Today, 16 January 2017, almost four years on from the first public call for submissions on the proposed revision of the 2006 wind energy guidelines, we are sharing information in relation to modelling undertaken by the RPS Group, in 2015, which was commissioned by the Sustainable Authority of Ireland (SEAI) for the then Department of Communications Energy and Natural Resources (now the Department of Communications, Climate Action and Environment) and the then Department of Environment, Community and Local Government (now the department of Housing, Planning, Community and Local Government).

RPS were commissioned to model Ireland’s land area and power generating potential from wind energy developments, taking into account a number of variable factors including:

• Turbine size, type and hub/tip height;
• Noise and shadow flicker;
• Proposed setback distances;
• Minimum wind speeds;
• Terrain contours; and
• Ground factors.

The background to this modelling was the proposed technical revision to the Wind Energy Development Guidelines 2006. As regular readers of this blog will be aware the proposed technical revision has turned into a political hot potato with no Minister yet willing to stand up to the wind industry, despite the Minister for Communications, Climate Action and Environment declaring that the current guidelines are ‘not fit for purpose’. The proposed Strategic Environmental Assessment (SEA) and further consultation have still not been commenced.

Nevertheless, the discussion in the RPS Group, Report on Wind Turbine Noise Modelling, of 11 May 2015 is startling for most communities, as RPS through consultations with the wind industry expect tip heights of between 150m to 175m to be the norm for future developments, with 200m tip heights being required for some low wind sites.  Possible setback distances emerging from the acoustic modelling are also quiet frightening (see copy of table 3.2 below).

Documents, in PDF, we are sharing are:

• rps-group-report-on-wind-turbine-noise-modeling-11-may-2015
• rps-group-draft-preliminary-report-on-wind-turbine-noise-modeling-19-march-2015
• Department of Environment, Community and Local Government, note-on-the-spatial-impact-of-the-revisions-to-the-wind-energy-guidelines-undated
• Department of Environment, Community and Local Government, meeting-note-on-setback-modelling-exercise-19-june-2015
• details-of-land-cover-classes-memo-29-apr-2015-and-the-model-calculation

Further iterations of the modeling then followed which were also released:

• Department of Communications Energy and Natural Resources (DCENR), iteration-1a-include-setback-from-properties-19-may-2015
• DCENR, iteration-2-45db-include-setback-from-properties-27-may-2015
• DCENR, iteration-3-5-june-2015
• DCENR, iteration-4-include-wind-energy-strategy-no-go-areas-12-june-2015
• DCENR, iteration-5-15-june-2015
• DCENR, iteration-6-see-memo-19-june-2015
• DCENR, iteration-7-13-june-2015.

Please note these documents were shared with us by a friend of this blog, who gained access to them under the Access to Environmental Information Regulations.  Access was only granted following a number of Appeals to the Commissioner for Environmental Information; with the Department of Housing, Planning, Community and Local Government, further delaying release for three months despite the Commissioners decision.  We are heartened that the Commissioner in deciding that these documents should be released stated:

In my opinion, it is at least possible that disclosure of the withheld information would help the public to scrutinise the reasons put forward by politicians in delaying this important policy decision.  I therefore accept that this public interest argument would favour disclosure now, before a decision is made.
…
… if disclosure were to lead to a submission being made to the Department which was of such import that it could not be ignored, such a submission would appear to be highly important and very much in the public interest. There is a strong public interest in making the decision [in relation to the revised guidelines] as soon as possible, but there is also a strong public interest in getting it right.
For these reasons I am not persuaded that disclosure would be contrary to the public interest. As that is my conclusion, I must find that refusal to provide access to the withheld information is not justified on this ground.

With the Commissioners words ringing in our ears we are calling on our readers and followers to review, scrutinise and find flaws in the reasons relied upon by your politicians and policy makers.

We are also welcoming guest blogs on this issue and if any of you out there want to provide some much needed technical analysis of these documents and to publish on this blog (or to make a valuable submission to the Minister), please e-mail us at: cawt.donegal@gmail.com.