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Coastal Environment - Visual Impact Assessment of Offshore Development

Ireland

Ireland is an island nation and our coastal landscapes and seascapes are an important and highly appreciated factor in our identity. They make a major contribution to our economy, tourist industry and quality of life. The existing legislation and regulations governing construction at sea afford virtually no protection to our coastal landscapes.

Under The Foreshore Act 1933, the Minister for the Marine has responsibility for assessing the potential impact of offshore developments including impact on coastal landscapes, a factor which was probably not envisaged when the legislation was drafted. There is no statutory involvement of local planning authorities, their jurisdiction ends at the shoreline, and no public right of appeal to an independent appeals board such as An Bord Pleanala.

In making a decision on foreshore lease applications, the Minister is advised by a Marine Licence Vetting Committee (MLVC), which assesses the information provided in the developer's Environmental Impact Statement and makes recommendations to the Minister. The MLVC is composed of scientific and technical experts. It does not have a landscape professional as a member.

Under Ireland’s outdated permitting system, which is no longer “ fit for purpose”, no independent, professional assessment of the potential visual impact of offshore wind farms, individual or cumulative, is carried out. This is a very serious gap in the proper assessment of large-scale industrial projects proposed off high amenity coastlines, designated as Areas of Outstanding Natural Beauty in order to preserve their special scenic qualities.

International experience shows that the visual impact of offshore wind farms is an issue of paramount concern to local authorities and communities. Reflecting this concern, many EU countries are introducing buffer zones of 12 nautical miles (22.2km) to protect coastal areas. International comparisons show that Ireland is out of line with good international practice in permitting large-scale offshore wind farms with hundreds of giant turbines in sensitive, inshore zones, details here. Apart from perhaps the UK which, unlike Ireland, needs substantial amounts of offshore wind to reach binding EU targets for renewables, no other country in the EU is proposing large-scale development for inshore areas.

Ireland’s inadequate regulatory regime which affords no protection to coastal landscapes has been compounded by the Irish authorities’ failure to carry out a Strategic Environmental Assessment, in line with the EU SEA Directive, to assess cumulative impacts prior to permitting two of the biggest offshore wind farms in the world ( totaling 1620MW) 10/12km off Wicklow.

What is the value to Ireland and its people of the unspoiled seascapes of say Dublin Bay, Killiney Bay or Wicklow Bay? This is an important public question which must be openly and urgently addressed. The large-scale offshore wind farms permitted and proposed inappropriately close to Ireland’s east coast; involve hundreds of giant 5MW turbines, each 150m / 435 feet high, as high as a 35 storey building. These huge turbines spread over large areas of open sea will industrialise these iconic seascapes, significantly altering their character and quality.

Offshore wind turbines: how high?

Figure 1: Offshore Wind Turbines: Height from Sea Level to Blade Tip

No official assessment of the potential visual impact of offshore wind farms on Irish coastal landscapes appears to have been carried out. When such developments were first proposed, Ireland’s Marine Institute commissioned a report ‘Assessment of the Impact of Offshore Wind Energy Structures on the Marine Environment’, (April 2000). The scope of the study was limited to impacts on the underwater marine environment. Landscape / seascape impacts were not considered.

The Department of Communications, Marine and Natural Resources has been responsible for foreshore administration. The Department's ‘Offshore Electricity Generating Stations - Notes for Intending Developers’, (May 2001) is the key document providing guidance for offshore wind farm developers. The document devotes one paragraph to visual issues. It states;

“Where a proposed wind farm development is less than 5km from the shore, the developer must clearly demonstrate that it will not have a significant adverse visual impact.”

This implies that, if developments are sited at a distance of greater than 5km (3 miles) from shore, developers are not obliged to demonstrate that they will not have “a significant adverse visual impact”.

CCA comment

The trend now in strategic planning for coastal areas is to introduce buffer zones to protect high quality coastal landscapes. Germany, Belgium and Netherlands have introduced 12 nautical mile exclusion zones for offshore wind (22.2 km). In Ireland, the two extensive offshore wind farms permitted off Wicklow are inside this exclusion zone, 10/12 km off a coastline designated as an Area of Outstanding Natural Beauty.

The visual impact assessment of these two extensive developments was grossly inadequate. See details here. Absence of independent, professional landscape impact assessment, misleading photomontages and limited public consultation have combined to ensure that no-one has a clear idea of what these two extensive developments will look like or their impact on the quality and character of the Wicklow coastline.

Wicklow’s heritage is at risk. Corrective action must be taken. Independent professional assessment of cumulative visual impact must be carried out in line with best international practice before any public money is devoted to furthering these developments.

International

The visual impact of offshore wind farms is a matter of major concern and evaluation in other EU countries. In the United Kingdom, for example, the Department of Trade & Industry has produced a comprehensive document ‘Guidance on the Assessment of the Impact of Offshore Wind Farms: Seascape and Visual Impact Report’ (2005).

The introduction states:

“The growth expected in the offshore wind farm industry in England and Wales has the potential to change the seascape and visual amenity of coastal landscapes. Existing information, experience and issues of concern about seascape and visual assessment, and of offshore wind farms, are not necessarily in the public domain or documented within existing guidance and environmental statements.”

Scottish Natural Heritage has commissioned a report ‘An Assessment of the Sensitivity and Capacity of the Scottish Seascape in relation to Windfarms’ (2005). The objective was to develop, agree and apply a methodology for the strategic assessment of seascape sensitivity to, and capacity for, offshore wind farm development.

The Environment & Heritage Service (Northern Ireland) have also produced a report ‘Wind Energy Development in Northern Ireland Landscapes’ (February 2008). Given plans for increased cross-border cooperation, this document, which refers to seascape, underlines the urgent need for Ireland to assess landscape and seascape sensitivity to wind energy development.

CCA comment

The attention to visual impact assessment in the UK and other EU countries is in marked contrast to Ireland where no assessment of the sensitivity of Irish coastal landscapes to offshore wind farm development has been carried out. This represents a serious failure by government to protect one of Ireland's most important national assets, highly valued by local people and tourists alike.