I have had too much on the go to be able to do another blog, so I am very happy to welcome an experienced wind warrior and ethical activist, Nigel de Haas, to tell us about his correspondence with the esteemed Minister.
Copies of the letters can be found at the end of the blog:
“A LOUD CLANG AS THE CAN GETS KICKED (AGAIN)
The Minister for Communications, Climate Action and Environment has responded to a letter that I wrote to him on 14th February by letter dated 27th March in which he has clarified the following points of public interest:
● A review of the Wind Energy Guidelines is a key commitment in the Programme for Government (May 2016);
● The review of Wind Energy Guidelines began in December 2013;
● This is a very technical area and engagement between the DCCAE and the DHPCLG is ongoing in order to bring the review to completion;
● The proposed new guidelines will be subject to SEA and associated public consultation before they are finalised by Government.
And so dear folks, having sat on their hands for three years since the close of public consultation, and having sat on the findings of the July 2015 RPS Report for two years and despite having committed to issuing the revised guidelines by November last year, the Minister and his Department intend to kick the can right out of the stadium, let alone down the road.
How far we have travelled from the lofty promises of the Programme for a Partnership Government, where Section 13.3.K) addressed the Rights of Local Communities and Indigenous Energy Generation with the words:
“The new Government understands the divisions and distress caused in local communities who feel that new energy infrastructure, like wind farms and pylons are imposed on them. The technology and scale of wind farms has evolved significantly since the last set of planning guidelines were introduced in 2006. As a matter of urgency the new Government will update the wind farm planning guidelines, within 3 to 6 months, to offer a better balance between the concerns of local communities and the need to invest in indigenous energy projects. These new planning guidelines will be informed by the public consultation process and best international practice”.
Words it seems are not the same as promises. Perhaps they are the new alternative reality? The subject of my letter to Minister Naughten of 14th February was the Public Disclosure finding by the Commissioner for Environmental Information in case CEI-15-0032 where he stated that:
“If disclosure were to lead to a submission being made to either or both Departments which was of such significance that it could not be ignored, such a submission would appear to be highly important and very much in the public interest.”
The disclosure referred to included a report commissioned by SEAI and prepared by RPS in 2015, showing that the size and ramifications of planned wind farm development far exceed the parameters in current use. Section 3.2.3 of the report states that the typical wind turbine size in any future development is likely to have a power rating of 3.5MW and a tip height of 150 to 175m (up to 190m in low-wind areas).
This is five (5) times larger than the 0.66MW wind turbines typically installed in 2006 when WEDG06 was issued.
Table 3.2 of the report shows that an estimated setback distance of 1209m would be necessary to meet the 40dB absolute noise limit proposed in the draft revision of WEGD06, and even with a 45dB limit the setback is estimated as 782m.
Compare these (Government-Commissioned Study) figures to Section 5.6 of WEDG06 which states:
“noise is unlikely to be a significant problem where the distance from the nearest turbine to any noise sensitive property is more than 500 metres”.
The disclosure is certainly of a significance that cannot be ignored, and it is indeed in the public interest that the following submission should be made:
● The proposed revision to the Wind Energy Development Guidelines (WEDG06) is now three years overdue;
● The existing, obsolete guidelines do not afford proper protection to rural residents;
● The Government has been shown by the CEI-ordered disclosure above to have commissioned modelling that reinforces the point that WEDG06 does not afford proper protection to rural residents.
Public planning policy implemented by all administrations in Ireland over the past 50 years or more has supported dispersed rural housing rather than the consolidated settlement pattern found in continental Europe where farms are huge and farm labour lives in consolidated hamlets and villages. Irish farms have historically been small, and sons and daughters frequently build on parcels of land from the family farm, or farmers have sold off plots to people who prefer to live in the quiet of the countryside.
The direct consequence of this historic planning policy is that there is far less potential to develop wind farms in Ireland than there is in continental Europe, without adversely affecting the lives of large numbers of people who have their homes in rural Ireland. Key Objective 5.6.1 of the draft revision to WEDG06:
“seeks to achieve a balance between the protection of residential amenity of neighbouring communities in the vicinity of wind energy developments, and facilitating the meeting of national renewable energy targets”.
The Minister is not convinced; in his letter of 27th March he takes the following position on the RPS report and setback distances:
● Key to the (RPS) calculations were the accumulation of worst-case based scenarios meaning that the figures arrived at cannot always represent likely real world situations;
● The figures should therefore be considered as maximum theoretical distances at which wind farm noises can be detected at the specified levels, rather than as minimum distances required to reduce noise intensities to those levels;
● This highlights the complexity of the conditions under investigation in the review of the guidelines currently under way.
It is all sort of flexible, squeezy stuff. Especially a setback of 1209m, which the Minister considers to be a maximum theoretical distance at which wind farm noises can be detected at a level of 40dB (the noise level first mooted by his Department in the 2013 draft Targeted Revision of the Wind Energy Guidelines).
The long suffering residents of rural Ireland have a better chance of resolving how many angels can dance on the head of a pin than getting any reasonable level of protection against inappropriately closely sited wind farms from the Ministers of DCCAE and DHPCLG any time soon.
And in the intervening period, more and more wind farms will happily pass through the planning process bound only by the outdated 500m setback, 43/45dB noise limit and permissible levels of shadow flicker.
Whatever happened to the concerned Minister for Communications, Climate Change and Environment who told the Dáil on 6th October 2016 that “I am as anxious as anybody else to have these new guidelines put in place as the current guidelines are not fit for purpose”?”
Nigel de Haas
Dunmanway, Co. Cork.