Submission on the Draft Renewable Energy Strategy for County Mayo

Transcription

1 Irish Wind Energy Association, Sycamore House, Millennium Park, Osberstown, Naas, Co. Kildare. Iain Douglas Senior Planner Mayo County Council Áras an Chontae The Mall Castlebar Co Mayo Date: 28 January 2011 By Dear Mr. Douglas, Submission on the Draft Renewable Energy Strategy for County Mayo The Irish Wind Energy Association (IWEA) is Ireland s leading renewable energy representative body and as such welcomes the publication of the Draft Renewable Energy Strategy for County Mayo, which will inform the choice of location and design of renewable energy developments in the County until IWEA appreciates this opportunity to comment on the draft Strategy as published in December IWEA would like to request a meeting with you to discuss the document and our response in more detail. Yours sincerely, *sent by , bears no signature Caitríona Diviney Chief Operating Officer Irish Wind Energy Association

2 IWEA Submission on Draft Renewable Energy Strategy for County Mayo (December 2010) 1. Discussion IWEA welcomes Mayo County Council s recognition in the Renewable Energy Strategy (RES), that there exists in County Mayo a significant wind resource which can be harnessed to deliver significant benefits for the regional and national economy by producing electricity from indigenous renewable sources and benefits to the local economy. These developments will also significantly contribute to national targets of 40% of electricity from renewable energy sources by 2020 and National Climate Change Strategy policies to reduce CO 2 emissions. IWEA welcomes the recognition in the RES of the importance of the Eirgrid Gate 3 ITC Programme. There is grid connection approval in Gate 3 for 732MW of wind generation in County Mayo (not MW as stated in the RES). 646MW of projects have been offered connections to the Bellacorick node, which is almost 90% of the total Gate 3 projects for Mayo. There is an additional 40.8 MW of wind generation approved for the Dalton node, 30MW for the Tawnaghmore node and 15.15MW for the Bunnyconnellan node. The designation of Preferred and Open for Consideration areas, in particular in the North West represents a significant opportunity to establish an energy development hub by concentrating on the western part of the County where the technically and commercially mature wind energy resource can be developed within the lifetime of the RES. IWEA also welcomes the support in the RES for EirGrid s Grid Development Strategy, Grid25, and the recognition that it is a prerequisite to the development and export of electricity with the consequent economic and security of supply benefits for County Mayo. The provision of an upgraded electricity infrastructure will form the basis for the development of the Gate 3 ITC Programme but also in the long term for the development of renewable energy projects from other sources besides wind, as described in the RES. 2. Submission Proposals 2.1 Map 1 Wind Energy Clarification is needed on the anomaly between the text on Page 46 Section Wind Energy - On-shore Wind Energy and the Legend on Map 1. The text in Section lists 4 classifications in: - Priority Areas are areas which have secured planning permission and where on shore wind farms can be developed immediately. - Tier 1 (Large) are areas in which the potential for large wind farms is greatest. - Tier 1 (Cluster) are areas identified as being most suitable for smaller clusters of wind turbines (clusters of up to three turbines). - Tier 2 identifies areas which may be considered for wind farms or small clusters of wind turbines but where the visual impact on sensitive or vulnerable landscapes, listed highly scenic routes, scenic routes, scenic viewing points and scenic routes36 will be the principal consideration. However Map 1 Wind Energy on Page 69 illustrates 5 areas:

3 1) Existing Windfarms 2) Consented but not constructed windfarms 3) Preferred Tier 1 (Large) 4) Preferred Tier 1 (cluster) 5) Open for consideration Tier 1 IWEA suggests that Areas 1 & 2 on Map 1 should be Priority Areas where it is policy to: a) in areas identified as Existing windfarm - allow for extension turbines if there is available grid connection capacity. b) in areas identified as having Consented but not Constructed wind farms- a presumption of planning consent for turbine design or location changes to respond to technology changes that occur in the interim while projects wait on grid connection access and construction. 2.2 Potential Areas for On-Shore wind development as identified in Map 1 IWEA submits that consideration should be given to proposals for wind turbines in areas contiguous to the Preferred Areas (Tier 1) if it can be demonstrated that more favourable ground or visual mitigation conditions exist there than within the designated area. This would allow some flexibility to locate turbines just outside the chosen areas to mitigate environmental impact. 2.3 RES Section Wind Energy - On-shore wind energy Area Classifications IWEA suggests that in Tier 1 (Cluster) clusters should be defined as up to five turbines. The draft defines a Cluster as 3 turbines but this could be very limiting. A visual cluster - depending on the turbine layout and specific landscape characteristics of the area - might well be able to accommodate 5 turbines acceptably. Extending the definition to 5 turbines would optimise use of an indigenous resource and valuable grid infrastructure in south-east Mayo. 2.4 Designated areas There are a variety of habitats and areas designated throughout County Mayo, for example, NHAs, SACs and SPAs. There are situations where the designation of some of these sites with proper controls in place, would not be negatively impacted upon by the development of a wind farm near or on the site. In particular wind farms may have little or no impact on sites if the construction process is managed in a manner sensitive to the key reason for the designation. In such cases wind energy developments should be considered on their individual merits rather than with a presumption of incompatibility with the designated area. The European Commission has recently published guidelines, Wind energy developments and Natura , which provide guidance to national and regional authorities on how to ensure that the development of wind farms in Natura 2000 areas is compatible with the EU s Birds and Habitats Directives. It should be noted that within the guidance document it is stated that appropriately sited and well designed wind energy developments are generally not a threat to biodiversity and the document highlights that if planned properly, modern wind energy activities can not 1

4 only avoid impacting on wildlife but can also on occasion actively contribute to biodiversity conservation. Today wind farm developers are required to undertake an Environmental Impact Assessment before construction can start and in addition the EU s Habitats Directive (Article 6) includes substantive safeguards that must be applied to wind farm projects deemed likely to have an adverse effect on a Natura 2000 site. Overall, wind power s impact on birds, bats, other wildlife and natural habitats is extremely low compared with many other humanrelated activities. European Commissioner for the Environment, Janez Potočnik, has said: These new guidelines will give Member States and industry clarity regarding the undertaking of wind energy development activities in accordance with Natura 2000 requirements. There is no change of legislation or policy, but merely guidance on existing law. Our aim is to ensure that renewable energy targets are met while fully respecting EU law on species protection. The European Commission clearly recognises the need to meet renewable targets while ensuring biodiversity conservation in Natura 2000 protected areas. Their guidance document aims to avoid any conflict and clearly states that the Habitats Directive does not, a priori, exclude wind farm developments in or adjacent to Natura 2000 sites. These need to be judged on a case by case basis. In this context IWEA is concerned re Mayo County Council s presumption that wind energy and Natura sites cannot co-exist is in contradiction to EU Guidance. Wind energy developments need to be considered on their individual merits rather than with a presumption of incompatibility with a designated area. 2.5 Proposed Routing of 400kv Line The construction of the 400kV line (Flagford-Bellacorrick) is essential in realising the ambitious targets set out in the Renewable Energy Strategy, as established in Eirgrid s Grid 25 Strategy. We note that the Council s preferred corridor for a 400kv line is that along the existing 110kv line in the County (Page 35). We would agree that this represents a logical approach to development and seeks to provide an efficient utilisation of an established line corridor. However, this approach must be viewed within the constraints of 400kV line design parameters and specific issues may arise during the course of detailed line routing which prevents development along this route. In such instances there should be sufficient flexibility within the adopted policy to allow for deviations from this route. In this regard, we would ask the Council to amend Objective 3.2, to state: It is an objective of the Council to advise Eirgrid that, primary consideration should be given to following the existing 110kv and 38kv lines in the County or their established way leaves when selecting route options for any new 220kV or 400kV transmission line, wherever feasible. Furthermore, given the fact that the Flagford-Bellacorrick line will potentially traverse up to 4 counties (Leitrim, Roscommon, Sligo and Mayo) we would ask that Mayo County Council actively liaise with the adjoining Councils to ensure that a considered and consistent analysis of route options takes place. A co-ordinated approach between the relevant local authorities is essential in order to facilitate the construction of this key piece of infrastructure.

5 3. Conclusion IWEA agrees that the RES sets out a path to allow County Mayo to contribute to meeting national legally-binding targets on renewable energy and sets out opportunities for individuals, communities and businesses to harness renewable energy in a sustainable manner. The new Renewable Energy Strategy will be used as a framework document to realise the potential in Mayo to: Develop a sustainable, renewable energy industry employing construction and professional service providers and attracting significant capital investment over the next 13 years Significant rates revenue to County Mayo Significant community benefit including land lease payments to local landowners Construction of an electrical grid infrastructure in the North-West of the county that would be the basis of the new renewable energy hub. This could also be the basis that attracts industries that require strong electricity infrastructure locally. IWEA welcomes the proactive approach taken by Mayo County Council to realise Gate 3 onshore wind projects potential.