Submissions to Offaly draft County Development Plan

I wish to make a submission with respect to the Material Alterations to the Draft Offaly County Development Plan 2014-20.

1. I submit that the additional inserts to Section 1.8.3 in relation to Energy need to be deleted and in particular, the line " Development of the Grid will be facilitated where practical and necessary in the context of national transmission network planning" (p.6). Eirgrid have made it clear in their own Literature that the current Grid upgrade, Grid 25 is to facilitate wind-derived electricity. Eirgrid describe Grid 25 as “a platform to harness Ireland’s renewable energy and...........will enable Ireland to link with Great Britain with the potential to export and import electricity” (Eirgrid. 2012. p15).

Given that the economic viability of plans to increase wind energy in the Irish electricity system and to begin exporting wind derived power to other countries has not been adequately assessed, I submit that development of the grid should not be facilitated by Offaly County Council until such time as the Government's Energy Policy has been the subject of a full independent Cost Benefit Analysis.

2. Clause Ent O-08 which states "It is an objective of Offaly County Council to support the development of the Lough Boora Parklands as a National Peatlands Centre" needs to be retained in the CDP. This proposal is in line with the recommendations of the Draft National Peatlands Strategy published in Spring 2014 that National Peatland Parks be created on cutaway bogs. This proposed park “could provide an opportunity to develop a centre of excellence for applied integrated peatland research and a national database for peatland related data” (p.49 National Peatlands Strategy).

3. I also wish to register my support for Clause TO-10 which states "It is an objective of the Plan to promote the existing educational and amenity facilities at Clara Bog and Lough Boora and their expansion, subject to appropriate assessment". Clara Bog has been described by Amanda Pedlow, heritage officer with Offaly County Council as “ one of the rarest and most important ecosystems in western Europe – a raised bog”. Boora Bog outside Kilcormac in Co. Offaly was the first midlands site to be selected to participate in the Bioblitz organized by the National Biodiversity Data Centre and in a single 24 hour period on the 18th May 2012, over 940 different species were recorded proving that just two decades after peat harvesting ceased at Boora, a wide variety of wildlife has re-colonised the cutaway. Lough Boora already attracts thousands of visitors each year.

4. I submit that Clause TO-11 be removed from the CDP. This Clause proposes that the feasibility of an Energy Park with educational and amenity facilities be investigated. The Clause states "Any development of Renewable Energy on cutaway bog will be required to provide increased opportunities for amenity access and education". In the first instance, as evidenced by a recent Fáilte Ireland survey, people do not wish to spend their amenity/leisure time in an Energy Park of wind turbines. This Failte Ireland Draft Report as published by RTE on the 12th September 2013 found that 24% of tourists said wind farms would negatively impact on any future plan they had to holiday in Ireland. Fáilte Ireland will use this research to decide what planning applications for wind turbines it may or may not object to on the grounds of whether they are perceived to pose a risk to Ireland's tourism industry.

Secondly, it is contrary to peer-reviewed scientific research to site wind turbines on cutaway bogs. The Irish Peatland Conservation Council has described quite clearly why peatlands are especially unsuitable for the construction of wind farms. “Peatlands act as carbon sinks, holding the bulk of Ireland’s carbon stores, which is locked up in the peat soils. The construction of wind turbines on peatlands causes dessication of the peat soil and so upsets the carbon accumulation process and leads to an increase in the CO2 released into the atmosphere”. A 2013 study by Smith J. et al at the University of Aberdeen found that “wind farms constructed on undegraded peatlands introduce higher risks of net loss of carbon than wind farms constructed on mineral soils.” In relation to other peatland sites, they found that “when projected changes in emission factors are accounted for, the potential saving is very much reduced and most peatland sites will show no net carbon saving”. (Smith J. et al. Wind farms on undegraded peatlands are unlikely to reduce future carbon emissions. Energy Policy. 2013).

In fact, as recently as December 2014 Dr.Feehan spoke out about the current threat to our boglands from wind farm developments. During the course of a speech entitled “Reflections on fifty years of natural history” he categorically stated; “I need to say that if the policy of extensive wind farm development that is so much in the news these days, threatens the rich bio-diversity and open landscape of extensive areas of cutaway bog – which has such an essential role to play in the future wealth and wellbeing of our communities apart from any consideration of nature conservation – then the widespread awareness and appreciation of the community at large will have to be harnessed to the full in opposition to it”. (Speech at Offaly Historical Society, Dec 2014).

5. In view of the above, I also submit that the line in Ch 3 which states "It is Council policy to encourage the development of wind energy in cutaway bogs" be removed as it is contrary to scientific research and IPCC recommendations. Furthermore, this statement is incompatible with Section 7.1.3 of the CDP which notes that "Offaly has a wide diversity of natural and semi-natural habitats such as bogs, wetlands, etc that support a wide range of wild plant and animal species. Many of these areas are coming under increasing pressure as development intensifies and it is important that measures are put in place to respond to these pressures and that any development should not have a detrimental effect on the natural environment". (emphasis added). Offaly County Council need to note the recommendations in the EPA Report “Carbon Restore – The potential of restored irish peatlands for carbon uptake and storage” which state that “restoration and rehabilitation of drained peatlands can offer considerable resilience against the ongoing impacts of climate change” ( referenced on p.29 Draft National Peatlands Strategy). I submit that restoration of drained peatlands to naturally functioning peatland ecosystems should be the principal future land use of cutaway bogs. The statement that "it is Council policy to encourage the development of wind energy on cutaway bogs" is also incompatible with Section 7.9.5 of the CDP which states "There is potential to regenerate cutaway bog as is evidenced by the Lough Boora project". The pouring of thousands of tonnes of concrete into boglands for the construction of wind turbines is wholly incompatible with the regeneration of the cutaway.

6. With reference to the proposed amendments to Section 3.5.1 of Chapter 3 regarding wind turbine setback distances, I endorse the proposal that "Appropriate buffers should be provided which shall be a minimum of 3.2km from;

-town and village cores

-all residences

-areas of high amenity".

In view of the fact that a recent A.I.E. request (A.I.E./2014/15-Wind Turbines) revealed that the Department of Health had no input into the WEDG 2006, thereby revealing the complete lack of regard the aforesaid Guidelines have for public health, it is incumbent on Offaly County Council, who have a legal obligation to protect community health, to ensure that residents are protected by ensuring a minimum setback of ten times the turbine tip height from people's homes. It should be noted that the Deputy Chief Medical Officer Dr. Colette Bonner has confirmed that the reports which substantiate a ten times setback distance are in line "with best practice internationally". Furthermore this setback distance is consistent the Midland Regional Authority Planning Guidelines 2012-20 and gives clear effect to the Midlands Regional Authorities' requirement to direct the focus for wind farm development away from residential properties.

It also appears on examination of these Department of Health AIE documents that no Local Authority nor An Bord Pleanala has ever contacted the Department of Health for advice relating to recommending a safe level of noise, which is likely due to the representations by the Minister and others that the Guidelines adequately protect health.

This is a very serious anomaly and perhaps explains why the current Wind Energy Guidelines and the Draft Revision to those Guidelines prescribe a noise level that is in excess of twice that which the World Health Organisation recommend for protecting community health.

Given this situation, it would be gravely remiss of the Executive of Offaly County Council to dismiss issues of wind turbine noise and appropriate setback distances "as beyond the scope of the Council" (as described in the County Manager's Report to members on this issue dated April 2014). These issues were not beyond the scope of Donegal County Council, who voted on an amendment to the Donegal CDP on Monday 30th June to ensure that residents would be protected by a ten times setback distance from wind turbines.

7. I submit that Clause NHP26 should NOT be removed from the CDP. This Clause states "It is Council policy to discourage the felling of healthy mature trees to facilitate development". The removal of this Clause is contrary to The Convention on Biological Diversity 1993, which the state signed up to, whose definition of sustainability emphasises the protection of native flora and fauna in situ / place of origin – particularly the native trees of any place (being nature's highest achievement in the plant kingdom). The Convention states that native forests must be granted highest priority for protection, conservation and enhancement. All stability in nature of soil, air and water is conferred by native trees.

8 CSP08

European Communities (Environmental Assessment of Certain Plans and Programmes) Regulations 2004- 2011, Planning and Development (Strategic Environmental Assessment) Regulations 2004-2011 and the European Communities (Environmental Impact Assessment) Regulations 1989-2011 (or any updated/superseding legislation). Planning applications for proposed developments within the Plan Area that may give rise to likely significant effects on the environment may need to be accompanied by one or more of the following: an Environmental Impact Statement, an Ecological Impact Assessment Report, a Habitats Directive Appropriate Assessment Report or a Natura Impact Statement, as appropriate.

May needs to be removed from this sentence.

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