21st November 2013.
Dear Mr. Duggan,
We make this submission in response to Public Consultation, Stage 1 on the Renewable Energy Export Policy and Development Framework.
As this Stage is to set out the Framework for a scoping document in accordance with the undertaking of a Strategic Environmental Assessment as provided for under Directive 2001/42/ EC, we wish to make the following points.
The Directive provides for the assessment of the affects of certain plans and programmes on the environment and places responsibility towards sustainable development and protection of the environment as very clearly the responsibility of member states. We note from the background document provided that a separate process is to be undertaken which will provide a cost benefit analysis on this process. This is clearly a critical requirement and it should be incorporated into the criteria set out for the preparation of a scoping document. This essential element is an integral part of any such assessment in establishing the long term viability of this programme, particularly in circumstances where to date there has been a considerable bias in favour of Renewable Energy Policy in Ireland, and wind farms in particular. This has never been subject to any critical analysis,or cost benefit analysis. However, it has clearly been established that, while 2,100 MW of wind power has to date been installed on the National Grid, the average daily output from wind has been extremely variable, with an overall National average return of 25%. What is most important is the absence of wind generated energy on the grid at times of critical need.
The costs increase in accommodating and subsidising this form of energy has seen Ireland now having the third most expensive electricity bills in Europe. This is in contrast to the situation in 2000, when we were one of the cheapest countries for this essential source of energy. This has to be examined in the policy context, and the reality of our situation in terms of attracting, and maintaining, investment of industry in the country at a time when our economy has been destroyed by the failure of other regulatory policies and the misguided development of the construction sector in the absence of proper critical analysis. To all intents and purposes the current proposal to export renewable energy has the same potential to place an unsustainable burden on the next generation, if this grandiose project proves to be another monstrous failure.
The policy of allowing these developments in sensitive environments, based on the assumption of strategic need, is not balanced against the requirement and obligation to carry out a full cost benefit analysis and to critically review the long term stability of this policy and its capacity to make a viable return.
One of the flaws inherent in this proposal is the requirement for the State to effectively underwrite private enterprises by providing the necessary infrastructure to facilitate this development. No verifiable costings have been provided to show an established return to the Irish public. The life time of turbines operating in Ireland is known to be limited, with an average of 12 years currently being recognised as a reasonable life span. While permissions are granted on a 25 year basis, this short life span, and the tendency for output to drop drastically after a short term of operation,are critical factors in terms of economic viability.
It is essential that the criteria set out for the scoping stage of this proposed SEA process be comprehensive in its description of environmental vulnerabilities and sensitivities.
Article 174 provides that the Community Policy on the environment is to contribute to the preservation, protection and improvement of the quality of the environment, the prudent and rational utilisation of natural resources based on the Precautionary Principle.
It is a requirement of the SEA Directive that it be taken in parallel with the Habitat's Directive. This is an essential requirement in this process. Compliance with appropriate assessment of Natura Sites, and the consideration of restraints placed on the environment, must be assessed through the use of the 3 stage process.
As this first stage is purely intended to seek the views of the public and stakeholders in relation to the appropriate scope and level of detail that the Environmental Report will contain, we will present some facts in relation to County Donegal and the level of constraints that arise in respect of its environment.
Wind farms, by virtue of scale and size, are not localised features and the related ecological impacts of their development must be clearly identified and addressed in the preparation of the Environmental Report. In the case of Donegal, displacement of peat entering water courses, and the general sensitivity of Fresh Water Ecology, are notable concerns. Peat stability is a central consideration, and geo-
County Donegal hosts an ecologically rich and varied range of environments. There are a total of 74 European Sites within the County Development Area, 41 Annex 1 Habitats listed under the Habitat's Directive are represented in the SACs of County Donegal, with 9 of the Priority Habitats listed under the Directive recorded here.
The full extent of the County's Natural heritage extends to more than just those sites and the Environmental Report must consider the importance of active peat as a natural carbon sink. Active Blanket Bog is capable of removing 0.7 tonnes of carbon per hectare from the atmosphere on an annual basis. The figure of storage is estimated at 5,000 tonnes per hectare as an average by Pearce and Higgins in 1994. These are essential considerations for an SEA Scoping Process.
European Court of Justice has previously identified the relevant requirements for appropriate assessment under the Habitat's Directive in Case 258/11. As this is Stage 1 it is not essential for us to go through that Judgement. At this stage we merely draw attention to what the Court interpreted as the requirements.
In Donegal we have 6 Sub Basin Districts for the protection of the Freshwater Pearl Mussel. These were established under the Freshwater Pearl Mussel Regulations 2009 as part of the Water Framework Directive and following on from a previous Judgement of the ECJ against Ireland.
In drawing up the criteria for the Environmental Report consideration under Article 6 of the Habitat's Directive is a requirement. This is particularly important in the context of Donegal, given the receiving environment.
Your attention is also drawn to Article 10 where it states that member states should endeavour, where they consider it necessary in their land use through planning and development policies, to encourage the management of features of landscape which are of major importance for wild flora and fauna. Wind farms have the capacity to significantly impact on areas of environmental sensitivity.
Landscape considerations, in terms of visual amenity, and their importance to the establishment and maintenance of the tourism potential of Donegal,should also form part of the SEA Environmental Report.
In conclusion : we would urge that the strategic objective of the next phase of this process would have regard to the requirement for the consideration of potential cumulative affects, and in combination affects, of allowing, or zoning, parts of Donegal for this type of programme.
Environmental constraints and vulnerability maps should be drawn up. Clarity and transparency is an essential objective for the development of this Framework. Any implementation based on a systematic and comprehensive SEA Process must reflect the bio diversity of the County and the environmental performance. Donegal already has the highest number of wind farms in Ireland, with many more permitted, and the recent EPA Report on water quality in the County has identified siltation in the Oily River, part of a Freshwater Pearl Mussel Catchment, as being, in part, due to an adjoining wind farm.
While Donegal County Council has yet to carry out a landscape assessment for the County, the visual impact of these large scale developments must be considered in the context of their potential to erode and undermine the material asset that is the visual quality of Donegal and the importance of that landscape in making the County attractive for tourism.
Please give consideration to this submission.
Glenties Wind Farm Information Group