I wish to make the following observations on the above
1. Renewable Energy Zoning
The County Development Plan states Kerry produces 18% of all wind electricity in the country, while having 6.8% of land mass and 3% of the population. This is an over concentration of wind farms. The cumulative effect of wind farms in an area, especially in North Kerry, needs to be taken into account for any future development and for any application for extending,“repowering” or renewing. The Board of an Bord Pleanala quotes Kerry County Council's planning zoning which identifies areas as suitable for wind farms as reasons for permitting applications for planning. Therefore, Kerry County Council is facilitating the development of more wind farms by zoning them as suitable for repowering, or by zoning any part of Kerry as open to consideration for more wind farms. All of this zoning should be removed from the development plan.
2. Landscape Charter Assessment / Tourism
The still applicable Landscape Character Assessment (2012) states that North and East Kerry’s landscapes are not important for scenery, tourism or recreation and no change to this is mentioned in the plan. This contradicts the development plan stated aims to encourage tourism in the whole of the county and to promote the Wild Atlantic Way and the county’s heritage and scenic sites as a destination for both national and international tourists. The development plan states that Kerry County Council will “support existing and new major attractions in County Kerry” this must apply to the whole of the County for example the North Kerry Greenway, Rattoo Tower, and ensuring our Blue Flag beaches keep their designation.
3. Biodiversity
The Kerry County Council must take into account the aims of the plan when considering any application that could impact on the wetlands, rivers and water courses in the County, both with respect to encouraging tourism into the county and the protection of the county’s wildlife and habitats. Kerry County Council must ensure that any developments in ecologically sensitive areas fully comply with EU Directives and that this requirement is applied to all aspects of any future development plans. Protection must be afforded to all rivers, lakes and watercourses both to ensure a clean water supply to business and homes but also to ensure that rivers and lakes comply to EU standards. This will encourage tourists such as bird watchers, anglers and walkers to the County and help to protect and encourage the diverse aquatic, birdlife and pollinators which are the mark of healthy, sustainable habitats. There has been a total disregard in environmental assessments to the number of Birds especially as nearly all are threatened with extinction and the modelling they are currently using is from Scottish heritage which is clearly outdated to current times of our biodiversity. Ireland should have its own modelling which matches our numbers and our biodiversity crisis that is why our numbers in wildlife are in a dire state it is clear from numbers of reports and needs to be tackled.
4. community consultation
There is a lack of engagement from developers and a total disregard to locals and communities welfare and voices of concern. Developers are discreetly signing land owners and doing the bare minimum to tick boxes in all sectors of scoping and reports for planning. Each development effects residents and communities with turbines of heights of 170m shouldn't be witthin a home or community 10x the tip height and guidelines should of facilitated and expanded when they were 50m and 500m from any dwelling.
5. Developments in peat
wind farms are continuously being constructed in peat, which as science shows sequester huge amounts of carbon, Germany are adopting to make wetlands for carbon offsets, where we have the potential for huge amounts of offsets by just saving all our bogs, construction in peat completely changes the hydrology and drains our bogs to facilitate turbines, roads and infrastructure where we could just block drains and let nature take its course it makes no sense what is happening. It will combat climate change and help biodiversity as biodiversity and climate change go hand in hand and without healthy ecosystems humans will not survive and what would it all been for financial gain of very few as biodiversity conservation and healthy ecosystems benefits all !!!