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53. Wind Energy Ireland WEI Submission on the strategic issues and options paper for Monaghan County Council 2025 – 2031 2 INTRODUCTION Table of Contents 1 Introduction .................................................................................................................................... 3 1.1 WEI and Wind Energy in Ireland ............................................................................................. 3 1.2 Wind Energy and Public Opinion ............................................................................................ 5 1.3 Wind Cuts Carbon and Cuts Energy Bills ................................................................................. 6 1.4 Regional Contribution of Wind Farms .................................................................................... 6 1.5 International Context and Policy Drivers ................................................................................ 8 2 Policy Ambition on Climate Action & Renewable Electricity .......................................................... 9 3 Climate Change - Facilitating Wind Energy Development ............................................................ 10 3.1 Importance of Onshore Wind Energy ................................................................................... 10 4 Regional Approach ........................................................................................................................ 12 5 Conclusion ..................................................................................................................................... 14 3 INTRODUCTION 1 Introduction Wind Energy Ireland (WEI) welcomes the opportunity to comment on the review of the existing Monaghan County Development Plan 2019 – 2025 (CDP 2019) and the preparation of the new Monaghan County Development Plan 2025 – 2031 (CDP 2025). We have reviewed the strategic policies and objectives relating to wind energy development in the CDP 2019 and the matters raised in the Pre-Draft Issues Paper, which was published to stimulate discussion in the review process. As the review will inform the vision, objectives, and policies of the new plan for Monaghan from 2025, WEI very much welcomes the opportunity to make a submission at the pre-draft stage and look forward to engaging constructively with Monaghan County Council throughout the development plan process. From our experience of the operation of the existing CDP 2019, WEI has an insight into what has worked well in applying the current policies and objectives and how policy can be further developed to ensure that the planning system facilitates good planning, supports renewable energy for the good of the consumer and helps drive sustainable energy development, as well as helping meet ambitious targets of doubling the installed wind energy capacity of Ireland to achieve a minimum 80% renewable electricity output by 2030 and net zero by 2050. This submission sets out the strategic context for wind energy development in Ireland before suggesting how specific local policies and objectives can help guide developers, provide an element of certainty, and ensure that such developments are carried out at locations and in ways that accord with the proper planning and sustainable development of the county and region. 1.1 WEI and Wind Energy in Ireland Wind Energy Ireland (WEI) is the representative body for the Irish wind industry, working to promote wind energy as an essential, economical, and environmentally friendly part of the country’s low- carbon energy future. We are Ireland’s largest renewable energy organisation, with close to 200 members who have come together to plan, build, operate and support the development of the country’s chief renewable energy resource. Ireland has just over 300 operational wind farms,1 representing an investment of over €7 billion and, as of 2022, 34 per cent of Ireland’s electricity. The wind energy industry supports 5,000 jobs and annually pays more than €48 million in commercial rates to local authorities2. We are a country with enormous renewable energy resources and potential and a world leader at incorporating onshore wind into the national grid. Wind energy decarbonises the electricity supply, cuts energy import costs and drives down wholesale electricity prices. To achieve this, Ireland has built just over 300 onshore wind farms, mostly since 2003, with a combined capacity of 4632 megawatts (MW) (see Figure 1 for historical growth of wind) and over 2,500 wind turbines. Even though these wind farms are supplying Ireland with the highest share of onshore wind 1 It should be noted that WEI, like the transmission system operator EirGrid, bases these figures on the number of individual wind farm connections. Some larger wind farms may have multiple connections. 2 Independent research carried out by Eamonn Halpin & Co. LTD – ‘Report on the rateable liabilities of wind farms’ on behalf of WEI (2022). 4 INTRODUCTION in any EU electricity system, the resource in Ireland is so large that Ireland’s turbine density is relatively low by EU standards. Due to a delay between the end of the REFIT scheme and the start of the RESS scheme, only 135 MW and 54 MW were installed in 2020 and 2021 respectively. There was an improvement in 2022 but the added capacity was below the 300 MW average we saw in the preceding two decades. Five other EU countries have a higher number of turbines per square kilometre than Ireland, as shown in Figure 2, suggesting there is still potential for further growth. Figure 1: Installed capacity of onshore wind in Ireland since 2000.3 Figure 2: Turbine density in various European countries. 3 Based on WEI databases 5 INTRODUCTION Onshore and offshore wind power now needs to propel Ireland to renewable energy heights if we are to meet the future renewable energy targets set out in Ireland’s Climate Action Plan. Government ambitions were initially set on developing at least 3.5 GW of offshore wind by 2030, this was later increased to 5 GW through the Programme for Government (PfG) agreed in June 2020. This is on top of the onshore commitments of an increase from ~ 4632 MW as of June 2023 to ~ 9000 MW by 2030. It is critical that the new MCC Development Plan provides every opportunity to get as many of the projects currently in development through the planning and approvals system to enable them to contribute to hitting our 2030 targets and to achieving carbon neutrality by 2050. Changes made to various government renewable energy policies in recent years have positioned planning permission as the critical first stage of any renewable energy project. Only when planning permission is secured can a project now apply for grid connection to export energy to the national grid and identify a route to market to sell it. Clear and supportive planning policies are needed for wind and all renewable energy developments to meet the challenges of climate change and decarbonisation over the coming decades. 1.2 Wind Energy and Public Opinion The most recent opinion poll carried out for WEI by Interactions 4 found that 80 per cent of Irish people were strongly in favour of, or tended to favour, wind energy (see Error! Reference source not found.3). It is important to reiterate that these figures have been born out through similar polling over the years, including with different polling companies. Furthermore, the opinion poll also goes to show that Nationally 58% of people indicated they would be open to a wind farm being developed in their local area. This marks the highest number in favour since WEI began this tracking. Only 1 in 10 rural residents opposed the development of a wind farm in their local area. Almost half of respondents (45%) ranked cheaper electricity as the top wind energy benefit. Figure 3: Results from opinion poll carried out by ‘Interactions’ on the attitude of Irish people towards wind energy. 4 https://windenergyireland.com/images/Final_WEI_Annual_Attitudes_Survey_2022.pdf 6 INTRODUCTION 1.3 Wind Cuts Carbon and Cuts Energy Bills Irish consumers avoided paying €2 billion for gas last year because the country’s wind farms provided 34 per cent of our electricity, up four points on 2021. The figures come from a new analysis published today by energy specialists Baringa entitled Cutting Carbon, Cutting Bills: Analysis of gas savings delivered by wind farms in 20225. The Baringa analysis found that without wind energy, Ireland would have had to spend an additional €1.65 billion on gas for power generation in 2022 and an extra €340 million on carbon credits to produce electricity by burning that gas. The savings were particularly significant on days with extremely high gas prices and large volumes of wind energy on the electricity system. On a single day – Tuesday 8 March – the combination of high winds and soaring gas prices delivered a total avoided cost of €43 million in just 24 hours. It is important to consider the views of those living near wind farms, but this must be measured against the needs of the wider population of the County, region and State when identifying the priorities for a new Monaghan County Development Plan. 1.4 Regional Contribution of Wind Farms Across Ireland, the onshore wind sector contributes €48 million to local authority tax take. This is a significant sum, supporting local employment, local services, and investments in communities. In some locations, they can represent more than 10% of a council’s commercial rates income6. 5 https://www.windenergyireland.com/images/Article_files/20230120_Cutting_Carbon_Cutting_Bills.pdf 6 https://windenergyireland.com/images/files/economic-impact-of-onshore-wind-in-ireland.pdf 7 INTRODUCTION Figure 4: Local Authority Rates from Wind Farms by County, Source WEI The sector also makes a vital contribution to Gross Value Add (GVA) on a regional level. This takes the form of spend on suppliers to maintain existing wind farms and turbines, and these suppliers’ induced spend in local shops and on local services. It is estimated that in 2020 estimated that total GVA from operational spend Nationally is €140 million. Currently, the Southern region makes the greatest contribution to national GVA (€83 million), following by the Northern and Western region (€50 million), and the Eastern and Midlands region (€7 million). Given Ireland’s relatively small land mass, the benefits of onshore wind are likely to flow between and across regions. Figure 5: Analysis Based on KPMG Impact Model 8 INTRODUCTION 1.5 International Context and Policy Drivers Beyond the climate emergency, the ongoing war in Ukraine has made even more pressing the need to develop Ireland’s indigenous energy generation resources to bring about predictability, self-reliance, and security of energy supply. The broad global, European, and national policy contexts have shifted towards a more rapid focus on the transition to renewables as states try to rebalance the over-reliance on Russian oil and gas supplies. As the key driver of decarbonisation within Ireland’s electricity sector, wind energy has an important role to play in this movement, presenting the potential to move Ireland into centre stage as a global leader of wind energy production. To that end, REPowerEU proposes new EU legislation7 that will, until climate neutrality is achieved, require that all member states institute a presumption that renewable developments are in the overriding public interest and serving public health and safety when balancing legal interests in individual cases.8 This would apply to the planning, construction, and operation of plants built to produce energy from renewable sources, and for their connection to the grid, related grid development, and storage assets. As national, regional and local planning policy will be governed by this change, it is important that variations to existing city and county development plans and new plans take account of this upcoming change and ensure it is accommodated in these vital local planning strategies. 7 To be introduced through the amendment of EU Directive (EU) 2018/2001 on the Promotion of Energy from Renewable Sources, Directive 2010/31/EU on the Energy Performance of Buildings and Directive 2012/27/EU on Energy Efficiency 8 For the purposes of Articles 6(4) and 16(1)(c) of Directive 92/43/EEC, Article 4(7) of Directive 2000/60/EC and Article 9(1)(a) of Directive 2009/147/ 9 POLICY AMBITION ON CLIMATE ACTION & RENEWABLE ELECTRICITY 2 Policy Ambition on Climate Action & Renewable Electricity The National Climate Action Plan 2023 (‘CAP’) set an ambitious 80% target for renewable electricity production by 2030. To meet this, we must double amount of electricity currently generated in Ireland from renewables. Figure 5 below, taken from the CAP 2023, illustrate Ireland’s current and projected renewable electricity production requirements to meet the 80% target. Based on the CAP assumptions, onshore wind will provide most of the required electricity yield out to 2030. Taking account of this, Monaghan County Council and all local authorities must be cautious when considering the designation of areas for renewable energy development, so as not to constrain any areas with renewable energy potential, particularly those potentially suited to wind generation. Figure 6: Ireland's electricity generation targets 2030 The CAP requires 4,600 MW of additional wind energy development over the next decade to reach the 2030 target of generating 80% of Ireland’s electricity through renewable sources. To put this in context, it took 20 years to install the existing 4,632 MW of wind energy and we must now more than double that in half the time. All local authorities have an important role to play in delivering on this lofty aim. WEI has, however, observed such calculations in draft and finalised CDPs from across the country, which suggests that this exercise is not only possible but is eminently achievable within the scope of the resources available to Irish local authorities. Though we do not suggest that such a task is easy as it requires substantial technical data and know- how to accurately gauge such development potential, WEI would be disappointed to see a similar approach being taken to the new draft CDP that is due to govern the strategic development of the county in the crucial years from 2025 to 2031 when many of the country’s initial climate targets fall due for realisation. We view it as well within the scope, expertise, and ability of Monaghan County Council to produce such calculations and would like to impress upon the local authority the importance of adhering to this responsibility as set out in national policy to ensure a clear headline target is set for wind energy development across the county. 10 CLIMATE CHANGE - FACILITATING WIND ENERGY DEVELOPMENT 3 Climate Change - Facilitating Wind Energy Development 3.1 Importance of Onshore Wind Energy Ireland currently boasts close to 4700 MW of installed onshore wind generation capacity (Wind Energy Ireland, 2023). Monaghan has an installed capacity of only 27.2 MW (0.6% of installed capacity in ROI) of onshore wind, lagging behind many other counties. WEI would ask Monaghan County council to consider deploying a wind energy strategy in their new CDP in 2025 to aid the county increase their share of onshore wind energy which will be crucial in the battle against climate change and meeting Irelands 2030 CAP targets. Monaghan has the opportunity under the new CDP for 2025 to implement a wind energy strategy, such as what Clare County council have done9 . By doing this Monaghan can create a clear strategic plan and a clear pathway to generate jobs and investment within the county that will be sustained for decades to come. Figure 7: County by County share of onshore wind energy as of 2022 To meet Ireland’s national target to reach net zero by 2050 and increase the amount of electricity produced from renewable sources to 80% by 2030, installed onshore wind capacity must double in the coming eight years. Though WEI’s members are currently engaged in the development of a range of ambitious and ground-breaking offshore wind energy projects that are set to produce a step-change in Ireland’s installed wind energy capacity, much of this is not set to be delivered until the latter years of the current decade and into the 2030s. This is owing 9 https://www.clarecoco.ie/services/planning/ccdp2017-2023/vol6/clare-county-development-plan-2017-2023-volume-6- clare-renewable-energy-strategy-2017-2023-24127.pdf 0.0 100.0 200.0 300.0 400.0 500.0 600.0 700.0 800.0 KerryCorkDonegalTipperaryGalwayMayoClareLimerickWexfordOffalyCavanRoscommonWicklowSligoLeitrimWaterfordKilkennyMonaghanLouthLaoisCarlowMeathDublinKildareLongfordWestmeathMWCounty ROI Installed Capacity (2022) 11 CLIMATE CHANGE - FACILITATING WIND ENERGY DEVELOPMENT to a range of factors, including the time and resources involved in developing projects of the scale and complexity seen in offshore wind energy. Other forms of renewable energy production can and must also contribute to our drive towards Ireland’s 2030 and 2050 goals, these include solar, biomass, and green hydrogen energy production. However, none of these energy sources can currently compete with the scale of renewable energy generation possible through responsible wind energy generation. This means that onshore wind is set to continue as the workhorse of Ireland’s renewable energy generation sector up to 2030 if not beyond. To reach our targets, not only do we need to maintain and find technological solutions to repower or extend existing onshore wind energy assets, but we must also identify suitable sites that will allow for sustainable, appropriate, and vital new onshore wind developments across the country. 12 REGIONAL APPROACH 4 Regional Approach WEI acknowledges that Monaghan County Council is only responsible for its own functional area and that the new CDP 2025 and Renewable Energy Strategy for the County will only extend as far as the Monaghan County boundary. Nevertheless, WEI would like to highlight to the local authority and its members where it is expected the new Renewable Energy Strategy will fit into a regional and national planning policy context in the future. The Renewable Electricity Spatial Policy Framework and roadmap for Regional Renewable Electricity Strategies are expected imminently. This will likely need to be incorporated into the CDP as it progresses. WEI has been advocating for a regional-approach to the spatial planning of wind farm developments for some time to complement the local authority-level approach that has been the case to-date. WEI previously prepared a Discussion Document (available upon request) on this specific topic, which outlines the benefits of a regional approach. In sum: • It fits within and neatly complements the Regional Spatial and Economic Strategies (RSES) now prepared for the three regions. (As the three RSES policy documents have now been formally adopted, spatial plans for renewable energy projects can be progressed as supplementary work streams by the Regional Assemblies and compliment the RSES). • A single, consistent methodology can be used across an entire region and across all three regions in the country, including across county and local authority boundary areas where approaches to-date have been inconsistent in many cases. • A regional approach would ensure that the optimum locations for wind energy development are identified, and every county’s potential is assessed in a regional and national context, in direct comparison with the rest of the region. • It would ensure that national targets, objectives, and requirements for the delivery of wind energy directly translate into the identification of suitable areas and corridors, and a sufficient quantum of land is identified and deemed appropriate to ensure national targets, objectives, and requirements can be delivered. • Landscape sensitivity, value and capacity can be assessed on a broader, regional scale, rather than just within the sometimes-limited confines of an individual county. This would provide consistent, evidence-based landscape policies across local authority areas, and ensure the appropriate landscape policies are implemented irrespective of the county boundaries. It would also ensure that wind and other electricity infrastructure projects that span or are visible across county boundaries, can be assessed in a consistent landscape policy context. • While the National Landscape Strategy will have to provide for all forms of development and types of land uses, the assessment of landscape sensitivity and capacity specifically for wind energy and electricity infrastructure is a much more defined work stream, that could be progressed in advance. Existing Local Authority landscape policies can be used to align landscape values across a region, to ensure existing local policy is fully considered when 13 REGIONAL APPROACH moving to a regional approach for the assessment of landscape sensitivity and capacity for wind energy and other electricity infrastructure. A regional approach to the spatial planning for wind energy was suggested by WEI as far back as March 2018 and is still considered vital if the transition to a low carbon economy in the coming years is to be achieved. WEI maintains it is essential to plan for this transition, based on the three Regional Assembly areas in addition to the 31 Local Authority areas as has been the case to-date. The regional approach would undoubtedly provide a more appropriate platform for ensuring national policy can be transposed effectively to local level, and ensure a consistent approach is used across the entire country that reflects government policy. In addition to the local authority-based approach to incorporating renewable strategies into their respective development plans, to compliment the Renewable Electricity Policy and Development Framework (REPDF) currently being prepared by the Department of Environment, Climate and Communications (DECC), WEI will continue to advocate for the accelerated preparation of Regional Renewable Energy Strategies and prioritisation by the three Regional Assemblies. Only the Regional Renewable Energy Strategies can ensure that a sufficient quantum of land within each region is identified as having wind energy potential sufficient to meet the national requirements. WEI recommends that Monaghan County Council adopt a regionally focused approach to developing the Draft Monaghan County Development Plan by consulting the CDPs produced by neighbouring counties and all relevant regional strategies and guidelines that might inform a coordinated and strategic approach to planning development. 14 CONCLUSION 5 Conclusion WEI would again like to thank Monaghan County Council for the opportunity to contribute to the discussion surrounding the development of a new CDP that will govern strategic development across the county during the crucial years leading up to the key 2030 climate milestone. We have great hope that the local authority will produce a thoughtful, forward-looking, and ambitious CDP that can help to guide Monaghan forward towards a world of decarbonisation where landscapes, natural habitats, and human endeavours can be brought into greater alignment and harmony than has ever been possible before in the modern world. As part of that, WEI hopes to see a considered and nuanced approach to the further development of the county’s policy framework for wind energy development to ensure the considerable potential for renewable assets within the county’s boundaries can be realised in line with the principles of proper and sustainable planning. WEI looks forward with anticipation to viewing the Draft Monaghan CDP 2025 – 2031 within the context of the second phase of the CDP development process and wishes all involved in crafting this key strategic planning document well with the considerable work that lies ahead. WEI Recommends: • That Monaghan County Council adopt a regionally focused approach to developing the Draft Monaghan County Development Plan by consulting the CDPs produced by neighbouring counties and all relevant regional strategies and guidelines that might inform a coordinated and strategic approach to planning development. • The full implementation of the Regional Renewable Electricity Spatial strategy – a key piece of national policy currently under construction - is of crucial importance.