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Windfarms and Upland Bogs 1996

Non-Governmental Organisations Observations on Irish Wind Farm Programme

The undersigned non-governmental organisations, recognise the fundamental importance of increasing Ireland's renewable energy sector as part of international efforts to combat climate change and reduce dependency on fossil fuels.

We further recognise that wind energy is a clean renewable, non-polluting source of energy, which is deserving of even greater government support than it currently receives when taking into account the external environmental costs posed by electricity generated from fossil fuel sources.

We support the Department of Public Enterprise's renewable energy strategy which aims to source 10% of Ireland's electricity supply from renewables by 2010 and other efforts to reduce Ireland's dependence on imported fossil fuels and to increase energy efficiency. We believe that much greater effort is required if Ireland is to meet its commitment of stabilising greenhouse gas emissions at +15% above 1990 levels, and that a radical programme of demand-side management and end-use efficiency will be necessary to curb the sharp rise in energy demand.

However, we are concerned that in the absence of a clear strategy governing wind farm developments and their environmental impacts, their full benefits may not be realised to the host communities or to the Irish economy.

We have recently discussed concerns felt over the development of wind farms, particularly in so far as they affect upland wildlife, habitats and sensitive visual amenities. We therefore wish to make the following comments on the nature and implementation of the current grant schemes relating to wind farm developments, which recognise their overall benefits in comparison to fossil fuel sources.

Specifically we wish to make the following points in relation to the Governments wind farm programme.

1. Habitats protection

Although the Department of the Environment has published guidelines for wind farm schemes (Wind farm Development-Guidelines for Planning Authorities, September 1996) we feel that environmental concerns need to be integrated more directly into proposed developments.

The current criteria for eligibility under the AER schemes require only that the applicants secure planning permission for the proposed development. No assessment of the site from an ecological or biodiversity perspective is undertaken by the Department and only commercial and technical criteria are used to evaluate applications. This represents a major weakness in the current AER schemes. It has the effect of placing tremendous pressure on sensitive upland areas, which, due to gaps and inconsistencies in the designation of Natural Heritage Areas's and Special Areas of Conservation's may not have been surveyed or designated under the draft list of SAC's forwarded to the European Commission. It is critical that the siting of wind farms is placed in a national context of inadequate upland habitats protection and enforcement, and that the Department revises the current scheme to specifically rule out the location of wind farms in ecologically sensitive areas, in or adjacent to designated habitats.

The Department of Public Enterprise and Employment should commission a land survey use, in association with relevant development and conservation departments, to identify those areas best suited to wind farm sites. This selection process should give due consideration to the biological and scenic value of areas. Such a scheme should be undertaken as a matter of priority.

2. Surveying of sites

The siting of wind farms in appropriate areas can have adverse affects on local ecology and biodiversity, especially upland bog areas and bird habitats. The National Parks and Wildlife Service should be required to carry out rigorous surveys of proposed sites as part of the site selection process in advance of planning approval and the granting of aid under the AER scheme. In general there ought to be much closer co-operation between the NPWS and the Department of Public Enterprise in assessing applications under the AER schemes relating to wind energy.

3. Environmental Impact Assessment and the Planning Process

Currently, there is no mandatory Environmental Impact Assessment for wind farm developments and there are some inconsistencies over the status of the biological importance of sites in recent An Bord Pleanala decisions. It is essential that all planning authorities explicitly recognise, on an equal footing, the ecological importance of sites in conjunction with visual amenities. We feel that all wind farm proposals, irrespective of size should be subject to full and proper Environmental Impact Assessment Surveys under EU Directive 85/337/EEC.

These surveys must address, inter alia:

(a) Visual and Noise Impacts

The visual and noise impact on areas in order to fully assess the visual impact of wind farms, local authorities should insist on adequate photo-montages or computer graphics to facilitate assessment. Zones of visual influence should be clearly defined at distances of 250m, 500m, 1000m, 1500m, 3000m, and 5000m accompanied by appropriate photo-montages and/or computer graphics.

In order to fully assess the impact of noise from a wind farm development, local authorities should insist on noise contour maps that take into consideration the topography of the immediate area and should include information on noise levels at distances of 100m, 200m, 500m, 1000m, at wind speeds of 5m/s, 8m/s and 12m/s. Noise levels should not exceed 40dB leq at the nearest noise sensitive property.

(b) Bird Impacts

From the research completed to date, there is sufficient evidence to determine that wind farms do impact on birds, however further research over a longer period is required before the effects can be established. Given this situation the precautionary approach to windfarm development in ecologically sensitive sites, must be applied. As such the following basic guidelines to wind farm development should be considered:

There should be a presumption against the siting of wind farms in ecologically sensitive sites. Many of these sites are designated as Special Protection Area's for birds, or are proposed as Natural Heritage Areas and Special Areas of Conservation. However, as there has been no recent and comprehensive survey of upland breeding birds, there are sites of potential conservation importance which have not been identified and are therefore not protected by the existing suite of statutory designations.

To ensure that upland sites of potential importance for bird conservation are identified and adequately assessed wind farm developments in upland areas of appropriate habitat should be subject to statutory environmental impact assessment as described by the European Communities (Environmental Impact Assessment) Regulations, 1989.

The Environmental Impact Assessment, should include a survey of the birds breeding and feeding within the impact area over a winter and summer season. During this period at least two winter and three summer visits should be completed. This will provide the minimum information required upon which to assess the conservation importance of the area and to determine whether or not the development is appropriate. Should the development then go ahead, this will also provide the basis for a monitoring programme.

Long term monitoring programmes should be implemented for a number of selected proposed wind farm sites. If the above guidelines are implemented, such sites will be of marginal conservation importance, however the data collected will be of use in determining the long term effects of wind farm developments on some bird populations. This will help to inform decisions regarding the siting of future developments. In such cases, pre - construction baseline data on the birds should be collected over a 2-3 year period and a range of ecological variables should be monitored both during and post - construction. Long term monitoring programmes to investigate impacts such as bird mortality and disturbance effects, should also be introduced at a number of existing wind farm sites.

(c) Upland Bog and Montane Heath Impacts

All upland areas scheduled for wind farm sites must be adequately surveyed for their habitat value. Where a site is found to be of conservation importance a bogland survey must be undertaken by technical experts from the National Parks and Wildlife Service. This is particularly important as no upland blanket bog survey or mountain heath survey to identify Natural Heritage Areas and Special Areas of Conservation has yet been undertaken by the National Parks and Wildlife Service. This has resulted in sites of high conservation value for their habitat being damaged by inappropriate wind farm schemes in Ireland.

4. The pricing structure for renewable energy

We note with concern that the low price of 4p per kW/hr offered to producers of wind energy tends to compel producers to locate wind farms in upland areas so as to increase the economic viability of the proposal. We recommend that the Department undertake an immediate review of the pricing structure under the AER schemes, especially given that the price offered to renewable energy producers has not increased since 1987. This review should attempt to ensure that the pricing structure makes non-upland areas attractive for wind energy producers.

5. The liberalisation of the electricity sector

The current debate surrounding the liberalisation of the electricity sector in Ireland has not taken sufficient account of the environmental impacts of electricity generation, especially from fossil fuels. We recommend that the forthcoming legislation set a clear target for wind energy generation with powers for the regulator to insist on wind farms being located in environmentally appropriate areas.

6. Benefits to local communities

Wind energy affords major opportunities for local communities to engage in sustainable development (see DEAT 1997 report on local and community owned wind energy projects). We urge the Department to prevail upon local authorities as part of their Local Agendas 21 to develop wind energy projects in conjunction with local communities under the AER scheme and the third party access facility. As long as wind farms are associated only with large schemes supplying energy to the national grid there will be little appreciation of their value and benefits. Wind farm developers should be required to offer a percentage of the energy they generate to local host communities. In addition, further grant aid should be made available to very small schemes to demonstrate the potential for energy self-sufficiency for local communities.

It is our opinion, that the implementation of the above suggestions would encourage greater local and national support for national wind farm schemes.

Changes along the lines suggested above would also ensure that wind farm scheme fully integrate environmental concerns into their planning and operation ensuring their sustainability and harmonisation into the National Biodiversity Plan being developed for Ireland by the Department of Arts, Heritage, Gaeltacht and the Islands.

If the Government were to adopt such guidelines, it would help prevent the recurrence of events already witnessed in Donegal where wind farm developments have been subject to appeal to An Bord Pléanála, or have been subject to investigation by the EU Commission for contravention of the Habitats Directives, or have not conformed to the Department of the Environments own guidelines.

On behalf of:

• Irish Peatland Conservation Council
• An Taisce
• Birdwatch Ireland
• Earthwatch
• Irish Wildlife Trust
• Mountaineering Council of Ireland