Coastal Concern Alliance
Working to Protect Ireland's Coastal Zone since 2006
CCA submission to Citizens' Assembly on Biodiversity Loss
In our submission to the Citizens' Assembly, Coastal Concern Alliance endorses the recommendations made by Fair Seas, outlining key actions required to conserve and restore Ireland's marine biodiversity. These actions are necessary, not alone because of the need to protect at risk habitats and species, but to ensure that the carbon capture potential of our seas is maintained.
In addition, based on our close observation over the past 16 years of management of Ireland's flawed Marine Planning regime, we also called for:
No fast-tracking of 'Relevant Projects', massive proposals for offshore wind development that have been advanced under the old Foreshore regime, acknowledged for decades to be not ‘fit-for-purpose’.
‘Relevant Projects’ have been subject to no Strategic Environmental Assessment. This critically important environmental safeguard must be undertaken, as officially required, to ensure that marine ecosystems will be protected, conserved and restored.
Offshore Renewable Energy Development Plan 1, that expired in 2020, must be fully reviewed and subject to effective Strategic Environmental Assessment.
The potential for wind farm construction on sandbanks to result in increased coastal erosion and habitat degradation along the already vulnerable east coast must be carefully assessed.
All applications for development consent must be assessed under the new planning regime by the Maritime Area Regulatory Authority, due to be set up in 2023.
No foreshore leases should be issued until additional Marine Protected Areas are established. As of September 2024, this has not happened.
Proposed East Coast Wind Farms
Huge near-shore developments with hundreds of turbines up to 320m high are being progressed along the coast from Dundalk Bay to Carnsore Point, around Carnsore Point past the Saltee Islands by the Wexford and Waterford coasts, in advance of the designation of Marine Protected Areas to protect marine biodiversity and urgently required legislative reform. A further major project is proposed in Galway Bay.
A Review of the National Marine Planning Framework, commissioned by SWAN, shows that this Framework does not comply with the basic requirements of the Marine Spatial Planning Directive (2014/89/EU ) making a nonsense of the commitment to introduce ecosystem-based Marine Spatial Planning in Ireland.
A CCA graphic shows that turbines proposed are too big, too close to shore and out of line with good international siting practice. It is stated by the industry that these 'Phase 1' projects cannot be placed further out from shore due to increased water depth. This is simply not true. Fixed bottom turbines can now be constructed in waters that are 60-70m deep and areas with this depth can be found 30km from Ireland's east coast. Indeed, SSE, seeking consent to industrialise the Arklow Bank, are themselves stating that they can build in deeper waters off Ireland's south coast.
Based on their rich ecology that supports national and internationally important bird species, fish spawning grounds and cetaceans, east coast sandbanks are unsuitable sites for offshore wind farms. The sandbanks also function to protect the coast from the worst impacts of easterly gales, and reduce the risk of coastal erosion, already a major threat to communities along much of the vulnerable east coast.
The increased risk of coastal erosion associated with wind farm construction on the sandbanks was flagged in the EU Conservation Assessment Report, 2007 by the National Parks and Wildlife Service, but laterally this significant risk appears to have been given little consideration.
Applications for permission to construct have been made (September 2024) for North Irish Sea Array and Arklow Bank (Consultations closed) and Codling Wind Park (Consultation open; closes 5.30pm, 18th November 2024) more will follow, probably before end 2024.
The information presented below does not reflect recent events so for updates on current proposals please see the information provided by individual developers.
Arklow Bank Wind Park Codling Wind Parks 1 & 2
Dublin Array North Irish Sea Array
Oriel Wind Farm Other proposed projects
National Marine Planning Framework
Draft Marine Spatial Plan and SEA published.
CCA Submission in response to the Public Consultation.
This CCA document raises serious concerns about the dominance of developer interests in the draft Plan produced.
Regulatory Failure
Buffer Zone Needed to Protect our coast
Nature Protection
Who Are Coastal Concern Alliance?
Coastal Concern Alliance (CCA) is an independent, voluntary group, set up in 2006 by environmentally conscious citizens to campaign for:
Reform of the outdated and undemocratic legislation governing construction in Irish seas (The Foreshore Act 1933).
Introduction of a new planning framework to protect our coastal landscapes and marine environment.
Development of a Marine Spatial Plan for Ireland.
We have no affiliation to any political party or industry group.
Why was Coastal Concern Alliance set up?
The vast majority of Irish people are unaware that large tracts of our ecologically sensitive, near-shore waters off the east coast have been targeted by developers for construction of some of the biggest offshore wind farms in the world. During the Celtic Tiger Era, 99 year Foreshore Leases were awarded for construction of two large scale wind farms with hundreds of huge turbines on the Arklow & Codling Banks off the coasts of Wicklow and south Dublin. Extensive exploratory licences were also awarded off the coasts of Louth, Dublin & Wicklow and in Galway Bay. More recently, Foreshore Licence applications have been submitted for exploration of large nearshore areas off Waterford and Cork.
An outdated and undemocratic legislative regime has facilitated this 'sea-grab' under the radar of public attention. This legacy of speculation and inadequate regulation continues to shape the future of our coastal zone, endangering protected habitats, marine wildlife and coastal landscapes.
The management of Ireland's coastal waters is a matter of great importance to many citizens who have been excluded from the decision-making process because of the serious democratic deficits which have existed for decades. The current marine planning legislation, the Foreshore Act 1933, empowers a sole individual, the Minister for the Environment, to grant foreshore leases to private individuals and dictate conditions attaching to those leases, with no statutory involvement of Local Authorities, no pre-selection of sites by government and no affordable public right of appeal against the Minister's decision. Developers were allowed to pick out sites on a 'first come first served' basis, with no public tendering. As a result of the low key manner in which this process worked, leases and licences have been granted without the knowledge of the vast majority of Irish citizens and their public representatives.
Coastal Concern Alliance supports the development of offshore renewables in Irish waters to help Ireland meet national energy objectives. We believe that permission to construct such huge industrial installations must be assessed under a democratic fit-for-purpose legislative process and developments must be to a proper scale and properly sited to avoid damaging impacts on marine wildlife, habitats and coastal landscapes.