Chapter/Section

Chapter 12

Objective List Heading

Gas Network

Amendment Ref.

12.1

Amend Objective

KCDP 12-3: Facilitate the sustainable expansion of the gas network, including the facilitation of a gas importation facility in the Tarbert/Ballylongford Landbank, and the expansion of the network to the Kerry Hub and Knowledge Triangle settlements of Tralee, Killarney and Killorglin.

Chapter/Section

Chapter 12

Objective List Heading

Transmission Grid

Amendment Ref.

12.2

Amend Objective

KCDP 12-9: Support the sustainable implementation of EirGrid’s Grid 25 Investment Programme Shaping Our Electricity Future roadmap (and successor programmes), subject to landscape, residential, amenity and environmental considerations.

Chapter/Section

Chapter 12

Objective List Heading

Transmission Grid

Amendment Ref.

12.3

New Objective

Grid connection routing options should be developed to safeguard the strategic function of the national road network in accordance with Government policy by utilising available alternatives and standards/guidelines for glint and glare assessments.

Chapter/Section

Chapter 12

Objective List Heading

Transmission Grid

Amendment Ref.

12.4

New Objective

When considering the siting of powerlines all technological options including undergrounding shall be considered and it will be a priority to seek to avoid significant adverse effects on the environment including sensitive landscape areas and the ecological integrity of Natura 2000 sites

Chapter/Section

Chapter 12

Objective List Heading

Renewable Energy

Amendment Ref.

12.5

New Objective

Support and facilitate proposals for hybrid energy systems and/or co-location of renewable energy where applicable where such development has satisfactorily demonstrated that it will not have adverse impacts on the surrounding environment.

Chapter/Section

Chapter 12, Section 12.5.1

Amendment Ref.

12.6

Amend Text

The plan will be updated to refer to the Climate Action Plan 2021 [Section 12.5.1]

 

It is estimated  that  the Draft  County  Development  Plan  provides  the framework for approximately 389MW of additional renewable energy to be generated  over the lifetime of the plan from the following sources:

Hydro (6MW)

As is outlined in Table 12.3 of the Draft Kerry County Development Plan 2022-2028 there is limited generating capacity in terms of hydro in the county. In 1985 the Department of Energy published

Small Scale Hydro-Electric Potential of Ireland. This document identified a number of sites with potential for small scale hydro in Kerry. There are environmental factors that may determine the suitability or not of a site for hydro-electric generation.  Notwithstanding these issues, the total potential of the additional sites identified in Kerry is 5.93MW.

Solar (373MW)

Section 12.5.3.3 states that 13 solar farms have been permitted in Kerry. The generating capacity of these permitted solar farms is 137MW. Having regard to these recent applications and the landscape of the County there is potential for at least an additional 200MW of solar energy to be permitted in the County.

There  is  significant  potential  for  solar  PV  panels  to  be  provided  on  existing  housing  stock,  but  in  particular  on  the  7,000 housing units necessary over the lifetime of the plan as set out in the Core Strategy. If each of those proposed houses had solar panels installed, it could generate an estimated 15MW.

Between January 2017 and December 2019, approximately 100,000m² of agricultural buildings were permitted in the county as  new  buildings  or  as extensions  to  existing  buildings.  Over  the  lifetime  of  the  development  plan  it  is  estimated  that approximately 200,000m² of agricultural buildings will be permitted. If 50% of these roofs install photovoltaics, they could potentially generate 20.5MW of energy.

Bioenergy (10MW)

In terms of bioenergy, suitable agricultural lands that could contribute to same are located in all parts of the County, whether it be sources associated with lands or animals. It is estimated that up to 10MW of electricity, with additional potential for heat generation, could be generated from bioenergy.

Chapter/Section

Chapter 12

Objective Heading List

Wind

Amendment Ref.

12.7

Amend Objective

CDP 12-13: Ensure that projects shall be designed and developed in line with the Draft Revised Wind Energy Development Guidelines (DHPLG, 2019) and any update of these guidelines in terms of siting, layout and environmental studies   environmental assessment.

Chapter/Section

Chapter 12, Section 12.5.4.1.3

Amendment Ref.

12.8

Amend Text

Local areas where communities have developed or are developing proposals for on shore community-based wind projects may be considered in areas not deemed suitable for commercial wind farm development, subject to environmental assessment, including compliance with the requirements of the Habitats Directive.   They may be considered in areas outside of those zoned open to consideration or repower areas that are not subject to constraints as identified in the Wind Zoning Methodology.

Chapter/Section

Chapter 12, Section 12.5.4.1.4

Amendment Ref.

12.9

Amend Text and Map

12.5.4.1.4 Open-to-Consideration

Having regard to County Kerry’s current contribution to the provision of wind energy generation capacity in the State, the scale of this contribution and the scale of permitted, but not as yet constructed development, it is considered that the capacity of certain areas in the County to facilitate additional wind energy developments has been reached.

 

12.5.4.1.4 Open-to-Consideration

Second last bullet point to be amended as follows:-

Ensure that all applications are in compliance with Article 6 Habitats Directive, EIA Directive and Water Framework Directive. Where applicable, this should be informed by at least 2 years of annual (breeding and wintering) bird survey undertaken to best practices guidelines in addition to early engagement with statutory and non-statutory holders of ecological data, including with the Irish Hen Harrier Winter Survey

Wind Zoning Material Alterations Map

Map 12.4: Wind Energy Areas

Chapter/Section

Chapter 12

Objective List Heading

Renewable Energy

Amendment Ref.

12.10

New Objective

Facilitate and promote alternative forms of renewable energy including hydro, micro, solar and off-shore wind energy.

Chapter/Section

Chapter 12

Objective List Heading

Renewable Energy

Amendment Ref.

12.11

New Objective

During the lifetime of the Plan, Kerry County Council seeks to prepare a Renewable Energy Strategy for the County inclusive of targets across renewable energy sources, including the potential for offshore renewables, bioenergy, solar etc.

Chapter/Section

Chapter 12, Section 12.5.4.1.6

Amendment Ref.

12.12

Amend Text

12.5.4.1.6 Unsuitable for Wind Development

These areas are not considered suitable for commercial wind farm development due to visual, environmental or ecological sensitivities or the potential impact on recreational or cultural facilities or on sensitive receptors.

Chapter/Section

Chapter 12, Section 12.5.4.1.7

Amendment Ref.

12.13

Amend Text

Amend wording of Section 12.5.4.1.7 as follows:

As wind turbine technology continues to advance, existing windfarms and sites developed today have the potential to greatly increase efficiency and capacity by upgrading older turbines with more efficient technology or their replacement with larger capacity turbines in the future. It is noted that in some cases the existing windfarms in the repower area predate the European Site designation.  For the purposes of this plan and related development objectives, repowering includes wind farm upgrades, renewal, repowering or extension to permitted operational duration.

Within the Wind Energy Zoning maps accompanying this plan potential repowering areas have been identified, some of which are located within the Stack's to Mullaghareirk Mountains, West Limerick Hills and Mount Eagle SPA, known locally as the Hen Harrier SPA. This plan should not be construed as one which facilitates repowering within the Hen Harrier SPA without a legally acceptable Habitats Directive Assessment. But rather is one which facilitates the careful consideration of such proposals on a case-by-case basis, in accordance with the requirements of the Habitats Directive and the proper planning and sustainable development of the area. As part of this, impact on Hen Harrier population health within the SPA, in relation to ‘Favourable Conservation Status’, will be a fundamental consideration.

Repowering proposals differ from new applications in so far as they may be able to avail of the existing infrastructure and accordingly may not result in direct habitat loss of value within Hen Harrier SPAs. It is further noted that some windfarms in the SPA predate the European Site designation. Nonetheless, repowering proposals may still require grid upgrade works and / or transport upgrade works if taller turbines with greater capacity are proposed. In addition, displacement effects resulting from the unavailability of otherwise suitable habitat may still arise, as may disturbance risks (particularly during the construction stage) and collision risks (at the operational stage).

Given the outcome of the European Union Court of Justice (CJEU) Case C-164/17, wind farms in/adjacent to SPAs designated for Breeding Hen Harrier, when applying for repowering will require the submission of a Natura Impact Statement (NIS) that is informed by this judgement. This will include upgrades, renewal, repowering or extension of existing planning permissions, for wind farms. The EU Commission notice 2021/C 437/01 regarding alternative solutions and compensatory measures should also be taken into account, as appropriate. This notice outlines that ‘those measures which are not functionally part of the project, such as habitat improvement and restoration (even if contributing to a net increase of the habitat area within the affected European site) or creation and improvement of breeding or resting places for the species, should not be considered as mitigation as they do not reduce negative impact of the project as such. Such types of measures, if they are outside the normal practice required for the conservation of the site, meet rather the criteria for compensatory measures’. Proposals requiring such compensatory measures are required to be assessed within the context of Article 6(4) of the Habitats Directive, which also requires consideration of alternative solutions and imperative reasons of overriding public interest.

In summary, repowering of existing wind energy developments may be considered within the potential repowering zoning and which are within or adjacent to European sites will be open to consideration. These applications will be dealt with, on a case-by-case basis, in accordance with best practice environmental standards and compliance with Article 6 of the Habitats Directive and the proper planning and sustainable development of the area.

Chapter/Section

Chapter 12

Objective List Heading

Repower Areas

Amendment Ref.

12.14

Amend Objective

KCDP 12-16:

(a) Facilitate the sustainable replacement of turbines or repower energy projects in areas shown as ‘Repowering areas’ and areas ‘Open-to-Consideration’. Such proposals will be required to comply with Article 6 of the Habitats Directive.

(b) Ensure that repowering proposals within or in proximity to SPAs designated for Breeding Hen Harrier shall not result in insufficient habitat for the Hen Harrier in line with the conservation objectives of the SPA. As part of this re-powering, proposals will not be permitted to result in the taking out of additional Hen Harrier foraging habitat within the SPA.

(c) Ensure that all mitigation measures outlined in a Natura Impact Statement, submitted in support of Repowering proposals within or in proximity to SPAs designated for Breeding Hen Harrier shall be certain beyond all reasonable scientific doubt and shall be supported by robust evidence including at least 2 years of annual ornithological survey work.

(d) Ensure that repowering proposals within or in proximity to SPAs designated for Breeding Hen Harrier do not constitute an unacceptable collision risk to Hen Harrier. As part of this, early engagement with statutory and non-statutory holders of ecological data should be undertaken, including with the Irish Hen Harrier Winter Survey.

Chapter/Section

Chapter 12, Section 12.5.4.1.8

Amendment Ref.

12.15

Amend Text

12.5.4.1.8 Extension to Existing Windfarms

In certain circumstances an extension to an existing wind farm may be considered subject to its location in an open to consideration area or potential repower area, and subject to best practice environmental standards and where existing infrastructure can be used. Extension to existing windfarms will not be considered within Natura 2000 sites.

Chapter/Section

Chapter 12

Objective List Heading

Extensions to Existing Wind Farms

Amendment Ref.

12.16

Amend Objective

KCDP 12-18:  Consider extensions to an existing windfarm in areas zoned open to consideration or potential repower areas where it can be demonstrated to the satisfaction of the planning authority that there will be no significant adverse impact on residential amenity, the built and natural environment, or on the visual character of the landscape.

Chapter/Section

Chapter 12

Objective List Heading

Solar Energy

Amendment Ref.

12.17

Amend Objective

KCDP 12-21: Facilitate USSPV,  including USSPV electricity connections, where it can be demonstrated to the satisfaction of the planning authority that there will be no significant adverse impact on the built and natural environment, the visual character of the landscape, or on residential amenity.

Chapter/Section

Chapter 12

Objective List Heading

Solar Energy

Amendment Ref.

12.18

New Objective

Ensure that applications for Solar Farm developments should be accompanied by glint and glare assessments.

Chapter/Section

Chapter 12

Objective List

Heading Hydropower

Amendment Ref.

12.19

Amend Objective

KCDP 12-23: Support the sustainable development of small-scale hydro energy plants in appropriate waterbodies where proposals comply with the recommendations contained in the “Guidelines on the Planning, Design, Construction and Operation of Small-Scale Hydro-Electric schemes” published by Central Regional Fisheries Boards Inland Fisheries Ireland.

Chapter/Section

Chapter 12

Objective List Heading

Bioenergy & District Heating

Amendment Ref.

12.20

Amend Objective

KCDP 12-26: Consider in rural areas proposals for suitably small scaled developments for bioenergy plants including anaerobic digestors, close to the source material and where roads have capacity to absorb increased traffic flows. Such plants should, where possible, be located in proximity to existing agricultural buildings. Bioenergy installations shall not be permitted in areas where such developments may affect residential or visual amenity.

Chapter/Section

Chapter 12

Objective List Heading

Ocean Energy

Amendment Ref.

12.21

Amend Objective

KCDP 12-29: Support the sustainable development of onshore infrastructure, including grid connections, to facilitate the sustainable development of offshore energy projects at appropriate locations and further to environmental assessments.

Chapter/Section

Chapter 12

Objective List Heading

Community Consultation, Community Benefit & Community Projects

Amendment Ref.

12.22

Amend Objective

KCDP 12-33: Ensure that community benefits are derived from all renewable energy development in the county, including those subject to repowering or extension applications.

Chapter/Section

Chapter 12

Objective List Heading

Community Consultation, Community Benefit & Community Projects

Amendment Ref.

12.23

Amend Objective

KCDP 12-34: Facilitate suitably scaled community owned/led sustainable renewable energy projects in appropriate locations, including areas outside of open to consideration and potential repower areas. This will include requirements and considerations in relation to: residential amenity, landscape; cultural heritage; Natura 2000 sites and the Habitats & Birds Directive; the objectives of the Water Framework Directive; Flood Directive; and electricity infrastructure.

We are concerned that the Material Alteration to the County Development Plan to ‘facilitate the sustainable expansion of the gas network’ is at the least premature and at the most a misuse of the...
Please see attached document.
Amendment Ref. 12.6 (Chapter 12, Section 12.5.1) We submit that this objective as it stands is not in support of the Climate Action Plan (CAP) 2021. An allowance should be set for additional...
Please see the attached PDF for our submission to the public consultation. Best, Denis Devane
Please see attached letter