant cost, reworks and delays in connection. In extreme cases the developer may lose his place in the queue.

If the EirGrid is dealing with a group or sub-group, they will write to each member of the group asking them if they want to use the technical data submitted with the application for the completion of the studies or if the individual wants to submit new data. Any change to data or additional information must be submitted with 30 days of the receipt of the notification letter from EirGrid.

EirGrid have developed a methodology for determining which developer’s MEC is assigned to which local node. Consider the following frictional example explains principle of node assignment for the gate system:

Developers A and B are located within the sample geographical area. Developer A submitted a request for 10MW on 1st July 2007 and Developer B submitted a request for 8MW on 1st September 2007. Developer C submitted a request for 4MW. Developers A & B got confirmed offers from the CER for the current Gate. Developer C did not get a confirmed offer for the current Gate. No other Gate requests for this area were made. The current local node in the area has a capacity to for 7MW. From their studies, EirGrid has planned the following for the area:

  1. Developer A will get connected to Grid with a 7MW on 1st September 2008.

  2. The local node will be upgraded to 20MW completed on 4th January 2009.

  3. Developer A will get connected to Grid with the remaining 3MW before Developer B is connected scheduled for 10th April 2009.

  4. Developer B can only be connected to the grid after 10th April 2009. His connection is scheduled for 10th September 2009. Developers B full MEC of 10MW will be connected.

  5. The upgraded node now is now transmitting 18MW of power and has a spare capacity of 2MW.

During 2009 the CER will complete the first 2 yearly review of the current status of the Gate process. In May 2009, Developer B only got planning permission for 5MW. Under the review mechanism, the CER decided to reorganise and reissue the confirmed offers under the current Gate. Their decision was follows:

· The confirmed offer to Developer A of 10MW MEC remained unchanged.

· The confirmed offer to Developer B was revised and reduced to 5MW.

· A confirmed offer to Developer C for a MEC of 4 MW was made.

· The revised spare capacity in the node was reduced from 2MW to 1MW.

EirGrid would also consider the effect on capacity the downstream node, (i.e. the node in which the node at the wind farm feeds into), in their deliberations before making a confirmed offer to the developer.

In conclusion “The CER continues to believe that the group processing regime represents the most efficient and practical method of processing for connection the large volume of renewable applications. From their consultations with the wind industry, there was no respondent to the CER that proposed suggestions to abandon it”. The CER believe that the current Gate Mechanism will prevent large scale developments held –up with problems being leap frogged by smaller developments, [19].

Renewable Feed In Tariff (REFIT) Scheme & Revenue Generation.

The Renewable Feed In Tariff (REFIT) Scheme was an initiative by the European Commission to encourage the development of renewable energy sources. The first REFIT scheme ('REFIT 1') was announced in 2006 and was approved as state aid in 2007. The REFIT 1 scheme was open for applications until 31st December 2009. After this date no new applications were submitted. There is no REFIT scheme for Gate 3. Some projects that were accepted into the scheme before that the closing date, were granted an extension of time to become operational.

REFIT 3 is concerned with biomass and is outside the scope of this article, but has recently been approved for state aid. An application from Ireland is currently with the European Commission for state aid approval for the REFIT 2. As of November 2011, No decision has been made on this. The REFIT scheme is funded through the Public Service Obligation (PSO) charged to all electricity consumers (Section 39 of the Electricity Regulation Act 1999 sets out the legal basis for the PSO).

The REFIT Scheme was administered by the Irish Department of Communications, Energy & Natural Resources, (DCENR), an entirely separated administration body to the CER. Under the terms of the REFIT scheme, each generator is obliged to enter a PPA with a licensed supplier. The REFIT payment is based upon one type of generation technology category, (i.e. either wind or biomass, but not both). The REFIT payment is for 15 years. To apply to the DCENR for a REFIT, (based upon the original in 2006), the following would be required:

· Evidence of Power Purchase Agreements (PPAs) with a valid and currently licensed REFIT supplier registered with the CER.

· Proof of grid connection for the project must be supplied.

· Evidence of current and valid planning permission for the project.

For the wind farm to get the REFIT payment, the project will need to be listed in the REFIT Statutory Instrument, annually updated by DCENR. It is emphasised that REFIT is only payable for electrical exported to the grid.

REFIT payments are only made to those suppliers on behalf of specific projects that were notified by the suppliers to be included in the CER’s PSO Decision, ahead of the commencement of the particular PSO year.

The Irish DCENR had stated that the processing order for applications will be clarified when the new REFIT scheme is announced and will facilitate projects that are already operational or that will shortly become operational. All the terms have not been fully clarified by the DCENR yet.

The CER determines the calculation method use to determine the REFIT payment on a on a yearly basis from the PSO.

Figure 6: Standard Arrangement for the REFIT 1 Scheme, [20].

A reference price is published annually for each generation technology. It is also indexed to account for inflation. The supplier is paid 15% of wind reference price for every kWh purchased.

If PPA price is greater than the reference price, the supplier is paid the difference between the PPA price and the reference price.

If PPA price is less than the reference price, the supplier is not paid any difference, but still receives the 15% of wind reference price for every kWh. The SEM operates similarly in terms of the wholesale electrical price for REFIT projects.

The REFIT is considered state aid, but as it is paid by the customer through the PSO. The industry have queried why is REFIT considered state aid. Being considered as state’s aid makes it subjective to complex EU regulation and delays it implementation. REFIT funds come from the consumer via PSO payments. REFIT funds not paid from the State Budget. German and UK support systems not considered state aid. There would be a preference to have the REFIT system ran on similar lines to UK. The IWEA believe this would reduce the red tape and work load on generators, resulting in lower operational costs.

German law says wind any project with planning automatically entitled to REFIT and grid”, [20]. The IWEA have asked government why there is not a simple “all-in-one” application for planning, REFIT, grid connection and generation license. The government has not replied to this call,[20].

It is accepted within the wind energy industry that the new REFIT proposed could potentially introduce unfair competition into the SEM.. Existing renewable generators which are coming to the end of, or are no longer in a government PPA contract may not be able to compete with wind generators in a new REFIT Scheme. It is envisaged that the electricity price will be considerably reduced during high wind as electricity production will be increased. The SEM is designed to suit the fossil generators. (They produce 80% of the electricity for Ireland). The major concern is that the non-PPA contracted generators will be forced in a non-viable business case by the excessive competitive market place principle of the SEM. It is believed that the new windfarm developments should be subsidised

The industry is concerned that if the current circumstances continue, the old wind farms may have to be taken out of operation, as they will not be able to compete openly in the SME. The IWEA have argued that the original REFIT 1 projects were granted via competitive tender rules and delivered renewable power at a very low price per kWh thus making the projects operate on exceedingly tight margins. The expectation was that there would be an ability to continue producing renewable electricity after the contract period at a profitable margin. They feel that the SEM structure does not provide this and is in contradiction to the promotion of wind/renewables by the European Union. The industry believes that the following need issues to be addressed:

· Reference prices.

· Indexation.

· Intermediaries and capacity payments.

· Operation of the SEM., [21].

In the operation of the SEM, let us consider the following graphs:

Figure 7: Average System Marginal Price in the SEM, [20].

Figure 8: Average Market Schedule for Wind in SEM, [20].

Figure 9: Average Load Weighted Price for Wind in SEM, [20].

Figure 10: Average Load Weighted Price by Type in SEM, [20].

The Graphs above indicates the performance of the wind energy within the SEM. The average wind energy payment was ca. 7.4c per kWh of output, (based on Jan, Feb, Mar). This was the period for highest wind also). The capacity payment for a wind farm was approximately 1c/kWh produced. As seen above, wind is a technology with one of the lowest SMP in the SEM. In the DCENR’s REFIT clarifications of January 2009, it showed the last price was 6.3739c/kWh. Using an average CPI of 4%, 2010 and 2011, gives a reference wind price of ca. 6.894c/kWh, [23]. The 15% of the wind reference price that the supplier gets as a rebate from the REFIT is ca. 1.03c kW/h.

Therefore basezd upon above, it may be concluded the SEM gives a better return, z(total of 8.4c /kWh compared to the REFIT scheme where the PPA only guarantees a reference price of ca. 6.894c/kWh. The only advantage that the REFIT scheme has over the SEM is certainty of a supplier to purchase the volume of power under the PPA. This gives the REFIT scheme an advantage over the SEM. So based upon the figures above, the SEM and REFIT scheme are approximately equal. The security of the REFIT scheme is preferred by the IWEA over the variations of the SEM. Ireland is the only country in Europe not operating a REFIT scheme at the moment. Ireland and Northern Ireland are the only countries in Europe operating a SEM. The SEM has removed the need for balancing payment and issues associated with balancing. It is also in the supplier’s interest to keep the REFIT scheme as they are effectively getting a 15% discount on the electrical reference price. The more wind that comes onto the grid, the lower the SMP and the IRR will reduce. This means that the SMP will come close to the REFIT reference price and wholesale cost to the supplier will fall, (they will still get their 15% discount paid for by the end consumer in the PSO charge). The IWEA believe that this trend will erode the revenue stream of wind farms making developers shy about investing in wind farms. The IWEA would like to see:

· Capacity payment increases to 2c kW/h

· REFIT scheme for Gate 1 projects not yet in operation should run for the full 15 years.

· IRR to be a minimum of 12% guaranteed for wind.

· Grid connection and transmission charges reviewed and lowered.

Losses on the transmission grid is also another issue of cost concern, but outside scope of this article. One functions of the SEMO is to manage load on the grid and advising when generators are to come online. At the establishment of the SEM, it was though that transmission losses on the grid would be greatly reduced. The balancing issues is also eliminated.

Another concern of the wind industry has is that “generators in Northern Ireland are paid for Renewable Obligation Certificates, (ROC) by the UK government which is an additional payment to the energy (plus capacity) payment. This means that they can bid their electricity sale price substantially lower and still receive equal income, (due to the ROC payment), compared to their counterpart renewable generators in the Republic. This is putting renewable generators in the Republic trading in the Single Electricity Market at a significant disadvantage as the NI renewable generators could conceivably pay the SEM to take electricity (a negative SMP is possible in the SEM) and still have an income from the ROCs”, [21]

Wind Site Development Preliminary Works.

The first step in the development of a wind farm project is to identify potential sites and conduct feasibility studies. To fully evaluate the potential of any site and its economic viability, a study of the local wind regime is necessary. The local planning authorities have developed county development plans reports for each their own areas. Included in the county development plans is a specific section totally dedicated to wind energy development. The plan identifies:

· areas considered as suitable for wind farm development.

· areas considered not suitable for wind farm development.

· Special Areas of Conservation.

· Special Areas of Amenity.

· location of existing and future infrastructure, (e.g. the grid lines and its future extensions).

This development plan is a good document for investors and developers to identify potential windfarms for further consideration.

The starting point for a developer in considering a site is to review the average wind speeds in the area, (minimum of 5 to 10ms/), using sustainable Ireland Energy’s online wind atlas. After that an anemometry mast should be installed onsite. For preliminary studies one mast maybe installed on the site. Once the preliminary readings of the mast confirm the availability of the wind potential, several masts may be placed on the site. These masts will confirm the variation in wind speed over the site area. This data greatly assists in detailed the design of the site. The general rules of thumb for position of the anemometry masts are:

“The mast should be placed at least two thirds of the hub height of the turbine.

In very severe terrain, the closest mast should be within 500m.

In simple terrain a much lower density of masts over the site would be appropriate.”

Schlez and Tindal advise that no turbine should be located more than one kilometre from the mast in design of the wind farm, especially in complex terrain. It is standard practice to leave these masts in place for at least 12 months to observe any seasonal change in the wind patterns. [1].

Planning permission is required for wind measuring masts. These planning permissions are granted for a two year period. This period can only be extended upon submission of and granting of a retention planning application for the mask. Otherwise the mast would have to be removed, [5].

Preliminary Site Layout Design.

Data from the wind regime is used within a computer numerical model to help develop the best preliminary site layout design. (i.e. first draft of placing the turbines on the site). Once the site is confirmed as having good wind potential, the site constrains must identified and defined. Typical site constrains are:

· Site boundary.

· Set back from obstructions, ownership boundaries etc,

· Location of visually sensitive viewpoints and assessment criteria

· Maximum installed capacity due to grid capacity or Power Purchase Agreement.

· Environmental Constrains.

· Planning constrains, (Noise, turbine type, shadow castings beside dwellings etc.).

· Turbine minimum spacing.

· Access to site. [1].

Provision of access to a site for construction and operation requirements is a key parameter for consideration when selecting and assessing the economical viable of that site. Access to site must accommodate the delivery of turbines and removal of surplus material from the site during construction. Terrain is the most influencing factor on the cost of providing access to a site, in particular the incline of any slope. The slope of the incline is a key parameter in the design of any site roads.

Planning Legislation.

Planning legislation applicable to the windfarm developments are:

· Planning and Development Act 2000 (No. 30 of 2000), used by local planning authorities.

· Planning and Development (Strategic Infrastructure) Act 2006 (No. 27 of 2006) used on projects considered to be of national strategic importance.

The latter is used for projects of “national strategic importance”,[5]. It is an act that provides a mechanism of applying for planning permission directly to An Bord Pleanala for developments that are considered in the common good of the state. Local Authorities are not included in this process. The board appoints a planning inspector to review the application, site and submissions on the application. The inspector then makes a recommendation to the bord for or against. This act is used for seeking planning permission for road, electrical transmission lines and public infrastructure.

The Planning and Development Act 2000 is the legislation which defines the normal planning regulations for all types of developments. This is the act which includes the requirements for the Environmental Impact Assessment to be completed on all developments over a certain size and value.

Typically the windfarm applications a submitted to the local planning authority under Planning and Development Act 2000, however a developer in Clare submitted a planning application to An Bord Pleanala under the Planning and Development (Strategic Infrastructure) Act 2006.

Gordon Deegan of the Irish Examiner reported that a €100 million, planned for west Clare is to bypass the normal planning process. He states that the justification was the wind farm is considered strategic infrastructure and can be considered directly by the appeals board. He reports that Clare Coastal Wind Power had a pre-planning application consultation with an Bord Pleanála. In that meeting Clare Coastal Wind Power claim that “the development would contribute substantially to the fulfilment of any of the objectives in the National Spatial Strategy or in any regional planning guidelines by assisting in meeting goals in relation to sustainable energy”, [11].

The paper also reports that in the inspector’s report back the board “the applicants state that the plan would be of strategic economic or social importance to the state or the region in terms of benefits to the local economy in providing electricity; the annual reduction of 207,000 tonnes of CO2 and displacement of use of fossil fuel generation of an annual energy equivalent production from 77,280 tonnes of oil”

The paper reports also that Clare Coastal Wind Power must submit an Environmental Impact Statement and application with An Bord Pleanála. During this time third parties will also have opportunities to make submissions on the application.

This article raises an interesting question, what happens when a development is of national strategic importance? Does national interest overrule local interest? The departments guidelines do not address this issue, only refers it back to the local planning authority, stating that they must follow current guidelines and policy laid down by the government. Research within the scope of this assignment would indicate the references planning authorities follow are not coordinated at best and are in conflict in some cases. An example of this was a proposal for the wind farm in Connemara, (detailed later in the article). In this case the planning authority identified with as an area suitable for wind turbines to be erected in. The planning appeals board did not consider it suitable. The boards concern was that the turbine development would adversely effect the visual impact in an area with a reputation of natural scenic beauty. The board also were concerned that the presence of the turbines would hurt the local economy highly dependent on the tourism trade.

It is conceivable that more developers will use the Strategic Infrastructure regulations rather than the normal planning regulations to expedite the planning process as 2020 draws closer. This may have a negative impact on the “buy-in factor” for development of wind power in Ireland as local people will feel that their rights and opinions are not being considered or respected. Thus the objection to turbines will be stronger. It should be noted also that planning applications are not considered in isolation, but with reference to county development plans, National Spatial Strategy, National Development Plan and other government policies.

Grid Planning Permission.

EirGrid must get planning permission for development of the national grid. Planning permission for the grid is completely separate from the windfarm planning application. It is also completely separate from applying to EirGrid for a grid connection. Typically power is taken from each turbine to the windfarm’s substation via underground cabling. It is at this substation that the grid is connected.

The department’s planning guidelines on windfarms propose an integrated application, for both the windfarm and grid connection. This however is highly unlikely as Eirgrid prefer to use their own in-house procedures for handling such planning applications.

The 400/220kV line planning applications are submitted under the (Strategic Infrastructure) Act 2006. Submissions are invited by 3rd parties during the processing stage of the application under these regulations.

The 110/38kV lines applications are made to the local authorities under the normal planning regulations. These lines are also subject to “The Local Government, (Planning & Development Regulations), 2001.” Under Section 28 of this act, “Location of Overhead Lines”, the electrical company must follow a pre-determined route approved by the planning authority or keep a minimum distance of 40m either side of notional line, [13]

These lines are subject to appeals procedure under the 2000 planning regulations. Appeals must be lodged with 4 weeks of the planning decision being made. In addition these lines are also subject to the requirement of an EIA being completed.

Class 27 of the Local Government, (Planning & Development Regulations), 2001”, states that transmission and distribution lines of 20KV or less do not require planning permission, with the only exception to this being a Area of Special Amenity define within the regulations. This would be where there is a concern that it would interfere with the “Character of the landscape”,[5].

Class 26 of the Local Government, (Planning & Development Regulations), 2001”, states that the laying of underground mains, cables and pipes are excluded from planning permission.

Class 29 of the Local Government, (Planning & Development Regulations), 2001”, states that substations of 20kV or less do not require planning permission, provided that the above ground volume in not greater than 11 cubic meters, measured externally. Again only exception to this regulation is for Areas of Special Amenity.

All of the above lines would be subject to similar objections as a windfarm. Main concerns being visual impact with the pylons on the landscape, and electromagnetic radiation from the transmission lines. Recently the public are of the growing opinion that all power cables should be underground, especially near residual areas.

Other powers given to ESB networks to aid the development of the national grid are:

· ESB Networks can open a Road or Street without a licencse from the local Authority.

· ESB Networks can acquire wayleaves for both above ground and below ground lines by Compulsory Purchase Order.

Pre-planning Consultation.

After the completion of the feasibility study, the next step in the project is to meet with the planning authority. To get maximum value out of the pre-planning meeting the authority would invite the developer to put in a pre-planning submission. It is recommended also that a project scope statement, location and site maps, details of the current existing infrastructure, details of the development infrastructure requirements, economic market case study, zone of theoretical visibility samples and details of the proposed EIA study are forwarded to the planning authority in pre-planning submission. It is recommended that the pre-planning submission is submitted before the pre-planning meeting with the authority, [5]. The planning authority is a major stakeholder on the project. The pre-planning meeting is considered good stakeholder management under the PMI system.

Public Consultation.

The Best Practice Guidelines for the Irish Wind Energy Industry Published by the Irish Wind Energy Association, (IWEA) & Sustainable Energy Ireland, (SEI), recommend that the consultation with the public should definitely carried out. They recommend that this process is only commenced after the feasible study has been completed because up until this point, there has been no commitment to the project by the developer. The IWEA/SEI suggest consultation be held with the public at the following stages of the project:

· “Early Project Development/ Pre-Planning

· Environmental Impact Assessment.

· Several times during construction.

· Regular intervals during operation”, [6].

It is important for project success to get community support for such a development. In project terms the community in which the windfarm is being built are stakeholders. The Project Management Institute publishes protocols for managing projects, called the PMBOK, [7]. The PMBOK suggests that all stakeholders be identified during the planning stages of the projects. After the of consultation meetings take place, people’s concerns should be logged in a stakeholders register. During the development of the project scope the stakeholders requirements logged on the stakeholder register are included or excluded in the project scope. Project management procedure requires stakeholders whose requirements are excluded are informed of this via the project communications plan and explanation of why their requirements are excluded given to them. In a project like this, the typical method in communicating with local communities, (considered as a stakeholders group), is public meetings.

Normally before commencement of these public consultations with local communities, the following would be completed:

· Feasibility Study.

· Preliminary review of the EIA,

· Photo montages.

· Noise study.

· Review of local infrastructural and upgrades requirements including grid, access roads and drainage.

· Method of Construction identified.

It is recommended the developer gives a lo-call number during the consultation process to enable queries from the local community be processed.

Planning Process.

Every wind farm development requires a planning permission. Current common practice is to submit wind farm planning applications to the planning authority in the county of construction. This allows time for local residents and any other party to view the development proposal and submit queries and objections to it. The most frequent identified objections to wind farm developments were:

· Visual impact on the landscape

· Shadow flicker.

· Noise generated by the wind turbines.

· Electromagnetic inference.

· Habitats and Birds Directives/Special Areas of Conversation”, (SAC’s).

· Impact on tourism trade, (Spoiling of natural landscape).

· Soil mechanics.

· Infrastructural & grid connection.

· Aviation light pollution.

The planning authority reviews the application with reference to government energy policy and legal regulatory requirements including but not limited to:

· Planning and Development Act 2000.

· Electricity Regulation Act 1999.

· EU Directive 92/43/EEC Habitat Directive.

· EU Directive 79/409/EEC, Birds Directive.

· Environnemental Impact Assessment Directive.

· National Biodiversity Plan, 2002.

To date most of the potential sites are located remote natural scenic SAC areas. Some of these areas are also designated areas of historical significant. Organisations such as An Durlas and An Taisce review proposes for new infrastructural developments during the planning process to ensure that there is no environmental or historical disturbance associated with the development. An Environmental Impact Assessment, (EIA) has to be conducted under planning regulations.

An Taisce have developed an energy unit and are quiet proactive in their support of renewable energy developments, but in an environmental supportive way. An Taisce recommend that further co-ordination between all energy sector participants resulting in a management strategy rather than a policy approach. They have called for an integrated management strategy at EU, government and local level. They would also like to see standard model developed to be used nationally especially in the area of public consultation by the Commission for Energy Regulation, (CER) and the Department of Environment’s planning section. Their view is Guidelines can be interpreted in a variety of ways, dependent upon the project stakeholder involved. Their preferred view would be a set of national obligations were implemented, [4].

The Department of the Environment, Heritage & Local Government published guidelines for the development of windfarms. The guidelines were issued under section 28 of the Planning and Development Act, 2000. Therefore both planning authorities and An Bord Pleanana must refer to them during the execution of their duties with regard to windfarms.

Section 3 of these guidelines indicates the need for the planning authority to conduct assessment of potential sites within their area that they could considered suitable and unsuitable for development. The results of this study are laid out in the wind energy development plan for that county. It aims is to provide clarity for the public, developer and the planning authority. The planning guidelines require the planning authority to be proactively support the development of potential wind energy generation sites. The wind development plan compiled by the planning authority identifies local sites, they accept in principle are suitable for development. These sites will have been determined by the authority to have the greatest wind potential in the county. The development plan maps will also identify sites of “scenic quality, rarity, uniqueness, natural and culture heritage consideration”, [5], and historical significance. The maps will also show locations and routes of the transmission grids. The purpose of this wind development plan is exploit natural wind resources in planned, co-ordinated and environmentally friendly way. The plan is aimed at achieving census among all project stakeholders, thus minimising the time for planning approval and wind farm development.

In recent years, in areas considered to have a natural scenic quality, the tourism and recreation industries have object to planning permissions for wind turbines. They have stated that the turbines adversely impact on the scenic quality of the landscape and which could impact negatively on the tourism potential of an area, especially in areas where tourism is the main source of revenue. Guidelines require the authority to give this due consideration when making a decision on planning. The guidelines propose that roads to windfarm may open access to areas so as to improve the recreation potential. The department suggest that this could be a possible comprise solution to certain objections, to be worked out between the planning authority and the developer at local level, [5].

The Department’s guidelines also suggest that the planning authority should give due consideration to the following during assessment of the wind development planning application:

· “Ground conditions, including peat stability.

· Site drainage and hydrological effects, such as water supply and quality and watercourse crossings.

· Size, scale and layout and the degree to which the wind energy project is visible over certain areas.

· Potential impact of the project on natural heritage, to include both direct and indirect effects on protected sites. These habitats would be of ecological sensitivity and biodiversity value. Also where necessary, management plans to deal with the satisfactory co-existence of the wind energy development and the particular species/habitat identified may be required.

· Potential impact of the project on the built heritage including archaeological heritage.

· Landscape issues.

· Visual impact of ancillary development.

· Local environmental impacts including noise, shadow flicker, electromagnetic interference, etc.

· Adequacy of local access road network to facilitate construction of the project and transportation of large machinery and turbine parts to site.

· Information on any cumulative effects due to other projects, including effects on natural heritage and visual effects.

· Information on the location of quarries to be used or borrow pits proposed during the construction phase and associated remedial works thereafter.

· Disposal or elimination of waste/surplus material from construction/site clearance, particularly significant for peatland sites.

· Decommissioning considerations”, [6].

Environment Impact Assessment Report.

The conduction of an Environmental Impact Assessment, (EIA), study is a requirement for all developments under both the 2000 and 2006 planning regulations. The report of this EIA study is one of the key documents considered in the processing of the application by the planning authority. It can always be assumed that there is going to be some disturbance to the environment with a windfarm development. An EIA study report is typically structured as follows:

Introduction: Details of the proposed development (size and location), applications,(who are they and their history in wind energy), consulting engineering team, (experience), and identification of the need for the proposed development.

Summary of the Existing Environment: This section outlines what is the status of the current environmental conditions of the proposed site prior to any works.

It identifies the pre-construction current conditions of the site in terms of

· Site status, (Special Area of Conservation etc.).

· Landscape setting,

· Species of plant and animals currently habituating the site.

· Water quality within the site boundary and hydrology.

· Geology, hydrogeology and peat stability.

· Noise levels.

· Human influence factors, (e.g. special area of amenity).

· Air quality.

· Climate influences.

· Materials assets.

· Culture & historical heritage.

· Telecommunications.

Proposed Development: This section includes details of the each phase of the developing including:

· Construction methods & techniques.

· Operation and Maintenance, (O&M), requirements and procedures for the turbines and all ancillary facilitates such as controls system, substation, roads and drainage.

· Decommissioning and reinstatement methods.

Planning and Policy Context: Identifies the need for the development and how the proposed development integrates into county development plan. This section also identifies how the development is supported by current government policy.

Consultations: This section includes:

· Details of all the public consultation meetings on the development held.

· Details of consultation meetings held with the planning authority.

· Details of the pre-planning submission.

The EIA report will contain a section on each of the following items:

· Ecology/habitats.

· Geology, hydrogeology and peat stability.

· Hydrology.

· Landscape & visual impact - This section contains the ZVI studies, visual impact report and photomontages.

· Water quality

· Noise & vibration - This section will contain details of the noise survey conducted prior to construction to identify level of background noise. It will also contain details and report of the noise simulation study for the turbines and their ancillary services.

· Human influence factors.

· Culture & historical heritage.

· Air quality & climate influences.

· Electromagnetic effects.

· Discussion.

· Conclusions.

Each of the above sections of the EIA report will:

1. assess the potential impact of the development on the environment for each parameter

2. detail mitigation measures to limit impact.

3. identify residual environmental impact of the development.

The report documenting the study will recommend if the site is suitable for development as a windfarm. It will identify key risks associated with the development and also details of the worst case scenario identified during the risk assessment. It will propose mitigation measures through changes in construction techniques, O&M practices and decommissioning procedures to minimise environmental impact of the development on the proposed site. An EIA Study takes about six weeks to eight weeks to complete. To comply with the standards required by the planning authority it is best employ the services of a profession specialist environmental firm. There are a number operating in Ireland.

Planning Conditions.

The planning authority will typically attach planning conditions to the following items when granting planning permission:

· Siting, design and layout.

· Flexibility of turbines layout on site.

· Flora, fauna and habitats.

· Archaeology.

· Noise.

· Environmental impact and monitoring.

· Construction methods.

· Borrow pits and quarrying.

· Roads and access routes.

· Associated structures and equipment.

· Grid connections.

· Site management issues.

· Shadow flicker.

· Electromagnetic interference.

· Aeronautical safety.

· Windtake.

· Wind measuring masts.

· Decommissioning.

Natural Heritage, Birds and Habitats.

During the planning assessment, due consideration must be to the requirements of:

· All species of flora and fauna, especially in areas determined to be protected areas, Special Areas of Conservation and Candidate Special Areas of Conservation.

· Maintaining the habitats including peatlands, (mainly blanket bog, heaths, flushes and other wetlands), woodlands and semi-natural grasslands. Of particular concern are watercourse, waterways and groundwater. The combined impact of the development with high levels of rainfall during construction and operation must be assessed for the planning authority. Habitats are identified in the habitat biodiversity plan of the planning authority.

· Eliminating adverse impact on local bird colonies, including:

o Avoid disturbance of colonies during construction and operation.

o Minimising collision mortality.

o Avoiding impact on migration, breeding, feeding and roosting habits of the local birds.

o Special groups of birds most considered at risk from developments are Raptors, Swans, Geese and Divers.

Archaeology & Architectural Heritage.

The planning authority must ensure that the development does not adversely disturb any local historical site such as monuments. This concern would also extend to safe access to the site for general public. The planning guidelines are limited on the issue of architectural concerns. They are more concerned with one off turbine erects within an urban setting, but reference is made to blending with agricultural developments in the area, particularly on turbine colour.

Proximity to Road & Railways.

Typically wind turbine service as a distraction for passing motorists. It is recommended that a lay-by be located adjacent to the turbine sites to facilitate viewing would reduce the effect of distraction. It is also considered best engineering and safety practice to set-back the turbines a minimum distance equivalent to the overall turbine height to edge of the blade tips from all public roads and railways.

Proximity to Powerlines.

Sufficient clearance most be provided between the turbine and overhead powerline, similar to any other structure. In addition there is a statutory obligation to notify the electricity distributor of proposed developments within 23 meters of any transmission or distribution line.

Safety Aspects.

The developer must comply with health and Safety legalisation in the construction and operation of the wind farm. There is no additional requirement in terms of restrictions or fencing. Both people and animals can walk up to the base of the turbine during operation.

Windtake.

In general windtake distances are used to optimise performance of turbine and reduce turbulence and wake effects. The planning authority generally like to see 3 rotor diameters for crosswind direction and 7 rotor diameters for prevailing wind direction. A distance of not less than two rotor diameters from the boundary of an adjoining property is also required. Where the adjoining property is a windfarm, minimum crosswind and prevailing wind distances should be respected, [5].

Decommissioning & Reinstatement.

Consideration to the method of decommissioning and disposal of the turbine farms after service should to be outlined at pre-planning consultation stage, by the developer. It will certainly be an issue in the granting of planning permission for the development. The developer will have submit a proposal that decommissions the wind farm in an environmental friendly manner and returns the site to it original state.

Interference with Communication Systems.

Wind farms produce electromagnetic radiation and hence can interfere with communications systems. This problem maybe overcame with the installation of deflectors or repeater. The developer is obligated to contact the communication regulator, as well as individual local and national broadcasters to inform them of the proposed development. Contacting of mobile phone operators is also advised by the planning authority.

Aircraft Safety.

Windfarms can interfere with Communications, Navigation and Surveillance systems used for Air Traffic Control. Wind turbine siting may also have implications for the flight paths of aircraft. Reference 5 states that “The Irish Aviation Authority's Obstacles to Aircraft in Flight Order, 2002, (S.I. 14 of 2002), as amended, specifies the criteria used to determine whether or not any object anywhere in the State is deemed to be an obstacle affecting aircraft operations. In order to assure the safety and efficiency of aircraft operations in the vicinity of airports, the International Civil Aviation Organisation (ICAO) has defined a volume of air space above which new objects are not permitted. No part of the wind turbine should penetrate these defined surfaces.”, [5].

Wind energy developers should contact the Irish Aviation Authority at the pre-planning stage of consultation, to ensure that the proposed development will not cause difficulties with air navigation safety.

Shadow Flicker.

Wind turbines, in particularly the blades, can cast long shadows on nearby houses. This is called shadow flicker. The shadow flicker can have an on/off effect due to the rotation of the turbine blades. Shadow flicker occurs under a set of given circumstances which are:

· the sun is shining and is at a low angle (after dawn and before sunset).

· the turbine is directly between the sun and the affected property.

Good layout design can greatly reduce the effect of shadow flicker using modelling software. Current guidelines are that shadow flicker at neighbouring offices and dwellings within 500m should not exceed 30 hours per year or 30 minutes per day. Maintaining a distance of greater than 10 rotor diameters from the nearest neighbouring offices and dwellings results in a low potential for shadow flicker. Where shadow flicker is a potential problem, developers should provide calculations to quantify the effect and where appropriate take measures to prevent or mitigate potential effect of shadow flicker. “Current shadow flicker recommendations are based on research by Predac, an European Union sponsored organisation promoting best practice in energy use and supply which draws on experience from Belgium, Denmark, France, the Netherlands and Germany”,[5].

Environmental Monitoring.

The planning authority can request environmental monitoring at the developer’s expense. Conditions such as dust generation, noise and vibration limits, and other wild life considerations may have to be monitored during all phases of the project. An agreed monitoring/management programme can be used to address concerns of third parties over the development. In certain circumstances the monitoring may be extended to the first two years of turbine operation.

Construction Methods.

This is an area of major concern for planning authorities. They consider this a critical stage of the development. Typically they clarify the following:

· “Hours of construction – for noise limitation and H&S requirements, (i.e. Time in work act).

· Monitoring and supervision of construction phase by qualified and experienced geo-technical engineer to mainly mitigate against the risk of landslide.

· Construction traffic management plan to maintain road safety and avoid nuisance to locals with increased levels of construction traffic.

· Ground disturbance during construction for environmental reasons, (habitats and landslides).

· Management and treatment of rock and soil excavated during construction work.

· Storage and transfer of removed material, during construction to avoid any pollution of surface or ground waters.

· Impacts of construction on surface and groundwater drainage, especially during heavy rain fall.

· Reinstatement of the site where construction works result in ground disturbance/surface damage or erosion.

· Removal of ancillary construction equipment including site offices, portakabins and portable toilet”, [5].

Borrow Pits & Quarrying.

Soil slippage is an issue of great concern to the planning authority. They want to know from what location will rock and soil be excavated and where this surplus materials will be stored. Ensuring that it is not stored on gradient slope of greater than a certain incline, (.i.e. 4 to 8 degrees).

In addition the planning authority will want a risk assessment completed in which possible causes of soil slippage are identified, what mitigation measures are taken to avoid the occurrence of soil slippage. They will also want to know what possible damage will result should the unique circumstances occur causing soil slippage and what proposed remedial works will be required to repair the potential damage.

Landslide Slippage Case Study: Derrybrien.

As can be seen from above the planning authority is deeply concerned with the issue of ground stability, especially during construction and while working in bog areas with good peat depths. Hibernian Wind Power Ltd. developed a windfarm on the Slieve Aughty Mountain in the Derrybrien area of County Galway. On 16th October 2003, excavated material slipped a distance of 2 km overnight and stopped moving when it reached a bridge on a local bye road. The local authority reaction team deployed barrier to inhibit further movement of the material.

Following heavy rain on the night of 22nd to 23rd October the mass of material became saturated and unstable. It began to move again, over topping the bridge and road and moving towards the Owendalulleegh river. The material was moving an estimated 25cm per second. Emergency remedial works to cut new drainage channels upslope of the slippage were completed onsite. This diverted the surface water of the catchment away from the peat mass. This prevented further slippage of the peat mass. The team also set-up cross diverter channels and skill traps to reduce the suspended solids contain of surface drainage reaching the Owendalulleegh river.

Following investigation by the local authority’s consultants, it was determined that the landslide was caused by the construction methods used. By stock piling excavated material at the base of a turbine on a downhill slope, the resultant increase in load, weaken the top layers of the peat mass and caused failure of the bottom layers. This most probably caused the minor rotational slip failure which in turn developed into transitional slip failure of the entire slope from the base. The investigation determined also that the transitional failure occurred during dry weather. As a consequence of the resultant transitional slip, the mass of material moved into a drainage channel.

With the heavy rainfall during 22nd to 23rd October, with heavy drainage flows from the catchment area, the mass was again mobilised due to the saturation. The net result was that the peat mass had no effective strength and recommenced movement again.

It was concluded that the external factors contributing to the land slide were as follows:

· The placing excavated material on the crest of a slope considered to be unstable.

· The uncontrolled discharge of water above and around the area of the failed slope.

· The blocking or removal of pre-existing water paths throughout the site.

· Vibrations from construction activity.

Is was determined that these in conjunction with the natural factor such as peat thickness and strength and slope angle combined to clause the slip at the site.

Dr. Michael Rodgers and Mr John Mulqueen of the Civil Engineering department, NUI Galway, reviewed the Derrybrien windfarm site and recommended that:

1. Geotechnical investigations are completed at each turbine bases, access roads and repository locations of surplus excavated material.

2. Stability analysis is completed at each construction location and access road.

3. Full design review of the entire site drainage is completed for both construction and operational needs.

4. Dewatering activities during construction is discharge to proper water courses.

5. Disposal locations for excavated material is properly drained.

6. Foundations of access roads to be of sufficient bearing strength to carry all operational and construction traffic.

7. Environmental monitoring to observe physical movement of topsoil and pore water pressure during both the windfarm’s construction and operational phases.

The environmental impact of the Derrybrien windfarm incident included the following:

1. Excess suspended solids and color loading of the Owendalulleegh river and its tributaries.

2. Shannon Fisheries estimated the fish kill at 50,000, (trout, eels, brook, lamprey).

3. Natural ecological status of the Owendalulleegh river was altered. However the ecological status of the tributaries were disturbed but will recover naturally within a period of 12 to 18 months. Migrations patterns of species to and from the tributaries were not seriously disrupted. The Owendalulleegh river will require some assistance to recover.

4. Damage of the flora and fauna will recover after a prolonged period. The will be permanent damage to the raise peat bogs the Slieve Aughty Mountain. Visual impact damage to the mountain as considered to be negligible.

5. Additional stabilisation remedial works was required with removal of additional peat mass to prevent secondary landslides occurring, [12].

Roads and Access Tracks.

Conditions maybe imposed by the authority “in relation to design, width, surface materials, construction details, silt traps, associated earthworks(such as cutting or embankments), and routing of tracks within the site, not only to minimise visibility, but also with regard to erosion and minimising impact on habitat”, [5].

Ancillary Structure & Equipment.

In addition to the wind turbine, details of the sites ancillary structures and equipment are required to be submitted as part of the planning application. Ancillary structures would include, stores onsite, sub-stations, controls houses, control system transmission system antennas etc. the planning authority will require, location maps, layout drawings, elevation drawings, details of external finishes and details of finished heights. The planning authority prefers that security fencing kept to a minimum, [5].

Time Limits & Planning Contributions.

Typically the life of planning permission is five years. This maybe extended upon agreement with the planning authority to facilitate connection to the grid. The authority however prefers that planning permission are re-submitted after five years to enable them evaluate the development with reference to most recent standards, regulations and advancements not considered five year previously.

All wind farm developments are subject to a planning fee and levy to cover costs associated with assessing the application. Should the proposal require that the authority be required to update local public infrastructure to facilitate the development, then cost of this work will be added to the planning levy, (e.g. Regional road upgrades), [5].

Visual Impact.

The visual impact of the turbines on the site is a very common objection to windfarm developments. There is no hard and fast rules the department can provide to instruct planning authorities how to proceed, as the issue is very specific to the location of the site and the local community living there. It is common sense however if the location is considered to be Area of Special Amenity or defined as a Speical Area of Conservation under the Habitats Directive, then it can be assumed that there will be strong opposition to this on visual impact grounds, regardless of what planning act the application is submitted under. The way to avoid this problem is to remain within locations determined by the planning authority suitable for wind farm development. These locations are identified in the county development plan. These plans will have specific sections dedicated to how it is envisaged that wind and other renewable sources are developed within the county. The department guidelines summarised in the table below general recommendations how to assessment visual impact in different locations.

Table 2: Department of Environment, Heritage and Local Government Guidelines on how to assess visual impact., [5].

Zone of Visual Influence.

As visual impact on the landscape is a major concern of wind farm development. The use of software design packages allows the “Zone of Visual Influence”, (ZVI), to be determined. The ZVI is an assessment of visibility footprint and identifies the directions from where the wind farm will be visible. This tool facilitates the development of photomontages. These photomontages predict the visual impact of the turbines on their surrounding from a variety of directions. These software packages also predict noise levels generated by the wind farm. (Noise is discussed in detail in a later section of this report). Both visual influence and noise are two key parameters in the environmental assessment for this type of project.

The Department recommends that determination of visual impact reports should include the following stages:

· “Description of proposed development, including alternatives considered during the design process.

· Description of geographic location and landscape context.

· Definition of study area, defined by identifying the Zone of Theoretical Influence.

· General landscape description of the Study Area.

· Selection of viewshed reference points from where the proposal is examined in detail.

· Assessments of the sensitivity of the landscape from each viewshed reference.

· Preparation of photomontages.

· Estimation of the likely degree of impact on landscape.

· Recommendation of mitigation measures”, [5].

For the Zone of Theoretical Visibility, (also called the Zone of Visual Influence, ZVI), study the department concluded that:

· For blade tips up to 100m or less in height, a ZVI radius of 15km would be considered adequate.

· For blade tips over 100m in height, a ZVI radius of 20km would be considered adequate.

· Where developments are within 25km of scenic of national important, the distance would extend fully in the direction of that landscape.

· The degree of visibility should be based upon a number of turbines. The height of visibility should include half the height of the turbine blade above the hub. Using nub height is not considered to be appropriate.

· The ZVI maps should be an OS map 1:50,000 printed at this scale. All theoretically exposed viewing point clearly marked on the map.

· Number of turbines visible at each location should be marked on the map, (Colour code recommended).

· Cumulative effect of different windfarm developments should be included in the study and marked on the map.

· “At initial design stage of preparing the wind energy development layout it is recommended is to carry out a “reverse zone of theoretical visibility” (reverse-ZTV) from locations known tobe highly sensitive and from where views of turbines should be avoided”, [5].

Selection Of Viewshed Reference Points.

These are locations from where the visibility of the new proposed development. It is recommended that:

· Planning authority is consulted to avoid delays in processing the application due to the omission of viewshed reference points.

· Viewshed points that are included should made reference to the county development plan and local areas of scenic amenity.

· Worst case viewsheds should be considered.

· Viewsheds should be at varying distances along and varying directions to the windfarm.

Photomontages.

For photomontages the department recommends:

· 50-70m camera lens should be used.

· Panoramic photographs of the windfarm development to set it context with the landscape.

· Photomontages used should be prepared from locations where the windfarm is visible. (The ZVI will highlight places from where the view is not needed to be provided).

· Photomontage should be the most open case, care should be taken not to place obstruction between the camera and turbines.

· Photomontage computer generation models should be given to local authority to enable them view the entire site.

· Estimated likely degree of impact on the landscape should be reported on for each photomontage.

The department states that the structure Landscape Impact Assessment report is critical for fast processing of the planning application. The following structure should be used:

· “Describe the landscape in general, including landform, landcover, structures and features, spatial flow/interconnection and degree of naturalness or human influence.

· Assess the visual presence of the wind energy development, for example, how spatially dominant it is.

· Assess the aesthetic impact of the wind energy development on the landscape and determine whether the impact might be adverse or positive.

· Using the results of the earlier estimate of landscape sensitivity from each key viewpoint along with the visual presence and aesthetic impact, estimate the significance of the impact on the landscape”, [5].

Noise.

Opponents to wind turbines have claimed that wind turbines are noisy. For a HWAT, there are two sources of noise on a wind turbine are the blades passing through the air as they rotate called aerodynamic noise and the mechanical noise from the gearbox in the nacelle for a HAWT. Factors that can increase aerodynamic noise from a wind turbine are:

· the shape of the blades.

· the interaction of the airflow with the blades.

· the tip shape.

· the shape of the trailing edge.

· stall conditions and turbulent wind flow caused by high wind speeds or unsteady forces.

Noise is measure in decibel, (dB (A)). The dB(A)) measures the sound pressure level which is defined as the magnitude of pressure variations in the air. For a 3 blade HAWT 25m high, would typically create a noise of 50-60 dB(A) at 40m. At a distance of 500m sound pressure level is reduced to 25-35 dB(A), [17]. Acoustic padding and cladding is now designed in to the nacelle of a modern HAWT to trap noise generated by the turbine’s gearbox. Typical every day noise generation levels are given in the table figure below.

Figure 11: Noise Threshold Data. Originally iinformation taken from The Scottish Office, Environment Department, Planning Advice Note, PAN 45, Annes A: Wind Power, A.27. Renewable Energy Technologies, August 1994, [17].

[1] http://www.garradhassan.com/ Accessed 20th October 2011.

[2] http://www.top-alternative-energy-sources.com/inside-a-wind-turbine.html. Accessed 22nd October 2011.

[3] Not used.

[4] Muldowney, E., (2011), “Wind Energy 2011: Planning, People and the Environment – An Taisce Energy Policy”, An Taisce, Dublin. (Accessed 30th October 2011).

[5] Department of the Environment, Heritage & Local Government - (DoEHLG), (2006), “Wind Energy Development Guidelines - Guidelines for Planning Authorities”, DoEHLG, Dublin.

[6] Irish Wind Energy Association, (IWEA) & Sustainable Energy Ireland, (SEI), (2008), “Best Practice Guidelines For The Irish Wind Energy Industry”, Irish Wind Energy”, www.sei.ie, (Accessed 30th October 2011)

[7] Project Management Institute, (2001), “A Guide to the Project Management Body of Knowledge, - PMBOK Guide”, 4th Edition, Project Management Institute, Pennsylvania.

[8] Westmeath Independent Newspaper, Wednesday, 24th August 2011.

[9] The Irish Times Newspaper - Friday, August 19, 2011

[10] The Clare People Newpaper, 31st January 2011.

[11] The Irish Examiner Newspaper -Thursday, October 27, 2011.

[12] Galway County Council, (2004), “Landslide at Derrybrien Windfarm”, Galway Co. Co., Galway.

[13] Department of Communications, Energy & Natural Resources, (DCENR), “National Renewable Energy Action Plan for Ireland”, DCENR, Dublin.

[14] Department of Justice, (DOJ), (1999), “Electricity Regulation Act, 1999 (Criteria For Determination Of Authorisations) Order, 1999, S.I. No. 309 of 1999” , DOJ, Dublin.

[15] Commission For Energy Regulation, (CER), (2010) “New Application Procedures For Authorisations and Licences for Generators up to 40MW - Decision Paper”,CER, Dublin.

[16] Commission For Energy Regulation, (2011), “Factsheet On Single Electricity Market ,cer11075”, CER, Dublin.

[17] British Wind Energy Association, (BWEA), (2000), “Noise From Wind Turbines”, BWEA, London.

[18] Boyle, G., (2004), Renewable Energy, 2nd Edition, Oxford, Newyork.

[19] Commission For Energy Regulation, (2008), “Criteria For Gate 3 Renewable Offers & Related Matters - Direction To The System Operators”, CER, Dublin.

[20] O’Sullivan, J., (2008), “Facilitation of Renewables: Operational Policy and Performance - REFIT, Grid Code and SEM”, EirGrid, Dublin.

[21] Healy, G.,( 2010), “Revision OF REFIT”, Meitheal na Gaoithe Conference, Kilkenny.

[22] Department of Communications, Energy and Natural Resources REFIT website, http://www.dcenr.gov.ie/Energy/Sustainable+and+Renewable+Energy+Division/REFIT.htm. (Accessed 6th December 2011).

[23] Department of Communications, Energy & Natural Resources, (DCENR), (2009),"REFIT Clarifications”, DCENR, Dublin.

Figure 12: Noise pattern from a typical wind turbine, (original source EWEA 1991), [17].

The British Wind Energy Association, (BWE), in conjunction which their acoustic consultants, Hayes & Mckenzie Partnership, recommend the following for planning wind projects:

· Determine the distance of the nearest house, (Maintain a distance of at least 500m).

· Conduct a background noise survey of the site and the surrounding houses. The noise survey should be conducted when the wind is blowing towards the nearest house.

· Levels of background noise should be measured within the house when windows are open.

· Construct a noise model using software. The turbine manufacturers are required to comply with noise emission regulations. The manufacturers are also required to provide data on the each individual operational range. These values can be incorporated into the noise model.

· Most turbines do not operate below the cut-in speed, (typically 5m/s for HAWT). Wind turbines are below the cut-in speed for 30% of the time.

· Noise generated varies with wind speed

Preliminary recommendations from the Wind Turbine Noise Working Group,(September 1996), established by the DTI, are that turbine noise level should be kept to within 5 dB(A) of the average existing evening or night-time background noise level. This is in line with standard practice for assessment of most sources of noise except for transportation and some mineral extraction and construction sites when higher levels are usually permitted. A fixed low level of between 35 and 40 dB(A) may be specified when background noise is very low, ie. less than 30 dB(A)”, [17].

The latest innovation in wind turbine noise is the use of variable speed turbines. Turbine noise increases as wind speeds increase. Also as the wind speed picks up, the background noise also increase at a greater rate than the turbine noise increase. Therefore the increase in Turbine noise is drowned out by the background noise. The effect of wind turbine noise is likely to be greater at the lower wind speeds. At higher wind speeds noise from wind has the effect of largely masking wind turbine noise. This means that the turbine can be heard more easily due to the lower background noise. Larger and variable speed wind turbines emit lower noise levels at cut-in speed than smaller fixed speed turbines. At the lower wind speed the variable speed turbine slows the rotation speed of the blades, gearbox and generator, thus emitting less noise from the turbine. As wind turbines will operate at the lower range for the majority of it’s time the variable speed turbines are considerable quieter machines than the constant speed turbines for the operational life of the wind farm.

Noise from wind turbines is radiated more in some directions than others, with areas down-wind experiencing the highest predicted noise levels. Experience from BWEA members has shown that upwind HAWT are quieter than the downwind HAWT. Most installations in Britain and Ireland are upwind HAWT. Most HAWTs installed in USA are downwind. In USA wind noise is considered a greater problem than in Britain.

Direct drive machine with no gearbox are currently being studied. Work to date has indicated that they are quieter due to less mechanical. They are a lower efficient machine with a smaller operational range than the gearbox turbines. Research work into this type of machine is still ongoing.

Boyle states in his book that in the UK there is no standard maximum permitted noise specifically for wind turbines. The building regulations state that noise levels at buildings adjacent to roads must be less than 68dB(A). It can only exceed this for 10% of the time within an 18 hour period. For wind project construction, the UK Department OF Environment only provide a guidance document on noise, (Planning Policy Guidance Note 22).

From a project manage prospective, unless people’s concerns on noise are considered at design and planning stages of the project, opposition to the project is likely to develop and increase. (again good stakeholder management).

Denmark regulates to control noise emissions from wind turbines. Their standard states that the maximum noise limit permitted at the nearest dwelling is 45dB(A) in rural areas and 40dB(A) in urban areas.

Most HAWT turbines are designed to comply with either Danish noise regulations and tested to a procedure developed by the International Energy Agency, [18].

The planning authority will impose restrictions on noise for both operation and construction. Typical conditions issued by the planning authority on noise after processing of an application will address:

· Level limits.

· Locations at which those limits apply.

· Time of day at which the limit applies.

· Parameters to be measured for control purposes.

· Access to data generated by the monitoring programme”, [5].

It should be noted that during the construction phase of the wind project, the planning authority can impose noise restrictions, especially during night hours if the development is close to a residual dwelling. The conditions may also ban certain construction methods, due to what the planning authority considers to be excessive noise conditions that may cause habitat damage or interference with wild life, (E.g. vibration from piling activities). The planning authority want to see an appropriate balance must be achieved between power generation and noise impact.

To ensure good acoustical design and no significant increase in ambient noise levels at any nearby noise sensitive locations carefully considered sitting of turbines is required. To demonstrate to planning authority, a noise survey of the ambient background should be conducted with particular attention being paid to the nearest noise sensitive regions, (residences, commercial buildings and relation areas). This survey allows a noise baseline for the site to be established for both quiet and windy conditions. A noise computer model can then be generated using noise information from the turbine suppliers. The noise model will identify any problematic issues, regions, or directions. The layout design can be modified to minimize the problematic issues, thus mitigating the noise issues associated with the planning application.

The planning authority will generally require a lower fixed limit of 45 dB(A) or a maximum increase of 5dB(A) above background noise at nearby noise sensitive locations. Planning authorities need to be careful and balanced with the specification of the 5dB(A) margin above background noise. It may not be required at nearby noise sensitive properties and hence may unduly restrict wind energy developments which should be recognised as having wider national and global benefits.

Instead, in low noise environments where background noise is less than 30 dB(A), it is recommended that the daytime level of the LA90, 10min of the wind energy development noise be limited to an absolute level within the range of 35-40 dB(A). Separate noise limits should apply for day-time and for nighttime”, [5].

A fixed limit of 43dB(A) will protect sleep inside properties during the night. In general, 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. Planning authorities may seek evidence that the type(s) of turbines proposed will use best current engineering practice in terms of noise creation and suppression.

CASES STUDIES – WIND FARM DEVELOPMENT PLANNING OBJECTIONS.

Seven Hills Wind Farm Development.

It has been reported by the local newspaper “ Westmeath Independent” that Roscommon County Council received 130 submission objecting to the proposed construction of 19 turbines as part of the “Seven Hills” by Galtech Energy Ltd near Dysart Co. Roscommon. The investment is worth 76 million euro, with Galtech claiming to create 600 construction jobs in the area. Phase 2 of the project will involve a further 16 wind turbines with an investment of 80 million euro. A sample of objections from the local communities were noted as follows:

The latest wind turbine plans would be "a blot on what is a beautiful landscape" a submission from Alex and Fiona Clarkson, Skyvalley, Taughmaconnell argued this week in relation to the latest proposals, adding that the location of a turbine less than a kilometre from their home would mean they would never be able to sell it. The written submission also expressed concern that it would decimate wildlife, "interrupt the migratory swans" which come to the area every year, present a noise hazard and "bring strangers to the area, some of which could be undesirable." Concern that the development would take away their hobby of flying radio controlled model planes because of the EM fields they produce was also articulated by the couple.

Another submission from Christine and Graham Mogg in Skyvalley dubbed the "size and number of turbines overwhelming in terms of visual impact alone". They also complained about the lack of public consultation, property devaluation and the proximity of the turbines to their home, while Dermot Butler in Cam believes that the local community hasn't been considered at all. He said the noise and flicker from the turbines will be an issue for people living in the area and believes the turbines should be over 1,500 metres from houses.

A submission from Aoife Butler with an address in New York argued that natural springs and the water table in the surrounding area will become polluted by concrete works associated with construction of the development, thus lands which flood in the water will become polluted with polluted flood waters.

She also believes farming activities will be stopped on the land changing the landscape and a way of life in the area, while she also has misgivings about the traffic generated during construction and the health implications of wind energy in her submission to the council. "The peace of the countryside would be interfered with the continuous noise and by the flicker brought on by them in the sunlight," Mary F Fallon, Gardenfort, Dysart stated in her submission, adding that there have been problems with TV receptions in areas where windfarms have been situated.

Elsewhere, among his objections, Kevin Coleman in Dysart pointed out that in his view the project will turn the " skyline into little more than an industrial landscape" and the "inevitable miles of pylons needed to carry electricity away from them" will have a negative impact on every parish they go through. Gerry and Terersa Connolly, Breole expressed concern at the fact the development according to the company's EIS will be seen from Clonmacnois could impact on visitor numbers to the monastic site. "The loss or devaluation of this national treasure by a developer would cause serious reduction in visitors to the site with a consequent loss of revenue to the region," the submission outlined, while in a wide ranging document Skyvalley Concerned Residents Group believe the project will have a detrimental effect on the area, complaining about a lack of information in relation to effects on built landscape and concerns about the decommissioning of the turbines were just a few of the myriad of issues raised in opposition to the plans”, [8]. The project is still within the planning process.

Connemara Wind Farm Development.

The Irish Times reported on August 19, 2011 that An Bord Pleanála refused planning permission for a development of 27 turbines in Connemara, West Galway. Gaoi an Iarthar Teo wanted to construct the wind farm in a scenic area of bog and lakeland landscape, 4km north of Ros a’Mhil. The board concluded on the objection lodged by An Taisce that “ the proposed wind farm would be an excessively dominant feature and visually obtrusive form of development in south Connemara’s highly scenic open landscape.”, [9]

The board also noted that “The proposed area of construction was part of the Connemara Bog Complex Special Area of Conservation (SAC), with a “high” landscape sensitivity designation in the current Galway County Development Plan – even though it was also identified as having wind farm potential. The development will also have ecological impacts, and while not affecting the integrity of the adjoining SAC, it will impact negatively on the ecological value of the site itself and on its value within the wider area . . . by reason of its nature and scale.

The proposed development would seriously injure the amenities of the area, would interfere with the character of the landscape which it is necessary to preserve and would, therefore, be contrary to the proper planning and sustainable development of the area.”, [9].

It was reported by the paper that An Taisce believed that the development would adversely impact on ecological of the area, particularly in special protection areas for hen harriers and other species protected by the EU birds directive.

This proposed development showed that the planning guidelines developed for windfarm developments proposed by the Department of Environment Heritage and Local Government was of limited success due to limited engagement of all stakeholders by the project management team. It also demonstrates how Galway County Council’s implementation of the guidelines was completely different to An Bord Pleanála’s, both planning authorities.

In addition how an area protected by the EU birds directive came to be considered suitable for wind farm development by Galway County Council should be reviewed and explained. This decision also brings into questions how effectively the national strategy for future wind energy development is managed? How can Ireland meet renewable energy targets commitments without a workable mechanism to reconcile differences between utilizing area of highest wind power potential and “at the same time protecting biodiversity and our most iconic landscapes”,[9].

The conclusion of The Irish Wind Energy Association, was that a need was identified for “a forum where industry experts, the Department of the Environment, local authorities and An Bord Pleanála could engage on planning issues”, [9].

Gaelectric response to the decision was to launch a new training course for teachers to raise young people’s awareness of Ireland’s “massive reserves of renewable power” in partnership with The Irish Wind Energy Association.

Lissycasey Wind Farm Development.

It has been reported by the Clare People that a new 50 million euro wind was given the go ahead by An Bord Pleanála. An Taisce had logged an objection against the decision to grant planning permission by Clare County Council to Hibernian Windpower Ltd to construct an 11-unit 375ft high wind farm at Boolynagleragh, Lissycasey. The completed development will have 40 turbines. An Taisce raised concerns over ground stability around the turbine bases and potential adverse impact on the protected hen harrier bird. An Bord Pleanála concluded that Hibernian Windpower Ltd had address all concerns adequately in their submission, [10].

Using the PMI project management systems would have prevented the Connemara Wind Farm development from going to planning. Correct project management practice suggest that you must identify all stakeholders and risks to the project as early as possible to avoid conflict with stakeholders and cost increases. Risks are identified through the life of the project, but a historical review of other similar projects would identify the vast majority of them. All risks to the project should be put into a risk matrix and rank in priority of treat. Risks of highest concern should have a mitigation measure and a person of responsibility should be assigned to manage both the risk and mitigation measures, [7].

The risk matrix would have identified that the site was a protected SAC by the EU birds directive. “Is the site a SAC?” is one of the standard questions on a windfarm risk matrix template. Research would have identified this as one. The risk of not getting planning goes up. The costs to the project would then also go up. There is little mitigation measures that could be implemented to reduce this risk. The project should have been stopped at feasibility study stage based upon this information to minimise cost to the developer.

The Lissycasey Wind Farm is an example of good project management. Risks were identified early in the project, mitigation measures were put in place allowing the planning permission milestone on the project to be achieved. This can be concluded from An Bord Pleanála as they stated that Hibernian Windpower Ltd had address all concerns adequately in their submission.

DISCUSSION.

General.

From the literature review, it can be concluded that the mechanism’s used for delivery of wind energy in Ireland needs to be refined. There has been various suggestion from all in the industry. The suggestions encountered during the research for this article are all from invested interest groups within the sector, weather they are public bodies or developers. Some groups within the wind energy sector would as go far to say that there is no attempt to co-ordinate strategy, that the mechanisms used are very chaotic. They have asked why is there multiple applications to be completed and submitted for the various aspects of the project.

The literature review would support the conclusion that Irelands has all the required mechanisms, plans, policies and strategy to achieve the 2020 40% target. Central to this was the National Renewable Energy Action Plan submitted to the European commission under article 4 of Directive 2009/28/EC. The local planning authorities have created wind energy plans, the Department of Environment have the planning guidelines, the CER has the gate and licence system and EirGrid have Grid 2025 (GDS). The obvious item determined from the literature review is that there is no leading authority to take charge of the strategy implementation. I believe the CER could fulfil this role.

I would recommend the establishment of a Working Industry Liaison Group. This group would be chaired by the CER. This group would deal with issues in the industry such as:

· Planning guidelines.

· Future plans to develop the national grid.

· Potential for export.

· Electrical cars.

· The issues of the SEM and REFIT.

This working group would consist of the CER, SEMO, IWEA, other renewable organisations, DCENR, Department of the Environment, EirGrid as TSO and ESB Networks as DSO.

The industry has enquired why the administration of the wind sector in Ireland is not more like rest of Europe. (Grid development on a reactive basis like Germany, the REFIT similar to the UK’s ROC scheme). Ireland is unique in Europe as we are the only country operating a SEM. The Europe Commission’s current strategy is to subsidise renewable developments, this is counter active to the competitive principle of the SEM. Another key item that should be remembered is that Irish national grid is not as fully developed as grids of the central Europe countries.

The three key issues in which the industry which could be refined are:

· Planning.

· Financial.

· Grid connection/administration.

Great care most be taken that the wind energy sector, so that it does not become the next bubble sector. The sector must be developed in a co-ordained way. Not concept that developers and financial people understand fully. One of the advantages of the Gate system is that it puts order and regulation on the development of the sector.

Planning.

It possible to conclude that the IWEA’s call to make it easier for developers to get planning would have a negative impact on the attempt to get local communities to “buy in” to windfarm development. Using the Planning and Development (Strategic Infrastructure) Act 2006 (No. 27 of 2006) for windfarm projects, citing national strategic importance is the wrong approach. Ireland has a very local political based culture, where the rest Europe function on a more central government approach. So the get communities to “buy into” the wind energy is an easier concept there than in Britain or Ireland. Using central government planning legislation, local people may feel that their civil rights are being disrespected and their voice ignored. Planning authorities should make it a requirement for all developers to implement the recommendation for the lo-call telephone numbers to allow local communities communicate their queries to the developers, (Could be part of the communications plan recommended by the PMI).

There is a need for an educational program to explain the advantages and disadvantages of wind energy. The industry should consider investing in an education program, so people can better understand the concepts. Such a program may prevent objections like was seen in the Seven Hills case study from Roscommon.

All windfarm planning applications should continue to be submitted under the Planning and Development Act 2000 (No. 30 of 2000). As shown above the amount of material required by the planning authority is extensive. It is also onerous and expensive to prepare, but the authority has an obligation to the public to protect them. If the industry developers worked more closely with the communities to address fears and misconceptions, then objections to wind developments may reduce as the buy-in factor begins to take hold. Thus a repeat of Seven Hill could be avoided. As the buy-in factor increases, local communities may be more willing to except major inconvenience such as a little noise or shadow flicker.

The level of detail required by the planning authority should remain at current levels. If there is any relaxation, the environment may be put at risk which would actually have a negative impact on the industry’s image. Short cutting environmental protection to safe carbon footprint, could cause the public to loss interest in renewable energy. Thus the insistence of end customers demanding that suppliers to provide them with green energy will reduce. This could reduce the commercial advantage to wind energy sector have to lever more favorable terms from the SEMO.

All development plans prepared by the local authorities need to be reviewed by the CER, to ensure that an incident with planning as occurred with Connemara Wind Farm Development is never repeated. This incident did damage the reputation of the wind sector as a whole. To repair the image, the developer, Gaelectric developed a new training course for teachers to raise young people’s awareness of Ireland’s “massive reserves of renewable power”.

The department of environment need to develop their guideline document into a typical template for assessing windfarm developments. This would increase the transparency and efficiency of the assessment process for windfarms planning.

Financial.

The developers make a good point on this argument on this point. The SEM should be reformed to include all wind developers as a whole and incorporate the REFIT 2 scheme. Without a good busy case for windfarms, Ireland will not meet the obligations given due to lack of investment in the sector.

The money for REFIT is not from the EU but comes from the PSO payment made by the end consumer. I would suggest the following reforms to SEM for inclusion of the new REFIT scheme:

1. End the commercial advantage to the suppliers by removing the 15% rebate.

2. Set the SMP for wind and other renewables at the reference price, (i.e. put a floor on the price).

3. Increase the capacity payment using the 15% rebate taken from suppliers, (i.e. PSO goes towards capacity payment)

4. Increase the percentage renewable and CHP energy the suppliers have to purchase.

5. Make it mandatory for all renewable sites to sell into the pool.

6. Looking at the SEM and reference price comparison above, they are approximately equal. A special category of carbon tax can be created for fossil generators should, their SMP come in lower than the renewable SMP.

7. The reference prices for each renewable sector should be set in a bid style manner similar to the SMP mechanism.

8. Make the application for the generation licence and participation in the SEM the same form. Under this suggestion a separate. REFIT application is no longer required.

9. Get the funding from the PSO re-classified as non-state aid similar to UK.

10. Remove the DCENR from participating in the wind energy sector.

11. Under these suggestions, the IRR would be reduced, but the mechanism could allow for the occurrence where the IRR goes above a certain percentage, then wind generator drops into a lower profit band. This would give some a percentage relief to the end customer.

12. This mechanism would deal with the balancing issue that the generators are worried about and that is not currently in the SEM. In the above suggestion the intension is too pay more for periods of high energy production and low demand and pay less for peaking at times of high demand.

The above concept would alter the behaviour of the SEM. The SEM would firstly support sustainable renewable energy through a regulated fair-price mechanism managed by the CER/SEMO. The next priority of the SEM would then be to implement the original competitive philosophy of the SEM to fossil fuel plants.

As more renewables come onto the grid and fossils drop off, the SEM will behave more like a REFIT scheme. The trade-off for having a floor on the SMP price for wind is that the IWEA would have to accept the continuance of providing renewable power at tight margins, the original concept behind REFIT. Profit margin bands should be regulated by the CER/SMO to protect the end consumer. This would address the developers/ wind generators concerns that the SEM is making windfarms non-viable due to erosion of the SMP.

I believe the SEM in Ireland is leading the way in Europe for market and grid regulation.

National Grid.

The biggest barrier to the development of a renewable energy in Ireland is the national grid. While the Gate process may address the short to medium term issues, a longer term strategy is needed. There is conflict between the Gate process which goes to 2020 and Grid25 which goes to 2025. The only focus in the wind sector at the moment is in achieving the 40% target. There is no strategy for the sector beyond this. A future mechanism is needed to facilitate the installation of approximately 500MW of new capacity each year. The revised mechanism needs to focus on the export, electric car and electrical heat spacing potential of the future.

The GDS concept is Ireland is also has a more leading concept that what is presently being used rest of Europe, (Britain & Germany still use reactive process for granting a grid connection).

Our Gate system is onerous on the application, but since its introduction there has been excellent improvements; increases in the processing speed of the applications, reduction in the information required, introducing flexibility in how applications are processed, the formation of the industry liaison group and the review every two years. There is ca 7,300MW unsigned capacity queued in the Gate system, waiting for an offer to connect to grid, [20].

The only disadvantage of the Gate 3 mechanisms is with the cut-off dates. Any development in the conceptual stages of the project will have a high-degree of uncertainty which makes it hard to get financial backing. The mechanism should be reformed to allow the new developments get queued into the Gate process.

Project Management.

As detailed through the article, the PMI project management practices are key to the delivery of windfarm developments. The PMI tools of scope development, risk analysis, stakeholder management, communication plans and program have been shown to work well for managing the design and construction phases of a wind farm development.

In developing a project manage plan according to the PMI best practices, the first critical milestone is not getting planning permission, but it is to get queued into the Gate process and get a confirmed offer for a grid connection. Not knowing when Gate calls will be issued, makes it hard to develop a project management plan for to complete the feasibility studies and design work required by the Gate process.

CONCLUSIONS.

  1. The PMI project management practices are key to managing the design and construction phases of a windfarm development.

  2. Careful stakeholder management is needed to deliver the wind farm projects.

  3. Not knowing when Gate calls will be issued makes project management difficult.

  4. An industry Working Industry Liaison Group needs to be established.

  5. The CER needs to take a more leadership in the delivery of wind energy for Ireland.

  6. Gate 3 mechanisms work well for the delivery of the GDS.

  7. A reactive approach to the GDS is wrong. The co-ordinate planned and integrated method is more beneficial and cost effective in the longterm.

  8. Ireland is leading Europe on GDS strategy.

  9. The SEM needs to be reformed to give windfarms are stronger business case to maintain investment in the area.

  10. Ireland is leading Europe with the SEM

  11. The Department of the Environment need to convert their guidelines into a template for windfarm planning application processing. Such a template would increase the speed and transparency of the assessment procedure.

  12. An education strategy is needed to raise profile wind energy in Ireland. The program should out line the benefit of wind energy and identify that the extensive checks conducted by the planning authority to eliminate the common complaints people have about wind turbines.

  13. Using the Planning and Development (Strategic Infrastructure) Act 2006 (No. 27 of 2006) for windfarm developments should not be allowed. This may have an adverse impact on the image of the wind sector

  14. All county development plans for wind power should be reviewed by the CER.

  15. The wind sector believes that it is unlikely that the government’s 40% renewable energy target will be met by 2020.

REFERENCES.