Submission to Consultation Process on Marine Planning & Development Bill with reference to Offshore Renewal Energy, Marine Planning Regime and marine leisure.

I made a submission in early January but feel more is needed after the Consultation session in Arklow where I briefly made the following points:

Windfarms Visual impact. I represent the Greystones Municipal District and am concerned about the Visual Impact of proposed windfarms from the land. Particularily on large towns that face the sea and place significant emphasis on maintaining an attractive vista from promenades and piers such as Greystones & Bray. These towns have made significant investments in the seafronts and vistas. Also from coastal walks such as Bray Head and Kilcoole.

The Consenting process needs to explicitly consider the scale of the Visual Impact from the land versus the amount of carbon saved. It also needs to consider the combined visual impact of all seaward developments from these locations, not just the specific licence being applied for. This needs to be balanced against the National need for carbon free electricity and using the wind resources which we have.

The development of a large windfarm with a smaller visual effect, well out to sea, should take priority over a small one with a larger visual effect. There should be a limit to the visual effect permitted in such towns.

In 2005 the Codling windfarm obtained a windfarm licence for 220 turbines which are 15km from the coast at the nearest point, The plan had a 25 degree angle of view from Greystones and generated 1100 Mw, possibly the largest of any proposed in Ireland. There is talk of an extension to this which may produce a combined total of 2GW, over 50% of the national target of 3.5GW.

The Dublin Array application seems similar to the Kish/Bray bank one which was for 145 turbines the nearest within 9 Km of the coast producing about 600MW. The Visual Impact documents, which were on display in Garda stations, say it will have an angle of view of 62 degrees from Greystones. They describe the impact as ‘adverse moderate’ on Greystones and ‘adverse major’ on the view from the Cliff Walk. It must also have a significant impact on Bray. The visual impact of the combined schemes is described as ‘significant’ on Greystones.

The 25 degree angle of view is reasonable, the 62 degree is not, especially considering the combined effect which is probably 87 degrees. The consenting process should approve the large Codling one and refuse the much smaller Dublin array which has a very negative visual effect.

None of the Documents on the Planning & Consenting framework seem to mention the Visual Impact and it must be a factor. This should especially reference seaside towns with a large population.

Local areas which have this visual intrusion forced on them should also receive a benefit. An industrial facility such as a power station may negatively affect an area but benefits, such as jobs, rates and trade come to the area. The same should apply to windfarms.

The local Municipal District should formally input their views to the Consenting process in a similar way to that prescribed for Strategic Housing Developments applying to Bord Pleanala. This specifies that a formal input from the Municipal District should be sent in following a presentation on the project.

There should be a time limit on any permission. It is not satisfactory that permits remain valid after 15 years of no progress.

Consenting Process. The Consultation draft does not deal or mention some existing Marine Planning consent methods as regards Local Authorities which are relevant to near shore developments. A Local Authority, as a Planning Authority, can Compulsory Purchase the foreshore from the Department of Finance. If the development is above a certain scale the Council applies to Bord Pleanala. This, for example, is how Wicklow County Council built Greystones Harbour, probably the first harbour built on the open sea in Ireland since independence. The BP process confirmed CPOs on the foreshore, on the land, closed rights of way and granted planning permission for the harbour, community clubs, boatyards, marina, public slipways, public square, public park, landscaping, promenades, boardwalk, houses & apartments etc. in one combined process. It involved 2 Oral Hearings and a Further Information request to change the buildings substantially. This process should remain for such developments and serves as a model process for some aspects mentioned in the Draft strategy as there are procedures and time limits in the process. A great deal of technical information about wave heights, currents, visual effects, traffic etc. Was dealt with and informed the decision.

Marine Leisure.

Marine leisure for the local population needs to be encouraged. Facilities such as public slipways, walks, marinas, dredging, mooring, boat storage for boats, canoes etc. Need to be provided. Where the population is expanding these facilities need to be expanded in a similar way to sports pitches are provided on the land as a part of town planning. Much marine literature seems to prevent development, these types need to be encouraged. The 17.1 list of activities does not include public slipways & marinas. Some countries, such as the USA, have national policy of providing them and encouragement is needed here.

Marine leisure is useful for tourism and is the largest provider of jobs in the marine environment.


Derek Mitchell

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