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33. Energia Energia Response to Monaghan County Council County Development Plan 2019-2025 and Preparation of the Monaghan County Development Plan 2025-2031 Strategic Issues & Options Paper July 2023 CDP - Strategic Issues & Options Paper July 2023 2 1 Introduction Energia Group is a leading integrated and innovative energy company with substantial businesses in both Ireland (Republic of Ireland (ROI) and Northern Ireland (NI)) and is committed to playing a key role in the decarbonisation of the energy system across the island of Ireland. Energia operates through three businesses: Renewables; Flexible Generation; and Customer Solutions. Energia has a substantial and growing portfolio of renewable generation capacity throughout Ireland and has extensive experience in the design, construction, and operation of renewable energy developments. Presently Energia has 15 operational windfarms across the Island of Ireland with operational capacity of 309MW. In 2021, Energia generated over 6TWh of electricity, with over 50% from renewable sources1. In 2021 we had over 1,200MW of renewable electricity under long-term contracts. The Company has 321MW of wind and solar projects in development, and 50MW of battery storage. We are committed to making a positive impact in the communities in which we operate and have a Windfarm Community Benefit Scheme providing more than €750,000 per annum through our 8 windfarm funds, sponsorships, and Local Electricity Discount Schemes in FY23. Energia has a Positive Energy Programme which, launched in 2019, set out an investment of €3 billion focussed on a range of major renewable energy projects. Ongoing projects include onshore and offshore wind, solar, battery storage and green hydrogen, and it is anticipated this programme can add circa 1.5 Gigawatts of additional renewable capacity to the system by 2030 to facilitate the achievement of Government targets and keep momentum towards the overall objective of Net Zero. Presently in the County, Energia developments comprise Drumlins Park Wind farm and Coolberrin Wind farm. Energia are developing Drumlins Park, an 8 turbine wind farm near Newbliss. Construction commenced in 2022 and remains on going with expected commercial operation later in the Autumn of 2023. The wind farm will generate up to 49MW of renewable energy, enough to meet the annual electricity needs of around 34,000 households. The development will give rise to a range of benefits, including up to 100 temporary construction jobs. It will also create permanent operation and maintenance roles, as well as ancillary functions. The development will have a 30-year operational life from the date of commissioning. The Coolberrin Wind Farm site is located near Emyvale, in the townlands of Greagh, Dernadariff, Cornahieve, Aghamackalinn, Luppan, Derryrellan, Cavan (Moutray) and Drumbirn. This 21MW wind farm development has been granted planning consent for seven turbines with a maximum tip height of 119m. 1 Energia Group Responsible Business Report 2021 CDP - Strategic Issues & Options Paper July 2023 3 2 Strategic Issues & Options Paper review and comment Energia submits the following observations for the Council’s consideration which may inform the preparation of the Draft County Development Plan. Climate change is one of the biggest challenges of our times. The energy system will need to undergo profound and unprecedented change during this decade to ensure commitments on climate action are achieved and there is now less than 7 years to deliver Ireland’s 2030 targets. Electrification will play a central role in decarbonising the energy system, with renewable electricity playing an increasing role in our power system and in the provision of heat and transport. Planning policy and the development consenting regime is key to delivering the renewable technologies required to ensure Ireland meets its targets for 80% renewable electricity by 2030. Climate Change, Environment and Heritage ‘Climate change is recognised as the significant challenge of our time, and will do so into the future. Responding to this challenge requires a dual approach of both mitigation (tackling the cause) and adaptation measures (reducing the impacts and building adaptive capacity and resilience). The National Planning framework confirms that the planning process provides an established means through which to implement and integrate climate change objectives, including adaptation, at local level and the transition to a Low Carbon and Climate Resilient Society. Addressing the challenges of climate change will require continued policy development at both national and local levels.’ Should there be more favourable policies and objectives on renewable energy development? Response: The Draft Monaghan County Development Plan 2025-2031 should be shaped by progressive policies and objectives to ensure Monaghan’s delivery of the national climate change and renewable energy targets which are intended to decarbonise the Irish economy in line with the National Planning Framework and Climate Action Plan 2023. The Council must be confident its policies and objectives of the Draft County Development Plan, will be able to deliver on those national targets and importantly align with them. Renewable electricity plays a crucial role in Ireland’s efforts to combat climate change. Under the CAP23 Government has set a target of having an 80% share of electricity generation capacity coming from renewable sources by 2030 to create a more sustainable and resilient energy system for the future. As part of the overall target of having 80% of Ireland’s electricity being met from renewable sources by 2030, CAP23 sets out that Ireland is targeting 9 GW of onshore wind and 8 GW of solar electricity generation capacity, as well as delivery of required long-term storage and major acceleration to the overall flexibility of the electricity system. Wind energy has been the primary driver, through substantial investments in onshore and offshore wind farms. Ireland has abundant wind resources and is one of the CDP - Strategic Issues & Options Paper July 2023 4 leading countries in wind energy per capita. Current provisions across Monaghan County can be viewed at the SEAI Wind mapping system. Wind Mapping System (seai.ie) Solar also plays an important role in Ireland’s efforts to transition towards a more sustainable and decarbonized energy system. It is recognised that in making the development plan, the elected members are restricted by the Planning and Development Acts 2000 to 2021 to consider the proper planning and sustainable development of the area to which the development plan relates, the statutory obligations of the local authority in the area and any relevant policies or objectives of the Government or any Minister of the Government. We note that the statutory obligations of the Council include the obligation to ensure that the development plan is consistent with: (a) the national and regional development objectives specified in (i) the National Planning Framework, and (ii) the regional spatial and economic strategy, and (b) specific planning policy requirements specified in guidelines under 28(1) of the Planning Acts. We further note that the Interim Guidelines for Planning Authorities on Statutory Plans, Renewable Energy and Climate Change provide that it is a specific planning policy requirement under Section 28(1C) of the Planning Acts that, in making a development plan, with policies or objectives that relate to wind energy developments, Council is obliged to carry out the following: “(1) Ensure that overall national policy on renewable energy as contained in documents such as the Government’s ‘White Paper on Energy Policy - Ireland’s Transition to a Low Carbon Future’, as well as the ‘National Renewable Energy Action Plan’, the ‘Strategy for Renewable Energy’ and the ‘National Mitigation Plan’, is acknowledged and documented in the relevant development plan; (2) Indicate how the implementation of the relevant development plan … over its effective period will contribute to realising overall national targets on renewable energy and climate change mitigation, and in particular wind energy production and the potential wind energy resource (in megawatts); and (3) Demonstrate detailed compliance with item number (2) above in any proposal by them to introduce or vary a mandatory setback distance or distances for wind turbines from specified land uses or classes of land use into their development plan or local area plan. Such a proposal shall be subject to environmental assessment requirements, for example under the SEA and Habitats Directives. It shall also be a material consideration in SEA, when taking into account likely significant effects on climatic factors, in addition to other factors such as landscape and air, if a mandatory setback or variation to a mandatory setback proposed by a planning authority in a development plan or local area plan would create a significant limitation or constraint on renewable energy projects, including wind turbines, within the administrative area of the plan.” Energia acknowledges that the availability of a safe, secure and reliable supply of electricity is an essential requirement for Ireland’s current and future economic wellbeing. The greening of energy generation via the transition from conventional fossil fuel power generation to sustainable forms of renewable energy supply such as wind and solar power is an essential development if Ireland is to meet its obligations to cut CDP - Strategic Issues & Options Paper July 2023 5 greenhouse gas emissions as we move towards a zero carbon economy and Energia fully supports Government policy in this regard. Recommendation: • Ensure that Climate Change is a key consideration in the preparation of all policy in the Draft CDP. • To ensure the policies and objectives in the Draft CDP fully reflect, and are compatible with international, national, and regional climate change policy. • To ensure adherence with national planning policy, Monaghan County Council should prepare a Renewable Energy Strategy. Infrastructure and Services ‘The supply of energy throughout the County is an important factor in the provision and location of development. Monaghan County Council will continue to work alongside key energy providers in the provision of electricity and gas, where feasible. Provision will be made within the development plan for wind energy and other renewable energy sources.’ Response: We would encourage Monaghan County Council to recognise the importance of a diverse and innovative renewable energy supply to allow Ireland to meet its energy needs. As well as the traditional wind and solar renewable energy provisions, emerging technologies will play an important role in supporting Climate Action Plan deliverables. Consideration should be given to flexibility within policy to accommodate the development of e.g. Battery Energy Storage Schemes, synchronous condensers, and other not yet known supporting technologies. In FY23, Energia’s 15 onshore windfarms generated 695 GWh of renewable electricity and a further 11.9% of all available generation from these sites was lost due to system constraints and curtailment. The generation lost to constraints and curtailment is the equivalent to all of the output from a 31 MW onshore windfarm and would generate enough renewable electricity to power over 22,000 homes for one year. The primary reason for these losses was in inability of the local grid to transfer the power from the windfarm (constraints). It is clear that achieving the relevant renewable and decarbonisation targets will require significant grid investment, including both new substations in addition to overhead power lines, and other related reinforcements. Repowering windfarms will become a core component in the achievement of Ireland’s energy transition targets. When deciding to repower a windfarm, a range of factors are considered such as the regulatory framework, planning restrictions, the availability of grid capacity and the investment required. Recommendation: • Promote the provision of renewable energy across the County. CDP - Strategic Issues & Options Paper July 2023 6 • Integrate policies and objectives within the Plan that recognise, promote and facilitate onshore wind developments which ensure that the renewable energy potential of the county is maximised to achieve the most recent national targets. • Provide for the harnessing solar energy in meeting our renewable energy targets, and the need to develop renewable energy to secure energy supply and combat climate change. • Ensure provision for emerging technologies are accommodated. • That the Draft CDP includes a policy to favourably consider the repowering and extension of existing windfarm developments where equipment is upgraded to the best available technology subject to development management standards and environmental considerations. Conclusions The preparation of a new County Development Plan for Monaghan is an opportunity to consider the role it can play in supporting and delivering overarching national goals. We trust that the matters outlined in this submission will be fully taken into consideration in making the Monaghan County Development Plan 2025 - 2031.