Four easy options to make a submission to Kilkenny County Council to influence its wind strategy for the coming 6 years in favour of communities
Save Our Hills is looking to everyone to make a submission to Kilkenny County Plan to address some concerns we have a as a group with the Kilkenny County Plan
We have outline below the submission we would like to you make. So all the hard work is done we now just need you to lodge the submission There are number of ways to make a submission.
Remember the closing date for the submission is 5pm on Wed 28 July
1. The Easy Way. Register with Save Our Hills. We send you a digital copy of the submission to sign. We will then send on your behalf. It’s very easy just ask save our hills.
2. Download a PDF copy of the Submission, Print sign name and write address in the space provided, contact anyone attached to the saveourhills group , we will collect and deliver on your behalf, or post to Denis Malone, senior planner, county hall, john st , kilkenny
3. download the pdf and attach to an email and write your name and address on the email and send to firstname.lastname@example.org In the subject line of the email write ‘Submission to material alterations’
4. Register your name and details on the Kilkenny County Council Online Then post your submission by clicking on the following link. Submission To County Plan Simple cut and paste the text below into the Submission
Cut and Paste from Here down
SUBMISSION REGARDING PROPOSED MATERIAL ALTERATIONS TO CHAPTER 11 & APPENDIX K OF THE KILKENNY CITY & COUNTY DRAFT DEVELOPMENT PLAN
This submission is made in accordance with Section 12(7) of the Planning & Development Act 2000 as amended, i.e. a written submission with respect to the proposed material alterations (or strategic environmental assessment) that shall be taken into account by the planning authority before the development plan is made.
- We welcome many of the sensible Material Alterations that have been proposed to the Draft Wind Energy Development Strategy.
- However it follows from these material alterations that the Draft Wind Strategy Areas Map [Figure 11.4] must be reconsidered for the entire County as set out below:
- As the Material Alterations to Section 11.5 Wind Energy omit almost all reference to the Draft Revised National Wind Energy Guidelines (which have not yet been adopted and may be altered prior to final publication), it therefore follows that the proposed County Wind Energy Development Strategy must now be in accordance with the current National Wind Energy Guidelines 2006, i.e. the same guidelines that were followed for the 2014-2020 County Development Plan.
- The “sieve mapping” methodology as outlined in the 2006 Wind Guidelines document produced the existing Wind Energy Development Strategy Map published as Figure 10.2 in the 2014-2020 Development Plan. Given that the same methodology must now be followed for the present Draft City & County Development Plan, then the resulting wind strategy map must be similar, as the input factors remain the same – there cannot have been any significant changes to wind speeds, landscape sensitivities, natural & built heritage, areas of archaeological importance in the last 7 years.
- Much of Appendix K, including the sieve mapping methodology, appears to still refer to the Draft 2019 Wind Guidelines and must be amended to the 2006 Wind Guidelines.
- The sieve mapping methodology omits many of the evaluation factors for landscape sensitivities that were included in the previous plan methodology – e.g. “Prominent Ridge Lines / Peaks” & “Settings/backdrops/horizons to centres of population” without any explanation for omission. The current 2014-2020 County Development Plan categorised the Mountnugent / Johnswell area as “UNSUITABLE” for wind energy development on the following basis:
“This area forms the backdrop for Kilkenny City and is highly visible from the eastern part of the city. There are views from this area of the City, and the converse applies. There are no windfarms permissions in this area.”
However this area is now deemed to be “Acceptable in Principle” without any justification. The potential for having large-scale wind farms as a backdrop to Kilkenny city is alarming not just for residents of the area but for the entire image and marketing of the “medieval city”. This area must be returned to “Not Normally Permissible” based on the same methodologies that were employed in the previous development plan.
7.The cherry-picking of just 3 areas from the Landscape Character Analysis for inclusion in the sieve mapping process is without justification, as nowhere in this document are these 3 areas specifically picked out over and above other areas. Indeed, the descriptions for the Nore and Suir valleys are very similar in wording to the description for the Castlecomer Plateau yet the latter has been completely omitted from the sieve mapping. This is despite Map 12 of the LCA identifying the Johnswell/Castlewarren as an “Area of High Amenity” and the final paragraph of Section 1.4.4 of the LCA which describes the Castlecomer Plateau as one of the “high amenity areas”.
- We also question the use of a Landscape Character Analysis dating to 2003 which describes the Kilkenny landscape as dynamic – on this basis should an up-to-date LCA not have been procured to inform future development plan mapping?
- The mapping process fails to measure the current and future carbon sink potential of the proposed windfarm sites, including tree lines, hedgerows, and wetlands. Carbon sink potential should be projected prior to any development of wind farm sites. Furthermore, the Common Agricultural Policy reforms tie farmer’s direct payments to results based eco-schemes. The impact of wind farm development and associated substations and road networks will impact on the biodiversity of neighbouring lands and further devalue the rural economy.
- It is clear from the proposed material alterations to change the designations of the Lingaun Valley and Templeorum/Mullenbeg areas to “Not Normally Permissible” that significant oversights were made in the initial draughting of the revised wind strategy map by failing to recognise many areas of significant archaeological importance. We believe that a further oversight has been made with regards to Freestone Hill, as Section 220.127.116.11 of the Draft Plan identifies “Freestone Hill and environs” as a priority for archaeological protection, however the sieve mapping process for the wind strategy map considered only Freestone Hill as a standalone element, and not its environs which would include its wider setting and backdrop of the Castlewarren / Johnswell hills.
- The New European Agenda for Culture (2018) recognises the importance of cultural heritage and its role in the future of sustainable tourism and sustainable rural areas. Sustainability is one of the five pillars of the Framework for Action on Cultural Heritage. This framework highlights the potential to enhance social capital, boost economic growth and secure environmental sustainability. Culture and natural heritage can help to achieve inclusive and sustainable development. The wind strategy fails to consider the impact of windfarms on the economic viability and social fabric of rural areas. Thriving rural economies have the potential to be decimated by depopulation and devaluation by the location of windfarms.
- The proposed Draft Wind Strategy Map if adopted without change would result in the almost wholesale opening up of the county to speculative wind farm developers. There is no strategic basis to do this. The proposed Material Alterations correctly remove the requirement for all of the County’s electricity demand to be met by renewable energy produced within the county. Electricity generation is carried out on a national basis, and some areas within the State are much more suited to wind farm development than others, with less landscape sensitivities and less dense rural populations. Therefore, some counties are likely to produce more than their required “share” of renewable energy, and other counties less.
- The proposed material alterations correctly identify that an increase in solar PV farms will also play a significant role in renewable energy provision within the County. Kilkenny as a whole is much more suitable for solar PV farms than wind farms, and these can easily allow the county to contribute to national renewable energy targets without the requirement for a proliferation of wind farms which have a mush more significant and negative impact on both natural heritage and rural residential amenities.
- While the new Development Plan must certainly have regard for current National Renewable Energy targets, it does not follow that significant amounts of upland areas in the county should be opened up to speculative wind farm developers. It must be borne in mind that offshore wind farms will play a significant part in meeting national renewable energy targets also.
- Indeed, Eirgrid have recently published their own analysis of how the national grid can be prepared to meet these renewable energy targets, as the locations of generation of electricity will change significantly. A presentation on this analysis was made to the Council by Eirgrid in May 2021. Their analysis clearly sets out that a developer-led approach to renewable energy generation will not achieve the 70% 2030 target as it will require too much additional infrastructure work to the national grid. Instead the Eirgrid analysis concludes that a generation-led approach which focuses much more on offshore wind energy generation is the only approach likely to meet the required target by 2030.
- Eirgrid’s preferred “Generation-Led” approach will require around 4.5GW offshore wind generation and just 1GW of additional inland generation from both solar and wind and will cost in total just €0.7Bn and is “highly likely to succeed”. In contrast a “Developer-Led” approach, which is basically a continuation of current policy allowing developers to propose wind farms wherever they want, will require an additional 4GW of inland wind farms, plus 2GW additional offshore plus 2GW of solar generation totalling €1.9Bn in cost and is “highly unlikely to succeed” in meeting 2030 targets.
- With respect to the proposed material alteration to the Strategic Aim of Chapter 11 Renewable Energy, we suggest the following addition in green text:
Strategic Aim: To promote and facilitate all forms of renewable energies and energy efficiency improvements in a sustainable manner as a response to climate change in suitable locations having due regard for and without significant detriment to existing natural heritage, built heritage, biodiversity and existing residential amenities.
- With respect to Section 11.5.2(d), we suggest the following deletion:
Large-scale wind energy developments will,
in usual circumstances, only be considered in ‘Acceptable in principle’ areas.
In summary we welcome the material alterations to the wind energy strategy but we believe that these alterations require the areas identified as unsuitable for wind farm development in the 2014-2020 Plan to be carried through into the new 2021-2027 Plan due to shortcomings in the sieve mapping process which should now be using the same methodologies and input factors as the previous development plan.
The Johnswelll/Castlewarren areas in particular form a significant scenic backdrop to Kilkenny City as well as providing highly scenic views over the Kilkenny basin (from Knockadeen Hill it is possible to see a panoramic view of 8 counties), it also contains significant archaeology and built heritage not least of which is Freestone Hill and the nationally regarded Ballysallagh House, the settings of which could be devastated by a significant wind farm development in the area. It is difficult to see how such a development in this area would not also damage the tourism and branding of Kilkenny as a “medieval city”.
Proceeding with the proposed material alterations to the county wind strategy and adopting the further amendments suggested above does not impact Kilkenny’s compliance with the Climate Action Charter for Local Authorities – being a signatory to this charter does not compel the local authority to provide for inland wind farm development over and above what can reasonably be accommodated having regard to the particular landscape sensitivities and rural amenities of the county. There remains significant potential for solar energy together with local community-led small-scale schemes in appropriate areas.
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