Need for Reform

Recommendations

The Irish government, acknowledging that the current developer-led approach to offshore windfarm development is not in the public interest, is finally moving to update our outdated system of marine licensing.

Responsibility for the awarding of foreshore leases was transferred to the Minister for Environment, Heritage and Local Government (now (2018) Housing, Planning and Local Government) who is currently reviewing foreshore legislation. A long overdue Strategic Environmental Assessment of the draft Offshore Renewable Energy Development Plan (OREDP) (2010) was commissioned. Coming in the wake of a decade of speculative activity, Coastal Concern Alliance hoped that these developments would represent first steps in the process of updating Ireland’s maritime governance.

However, it soon became obvious that the Plan and it's accompanying SEA, were designed to rubber stamp the large scale development permitted and progressed with no plan and no SEA from 2002-2010. A key question was how would the SEA handle this large scale development.

Once again, developer interests prevailed. In the Preface to the plan Minister Eamon Ryan stated that the Strategic Environmental Assessment of the Plan “should not influence or affect the processing of existing Foreshore Lease applications”. The Purpose of an SEA is to ensure that Plans and Programmes do not have a detrimental effect on the receiving environment. By excluding from that assessment or, in effect, requiring the SEA to rubber stamp all the already permitted and proposed developments, Minister Ryan effectively allowed developers to lay claim to huge tracts of environmentally sensitive in-shore waters (267 Km2) with no proper planning and no SEA.

The methodology and findings of this SEA were severely criticised by Coastal Concern Alliance and other important national bodies including the Heritage Council. In the SEA Final Report the consultants themselves acknowledged the significant data and information gaps. They also acknowledged that, even with mitigation, there would be a risk of Likely Significant Effect occurring as a result of direct damage to or loss of habitat from the installation of offshore renewable energy developments on Sandbanks slightly covered by sea water at all times, an Annexe 1 listed Habitat. The submissions to the SEA public consultation were not published and this flawed OREDP was adopted by government in 2014.

The emphasis of reform should have been on introducing a modern, transparent system of coastal and marine planning to protect our environment rather than on speeding up the permitting of inappropriate applications currently moving through a discredited and outdated consent process. Our new planning system must work to protect the long term national interest rather than the interest of any particular sector.

The Irish Academy of Engineering in a submission (March 2010) to the Joint Oireachtas Committee on Climate Change & Energy Security stated ”Offshore wind is technologically proven but remains exceedingly expensive in capital cost terms. It is not yet evident that its introduction at a large scale is possible due to restricted installation facilities. This technology will be pioneered in the UK over the next decade. Unlike England, Ireland has sufficient on shore sites to allow a significant further expansion of wind power without moving to expensive offshore facilities”.

Five years later, in a blog published in 2015 they recommended that the price supports for wind generation should be modified, that new renewable electricity developments should contribute to the full cost of associated network reinforcements in proportion to the share of additional capacity required for their development and that, in Ireland, there is no justification for introducing higher price supports for offshore as opposed to onshore wind. They believed that it was inappropriate that wind generators should benefit from the system problems caused by increased wind farm penetration.

Environmental impacts of large-scale offshore wind farms are not understood and there is widespread concern about possible impact on marine wildlife and habitats. Clearly, it would be wise to adopt a precautionary approach to such developments, in order to protect coastal processes and marine biodiversity, already under threat from climate change and man’s activities. Coastal Concern Alliance notes that almost all the large East coast wind farms proposed by developers are on shallow sandbanks, an important and fragile wildlife habitat, listed for protection in the EU Habitats Directive.

The adverse visual impact of large scale near-shore windfarms is well recognised. This is a major reason why most EU countries and the USA are reluctant to permit large-scale projects close to coastlines, valued by locals and tourists alike. Germany, Netherlands and Belgium have introduced a 12 nautical mile (22.2km) exclusion zone around their coasts to protect wildlife, coastal landscapes and sandbanks and are considering large scale offshore wind farms with hundreds of huge turbines far from shore in the North Sea. In Ireland, offshore wind farms of a similar scale have been approved well inside this buffer zone, as close as 10km off the scenic Wicklow coast.

Technological advances are enabling deep-water wind farms to be built far from shore. Spurred on by environmental concerns about large, near-shore windfarms, European countries, including Ireland, are devoting considerable R & D resources to developing deep-water technology to enable giant turbines to be placed far out to sea where visual impact is not an issue and winds are stronger and more consistent. Floating turbines are being developed which will enable turbines to be built on shore, hauled out to sea and tethered to the sea bed in deep water, in strong wind areas. These developments could enable wind farms to be installed far off Ireland’s west coast where the wind regime is among the best in the world. At the moment, offshore wind farms are almost all proposed for shallow, wildlife rich sandbanks near Ireland’s east coast, where the wind map of Europe indicates that the wind regime is on a par with many maritime regions in N. Europe.

By waiting a few years, Ireland can have large offshore windfarms, further from shore, with better wind and no negative impact on our unspoilt coastal landscapes. This is an important consideration for a country whose iconic coastal scenery is a key national resource and a central part of its attraction for visitors and locals alike.

SUMMARY

There is no economic, social or environmental need for Ireland to rush into permitting large-scale offshore wind farms close to sensitive coastlines on habitats listed for protection. On the contrary, it is clear that such a policy would not be in the national long term interest. Ireland has an opportunity now to adopt a measured approach to offshore renewable energy development, learning from experience in other EU countries and adopting policies and technologies which protect our marine environment, our treasured coastal landscapes and our economy.

CCA RECOMMENDATIONS

The development of marine renewable energy, built to a proper scale and properly sited, holds enormous promise for Ireland. As other EU countries have shown, such development does not have to come at the expense of nature protection and unspoilt coastal landscapes.

Ireland has made major mistakes in land-use planning with regard to over- zoning and developer-led planning. Similar mistakes are now being made in relation to the planning and sustainable development of Ireland’s valuable coastal zone. These mistakes are reversible. The two large-scale offshore windfarms permitted inappropriately close to the Wicklow coastline, under a regulatory regime now under reform, have not yet been built. No public money has yet been devoted to the highly expensive infrastructure, on land and at sea, needed to connect these developer-led projects to the Irish grid or indeed directly to a European Supergrid as the wind industry is now advocating. It would be ironic if Ireland ended up ruining unspoilt coastlines and degrading its wildlife habitats in order to allow international power companies to export wind energy to other EU countries who have introduced strict protection measures for their own coastal environments.

Coastal Concern Alliance recommends:

  • A review of the manner in which two of the biggest offshore wind farms in the world were approved in Wicklow’s near-shore waters by the Minister for the Marine under outdated legislation, with no statutory involvement of local authorities, no public right of appeal , no strategic environmental assessment and no independent, professional analysis of cumulative landscape impacts, details here (These developments, both involving over 200 turbines up to 150m high, are the 520MW Arklow Bank Wind Park off Arklow and the 1100MW Codling Wind Park off Bray Head).
  • An independent professional assessment of the landscape impacts of these developments which will have significant adverse impact on unspoilt coastal landscapes, (from Killiney Bay through County Wicklow to N. Wexford ) designated for protection in county development plans.
  • An open analysis of the cost of the price subsidies and grid development necessary to connect these projects to the Irish grid and the impact on Ireland’s price competitiveness.
  • A strategic plan-led policy framework for the development of offshore renewables to replace the current developer- led approach.
  • Comprehensive Strategic Environmental Assessment of the Irish coastline (including Wicklow) to be carried out with full public participation in line with EU legislation.
  • Marine Spatial Planning based on an ecosystem approach, to protect the marine environment and provide greater certainty about where developments should be allowed.
  • A 12 nautical mile exclusion zone (22km) for offshore wind farms to protect Ireland’s coastal landscapes and in-shore wildlife.
  • Integrated Coastal Zone Management to manage the land /sea divide, promote public participation and ensure local communities have a say in what happens to their coastline.
  • Cost/ benefit analysis of offshore renewable energy devices- wind, wave and tidal- to establish the best options for Ireland from an economic, environmental and social point of view.