29th July 2014
Re: Wind Turbines by ATHGW at Eadestown, Naas, Co. Kildare
To whom it may concern
I wish to object to Planning Application Number 14/514 on the following grounds:
A: General development in the area
1. This area is part of Kildare uplands and as a consequence, the proposed wind turbines are in an area of development and environmental sensitivity as per the County Development Plan (see map 2.4):
8.3 To ensure that the location of renewable energy structures should minimise and / or mitigate any adverse visual and environmental impacts on the built or natural environment
8.5.1 It is recognised however that certain areas, which are suitable for the exploitation of large-scale renewable energy, may also coincide with the county’s designated sensitive and scenic areas.
10.3 – In parallel, the quality of the rural environment will be enhanced and protected from inappropriate development and/or practices.
2. With regard to the protection of views, the County Development Plan is quite clear (as outlined in Appendix 4) that the views in this area should remain uninhibited:
12. Views West of the Kildare plains from Redbog Area and Views towards Caureen;
from Rathmore Cross Roads to Pipershall. (Location:Greenmount, Redbog, Pipershall, Rathmore West)
The local road that runs through Rathmore provides scenic vistas of the Kildare plains to the southwest and the undulating lands at the County Boundary to the southeast. The elevated nature of the road and the generally low hedgerows and vegetation of the agricultural lands allow long-distance visibility. Although scattered rural housing is located in the area, these are partially screened by existing vegetation. The views available from hedge opening along the road remain unaffected.
See also map attached which details of scenic views and roads in this area.
B: Development of turbines in the area
1. While the Council must take into consideration the Wind Energy Guidelines 2006 in the context of this application, it is important to note that these are currently under review. Draft Energy Guidelines were published for consultation on December 2013 and submissions are currently being examined by the Department of Environment, Community and Natural Resources. A main focus of these submissions is the distance from turbines to residential properties. As part of my submission to the Draft Energy Guidelines, I indicated that while international practice varied, the distance should be in correlation with the turbine tip height. As per the suggestion in my submission, it would not be unreasonable to have a distance of ten times the turbine tip considered. As the proposed height for this development is 135 metres, therefore the appropriate set back distance should be 1.35 kilometres. However the nearest residential curtilage to the current development site is just over 500 metres, consequently I believe this development is too close to residential areas.
2. The County Development Plan refers to supporting Green Energy Projects (10.4.8) throughout the rural areas in the county, but with cognisance of the following – the need to protect landscape sensitivities, residential amenities, views or prospects, public rights of way, wildlife, habitats, special areas of conservation, protected structures, bird migration paths, etc. I do not believe that this application takes into consideration these conditions.
3, The County Development Plan recognises that wind energy is an integral part of the overall renewal energy strategy – 8.11.2 – WE 2: To encourage the development of wind energy in suitable locations in an environmentally sustainable manner and in accordance with Government policy. Whilst I also agree with the importance of wind energy, it is important to note that the County Development Plan (8.11.2 – WE 3) also ensures that the assessment of wind energy development proposals will have regard to:
• the sensitivity of the landscape;
• the visual impact on protected views, prospects, scenic routes, as well as local visual impacts;
• the impacts on nature conservation designations, archaeological areas and historic structures, public rights of way and walking routes;
• local environmental impacts, including noise and shadow flicker;
• the visual and environmental impacts of associated development such as access roads, plant and grid connections;
• the scale, size and layout of the project, any cumulative effects due to other projects;
• the impact of the proposed development on protected bird and mammal species
C: Impact on the wider community
I am aware that the Department of Defence is also submitting an objection as this development will conflict with air safety regulations for flying operations for the Irish Air Corp based in Baldonnell Airdrome. I fully support their objection.
Anthony Lawlor TD