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41. Greensource LtdMonaghan County Development Plan 2025-2031 - Pre-Draft Submission Form Deadline for submissions is Friday 7th July 2023 at 5p.m. Please read the Privacy Statement before completing this form. The Monaghan County Development Plan 2025-2031 must contain objecves and policies on a wide range of important topics. These topics are set out as headings below to assist in making a submission. A number of quesons are also posed under each of these topic headings to encourage you to think about these topics and to assist you with making suggesons on what the key issues facing County Monaghan over the future plan period are and how they can be addressed under the development plan. Please enter “N/A” in any of the comment boxes where you have no comments to make under a parcular topic. Please note, at this pre-draft stage, submissions relating to requests for zoning of land cannot be considered. It is recommended that you save your submission periodically as you enter data using the 'Save as Dra' opon at the boom of the form, especially if the submission is large or detailed. This will prevent your comments being lost in the event of a me-out or loss of connecon. Please note that submissions or observaons made to Monaghan County Council will be made available for public inspecon on the Council's website and may be redacted in line with GDPR and other legal requirements. Q1. Name of person/body submission is being made by, or on behalf of Name * Q2. Agent Details Are you an agent making a submission on behalf of the person/body stated above?* Please provide your name below * CONTACT INFORMATION * required field Greensource Ltd Yes No Susan Byrne Enter Full Address or Postcode Search SUBMISSION INFORMATION Below there are a list of quesons on a range of topics. These quesons should be considered as they may be helpful when draing your submission. Please note, this is not an exhausve list of topics. Space is provided below (at Q11) to insert comments relang to any other topics you consider important for consideraon in the Monaghan County Development Plan 2025-2031. Q4. Environmental Assessment and Monitoring Please provide your comments in the box below. Enter N/A if no comments.* Q5. Settlement Strategy Please provide your comments in the box below. Enter N/A if no comments.* Q6. Housing Strategy Please provide your comments in the box below. Enter N/A if no comments.* Q7. Climate Change, Environment and Heritage Please provide your comments in the box below. Enter N/A if no comments.* Q8. Economic Activity Please provide your comments in the box below. Enter N/A if no comments.* Q9. Infrastructure and Services Please provide your comments in the box below. Enter N/A if no comments.* Q10. Community Services/Facilities Please provide your comments in the box below. Enter N/A if no comments.* Max 2500 characters N/A Max 2500 characters N/A Max 2500 characters N/A Max 2500 characters N/A Max 2500 characters N/A Max 2500 characters N/A Max 2500 characters N/A Q11. Are there any other topics/comments you wish to make in relation to the Monaghan County Development Plan 2025-2031? Please provide your comments in the box below. Enter N/A if no comments.* Supporting documentation By clicking the 'Submit' button you give Monaghan County Council permission to analyse and include your response in any results generated from this information. After you click submit, you will no longer be able to go back and change any of your answers. If you are having technical difficulties uploading your submission please contact devplan@monaghancoco.ie for assistance. Once you have submitted this form there will be links available on the next page to either download this form or email yourself a copy of the form. Signature * Date * Max 2500 characters N/A Please upload any supporting documentation you wish to include with your submission. Greensource Monaghan Co Development Plan_Issues paper submission .pdf 423.88KB Max file size per document uploaded:- 5MBs DECLARATION 07/07/2023 Monaghan County Council Greensource submission to Review of Monaghan County Development Plan – July 2023 THIS PAGE IS INTENTIONALLY LEFT BLANK Development Plan submission July 2023 i ISSUE FORM Project number Document number Document revision A Document title Submission to Monaghan County Development Plan – July 2023 Document status Final Document prepared by Susan Byrne Document checked by David Mc Donnell Development Plan submission July 2023 ii Table of Contents 1 INTRODUCTION ...................................................................................................... 1 2 GREENSOURCE ENERGY – COMPANY BACKGROUND ............................................... 1 3 MONAGHAN COUNTY DEVELOPMENT PLAN REVIEW PROCESS ............................... 1 4 POLICY AND LEGISLATION ...................................................................................... 2 4.1 International ..................................................................................................................... 2 4.2 European .......................................................................................................................... 2 4.3 National ........................................................................................................................... 3 4.4 Regional ........................................................................................................................... 4 4.5 Local ................................................................................................................................. 4 4.5.1 Monaghan Renewable Energy Strategy .......................................................................................... 4 4.5.2 Monaghan County Development Plan ............................................................................................ 5 5 PROPOSED MONAGHAN COUNTY DEVELOPMENT PLAN 2025 – 2031 ...................... 6 6 OPPORTUNITIES FOR COUNTY MONAGHAN ........................................................... 6 7 DEVELOPMENT PLAN 0BJECTIVES AND POLICIES – PROPOSED ENHANCEMENTS ...... 8 8 CONCLUDING STATEMENT...................................................................................... 9 Development Plan submission July 2023 1 1 INTRODUCTION Monaghan County Council is commencing the preparation of the Monaghan County Development Plan 2025-2031. This will be the first County Development Plan prepared by Monaghan County Council, following the merger of North and South Monaghan County Council in 2014 and is an important blueprint for the development of Monaghan from a physical, economic, social, and environmental viewpoint. The process includes a review of the existing County Development Plans and will set out the overall strategy for the sustainable development of Monaghan for the period up to 2031. The development plan review process has a series of steps, and this submission is framed on the Strategic Issues Paper issued in May 2023. The Strategic Issues Paper is the first step in stimulating engagement on the upcoming revised County Development Plan 2025 - 2031. 2 GREENSOURCE ENERGY – COMPANY BACKGROUND Greensource is a wholly owned Irish renewable energy company based in Adare, County Limerick. The company has grown and diversified over the last twenty years, having significant expertise in the planning, construction and operation of renewable energy projects in Ireland and abroad. Since inception, the company has played a key role in the development of over 150 MW of renewable energy projects in Ireland, playing a significant role in further decarbonising the electricity market in this country. Greensource has developed a suite of renewable energy projects including wind and biogas, involving one of the first, state of the art farm-scale anaerobic digestion plants in Ireland, which has been operational since 2010. The GreenGas Anaerobic Digestion Plant processes manure and slurry as well as other imported feedstock to convert these materials into energy, adding 1MW of renewable electricity generation into the national grid. The GreenGas plant provided a roadmap for the development of farm scale anaerobic digestion plants in Ireland. Greensource believes a major focus is required on the benefit to communities in the vicinity of renewable energy projects. Greensource has a strong affiliation to community benefit from the projects developed, with neighbouring communities having benefitted by in excess of €100,000 to date from these projects. The involvement of local communities and the development of community renewable energy projects will be key in ensuring renewable electricity targets are achieved. The development of small scale (<5MW) community renewable energy projects in Monaghan, on both private and commercial lands will provide educational, economic and employment opportunities in local communities. The benefits of such an approach are already evident in Tipperary, with Ireland’s first community owned windfarm, Templederry Community Windfarm in operation. Greensource provided an advisory role in the development phase of this project and are therefore cognisant of the challenges and opportunities present for community renewable energy projects. 3 MONAGHAN COUNTY DEVELOPMENT PLAN REVIEW PROCESS The review of the Monaghan County Development Plan commenced in May 2023 with the issuing of the Strategic Issues Paper as part of the Pre-Draft Public Consultation Phase. This first stage in the Development Plan submission July 2023 2 process has a focus on seeking engagement on objectives and policies to deliver an overall strategy for the proper planning and sustainable development of the county. The county council is seeking submissions/observations that are strategic in nature and focus on ‘big picture’ issues. The Strategic Issues Paper identifies a number of themes for consideration, as follows:  Environmental Assessment and Monitoring  Settlement Strategy  Housing Strategy  Climate Change, Environment and Heritage  Economic Activity  Infrastructure and Services  Community Services and Facilities The ongoing development of renewable energy and green infrastructure touches on each of the themes outlined above. The following are some of the key issues that should be considered in the preparation of the first draft of the development plan in terms of Energy.  Sustainable development  Policies and objectives that tackle the onset of climate change  Sustaining business and economy, while protecting or enhancing our environment  Security of supply in terms of Energy  Sustaining rural Ireland population and providing local employment  Zoning of sufficient lands to facilitate the ongoing delivery of wind energy projects 4 POLICY AND LEGISLATION 4.1 INTERNATIONAL Agenda 2030 Sustainable Development Goals and The Paris Agreement on climate change require a transformational shift of our economies and societies towards climate resilient and sustainable development. In light of the issues of energy security and possible future resource constraints and the issue of global warming, the renewable energy sector looks set to play a bigger role in the economic and infrastructural future of our country. 4.2 EUROPEAN The Irish government supports the ambition within the European Union (The European Green Deal) to achieve a net zero target by 2050 and the pathway to 2030 which would be consistent with a net zero target by 2030. The European Green Deal provides an action plan to: • Boost the efficient use of resources by moving to a clean, circular economy • Restore biodiversity and cut pollution Development Plan submission July 2023 3 The plan outlines investments needed and financing tools available. It explains how to ensure a just and inclusive transition. The EU aims to be climate neutral in 2050. Reaching this target will require action by all sectors of our European country economies, including: • Investing in environmentally-friendly technologies • Supporting industry to innovate • Rolling out cleaner, cheaper and healthier forms of private and public transport • Decarbonising the energy sector • Ensuring buildings are more energy efficient • Working with international partners to improve global environmental standards The EU will also provide financial support and technical assistance to help those that are most affected by the move towards the green economy. This is called the Just Transition Mechanism. It will help mobilise at least €100 billion over the period 2021-2027 in the most affected regions. Ireland through its national policies and legislation along with regional and county development plans will provide a strong planning framework that will provide a pathway for investment and change. The new Monaghan County Development Plan should have the key mechanisms, policy or objectives that are aligned with the European Green Deal so we can maximise the benefit to society. 4.3 NATIONAL The Monaghan County Development Plan will be guided by the UN Sustainable Development Goals and will be consistent with the National Planning Framework ‘Project Ireland 2040’ and the Regional Spatial and Economic Strategy for the Northern and Western Region in areas such as climate action and clean energy. The transition to a low carbon electricity system, based on renewable energy generation and storage is a key pillar of Project Ireland 2040 – National Planning Framework. The requirement for energy security and climate action has led to increased focus on renewable energy generation in Ireland. In 2022 wind generation provided 34% of the electricity generated in Ireland, up from 32.5% in 2019 and 25% in 2017. It is well recognised that Ireland has excellent renewable energy resources, with technologies such as offshore wind, tidal etc. remaining vastly untapped. Other technologies such as solar have seen major developments, with numerous projects receiving successful grants of planning permission in Monaghan in recent years. It is envisaged that many of these developments will become operational over the lifetime of the new Monaghan County Development Plan. The predominant source of renewable energy production in Monaghan remains wind generation. In order to achieve climate action goals, the development of further renewable energy projects is required, along with the diversification of associated technologies. There is an obligation to increase reliance from 30% to 80%, (with peat and coal plants closing) across the country. The delivery of Irelands largest battery storage project in Lisdrum, near Monaghan Town is a positive step towards Irelands low carbon transition. The strategic location of Monaghan provides substantial opportunities for the further development of onshore renewable energy technologies in conjunction with the North- South Interconnector and battery storage at Lisdrum. Development Plan submission July 2023 4 Continued support of renewable energy technologies and associated infrastructure will be required as part of the proposed Monaghan County Development Plan 2025-2031 to ensure local and national needs are met. The Climate Action Plan 2023, issued by the Department of Communications, Climate Action & Environment recognises that Ireland must significantly step up its commitments to tackle climate disruption, with a local authority leadership role required to achieve decarbonisation goals. The Climate Action Plan 2023, sets out objectives in relation to renewable electricity: • Increase reliance on renewables from 30% to 80% setting targets of 9GW from onshore wind, 8GW from solar and at least 5GW from offshore wind by 2030, with some of this delivered by private contracts. • The Microgeneration Support Scheme will support micro-generation with a price for selling power to the grid. • The Community Energy Framework will open up opportunities for community participation in renewable generation by opening up new routes to market and will address barriers identified in grid connections. 4.4 REGIONAL The Regional Spatial and Economic Strategy for the Northern and Western Region has policies that relate directly to energy infrastructure and renewable energy. These are reproduced below. Regional Policy Objective 8.1: The Assembly support the development of a safe, secure and reliable electricity network and the transition towards a low carbon economy centred on energy efficiency and the growth projects outlined and described in this strategy. Regional Policy Objective 8.2: Support the reinforcement and strengthening of the electricity transmission network with particular reference to the regionally important projects. Regional Policy Objective 8.3: The Assembly support the necessary integration of the transmission network requirements to allow linkages with renewable energy proposals at all levels to the electricity transmission grid in a sustainable and timely manner. Regional Policy Objective 8.4: That reinforcements and new electricity transmission infrastructure are put in place and their provision is supported, to ensure the energy needs of future population and economic expansion within designated growth areas and across the region can be delivered in a sustainable and timely manner and that capacity is available at local and regional scale to meet future needs. Ensure that development minimises impacts on designated areas. 4.5 LOCAL 4.5.1 Monaghan Renewable Energy Strategy The current Monaghan County Development Plan (2019-2025) does not include a detailed wind energy strategy or outline distinct guidelines around the development wind energy. However, Section 9.15 states that “Monaghan County Council will seek to achieve a balance between enabling the wind Development Plan submission July 2023 5 energy resource of the County to be harnessed while taking account of the visual, environmental and amenity impacts to ensure consistency with proper planning and sustainable development. The Planning Authority will adopt a favourable approach to wind energy development provided they are sited so as not to cause a serious negative impact on the special character and appearance of the landscape, designated conservation areas, protected structures or sites of archaeological importance.” Greensource believe that a Renewable Energy Strategy for Co Monaghan will provide clarity and is important for the development of renewable energy where it guides and facilitates appropriate site selection. Furthermore, the development of wind energy infrastructure that implements an environmentally, socially and economically sensitive approach will benefit all. A Renewable Energy Strategy should identify areas which are deemed suitable or unsuitable for wind energy development, under the following categories: • strategic areas, • preferred areas, • areas open for consideration, and • no-go’ areas. As technologies have advanced, turbines have been developed which can yield the same energy from lower wind sites than their older counter parts. Greensource recommend the exclusion of wind resource data when developing and zoning areas for renewable energy development. Greensource also believe that grid constraints should not be considered by the local authority in the preparation of the County Development Plan as this is identified as a developer’s constraint. We ask that this is taken into consideration in the Monaghan County Development Plan 2025-2031. 4.5.2 Monaghan County Development Plan As set out in the Climate Action and Low Carbon Development (Amendment) Bill 2020, each local authority will be required to plan for climate action. This plan will specify the mitigation measures and the adaption measures to be adopted by the local authority, with regard to national frameworks and policies on climate change. Renewable energy strategies and the ongoing support of renewable energy projects within the local authority area will be key in achieving climate action and development of a low carbon economy. The transition and implementation of the development plan is interlinked with national and European policies such as the European Green Deal, which outlines a roadmap for making the European economy sustainable, turning climate and environmental challenges into opportunities. The implementation of the new Monaghan County Development Plan 2025-2031 has the potential to provide an opportunity for significant habitat restoration and enhancement, clean energy by providing opportunities for alternative, cleaner sources of energy, sustainable agriculture through landowner income associated with renewable energy developments and rural development as a result of community benefit funds associated with renewable energy developments. Development Plan submission July 2023 6 Continued support of renewable energy technologies and associated infrastructure will be required as part of the proposed Monaghan County Development Plan 2025-2031 to ensure local and national needs are met. In supporting the objectives of the Climate Action Plan 2023, acknowledgement must be given to the existing renewable energy developments in operation in County Monaghan and the requirement for the addition of further renewable energy developments and the technological diversification of such developments including bio-mass, wind power, small scale hydro power, anaerobic digestion, solar PV, hydrogen and other such technologies which may emerge over the period of this development plan. The contribution of small-scale renewables including domestic and agricultural is likely to grow. 5 PROPOSED MONAGHAN COUNTY DEVELOPMENT PLAN 2025 – 2031 Monaghan County Council has commenced the preparation of the Monaghan Development Plan 2025-2031 in publishing the Strategic Issues Paper for review and to encourage submissions and proposals from the public and interested parties. The preparation of the Monaghan County Development Plan is one of the most important functions of the council acting as the blueprint for the development of Monaghan from a physical, economic, social and environmental viewpoint. The process includes a review of the existing development plans and will set out the overall strategy for the proper planning and sustainable development of Monaghan as a whole over a six-year period up to 2031. The development of the new county development plan will be informed and guided by existing policy and legislation but will also build on the work completed in the previous plans. 6 OPPORTUNITIES FOR COUNTY MONAGHAN In developing a new Monaghan County Development Plan the future is being set out through policies, objectives and zoning. The process of reviewing the previous development plans and developing the fundamentals of the new plan will in itself identify challenges but also opportunities for the county. In terms of renewable energy, the challenges ahead are clear if we are to achieve our national targets and de-carbonise our economy. While we won’t achieve everything in the short term it is essential that there is a long-term plan with clear targets and a mechanism through the planning process to deliver projects. In developing the first draft of the proposed Monaghan County Development Plan 2025–2031 we request the Local Authority be mindful or consider the following potential gains that can be achieved with an integrated plan for renewable energy in the near future. The following are some of the main opportunities that will arise:  Increased generation of Green Energy in the county across all technologies.  Continued Investment in projects and in the local economy. Development Plan submission July 2023 7  Guaranteed income stream of €2 per megawatt hour from RESS projects that is ring fenced for communities.  Increased and continuous income from rates from wind farm projects providing a valuable income stream for the Local Authority – this can be used for projects and infrastructure that will ultimately benefit society.  Continued employment across a range of sectors including construction, planning, design, environment, grid and operational phase maintenance.  Sustainability – working towards a sustainable and balanced economy and way of life going forward that benefit from reduced fossil fuel consumption.  Improving the reliability of energy supply into the future with reliance on locally generated renewable energy while replacing fossil fuel dependency.  Reduced carbon emissions and improved air quality.  Ongoing upgrades to our national grid infrastructure to facilitate renewable energy generation.  Companies are seeking to use renewable energy for their business and will seek out opportunities or locations where there is a strong grid infrastructure and availability of reliable renewable generation.  Demand for power is increasing and in areas such as the development of data centres where significant load is required. This taken in the context of the closing of key electricity generation plants including Moneypoint and Edenderry, and the development of the North-South Interconnector, Monaghan is well placed to become as regional energy generator.  There is an opportunity in the Northern and Western Region of Ireland to grow based on our experience in delivery of renewable energy projects over the last 20 years and further provide jobs and employment in this niche sector. Skills and expertise which are in demand across Europe in renewable energy generation are well developed here but can be grown more. The items above are an overview and there are many indirect benefits that will not be apparent at this stage. The experience in countries like Denmark where the renewable energy sector is very well developed and moving almost completely away from fossil fuel use, is that the benefits to a county, its environment and people is very clear over time. Monaghan is in a strategic location to enable the decarbonisation of the gas network through the development of biogas infrastructure in the county and the resulting grid injection of renewable gas. Gas Networks Ireland have published Vision 2050 aiming to achieve a net zero carbon gas network by 2050. Gas Networks Ireland plans to inject 50% carbon neutral or zero carbon gases into the network, with renewable gas generated through the anaerobic digestion process key to achieving this. Therefore, significant support of anaerobic digestion facilities will be required and the associated gas network injection infrastructure. Development of the gas grid in Monaghan will be required to avail of the opportunities for the development of anaerobic digestion facilities to ensure renewable gas targets are achieved. The transition to a low carbon economy places emphasis on a move from petrol and diesel vehicles, towards EV and potentially biogas and hydrogen in the future. This transition places further emphasis and requirements on renewable energy generation to provide for these low carbon modes of transport. Bus networks, electric cars and bikes will be commonplace on the streets and roads of Monaghan during the County Development Plan 2025-2031, placing additional pressures on the electricity transmission and distribution systems, and the requirement for charging points for electric Development Plan submission July 2023 8 vehicles, and filling stations for biogas/hydrogen powered vehicles. Major road networks in Monaghan such as the N2 and N54 will provide refuelling/charging facilities for alternatively powered vehicles. This transition requires additional installation of renewable energy developments including wind, solar and biogas. The support of further renewable energy developments will lead to the establishment of a support system for biogas powered vehicles including buses etc. placing Monaghan to the fore of energy security and low carbon electricity and transport systems. It was planned that the Moneypoint electricity generation station and SSE’s oil-burning Tarbert unit will cease operation (closure date extended to 2025), leaving an energy short-fall of 1050MW. This represents an estimated one-fifth of the Irish Republics peak requirements. While the government has stated that no closures will take place until they are replaced with secure supply and secure renewables, this may take a considerable amount of time. Without significant investment and support of renewable energy projects in the region, energy security is a major concern, with a threat of limited supply imminent. This closure, coupled with the requirements the transition to electric vehicles will place on the electricity network, places further emphasis on the required support of renewable energy projects and associated grid connections in the country and specifically in the Monaghan County Development Plan 2025-2031 in this instance. The development of large-scale electricity users such as data centres which can have a requirement of in excess of 20MW, will place further constraints on the electricity network. The co-development of industries such as data centres and renewable energy projects will be required. In Ireland, we are in the process of change and transition and this journey will have many twists and turns. What is certain is that a robust Monaghan County Development Plan with an integrated approach on renewable energy and climate change is essential to bridging the implementation gap. 7 DEVELOPMENT PLAN 0BJECTIVES AND POLICIES – PROPOSED ENHANCEMENTS In preparing this submission the following were completed:  Review of the Monaghan County Development Plan 2025 - 2031 Strategic Issues Paper  Review of the Northern & Western Regional Spatial and Economic Strategy 2020 - 2032  Government of Ireland Climate Action Plan 2023  Monaghan County Council Climate Change Adaptation Strategy 2019 – 2024  County Monaghan Social Enterprise Strategy 2021 - 2025  Desk based constraints analysis  Mapping of grid infrastructure  Identification of potential areas that are suitable to provide additional renewable energy generation In preparation of the Monaghan County Development Plan 2025-2031, Greensource recommend the following:  Regional approach towards wind energy zoning taking changes to neighbouring county zoning patterns into account.  Exclusion of wind speeds as a criterion for developing and zoning areas for renewable energy development. Development Plan submission July 2023 9  Exclusion of grid constraints as a criterion for developing wind energy zoning.  Support for projects which may enter the repowering stage during the lifetime of the development plan.  Support of alternative renewable energy technologies including biogas, battery storage, hydrogen or other technologies which may become available over the duration of the development plan. We note from the Issues Paper that at this stage the focus is in identifying the “big ticket“ or fundamental items. Consequently, we have focused on what aspects could fundamentally change that would give a step change in the potential to generate significantly more renewable energy in the county. 8 CONCLUDING STATEMENT Greensource is one of the leading innovative energy companies in Ireland and has a clear focus on being one of the drivers for change in the transition to a low carbon economy. In order for that, companies like Greensource need clear pathways through planning and development as the typical timeline from identifying a potential site to the day it is energised can be between 3 and 5 years subject to factors like Judicial Review proceedings. In that regard the County Development Plan becomes a key instrument for industry to follow and be guided by as we move forward in time. Greensource have completed a strategic level analysis based on a constraints approach and have identified areas of land that can afford new renewable energy generation capacity for the county. Greensource look forward to engaging with the forward planning unit in Monaghan County Council over the coming months and will bring their knowledge and expertise to the discussion where appropriate.