20th February 2014
RE: Wind Energy Guidelines (WEDG13) Submission
To whom it may concern
Whilst I appreciate that green energy is the way forward in terms of renewable energy in Ireland, the primary issue I have with the proposed revisions to the Wind Energy Development Guidelines 2006 is to do with the Section 5.6.4. In particular I would like to raise my concerns with the reference to the ‘minimum of separation of 500m between any commercial scale wind turbine and the nearest points of the curtilage of any property in the vicinity’.
The WEDG13 strives to ‘seek a balance between the protection of residential amenity and facilitating wind energy’ and it is therefore imperative that a reasonable approach is taken to alleviate the impact of noise and its associated effects on sleep and consequently health. Furthermore, the possible negative impact on the value of the property, particularly when the distance is less than 2km, must not be ignored.
I appreciate that a distance of 500m is used in other jurisdictions, such as Wales, however in Scotland the distance has been set at 2km whilst international best practice appears to be anywhere between 1.5km and 2km (and greater based on a turbine of height 125m).
• I would argue however that the setback distance, rather than being fixed at a particular distance, should be proportional to the height of the turbine – the higher the turbine the great the distance. It seems counterintuitive to claim that the impact of a 100m turbine at a distance of 500m from a house would have the same impact as a 175m turbine at the same distance.
• I also would have concerns with Section 5.6.9 allowing an exception to the 500m setback, where the owner provides consent- this could open landowners to coercion to consent.
• Whilst the density of wind turbines is not included in the guidelines, I would strongly recommend that the number of turbines erected in one location is limited to minimise impact on the local residential community.
• It is also imperative, both from a prudent commercial point of view and for the benefit of residents who will be directly affected by wind turbines, to undertake a transparent cost benefit analysis for wind derived electricity.
I hope you will consider some of these suggestions.
Anthony Lawlor TD