Dear Sir/Madam,
Bord Gáis Energy (BGE) welcomes the opportunity to comment on the draft Kilkenny County Development Plan 2014 – 2020.
Bord Gais Energy (BGE) is a dual-fuel, all-island business that serves nearly one million customers. It has over 1,000 staff employed across Ireland. Bord Gais Energy owns and operates over 200MW of wind power in the Republic of Ireland and Northern Ireland. As a major stakeholder in the wind energy sector, Bord Gais Energy welcomes the comprehensive and proactive approach that Kilkenny County Council has taken with regard to the future planning and development of wind within County Kilkenny, culminating in Chapter 10 – Renewable Energy Strategy and Appendix J – Wind Energy Development Strategy.
BGE believe that the availability of significant natural resources provides County Kilkenny with the opportunity to make a meaningful contribution to the development of renewable energy in line with National targets. There have been a number of policy documents published in recent years relating to targets for renewable energy developments. In March 2007 the Government published an Energy White Paper, Delivering a Sustainable Energy Future for Ireland 2007-2020. This paper sets out the Government’s Energy Policy Framework 2007-2020. The report details the many challenges Ireland is going to face in the future and sets actions and targets for a framework to 2020. In line with these commitments, the Government set a 40% National target for electricity from renewable energy sources (RES-E) by 2020.
BGE notes and supports Kilkenny County Council’s strategic aim outlined in Section 10 of the Draft 2014 – 2020 County Development Plan to promote and facilitate all forms of renewable energies and improvements in energy efficiencies as a response to climate change.
Bord Gáis Energy understand that the Draft 2014 – 2020 County Development Plan includes a revision of the current Wind Energy Development Strategy (2007, Appendix D Kilkenny County Development Plan 2008 - 2014) as Appendix J, which includes a revised Wind Energy Development Strategy map, Figure 10.2 replacing Map 15: ‘Kilkenny Wind Energy Development Strategy Map’.
More specifically, it is illustrated that under the proposed Draft 2014 - 2020 County Development Plan, an area currently identified as ‘Acceptable in Principle’ located north of Urlingford and northwest of Johnstown as highlighted in the map overleaf, has been significantly reduced in scale and is illustrated as Zone No. 5 ‘Preferred’.
BGE have particular interest in this general area and have recently commenced consultations with the relevant authorities and statutory consultees, including Kilkenny County Council and Laois County Council with regards to an 8 turbine wind energy development within the townlands of Baunmore, Bruckana and Rathpatrick in Co. Kilkenny and Graigueadrisly in Co. Laois.
While BGE welcome the retention of this localised area as a ‘Preferred’ area, we respectfully request Kilkenny County Council to consider expanding this designation further eastwards, as suggested by the area outlined in red below.
In making this request, BGE have taken due consideration of the methodology used to develop the strategy policy areas, and wish to note the following:
Wind Speed & Viability:
The SEAI Wind Atlas of Ireland approximates a wind speed of 7.25 to 7.5 m/s at a height of 75m within Zone 5 and surrounding region, increasing to 8m/s moving eastward. It must be noted that with each site, the wind regime is monitored closely by BGE to examine, in the first instance, feasibility but also to ensure the most appropriate turbine technology is matched with the site specific conditions, maximizing potential for the generation of wind energy. From initial BGE assessments, the wind regime within the red boundary line is similar to that of neighboring BGE windfarms Lisheen I and Lisheen II, which collectively have an export capacity of up to 60MW. These initial assessments suggest that Zone 5 and the suggested extension area as outlined in red are suitable for wind energy development.
As noted above, the Irish Government has set a target of 40% of electricity generated in Ireland to come from renewable sources by 2020; an 8 turbine wind energy development within the townlands of Baunmore, Bruckana and Rathpatrick in Co. Kilkenny and Graigueadrisly in Co. Laois has the potential to generate up to 24MW (maximum export capacity). Based on figures published by the Irish Wind Energy Association1 (IWEA), given a 31% load factor a 24MW wind farm has the potential to produce roughly 65,174 MWh in a year (24 MW*8760*0.31[1]). On average, this is enough to supply the electrical needs of around 10,9901 households for the year, resulting in significant CO2 emission savings.
Evaluation of landscape:
- Categorisation in 2003 LCA: With reference to the 2003 Kilkenny County Landscape Character Assessment (LCA) Section 4.11, the suggested eastward extension to Zone 5 lies within the A1 Slieveardagh Western Transition Area. The 2003 LCA notes: The transitional areas of the Slieveardagh uplands are not perceived as being of a special or sensitive nature.
- Prominent Ridge Lines/Peaks: With reference to Map 2 Landscape Sensitivity Factors ( LCA 2003), there are no principal ridges lines within the suggested eastward extension to Zone 5 or surrounding hinterland.
- Settings/Backdrops/Horizons to centers of population: The nearest centers of population to the suggested eastward extension to Zone 5 are Crosspatrick and Johnstown to the southeast, Templetouhy to the west and Rathdowney to the northeast. The area under consideration is not considered to form a setting, backdrop, main outlook or horizon for these centers of population.
- Tourism/Heritage: With reference to Figure 8.2 Landscape Character Assessment (Draft 2014-2020 CDP) there are no protected views within the suggested eastward extension to Zone 5. With reference to Draft 2014-2020 CDP Figure 7.1 Walking, Cycling and Rights of Way, there are no trails or walkways illustrated in the general Zone 5 region or surrounding areas, nor are there any Natural Heritage Sites located in this area (Ref. Draft 2014-2020 CDP Figure 8.1). Preliminary research has indicated that there are two Site & Monument Records within the suggested extension area (KK007-001001-Castle & KK007-001002-Earthwork); however the proposed 8 turbine wind energy development is not expected to have any significant impact on these sites and are located at a distance greater than 500m from the nearest proposed turbine location, falling outside of the proposed development site boundary.
- Existing Wind Farms: Bord Gáis Energy own and operate two existing wind farms in the Lisheen area, southwest of the area under consideration. The Lisheen I Wind Farm is located at Lisheen Mines close to the village of Moyne about 15 km from Thurles, within the townlands of Barnalisheen, Coolney, Derryfada, Derryville and Killoran, Co. Tipperary. Planning permission was granted by An Bord Pleanála on 14th August 2007 (ABP Planning Ref. PL.22.222142, Pl. Ref. 06/51/0773) to develop a renewable energy 20 turbine wind power development and associated works, subject to 17 conditions. 18 of the 20 turbines consented were constructed and the site is in commercial operation since September 2009. Lisheen II Wind Farm was granted planning by North Tipperary County Council, on the 30th of September 2009 (Planning ref. 09/510100). The 12 turbine Lisheen II Wind Farm is situated in close proximity to Lisheen Mines within the townlands of Barnalisheen, Cooleeny, Derryfada, Derryville and Killoran, Co Tipperary and has recently commenced operations. In 2010 Bord na Mona sought and received planning for a 16 turbine wind farm just west of the area under consideration within the townlands of Bruckana, Rathpatrick and Baunmore in County Kilkenny, Baunaghra in County Laois and Tullowmacjames, Derryvilee and Killoran in North Tipperary, planning permission. As the suggested extension area is located in an area of considerable existing wind farm development, it is considered that there is good potential for the proposed wind farm to be absorbed into the surrounding landscape without significant visual impact.
- Adjoining county’s policy: The suggested extension area east of Zone 5 shares its northern boundary with Co. Laois. As illustrated in the mapping below, the adjoining area is designated as a ‘Preferred Area’ for wind energy development.
Based on this review of ‘Wind Speed & Viability’ and ‘Evaluation of Landscape’, BGE consider that the area immediately east of preferred Zone 5 is suitable for wind energy development without any likely significant impact(s). Therefore we respectfully request Kilkenny County Council to consider expanding this ‘Preferred’ designation further eastwards. BGE also wish to clarify that any planning application for development in this area as extended would be subject to the full rigor of detailed site specific screening assessments and subsequent environmental and ecological assessments as required according to best practice in advance of submission.
BGE support Kilkenny County Council’s objectives to maximise renewable energy development potential in a sustainable and sensitive way. BGE recognise the potential progress the application of these objectives may offer towards meeting National targets. BGE strongly believes that the suggested eastward extension to Zone 5, as outlined above, meets these objectives with regards to maximizing potential for the generation of wind energy in a manner which is consistent with proper planning and sustainable development, while contributing to National targets without creating any significant impacts.
We trust that this submission will inform the preparation of Draft Kilkenny County Development Plan 2014 - 2020 and we look forward to any further opportunities to contribute to the strategy preparation process.
