Re: Submission in relation to Draft Kilkenny County Development Plan 2014 - 2020
Dear Sir / Madam,
Mainstream Renewable Power wish to make the following submission to Kilkenny County Council in relation the Wind Energy Development Strategy 2014 - 2020 which is currently in draft format.
INTRODUCTION :
Mainstream Renewable Power is an Irish based, majority Irish owned onshore wind, offshore wind and solar development company, operating in 8 countries across four continents. Since being founded by Eddie O’Connor in 2008 after the sale of Airtricity, Mainstream has a developed a pipeline of 16,800MW renewable energy projects worldwide, of which 330MW is already operational or in construction. This includes three projects here in Ireland – Caherciveen Wind Farm in Co. Kerry, Carrickeeny Wind Farm in Co. Leitrim and the Energy Bridge export project based across seven counties in the Irish Midlands.
Ireland has a comparative advantage over other countries by having one of the best wind resources in the world, calculated at approximately nineteen times our domestic consumption. Already relatively well developed with over 2000MW of electricity generated from wind (18%) and a further 4000MW scheduled for grid connection by 2023 to comfortably meet Ireland’s EU target of 40%, the Irish wind industry is at capacity. Grid connection queues are well in excess of ten years. Our island market has reached saturation point and there is little scope for further investment in the domestic market for greenfield projects.
Our neighbouring UK market is, by contrast, underserved, and the development pipeline even if delivered on time may fall short of its legally binding 2020 renewable energy targets of 30%.
THE ENERGY BRIDGE PROJECT :
Mainstream’s Energy Bridge is a 5,000MW wind energy export project between Ireland and the UK, being developed by Mainstream Renewable Power. The development focuses primarily on delivering 1200MW of onshore wind generation from the Irish midlands and transmitting it to the UK market from 2017 to 2020, through a fully undergrounded private transmission network, on land and via a subsea cable from Irish Coast to UK Coast. A 5,000MW grid connection agreement signed with UK National Grid guarantees Mainstream the ability to realise the project through a series of phased connections into the UK.
One of the key success drivers of the Energy Bridge project is securing a sufficient land bank to deliver the required level of electrical generation. Mainstream Renewable Power has, at May 2013, secured the first 1000MW of suitable land from private owners in the midlands, with lands representing a further 500MW currently under negotiation. A number of study areas, amounting to approx. 5000 acres have been identified across seven midlands counties.
Mainstream’s Energy Bridge project is scheduled to provide a route to market for Ireland’s surplus wind power, both onshore and offshore, and by developing Ireland’s underutilised wind resource create a very significant new export economy for Ireland.
The total benefit to the Irish economy in the medium and long term goes far beyond the export of the green power generated by Energy Bridge. The scale and timing of the opportunity, the favourable tax regime and the strategic positioning of Ireland at the edge of the world’s largest off-shore wind centre combine as key criteria for location decisions for new manufacturing plant to service the growing Northern European wind and cable transmission industries.
At 5000MW, the scale of Energy Bridge is more than sufficient to attract turbine manufacturing capacity, reducing significant transport costs for the technology companies for foundations, blades, towers, nacelles. Transport costs alone make location of new manufacturing plant feasible for this project.
Technology clustering and associated network effects have been seen in this industry in Denmark, Germany and more recently the UK for offshore technologies. Ireland’s location in Northern Europe, and our physical proximity to the UK (the world’s biggest offshore market) is a unique and defendable advantage.
New wind and ocean technology markets identified by the North Seas Offshore Grid Initiative, and the ISLES Project in conjunction with the British Irish Council, will be facilitated by the innovative transmission solutions driven by Energy Bridge. These long term projects will create long term demand for offshore turbines in the North Seas region, increased demand for onshore turbines in previously remote coastal locations, turbine and electrical components, HVDC cables, voltage source converter technologies and technical expertise.
Ireland’s support of a project of this scale will allow the country to capitalise on our comparative advantage and taking advantage of external circumstances will create another export industry which will deliver significant economic benefits both locally and nationally. There will be permanent benefits for the economy as a whole, the state itself and the local communities where the wind farms are situated.
Both the Irish and British governments have been working together to deliver the legislation which will facilitate the trading of renewable energy between to member European states, the first of its kind in Europe. A Memorandum of Understanding has already been signed by both governments and the completion of this agreement will ultimately result in an international trade agreement under the EU directive on Renewable Energy.
We must confirm that Ireland is open for business, otherwise we risk the opportunities created by with project being enjoyed elsewhere.
NATIONAL POLICY :
National policy on wind energy is contained in a variety of policy documents and frameworks. These set out the strategic vision that the Government have for the development of wind energy as a fundamental building block to our Green Economy. They can be summarised as follows:
· The National Spatial Strategy 2002
· Wind Energy Development Guidelines for Planning Authorities 2006
· The Energy Policy Framework 2007-2020
· EU Directive 2009/28/EC
· Department report 2009
· Developing the Green economy in Ireland 2009
· The Midlands RPG 2010-2022
· SEAI methodology 2012
The National Spatial Strategy
In 2002 the Government published the National Spatial Strategy (NSS) which is a framework to achieve a better balance of social, economic, physical development and population growth between regions. This strategy recognises the potential of regions outside of the GDA to develop new industry which in turn will generate benefits closer to where people live.
1.1 of the NSS refers to the Key concepts of which it states that;
“Linkages in terms of good transport, communications and energy networks are vitally important to enable places and areas to play to their strengths.” And also “a reliable, secure and cost-competitive energy supply…whose assembly at strategic locations in a targeted way is vital to foster a wide range of enterprise activity and employment creation”.
The Energy Bridge is entirely consistent with the aspirations of the NSS. The Midlands is a strategic location in the heart of Ireland that has large areas of land potentially suitable for wind farm development. The Midlands also has the strongest tradition for using and working with the landscape for industrial development and job creation (ref NSS section 4.4). Mainstream intends to continue this tradition and aims to harness the potential for economic development of the region through the Energy Bridge project.
At present it is not possible to connect to the local grid due to the current gate process being closed and oversubscribed. Demand will be met by the Gate 3 approved projects. However it is consistent with the NSS to transport this energy to where the demand is; the UK and European electricity markets, which is strongly supported under the EU Commission’s strategy for electricity market integration. This enables the use of the strategic location of the Midlands to facilitate the creation of a new industry and continued long term employment for the region.
Wind Energy Development Guidelines for Planning Authorities 2006
In 2006 the Department of the Environment published guidelines to be used when considering the planning of wind farm developments. Local authorities and An Bord Pleanála must have due regard to these guidelines when considering planning applications. The recommendations within the guidelines represent industry standards and best practice for wind farm development. The Noise and Shadow Flicker guidance is currently under review and public consultation has commenced in this regard.
Mainstream have applied these guidelines as best practice and propose to adhere to these guidelines and any subsequent revisions as a minimum standard when planning each wind farm in the Energy Bridge project.
The Energy Policy Framework 2007-2020
In 2009 the Government published a white paper containing the Energy Policy Framework 2007-2020. This document refers to Irelands difficulties as a small energy market. However it highlights the major opportunity that exists in harnessing the full potential of our renewable and bio-energy resources.
Included in the strategic goals of this framework are:
· The acceleration in growth of renewable energy sources
· The development of an all island Energy Market (which includes parts of the UK)
· Creating Jobs, growth and innovation in the energy sector
The Energy Bridge project is entirely consistent with the strategic goals set down in the Energy Policy framework.
EU Directive 2009/28/EC
In 2009 the EU published this Directive to establish a common framework for the use of energy from renewable sources in order to limit greenhouse gas emissions and to promote cleaner transport. To this end, national action plans were defined.
Each Member State has a target calculated according to the share of energy from renewable sources in its gross final consumption for 2020.
The Directive supports the cooperation of member states working together to achieve required targets. Member States can “exchange” an amount of energy from renewable sources using a statistical transfer, and set up joint projects concerning the production of electricity and heating from renewable sources.
The Directive sets the target of 16% for the share of energy produced from renewable sources in Ireland’s gross final consumption of energy by 2020 (S2020). This has subsequently been increased by the Irish Government to 40% in the National Energy Efficiency Action Plan. However, the Directive creates the conditions around Member state cooperation which forms the background to the Energy Bridge project.
National Energy Efficiency Action Plan 2009 -2020
In direct response to the publication of EU Directive 2009/28/EC the Irish Government published the National Energy Efficiency Action Plan (NEEAP). This plan lays down the targets to be achieved in accordance with and exceeding the targets set out in the EU Directive.
As discussed above, the targets set by the EU was 16% for the share of energy produced from renewable sources in gross final consumption of energy by 2020. However the NEEAP increased this target to 40%.
Paragraph 65 of NEEAP states that the Government policy is committed to promoting competition and choice, and continuing to developing the All-Island Energy Market Framework across a range of energy priorities, building upon the establishment in 2007 of the Single Electricity Market, leading to a more efficient supply sector.
The NEEAP also commits to examining the convergence of communications and electricity generation and distribution networks in order to develop a smart grid. A smart grid is one which can automatically control energy demand by signalling connected equipment to power down at times when increased demand might cause the system to exceed its optimum efficiency. This can improve continuous matching of supply to demand and allow seamless integration of intermittent renewable energy sources into a power grid. Smart grids can also facilitate the introduction of variable pricing tariffs, to incentivise consumers to use energy only at times when it is more available (e.g. lower price energy offered at off-peak times when there are high winds). Smart grids help reduce the need to store energy generated by renewable sources.
The Energy Bridge will be the first piece of the smart grid and will facilitate the export of Irish electricity to international markets. It heralds the creation of a new export Industry for Ireland.
Since its publication the NEEAP has been recently updated and supported with the publication of the NEEAP 2 in February 2013.
Developing the Green Economy in Ireland 2009
The Government’s framework for sustainable economic renewal (Building Ireland’s Smart Economy) incorporates a commitment to establish a High-Level Action Group on Green Enterprise. In May 2009, the Tánaiste and the Minister for Communications, Energy and Natural Resources established a High-Level Action Group mandated with developing an action plan to foster the growth of the green economy in Ireland.
The resulting report “Developing the Green Economy in Ireland” is focused on subsectors with high potential to create jobs and exports. The report highlights the importance of the renewable energy sector and in particular our wind resource which has significant potential to create sustainable jobs in the form of an export market.
The Energy Bridge project is entirely consistent with the recommendations of this report. There is a significant potential for the creation of short term construction jobs as well as long term manufacturing, software development and maintenance jobs.
We would welcome Kilkenny County Council’s support for this significant level of sustainable job creation in the county through the Energy Bridge project.
The Midlands Regional Planning Guidelines 2010-2022
The Midlands Regional Planning Guidelines are the direct interpretation of the Strategic objectives of the NSS. Out of the key strategic issues identified, the rural issues discussed in section 3.4.4.6 refer to the potential of renewable energy to create jobs and add wealth to the rural economy.
Section 3.4.6 supports the development of the Green Enterprise to enhance the region’s economy by creating employment and export opportunities. Given the rural nature of the landscape of the region, the planning guidelines state that the region offers significant potential for wind development.
Section 3.4.6.1 states that the RPGs support the development of wind energy generation, subject to appropriate siting considerations as set out in the Wind Energy Development Guidelines, DoEHLG(2006), Local Authority Wind Strategies and compliance with the environmental and landscape designations. This is supported by Economic Development Policy EDP 3.
The Energy Bridge project is consistent with the objectives of the MRPGs.
SEAI methodology for local authority renewable energy strategies 2012
In 2012 the SEAI produced a draft renewable energy strategy methodology for local authorities for public consultation. The document outlines the elements involved in renewable energy and the required information for compiling a renewable energy strategy.
The report notes that onshore wind farms currently represent the greatest contribution to the amount of renewable energy generated in Ireland. As of June 2012, Ireland has approximately 2195 MW of installed wind capacity. It is envisaged that in 2020, wind energy will contribute a substantial proportion of Ireland’s renewable electricity target (3,521 MW according to the NREAP First Progress Report, Jan 2012). Most of this energy generation will be from onshore wind.
Within a wind farm site, rarely more than 4% of the total land area of the site will be occupied or modified during the lifetime of the wind turbines.
The steps in the methodology for Local Authorities developing a Renewable Energy Strategy are as follows:
STEP 1 – POLICY CONTEXT
STEP 2 - IDENTIFY AND ASSESS THE RENEWABLE ENERGY RESOURCES AND POTENTIAL
STEP 3 - CONSTRAINTS AND FACILITATORS REVIEW
STEP 4 - DEVELOPMENT OF RENEWABLE ENERGY POLICY AND IMPLEMENTATION
Whilst we acknowledge that this document is only a draft, we support taking a holistic approach to developing renewable energy policies. It is vital that the public understand the strategies and potential opportunities available in each County and communicating these strategies has the capacity to assist future projects and the county’s success.
Fig. 1- SEAI Methodology for a Renewable Energy Strategy
Mainstream would be supportive of any Renewable Energy Policies being considered in accordance with the Methodology laid out by the SEAI.
WIND ENERGY DEVELOPMENT STRATEGY MAP:
Kilkenny County Development Plan 2008 – 2014 / Draft Wind Energy Development Map
The Wind Energy Development Strategy Map contained within the current Kilkenny County Development Plan has three classifications :
· Acceptable in Principal
· Not Normally Permissable
· Open for Consideration
ENERGY BRIDGE PROJECT – KILKENNY:
Since 2011 Mainstream have conducted site suitability assessments on a number of areas in Kilkenny as part of its development programme for the Energy Bridge project. The site selection process was initially focused exclusively on areas identified in the Wind Strategy Map and these sites are located primarily within areas categorised ‘Acceptable in Principal’ and ‘Open for Consideration’. Further assessments were completed on sites outside of these areas which relate to areas identified in the current Draft Wind Energy Strategy.
In the selection of these sites, Mainstream has paid particular attention to the screening out of high level constraints such as:
· Avoidance of all Natura 2000 sites
· Avoidance of all National designations
· Kilkenny County Development Plan
· DoEHLG 2006 Wind Energy Development Guidelines
· Midlands Regional Planning Guidelines
This screening process allowed Mainstream to identify a number of potentially suitable sites in Kilkenny, primarily in the area around Mullinavat with a small site also in the North West of the County on the border of Tipperary. These areas in principle would satisfy the national, regional and county development guidelines for wind energy development and are consistent with the current Kilkenny County Development Plan. As part of Mainstream’s Energy Bridge project, each viable site will be subject to the rigours of a full Environmental Impact Assessment, with only suitably qualified sites being included in a future planning application for the Energy Bridge project. Land agreements are already in place with the majority of private landowners within these sites and development works & EIA studies have been advancing in each area.
As part of the wider project Mainstream will also seek to conduct a cumulative assessment of wind energy throughout the counties involved in the Energy Project, the result of which will be submitted as part of our planning application.
In addition to our own in house EIA for each site the Irish government, through the Department of Communications, Energy and Natural Resources (DCENR), will conduct a full Strategic Environmental Assessment (SEA) of the midlands region over the coming year in relation to the export of renewable energy from projects based in this area. It is expected the outcome of this SEA will provide a framework for assessment of any project intended for the energy export market.
Mainstream are cognisant of the existing domestic wind energy industry and any projects destined for the domestic market. Mainstream will not seek to disrupt any existing wind energy projects via the development of the Energy Bridge project.
CONCLUSIONS :
A review of the National Planning Context shows that there is support for the Energy Bridge Project.
We request that Kilkenny County Council retain the current wind deployment zones contained within in the 2008-2014 County Development Plan. In relation to those outlined in the current Draft plan Mainstream would request that certain criteria limits be lowered to more suitable level in for modern wind energy development.
The criteria used to identify suitable wind development areas includes only identifying sites 75m above ground level and with wind speeds of 8m/s or above. Current wind turbine technology allows for commercially viable wind farms to be operational at sites where wind speeds are lower than 8m/s, and also on sites where the terrain is flat and significantly closer to sea level. Bord Na Mona’s Mount Lucas project in County Offaly, currently under construction, would be an example of one such project. The wind speeds in the Offaly region would be circa.7m/s and on a virtually flat landscape. The adoption of the limits used in the Draft plan will potentially rule out otherwise perfectly viable wind energy sites. It is Mainstream’s request that this criteria used in the Draft plan be reduced to more appropriate levels to allow for site suitability to be assessed on a site by site basis by scientific environmental assessment and a democratic planning process.
We would like to thank you for your time and consideration of the above matters. We would be happy to meet with you to discuss this submission in more detail. If you require any additional information to assist in your preparation of the Wind Energy Policy please do not hesitate to contact me directly.
