Marine Policy & Planning Environmental Assessment
STRATEGIC ENVIRONMENTAL ASSESSMENT
EU Directive 2001/42/EC, on the Assessment of the Effects of Certain Plans and Programmes on the Environment (The SEA Directive), requires that a Strategic Environmental Assessment (SEA) is undertaken to evaluate the likely significant environmental effects of certain public plans and programme.
Ireland is the only EU country to have permitted and advanced a significant amount of near-shore wind farm development through the permitting process without first putting in place a strategic plan and carrying out a SEA to assess cumulative effects.
The Irish government did not draw up a plan for development of offshore renewable energy. Instead the entire process was developer-led. Developers were allowed to pick out sites on a “first come first served basis” in Ireland’s near shore zone and then apply to the Minister for the Marine for foreshore leases to construct some of the biggest offshore wind farms in the world under the outdated Foreshore Act 1933.
Extensive, individual offshore wind projects set out below have been approved (1620MW) or advanced (2145MW) under our inadequate regulatory regime without the high level protection of a Strategic Environmental Assessment to assess cumulative environmental impacts:
All the above wind farms, with the exception of the Oriel project, are sited on shallow sandbanks, a habitat listed for protection under the EU Habitats Directive because of its importance to wildlife and vulnerability to human interference. The Oriel Foreshore Lease pertains to an area in Dundalk Bay, which is designated as both a Special Area of Conservation (SAC) for numerous habitat types, and a Special Protection Area (SPA) for numerous bird species. It is likely that extensive developments, by virtue of their nature, size and location in these sensitive environments, would result in significant adverse effects on the environment. The SEA of the OREDP states that, even with mitigation, there would be a medium risk of Likely Significant Effect on sensitive habitats such as sandbanks, mudflats and sandflats if development of permitted and proposed wind farms was to proceed. (OREDP Natura Impact Statement, 2011, p27).
Apart from the Sceirde project, all the proposed and permitted development is on the East coast. Essentially developers have been allowed to lay claim to extensive, wildlife-rich, scenic areas of Ireland’s East coast from Dundalk to Wexford, without the high level of environmental protection provided by Strategic Environmental Assessment. A total of 1620 MW of offshore wind power has been fully approved in Ireland’s near shore zone and a further 2145 MW has been advancing through our outdated and undemocratic permitting process with no SEA. This is almost three times the total amount of offshore wind power (1400 MW) installed worldwide at end 2009.
Foreshore leases for construction of offshore wind farms are extremely valuable commodities and can be sold on to international power companies at a price based on the size of the development permitted. The 'free for all' permitted by the Irish government and its failure to carry out an SEA in line with EU policy in advance of granting leases and licences, means that the profit motive rather than environmental protection has been the driving force shaping our coastal environment. Private individuals have benefited at the expense of the community at large.
STRATEGIC ENVIRONMENTAL ASSESSMENT - 2009
In 2009, the Irish government finally set about rectifying this serious failure in environmental protection. Eamon Ryan, Minister for Communications, Marine and Natural Resources requested that the Ocean Energy Development Unit (OEDU) of Sustainable Energy Ireland, in close collaboration with The Marine Institute, undertake a Strategic Environmental Assessment of Offshore Wind and Marine Renewable Energy in Ireland.
The Environmental Report, the main output of the SEA process, should identify, describe and evaluate the likely significant effects that the Offshore Renewable Energy Development Plan would have on the environment. The draft Environmental Report was published for public consultation in October 2010. CCA submission on the Strategic Environmental Assessmet of the Draft OREDP, May 2011.
The Offshore Renewable Energy Development Plan was adopted by government in 2014. The Plan served to rubber-stamp all the developer-led projects of the previous decade, but in addition concluded that a total of 9,800MW to 12,500MW of fixed offshore wind could be developed without likely significant adverse effects on the environment. This is almost three times the High Scenario (4500MW) which was tested in the SEA of the draft plan. No explanation is given as to how this was determined.
The actions listed in the OREDP were reviewed in 2017. For CCA comment see OREDP Mid-Term Review - CCA Submission, December 2017. A full review of the Plan is due to take place in 2020. This review must address the serious shortcomings which undermine the validity of the Plan.
CCA find it inexplicable and scientifically questionable that an assessment process specifically designed to consider three Development Scenarios for fixed offshore wind (Low-800MW; Medium-2,300MW and High-4,500MW) should conclude, without any valid explanation to support the decision, that a Scenario of 12,500MW, a multiple of the maximum tested, could be developed without likely significant adverse effect on the environment.
FOR FURTHER INFORMATION:
Offshore Renewable Energy Development Plan. (February 2014)