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15 October 2016

Maritime Spatial Planning

Ireland's Maritime Spatial Plan will determine the long-term future of our coastal waters.  CCA has written to Simon Coveney, Minister for Housing, Planning and Local Government, urging him to ensure that Ireland's first Marine Plan rectifies developer-led foreshore administration and protects our unique and much valued coastal environment. The mistakes of past foreshore governance, which are well known at all levels of government, must now be openly acknowledged and addressed. See letter to Minister Coveney here.

2 April 2014

Offshore Renewable Energy Development Plan 2014 – A threat to east coast landscapes and marine environment

The Government has recently (Feb 2014)  adopted an Offshore Renewable Energy Development Plan (OREDP 2014) which poses a serious threat to the protected coastal landscapes and marine wildlife of Ireland’s high amenity East coast.  The Plan and its accompanying Strategic Environmental Assessment provide the framework for the construction of large- scale wind farms with up to 800 giant turbines (up to 180m) in full view of the coasts of Louth, Dublin and Wicklow. These wind farms are proposed by private developers and the energy generated is to be exported direct to the UK.  They are to be constructed 6 to 13km from shore, mostly on shallow sandbanks, a vulnerable habitat, protected under EU Habitat’s Directive (Annex 1) because of importance to marine wildlife, cetaceans and birds.

The OREDP 2014  “ a framework for the sustainable development of Ireland’s offshore renewable energy resource “ states that at least 4800MW of offshore wind can be installed off the East coast  “without significant adverse impact  on the environment”. (p.30). Such a conclusion can only be drawn if significant adverse visual impact on designated coastal landscapes (predicted in  developers’ environmental statements) and unknown impact on marine wildlife is not considered to be an environmental constraint. 

The OREDP 2014 is not a “national strategic plan” in the accepted sense of forward planning in the public interest.  With regard to offshore wind it is a clear example of retrospective planning. It serves simply to rubber stamp the large scale offshore wind farms permitted (1620MW) and progressed (c 2000MW) close to the East coast in an ad hoc manner with no national plan and no Strategic Environmental Assessment during the Celtic Tiger era. The permitted wind farms, both off Wicklow, are the 520MW Arklow Wind Park (200 turbines) permitted 2002, and the 1100MW Codling Wind Park (220 turbines) permitted 2005.  Proposed wind farms include the  330MW  Oriel Wind Park ( 55 turbines) off Louth; the 520MW Dublin Array (145 turbines) off Dublin and the 1000MW Codling Wind Park 2 (200 turbines off Bray Head). The location of these large scale windfarms, on protected habitat close to protected East coast landscapes, is out of line with good international siting practice, reflecting the inadequate regulation of the sector. These windfarms are too big and too close to shore. The average distance from shore of these windfarms is 10km. This compares to the average distance from shore of offshore wind farms under construction in Europe in 2013 which is 30km according to the European Wind Energy Association. The visual impact of offshore wind farms on adjoining coastal landscapes is a key consideration in all EU maritime countries, with countries such as Germany introducing 22km buffer zones around their coasts to protect visual amenity . The shocking lack of consideration given to this key aspect of appropriate siting in Ireland, reflects the undemocratic and outdated permitting process and the dominance of development interests.

The offshore wind farms off Ireland’s East coast have been advanced under the outdated Foreshore Act 1933 which gives the Minister for the Environment sole authority to permit construction in Irish waters. There is no affordable right of appeal against the Minister’s decision, contrary to the Aarhus convention This Act has long been officially acknowledged to be unfit for purpose and in need of significant reform. New legislation  - The Maritime Area and  Foreshore Amendment Bill -  is being introduced to reform the permitting system.

 In adopting the OREDP 2014, the Fine Gael /Labour coalition has failed to take the opportunity to address the legacy of speculation and inadequate regulation in the coastal zone which they inherited. They have ignored the well documented, inappropriate manner in which developer-led offshore wind projects were advanced off the East coast during the Celtic Tiger era under outdated legislation, at variance with good international practice.

Instead of taking a fresh approach, the coalition simply adopted the previous administration’s draft OREDP, produced by Minister Eamon Ryan in 2010. This draft OREDP 2010 , took all the huge wind farms advanced in an ad hoc manner off the East coast between 2002 and 2010 and presented them as part of a “Plan” to guide sustainable development in Irish waters.

The lack of transparency in the Offshore Renewable Energy Development Plan 2014 is very evident. Nowhere in the 60 page document - A Framework for the Sustainable Development of Ireland’s Offshore Renewable Resource - does it state that the bulk of the 4500MW of offshore wind development “that could potentially occur off the East coast assessment area without likely significant effects on the environment” has already been permitted or progressed with no Plan and no Strategic Environmental Assessment. .Submissions made in response to the public consultation on the Plan have not been published on the Department of Energy’s website. This serves to further undermine public confidence in the way our costal zone is governed.

Coastal Concern Alliance is extremely concerned at the manner in which developers’ plans for large scale development of offshore wind farms, originally proposed to service the Irish market and now earmarked for export,  are being advanced  with no cost benefit analysis and scant community consultation.

18 November 2013

CCA Submission to Joint Oireachtas Committee on New Foreshore Legislation

The undemocratic Foreshore Act 1933 is finally being reformed . It has left a damaging legacy of large scale offshore wind farms permitted and progressed in an inappropriate manner in Ireland’s near shore zone without any strategic planning. This legacy must be addressed if development in the coastal zone is to be sustainable

Coastal Concern Alliance was invited to make a submission to the Joint Oireachtas Committee on Environment , Culture and the Gaeltacht who are considering the heads of the new Maritime Area|& Foreshore Amendment Bill. The new Bill transfers responsibility for development consent for large projects deemed to be of a strategic nature to An Bord Pleanla.

See CCA Submission here

1 JUNE 2013

NOTE: Dublin Array Public Consultation Period extended to 5pm on 28 June 2013.

Coastal Concern Alliance has made a submission to the Department of the Environment, Heritage and Local Government (Foreshore Section) containing comments on the Environmental Impact Statement accompanying the application to the Minister by Saorgus Energy Ltd for a foreshore lease for the Dublin Array wind farm.. Our submission objects to the massive industrial development which proposes 145 huge turbines (160m high) with major adverse visual impact on Dublin and Wicklow coastline and unknown impact on marine wildlife and protected sandbank habitat. It highlights the outdated and undemocratic foreshore legislation, inadequate regulatory regime and developer- led process which has facilitated the application for this inappropriately sited development. The lack of democracy and inadequate consultation surrounding the issuing of foreshore leases, is underlined by the fact that the majority of coastal residents and their public representatives are unaware of the large scale development proposed for the Dublin/Wicklow coastline

CCA’s submission includes an Appendix prepared by Model Works Media .This appendix critiques the photomontages and visual impact assessment carried out on behalf of the developers and focuses on the impact of the wind farm on some specific preserved coastal views and prospects listed in Dun Laoghaire / Rathdown and Wicklow County Development Plans. It includes a photomontage showing the cumulative impact of the Dublin Array and Codling Bank wind farms on protected views from Bray Head. The methodology employed in the production of these verifiable photomontages is clearly set out. Model Works Media is an established firm in the production of verified photomontages and the assessment of visual impact on receiving environments. The firm is recognised as an independent expert among the architectural and planning professions. Its work is regularly relied upon by designers and planning authorities in the visual assessment of proposed developments. Its methodology follows and in some cases informs, best practice in the industry.

See CCA Submission here

Appendix 1 Photomontages here

1 MAY 2013

Overview: Dublin Array offshore wind  farm with 145 huge turbines proposed by  developer for Dublin Bay /Killliney Bay will have significant adverse visual impact on coast of Dublin and Wicklow.

Introduction: A private company has lodged an application with the Department of Environment, Community & Local Government for a Foreshore Lease to construct a large scale wind farm (“Dublin Array”) on the Kish & Bray Banks, 10 km off the coast of Dublin & Wicklow. The application proposes construction of 145 turbines, each up to 160 m from sea level to blade tip, five times higher than the Kish Lighthouse (31m) . The proposed development, one of the largest offshore windfarms in the world, would cover an area of 54 km2.
It will industrialise the entire seascape, degrade protected sandbanks and have unknown impacts on marine wildlife and birds.

Read the full article here

3 APRIL 2012

CCA's submission to the recent consultation on Our Ocean Wealth  puts on public record our concerns about the manner in which coastal zone policy has evolved in Ireland during the Celtic Tiger era, shaped largely by industry interests rather than an overall vision for our coasts and seas.

 Large scale offshore wind farm development has been permitted in Ireland’s East coast near-shore zone under outdated and undemocratic legislation (The Foreshore Act 1933) in a manner which does not comply with EU Environmental Directives; no coastal or marine spatial planning has been introduced to balance competing interests and large areas of ecologically rich habitat have not been surveyed and designated for protection as is required by the EU Habitats and Birds Directives.

As in many other areas of Irish governance, we are now at a turning point in our efforts to protect the public interest in management of a key national resource – the marine and coastal environment. The current administration must not choose to accept and build on the inadequate regulation and speculation of the past. Instead in the spirit of the  “Programme for Government”, it must openly acknowledge past mistakes and work to ensure that the future of our coastal area is based on open and democratic discussion of what is best for Ireland, its people and its environment into the future.

In a short introduction, CCA  puts on the public record our concerns about the following planning issues.

1. Global Offshore Wind Farms – Comparison with Ireland

2. Wicklow Offshore Wind Farms – Speculation and Inadequate Regulation

3. Draft Offshore Renewable Energy Development Plan – Developer led

4. Export of Offshore Wind Energy (ISLES project)-need for cost benefit analysis

5. Coastal Landscape Impact - a key constraint

The CCA Submission to Our Ocean Wealth is available here

2 FEBRUARY 2012

CCA calls for public inquiry in relation to application by Providence Resources for Foreshore Licence to explore 6Km from shore in Dublin Bay.

CCA  letter sent to  Minister Hogan  (1/2/2012) in response to the consultation on the application by Providence Resources for a foreshore licence for exploration in the Kish Basin. This proposed development is inside the 12 nm zone and highlights once again the  inadequacy of the current regulatory regime to democratically assess the large scale industrial development currently planned and proposed in Ireland's in shore waters. CCA are calling for a public inquiry and the introduction of  a 12nm buffer zone around the coast 

 

18 JANUARY 2012

Expensive Offshore Windfarms not Needed to Meet Ireland's Renewable Energy Targets says Minister Pat Rabbitte

At question time in Dail Eireann, Mr Pat Rabbitte TD, Minister for Communications, Energy & Natural Resources, outlined the Irish Government's position with regard to offshore wind energy. "I am confident that Ireland has the capability to achieve its targets for domestic renewable electricity from the onshore wind projects already in the existing gate processes", he said.  "Offshore wind currently costs in the region of €3 million per MW to deploy compared to the cost of onshore wind which is about half of that. ... Offshore wind is at least twice as expensive. I am satisfied, on the best advice available to me that we can make our targets from the development of onshore capacity, biomass and related technologies." 

Further details here.

13 DECEMBER 2010

Strategic Environmental Assessment of Offshore Renewable Energy Development Plan

The Irish government is belatedly moving to comply with the EU directive 2001 42/EC (The SEA Directive). The Department of Communications, Energy and Natural Resources has prepared a draft Offshore Renewable Energy Development Plan (OREDP) and has requested that SEAI’s Ocean Energy Development Unit, working in close collaboration with the Marine Institute, undertake a Strategic Environmental Assessment  “to evaluate the likely significant environmental effects of implementing plans to develop offshore renewable energy (offshore wind, wave and tidal) in Irish waters”.

The OREDP and Environmental Report were made available for public consultation from mid November 2010 for 8 weeks. Draft OREDP & Environmental Report This period of public consultation was subsequently extended by the Department of Communications Energy and Natural Resources to allow for publication of a Natura Impact Statement (NIS) during the month of February 2011 to inform the appropriate assessment of the OREDP. The Department’s website states:

The three documents (SEA Environmental Report, NIS and draft OREDP) will then be made available for comments and submissions by the public for a further period of not less than 4 weeks from the date of publication of the NIS by the Department of Communications Marine and Natural Resources. Written submissions may be submitted either by email to oresseaconsultation@seai.ie or by post to SEA Consultation, Sustainable Energy Authority of Ireland, Wilton Park House, Wilton Place Dublin 2.

Major National Issue

Two of the biggest offshore wind farms in the world, involving up to 420 turbines, have already been permitted,10/12 km off county Wicklow  on the sole authority of the Minister for the Marine with:

  • No national plan for offshore renewable energy development
  • No strategic environmental assessment
  • No statutory involvement of local authorities
  • No public right of appeal

These developments are the 520MW Arklow Bank Wind Park (approved by Minister Frank Fahey in 2002) and the 1100MW Codling Wind Park (approved by Minister Noel Dempsey in 2005).  In addition to these two permitted projects, substantial amounts of offshore wind power are already well advanced, notably   Dublin Array/Kish Bank, Dublin Bay (520MW); Oriel Windfarm, Dundalk Bay, (330MW); Sceirde Wind Farm, Galway (100MW).

How will the Irish government deal with these extensive offshore wind projects, permitted and progressing under outdated legislation and inadequate regulation?.  Will the Offshore Renewable Energy Development Plan and Strategic Environmental Assessment simply serve to rubber stamp inappropriate decisions already taken? Or will Ireland’s beautiful, wildlife rich coastal zone be given the protection afforded to the coasts of other EU countries?

Further details here.

18 MARCH 2010

Ireland: EU Commission sends final warning over four breaches of environmental law

The European Commission is sending a final warning to Ireland over four cases where it has failed to comply with European Court of Justice rulings concerning illegal developments that may harm the natural and man made heritage of the countryside, access to justice (and public participation in decision making) and protection of marine mammals (whales, dolphins and porpoises)

29 JANUARY 2010

ESB rules out involvement in “more expensive” offshore wind generation

The ESB believes offshore wind generated electricity is more expensive than even nuclear technologies and will not enter that sector in the medium term

16 DECEMBER 2009

ESRI questions offshore wind subsidies (RTE1)

The ESRI has published an economic policy review on sourcing electricity needs from wind, and building and maintaining the transmission network to accommodate this.

7 DECEMBER 2009

Ireland and eight European countries agree on North Seas Wind Project

At the Energy Council today, Minister Eamon Ryan signed a political declaration on the North Seas Countries Offshore Grid Initiative.

19 MARCH 2009

Small firms are looking to cash in big on green energy (The Scotsman)

“Small specialist companies are taking equity stakes in early stage renewable energy projects, gambling that they will enjoy a windfall long before earth is turned.” “ Joel Staadecker, SeaEnergy Chief Executive, said the resources needed to take an offshore wind farm to development stage are “small beer” compared with the construction phase, but the returns on investment are high.

5 JUNE 2008

Shell pulls out of key offshore wind farm project (Financial Times)

“Shell said on Wednesday it was seeking to sell its stake, while increasing its investment in onshore wind farms in the US”

30 MAY 2008

Vestas calls for greater focus on onshore wind (Business Green)

“Vestas, the world's largest manufacturer of turbines has today urged political leaders to focus on increasing capacity from onshore wind farms, amid warnings that the cost of installing offshore wind farms will continue to rise.”

29 MAY 2008

Offshore Wind Power: Capital Costs Will Continue to Rise (Cambridge Energy Research Associates)

“Supply chain bottlenecks and the resulting increases in capital costs for offshore wind power could create new challenges for Europe's target of generating 20 percent of its energy from renewable resources by 2020, according to a new report by Cambridge Energy Research Associates. The report, Offshore Wind: It's Not a Breeze outlines the major factors affecting offshore wind investment in the next decade.”

12 MAY 2008

Ireland's Biodiversity a Multi-Billion Euro Asset (Dept Environment, Heritage & Local Government)

“By drawing a comparison between the value of ecosystem services provided by biodiversity and the cost of implementing biodiversity protection policies, the authors established a marginal value of biodiversity to Ireland of at least €2.6 billion per annum”

8 FEBRUARY 2008

Announcement unlocks potential of renewable energy in Ireland. €4 billion investment in renewable energy now possible. (NOW Ireland)

“Measures announced by Minister Eamon Ryan today will unlock the potential of offshore wind energy in Ireland according to the National Offshore Wind Energy Association of Ireland. (NOW Ireland web site: Press releases)

8 FEBRUARY 2008

Minister launches new price support for offshore wind (DCENR)

“Minister Ryan announced the latest change to the REFIT scheme, which will support the development of offshore wind-power projects at a price of €140 per megawatt hour of power produced.”

14 FEBRUARY 2008

EU Nature Policy - Challenges in a changing world (EUROPA)

“2007 has been a remarkable year with environmental issues rising to the top of the EU's political agenda. Climate has grabbed the headlines but the loss of biodiversity is a global threat that is just as serious and needs to be faced with the same urgency. In one crucial way it is more worrying since there is no way to reverse extinction.” (Environment Commissioner Stavros Dimas)