An Taisce's Draft Policy for Wind Farms
March 2003
Introduction
This policy document outlines the current situation with regard to renewable energy development in Ireland; measures to encourage the development of the sector; benefits of wind power and the environmental impacts. We also recommend a strategic approach to the development of the sector in Ireland, examining the conditions where wind farms should not be permitted and outline mitigation factors for the siting of all wind farms.
An Taisce is of the opinion that if these recommendations are taken on board the development of the wind energy sector will be less contentious and better supported by the general public. Unfortunately, because of the way the wind farm energy is being introduced to date in Ireland, what is a vital initiative in renewable energy is in danger of acquiring a bad reputation. An Taisce urges the authorities and developers to involve local communities at the earliest stage of development right through the decision making process, regardless of the scale of the development.
GENERAL POLICY STATEMENT
An Taisce - The National Trust for Ireland recognises and supports the development of the wind energy sector in Ireland. However, An Taisce only supports wind turbine development where they are located outside protected natural sites, or sites nominated for or qualifying for protection, and where they are otherwise sensitively located and designed.
An Taisce recognises the benefits of wind energy over other forms of energy production, particularly over non-renewable fossil fuels. Wind power does not contribute to greenhouse gas emissions making a neutral addition to our GHG emission levels. If wind energy production replaces a significant proportion of our current methods of production it will contribute positively to our efforts to meet our Kyoto targets. Wind energy does not require constant feeding with coal or peat so associated transport costs, from economic and environmental standpoints are negligible (except during construction, de-commissioning or re-commissioning).
Importantly, the use of wind power instead of peat may help protect the remaining midland blanket bogs from industrial exploitation. It will also help preserve other non-renewable resources such as coal, oil and gas.
An Taisce supports wind energy as a means of energy production and wants to see a SIGNIFICANT increase in energy production by this means.
OVERALL ISSUES
Need for Integration with National Strategy
Current energy generation and use is creating a widening gap in meeting Kyoto greenhouse gas abatement tax targets to meet the requirement to cap 2008- 2110 levels at 13% over 1990 levels.
Consideration of wind energy must be linked to a wider energy conservation and power generation strategy including:
- Conservation and reduction of unsustainable energy use through increased thermal efficiency of national building stock
- Greater efficiency of use of energy at all levels
- Greater efficiency in new energy provision e.g. CHP plants
- Termination of any further burning of peat for electricity generation
- Closure of Moneypoint by 2008.
A clear target in annual generation levels in all renewables should be set out including biomass as well as wind, and recognising that potential for further hydro electric is limited, and workable wave energy applications are some distance into the future.
Fiscal Measures For Wind Energy
There is a need for strategy to integrate Renewable Energy Requirement with Electricity Regulation Act 1999 and EU Competition and Public Service Obligations, which would favour the most environmentally sustainable energy projects, and financially penalise the most unsustainable.
A current issue is that the purchase price of wind power for the national grid makes projects in the Bord na Mona cutaway bogs in the midlands unattractive, whereas the proposed peat burning stations are being inappropriately subsidised.
The de-regulation of the electricity supply sector under the Electricity Regulation Act, 1999 means that most of Ireland's future energy delivery will be provided primarily by the market, not directly by government.
The National Development Plan 2000-2006 seriously conflicts with the provisions of National Climate Change Strategy Ireland 2000.
A sum of £146 million was made available from 2000-2006 under the NDP for the following actions:
1. Promote energy efficiency
2. Promote research and development in energy efficiency and CO2 abatement
3. Promote alternative energy
4. Improve the energy efficiency of buildings
The 1999 Green Paper on Sustainable Energy states that it is intended to significantly increase the contribution of renewable sources of energy to meet Ireland's energy needs by setting a target for installed electricity generating a capacity of 500 Mwe in the period 2000-2005.
A new target must be set for 2008-2110. Wind energy should not have to carry the full renewable quota with a parallel programme to support biomass.
Need For Strategic Approach To Wind Farm Development
National Strategic Environmental Assessment undertaken to identify sites which may be suitable and results incorporated into National Spatial Strategy.
This would include identification of sites that should be excluded from wind farm developments.
In general the categories of sites most suitable are:
- OFFSHORE and largely east coast because of seabed condition. However marine off-shore wind farms - can alter sedimentation patterns
- CUTAWAY BOGS situated largely in midlands, where impact on residential amenity, natural heritage and sensitive landscapes in minimal. However wind speeds in these areas while higher that in many parts of Germany and other countries where wind is harnessed are lower that the west coast and other upland areas which in combination with sale price to the grid, makes development attractive.
- AREAS WITH LARGESCALE COMMERCIAL FORESTRY There are extensive areas where landscape character has been degraded through extensive Sitka and other planting. In these locations wind development would have less landscape impact depending on suitable siting, and contour lines. Compatibility of wind farms and forestry (at all stages of life cycle) should be ascertained.
Wind development should be avoided where there are:
- Nature or landscape designations should including SACs, SPAs, NHAs, SAAO, ASSI’s, IBAs and any candidate or proposed sites
- Visual impacts on sensitive landscapes requiring protection under European Draft Landscape Convention or designated in Local Authority Development Plans
- Impacts on birds, that are rare bird breeding sites or which host significant seabird concentrations Impacts on fragile peatland systems particularly blanket bogs through construction and maintenance access roads.
- Adverse impact on setting of archaeological sites
- Negative effects the tourism economy of the area
If any of these sites are suggested for development, the planning authority must ensure that the impact of the development is considered without mitigation measures factored in and ensure that there is no alternative location available before arriving at a decision.
The wind energy resource along the Irish west coast is one of the best in the world. Annual mean wind speeds of about 7m/s give annual available energy of 3MWh/m2, which would yield approximately 1MWh/m2 electrical output.
ESB (International) carried out a survey on the 'Total renewable resource in Ireland'- the results of which were published in 1997. The report found that the most significant element of the total renewable energy resource was wind energy and the best sites were primarily located along the west coast. The best counties for wind power were identified as Cork, Galway, Mayo, Wicklow, Donegal, Kerry and Sligo.
It is important to note that the west coast also hosts the majority of environmental designations, such as Special Areas of Conservation (SACs), Special Protection Areas (SPAs), Natural Heritage Areas (NHAs), Important Bird Areas (IBAs), amenity sites and sites where water designations apply.
The report also found that wind power had the potential to produce 19 times the energy currently being produced by the ESB.
MITIGATING POTENTIAL IMPACTS OF WIND FARMS
An EIS should be provided for all turbines.
Mitigation factors for siting of all wind farms should provide:
- Design and layout of turbines
- One access route always
- Post-construction, vegetation cover replaced on disturbed ground
- Semi-natural habitats on site to be retained
- Vehicle access gate to be locked at all times
- Sky-line and visual impact
Design Of Wind Turbines
Wind energy is harnessed using wind turbines, the height of which can extend to 100 metres when the highest point of the rotor blades is included. Each turbine usually has three rotating blades.
It is important to look at the design of the actual wind turbines when examining the potential impacts of a development. The use of a solid, rather than latticed turbine (which have been used at some sites in California and Spain) design is preferable. It seems that latticed turbines are more difficult to see in poor light and an increased bird mortality rate is associated with them due to a higher collision rate.
Footprint Of Development Vs Impact On Total Site
Although the actual land used for the siting of a wind farm may be quite large, extending to hundreds or even thousands of acres, the area used for the actual turbines, access roads and associated building is usually a small percentage of the total. Even so, the siting of a wind farm may cause habitat loss, disturbance and visual impacts.
Disturbance
Disturbance will occur during the construction phase but there may also be long term impacts associated with the life-time of the wind farm. The possible disturbance to birds is of particular concern and this can be caused by the noise of the rotating blades and by increased human activity on a site that was probably previously wild and undisturbed. The provision of access routes to service the development may also lead to increased traffic and walkers. The long term disturbance effects of wind farms on birds have not been proven but it is clearly site and species specific. Avoidance of the site by birds due to the wind farm must also be factored in to any possible impacts. If birds avoid the site, then a bird habitat has been lost.
Loss Of Habitat
Loss of habitat as a result of the land take for the turbines, buildings and roads must be considered individually in all cases. However, if the development is proposed for a protected habitat then the protection of that habitat must take precedence over the development. These included Special Areas of Conservation (SACs), Natural Heritage Areas (NHAs), Special Protection Areas (SPAs) and other designations. A wind farm can be re-located, an important habitat cannot. The fact that the rest of the site can still be undeveloped does not compensate for the fragmentation or other ecosystem changes that will occur.
In other cases the remaining land on site can be used for other purposes and in some countries cattle or sheep can graze right up to the base of turbines where they are located on agricultural land. In Ireland, the best wind resource has been identified as being in upland areas, coinciding in many instances with important blanket bog sites. In the absence of a national upland blanket bog survey, many important sites may not have an official designation and may be wrongly perceived by developers and planning authorities to have no conservation merit. The location of wind turbines on blanket bog areas should be avoided, particularly on intact units in order to prevent fragmentation of the habitat.
Soil Erosion
Wind turbines can facilitate soil erosion in areas with poor vegetation cover. It is possible that the impacts of tree felling or ground preparation for new tree plantations on soil erosion can be exacerbated by proximity to a wind farm. Depending on the effectiveness of silt traps connected to the forestry development, this could also have knock-on effects on water sedimentation/ siltation.
Landscape
Landscape impacts of a wind farm must be considered in all cases, but particularly where there are important views or protected landscapes or where the views are designated in the development plans as being of particular amenity. The assessment of visual impact should have regard to immediate visual impact and views from a distance. An Taisce supports national and county development plans that require developers to avoid hill top locations by ensuring that no turbine blade is above the ridgeline.
Appropriate techniques to facilitate the impact of potential visual impact should be adopted, including the provision of photomontages and for larger developments or developments on sensitive sites, more sophisticated computer imaging techniques.
Consideration must also be made of cumulative impacts, and planning authorities should co-ordinate policies and consult on developments with neighbouring authorities, including Northern Ireland.
All wind turbines should be similar in colour, design and rotation direction when in the same development. Care should be taken on neighbouring developments to have them look similar or clearly as two distinct developments.
Associated developments to the wind farm such as pylons, roads, and overhead power cables should also be examined for visual impacts. The surface of the road and indeed the road itself could have a significant visual impact on an otherwise undisturbed area.
MITIGATION FACTORS - CHOICE OF LOCATION
- No turbine blade should be visible above the ridge line.
- Access roads should be kept to the minimum, both in quantity and size - preferably just one per development.
- Wind farms should not cross important bird flight paths, migration routes or staging areas.
- Post-construction, vegetation cover replaced on disturbed ground.
- Semi-natural habitats on site to be retained.
- Access gate to be locked at all times.
An EIS should be undertaken for all proposed wind farms. Surveys of breeding and feeding birds within the impact area should be supplied for winter and summer.
The 'impact area' must include areas that will be used for the transportation of the energy into the national grid, and the impact of the structures that will be required for this.
Sky-line and visual impact must be considered.
References
DoE 1996. Wind Farm Development. Guidelines for Planning Authorities.
DoE 1999. Green Paper on Sustainable Energy.
FoE (UK) Special Briefing: Wind Power.
Brower, Michael: Cool Energy: Renewable solutions to environmental problems.
The Irish Energy Centre Renewable Energy Information Centre.
BWI. 2001. Policy on Wind Farms.
IPPC. 2001.Wind Energy. Draft bogs and Fens of Ireland Conservation Plan 2005.
Government of Ireland. National Development Plan 2000-2005.
ESB International 1997. Total renewable energy resource in Ireland.
An Taisce Wind Energy Policy. Presented to National Council 1998.